United States Office of Enforcement and EPA 305-R-07-001 

Environmental Protection Compliance Assurance March 2007 

Agency 

Guide for Addressing 

Environmental Problems: 

Using an Integrated Strategic Approach 
Disclaimer 

The Guide for Addressing Environmental Problems: Using an Integrated Strategic 

Approach was created primarily for employees of the United States Environmental 

Protection Agency (EPA) and state, tribal and local environmental regulatory agencies, 

and secondarily for stakeholders interested in partnering or collaborating with regulatory 

agencies in the implementation of a strategy. This Guide is intended to explain a 

strategic approach and its use in addressing environmental problems. It includes federal 

and state case examples, hypothetical examples, suggestions and illustrations on how to 

plan for each element in the strategic approach. The strategic approach and the 

supporting information are viewed as a planning tool only and do not constitute EPA 

rulemaking, policy or guidance. Thus, this Guide may not be relied on to create any 

rights, substantive or procedural, enforceable by any party in litigation with the United 

States. EPA may take action at variance with the Guide and its internal procedures. 

Download this document from: 

www.epa.gov/compliance/resources/policies/assistance/strategicguide.pdf 

Guide for Addressing Environmental Problems 1 
Introduction 

Contents 

Element 1: Developing a Statement of the Environmental Problem and Justification for 

Its Selection ....................................................................................................... 1-1
 

Element 2: Establishing Goals and Measures ................................................... 2-1
 

Element 3: Selecting, Sequencing and Segmenting Tools ................................ 3-1
 

Element 4: Establishing Roles and Assigning Responsibilities.......................... 4-1
 

Element 5: Developing an Implementation Plan, Schedule and Milestones...... 5-1
 

Element 6: Designating Resources/ Workforce Deployment ............................. 6-1
 

Element 7: Communicating the Strategy .......................................................... 7-1
 

Element 8: Monitoring and Evaluating the Strategy........................................... 8-1
 

Element 9: Exiting the Strategy.......................................................................... 9-1
 

Attachments 

A. Framework for a Problem-based Approach to Integrated Strategies 

B. Contacts for the EPA Regions 2002-2004 Integrated Strategy Pilot Projects 

C. Template for Developing a Performance-based Strategy for National Compliance 

and Enforcement Priorities 

D. EPA Region 2 Healthcare Compliance Initiative 

E. Enforcement Alert on Sanitary Sewer Overflows, March 2003 

F. Evaluation of OECA “Framework for a Problem-based Approach to Integrated 

Strategies” and “Guide to Implementing the Integrated Strategies Framework” 

Guide for Addressing Environmental Problems 2 
Introduction 

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Guide for Addressing Environmental Problems 3 
Introduction 

Guide for Addressing 

Environmental Problems: 

Using an Integrated Strategic Approach 

Introduction 

The U.S. Environmental Protection Agency (EPA) and state and local 

environmental agencies have several tools available to address 

environmental problems. This Guide will focus on the compliance 

assistance, incentives, monitoring, enforcement and other tools that 

have been used in different forms and combinations over many years. 

Each iteration of using these tools has demonstrated EPA’s evolved 

thinking and experience about how to most efficiently and effectively 

solve environmental and compliance problems. The result is EPA’s 

strategic approach for achieving improved compliance and better 

protecting human health and the environment. The term “strategic 

approach” is used throughout this Guide to capture the critical elements 

that EPA has identified for developing and implementing its strategies 

for resolving identified environmental problems. 

Purpose 

This Guide is specifically intended to: 

▪	 Explain in detail the concept of the strategic approach and its use in 

addressing environmental problems and improving performance 

▪	 Elaborate on and provide examples to illustrate the key elements 

that should be considered in planning, implementing and measuring 

the effectiveness of the approach 

▪	 Promote consistency in planning and implementing the approach 

▪	 Encourage knowledge transfer using lessons learned from federal 

and state case studies 

•	 Provide documentation of the decision-making and planning 

process from the case studies to assist practitioners in future strategic planning. 

Key Concepts 

The strategic approach: 

▪ Promotes better 

characterization and 

prioritization of 

environmental problems 

▪ Defines up-front what 

success will look like 

▪ Provides flexibility and is 

designed to be iterative and 

allow concurrent 

consideration of elements 

▪ Promotes transparency in 

and documentation of 

decision-making 

▪ Advocates up-front 

consideration, but not 

necessarily use, of all 

available compliance and 

enforcement tools 

▪ Recognizes the importance 

of effective communication, 

coordination and 

collaboration throughout 

the process 

▪ Encourages leveraging of 

resources and optimization 

of workforce deployment. 

Guide for Addressing Environmental Problems 4 
Introduction 

Audience 

The primary audience for this Guide includes managers and staff from EPA as well 

as state, tribal and local environmental regulatory agencies. Secondary audiences for 

this Guide include stakeholders, such as industry and trade associations, communitybased groups, assistance providers and affected communities, interested in partnering 

or collaborating with regulatory agencies in the implementation of the approach. 

These audiences can benefit from adopting or participating in the strategic approach. 

Some of the significant benefits the approach offers include: 

▪	 Increased communication between managers and staff and across different 

offices, resulting in the generation of new ideas to address environmental 

problems 

▪	 More sharing of knowledge and lessons learned, resulting in less time spent 

“reinventing the wheel” 

▪	 Enhanced efficiency and effectiveness of human capital as a result of better 

understanding of the roles and responsibilities of the various participants in the 

strategy 

•	 More measurable results and better accounting of resources used to achieve those 

results, which can in turn help establish benchmarks for future resource allocation. 

Background 

In 2002 an internal EPA advisory group, the Compliance Assistance and Policy 

Infrastructure Steering Committee (CAPI), developed the Framework for a Problembased Approach to Integrated Strategies (the Framework; see Attachment A). The 

Framework, which was endorsed and issued by EPA, provides a model for strategically 

and systematically addressing environmental problems and, for the first time, explicitly 

requires up-front consideration of compliance assistance as a tool, development of goals 

and measures, and documentation of the decision-making process. The Framework 

includes nine elements that guide the user through the planning process: (1) establishing 

the environmental problem; (2) justifying selection of the problem as a priority; 

(3) identifying anticipated performance measures; (4) selecting appropriate tools to 

address the problem; (5) identifying resource needs; (6) developing a schedule to 

implement the strategy; (7) establishing partners’ and stakeholders’ roles and 

responsibilities; (8) developing a communication plan for all interested parties; and 

(9) monitoring and evaluating the progress of the strategy. 

The Office of Enforcement and Compliance Assurance (OECA) tested the elements of 

the Framework by funding ten pilot projects across eight EPA Regions. See Attachment 

B for a list of the pilots and contacts. The pilots focused on an array of environmental 

problems (e.g., hazardous waste and solid waste management and disposal, stormwater 

runoff, groundwater and drinking water contamination) in several sectors, including 

schools, colleges and universities, healthcare facilities, auto salvage and construction. 

Between 2002 and 2004, EPA headquarters solicited participating EPA Regions and 

states to share their experiences in applying the Framework elements to their planning 

process and the impact it had on addressing the environmental problem(s). This 

Guide for Addressing Environmental Problems 5 
Introduction 

information was shared through quarterly conference calls, six-month summary reports 

and a final case study for each pilot. 

Pilot project participants provided EPA’s Planning Council with lessons learned on 

application of the Framework elements and recommendations for future planning of 

strategies. The Planning Council, comprised of EPA headquarters and regional 

managers, evaluates OECA’s planning and priority-setting process for selecting and 

addressing its national priorities. As a result of the Council’s evaluation of the existing 

planning process and with input from the pilots, OECA developed the Template for 

Developing a Performance-based Strategy for National Compliance and Enforcement 

Priorities (Template) to strategically plan for and address OECA’s FY 2005-2007 

national priorities. The Template uses a similar planning process, covering the same 

basic elements as the Framework, but condensed into six elements: (1) defining the 

environmental problem; (2) establishing goals and measures; (3) developing the 

strategy, including tool selection, environmental justice, internal and external 

communication, monitoring and evaluation, and roles and responsibilities; 

(4) determining when to exit the strategy; (5) defining workforce deployment and 

resources; and (6) establishing a schedule. See Attachment C for the Template. 

While implementation of the national priorities is ongoing, the authors of this Guide 

interviewed some of the EPA managers and staff who developed certain of the 

strategies addressing OECA’s national priorities to inquire about the application of the 

Template elements to their planning process. In this Guide, we have incorporated the 

experiences from testing the Framework through the Regional and state pilots, from 

developing strategies using the Template, and from developing other Regional and state 

strategies. These experiences highlight real-life cases and the challenges and 

opportunities of planning and implementing the strategic approach. 

Layout of the Guide 

The Guide is structured around nine elements, combining the elements of the 

Framework and the Template that are needed to plan for and implement the strategic 

approach. The elements are: 

Element 1 - Developing a Statement of the Environmental Problem and Justification for 

its Selection 

Element 2 - Establishing Goals and Measures 

Element 3 - Selecting, Sequencing and Segmenting Tools 

Element 4 - Establishing Roles and Assigning Responsibilities 

Element 5 - Developing an Implementation Plan, Schedule and Milestones 

Element 6 - Designating Resources/Workforce Deployment 

Element 7 - Communicating the Strategy 

Element 8 - Monitoring and Evaluating the Strategy 

Element 9 - Exiting the Strategy 

Guide for Addressing Environmental Problems 6 
Introduction 

For each element, we describe its purpose, key 

concepts, general approach, a step-by-step 

process for implementation, and key challenges 

and opportunities. Most importantly, each 

element highlights examples and lessons learned 

from the pilot project case studies and the 

development of the strategies implementing 

OECA’s national environmental priorities. To the 

extent possible, we also provide you with 

suggestions on how to overcome barriers in 

planning and factors to consider when looking at 

each element’s relationship to other elements in 

the strategic approach. The accompanying 

diagram of a wheel depicts all the elements of the 

strategic approach and illustrates the continuous 

motion of the planning process. This wheel will be 

used throughout the Guide and is intended to 

focus you on the element that is being addressed 

while highlighting the other elements that need to 

be considered in connection with it to ensure a For each chapter the element being addressed 

will be shown in white, and the highlighted well-thought-out and comprehensive strategy. elements will be shown in light gray. 

The Guide also includes one case study to summarize 

all of the elements of the strategic approach (Attachment D). The case study and other 

examples cited in each chapter give regulatory managers and staff an opportunity to 

learn from colleagues about tips for effective planning and suggestions on creative and 

efficient resource allocation that will yield positive results. There is no single way to 

address an environmental problem; multiple approaches and strategies may be 

equally valid and appropriate. We hope, however, through the documentation of these 

examples and case studies to begin to demonstrate when particular situations can be 

most effectively addressed through the strategic approach. The emphasis here is on the 

decision-making process and evaluating the range of possible approaches, even if only 

one approach is ultimately selected. 

Key Lessons Learned in Planning for and 

Implementing the Strategic Approach 

Below are some of the key lessons learned from both the pilots and the national 

priorities While these suggestions may be discussed in more detail under the relevant 

element, we are also sharing here a few of the more important ones to have a 

successful strategy. 

▪	 Designate one or two senior managers for each strategy who are responsible for 

ensuring that resources are committed up-front and the strategy is coordinated and 

managed across the appropriate offices and Regions. 

▪	 Ensure that sufficient time and resources are allocated to adequately characterize 

the problem, understand the audience and select tools. The Agency should consider 

giving some form of “credit” during the planning phase to recognize the level of effort 

required to fully scope out the environmental problem and to address unique 

circumstances in each Region. 

Guide for Addressing Environmental Problems 7 
Introduction 

▪	 Maintain regular coordination and communication across relevant EPA and 

state offices and with external partners to manage information and resources. 

Pilot participants reported that they found the monthly or quarterly calls and 

reports useful in sharing approaches/techniques to addressing the elements 

and in providing insight into the decision-making process. 

Guide for Addressing Environmental Problems 8 
Introduction 

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Guide for Addressing Environmental Problems 9 
Element 1: Developing a Statement 

of the Environmental Problem and 

Justification for Its Selection 

Objectives Key Concepts 

▪	 Introduce techniques and information sources that can help you 

locate and define an environmental problem. 

▪	 Provide an example of one step-by-step process for defining 

environmental problems and selecting problems to work on. 

•	 Identify key challenges and opportunities in defining environmental 

problems and selecting problems to work on. 

Purpose 

This element of the strategic approach focuses on locating the most 

complete and accurate information on the environmental problem, 

putting it into a usable format for decision makers, and explaining why 

this problem has been selected for action over other environmental 

problems. This element corresponds to Elements 1 and 2 of the 

Framework, “Statement of Environmental Problem” and “Justification for 

Selecting This Problem Over Others,” and Element 1 of the Template, “Problem 

Statement.” 

▪ Baseline Information: 

All key information 

related to the: a) health 

and environmental 

impacts; b) potential 

risks; and c) root and 

contributory causes of an 

environmental problem 

before an intervention. 

▪ Compliance Baseline: 

In the context of 

compliance with 

environmental 

regulations, it means 

making a preliminary 

assessment of a sector’s, 

facility’s or entity’s 

compliance status 

before an intervention. 

Approach 

For several years, EPA has been soliciting both internal staff and external stakeholders 

(states, tribes, non-governmental organizations, trade associations, etc.) to nominate 

environmental problems that are candidates for EPA’s attention. EPA then periodically 

reviews these candidate problems, analyzes available data on the problem and its 

potential impact on human health and the environment, and seeks out additional 

information to better characterize the nature of the problem and its relative priority for an 

EPA response at the national or regional level. For a well-thought-out selection of 

environmental problems, EPA managers should consider: 

▪	 Soliciting nominations of potential problems for EPA response from a broad array of 

interested parties. 

▪	 Reviewing and updating the results of any previous examinations of the candidate 

problem. 

▪	 Determining how EPA’s authorities complement or conflict with those of other 

federal, state or local governmental agencies. 

Guide for Addressing Environmental Problems 1-1 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

•	 Setting aside resources to purchase external 

publicly-available industry data, if needed. 

As you consider what data will best define a problem 

and subsequently, if warranted, justify action, heed 

the words of Harvard University professor Malcolm 

Sparrow: “pick important problems and fix them.” Do 

not get bogged down pursuing absolutely thorough or 

perfect information, as it probably does not exist. 

Explore available information sources that are the 

most informative; then look for indicators that will 

help you narrow your research. Look for alternative 

information sources. Acknowledge that you may 

make false starts while looking for especially serious 

unaddressed problems. Be flexible and ready to 

adjust at mid-course as your analysis and 

assumptions are confirmed or repudiated by new 

information. 

Keep in mind that environmental problems can be 

defined in many forms, such as by industry sector, 

chemical, process unit, geographic area or medium 

(i.e., air, water, land disposal, etc). Define the 

problem by whichever form makes the most sense 

and will allow an efficient response. For example, 

EPA’s Office of Enforcement and Compliance 

Assurance (OECA) often includes violations of 

enforceable regulations in its definition of the 

problem. It is important to ensure that the solutions 

pursued in addressing the problem do not transfer 

pollutants from one medium to another or cause a 

noncompliance problem under another statute. 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategies, we provide the following considerations for 

defining environmental problems and justifying your 

selection of problems to work on: 

▪ Do not expect to find flawless data on the 

universe of pollutant sources (e.g.,all 

manufacturing processes that use a particular 

chemical). However, many information sources 

will cover, at least partially, your area of concern. 

▪ Pay attention to government data systems but 

conduct a thorough search for other information to 

help you understand how much of the pollutant 

source universe is known and regulated. 

▪ Be ready to adjust your assumptions and shift 

direction as you refine your data and obtain 

feedback from field personnel (e.g., inspectors). 

▪ As your research progresses, focus on narrower 

areas that pose the greatest risk and that can be 

effectively addressed with available resources 

(i.e., agency personnel and contract dollars). 

▪ Document the range of problems reviewed and 

why a particular problem was selected to be 

addressed. Documentation is important to 

demonstrate good management of resources, as 

required under the Government Performance and 

Results Act (GPRA). 

▪ If applicable, point out ways that addressing the 

problem could satisfy other goals at the national, 

EPA Region or state level. 

▪ Consider the timing of EPA and state priority 

selection processes. 

Examples of well-defined environmental problems: 

▪	 Human health and environmental impact of smog. Air monitoring is conducted by 

states and EPA, and the ozone non-attainment status of cities and counties is 

announced. Health impacts are clear (e.g., lung damage, eye irritation, damage to 

plants). The cause and sources of the pollutants are well understood (VOCs, NOx 

and SO2, heat and sunlight). Environmental regulations and permitting systems are 

in place to address the problem. 

•	 Child Lead Poisoning. Tests are available to measure blood lead 

levels, and some state/city health agencies and the Centers for 

Disease Control actively monitor blood lead levels. Lead poisoning 

impacts on children are well understood (neurological damage). 

Sources of lead are also well understood (paint, lead solder water pipes, leaded 

gasoline). Regulations are in place to address the problem. 

“Pick important problems and fix 

them.” 

—Malcolm Sparrow 

Guide for Addressing Environmental Problems 1-2 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

Example of a poorly defined environmental problem: 

•	 Nanotechnology. Nanotechnology is engineering at the atomic or molecular level of 

functional systems such as electronic circuits, drug delivery, and fabric protection. 

There is little information currently available on the potential impacts of this 

technology to human health and the environment. Where data does exist, there is no 

clear consensus on its meaning. Few, if any, regulations are in place to control nano 

particles. These factors make it difficult to characterize whether a health or 

environmental problem exists as a result of nanotechnology and as such, it would not 

lend itself to being addressed by the strategic approach. 

Clearly justify why the environmental problem you are working to solve is important so 

that you can justify why resources are being dedicated to it at the expense of competing 

problems. The more substantiating information (e.g., inspector reports, inspection 

violation data, national reports, chemical Material Safety Data Sheets, national priority 

chemical initiatives) you can bring to bear, the more easily you will be able to deflect 

criticism; build support for the compliance activity; and potentially tie it to other national, 

EPA Region, and state environmental goals and priorities. 

In some instances, if a problem is obvious, it may not be necessary to 

expend resources on thoroughly analyzing and documenting why the 

problem is serious and why it should be addressed. One example of an 

obvious problem might be a state or EPA Region in a watershed with 

many concentrated animal feeding operations and few other industries 

that suffers from poor water quality due to high nutrient run-off and 

strong odor, high numbers of violations and citizen complaints about 

odor, and water body eutrophication. 

Finally, because choosing a particular problem raises its profile and involves the building 

of transferable expertise, familiarization of national managers with the problem, and use 

of resources, it can pave the way for further activity as a regional or national priority. This 

is further reason why clear justification is warranted. 

The following factors can play a role in identifying a problem and justifying selection or 

both. 

▪	 Baseline of compliance information: Seek to define the problem in a way that will 

allow you to measure results. Plan to conduct inspections or exploratory 

investigations to determine the kinds of noncompliance that may be encountered. 

Depending on the compliance activities’ focus (sector, chemical or geographic area), 

you will need to locate the best available information that will enable you to show an 

impact on compliance and risk over time. For instance, if you are working to improve 

compliance with requirements for construction permit applications, comparing the 

number of annual permit applications with an industry variable such as new housing 

starts will enable you to determine if compliance has increased. 

▪	 Health and/or environmental impacts and risks: Enhance information on 

compliance levels with information about the risks the subject pollutants pose to 

human health and the environment. Be as specific as possible by giving details on 

how the subject pollutant causes damage. For example, “mercury is a potent 

neurotoxin causing harm to the human brain and nervous system, especially to those 

of embryos and children.” Express your approach in terms that convey the urgency 

Guide for Addressing Environmental Problems 1-3 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

of the problem or the harm prevented; for example, by tying increased compliance to 

improved water quality, aquatic habitat protection, lower sedimentation at drinking 

water treatment plants, or the health of the larger estuary. Refer to well-vetted, 

published reports that make the case for action. 

▪	 Pollutant (or indicator) identification and characterization: Clearly describe the 

pollutant or related indicators. Include specific chemical characteristics, the forms the 

pollutant can take, when it occurs most frequently, and how the strategy aims to 

eliminate or reduce its harm. 

▪	 Distribution of geographic and population impacts: Describe the geographic 

range of the pollutant and its impacts on the environment and groups of people, 

including at-risk populations such as children, seniors or economically disadvantaged 

communities. Although a narrow geographic area may be affected, your description 

of the pollutant’s impacts on the area should to some extent inform the national 

priority selection process. Examples include the Great Lakes Initiative, Hudson River, 

and Anacostia River Watershed. 

▪	 Existing noncompliance issues and patterns: Using data you have gathered from 

EPA data systems, such as the Online Tracking Information System (OTIS) and the 

Integrated Compliance Information System, other available data systems, inspection 

reports, or accounts from witnesses, define and analyze what regulations are being 

violated. Describe any patterns that may exist. These could be types of 

requirements, such as monitoring, reporting or training, that are troublesome, 

geographic clusters of violations, or types of companies or sectors that are exhibiting 

problems. 

▪	 Sector characterization: If the problem is associated with a particular sector, 

compile information on the sector’s characteristics. This information could be based 

on Standard Industrial Code (SIC) or North American Industrial Classification System 

(NAICS) code definitions or particular groups or subsets. Your description of the 

sector’s characteristics could include references to products produced, raw materials 

used, proximity to water bodies, air emissions and major pollutant sources. By 

assigning SIC and NAICS codes, you can analyze data in the context of other 

information sources such as the U.S. Business Census, OTIS, or Dun and 

Bradstreet, which can help to identify other impacts associated with the sector that 

may not have been evident initially. If the problem in question is specific to a 

particular industry sector, determine the following: 

- Sector size: Examine multiple information sources to determine the size of the 

sector. Suggested sources are the U.S. Census, Dun and Bradstreet, EPA data 

systems, industry directories, and national business phone directories. 

- Sector differentiation/variability: Characterize the sector, noting how different 

segments pose different challenges, perhaps from facility size, materials used, 

location, or proximity to other pollutant sources. 

- Small businesses: Determine what portion of the sector is considered small 

business. Be sure to note whether it is small as defined by EPA (100 or fewer 

employees) or by another classification standard such as the one used by the 

Small Business Administration. 

- Businesses with limited capacity to comply: If a significant number of 

businesses are not able to comply, factor this into your strategy since it will likely 

raise political questions and pressures that need to be addressed to minimize 

their impact. Determine how you will handle companies that are unable to comply 

Guide for Addressing Environmental Problems 1-4 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

(e.g., by accepting widespread closing, locating grant funds to assist, or 

approaching business leaders to find a solution). Alternatively, if the problem is 

posed by a specific type of process operation, chemical(s), or is geographically 

based, conduct your research accordingly. 

▪	 Exploratory investigations: Once you suspect a particular problem with a particular 

set of facilities, conduct one or more well-planned, in-depth investigations, perhaps 

with the assistance of EPA’s National Enforcement Investigations Center. These 

“exploratory investigations” should confirm that the suspected problem exists, 

refocus attention on more serious or additional problems, reveal underlying causes, 

or simply find that serious problems do not exist. 

▪	 Existing regulatory gaps: Determine what regulations apply, what gaps exist in the 

regulatory structure and where there are opportunities for filling these gaps. The 

results from exploratory investigations can help you develop suggestions for 

voluntary initiatives, new regulations or combinations of multiple approaches to fill 

these gaps. 

▪	 Contribution of noncompliance to the problem: Determine if the problem is 

broader than noncompliance; that is, would the problem be solved if 100 percent 

compliance were achieved? If the problem is based on more than noncompliance, 

suggest remedies, including the modification of regulations or voluntary pollution 

prevention initiatives. 

▪	 Significance relative to other environmental problems: By defining the adverse 

impacts that you aim to eliminate, you will be more likely to make a convincing case 

that it is worthwhile to address the selected environmental problem. 

▪	 Relevance to EPA’s mission, role and authority: Consider the problem’s 

relevance to EPA’s mission and statutory authorities to ensure that EPA has 

authority to act and that there is a clear federal role. Consider conducting an 

exploratory investigation if it is unclear whether the problem is within EPA’s scope or 

jurisdiction. Look for ways that your compliance activities can support existing goals 

and priorities. 

▪	 Current level of attention: Examine EPA data systems to determine EPA and the 

states’ current compliance activities in the problem area and their effectiveness. 

Decide whether the activities should continue and how they can be more effective. 

▪	 Pending regulatory actions relevant to the problem: Determine what 

enforcement cases or new regulatory actions (promulgation of new rules) are 

underway in order to avoid undermining ongoing compliance activities and to 

coordinate with other experts working on the activities. 

▪	 Planning cycles and opportunities to leverage resources: Aim to have results of 

your problem analysis available in time to inform government planning cycles (e.g., 

for negotiating activity under Memoranda of Agreement and partnership 

agreements). Also, be sure to highlight opportunities for collaboration between the 

problem at hand and high-profile national or regional initiatives that could enable you 

to leverage resources. 

•	 Relationship to other elements: Use the information gathered and analyzed to 

define the problem to inform other components of your strategy. For example, if your 

research shows that the sector universe is too large to handle through traditional 

Guide for Addressing Environmental Problems 1-5 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

inspections alone, plan for sizable self-auditing and compliance assistance 

components. 

Step-by-Step Process for Defining and Selecting 

Environmental Problems – A Sector-Based Example 

EPA regional offices generally know which 

sectors and media problems are the most serious 

in the geographical areas they cover, so they 

should be able to focus attention on narrowly 

defined areas that can be examined in-depth with 

exploratory investigations and state information. 

To ascertain which problems are the most 

significant and warrant increased attention, we 

suggest using a process similar to the one 

outlined below for sector analysis. 

Here is one example of an approach used to 

review problems on a sector basis. It was 

conducted in order to help EPA focus resources 

on environmental problems that would yield the 

highest return on resources. A systematic review 

of all 192 major manufacturing sectors in the US 

economy was conducted. The results of this 

study were used to inform selection of EPA’s 

Enforcement and Compliance Assurance 

1

National Priorities in 2003/04. This diagram focuses on the statement of the 

environmental problem and highlights in gray the Perform an initial screening using the following other elements that are particularly important in factors: stating the problem and justifying its selection. 

▪	 Patterns of non-compliance with the major federal 

environmental statutes, e.g. Clean Water Act, Clean Air Act, etc. 

▪	 Environmental impact indicators including whether the sector produces or uses 

chemicals on the High Production Volume (HPV) list, produces chemicals that are 

persistent bioaccumulative toxics (PBT) or persistent organic pollutants (POP), or 

produces chemicals that have high Toxics Release Inventory (TRI) emissions 

▪	 National prevalence of facilities 

▪	 Recent or forthcoming regulatory activity 

To help determine which sectors meet the initial screening factors, pull information from 

numerous sources, including EPA’s Enforcement Docket; federal government 

information (e.g., U.S. Census, and the Department of Energy; Regional, state, local and 

program Web pages; rule promulgation activity; Dun and Bradstreet; National Center for 

Manufacturing Sciences; Small Business Office annual report; and the news media (i.e., 

investigative reports). 

Carry out more research on the sectors that have passed the initial screening. 2 Then, compare your list to the ongoing sector-based activity of EPA and the states 

Guide for Addressing Environmental Problems 1-6 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

in order to capitalize on their expertise and interest. Consider the following sector-based 

activity indicators with regard to each sector. Has the sector been: 

▪	 Recently affected by new rules, the Small Business Regulatory Enforcement 

Fairness Act (SBREFA) and/or rules that EPA considers to be economically 

significant)? 

▪	 Considered and previously deferred as a priority problem? 

▪	 The subject of active enforcement or received compliance assistance? 

▪	 Considered as the subject of new Compliance Assistance Centers? 

▪	 The subject of sector-based programs in other offices such as the EPA Office of 

Policy, Economics, and Innovation’s Sector Strategies? 

▪	 Ranked high on the previously generated candidates list based on data from the 

Integrated Data for Enforcement Analysis (IDEA) system? 

▪	 Receiving significant, recent state attention? 

▪	 The subject of compliance inspector nominations for attention? 

3 Finalize list of candidate sectors using the abovementioned screening criteria 

and detailed selection criteria, such as: 

▪	 Is there a compliance problem in the sector? Information sources include compliance 

rates trends from the On-Line Targeting Information System (OTIS) 

▪	 Is there an environmental or human health problem in the sector? Are any problems 

defined in rulemaking background or support documents? Have any problems been 

identified by EPA staff research? 

▪	 Is the problem currently widespread or anticipated to be widespread or a growing 

problem? Is a problem associated with the sector being addressed by a new rule? Is 

this a growth industry (economic, market indicators)? Are releases reported via the 

Toxic Release Inventory (TRI) increasing over time? 

▪	 Do possible solutions fall within EPA’s role? Is there a nexus with existing 

Compliance Assistance Centers or a national or regional priority? Is there trade 

association interest in partnerships? Is the sector best suited for compliance 

assistance, incentives, or enforcement attention or some combination of tool use? Is 

the sector under the control of an industry environmental management system? Is 

the sector of concern under SBREFA? 

▪	 Is the problem large enough to merit EPA’s attention? Is the problem nationwide or 

multi-Regional? 

▪	 Does the proposed response fit EPA’s three- to five-year planning horizon? 

•	 What is the current level of attention to the sector? Is the sector already being 

addressed by the Agency? Is the sector being addressed by a number of state or 

local agencies or an outside group such as a trade association? 

Guide for Addressing Environmental Problems 1-7 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

Select priority sector(s) to address. The answers to the selection criteria that 4 you have utilized and any weighting that you have assigned to particular criteria will 

direct the selection of what problem you will address. Remember that there are 

competing resource needs and priorities in the Agency. Therefore, it will be important to 

describe the factors that make this problem(s) ripe for resolution and a relative priority 

and to document the process and criteria used to make your selection decisions. 

Challenges and Opportunities 

The following case examples provide insights into some projects that employ the 

concepts described in this chapter. They illustrate some of EPA’s attempts to define and 

prioritize environmental problems and justify their selection as problems to work on. 

Challenge: Adequately characterizing an environmental problem 

Opportunities and Suggestions 

It is important to characterize, in writing, the environmental problem to 

be addressed so there is a common understanding by all affected 

parties. Most problems take many years to address. With changes in 

Agency staff and the potential involvement of other stakeholders 

throughout the process, it is helpful to document the problem in terms 

that clearly make the link to protecting human health and the 

environment and that contain enough detail to understand the extent 

and nature of the problem that it is to be solved. This doesn’t mean that 

the characterization has to be lengthy. For example, EPA identified Combined Sewer 

Overflows (CSOs) as a National Priority in 2005. The strategy EPA developed to 

address CSOs clearly defines their impact on human health and the environment, and 

the scope of the problem in only a few paragraphs. Following is a portion of the 

characterization of the CSO problem in that strategy: 

Combined sewer systems (CSS) are designed to collect rainwater runoff, domestic 

sewage and industrial wastewater in the same pipe. When properly operating, combined 

sewer systems transport all of their wastewater to a sewage treatment plant, where it is 

treated and then discharged to a water body. During periods of rainfall or snow melt, 

however, the wastewater volume in a combined sewer system can exceed the capacity 

of the sewer system or treatment plant. When the capacity of the system or the 

treatment plant is exceeded, the excess wastewater flows directly into nearby streams, 

rivers or other water bodies, typically violating water quality standards. 

CSOs are a significant cause of water quality impairment as documented in Clean Water 

Act (CWA) Section 305(b) reports; often occur in areas frequented by the public such as 

parks, beaches, backyards, city streets and playgrounds; and represent significant 

threats to public health and the environment due to the risks they create for spreading 

disease through direct contact with or ingestion of water contaminated with human waste 

and toxic chemicals. 

Overflows affect approximately 836 permits in the United States for combined sewer 

systems. Affected communities are located in 32 states (including the District of 

Columbia), primarily concentrated in the Northeast and Midwest, and serve 

Guide for Addressing Environmental Problems 1-8 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

approximately 46 million people. Regions 1, 2, 3 and 5 collectively account for 

91 percent of the permitted CSOs in the United States. 

According to the EPA Office of Water Report to Congress, “Impacts and Control of 

Combined Sewer Overflows - Final Agency Review,” Draft dated November 2003: 

▪	 There are 836 National Pollutant Discharge Elimination System (NPDES) permits for 

CSOs covering 9,501 outfalls 

▪	 Annual discharges from CSOs are estimated to be 850 billion gallons (based on 

modeling) 

▪	 Receipt of CSO discharges: 75 percent to rivers, streams or creeks; 10 percent to 

oceans, estuaries and bays; 2 percent to ponds, lakes and reservoirs; and 13 

percent to other waters (ditches, canals, unclassified) 

▪	 141 CSO permit holders do not have an enforceable schedule to implement LongTerm Control Plans (LTCPs) 

▪	 559 CSO permit holders have enforceable requirements to implement LTCPs (457 in 

a permit, 102 in enforcement orders) 

•	 16 CSOs are within 1 mile upstream of a drinking water intake (from a surface water 

source) 

EPA’s CSO Control Policy set a January 1997 deadline for CSSs to meet the nine 

minimum controls. There are still a significant number of communities with CSSs that 

have not implemented the nine minimum controls, do not have a Long-Term Control 

Plan in place, or have long implementation schedules. 

This example provides a good characterization of the environmental problem that the 

strategy is addressing and documents the main source of baseline information used to 

characterize the problem. 

Challenge: Identifying serious cross-media compliance 

problems 

Opportunities and Suggestions 

Region 3’s Vinyl Chloride Initiative provides an excellent example of how to identify 

serious cross-media compliance problems. Cross-media compliance problems are 

created by processes or activities in one media (air, water, land, etc.) that lead to noncompliance issues in another media, e.g., Volatile Organic Chemical (VOC) emissions 

from wastewater discharges can result in a facility exceeding its air emission limits. The 

Region 3 initiative used a targeting methodology that examined public health data, 

environmental data and environmental justice/hotspot issues. From this targeting, 

releases of six chemicals of concern (probable or known carcinogens) were identified. Of 

these six chemicals, it was vinyl chloride emissions from the chemicals and allied 

products industry that was identified as the greatest threat to human health and the 

environment. A series of multi-media investigations were conducted that targeted vinyl 

chloride facilities in EPA Regions 2, 3, 4, 5 and 6. The initiative was also a good 

example of establishing goals that ranged from general, performance-based 

benchmarks to industry benchmarks, as well as environmental justice, and pollutant 

Guide for Addressing Environmental Problems 1-9 
Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection 

reductions goals. This initiative also contributed to elevating national awareness and 

expertise among the regions in the area of cross-media emission transfers. 

Challenge: Correcting widespread violations efficiently 

Opportunities and Suggestions 

Region 2’s Healthcare Strategy includes a well-researched 

definition of the problem along with a reasoned explanation of 

why the problem was selected for action. It is worth noting that 

Region 2’s healthcare initiative evolved out of an effort to 

eliminate mercury from hospitals and in their colleges and 

universities compliance initiative. During that initiative, the 

Region unearthed evidence of widespread noncompliance in an 

industry that had been relatively free of environmental oversight. 

As explained in the full case study of this Healthcare Strategy 

(Attachment D), Region 2 demonstrated that despite the large 

number of pollutant sources, with strategic use of inspections, enforcement, self-auditing 

and assistance outreach they were able to correct violations at nearly all sources without 

having to conduct inspections or pursue enforcement actions at all sources. The initiative 

is also a good example of a pattern of noncompliance at healthcare facilities in a single 

medium (hazardous waste) that led to the discovery of numerous violations in other 

media. In this case, the hazardous waste violations led inspectors to find noncompliance 

with other regulations, including Clean Water Act (CWA), Clean Air Act (CAA), and Oil 

Spill Prevention Control and Countermeasure (SPCC). 

Region 2’s Healthcare initiative is instructive in that the Region identified serious 

problems following a limited number of inspections associated with a separate project 

(Mercury elimination at hospitals). Motivated by the trend of poor compliance 

encountered by their inspectors and the significant level of enforcement, the Region 

conducted research to better define the universe of hospitals in the Region and the 

extent of their environmental problems. Later, once the self-audit and disclosure phase 

progressed, the Region was able to confirm their assessment that most hospitals were 

out of compliance with one or more regulation. 

Guide for Addressing Environmental Problems 1-10 
Element 2: Establishing Goals 

and Measures 

Objectives 

▪	 Explain how goals and measures work together. 

▪	 Provide a step-by-step process for identifying your strategy’s 

desired results and whether the results have been achieved. 

•	 Identify key challenges and opportunities in goal-setting and 

selecting and using measures. 

Purpose 

This element of the strategic approach addresses establishing: 

▪	 An overarching goal or result that is measurable and reasonably 

achievable in the given time frame 

▪	 Outcome and output measures 

•	 Baselines for all measures, or a plan for developing a baseline for 

each of the measures 

It corresponds to Element 3 of the Framework, “Desired/Anticipated 

Outcomes/Results,” and Element 2 of the Template, “Establishing 

Goals and Measures.” 

Key Concepts 

Baseline: The reference or 

starting point against which 

progress will be measured. 

Outputs: Product or service 

delivery targets you aim to 

produce. Often presented as 

the number of activities, work 

products or actions. 

Outcomes: Changes or 

benefits resulting from activities 

and outputs. Outcomes can be: 

± short term (changes in 

learning, knowledge, 

attitude, skills or 

understanding) 

± intermediate (changes in 

behavior, practice or 

decisions) 

± long term (changes in an 

environmental condition). 

Approach 

The key questions are “What do you hope to accomplish?” (goals) 

and “How will you determine your progress?” (measures). You can 

use measures to show progress toward the anticipated goal, the need 

for mid-course corrections, the effectiveness of a particular strategy and 

lessons learned for evaluating the overall approach. During the 

development of the strategy, identify both final measures of success and 

interim measures and milestones. Where appropriate, measure the 

impact of each type of compliance tool (e.g., compliance assistance, 

incentives, compliance monitoring and enforcement) you use as well as the synergistic 

effect of the tools to resolve the environmental problem. Measurement occurs 

throughout the planning and implementation of the strategic approach and for a variety 

of purposes as illustrated in the measurement continuum below: 

Goals and Measures should be: 

S - specific 

M - measurable 

A - attainable 

R - realistic 

T - time sensitive 

Guide for Addressing Environmental Problems 2-1 
Element 2: Establishing Goals and Measures 

Continuum of Measures Continuum of Measures 

BaselineBaseline Output Measures Outcome Measures

Capacity

Building CustomerCustomer 

Tools Satisfaction Environmental and Environmental and 

DevelopingDeveloping Deve loped Changes in Changes in Changes in Changes in Human Health Enforcement Enforcement 

Baseli nes ActivitiesActivities Understanding Understanding Behavior Behavior Improvements Reach

Establishing

Compliance 

Baselines 

Identifying 

compliance

problems/universe 

Establishing

Compliance 

Baselines

Identifying 

compliance

problems/universe

EXAMPLES: EXAMPLES:

Enforcement –AOs, Penalties Enforcement - injunctive relief

Incentives- # disclosures Incentives-violations corrected 

CA-outreach materials CA-emissions reduced after CA visit

distributed Inspections/CA – facility process change

Inspections - # conducted Understand need to apply for permit

Compliance Assurance Activities/Tools

Step-by-Step Process for Conducting Measurement 

1 Review baseline information on the 

environmental problem and target 

audience. The goals and measures that you 

establish for your strategy will flow directly from 

the information that you have collected on the 

problem and the populations (e.g., sectors, the 

public) that are contributing to the environmental 

problem. In addition to the goals and measures 

themselves, the methods you choose for 

collecting both baseline and subsequent 

performance measurement data may be 

influenced by the following factors: 

▪ Characteristics of the population of concern, 

such as knowledge, sophistication, size and 

resources. Some segments or subpopulations may need to be treated 

differently. 

• The scope of the problem and gaps where 

more information is needed. This diagram focuses on goals and measures 

and highlights in gray the other elements that 

are particularly important in establishing goals 

2 Identify goals. Establishing a good goal statement 

for your strategic approach is critical. Your goal 

and measures. 

statement should define, as specifically as possible, what you hope to accomplish and 

the time frame in which you expect this to occur. Be realistic in defining what you can 

achieve in the specified time period. For instance, a goal of “clean drinking water for all 

Guide for Addressing Environmental Problems 2-2 
Element 2: Establishing Goals and Measures 

residents of (a large state) within two years” may be desirable but is probably not 

realistic within a two-year time frame. In addition, “clean drinking water” as an 

overarching, general goal is fine, but as a goal statement for a specific strategy it is too 

vague (what is the standard for “clean”?). A better goal statement would be, “By 2009, 

90 percent of public water systems (in a large state) will have drinking water that meets 

all Safe Drinking Water Act standards as determined through annual water testing.” 

Remember, too, that the strategic approach is iterative, and you may need to revise your 

goal statement over time. You may frame the initial goal of your strategy in more general 

terms, but your goal may become more specific or even change as you learn more 

information about the problem you are addressing. For instance, in response to multiple 

chemical spills in a district’s high schools, an initial goal may be “all schools in the district 

will safely manage toxic chemicals stored on their property by X date.” However, after 

additional assessment, you may determine that this goal is not practical or feasible. You 

may need to revise the goal to include “removal of toxic chemicals from individual 

schools with central storage at the district level” or “substitution of toxic chemicals with 

non-toxic chemicals.” 

Identify, either here or in the statement of the environmental problem section of your 

strategy, the baseline or reference point against which you will measure progress. You 

may also want to identify the compliance assurance tool or tools that you plan to use to 

achieve the goal. For example, “By X date, X percent of all permitted Combined Sewer 

Overflows (as identified in the 2004 baseline) will have an approved Long-Term Control 

Plan with an enforceable schedule that will ultimately result in compliance with the 

technology-based and water quality-based requirements of the Clean Water Act, or a 

formal enforcement action will have been initiated to achieve that result.” 

Develop measures to determine if you are achieving desired results. Identify 3 specific measures for each goal. These measures may be aligned with the 

compliance assurance tool or tools that you plan to use. By measuring the impact of the 

selected compliance assurance tool(s) in addressing the identified environmental 

problem, you can better manage for results and communicate the effectiveness of all 

aspects of the enforcement and compliance assurance program (i.e., compliance 

assistance, incentives, monitoring and enforcement). After you have undertaken your 

activity, you also need to conduct a follow-up measurement activity to assess overall 

impact of the intervention(s). The purpose is to determine how well you addressed the 

problem and if you are reaching your goals. 

Listed below are some of EPA’s national outcome measures for compliance assistance, 

compliance incentives, and monitoring and enforcement. Some of these national 

measures or similar ones have been used to assess progress in meeting the goals of 

specific strategies. 

Compliance Assistance Measures 

▪	 Percentage of regulated entities receiving direct compliance assistance from EPA 

(e.g., training, on-site visits) reporting that, as a result of that assistance, they: 

- Increased understanding of environmental requirements 

- Improved environmental management practices 

- Reduced, treated or eliminated pollution 

Guide for Addressing Environmental Problems 2-3 
Element 2: Establishing Goals and Measures 

•	 Percentage of non-EPA compliance assistance providers reporting an improved 

ability to deliver assistance as a result of EPA assistance 

Compliance Incentives Measures 

▪	 Percentage of audits or other actions resulting in: 

- Reduction/elimination of pollution and protection of populations and ecosystems 

- Improvements in environmental management practices 

•	 Pounds of pollutants reduced, treated or eliminated and populations/ecosystems 

protected as a result of audit agreements or other actions; dollars invested in 

improving environmental management practices as result of audit agreements or 

other actions 

Monitoring and Enforcement Measures 

▪	 Percentage of entities taking complying actions as a result of monitoring 

▪	 Percentage of concluded enforcement cases 

▪	 Percentage of concluded enforcement cases requiring improved environmental 

management practices 

▪	 Pounds of pollution reduced, treated or eliminated and populations/ecosystems 

protected as a result of concluded enforcement actions 

▪	 Dollars invested in improved environmental performance/environmental 

management practices through concluded enforcement actions 

▪	 Inspections, civil investigations and criminal investigations in high-risk areas, areas 

displaying patterns of noncompliance or areas including disproportionately exposed 

populations 

4 Identify how the measurement data will be collected 

and tracked. Appropriate mechanisms for collecting the 

measurement data are essential for assessing progress toward 

achieving the goal. Regardless of how good a performance measure is, if a method for 

collecting the data does not exist or requires an excessive amount of resources it will not 

be a useful measure. An illustration comes from EPA’s tribal priority strategy. EPA 

wanted to track the number of tribes receiving solid waste management compliance 

assistance as one of its measures. While this is a perfectly acceptable measure, the 

Agency’s database for compliance and enforcement activities and measures could not 

be used to track this information. The database’s information on audiences for 

compliance assistance was limited to higher-level groupings, making it impossible to 

differentiate how many tribal representatives had received the compliance assistance. 

EPA determined that there was not sufficient time or resources to modify the existing 

database to capture the needed information. Capturing this information manually would 

also require too many financial and staff resources for the value of the information being 

collected. As a result, the measure was dropped. 

If you don’t measure it, it didn’t 

happen. 

Another lesson learned on collecting and tracking measurement data comes from EPA’s 

Region I. Regional staff developed a phone survey script with many open-ended 

questions to use with a large number of school personnel. The result was a large 

number of responses that were difficult to review, tabulate and summarize. 

Guide for Addressing Environmental Problems 2-4 
Element 2: Establishing Goals and Measures 

The following table provides examples of strategy goals and measures and of data 

collection methods appropriate to them: 

Strategy Goals Sample Performance 

Measures, Including Interim 

Measures 

Data Collection Methods 

By X date, verify the compliance 

status of all facilities in X sector. 

By X date, reduce by 30% the 

number of facilities in sector X 

that are in significant 

noncompliance (SNC) with air, 

waste and water regulations 

(from the baseline established in 

2000). 

By X date, 50% of hospitals in 

the state will eliminate the use of 

mercury. 

Number/percentage of hospital 

staff who increased their understanding, as a result of 

assistance provided, of the 

potential problems that may 

result from storing and using 

equipment containing mercury. 

On an annual basis, percentage 

of hospitals in the state that 

have conducted baseline 

assessments of their mercury 

use and waste. 

On an annual basis, percentage 

of hospitals in the state that 

have established mercury 

removal and purchasing policies. 

On-site visits 

Pre/post-workshop survey 

Response to mail or phone 

survey 

By X date, achieve 20% 

reduction in emissions of sulphur 

oxides (SOx) and nitrogen 

oxides (NOx) (from the 1995 

baseline) by the petroleum 

refining sector. 

Percentage of facilities in the 

sector that have been inspected. 

Percentage of enforcement 

actions/settlement agreements 

in the sector. 

Percentage of facilities in sector 

that evaluate their air, water and 

waste process-related 

operations through self-audits 

and address associated 

compliance problems. 

SNC rate of the sector 

Total reduction of 205,760 short 

tons per year of SOx/NOx 

emissions as a result of 

settlements and enforcement 

actions. 

Review of information in Agency 

compliance and enforcement 

databases. 

Self-audit disclosures and 

manual tracking. 

Review of information in Agency 

databases. 

Data collected through emission 

calculations and air monitoring. 

Tracked through the Integrated 

Compliance Information System 

(ICIS). 

Guide for Addressing Environmental Problems 2-5 
Element 2: Establishing Goals and Measures 

Strategy Goals Sample Performance 

Measures, Including Interim 

Measures 

Data Collection Methods 

By 2010, all colleges and 

universities in EPA Region X (as 

identified in EPA’s 2005 

inventory of institutions) will 

meet applicable RCRA 

requirements. 

Number/percentage of 

college/university staff who 

increased understanding of 

RCRA obligations as a result of 

assistance. 

Number of colleges and 

universities obtaining the 

required RCRA permits. 

Number/percentage of colleges 

and universities inspected by 

EPA with no RCRA violations 

identified. 

Pre/post workshop test, written 

or phone sector-wide survey 

after distribution of RCRA 

assistance materials. 

Review of information in Agency 

databases. 

Inspection reports. 

Conduct measurement activities. Use of each tool constitutes a separate activity 5 that should, when possible, include a step to measure the outcome of the activity or, 

at a minimum, record the “outputs” from the activity. For some compliance assurance 

tools, follow-up may already be built into the compliance assurance activity. For 

example, complying actions undertaken during a compliance monitoring inspection can 

be recorded by the inspector at that time on the Inspection Conclusion Data Sheet. In 

other cases, you may need to undertake a specific or additional follow-up activity or 

verification to assess the outcome of the intervention. For example, a follow-up to an 

inspection may be an enforcement action requiring specific injunctive relief. Reviewing 

documentation sent by a facility disclosing under the Audit Policy or sending an 

inspector to the facility can provide information on whether the audit resulted in reduced 

pollution or a changed environmental management practice. Compliance assistance 

almost always requires an additional follow-up activity (e.g., a survey, a follow-up site 

visit or an inspection). For compliance assistance, the follow-up may take the form of 

survey questions (e.g., on a test, through the mail, on e-mail or over the telephone) or 

questions asked during a site visit. Some of these methods may need to address the 

Paperwork Reduction Act (PRA) restrictions on the number of non-federal respondents 

that EPA can contact to ask questions. If you do need to collect information from nonfederal respondents an Information Collection Request (ICR) may need to be prepared 

and submitted to the Office of Management and Budget. The time needed to do this 

should be factored into your measurement planning. See the Challenges section of this 

chapter and page 11 in Chapter 8 for more details on the PRA and ICR process. 

Track the results of compliance assurance activities. It is important to establish 6 some mechanism for tracking the progress of your strategy in achieving its goals. 

This may be achieved through something as simple as keeping a notebook with 

summaries of all activities, strategy and measure modifications, and outputs and 

outcomes of activities. It is more common, however, for EPA staff to create a database 

dedicated to tracking a specific strategy or entering the data into a national database. In 

general, EPA staff is expected to enter both the outputs and the outcomes of EPA’s 

compliance assistance, compliance monitoring, incentives and enforcement into the 

Agency’s Integrated Compliance Information System (ICIS) or medium-specific 

Guide for Addressing Environmental Problems 2-6 
Element 2: Establishing Goals and Measures 

databases, as appropriate. There are certain instances, however, when it may be 

necessary to track information manually. 

Analyze the data. After collecting information on results, perform appropriate 7 analysis. The type and complexity will depend on the quantity of information you 

have, whether it is quantitative or qualitative, or your available resources. If you identify 

gaps, earmark necessary resources and allocate appropriate time to collect additional 

information. Review, reassess and revise the strategy as needed. Prepare results in a 

clear, presentable form, understandable to a general audience. 

Communicate results. Use the data collected to demonstrate the value of the work 8 being undertaken. You can communicate results in a variety of forms, including 

press conferences and releases, e-mail list announcements, magazine or trade journal 

articles, newsletters, reports, and internal briefing of program managers, to name a few. 

Do not wait until the end of the strategy’s implementation to begin reporting results. 

There is value in reporting on interim milestones (both outputs and outcomes); for 

instance, the communication helps inform other entities that may be contributing to the 

environmental problem that a problem exists and how it is being addressed. This 

increased awareness may, in turn, lead to increased compliance. Following is a sample 

of interim results included in a press statement: 

In 2005, EPA entered into legally binding agreements with 11 major domestic 

airlines and nine smaller airlines to ensure the safety of the drinking water used 

by their passengers and crew. The actions came after an EPA investigation of 

327 U.S. and foreign airplanes at 19 airports in 2004 found coliform
 

contamination in 15 percent of them. ... EPA will continue to work with smaller, 

regional and charter airlines to ensure the safety of their drinking water. 

Challenges and Opportunities 

The following case examples highlight a few of the key goal-setting and measurement 

challenges that have been encountered during EPA’s implementation of the strategic 

approach. The examples also identify some opportunities and suggestions for 

addressing these challenges that have come out of the pilots using the strategic 

approach. 

Challenge: Disconnect between the goals of the strategic 

approach and the performance measures 

This challenge came up several times during the pilot phase testing the strategic 

approach. In some cases the disconnect was the result of changes being made during 

implementation of the strategy with either the goal statement or the specific measures 

being modified but not both, resulting in inconsistency. In other instances, performance 

measures were identified for each tool being utilized to address the environmental 

problem, but the measures did not provide enough information to indicate whether the 

goal or goals were being achieved. 

Guide for Addressing Environmental Problems 2-7 
Element 2: Establishing Goals and Measures 

A hypothetical example of the latter would be a strategy with a goal of having 

construction sites in a particular geographic area comply with all applicable stormwater 

regulations within three years and performance measures limited to: 

▪	 Number of guides on stormwater requirements distributed to the target audience 

▪	 Number of representatives from construction companies in that area attending a 

stormwater workshop 

▪	 Number and percentage of workshop attendees indicating that they 

improved their understanding of the stormwater requirements 

▪	 Number of stormwater inspections conducted at construction sites in 

the area 

While there is nothing wrong with these measures per se, they do not 

go far enough to measuring progress towards the goal. One cannot 

discern whether providing stormwater information, and any reported 

improvements from the target audience about their understanding of the requirements, 

has translated into improved compliance. In addition, the number of inspections alone is 

not a useful measure. What were the results of the stormwater inspections? Did they 

occur after the compliance assistance was provided? Had baseline information already 

been established about compliance with the stormwater requirements before the 

compliance assistance was provided? 

Opportunities and Suggestions 

Utilize the many existing resources for developing good environmental performance 

measures that are directly linked to the goal of your strategy. The table under Step 4 in 

this chapter illustrates performance measures that are clearly linked and designed to 

achieve the identified goals. Other resources include EPA’s Guide for Measuring 

Compliance Assistance Outcomes, which is available at 

www.epa.gov/compliance/resources/publications/assistance/measures/index.html . This 

document contains detailed information on developing measures and collecting and 

analyzing compliance assistance data. In addition, go to EPA’s Web site at 

www.epa.gov/evaluate for more information that is specific to evaluation but addresses 

many of the same steps involved in developing goals and measures. 

Challenge: Emphasis is on implementing the strategy rather 

than measuring results 

Several of the teams piloting the strategic approach reported that this was one of their 

greatest obstacles. They reported that once an environmental problem had been 

identified, there was often a great urgency to take action to address the problem. This 

translated into the majority of their time being spent on planning for and conducting the 

inspections; developing and distributing materials to inform the regulated community 

about the problem; conducting workshops; inviting facilities to self-audit, correct and 

disclose violations; and initiating enforcement actions as needed. Measurement was 

often an afterthought. Although the strategic approach emphasizes spending time up 

front to scope out the problem and establish good goals and measures, doing so was 

still a struggle for many of the teams. Staff knew how to provide compliance assistance, 

conduct inspections, etc. However, many of the team members reported lack of 

Guide for Addressing Environmental Problems 2-8 
Element 2: Establishing Goals and Measures 

knowledge about and experience with goal-setting and measurement as one of the 

impediments to doing it. 

Opportunities and Suggestions: 

The following suggestions for addressing this challenge were made by the teams piloting 

the strategic approach: 

▪	 Establish a review process to ensure that the tools selected and the strategy’s 

performance measures are directly linked to each strategy’s goals. It was 

recommended that this review be done by an individual or individuals with expertise 

in measurement and the strategic approach. It was also suggested that the Agency 

develop guidance providing examples that link the environmental problem, the 

approach’s goals, the tools selected and the corresponding measures. 

▪	 Make measurement a management priority. Get senior management to buy in, 

support it with resources and staff time, and recognize that staff may complete fewer 

activities if they spend time on measurement. 

▪	 Require measurement of activities (e.g., include language in grant specifications) 

and require goals and measures of individual projects. 

▪	 Dedicate and train a person to do measurement, and provide support and outreach 

to others. Hire college interns to do follow-up phone/mail surveys of regulated 

entities after they attend an EPA workshop or receive an on-site compliance 

assistance visit from EPA. 

•	 Use the measurement data to inform others of progress on meeting the goals of the 

strategy. 

Challenge: Obtaining measurement data to set baselines and 

measure results 

Setting and achieving measurable goals has been a challenge for several of the projects 

testing EPA’s strategic approach. One reason for this problem has been the difficulty 

with obtaining data and other information on a sector’s, or other regulated entity’s 

environmental performance prior to and following the compliance assurance activities. 

This is particularly true for sectors with many small businesses where EPA has minimal 

compliance and enforcement data, and when reporting of data is voluntary. 

The Paperwork Reduction Act (PRA) also limits the Agency’s ability to obtain 

measurement data. This law attempts to minimize the federal paperwork burden on the 

public and requires federal agencies to obtain Office of Management and Budget (OMB) 

approval prior to collecting substantially similar information from ten or more non-federal 

respondents. EPA has a generic ICR for collecting some limited outcome data from its 

compliance assistance activities. Regions requesting approval for information 

collections using the generic ICR for compliance assistance can expect the process to 

take approximately thirty days to obtain OMB approval. Certain activities are not subject 

to the Act; the main one applicable to EPA’s compliance assurance and enforcement 

program is the collection of information during the conduct of a criminal or civil 

enforcement action. For more information on the PRA and information collection 

requests, go to EPA’s Web site, www.epa.gov/icr. 

Guide for Addressing Environmental Problems 2-9 
Element 2: Establishing Goals and Measures 

Opportunities and Suggestions 

One approach for obtaining additional measurement data is illustrated 

by EPA Region 1. The Region funded the development of tools to 

encourage voluntary reporting of information. One such tool was the 

Environmental Assessment Template, which helps federal and state 

agencies collect information from hospitals on environmental 

performance indicators, waste generation, pollution prevention and 

energy/water conservation. The information collected from 25 hospitals 

in three states was used to evaluate hospital mercury programs; identify 

sector-wide environmental, health and safety challenges; develop 

compliance assistance tools; and further define the need for assistance 

activities for the sector. The federal template was modified into three 

state-specific tools for Connecticut, Rhode Island and New Hampshire. 

The federal template is available at: 

www.epa.gov/region1/healthcare/pdfs/EPAHospitalTool.pdf 

Challenge: Choosing the right data collection method 

Gathering data is often the most difficult, time-consuming and resource-intensive step in 

conducting measurement activities. Therefore, selecting the data collection tool or 

method that will provide the best information is critical. A number of data collection tools 

are available, including surveys, Inspection Conclusion Data Sheets, focus groups, 

pre/post tests, and mandatory reporting forms like permit applications and Toxics 

Release Inventory forms. 

Opportunities and Suggestions 

Remember that the methods you choose for collecting both baseline and subsequent 

performance measurement data may be influenced by factors like existing information 

gaps; the scope of the problem; the knowledge, sophistication, and size of the audience 

or universe of facilities; and available resources. Some segments or sub-populations 

may need to be treated differently. 

By way of example, EPA Region 1’s pilot strategy team for schools reported that they 

initially planned to send a written survey to all the schools in the region to: (1) identify 

barriers to improving the school’s environmental performance; and (2) solicit information 

regarding the kinds of tools, services and incentives needed to get schools to make 

broad-scale behavior changes that would result in increased compliance and healthier, 

safer schools. However, through some initial contact with school representatives and 

feedback from inspectors, they learned that many schools were unaware of the 

environmental issues affecting schools and the regulatory requirements with which they 

needed to comply. In light of this information, EPA decided that a detailed written survey 

would be an ineffective means of obtaining data. Instead, EPA staff used, with great 

success, a series of focus group discussions that included representatives from several 

groups associated with K-12 schools, including those knowledgeable about their 

environmental issues. 

Guide for Addressing Environmental Problems 2-10 
Element 2: Establishing Goals and Measures 

Challenge: The length of time it may take to achieve the goals of 

the strategy 

Opportunities and Suggestions 

Be realistic about how long things take. Try to factor in contingencies (i.e., school 

schedules if the target audience is schools, contractual factors if using a contract). Be 

ready for mid-course corrections. 

EPA Region 2’s Healthcare Initiative provides a good example of the time that can be 

involved in addressing an environmental problem. The initiative began in 2002 with 480 

healthcare facilities. The initial approach focused on correcting hazardous waste 

violations and a voluntary effort to have hospitals remove mercury-containing waste from 

the healthcare waste stream. The initial results included mainly outputs (e.g., number of 

workshops on identifying and managing healthcare wastes delivered, number of 

compliance assistance tools developed and distributed, number of audit agreements 

signed, and number of voluntary self-disclosures with or without signing an audit 

agreement) and some interim outcomes from the use of these tools. 

Four years later, the Region is reporting on significant human health protection from 

voluntary self-disclosures, which have resulted in the correction of more than 1,700 

violations. More than 150,000 staff and more than 20 million hospital visitors annually 

are now better protected because of this initiative. These self-disclosures have also 

yielded significant protection of the environment. More than one million gallons of oil, 

more than 200,000 pounds of hazardous wastes and more than 150,000 pounds of 

Chlorofluorocarbons (CFCs) are now being managed properly. Mercury use also has 

been reduced by 96,000 pounds. 

This effort demonstrates that meaningful results can be achieved, but it often takes 

several years to implement the strategy and to collect enough data to show significant 

results. 

Guide for Addressing Environmental Problems 2-11 
Element 2: Establishing Goals and Measures 

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Guide for Addressing Environmental Problems 2-12 
Element 3: Selecting, Sequencing and

Segmenting Tools 

Objectives 

▪	 Introduce types of tools and considerations for their use that will 

address the target audience contributing to the environmental 

problem. 

•	 Identify key challenges and suggestions in selecting and 

implementing the tools. 

Purpose 

In this section, we will examine some of the more common 

considerations in selecting, sequencing and segmenting compliance 

assurance tools. This element corresponds to Element 4 of the 

Framework, “Use of Available Compliance Assurance and Enforcement Tools,” and 

Element 3 of the Template, “Priority Strategy.” 

Key Concepts 

Segmentation (of the target 

audience): The selection and 

implementation of more than 

one tool to address different 

needs within the target 

audience to yield a comprehensive approach. 

Sequencing: The implementation of more than one tool in a 

particular order to address the 

entire target audience to 

achieve maximum efficiency 

and impact. 

The goal is to select the tool or mix of tools that will 

best address the environmental problem. The 

information provided is intended to illustrate the 

breadth of considerations that could affect the tool 

selection process, rather than provide an exhaustive 

list of factors or a formula. Professional judgment and 

creative problem solving are still important in 

identifying the best approach for addressing the 

problem. 

Approach 

Select the tool or combination of tools that will best 

address the environmental problem and lead to 

improved performance by the target audience. Below 

are five general categories of tools. For more 

information about these tools and how they are used 

at EPA, look at http://www.epa.gov/compliance/. 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategic approaches, we provide the following 

considerations for selecting tools: 

 Consider the full range of possible tools to 

address the problem and evaluate the impact on 

the target audience; even if only one tool is 

ultimately selected. You may modify the tool(s) 

you initially select as you learn more information 

about the audience contributing to the problem. 

 When sequencing tools, consider how to transition 

from one to the next and the impact on the target 

audience. 

 When segmenting tools, consider the impact on 

the target audience and outcome for each set 

within that population. 

 Identify the anticipated resources (internal and 

external) needed to utilize each tool. 

Guide for Addressing Environmental Problems 3-1 
Element 3: Selecting, Sequencing and Segmenting Tools 

▪	 Compliance Assistance (CA). Compliance assistance involves activities, tools or 

technical assistance that provides clear and consistent information for helping: 

(1) the regulated community to understand and meet its obligations under 

environmental regulations; or (2) compliance assistance providers to aid the 

regulated community in complying with environmental regulations. Compliance 

assistance may also help the regulated community find cost-effective ways to comply 

with regulations or go “beyond compliance” through the use of pollution prevention, 

environmental management practices and innovative technologies, thus improving its 

environmental performance. To be categorized as a compliance assistance project 

or activity, at least one objective of the project or activity must be related to achieving 

or advancing regulatory compliance. 

▪	 Compliance Monitoring (CM). Compliance monitoring determines compliance 

status and detects violations of regulatory requirements and other legal obligations. 

Compliance monitoring personnel develop and use targeting tools and conduct 

inspections, investigations and evaluations of facilities to determine compliance 

status, respond to citizen tips and complaints, and support case development. 

Compliance monitoring involves the development and dissemination of new 

compliance monitoring tools and technologies for inspectors and the regulated 

community, and the training of compliance monitoring personnel. It also involves 

developing state, local, tribal and international capacity for monitoring. 

▪	 Compliance Incentives (CI). Incentives may provide encouragement for companies 

to take proactive measures and to take advantage of compliance assistance 

resources and opportunities. In essence, incentives prompt facilities to monitor their 

own compliance. Some EPA compliance incentive strategies or policies (e.g., Audit 

Policy, Small Business Compliance Policy) limit companies’ exposure to penalties or 

inspections if they have taken voluntary measures to discover, disclose and correct 

violations and have a solid compliance record. Compliance incentive strategies may 

also include partnerships between government and the regulated community, such 

as the Environmental Results Program. 

▪	 Enforcement. Enforcement requires the correction of environmental problems and 

returns a violator of the law to compliance. It can discourage the violator and other 

similarly situated entities from further violation by placing all regulated entities on an 

equal footing, eliminating any economic advantage to noncompliance. 

▪	 Innovations & Sound Business Practice. There are additional innovative practices 

to improve facilities’ compliance profile. These may take the form of voluntary, 

sustainability-oriented programs and projects such as pollution prevention, 

environmental management systems, best management practices and peer 

mentoring. Such innovative activities often encourage environmental performance 

beyond compliance. 

Before considering which tool or tools will best address the environmental problem, 

consider how you wish to influence a change in the target audience’s behavior. A range 

of options is available to foster compliance and improve environmental performance. 

Some of the more commonly used options that lead to behavior change include: 

▪	 Education. Compliance requires that the regulated community be aware of and 

understand the regulations that apply to it and that it have the means for achieving 

Guide for Addressing Environmental Problems 3-2 
Element 3: Selecting, Sequencing and Segmenting Tools 

compliance with those requirements. Education makes information available in ways 

that meet the needs of the regulated community for access, ease-of-use and 

understanding, and practical technical assistance. 

▪	 Encouragement. Removing actual or perceived barriers to compliance, providing 

incentives for responsible action, and supporting a culture of environmental 

stewardship and superior environmental performance can enhance compliance and 

improve environmental quality. 

▪	 Accountability. To achieve compliance, it is necessary to have measures in place 

that determine the success of actions taken by the regulated community and 

regulators. The regulator must be able to gather information on the regulated 

community’s compliance and to take appropriate action when the requirements of the 

law are not being met. The regulated community needs to know that it will be held 

responsible for its environmental performance and how that performance will be 

determined. 

•	 Deterrence. The complement to providing incentives for compliance is providing 

disincentives for noncompliance. This means leveling the playing field to remove 

unfair economic advantages derived from noncompliance and ensuring that 

everyone in the regulated community is held to the same standard of responsibility 

and performance. 

Many factors inform the decision as to which compliance assurance tool(s) to use to 

address a particular environmental problem and influence behavior change by the target 

audience. There is no set formula. Your strategy may include one tool, or a mix of tools. 

The important point is that all tools should be considered in the planning process. 

The following table serves to illustrate some of the considerations that 

can inform tool selection. Each of these tools can embody several of the 

behavior-changing options discussed above. For example, compliance 

monitoring can educate, provide accountability and function as a deterrent for the facility 

being inspected. Each tool has been assigned a “primary behavior option,” while 

recognizing that the tool may also be used to fulfill the other options. 

All tools should be considered 

in the planning process. 

Note, too, that there is no expectation that a tool should only be used when both the 

situational and audience characteristic considerations associated with it have been met. 

For instance, when there is a threat or actual harm to human health or the environment 

that requires immediate correction, EPA may use enforcement even if there is no 

indication that the person or entity responsible for that threat or harm willfully violated the 

law. 

Guide for Addressing Environmental Problems 3-3 
Element 3: Selecting, Sequencing a

Factors to Consider for Tool Selection 

Tool Primary Behavior 

Option 

Situational Considerations Audience Characteristic C

Compliance Education Assistance 

	 As part of the initial effort to imple ment 

a new rule. 

	 When the rules have been out for a 

number of years and data indicate “hot spots” of noncompliance or misunderstanding of certain aspects of the regulatory requirements. 

	 When enforcement and inspections do 

not seem to be improving comp liance in a sector. 

 When the regulations are partic ularly 

complex. 

 When a regulated entity requests 

assistance. 

When considering compliance assistance as a tool, refer to federal or state policies that may require up-front compliance assistance such as the U.S. EPA Indian Policy. 

	 When the sector is popula

small businesses. 

	 When regulatory complian

not readily available or acdemographic, geographiceconomic or other barriers

	 For sectors with well-defin

trade associations) that aor maximize the potential assistance accessible. 

	 When the regulations are 

complex. 

Compliance Accountability  Before and after a compliance  To address specific sectoMonitoring assistance effort to determine level of significant noncompliance 

compliance/effectiveness of effort. violations. 

 As follow-up with nonresponders to an 

incentives letter. 

	 To follow up on citizen, employee, state, 

local, other federal agency tips or complaints. 

	 To determine compliance with 

regulations, often on a schedule that is mandated by the regulation or statute. 

Guide for Addressing Environmental Problems Through a Strategic Approach 
Element 3: Selecting, Sequencing a

Tool Primary Behavior 

Option 

Situational Considerations Audience Characteristic C

Compliance Encouragement  To encourage identification and 

Incentives correction of noncompliance and 

negative environmental impacts. 

 To encourage innovative appro hes to ac

environmental compliance or environmental performance. 

 As part of a stepped-up enforcement 

activity. 

 To promote increased self- or third-party

auditing. 

 To promote improved performance that 

goes beyond compliance. 

	 The noncompliance involv

programs and facilities. 

	 The sector consists of larg

smaller sources that the ahave enough resources to Economies of scale are p

	 The sector’s compliance h

that certain incentives are incentives will actually moperformance or changed 

	 The sector has well-define

trade associations) that aor maximize the potential assistance accessible. 

Enforcement Deterrence  When there is a threat or actual harm to  Parties have demonstrate

human health or the environment that achieve compliance volunrequires immediate correction. inspections reveal continu

 Where the cost of the remedy is within sector after a CA ef

expected to be high. facilities have a history of 

 When enforcement supports efforts of  If the violations are willful. 

other entities such as states or citi zengroups. 

 When the situation may set a 

precedent. 

 When the threat crosses state lines , is

regional in impact or has national implications. 

When considering enforcement as atool,

refer to U.S. EPA and state Enforcement Response Policies to assess agencies’ position on specific types of violations. 

Guide for Addressing Environmental Problems Through a Strategic Approach 
Element 3: Selecting, Sequencing a

Tool Primary Behavior 

Option 

Situational Considerations Audience Characteristic C

Innovative and Encouragement Sound Business Practices 

 To encourage innovative appro aches  To promote “greening init

and technology transfer that will with vendors/suppliers. improve environmental performance  To encourage mentoring beyond compliance. small, or leading and follo

 To encourage practices that will  If the facility, company or 

address both the facilities’ economic test or incorporate new buinterests and improvements to the environment such as pollution prevention, environmental management systems and best management practices. 

Guide for Addressing Environmental Problems Through a Strategic Approach 
Element 3: Selecting, Sequencing and Segmenting Tools 

Step-by-Step Process for Selecting Tools 

Tool selection is one of the most critical elements 

in the success of the strategic approach. 

Selecting the best option for behavior change 

requires review of, and cross-reference with, 

other key elements during the planning process. 

Provided here are suggestions and examples of 

the type of information to consider and the other 

elements in the strategy that you should consider 

in the decision-making process. 

Review the information acquired from the 1 baselining of the environmental 

problem(s) and the target audience(s). 

Map the target audience’s characteristics. 

Audience characteristics can include knowledge 

of their environmental responsibilities; level of 

sophistication to understand the problem; size 

and location of the potential target audience; 

available resources of each facility to address the This diagram focuses on tool selection and 

sequencing and highlights in gray the other problem in a timely manner; history of noncompliance elements that are particularly important during across and within the sector; willingness to partner the decision-making process for tool selection. 

with you to address the problem; target audience 

obstacles to overcome such as language, cultural and socioeconomic obstacles; and 

sector-market barriers such as high turnover, transient workforce, and organizational 

and structural makeup. 

Identify and justify segments or subpopulations that may need to be treated 

differently. For example, a target audience may have different skill and resource levels. 

Compliance assistance could be used for the facilities needing to understand the 

environmental requirements, while compliance monitoring could be used for the facilities 

possessing a higher level of sophistication and greater resource availability. 

Identify gaps where more information on the target audience is needed and 

identify the approach you will take to acquire that information. Some approaches to 

gathering more information may include focus groups with the target audience to identify 

the root cause of the problem and their compliance needs; meetings with trade 

associations to gain an overall understanding of the sector’s compliance issues and 

identify vehicles to communicate with the associations’ members; and meetings with 

other regulatory agencies that may have information on location of or compliance issues 

with facilities that are subject to other requirements and are not easily identified through 

typical channels. 

Review the overarching goals and measures of the strategy and select tools that 2 will meet those goals and address the target audience needs. For example, if the 

overarching goal is to reduce air toxics emissions by 700,000 tons over a two-year 

period, assess whether more than one tool will be needed to achieve such a goal. If 

Guide for Addressing Environmental Problems Through a Strategic Approach 3-7 
Element 3: Selecting, Sequencing and Segmenting Tools 

more than one tool is required (e.g., compliance assistance and enforcement) evaluate 

the tools’ impact on the target audience’s compliance and the collective contribution of 

the tools in meeting the goal. 

If you find that multiple tools will best address the environmental problem and 3 influence behavior change, plot the order of the tools (if sequencing), the 

relationship across tools (if segmenting), and the approach for transitioning tools. 

For each tool selected, research the potential available resources within and 4 outside of your agency. To the extent possible seek commitment from the 

appropriate authority. Do not assume that the expertise, material and funding will be 

available at the time of implementation. 

Challenges and Opportunities 

The following case examples and suggestions provide insight into the circumstances 

under which different types of tools have been used. They illustrate the Regions’ and 

states’ thought processes in responding to the questions: 

▪ Why was a certain tool(s) selected? 

▪ Why were certain tools used in a particular order or sequence? 

• Why were certain tools used for different sets within the target audience? 

There is often no single tool or clear set of tools that best addresses a problem 

and influences behavior change; however, these case examples can provide 

you with ideas on ways to most effectively address your environmental problem 

through use of a specific tool or sequencing of tools. 

Guide for Addressing Environmental Problems Through a Strategic Approach 3-8 
Element 3: Selecting, Sequencing and Segmenting Tools 

Challenge: How to address sector-wide compliance problems 

through sequencing of tools that will best address the 

environmental problem given the target audience’s 

characteristics 

Opportunities and Suggestions 

OECA’s Stormwater Compliance Integrated Strategy provides an example of how some 

of the compliance assurance tools were sequenced and the rationale for these 

decisions. The requirements for Phase I National Pollutant Discharge Elimination 

System (NPDES) storm water permit applications and coverage have been in effect for 

more than 10 years. EPA and states spent years educating industry about storm water 

compliance requirements ( compliance assistance efforts include numerous trainings, 

storm water web sites, public service announcements, guidance documents, fact sheets, 

brochures and model permits). Nonetheless, in 2000, many industrial dischargers were 

still illegally discharging storm water. In response, EPA sequenced from outreach and 

compliance assistance toward increased enforcement for industrial dischargers across a 

targeted watershed or geographic area or against a specific sector with potential for 

highly contaminated runoff. 

 Then, when the Phase II NPDES storm water requirements became effective in March 

2003, EPA again offered compliance assistance to all regulated entities affected by 

these requirements because they were new. 

Another approach to tool selection and sequencing is illustrated by the Indiana 

Department of Environmental Management (IDEM) Auto Salvage Yards program. IDEM 

received more than 100 individual complaints per year about auto salvage compliance 

issues. Armed with the knowledge that there was a compliance problem across a sector 

that had minimal resources and limited understanding of the requirements, but not aware 

of the breadth of the problem across the state, IDEM provided compliance assistance 

to all the auto salvage facilities in the state so that they could learn about proper 

environmental practices and make corrections. Following the delivery of assistance, 

they also conducted compliance monitoring to gather more information on all the 

potential facilities through aerial flyovers and multimedia inspections. These steps were 

followed by enforcement for facilities not taking the steps to comply. 

Challenge: When to consider addressing a sector-wide problem 

through segmentation of the sector universe 

Opportunities and Suggestions 

Not all of the target audience within a sector is subject to the same legal requirements 

due to a number of factors (e.g., facility size or age, location in a sensitive ecosystem 

area, additional state or local regulations). Moreover, there are sector characteristics 

(e.g., willingness to comply and take corrective action voluntarily, history of 

noncompliance, seriousness of violations identified, structural and organizational 

complexity of the facility) that will factor into treating facilities differently to achieve the 

same compliance goal. Assess the best tool mix for the target sector response by 

reviewing the legal requirements impacting the sector, and past compliance rates and 

current compliance issues. This type of assessment could help in your tool selection and 

Guide for Addressing Environmental Problems Through a Strategic Approach 3-9 
Element 3: Selecting, Sequencing and Segmenting Tools 

segmentation process. Below are two case examples. The first highlights legal 

requirements based on facility size, and the second emphasizes sector characteristics 

based on facilities’ complexities, resources and willingness to participate in the strategic 

approach. 

In the EPA Region 2/New York and New Jersey Technical Assistance Providers Initiative 

for 1400 Dry Cleaners, the Region distinguished the sector between small (one dry 

cleaning machine) and larger, “industrial”-sized facilities (four to six dry cleaning 

machines with small quantity generators of hazardous waste). Compliance assistance 

developed and delivered by EPA, the state and the dry cleaners association included 

multimedia information packets, workshops and on-site visits for all facilities to help them 

understand their regulatory requirements. In addition, EPA provided an incentive, 

promoting its Small Business Policy to encourage facilities to assess and change their 

operations. For this purpose facilities were treated differently or segmented based on the 

size of the facility. Small facilities were offered on-site compliance assistance, while the 

larger facilities received RCRA compliance monitoring inspections to address 

imminent environmental problems through timely enforcement. 

For the EPA Region 1 Colleges and Universities Initiative, the region developed a 

phased approach that segmented the use of the tools based on the characteristics of the 

subpopulations within the sector, such as varying size and institutional complexity, 

knowledge of environmental requirements, availability of resources, and seriousness of 

violations. Facilities had the opportunity to select which phase of the strategy would best 

fit their given characteristics. In doing so the entire sector could be addressed. The 

strategic approach was as follows: 

▪ Well-publicized enforcement presence to ensure accountability and address more 

serious violations 

▪	 Compliance assistance delivered through multiple vehicles to reach the entire 

audience 

▪	 Compliance incentive promoting EPA’s Audit Policy and encouraging facilities to 

self-regulate 

•	 Sound business practice promoting innovative approaches such as peer auditing 

and greening pilots on campuses to encourage sustainability and environmental 

stewardship. 

Guide for Addressing Environmental Problems Through a Strategic Approach 3-10 
Element 4: Establishing Roles and 

Assigning Responsibilities 

Objectives 

▪	 Discuss how to engage a team that will plan and implement the 

strategic approach. 

▪	 Provide a process for identifying the individuals and organizations to 

implement the strategy that have the desired expertise. 

•	 Identify challenges and opportunities in establishing and 

maintaining a team. 

Purpose 

This information on this element includes some of the considerations in 

assembling a team that is well suited to develop and implement the 

strategy as well as desirable attributes of potential partners. This 

element of the strategic approach corresponds to Element 7, “Involved 

Stakeholders and Roles and Responsibilities” of the Framework and 

Element 3, “Priority Setting,” Section E, “Assign Roles and Responsibilities,” of the 

Key Concepts 

Stakeholder: An individual or 

entity that has an interest in or 

is affected by the planning, 

implementation or results of the 

strategy. 

Partnerships: A commitment 

within or across organizations to 

leverage resources and 

expertise to address environmental problems. 

Collaborative Problem 

Solving: When affected stakeholders work together and bring 

their collective resources to 

solve common problems that 

cannot be solved individually. 

Template. 

After initially discussing the need to establish clear internal leadership roles, this chapter 

focuses on the wide range of external expertise available to engage in the strategy’s 

development and collaborate with you to implement the strategy. The goal for this 

element is to identify the internal and external team members that meet the needs of the 

strategy and ensure that each group (and member) has a clear understanding of their 

role. 

Approach 

Planning and implementing a strategy requires a team of experts 

with clearly defined roles and responsibilities. Also required is a 

team with the appropriate levels of knowledge and skill sets. 

Selecting the strategy’s leadership is the obvious first step to 

developing, implementing and adjusting the strategy. The 

leader(s) must have the time to work on the strategy, the ability 

to select team members and marshal available or needed 

resources. Finally, the leader(s) must have decision making 

authority or direct access to decision makers. 

Guide for Addressing Environmental Problems 4-1 
Element 4: Establishing Roles and Assigning Responsibilities 

The team leaders should select team members based on their knowledge of the 

problem, relationship to the target audience, resources allocated to plan and implement, 

and access to information. A core number of “permanent” team members will ensure 

continuity over the strategy’s life. The team may want to engage additional members on 

an intermittent basis to address challenges as they arise. 

External entities or stakeholders can also play an important role in the strategy. The role 

stakeholder’s play is defined by whom they are, the type and extent of interest in the 

strategy, your need for input and support, and how they are impacted by the strategy, 

including their ability to promote or change behavior associated with the environmental 

problem addressed. Examples of external stakeholders that could participate on your 

team and share in the success of the strategy include: 

▪	 Government agencies (e.g., federal, state, tribal, 

local, cross-border agencies with Canada and 

Mexico) 

▪	 Educational/academic institutions (e.g., colleges, 

universities, vocational schools, K-12 schools, 

research centers) 

▪	 Business community (e.g., industry, consultants, 

vendors and suppliers, economic development 

centers) 

▪	 Nonprofit organizations (e.g., trade and 

professional associations, advocacy groups, nonregulatory assistance organizations such as 

Small Business Assistance Providers and Small 

Business Development Centers) 

•	 Community groups (e.g., civic and community 

organizations, neighborhood associations) 

It is extremely important to engage potential 

stakeholders on your team early in the planning process and communicate with them 

throughout the strategy’s implementation. Without a feeling of ownership and a stake in 

the outcome – particularly when collaborative problem solving is the goal – buy in and 

success is illusive. The following table illustrates some of the considerations in whether 

to create partnerships, with whom you might partner and what the partner may have to 

offer to the strategy. 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategic approaches, we provide the following 

considerations for creating your team: 

▪ Identify a lead manager and staff who are 

responsible for coordinating and communicating 

with all of the managerial and staff partners 

throughout the planning and implementation 

process. 

▪ Identify internal or external partners that have 

(1) the requisite expertise and skill level to assist 

in addressing the problem or (2) an understanding 

of or sound relationship with the target audience. 

▪ Assign individual responsibilities that match the 

person’s skill level and knowledge and 

complement the responsibilities of the rest of the 

team; do not duplicate and do not underutilize. 

Considerations for Potential Partners to Fulfill Potential Partner’s 

Partnering Role Contribution to Strategy 

Limited baseline information State, tribal, and local Ambient environmental 

requiring outside data to governments monitoring data; facility 

assess breadth of problem and identification, contact 

scope of target audience information and profiles; 

discharge and emissions data 

and reports; enforcement 

and/or compliance histories 

Guide for Addressing Environmental Problems 4-2 
Element 4: Establishing Roles and Assigning Responsibilities 

Considerations for 

Partnering 

Potential Partners to Fulfill 

Role 

Potential Partner’s 

Contribution to Strategy 

National or regional 

compliance problem requiring 

substantial resources 

Other federal, state, or tribal 

agencies regulating the target 

audience 

Leveraging of committed 

resources for dual purposes or 

sharing of underutilized 

resources (FTEs, funds, 

equipment) 

Existing partnerships or 

networks in place to gain 

access to and more 

information about the target 

audience 

Trade and professional 

associations, economic 

development agencies, 

community organizations 

Facility identification, contact 

information and profiles; 

introductions to target facilities; 

onsite assistance at facilities, 

development of assistance 

material; monitoring of 

environmental improvements; 

providing venues for meetings 

and training 

Building capacity to share 

information with the target 

audience 

Understanding the target 

audience’s complexities that 

will drive improved 

performance and address root 

causes of the problem 

 Technological barriers to 

enhancing process and 

environmental performance 

 Small business or 

businesses with limited 

environmental expertise or 

resources 

 Culturally and linguistically 

diverse target audience 

Environmental problems with 

potential community impact or 

impact on business 

communities located in 

residential areas 

State, tribal, and local 

government, community 

groups, trade associations, 

regulated facilities 

Academic institutions, research 

centers, professional 

associations, small business 

assistance providers, 

vocational training centers, 

trade associations 

Local government, civic 

associations, community 

groups, local business owners, 

economic development 

agencies 

Leveraging of existing 

communication vehicles (e.g., 

newsletters, Web sites, 

meetings, site visits) to inform 

the target audience and 

interested stakeholders 

Technical and process 

assessments and assistance; 

small business assistance; 

vocational training; alternative 

communication vehicles to 

reach non-receptive members 

of target audience 

Conduct surveillance of the 

target audience; make 

informed consumer choices 

that impact the facilities (e.g., 

green dry cleaners); use 

community or business 

communication venues to 

publicize good environmental 

stewardship actions 

Guide for Addressing Environmental Problems 4-3 
Element 4: Establishing Roles and Assigning Responsibilities 

Step-by-Step Process for Developing a Team 

Creating a team that will complement each other and work together to address the 

ultimate goals of the strategy requires consideration of some of the other elements 

during the planning process. 

Provided here are suggestions and examples of 

the type of information to consider in planning for 

this element. 

Designate team leadership. Effective 1 leadership is essential to developing, 

implementing, and adjusting the strategy. The 

team leaders should set aside specific, dedicated 

time for the strategy and be available and ready to 

make decisions. Ultimately, the team leader(s) is 

responsible for each step in this chapter and those 

of Element 5 (e.g., developing and overseeing the 

implementation work plan and schedule). 

2 Identify the list of skills and expertise 

needed to understand the complexities of the This diagram focuses on identifying roles and 

environmental issue; have information about and assigning responsibilities and highlights the other 

elements that are particularly important during access to the target audience; and develop and/or the decision-making for this element. implement the identified compliance assurance tools. 

Identify potential partners (individuals where possible and organizations at a 3 minimum) with the desired skill set, knowledge and abilities. View broadly potential 

partners both within and outside your organization. The type of partners and the 

decision whether to expand your team to outside stakeholders is at the discretion of the 

strategy’s leaders. For example, if a more traditional approach such as enforcement only 

is determined to be the best approach, then your team will remain with the parties privy 

to the enforcement action. On the other hand, for strategies where you will use a 

combination of tools, such as compliance assistance followed by compliance monitoring, 

consider partnering with individuals or entities that have an established relationship with 

the target audience. 

Identify and commit resources. The strategy team should identify resource 4 needs and propose and confirm workforce deployment. The team leader will 

present these needs to final Agency decision-makers and share decisions that are 

made on resources to support strategy implementation with all team members. In 

addition to considering the information acquired at this point and any decisions on ways 

to implement the strategy, factor in the possibility that the strategic approach could 

change based on resource allocation and workforce deployment constraints. These 

limitations could be the ultimate decision on the makeup of your team. 

Guide for Addressing Environmental Problems 4-4 
Element 4: Establishing Roles and Assigning Responsibilities 

Work with the designated senior manager to execute the partnership for team 5 members from outside stakeholders, either by a written instrument (e.g., 

Memorandum of Understanding, Interagency Agreement), if the partnership is long 

term or complex, or by oral agreement if the partner’s role is short term or limited in 

scope. 

Challenges and Opportunities 

The following case examples and suggestions provide insight into creating, executing 

and maintaining effective teams. They illustrate some of the processes used by EPA 

Regions and states to identify partners and gain their commitment during the pilot phase 

of testing the Framework. The pilot participants were asked to answer the following 

questions: (1) how did you address challenges in developing and implementing your 

strategic approach; and (2) with limited resources, how did you work with other 

organizations to reach the desired outcomes? Their responses and examples may help 

you gain insight and ideas on some of the issues associated with team building. 

Challenge: How to work with partners where there are target 

audience complexities that need to be addressed to return to 

compliance 

Opportunities 

An obstacle that may hinder working with small business owners 

is the resource commitment to train and return owners to compliance. This concern is heightened when the business owners’ 

primary language is not English. To address a community-wide 

environmental issue, EPA Region 3, the Maryland Department 

of the Environment, the Park Heights Community Group and the 

auto body shops located in the residential neighborhood proved 

that working together would be beneficial for all involved. The 

federal and state regulators met with the community group and 

the auto body shop owners to evaluate the scope and causes of 

the issues, and to discuss the best approach to promote 

compliance. Through several meetings and site visits, trust grew, roles were defined and 

responsibilities were assigned. The community group members shared their knowledge 

of the shop owners; EPA led (with the participation by the state), inspections and 

assessed the owners’ understanding of their obligations; the state reviewed the 

inspection reports, led the development of an auto body shop compliance manual and 

conducted training for the shop owners. By working together and working directly with 

the owners of the facilities, the federal and state regulators were able to develop 

assistance material to address a target audience where English is a second language. 

This three-year partnership resulted in improved compliance by owners, monitoring of 

the owners’ compliance by the community group and the creation of an auto body shop 

owners’ association to train new shop owners. 

Guide for Addressing Environmental Problems 4-5 
Element 4: Establishing Roles and Assigning Responsibilities 

Each target audience has its own characteristics and complexities, but taking the time to 

meet with the audience, build the relationships and discuss options to improve 

compliance is a resource well invested. EPA Region 3, the Maryland Department of the 

Environment, and Maryland School Administrators and Teachers met to discuss the 

environmental issues placing their students at risk of accidental spills, hazardous waste 

mishandling and mold. While the federal and state regulators were working with the 

schools, they realized that there was limited knowledge of environmental requirements. 

During the next year all stakeholders participated in developing a program that would 

raise awareness and an understanding of the obligations to the environment and to 

schoolchildren. EPA took the role of conducting surveys to understand the schools’ level 

of understanding and was also the lead on developing a compliance workbook. The 

state reviewed the workbook including state-specific obligations, and the Maryland 

School Board reviewed it to ensure that it was in a language understood by the 

education community. While the state took the lead on conducting the training across 

Maryland, the School Board took advantage of existing networks and associations to 

market the training and share the workbooks. As a result of partnering and defining the 

roles and assigning responsibilities, the training was transparent and well received. 

Challenge: How to secure partners through trust in and 

ownership of the approach and outcome 

Opportunities 

Building capacity across all stakeholders impacted by an 

environmental issue may appear to be a daunting and 

unattainable task. However, if there is a clear goal, transparent 

approach and reasonable timetable, then creating and defining a 

partnership to complete that task could be quite easy. EPA 

Region 10, the Idaho and Alaska chapters of the Associated 

General Contractors (AGC), the Army Corps of Engineers, the 

Idaho and Alaska departments of transportation and local 

governments all had a hand in meeting the common goal of 

protecting water quality and preparing the construction industry 

for increased inspections. To prepare the industry for understanding their federal/state/local requirements, EPA and AGC worked cooperatively to 

develop and deliver workshops for the sector on National Pollutant Discharge 

Elimination System (NPDES) erosion, sediment and pollution control. All levels of 

government were present at the training and during the inspections. Working in tandem 

the inspectors provided their expertise on the different regulations and educated each 

other as well as the target audience. Recognizing the collaboration across the various 

regulatory agencies, AGC took the lead on hosting the training sessions and 

emphasized the importance of working together to increase awareness of the 

stormwater requirements. In the end, the partnership built trust and increased capacity to 

continue training and developing additional assistance material to be distributed by all 

parties engaged in this partnership. 

EPA Region 10 also used its partnership approach under a completely new set of 

circumstances and environmental issues. EPA responded to compliance issues on the 

Yakama Reservation in Alaska with increased oversight of pesticides application and 

worker safety practices. EPA’s efforts did not end there. By partnering with a local 

Guide for Addressing Environmental Problems 4-6 
Element 4: Establishing Roles and Assigning Responsibilities 

pesticide inspector funded through a tribal agreement, the Region was able to receive 

credible and timely information to pursue enforcement actions within the reservation. 

Providing the resources to the local inspector through a clearly defined written 

agreement, EPA relied on the expertise of the inspector and used its efforts on 

enforcement. Partnering between federal and local governments to achieve a common 

goal of worker protection on tribal lands generated cases with multiple violations by both 

tribal and nontribal owners. 

Guide for Addressing Environmental Problems 4-7 
Element 4: Establishing Roles and Assigning Responsibilities 

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Guide for Addressing Environmental Problems 4-8 
Element 5: Developing an 

Implementation Plan, Schedule and 

Milestones 

Objectives 

▪ Introduce techniques associated with effective planning. 

▪ Provide a step-by-step process to ensure successful planning 

and scheduling. 

• Identify key challenges and opportunities in planning and 

scheduling that may arise during the development and 

implementation of a strategy. 

Purpose 

The information on this element includes some common considerations associated with developing and implementing a work plan (plan 

and schedule). It also examines some common pitfalls associated 

Key Concepts 

Plan: A “detailed scheme, 

program, or method worked out 

beforehand for the 

accomplishment of an object.” 

The goal of planning is to 

ensure the development and 

implementation of a wellthought out strategic approach. 

Schedule: The “production plan 

allocating work and specifying 

deadlines,” which includes 

identifying roles and 

responsibilities. The schedule’s 

goal is to ensure process 

transparency, facilitate 

oversight and communication 

with key stakeholders, and 

provide opportunities to 

reassess and realign the plan. 

with planning and scheduling and identifies ways to ensure successful implementation. 

This element supports Element 6 of both the Framework and the Template, both titled 

“Schedule.” The goal of this element is to provide an overview of how to effectively plan, 

monitor and oversee a strategy. 

Approach 

The Team Leaders must commit to establishing and 

maintaining a work plan. 

One of the most effective ways to establish a work 

plan is for the team to “brainstorm” about the primary 

activities associated with each element of the strategy 

and the appropriate milestones for completing these 

activities. This will ensure the work plan is based on 

the team’s knowledge of the problem and that the full 

range of solutions are identified. During the 

brainstorming, activities should be grouped together 

so they either build on each other or are related in 

some way. Team Leaders should make final 

Key Considerations 

▪ Ownership/Engagement: The team leaders 

must assume overall l responsibility for the 

work plan and monitoring progress. Team 

members must be given ownership of specific 

tasks in the work plan. If only the managers 

or a few of the staff follow up on the work 

plan, many of the activities and the 

associated milestones will not be completed. 

▪ Updating of the Work Plan: Keep the work 

plan current because dates and tasks often 

evolve over time. 

▪ Format: Use a format (e.g., Microsoft Excel) 

for the plan and schedule that is optimal for 

the team and the managers. 

▪ Outside Forces: There will always be 

obstacles to implementation that are outside 

your control. Just expect them and work 

around them. 

Guide for Addressing Environmental Problems 5-1 
Element 5: Developing an Implementation Plan, Schedule and Milestones 

decisions about the work plan and assign specific team members responsibility for 

tracking tasks. 

Throughout the implementation of the strategy, Team 

Leaders should check in with the team member 

responsible for each task and make decisions on 

whether adjustments to specific activities or milestones 

are appropriate. 

Step-by-Step Process for 

Developing an Implementation 

Plan, Schedule and Milestones 

Provided here are suggestions and examples of the 

type of information to consider in planning for this 

element. See the sample work plan at the end of this 

chapter. 

Brainstorm the work plan. This diagram focuses on developing a workplan The team should 1 for the strategy and highlights in gray the other discuss the entire range of potential primary activities elements that are particularly important during to be implemented in the strategy. It is recommended the decision-making process for this element. 

that at least one face-to-face brainstorming session take 

place. 

Develop the work plan. The work plan is a functional calendar that contains the 2 primary elements and activities of the strategy. The work plan should be 

prospective, be built around specific calendar dates, and include each program activity 

and associated measure. At a minimum, the work plan should contain the following: 

▪	 Each program activity and associated deadline(s). Include a team leader and team 

member point of contact for each program activity. 

▪	 Each program measure and its associated method for tracking progress. Include a 

management and staff point of contact for each measure. 

▪	 New or existing mechanisms to track and measure results. 

▪	 The date and time for each activity and/or meeting. 

▪	 Dates to consider revising program activities, deadlines and measures. 

▪	 Baseline information. The work plan should include the baseline data used to 

establish the strategy’s activities and measures. Inclusion of baseline data is 

important to track performance according to the existing measures. 

•	 A formal evaluation phase so that team leaders and their managers can determine 

whether activities are being completed in a timely manner and, if not, why. The 

evaluation phase is essential to determine whether and when mid-course 

adjustments are required. 

Guide for Addressing Environmental Problems Through a Strategic Approach 5-2 
Element 5: Developing an Implementation Plan, Schedule and Milestones 

Including the following components will increase the work plan’s functionality and value: 

▪	 Information on relevant internal and external stakeholder meetings (e.g., of OECA’s 

Planning Council, states, tribes, the regulated community, nongovernmental 

organizations, including environmental justice communities). 

▪	 Anticipated timeframes for internal budget requests. 

▪	 Anticipated funding opportunities and associated deadlines for external grants and 

cooperative agreements. 

•	 Anticipated congressional or Office of Management and Budget hearings or 

requests. 

Team leaders assign activity and progress coordinators. For each strategy, the 3 team leaders should oversee each activity and assign a team member to “manage” 

each activity on a day-to-day (or regular) basis. See the chart on page 5 of this chapter 

for an example of how to create a Strategy work plan and monitoring progress. 

Together, the team leader and team member with oversight responsibility can. 

▪	 Focus additional attention in a particular area and develop (or apply existing 

expertise. 

▪	 Draft and maintain documents within their area of responsibility, including a record of 

all final decisions. 

•	 Track and report on issues within their area of responsibility, including designing 

necessary adjustments or other outstanding issues. 

▪ Scheduling meetings. 

Ensure team participation. Team leaders should ask team members for a 4 minimum level of commitment (e.g., average of X hours a week on the strategic 

approach or engagement in, or responsibility for, a certain number of projects each 

year). The commitment of hours would depend on the quantity of work to be done and 

the number of team members who are available. 

Review the activity milestones. Be pragmatic about the work plan’s timetable. 5 There are many issues outside your influence that affect the ability to accomplish 

activities and meet milestones. Revisit your milestones on a quarterly basis and update 

them as necessary and appropriate. 

Maintain regular communication and manage strategy documents. The 6 following are appropriate for each strategic approach: 

▪	 Establish regular conference calls. The frequency will depend on the issues to be 

discussed. 

•	 Make the work plan and all final documents available through a shared network 

directory. This will enable managers and staff to revise existing documents. 

Guide for Addressing Environmental Problems Through a Strategic Approach 5-3 
Element 5: Developing an Implementation Plan, Sch

Guide for Addressing Environmental Problems Through a Strategic Approach 

NATIONAL PERFORMANCE BASED STRATEGY - COMMUNICATION AND COORDINATION PLAN 

FY 2005 WORKPLAN CHAMPION: Sally Douglas HQ LEAD STAFF: David Painter REGIONAL LEAD STAFF

LEAD 

CURRENT STATUS TACTICAL STEPS 

OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN 

JUL

AUG

SEP 

David Ongoing Internal: conference calls every other week Starting conve

Team Leaders Team Team Managers 

Ongoing 

Internal: share Strategy with EPA regions. Internal use only 

Internal: get at least 2 more EPA regions to engage/participate 

Internal: brief senior managers 

Team ManageSpecifically - Ron the team) Meeting schedannually durin

Smith Internal: identify and select EPA advisory board What topics a

Team Leads Internal: scope & prepare for senior managers meeting: What outcome are we looking for? How can we get buy-in? By December

Team Leads Senior managers to meet with key internal & external partners 

Bobby Brown Carol Reese 

Ongoing 

Ongoing 

Stakeholders: identify key external stakeholders 

Stakeholders: Establish regular communication with key groups 

Stakeholders: Work with Department of Education on schools emphasis area 

Smith Press: draft & update communication material to share with stakeholders Jasper to beg

Sally Press: plan two events for FY 2005 -- D.C. and California May 5, 2005 Team Leads Press: Event on mid year & end of year successes 

Clayton Public meetings: Kansas (11/05); New York (1/06), Denver (3/06), D.C. 9/06) Identify 6/06 m

Sally Internet Portal: get senior management support &B check-in Sally will discu

Jim Smith Portal: What $ do we have? How do we get more? Can this wait u

how best to al

Smith & Hubert Smith 

Completed Portal: focus groups with key internal & external stakeholders 

Internet Portal - beta tests 

10/04/2004 D

Mary to send v

Smith Portal: go live with press event Hold in Silicon 
Element 6: Designating Resources/ 

Workforce Deployment 

Objectives 

▪	 Discuss how to assess what resources you need to plan, execute 

and measure the strategy. 

▪	 Provide a step-by-step process for identifying and leveraging 

available resources. 

•	 Identify challenges and opportunities in committing and effectively 

deploying available resources. 

Purpose 

The information provided on this element highlights considerations in 

securing the appropriate mix of resources necessary to implement the 

strategic approach. This element supports Element 5, “Resources,” of 

the Framework and Element 5, “Workforce Deployment Strategy,” of 

the Template. 

The goal is to ensure that the necessary resources are in place to operate an effective 

team that has the requisite skills, knowledge and experience to carry out its 

responsibilities. This element provides a broad overview of the types of resources that 

you may need to carry out the strategy. It also provides case examples to illustrate 

creative leveraging of resources, which are always at a premium. Using this element in 

combination with Element 4, Establishing Roles and Assigning Responsibilities, you 

should be able to effectively implement the strategy. 

Key Concepts 

Resources: The money and time 

dedicated to implementing the 

strategic approach, including 

management and staff time, 

professional services, equipment 

and supplies, travel or training. 

Funding Vehicles: Any agencyapproved agreement to commit 

resources. 

Human Capital: People with the 

skills, knowledge and experience 

needed to most effectively 

implement the strategy. 

Approach 

Identifying, leveraging and managing needed resources within and outside your 

organization is critical to ensuring that you can complete all the activities identified in 

your strategy to achieve your goal. The following are examples of the types of resources 

that you may need to utilize implementing the strategy: 

▪	 Funding Vehicles: Contracts, grants, interagency agreements, cooperative 

agreements. 

▪	 Human Capital Team: Internal and external partners that you select based on their 

skills, knowledge and experience. 

▪	 Professional Services: Agency contractors that are not team members but are 

providing certain types of services for the approach (e.g., laboratory services). 

Guide for Addressing Environmental Problems 6-1 
Element 6: Designating Resources/Workforce Deployment 

▪	 Supplies: Items needed to implement the 

strategy (e.g., vehicles, sampling equipment, 

computers, office supplies). 

▪	 Travel: Travel required for team members and 

contractors to conduct and implement certain 

elements of the strategy (e.g., inspections, 

investigations, site visits, workshops, meetings). 

•	 Training: Appropriate training for team members 

to help them understand the environmental issues 

(e.g., statute- or regulation-specific issues) and 

implement activities (e.g., safety training for 

inspections and hazardous materials), and for 

regulated entities as part of compliance 

assistance. 

To make planning for resources committed by others 

seem less daunting, be realistic about the type and 

amount of resources needed. Factor in unanticipated 

changes and prepare for contingencies. Moreover, 

work with your team to develop creative approaches for the unforeseen issues and for 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategic approaches, we provide the following 

considerations for designating resources and 

deploying your workforce: 

▪ The resource demands of the strategic approach 

will compete with other priorities and projects; you 

will need to assess available resources and 

clearly define and prioritize needs. 

▪ Invest in training as needed for team members 

and other appropriate staff before implementing 

the strategy. 

▪ When creating internal and external partnerships, 

work with the assigned senior manager to ensure 

that the partners have a clear and common 

understanding of the type of resources and timing 

of their use, as well as roles and responsibilities in 

implementing the strategy. 

resource constraints. To ensure efficient use of limited resources, take the time to 

assess the capacity of potential partners to contribute to the team and actually deliver on 

their commitment. Competing priorities and projects may hinder partners’ ability to 

implement elements in a timely way; creative management and leveraging of resources 

across partners or even with others in your organization may be necessary. 

The following are some considerations in planning for resource management. 

Considerations in Planning for Resources 

Developing Your Team 	 Assess in-house expertise available to implement each tool 

selected for the strategy. 

	 Identify and seek commitment from partners with the exper ience 

and capacity to implement the compliance assurance tools selecte d 

and measure success. 

	 Cross-train team members and other relevant staff who will suppo rt 

the strategy. 

	 Encourage team members to balance their time to work on other 

projects and to notify the team lead of time limitations. 

	 Set a schedule and adhere to it so that team members are 

available to implement tools at critical times. 

Guide for Addressing Environmental Problems 6-2 
Element 6: Designating Resources/Workforce Deployment 

Considerations in Planning for Resources 

Designating Your Resources  Coordinate work with other projects dealing with related areas or 

issues. 

 Identify and secure appropriate grants for states and other grant 

recipients. 

 Secure contract funds for specific needs of the team such as 

gathering data, defining the baseline or developing materials. 

 Prepare to make adjustments when capacity or funding is not 

available at critical points in the strategy. 

 Anticipate future resource needs for continuing or maintaining the 

strategy. 

Step-by-Step Process for Managing and Leveraging 

Resources 

Identifying resources and securing commitments 

is essential to the success of your strategy. The 

availability of resources can influence decisions 

about which tool or tools will be used to address 

the environmental problem. Provided here are 

suggestions and examples on the type of 

information to consider and the other elements in 

the strategy that should be considered in the 

decision-making process. 

Develop a complete list of resources and 1 expertise necessary to implement the 

activities of the strategy requiring such 

funds and/or expertise. In many cases these 

activities include collecting information to fully 

understand the scope of the environmental 

problem and address the target audience; 

analyzing data to determine the success of the 

strategy and measure its accomplishments; 

implementing any or all of the compliance This diagram focuses on designating 

assurance tools selected to address the problem; and resources/workforce deployment and highlights

the other elements that are particularly important training personnel in any of the previously mentioned during the decision making process for activities. resource designation. 

Match available internal resources to your 2 needs. Search both within your own office and across other offices within your 

organization to identify experts in the fields that you need (e.g., media-specific 

experts to help you and your team understand the appropriate regulatory requirements, 

inspectors to conduct inspections or investigations for baselining, compliance 

evaluations, and onsite visits). Also identify resources to be leveraged (e.g., existing 

grants or contracts that meet your scope of work and are not at capacity, other projects 

underway where activities can be coordinated such as tagging onto scheduled 

inspections or trainings). 

Guide for Addressing Environmental Problems 6-3 
Element 6: Designating Resources/Workforce Deployment 

3 Identify resource gaps where external partners will be needed. Some instances 

where gaps occur that could be fulfilled by external partners are: understanding the 

full scope of the environmental problem and the impacted audience; identifying existing 

compliance assistance material that can be modified for the strategy; securing venues to 

conduct training for the targeted audience. 

Develop a list of potential external partners and their capacities. Potential 4 partners can range from other federal, state or local agencies that also regulate the 

target audience, to trade associations able to provide additional information about the 

target audience. 

If you cannot retain all needed resources and experts or if you foresee 5 commitments that will be needed down the road to complete the strategy, identify 

the gaps and future opportunities for leveraging resources. For ease of 

implementation and to refresh your memory as you continue the strategy align these 

resource needs with the implementation schedule and milestones. 

Challenges and Opportunities 

The following case examples and suggestions illustrate some Regions’ and states’ 

experiences in identifying needed resources and the factors they considered in 

assembling the resources. It also looks at how they balanced existing resources for 

ongoing projects with the additional resources needed for the work by answering the 

questions: (1) What resources and deployment of resources were used to develop and 

implement the strategy; and (2) Was there an impact of deploying resources on this 

priority with regard to other priorities or projects? 

Challenge: Identifying efficiencies to reduce personnel burdens 

Opportunities and Suggestions 

The workforce is the most precious commodity we have to ensure that 

the environment is protected. However, there are not enough staff and 

not enough time for staff to carry out all the activities necessary to meet 

all needs. There are, however, creative solutions to build capacity. EPA 

Region 2 planned for the possibility that up to 480 healthcare facilities 

would self-disclose under EPA’s Audit Policy after the Region provided 

an incentive for facilities to report violations to the agency. To maximize 

limited resources, the Region developed a model agreement for 

healthcare facilities disclosing under the initiative. The Region also 

created a small, ad hoc team of multimedia experts to review all the 

disclosures. By streamlining the negotiation process and the 

management of audit disclosures through the use of the model agreement, the Region 

had a viable and efficient tool to address an entire sector without unduly impacting the 

inspection and enforcement presence. The results of the process yielded 143 

disclosures covering 540 facilities with 40 audit agreements, and 2,173 violations 

corrected. 

Guide for Addressing Environmental Problems 6-4 
Element 6: Designating Resources/Workforce Deployment 

 Another creative approach was demonstrated during the EPA 

Region 3 Schools Initiative. The region was aware that 

schools in Maryland and the District of Columbia had 

multimedia compliance issues and that these schools had 

limited understanding of regulations and limited resources to 

return to compliance. The Region, however, was not in a 

position to have full-time EPA employees focus the time 

required to identify the schools’ assistance needs. To continue 

with this effort, the Region hired a student intern to evaluate 

the schools’ compliance assistance needs. This cost-efficient 

approach allowed an intern to gain job experience while 

satisfying EPA’s resource need. In turn EPA reserved its extramural funds to develop the 

schools’ laboratory practices training, which was requested by the schools. 

Challenge: How to leverage committed resources to accomplish 

multiple objectives 

Opportunities and Suggestions 

Addressing new environmental issues does not always require 

commitment of additional resources. Be aware of work underway in 

your Region and state and take advantage of existing commitments to 

satisfy multiple objectives from a single task. The Oklahoma 

Department of Agriculture did just that when the state was trying to 

develop an inventory of large Concentrated Animal Feeding Operations 

(CAFOs) that may need to apply for National Pollution Discharge 

Elimination System (NPDES) permits under a soon-to-be released rule. 

Traveling across Oklahoma to inventory all the facilities was expensive. 

Since the state had partial delegated authority for NPDES, EPA Region 

6 and the state worked together and expanded the schedule of inspections to gather 

additional NPDES data while providing assistance on the new CAFO rule. Two hundred 

sixty facilities were inspected and added to the NPDES inventory with minimal additional 

resource expenditure. 

A similar approach was used by the New Mexico Environmental Department. The 

state developed compliance assistance material informing 150 CAFO facilities how to 

comply with the new NPDES general permits. In this case, the state took advantage of 

scheduled inspections of its inventory of facilities to optimize time and travel resources 

by providing compliance assistance information during the inspections. 

Guide for Addressing Environmental Problems 6-5 
Element 6: Designating Resources/Workforce Deployment 

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Guide for Addressing Environmental Problems 6-6 
Element 7: 

Communicating the Strategy 

Objectives 

▪	 Discuss how to communicate the strategy throughout its planning 

and implementation. 

▪	 Provide a process for selecting the communication vehicles that will 

most effectively convey information to various stakeholders. 

•	 Identify challenges and opportunities in planning and executing 

communication options. 

Key Concepts 

Communication Vehicle: Any 

form of media that will convey a 

message to the audience. 

Networks: Existing organizational groups that will assist in 

conveying the message. 

Purpose 

The information for this element will provide ideas on what type, in what form and when 

to convey messages about the strategy. Informing interested stakeholders throughout 

the planning and implementation process is important for transparency of the strategic 

approach. This section supports Element 8 of the Framework, “Communication,” and 

Element 5 of the Template, “Communication.” 

The goal for this element is to identify all the potential stakeholders, the type of 

information that will be of interest to them and the best vehicle to communicate that 

message. The information provided is intended to illustrate options and suggestions for 

effective communication on the strategy. The type of stakeholders, the role of the 

partners, the type of tools selected and your organization’s communication policies and 

procedures will factor into your decision on how to 

communicate the strategy. 

Approach 

Stakeholders within and outside of your organization 

will have varying levels of interest in the progress of 

the strategy. Depending on the type and scope of the 

environmental issue and the affected audience, the 

communication approach could be straightforward 

with clearly identified stakeholders and 

communication vehicles, or complex with a web of 

networks and organizations (see diagram). Work with 

the stakeholders to determine their particular 

interests. There are three levels of stakeholders 

involved in any strategy: 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategies, we provide the following considerations for 

deciding how, in what form and when to communicate 

the strategy: 

▪ Identify all potential stakeholders, the information 

of interest to them, and the communication vehicle 

for conveying the message. 

▪ Align the communication messages with 

milestones and other critical points during the 

strategy so as to promptly inform the appropriate 

stakeholders. 

▪ Work with the public affairs, press offices and 

Web-based coordinators so that you understand 

the press and publication parameters. 

Guide for Addressing Environmental Problems 7-1 
Trade: 

journals, 

websites, 

newsletter, 

etc. 

Business 

journals 

(national, 

regional), 

news 

outlets 

State Reg. 

Agencies 

(HQ and 

regional) 

Dept. of 

Commerce 

Element 7: Communicating the Strategy 

▪	 Internal Partners: Managers and staff within your office and organizations who need 

to be either engaged in the process or kept informed of progress. 

▪	 External Partners: Individuals or organizations that have committed to participating 

in the planning and/or implementation of the strategy (e.g., other regulatory 

agencies, trade associations or universities). 

•	 Public: Individuals or organizations that have an interest in the outcome of the 

strategy or have an interest in assisting (e.g., the public at large, community groups 

or neighbors). 

Communication Partners for Targeted Audience 

Trade Other Sister Vendors Lawyers 

Hotlines 

Universities 

(ind. ext, 

SBDCs) 

business 

State CA Consultants BNA, FR, EPA health/env.

providers etc. agencies 

Target 

Audience 

Associations Plants Plants 

Local 

groups 

MEP, 

Local 

These two stakeholder groups are differentiated by the involvement and role of the 

participants. External partners play an active role and contribute to the success of the 

strategy. The public does not generally play an active role in the planning and 

implementation, but should be kept informed of its progress and results. 

In addition, the type of communication vehicle used is just as important as the audience 

you address. Not all stakeholders receive their information using the same technology, 

and you may need to convey your message through more than one vehicle. Just as you 

created a team with various areas of expertise, identify communication vehicles that will 

best address your audience. 

Guide for Addressing Environmental Problems 7-2 
Element 7: Communicating the Strategy 

Communication vehicles to consider include the following: 

▪	 Mass media: Broadcast messages (e.g., Federal Register notices, 

advertisements/press releases, newsletters, agency/organizational/topical Web sites) 

▪	 Targeted media: Messages focused on specific audience or segments of an 

audience (e.g., emails, educational brochures, listservs, newsletters, trade shows, 

conferences) 

▪	 Targeted interactive: Messages focused on structured feedback from audience to 

presenter (e.g., Web-based tools, focus groups, face-to-face meetings, workshops) 

•	 Exclusive interactive: Messages focused on one target audience member at a time 

and may include exchange of confidential information (e.g., mentoring, partner 

meetings, facility visits, audits, hotlines, word of mouth) 

The following table illustrates some of the considerations in communicating your 

message and in deciding with whom and with what vehicle you would communicate. 

Communication Objective Audience for Message Vehicle to Communicate 

Message 

Notify the target audience of a 

new rule and/or compliance 

assistance tools 

Target audience Federal Register to put the target 

audience on notice, workshops to 

understand how to comply 

Promote participation in an 

incentive program 

Target audience Targeted mailing to those who can 

participate in the incentive 

Encourage attendance at 

compliance assistance training 

or workshops 

Target audience Listservs, trade media, emails 

notifying of the training, 

enforcement press release of 

similarly situated facilitates 

encouraging reluctant facilities 

Notify the public of significant 

enforcement actions 

Target audience/Public Press release to deter similarly 

situated facilities from noncompliant 

behavior 

Gain access to the target 

audience/business community 

and verify baseline information 

Target audience/Partners Face-to-face meetings, facility visits 

for interactive discussion on the 

target audience’s compliance 

issues 

Update partners on the 

strategy’s progress and 

resource allocations 

Partners Periodic meetings, conference 

calls, emails for a focused and goaloriented conversation 

Build trust with new or potential 

partners 

Partners Focus groups, meetings, 

workshops to demonstrate your 

interest in working with partners 

Guide for Addressing Environmental Problems 7-3 
Element 7: Communicating the Strategy 

Step-by-Step Process for Communicating the 

Strategy 

Upfront planning will advance your strategic goals 

by evaluating the most appropriate times to 

engage stakeholders in the strategy. 

Provided here are suggestions and examples of 

the type of information needed for effective 

communication on the strategy. 

Identify all the potential stakeholders. You 1 will identify potential stakeholders throughout 

the process of developing and implementing 

the strategy. Keep updating your list of 

stakeholders and their contact information as you 

go along. 

Identify vehicles and messages for 2 conveying information. Tailor the main 

points for the specific audience and frame 

them to have the desired impact (i.e., do not assume This diagram focuses on communicating the 

that you can always use the same message or terms strategy and highlights the other elements that 

are particularly important during the decision for different audiences). Tailor your communication 

approach for your stakeholders by considering the following: 

▪	 Understand your stakeholders and their culture. 

▪	 Note communication issues or barriers for each stakeholder group (e.g., your public 

audience’s primary language, access to different types of media). 

▪	 Work with stakeholder groups to address the communication issues. 

•	 Determine who on the team will be responsible for delivering the message. The audience may respond to the same message differently depending on who is the 

messenger. 

Align your messages with the milestones and critical points of the strategy so 3 stakeholders can be engaged in or notified of the strategy’s progress in a timely 

manner. 

Identify any resources to develop and deliver the message. Where multiple 4 communication vehicles are available and used by the audience, assess the relative 

cost effectiveness and timeliness of implementation. 

Develop the message and seek team, managerial and organizational approval 5 (if needed). Each organization has its own policies and procedures for external 

communications. Become familiar with them. 

Once conveyed, monitor and evaluate the messages and methods of delivery. 6 An idea developed during the planning phase may not be successful when you 

Guide for Addressing Environmental Problems 7-4 
Element 7: Communicating the Strategy 

implement it. You may need to consider revising the communication vehicle and/or 

message. 

Challenges and Opportunities 

The following suggestions provide insight into communication 

planning. They illustrate the Regions’ and states’ use of 

messages and mechanisms to communicate the strategy. The 

scope of the audience, the type of information to convey and the 

method of conveying information varies for each strategy. We 

hope that these suggestions will give you insight and ideas on 

some common issues associated with communicating the 

strategy. 

Challenge: How to efficiently and effectively target the message 

Opportunities and Suggestions 

Every communication option has strengths and weaknesses. Given limited resources, 

first consider existing agency communication vehicles and their availability for 

communicating the strategy. While press releases may appear to be high profile, in 

many cases their actual use by the agency may be limited (e.g., significant enforcement 

actions). EPA frequently uses the Web to post periodic updates on the implementation of 

its strategies and initiatives but for more time-critical or sensitive information, it may not 

be timely or appropriate. Sometimes the methods that require the least time and are 

most readily available to your team may be the best options. For example, develop and 

maintain an email group of all partners and another for interested stakeholders. With 

those groups in place, create periodic updates on the progress on, milestones of and 

modifications to the strategy. Moreover, inventory existing communication vehicles 

(newsletter, brochures) in your agency and the timing of their release so you can include 

your strategy’s information (e.g., updates, articles, contact information, URLs) in them. 

An example of this is the March 2003 edition of the Enforcement Alert newsletter 

(Attachment E). This newsletter provided a mechanism to highlight the environmental 

problems posed by sanitary sewer overflows, and to highlight the strategic use of EPA’s 

enforcement and compliance assistance tools being implemented during that time frame 

to address the problem. 

Challenge: How to identify the message and vehicle for the 

target audience 

Opportunities and Suggestions 

Develop a communication approach that can be used when and where the target 

audience will have heightened interest in the strategy and be able to act upon the 

information conveyed. This means studying the recipients of the message to determine 

their education and behavior status, and identifying what points in the strategy are most 

Guide for Addressing Environmental Problems 7-5 
Element 7: Communicating the Strategy 

effective for conveyance. Because individuals who will react to messages and take steps 

to address the message are located throughout an organization, you should identify 

existing communication networks within the organization to have the broadest impact. 

Guide for Addressing Environmental Problems 7-6 
Element 8: Monitoring and Evaluating the Strategy 

Element 8: Monitoring and Evaluating 

the Strategy 

Objectives 

▪	 Define evaluation and its relationship to measurement 

▪	 Describe major steps in conducting an evaluation 

•	 Identify key challenges and opportunities in evaluating the 

effectiveness of the strategic approach in addressing the 

environmental problem(s). 

Purpose 

The goal of this element is to: 

▪	 Assess whether progress has been made throughout the interim 

stages of the strategy and if so, why. 

▪	 Identify whether some elements or aspects of the strategic 

approach are working but not others, and if so, why. 

Key Concepts 

Evaluation: A systematic study 

that uses objective 

measurement and analysis of 

answers to specific questions 

that explain how well a 

program, strategy or approach 

is working to achieve its 

outcomes and why. 

Formative Evaluations are 

intended to inform and improve 

the approach while it is still 

being designed or during 

implementation. 

Summative Evaluations are 

intended to make judgments 

about the approach after it has 

been established for some time 

or has ended. 

•	 Determine the overall effectiveness of the strategic approach. 

This element supports Element 8 of the Framework, “Monitoring & Evaluation 

Processes,” and Element 3 of the Template, “Priority Strategy.” This element differs 

from Element 3 in that you are not evaluating progress towards the strategies goals but 

rather the overall strategic approach itself. 

Broadly defined, evaluation and measurement are a systematic way to learn from past 

experiences. The terms “evaluation” and “measurement” are not synonymous but are 

closely related. Measurement is the ongoing monitoring and reporting of accomplishments, particularly progress toward established goals. Measurement provides a picture 

of “what is” but not “why it has occurred.” Measurement data provide information needed 

to conduct an evaluation and assess the overall effectiveness of the approach, program 

or project being evaluated. In this Guide we will focus on EPA’s strategic approach as 

the object of evaluation. The following table further illustrates the relationship and some 

of the differences between measurement and evaluation: 

Guide for Addressing Environmental Problems 8-1 
Element 8: Monitoring and Evaluating the Strategy 

Measurement Evaluation 

Ongoing monitoring and reporting of 

accomplishments. 

In-depth, systematic study that is conducted 

periodically or on an ad hoc basis. 

Examines achievement of the strategic 

approach’s goals. 

Examines a broader range of information on 

performance than is feasible to monitor on an 

ongoing basis. 

Describes achievements in terms of outputs and 

outcomes in a given time against a preestablished goal. 

Explains why the results occurred. 

Presents a picture of what is happening at various 

points in time. This picture can give management 

an early warning about potential problems. 

Longer-term review of effectiveness. 

Approach 

There are different types of evaluation that EPA or state agencies could apply to the 

design, development and implementation of the strategic approach to address 

environmental problems. Evaluations are generally categorized as either formative or 

summative. These categories typically describe how the evaluation results will be used. 

Formative evaluations inform and improve the strategy or strategic approach while it is 

still being designed or during implementation. Summative evaluations make judgments 

about the approach after it has been established for some time or has ended. 

Additionally, an evaluation can focus on one or more aspects of the strategic approach. 

An evaluation can be one or a combination of these types. Following are descriptions of 

these types: 

Formative Evaluations 

•		 Design evaluation focuses on the theory behind the integrated approach—given the 

context, is it reasonable to expect that the proposed activities will yield needed 

changes? Is the approach conceptually sound? 

•	 Process evaluation answers questions about how the strategic approach operates 

and documents the procedures and activities undertaken. 

Summative Evaluations 

▪	 Outcome evaluation answers questions about whether the approach has achieved 

its expected goals and results. 

▪	 Impact evaluation focuses on questions of causality. It attempts to establish cause 

and effect by linking observed outcomes, changes or improvements in the condition 

of the environment to the specific actions of the approach. An example of this would 

be to evaluate the individual contributions of each compliance assurance tool 

identified in the strategy toward achieving the goals. (Not sure if these is really a 

good example of impact.) 

•	 Cost evaluation addresses how much the approach or its components cost, 

preferably in relation to alternative uses of the same resources and to the benefits 

that the approach is producing. 

Guide for Addressing Environmental Problems 8-2 
Element 8: Monitoring and Evaluating the Strategy 

In planning an evaluation, you must determine whether the evaluation will have a broad 

or narrow scope. For instance, a summative evaluation can be designed to include 

outcomes, impact and costs or focus on only one of these aspects. 

Remember, a good evaluation can: 

▪	 Ensure that you are meeting the goals of your approach. 

▪	 Determine whether allocated resources are yielding the greatest environmental 

benefit. 

•	 Identify what works well, what does not and why; and answer questions such as: 

- What internal and external factors influenced performance? (Retrospective) 

- What effect will this level of performance have on future performance if the 

approach or activity is not modified? (Prospective) 

Step-by-Step Process for Evaluating the 

Effectiveness of the Strategic Approach 

Whatever type of evaluation you plan, the basic steps remain the same: 

Step 1: Develop an 

Evaluation Plan 

Step 2: Describe What 

Is Being Evaluated 

Step 3: Develop 

Evaluation Questions 

and the Evaluation 

Design 

Step 4: Collect Data 

Step 5: Analyze the 

Data 

Step 6: Present the 

Evaluation Results 

Develop an evaluation plan. The evaluation plan serves as the “roadmap” for 1 conducting the evaluation. To develop the plan, you will need to concurrently 

iden fy the key stakeholders involved in the evaluation. These include individuals ti

responsible for designing and conducting the evaluation and reporting the results; 

people who have an intimate knowledge of the approach being evaluated; and other 

individuals who have a vested interest in the conduct or impact of the strategy. The 

evaluation plan should include the following components: 

▪	 Purpose of the evaluation 

▪ Primary audience 

▪	 Design of the evaluation 

Guide for Addressing Environmental Problems 8-3 
Element 8: Monitoring and Evaluating the Strategy 

▪ Evaluation questions 

▪	 Roles and expectations for evaluators, staff, 

participants and key stakeholders 

▪	 Data collection/analysis process and protocols 

▪ Reporting 

▪	 Resources (staff and budget) 

▪ Timeline 

• Communications 

2 Describe the strategic approach. It is often 

very difficult to evaluate a program, project or 

approach that you don’t understand. Having a clear 

picture and understanding of how a program is 

designed to operate is an essential step of 

conducting an evaluation. The description of the 

subject of the evaluation can take many forms but 

should, at a minimum, identify what it consists of, This diagram focuses on monitoring and 

evaluating the strategy and highlights in gray how it is implemented and who the target audience or the other elements that are particularly customers are, and should include a description of important in evaluation. key activities and expected outcomes. One approach 

that EPA has used to graphically illustrate the subject of the evaluation is the logic 

model.

1

 While there are many ways to implement this step, we will use the logic model 

as an illustrative example. The logic model illustrates the logical and causal relationships 

among elements of the approach 

and the problem to solve, thus 

defining measures of success. It 

synthesizes the key activities 

intended to achieve the goals of 

the approach into a picture linking 

inputs to activities and to expected 

outputs and outcomes. 

3 Develop evaluation 

questions and the 

evaluation design. 

Evaluation questions are the 

broad questions the evaluation is 

designed to answer. They should 

reflect the general objectives of the 

evaluation and should address 

what is important for your 

audience to know about the 

strategic approach. Determine 

what your stakeholders need to 

2

Logic Model 

Long-term 

Outcomes 

Intermediate 

outcome 

Short term Resources Activities Outputs Customers outcome

HOW WHY

PROGRAM STRUCTURE 

OUTCOME STRUCTURE 

EXTERNAL CONDITIONS INFLUENCING PERFORMANCE (+/-) 

A logic model is a diagram and text that illustrates/describes the 

logical ( lationships among elements and the 

to be achieved 

causal) re program 

results 

Sphere of 

Influence 

I 

N 

D 

I 

C 

A 

T 

O 

R 

S 

1

Adapted from “Introduction to Program Evaluation” training course material developed by EPA’s National 

Center for Environmental Innovation, September 2005. 

Guide for Addressing Environmental Problems 8-4 
Element 8: Monitoring and Evaluating the Strategy 

know, and for what purpose and in what format they need the evaluation information. 

Also decide on the scope of the evaluation—is it formative or summative (i.e., does it 

address design, process, outcomes, impact or cost)? 

In identifying the evaluation questions, remember to: 

▪	 Review the goals of the strategic approach and the evaluation. 

▪	 Generate a potential list of questions. 

▪	 For each question, ask, “Why is the question important? How will the information be 

used, and by whom?” 

▪	 Identify the standard or baseline that you will use to assess the information. 

▪	 Assess feasibility of the question in terms of data collection, analysis and reporting. 

▪	 Select the final list of questions. 

▪	 Consult management and stakeholders. 

•	 Revisit your questions periodically and continue to consult management. 

The following table provides sample evaluation questions to ask when designing the 

evaluation: 

Sample Evaluation Questions2 

Approach 

Elements 

Resources/ Activities/ Target 

Audience 

Short-term Intermediate Long-term 

Inputs 

(We use 

these) 

Outputs 

(to do these 

things) 

(for these 

people) 

Outcome Outcome Outcome 

Evaluation 

Questions 

 Do we 

have 

 Are we 

doing things 

 Are we 

reaching 

 Did the 

target 

 Is our 

audience 

 What 

changes in 

enough? the way we our target audience’s using the condition 

 Are they 

the right 

ones? 

 What level 

is needed? 

 Is there 

consistency? 

 Why or 

why not? 





say we 

should? 

 Are we 

producing 

results at the 

level 

anticipated? 

 Are we 

producing 

results 

according to 

anticipated 

quality 

indicators? 

audience? 

 Are we 

reaching 

the 

anticipated 

number? 

 Are they 

satisfied? 

 Why or why 

not? 



understanding, 

knowledge, 

skills or 

attitude 

change? 

 What 

evidence do 

we have 

that the 

approach 

caused the 

desired 

changes? 





information, 

knowledge, 

skills and/or 

attitude 

change as 

expected? 

 With what 

results? 

 Is the 

audience 

changing 

behaviors/ 

practices in 

the 

(environment) have 

occurred? 

 Why? 

 Why or why 

not? 

expected 

direction/ 

level? 

 If so, what 

did we do in 

relation to 

the 

changes? 

2

Adapted from “Introduction to Program Evaluation” training course material developed by EPA’s National 

Center for Environmental Innovation, September 2005. 

Guide for Addressing Environmental Problems 8-5 
Element 8: Monitoring and Evaluating the Strategy 

Approach 

Elements 

Resources/ Activities/ Target 

Audience 

Short-term Intermediate Long-term 

Inputs 

(We use 

these) 

Outputs 

(to do these 

things) 

(for these 

people) 

Outcome Outcome Outcome 

External What factors might influence the success of the strategy? 

Conditions 

Remember that questions that attempt to establish a direct cause/effect link between the 

strategic approach and observed outcomes pose the greatest challenge and require a 

well thought out evaluation design. 

Evaluation design refers to the plan or protocol you will use to ensure that the 

evaluation’s results are reliable and valid. The goal of evaluation design is to rule out 

other possible explanations in order to state (with a high level of confidence) that your 

strategic approach caused the observed impact. There are a number of evaluation 

designs, including experimental with control groups, non-experimental and case study 

designs. Select the design that will provide the appropriate level of reliability and validity 

you need to support your evaluation results and any claims you want to make about your 

approach. Evaluation design is important because it helps strengthen the credibility of 

the evaluation, provide confidence in the results of the evaluation and respond to 

challenges that critics might have about the validity of the evaluation results. 

In selecting an evaluation design, consider the internal and external validity of the 

design. Internal validity asks, how sure are you that the action you undertook made the 

difference in this specific experimental instance? External validity asks, how sure are 

you that you can generalize these findings to other populations, settings and treatment 

variables? In general, the more you control the internal validity (controlling external 

influences to be sure that the action is indeed what “causes” the “effect”), the less you 

are able to control for external validity.3 

Collect data. Data collection usually involves collecting both qualitative and 4 quantitative data. Qualitative data are subjective and can come from observations, 

interviews, and descriptions of actions or processes. Quantitative data are numerical and 

can be collected from tests, reports, surveys and existing databases. 

Methods used to collect data include questionnaires, surveys, 

checklists, interviews, document review, direct observation, focus 

groups and case studies. If you use methods such as questionnaires or 

focus groups, data collection includes writing and carefully crafting 

questions to administer to your test group. Ideally, you should pretest 

your data collection instrument to be sure it is clear and provides 

unambiguous responses wherever possible. 

Analyze the data. To make the raw data meaningful, you must 5 analyze them. Data analysis is a complex but important task that 

involves comparison and scrutiny of the data to enhance interpretability. 

Perform analysis throughout the life cycle of your strategy, not just at 

the end. You will need as much time for analysis as you took to collect 

Tips on Data Collection 

▪ Use both qualitative and 

quantitative data. 

▪ Gather data from multiple 

sources. 

▪ Use one data collection 

process to meet the needs 

of multiple evaluation 

questions if possible. 

▪ Weigh the costs and 

challenges against the 

benefits of the data 

collection methods. 

3

Adapted from Campbell and Stanley, Experimental and Quasi-Experimental Designs for Research. Rand 

McNally, 1966. 

Guide for Addressing Environmental Problems 8-6 
Element 8: Monitoring and Evaluating the Strategy 

the data. Following are a few basic guidelines for analyzing evaluation data.4 

▪	 Review for consistency and accuracy: Perform additional checks to ensure the 

accuracy and consistency of the data, and eliminate incorrect or insufficient data. A 

simple scan of data will usually reveal extreme data points or values that are 

inaccurate. 

▪	 Use all relevant data: In most evaluations, the person conducting the evaluation 

desires positive results, which may provide a built-in bias. It may be tempting to 

eliminate data that do not support the desired outcome. For a valid analysis, use all 

relevant data. If not, explain why they were deleted. 

▪	 Treat individual data confidentially: Frequently, data collected will be the result of 

individual performances. In analyzing and interpreting the data and reporting results, 

maintain the confidentiality of the individuals. 

▪	 Use the simplest statistics possible: You can use a variety of statistical 

manipulators to compare changes in performance. Keep the analysis as simple as 

possible and confine it to what is necessary to draw the proper conclusions from the 

data. 

The use of statistics in evaluation serves the following primary purposes: 

▪	 Enables large amounts of information to be summarized: There are two basic 

measures used in summarizing evaluation data. One is the measure of central 

tendency, usually the mean, less often the median and mode. This measure 

presents, in a single number, a summary of the characteristics of the entire group, 

such as the average compliance rate of a group of facilities. The second measure is 

the dispersion, or variance, which is usually measured by the standard deviation. 

This reveals how much the individual items in the group are dispersed. 

▪	 Allows for the determination of the relationship between two or more items: In 

analyzing data, the relationship between one or more items may be important. The 

term used for this relationship is correlation, which represents the degree to which 

the items are related. A positive correlation between two items means that as one 

item increases, the other increases. For example, if the owner of a dry cleaning 

facility receives a high posttest score at a course on environmental requirements for 

dry cleaners, this high score might correlate to better compliance back on the job. 

There can also be a negative correlation between items (i.e., as one item increases, 

the other decreases). In this case, the correlation coefficient would be negative. 

•	 Shows how to compare the differences in performance between groups: When 

performance improves after EPA has implemented the strategic approach, you are 

likely to be asked: “Did the improvements occur because of the approach, or could it 

have occurred by chance?” In other words, without the program, would the same 

results have been achieved? How accurately can the conclusions be drawn? 

Statistics enable you to place a confidence level on your conclusions about the 

differences in groups of data. 

Statistics also allow you to make comparisons to show trends over time and actual 

performance against targets. Finally, remember to include multiple sources of data 

whenever possible to strengthen and validate a particular finding or conclusion. 

4

Leonard Nadler, The Handbook of Human Resource Development. John Wiley & Sons, 1984. 

Guide for Addressing Environmental Problems 8-7 
6 

Element 8: Monitoring and Evaluating the Strategy 

Present the evaluation results. Choose the format for presenting the data and any 

findings based on your audience, the nature of the data and the way that the 

information will be used. Most importantly, select a presentation method that will 

clearly communicate the results of your evaluation. There are several environmental 

evaluation reports on EPA’s Web site at www.epa.gov/evaluate that you may find useful 

to reference. This site provides a few examples of evaluation reports that have focused 

specifically on the results of using compliance assurance tools. One is an evaluation of 

Oregon’s Toxic Use and Waste Reduction Assistance Program (see 

www.epa.gov/evaluate/tuwrap1.pdf). The other is EPA New England’s (Region 1’s) 

evaluation of its Colleges and University Initiative in 2003. This initiative was also one of 

the national strategic approach pilots. This evaluation focused primarily on one of the 

tools the Region used to address the environmental issues at colleges and universities; 

namely, the self-audit compliance incentive tool. As an example of how evaluation 

results can be presented, excerpts from the Executive Summary of the Region 1 

evaluation follow; for the complete evaluation report, see 

www.epa.gov/newengland/assistance/univ/pdfs/Final-CU-Initiative-Evaluation6-03.pdf. 

Colleges and Universities Evaluation Executive Summary 

The New England Colleges and Universities Initiative (the C/U Initiative) 

provides compliance information and training to C/Us; promotes innovative 

self-audit and environmental management system (EMS) initiatives; and 

encourages environmental best management practices. The overall goal of the 

program is to improve environmental performance at C/Us while enhancing 

environmental awareness on campus. 

EPA New England developed an evaluation of the C/U Initiative, focusing 

primarily on the Audit component, under which participating schools were 

given low inspection priority and reduced penalties in exchange for completing 

self-audits of their facilities. The evaluation was based primarily on a survey of 

52 C/Us participating in the Audit component of the Initiative, as well as on a 

series of additional interviews with regulators and schools that chose not to 

participate in the program. 

The objectives of the evaluation were to help determine if C/Us were implementing 

preferred environmental practices as a result of the C/U Initiative; examine the factors 

that motivated C/Us to take part in the program; and consider the applicability of the C/U 

Initiative approach to other EPA Regions or other sectors of the regulated community. 

The evaluation yielded a variety of findings and conclusions about the effectiveness of 

the C/U Initiative: 

▪	 Program incentives encouraged participation: Roughly half of all New England 

C/Us took part in the Audit Initiative. While the threat of enforcement actions 

encouraged many C/Us to participate, nearly all C/Us were motivated by the 

incentives offered under the Audit Initiative, particularly the desire to achieve a lower 

inspection priority. 

▪	 Participants addressed violations identified in self-audits: About three-quarters 

of the Audit Initiative participants implemented short-term corrective actions to 

address problems found in their self-audits. Common actions included waste 

labeling, spill prevention and waste removals. 

Guide for Addressing Environmental Problems 8-8 
Element 8: Monitoring and Evaluating the Strategy 

▪	 Participants are implementing long-term environmental management changes: 

Rather than simply implementing “band-aid” corrections to issues uncovered in 

audits, nearly all of the Audit Initiative participants are implementing long-term 

environmental management improvements. Common changes include improved 

recordkeeping and information management, labeling programs, and enhanced 

training requirements. 

▪	 Participants intend to perform audits in the future: As further evidence of the 

potential for the Audit Initiative to yield future dividends, more than three-quarters of 

the schools surveyed intended to perform additional self-audits in the future. This 

finding demonstrated that, although participants found the self-audit process 

demanding, it was valuable and worth repeating. 

▪	 Participants find outreach tools useful: Survey respondents voiced satisfaction 

with the technical support efforts that EPA has taken as part of the overall C/U 

Initiative. Respondents cited the workshops, the common violations list, the 

regulatory interpretations and the summary of the SPCC regulations as being 

especially useful in completing self-audits. 

•	 Many schools are implementing or considering EMSs: Nearly half of the survey 

respondents are implementing, planning or considering an environmental 

management system. These schools cite the self-audit process and EPA’s overall 

educational efforts as influencing their decision to explore EMSs. This finding 

suggests that EPA efforts to increase awareness and encourage adoption of EMS 

are succeeding. However, most schools are in an early stage with their EMS and 

were not yet able to identify specific benefits yielded by the approach. 

Two factors appeared to be most responsible for the success of the C/U Initiative. First, 

the C/U sector has characteristics that are highly conducive to a self-auditing approach. 

Key features of the sector include the technical sophistication of decision makers (e.g., 

Environment, Health and Safety staff); sensitivity to public image; peer pressure 

between schools to maintain clean environmental records; and a mutually supportive 

exchange of technical information between schools. Second, the C/U Initiative was well 

managed and administered. State regulators and other stakeholders complimented 

EPA’s management of the program, highlighting EPA’s willingness to coordinate with the 

states, the open information exchange between EPA and the C/Us, and the quality of 

EPA outreach efforts such as workshops and guidance materials. By providing C/Us with 

a point of contact at the Agency, the program has improved communication and 

coordination between EPA and the C/Us. This positive rapport represents a noteworthy 

contrast to the adversarial relationship that often prevails in regulatory programs and has 

contributed to the overall success of the C/U Initiative. EPA may wish to consider ways 

in which it can maintain this relationship through a continued presence in the C/U sector. 

The evaluation also considered whether the self-audit approach could be readily 

transferred to other regulated sectors or other EPA Regions. Based on a qualitative 

review of the extent to which other sectors have features similar to the C/U sector, it 

appears that the approach may hold promise for sectors such as hospitals and research 

labs. In particular, these sectors possess the structure (e.g., many geographically 

scattered facilities), technical sophistication and image sensitivity that characterize the 

C/U sector. Likewise, several other EPA Regions are already applying the self-audit 

approach to manage compliance at C/Us. The success of these efforts has yet to be 

determined, but it is possible that the dominance of large, public university systems in 

Guide for Addressing Environmental Problems 8-9 
Element 8: Monitoring and Evaluating the Strategy 

some Regions may offer advantages (e.g., resource sharing, system-wide auditing) not 

realized in New England, where smaller, private campuses dominate. Overall, it was 

recommended that relevant Regions implement a comparative analysis of the self-audit 

programs completed thus far in order to identify key determinants of success that may 

guide future initiatives. 

In summary, this evaluation indicated that the New England C/U Initiative had 

successfully realized its key objectives, achieving compliance and environmental 

benefits with limited enforcement resources. Participants have implemented numerous 

corrective actions in response to audit findings and also have introduced long-term 

management changes designed to improve environmental performance. Collaboration 

between EPA and the schools has been extensive, and the participants speak highly of 

the technical support they have received. This collaboration allowed C/U environmental 

managers to meet their obligations and, in some cases, to move beyond basic 

compliance and institute innovative measures such as environmental management 

systems. 

Challenges and Opportunities 

Challenge: Lack of Agency experience and expertise in 

conducting evaluations 

Demand for information about the performance, operation and results of EPA programs 

and strategies has continued to increase. However, EPA has undertaken evaluation on 

an informal basis, and evaluation expertise has been limited. 

Opportunities and Suggestions 

The Government Performance and Results Act (GPRA) has served as a driver for EPA 

to focus on more systematically using evaluation. GPRA requirements to measure 

program results, outcomes and performance in terms of goals and measures are 

creating an opportunity for the Agency to think more critically about the underlying logic 

of its programs. Program evaluation can help identify program impacts, reasons for 

observed outcomes and how programs can be improved. However, program evaluation 

should be viewed in a context broader than GPRA alone. 

Other drivers for conducting program evaluation include the Office of Management 

and Budget’s (OMB) Program Assessment Rating Tool (PART). The PART is used 

to assess and evaluate programs across government and emphasizes use of 

“independent and quality evaluations” to determine if programs are effective and 

achieving results. 

The President’s Management Agenda (PMA) identifies five areas for improving the 

management and performance of the federal government using a scorecard to rate 

federal agencies on each initiative, giving a “score” of red, yellow or green. 

Program evaluation provides a range of strategies that can support the ongoing 

performance measurement that is required under GPRA and the other drivers discussed 

above. By constantly evaluating its environmental programs, EPA can capitalize on 

Guide for Addressing Environmental Problems 8-10 
Element 8: Monitoring and Evaluating the Strategy 

lessons learned and incorporate that experience into other programs and environmental 

arenas. 

To assist in these efforts, EPA’s Evaluation Support Division (ESD) in the National 

Center for Environmental Innovation is working to identify, build and leverage evaluation 

capacity throughout the Agency. This work demonstrates how program evaluation can 

be a valuable tool and an integral component of the Agency’s emerging results-based 

management framework. 

ESD has taken a leadership role in identifying and building evaluation skill and 

knowledge throughout the Agency through a number of activities. These have included: 

▪	 Co-chairing the EPA Program Evaluation Network. 

▪	 Designing and conducting evaluation training. 

▪	 Serving as an advisor to program offices conducting evaluations. 

▪	 Networking with state, academic and other program evaluation practitioners outside 

EPA. 

•	 Serving as an information clearinghouse for information resources encompassing 

program evaluation standards, tools, journals and associations. 

In continuing to build capacity for program evaluation in the Agency, ESD will continue to 

identify and disseminate knowledge of evaluation, and harness diverse information 

resources and tools. Environmental program evaluation has recently emerged nationally 

as a recognized sub-discipline that applies the principles and approaches of traditional 

program evaluation, tailored to the specific needs and challenges of environmental 

policy management. Go to www.epa.gov/evaluate for an extensive listing of evaluation 

resources. 

Challenge: Lack of data needed for evaluations 

Data collection is an ongoing problem for the Agency’s measurement and evaluation 

efforts. The availability of quantifiable data on environmental results to tie to the 

implementation of EPA’s strategic approach has been highly variable. When an activity 

or approach results in a change in the level of emissions or discharges that are already 

being monitored and tracked for regulatory purposes, data are easily obtained. However, 

if the approach is aimed at an environmental problem for which few or no data exist 

(e.g., non-point source pollution), it will be more difficult to quantify the level of 

improvement through environmental indicators directly related to the implementation of 

the approach. 

EPA has relied on qualitative and anecdotal data for many efforts. Lessons learned 

and information on how people involved with the strategic approach perceive it to 

be working are of some value. But even that information may be difficult to gather. 

For example, during the pilot phase when the Framework was being tested, EPA 

attempted to evaluate the usefulness of the Framework itself by use of a survey. 

Attachment F contains a copy of that survey. Unfortunately, due to insufficient 

responses, EPA was unable to complete the evaluation of the Framework. 

Guide for Addressing Environmental Problems 8-11 
Element 8: Monitoring and Evaluating the Strategy 

Another challenge to collecting data on results is the restrictions under the Paperwork 

Reduction Act on surveys and questions that the federal government can ask of nonfederal entities or persons. OMB must grant permission to collect this type of information 

through an Information Collection Request (ICR). ICRs are required for most EPA 

surveys to collect measurement or evaluation information from more than 10 non-federal 

recipients. 

Opportunities and Suggestions 

The Agency is exploring various mechanisms for improving data collection, including 

generic ICRs for evaluation, additional training on data collection and additional sources 

of data beyond those that EPA has traditionally relied upon. 

Guide for Addressing Environmental Problems 8-12 
Element 9: Exiting the Strategy 

Element 9: Exiting the Strategy 

Objectives 

▪	 Introduce considerations for deciding whether and how long to 

sustain the strategy and when to exit and transition to a core 

program or maintenance approach (see Key Concepts). 

▪	 Provide considerations on when to transition and a step-by-step 

process on how to plan for a transition. 

•	 Identify key challenges and opportunities for deciding when to 

transition or sustain the approach. 

Purpose 

This information on this element examines some of the basic 

considerations in assessing the most appropriate point to transition the 

strategy to a maintenance level or to sustain the strategy. It supports 

Element 4 of the Template, titled “Exit Strategy.” The goal in planning 

for this element is to recognize that at some point the strategy will no 

longer have a heightened level of resources and attention; the 

resources committed and the roles and responsibilities of the team will 

shift back to the core program or a maintenance mode. 

Approach 

Key Concepts 

Core Program: The 

fundamental activities 

implemented by EPA, state and 

local agencies (or a delegated 

authority) to protect the 

environment. 

Priority: Recognized 

environmental problems that 

warrant heightened resource 

and commitment levels for a 

designated period of time. 

Maintenance: The level of 

commitment to the strategy 

shifts from a resource-intensive 

priority to a level commensurate 

with the agency’s mission and 

long-term goals and objectives. 

Sustain: The level of 

commitment to the approach 

remains elevated until further 

assessment. 

Planning for a strategic approach includes planning 

how to exit it. Ignoring this element of the planning 

process leads to a higher possibility of failure and 

logistical complications. Think of exiting as the 

beginning of the next phase of the strategy. Most, if 

not all, of the elements of a strategic approach (e.g., 

goals, monitoring, resources, communicating) need 

to be addressed for a long-term maintenance plan. 

When a strategy ends, the need for environmental 

protection remains. Unforeseen circumstances and 

changes that arise during implementation of the 

strategy could affect your decision on when and how 

to transition; however, obvious and predictable 

factors (presented in the following table) will also 

influence your decision to either transition and exit or 

to sustain the strategy. These factors are not 

mutually exclusive; the decision for the next phase of 

the strategy could be based on any or all of them. 

Key Considerations 

Based on lessons learned from the pilot projects and 

other experience in developing and implementing 

strategies, we provide the following considerations for 

deciding when and how to exit the strategy: 

▪ Include this element from the start of the planning 

process. 

▪ Identify all the long-term options for continuing to 

address the environmental issue in the future, 

while balancing the resource commitment with the 

environmental impact for each option. 

▪ Develop a transition and maintenance plan that 

specifies future resource obligations, whether and 

how to address regulated entities not covered by 

the approach, and actions to safeguard 

improvements achieved. 

Guide for Addressing Environmental Problems 9-1 
Element 9: Exiting the Strategy 

Factors to consider in 

determining whether to 

sustain or exit the strategy 

Sustain the strategy if... Transition and exit the 

strategy if... 

Are the goals met? Goals for the approach are not 

achieved. 

Goals for the approach are 

substantially achieved. 

Goals cannot be substantially 

achieved, but activities are 

completed according to 

schedule. 

Are you prepared to evaluate the 

approach and measure the 

goals? 

Data are insufficient for 

program evaluation and 

performance measures. 

Data are sufficient to evaluate 

the approach and address the 

goals. 

Are resources allocated to 

perform key activities? 

Resources are available to 

continue key activities. 

None or limited resources 

remain to carry out key 

activities. 

If identified as a goal, is 

environmental compliance by 

the target audience being 

achieved? 

Environmental compliance is 

not achieved, and further 

actions as a high priority are 

warranted. 

The environmental problem is 

substantially addressed and is 

ready for a long-term 

maintenance plan. 

Are there competing priorities 

where resources could be used 

more effectively? 

The target audience is 

responding positively to the 

strategy, and continuation of 

the approach will most likely 

prove successful. 

The target audience is not 

responding positively to the 

strategy, and transitioning to the 

core program or to enforcement 

only is warranted. 

The target audience has 

responded to the strategy, and 

external partners are sustaining 

the return to compliance or 

beyond compliance. 

Step-by-Step Process for Exiting and Transitioning 

the Strategy 

Determining when and how to exit the strategy and what will be the next phase to 

address an environmental problem that was once viewed as a priority requires 

consideration of all the other elements in the strategy. 

Provided here are suggestions and examples on the type of information to consider in 

planning for this element. 

The default position for exiting a strategy is when the goals are met and measured. 1 With this position in mind, take the time up front to assess whether the goals 

and measures are clear, realistic and tangible, and whether the data to 

demonstrate success is obtainable. Assuming the strategy goes as planned, it will be 

obvious when to exit. However, that is not always the case. That is why you need to 

Guide for Addressing Environmental Problems 9-2 
Element 9: Exiting the Strategy 

consider how to best use other elements in the strategy to help you determine when to 

exit or when to sustain. More importantly, deciding “when” does not inform you “how” to 

transition and to determine what constitutes the “next phase.” 

Incorporate exiting the strategy with the 2 development of the implementation plan (i.e., 

schedules and milestones). Factor into the schedule 

the anticipated time and approach for exiting. 

Recognize that you may need to transition sooner 

than expected (e.g., goals met earlier, competing 

resources), or you may need to sustain the approach 

longer than you initially realized (e.g., strategy is 

successful but more time is needed to address the 

entire target audience, changed selection of tools 

midcourse, environmental issue is broader than 

initially determined). 

Incorporate exiting the strategy with the 3 development of monitoring and evaluation. 

Consider what actions (e.g., target audience’s 

response to the tools, compliance improvements, 

team resources) you will need to monitor to move 

toward exiting and what steps (e.g., communicating to 

This diagram focuses on exiting the strategy and interested and impacted stakeholders) will need to highlights the other elements that are particularly occur to prepare for exiting. Environmental protection is important during the decision-making process for dynamic and requires continuous monitoring to address this element. 

the success of the strategy. 

Develop a transition proposal. Even though your attention is focused on planning 4 for a strategy, take the time to draft a transitioning and maintenance proposal, 

assuming the best case scenario but preparing for obstacles along the way. At a 

minimum, include in your proposal the following: 

▪	 The tools used in the strategy that need to be maintained in the next phase. 

▪	 The current resource level (or the level used throughout the approach) and the level 

of resources required after the transition occurs. 

•	 The roles and responsibilities for the office that will be in charge of the next phase. 

Communicate the transition and maintenance proposal with your team and 5 share and seek concurrence on the proposal with the managers in the office that 

will be responsible for the maintenance phase. Seek concurrence in a timely manner so 

the office (or delegated authority) has time to secure resources for the next budgeting 

cycle and notify all affected personnel for the next planning cycle. 

Challenges and Opportunities 

The following case examples and suggestions provide insight into assessing whether to 

transition and exit or to sustain the strategy. These examples illustrate Regions’ and 

states’ response to the question: What factors or situational changes occurred during 

Guide for Addressing Environmental Problems 9-3 
Element 9: Exiting the Strategy 

implementation of the integrated approach that justified exiting, continuing or expanding? 

Each approach has a unique set of challenges, but these suggestions may help you find 

the justification for exiting or continuing your strategy. 

Challenge: When and how to continue to address a sector-wide 

compliance problem as a priority 

Opportunities and Suggestions 

In many cases the decision to continue the strategy beyond its original exit date turns on 

the knowledge gained about the scope and breadth of the environmental problem during 

implementation of the strategy. Your initial strategy may have focused on a defined 

population faced with a single environmental problem. But once the strategy starts, you 

realize that the targeted population has doubled and the environmental problems are 

numerous. This is the time to step back and assess how much more work needs to be 

accomplished to gain a better perspective on the problem and determine the most 

effective and efficient approach to acquire that information. Some regions take the 

approach of setting up focus groups and widely publishing the intent of their strategy to 

gather additional information on the scope of the problems. In other instances, regions 

may undertake new multimedia inspections or increase the number of scheduled 

inspections to understand the breadth of the environmental problems. This is not the 

time to stay the course as initially planned just to meet an end date you set a few months 

ago. At a minimum, you will need to reevaluate your strategy to determine whether it 

should be expanded to address and improve the additional problems identified. 

Challenge: When and how to make the transition from a priority 

to a core program or maintenance plan 

Opportunities and Suggestions 

Some level of non-compliance and related environmental problems will remain 

after a priority strategy ends. This underscores the importance of defining clear, 

realistic goals for priority areas that can be met and measured in a reasonable 

number of planning cycles. Identifying when it is time to transition from a 

priority to a core program level of attention in a particular program area 

requires a discrete endpoint by which the “mission is accomplished.” Not every 

mission will be defined in the same way. For example, some may use 

improvements in compliance rates for a particular sector or requirement, while 

others may be based on elevating attention to long-standing requirements that 

are in need of renewed focus. In EPA’s Safe Drinking Water Act (SDWA) 

Microbial Rules National Strategy, EPA and stakeholders realized that a 

short-term intense focus on core requirements of the SDWA could provide 

needed attention on reducing drinking water contamination from microbial 

pathogens, but would not completely eliminate non-compliance. Forty-nine out of 50 

states and most U.S. territories have primacy for implementing and enforcing the SDWA 

program; therefore, EPA enforcement presence could not necessarily change overall 

compliance rates associated with the microbial regulations. During the period of the 

drinking water microbial priority, the increased focus on and Federal attention to this 

environmental problem did, however, stimulate overall compliance and enforcement 

Guide for Addressing Environmental Problems 9-4 
Element 9: Exiting the Strategy 

activity in this area and helped decrease microbial contamination in drinking water 

provided by public water systems. 

All stakeholders agreed to transition from a national priority to the core program at the 

end of EPA’s first three-year planning cycle in FY 2004. In EPA's judgment, transitioning 

to the core program allowed EPA to shift Federal attention to program management and 

oversight efforts aimed at ensuring that primacy authorities continued to focus 

appropriate compliance and enforcement efforts to address microbial noncompliance 

and improve drinking water quality. 

Guide for Addressing Environmental Problems 9-5 
Element 9: Exiting the Strategy 

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Guide for Addressing Environmental Problems 9-6 
ATTACHMENT A Page 1 

Final 11/5/02 

Framework for a Problem-based Approach to Integrated Strategies 

BACKGROUND 

The “Interim Final 11/18/96 Operating Principles for an Integrated EPA Enforcement and 

Compliance Assurance Program” describes a set of core principles for EPA’s enforcement and 

compliance program, the various “tools” available to address environmental problems and guidance on 

the integration of those tools. Over the years, there has been different experience in using the guidance 

and effectively integrating these tools by the Headquarters and Regional offices who implement the 

national compliance assurance program. This Framework reaffirms the “Operating Principles” and the 

general approach its sets forth. A draft white paper on the Use of Integrated Strategies (May 25, 2001) 

was also developed by OECA which reaffirms the approaches laid out in the Operating Principles and 

discusses lessons learned in integrating compliance assurance tools. Both of these documents provide 

relevant background information. This Framework builds on these documents and advocates using a 

problem-based approach to using and assessing the impact of our compliance assurance tools. Further, 

the Framework advocates the consideration of all tools and the elements of the Framework - not 

necessarily the use of each tool and the application of each element to every problem. In some cases, for 

example, an immediate enforcement response may be the most appropriate approach given the situation 

and problem. 

This Framework is intended to be utilized after national and/or Regional problems have been 

identified on which federal resources will be expended. The Framework provides guidance for 

developing “integrated strategies”-- a strategic approach which gives up front consideration to which 

tool or tools – compliance assistance, enforcement, compliance monitoring and compliance incentives 

– to use when addressing identified environmental problems. The Framework encourages proactive 

consideration of the elements of an integrated strategy: 1) data gathering to further define the problem 

and universe and develop compliance baselines, 2) tool selection and sequencing to effectively address 

the environmental problem(s), 3) up front development of measures to assess progress and outcomes 

and 4)communication with stakeholders, partners and the public. Use of the framework can add 
ATTACHMENT A	 Page 2 

transparency to EPA’s decision-making process. 

I. STATEMENT OF ENVIRONMENTAL PROBLEM {“What” (specify) is the environmental 

problems or issues?}

 To understand the impact and significance of environmental problems/issues, establish a baseline 

of information on: a) health and environmental impacts; b) potential risks; and c) root and contributory 

causes. Establishing a baseline of information will help create the framework for the type and level of 

integrated strategy to be developed and the approach to measure the integrated strategy’s effectiveness. 

Below is a list of factors to be considered when establishing the baseline: 

•	 Pollutants involved 

•	 Geographic areas impacted 

•	 Population impacted (environmental justice communities) 

•	 Distinct/specific noncompliance issues or patterns that need to be addressed 

•	 Industry sectors that appear to contribute to the problem 

•	 Health and environmental consequences of the problem 

•	 Current applicable federal, state, & local regulations, regulatory gaps, and opportunities for use of 

other regulatory authorities or innovative approaches 

II. JUSTIFICATION FOR SELECTING THIS PROBLEM OVER OTHERS {“Why is the 

identified problem one that EPA should devote resources to now?}: 

Given competing resource needs and priorities, describe the factors that make this problem(s) ripe 

for resolution and a relative priority. 

Questions to consider when making this decision: 

•	 What is the scope/seriousness of the health or an environmental problem? 
ATTACHMENT A	 Page 3 

•	 How does this environmental problem rank relative to others being considered? 

•	 Is noncompliance contributing to the problem and could it be addressed by EPA intervention? 

•	 Has there been an EPA or state presence in the sector? 

•	 Are there a large number of facilities which will benefit? 

•	 Are there a large percentage of small businesses with limited capacity to comply? 

•	 Is the problem widespread or a growing problem? 

•	 Do the problems fall within EPA’s role/authority? 

•	 Does the problem merit the attention of OECA and the Regions? 

•	 Does the proposed problem fit EPA’s planning horizon? 

•	 What is the current level of attention? 

•	 Are there new or pending rules that may impact the problem? 

•	 Are there environmental justice considerations? 

III. DESIRED/ANTICIPATED OUTCOMES/RESULTS {“What” (specify) are the goals and 

objectives? “What” (specify) do we hope to accomplish?}: 

What do we want to measure? Measures can be used to show: a) progress toward the anticipated 

outcome - interim measures; b) need for mid course corrections, c) the effectiveness of the integrated 

strategy and, d) lessons learned for program evaluation. During the development of the integrated 

strategy identify both final measures of success and interim measures and milestones. Where appropriate, 

measure each type of tool used in the integrated strategy as well as the synergistic effect of the tools. 

Measuring each type of tool used may be more appropriate as an interim measure. In determining desired 

outcomes, consider compliance and “beyond” compliance goals. 

Below are examples of the generic outcome measures to be considered in problem based 

integrated strategies. 

•	 Increased understanding of regulatory requirements 

•	 Facility Management Changes 

•	 Facility Process changes 

•	 Return to Compliance 
ATTACHMENT A Page 4 

• Regulatory actions taken 

• Pollutant Reductions 

• Capacity Building 

• Adopt sustainable practices 

• Promote/demonstrate changes in industry supply chain 

Below are some examples of interim measures: 

• Tools developed 

• CAP program letters sent 

• Reach/outputs can be used as interim measures 

. 

How will we measure our progress? Identify the outputs/outcomes for your activity and the type 

and sequence of measurement tools to be used to assess your progress/results. The measurement 

continuum is far reaching and ranges from gathering baseline data to measuring environmental 

improvements. 
ATTACHMENT A Page 5 

IV. USE OF AVAILABLE COMPLIANCE ASSURANCE & ENFORCEMENT TOOLS {“How” 

are we going to address/solve the problems or issues?) 

Continuum of Measures Continuum of Measures 

Developing 

Baselines 

Baseline Output Measures Outcome Measures 

Reach 

Changes in 

Understanding 

Changes in 

Behavior 

Environmental and 

Human Health 

Improvements 

Customer 

Satisfaction 

Enforcement 

Activities 

Tools 

Developed 

Capacity 

Building 

Developing 

Baselines

Baseline Output Measures Outcome Measures

Reach

Changes in

Understanding

Changes in

Behavior

Environmental and 

Human Health

Improvements

Customer

Satisfaction

Enforcement

Activities

Tools 

Developed

Capacity

Building

Establishing EXAMPLES: EXAMPLES:

Compliance

Baselines Enforcement –Aement –AOs, Penalties Enforcement - injunctive relief

Incentives- # disclosures Incentives-violations corrected 

Identifying 

compliance

problems/universe

CA-outreach materials 

distributed

CA-emissions reduced after CA visit

Inspections/CA – facility process change

Inspections - # conducted Understand need ttand need to apply for permit

Compliance Assurance Activities/Tools

Consider any of the elements below when deciding on and developing integrated strategies In some 

cases, enforcement or compliance assistance alone may be an appropriate strategy. It may be appropriate 

to use cross-programmatic, multimedia and/or cross-regional teams to develop a plan for using the most 

appropriate tool/tools and sequence of tools. Various partners in the strategy may use different tools ( 

e.g., state Small Business Assistance Programs may use compliance assistance; EPA may use incentives 

or enforcement). See the attached guidance on factors to consider in choosing and sequencing tools (TO 

BE DEVELOPED) 

Overview1 

Element 1: Compliance assistance activities - What will be the level of CA? Determine the 

1 Briefly discuss the sequencing of the elements (and their integration into the overall effort), how the use 

of a particular element complements the use of the others, etc. 
ATTACHMENT A	 Page 6 

appropriate levels and types of CA that could be used to address the environmental 

problem. Who will provide it? What tools exist or need to be developed? What 

will EPA’s role be as a CA provider and how will EPA work with other providers? 

Element 2:	 Compliance incentive activities - Will EPA or state policies or activities be used to 

provide incentives? Consider the usage of policies and activities, including EPA’s 

Audit Policy, Small Business Compliance Policy, Small Communities Policy, and 

CAPs. 

Element 3:	 Compliance monitoring activities - What is the appropriate level of CM? Will CA 

be integrated with CM activities? Is there or can we develop common terminology 

on levels of CM/CA that can facilitate this integration? “ The Role of the Inspector 

in Providing CA” and the ICDS may be useful starting points. 

Element 4:	 Enforcement activities - What Enforcement Response Policies may be used? 

Determine what kinds of enforcement activities may be used to address the 

environmental problem. 

Element 5:	 Other Relevant Activities - what other EPA or state activities will be included in 

the strategy? (e.g., developing new regulations, sustainable industry program 

activities and other innovative approaches, coordination with other federal 

agencies, use of compliance-based environmental management systems, pollution 

prevention activities and other beyond compliance activities, best management 

practices that help ensure compliance and improved environmental performance, 

mentoring and demonstration of environmental leadership) 

V. RESOURCES [ What resource needs and issues are associated with the effort?] 

Questions to consider: 
ATTACHMENT A	 Page 7 

•	 What is the best sequence of tools to address the problem? Are there any cost efficiencies 

associated with certain tools or combination of tools? 

•	 Will different tools be applied to various segments of the regulated community? 

•	 Are the resources available to implement each tool of the integrated strategy? 

•	 What are potential sources for obtaining needed resources, i.e., where can we look for 

additional resources if we don’t have them? 

•	 Can there be varying levels of implementation of the tools to reduce costs? 

•	 What are the economic cost and environmental benefit for implementing each type of 

tool/cost of implementing the integrated strategy as a whole? 

VI. SCHEDULE - (What is the schedule for undertaking the specific tasks in implementing the 

strategy?] 

Draft a schedule with milestones for undertaking the strategy. Consider resource needs, the 

MOA and state planning processes, reporting deadlines 

. 

VII.	 INVOLVED STAKEHOLDERS AND ROLES AND RESPONSIBILITIES - (Who are the 

involved stakeholders and what are their roles and responsibilities?) 

Questions to consider: 

•	 How will EPA work with other regulators, including other federal agencies? 

•	 How will OECA and the regions coordinate with the other EPA program offices, and state offices? 

‚	 Which regulatory body will take the lead? 

‚ Enforcement - what regulatory body has the lead for enforcement actions? 

‚ Compliance monitoring - What regulatory body has the lead for conducting inspections? 

‚ CA - Who has the lead for delivering CA to the regulated entities? 

•	 Which unit within the organization will have the lead for coordinating and implementing the 

integrated strategy? 

•	 What is the role of the supporting regulatory agencies? 
ATTACHMENT A	 Page 8 

•	 What is the role of 3rd parties in the development and implementation of the strategy? 

a) Federal Regulators: 

HQ - which offices? which programs? 

Regions - which offices? which programs? 

b) Other Regulatory bodies: State/local tribal 

c) Third Parties: Trades, industry, nonprofit, community groups, suppliers, etc. 

VIII.	 COMMUNICATION {“How” will stakeholders be informed of the status and results of the 

activities reflected in the strategy? Has a communication strategy been developed?} 

There are three key audiences that must be kept informed throughout the implementation of the 

integrated strategy. Each of these audiences has a need for different types of information at different 

stages of the strategy. These three groups are: a) participants that are working on the integrated strategy; 

b) federal and state Agency management; and c) external stakeholders including the regulated community 

and the public (includes the news media). 

a) Participants working on the integrated strategy: They need to know all of the elements and actions of 

the strategy and have a clear understanding of all the activities and outcomes. It is critical to develop a 

glossary of clear and consistent terms and concepts to ensure that all parties are in agreement. If they 

are expected to communicate the strategy to others, should talking points and presentations be developed 

and shared? 

b) Federal and state agency managers: A communications plan needs to be developed at the onset of the 

strategy’s implementation to ensure that management is appraised of the strategy’s progress, and to gain 

support and potential partnership of the Agency’s efforts to address the compliance issue. The 

communications plan usually includes strategies and implementing tools/activities. 

c) External stakeholders: A communications plan needs to be developed at the onset of the strategy’s 
ATTACHMENT A	 Page 9 

implementation to ensure that the regulated community is adequately informed of its compliance 

responsibilities and EPA’s efforts to address the compliance issue/problem. Likewise, the Agency has a 

responsibility to inform the public on what EPA is doing to address compliance issues/problems, 

particularly in environmental justice communities. The communications plan usually includes strategies 

and implementing tools/activities. Regardless, there is a need to ensure consistent messages. 

IX. MONITORING & EVALUATION PROCESSES: {"How" will progress relative to goals and 

objectives be monitored?} 

Questions to consider: 

•	 Are we making progress throughout the various interim stages of the strategy? 

•	 Have we addressed the environmental/health problem(s) identified in Section I. The Statement of 

the Environmental Problem? 

•	 Have parts of the strategy worked but not others? 

•	 Do we need to modify the strategy? 

•	 What is the overall effectiveness of the Integrated Strategy approach? 
ATTACHMENT A Page 10 
______________________________________________________________________________ 

ATTACHMENT B

 Contacts for the EPA Regions 2002-2004 Integrated Strategy Pilot Projects 

Region 1:	 Schools: EPA New England K-12 Schools Integrated Strategy Mary Dever, (617) 

1717 

Hospitals: Healthcare Sector Strategy / Baseline Information, Janet Bowen (617) 

918-1795 

Region 2:	 Hospitals: Compliance Assistance for Hospitals as Part of Integrated Strategy 

Initiative for the Healthcare Sector, Kathleen Malone (212) 637-4083, John 

Gorman (212) 637-4008 

Region 3:	 Schools: Preventing Risks to Children’s Health in Schools by Increasing 

Compliance., Betty Barnes, (215) 814-3447 

Region 4:	 Wood Preserving: Developing a Baseline of Wood Preservers in Region 4 States, 

Shannon Maher (404) 562-9623 

Region 5:	 Auto Salvage: Indiana Department of Environmental Management Auto Salvage 

Facility Sector Project, Matthew Deaner, Indiana 

Region 6:	 Construction (Oil and Gas): Integrated Strategy Pilot for NPDES Storm Water 

Phase II Rule Implementation the Oil and Gas Industry in Region 6, Casey 

Luckett, (214) 665-7393 

Agriculture: Integrated Strategy Pilot for Compliance with new NPDES CAFO 

Permits at Concentrated Animal Feeding Operations, Abu Senkayi (214) 665-

8403, Richard Powell, New Mexico, Norma Aldridge, Oklahoma 

Region 9:	 Auto Salvage: Storm Water Protection Program Compliance Assistance for 

AutoWreckers/Recyclers: Assessment of Effectiveness of Compliance Assistance 

Methods, Angela Baranco (415) 947-4262 

Region 10:	 Construction: Alaska Stormwater Integrated Strategy Pilot Project for the 

Construction Sector, Chae Park (206) 553-1441 
This page intentionally left blank. 
ATTACHMENT C 

Final Draft 

2/18/04 

Template for Developing a
 

Performance-Based Strategy for National 

Compliance and Enforcement Priorities 

I. Problem Statement 

A. Define and characterize the environmental or non-compliance problem for the priority area 

B. Provide baseline information on the size of the priority universe, geographic distribution of 

the problem, level of compliance, and any environmental justice issues 

C. Address how the problem relates to each OECA criteria for priority selection 

D. Address how the problem affects Environmental Justice (all strategies) and Federal Facilities 

issues (where appropriate). 

E. Describe known or suspected causes of the problem 

F.	 Identify existing policies and guidance that address the priority; and past strategies or 

initiatives used to address the problem 

II. Goals and Measures 

A. Establish an outcome goal for the priority area 

1.	 The goal should address the priority area, be measurable, and reasonably achievable in 

the given time frame 

2. Achievement of the goal will serve as the end point for the priority 

B. Establish outcome and output measures for the priority area 

1.	 Outcome Measures should be directly linked to, and serve as the primary indicator of 

progress toward achieving the outcome goal 

2.	 Output Measures serve as indicators of progress toward implementing the components of 

the priority strategy, and will enable managers to track implementation milestones 

3.	 Measures should be developed for EJ (all strategies) and Federal Facilities (where 

appropriate) 

C. Establish baselines for all measures, or develop a plan for developing a baseline for each of 

the measures 

III. Priority Strategy 

A. Identify a mix of tools that will be used to address the priority area, and how they will result 

in achieving the outcome goal 

B. Describe how the tools will be used in conjunction with each other to achieve the best results 

1. Include the sequence in which tools will be used, targeting priorities, how long they will 

be used, implementation milestones, resource issues, and implementation roles (i.e., 

headquarters, regions, others) 

2. Include a description of how Environmental Justice (all strategies) and Federal Facility 
issues (where appropriate) will be addressed by the application of the tools 

C. Develop a plan for periodically reviewing progress and making adjustments to the strategy as 

needed 

D. Develop internal and external communication strategies. The internal strategy should focus 

on providing managers information on strategy implementation and periodic performance 

measure updates to enable them to track progress and make needed corrections. The external 

strategy should inform the regulated community and stakeholders, help improve strategy 

effectiveness, and communicate results. 

E. Assign Roles and Responsibilities. Identify all of the parties that will play a role in 

developing and implementing the strategy, and assign responsibilities for all of the 

development and implementation tasks. Responsibilities should be broken out by 

headquarters, regions, and others. 

IV. Exit Strategy 

A. Identify steps to discontinue formal priority treatment once the outcome goal has been met 

B. Develop a maintenance plan to include: 

1. Significant resource obligations 

2. Whether and how to address regulated entities not addressed as part of the strategy 

3.	 Actions to safeguard to improvements achieved; including periodic monitoring, review 

and adjustment 

V. Workforce Deployment Strategy 

A. The priority sector or problem area should be assessed to identify the skill sets needed to 

effectively address the priority and implement the priority strategy. This assessment should 

anticipate the different skills needed at different points in the strategy (e.g., compliance 

assistance early on, more enforcement towards the end). 

B. Taking into account the strategy’s ultimate goal, time line, and exit strategy; responsible 

parties in headquarters and regions should estimate the activity levels needed to achieve 

strategy’s ultimate goal in the given time frame. 

C. Gap Analysis - headquarters and regions should identify workforce gaps that will impact 

achieving priority goals, including deficits in overall number of employees to address a 

problem area, and in particular skill sets. 

D. Workforce Deployment Recommendations - based on the gap analysis recommendations for 

making workforce adjustments within individual regions and headquarters, and between 

regions, and regions and headquarters should be identified to maximize strategy 

effectiveness. 

VI. Schedule 

Develop an overall schedule for addressing the priority area 

2
 
ATTACHMENT D 

EPA Region 2 Healthcare Compliance Initiative 

06/08/2005 

Executive Summary 

Sector Healthcare 

Environmental Problem The 480 hospitals in New York, New Jersey, Puerto Rico, and the 

Virgin Islands pose a major environmental and public health concern. 

First, they contribute to the mercury in the environment which is of 

great concern in the Northeast. Rates of mercury deposition are 

estimated to be higher in the northeastern U.S. relative to most other 

parts of the country and extensive scientific data indicate that 

mercury is pervasive in freshwater fish in the Northeast at levels that 

pose health risks to people and some species of fish eating wildlife. 

According to a May 2002 New York Academy of Sciences report, 

hospitals, dental facilities and laboratories account for 90% of the 

mercury being discharged to the New York-New Jersey Harbor at 

this time. In addition to mercury, hospitals are also generators of a 

wide variety of hazardous wastes, (e.g., chemotherapy and 

antineoplastic chemicals, solvents, epinephrine, and pharmaceuticals) 

and produce two million tons of solid waste which is 1% of the total 

municipal solid waste in the U.S. Finally, random inspections at 

hospitals in Region 2 and across the country as well as results of selfaudits being conducted by healthcare facilities under EPA’s audit 

policy indicate a pattern of noncompliance with environmental 

requirements across much of the sector, especially in regards to the 

management of hazardous waste. Many hospitals have only one 

person in charge of all health, safety and environmental issues at the 

hospital and it is very difficult for one person to manage all the 

environmental aspects of a healthcare facility let alone the health and 

safety issues as well. 

Goals In response to the above concerns, EPA Region 2 embarked upon a 

healthcare initiative for the purposes of improving environmental 

compliance and safety at main and off-site healthcare facilities; 

changing the culture of the healthcare community to one in which 

environmental compliance is a priority; promoting compliance of the 

entire sector; not just those reached through inspections; and ensuring 

continued compliance by implementing permanent changes such as 

through the development of environmental management systems. We 

also encouraged as part of our initiative that hospitals join Hospitals 

for a Healthy environment, a voluntary program that is trying to 

educate healthcare professionals about pollution prevention 

opportunities in hospitals with the goal of reducing the environmental 

footprint of the healthcare sector. 
ATTACHMENT D
 

Measures 

Results 

The success of our healthcare strategy was measured in the following 

way: 

• Increased awareness among the healthcare community regarding 

environmental requirements based on pre/post tests given at 

seminars/workshops and a survey; 

• Increased number of healthcare facilities in Region 2 

participating in Hospitals for a Healthy Environment; 

• Number of violations corrected by hospitals as a result of our 

initiative as measured by case-conclusion data sheets (for both 

enforcement actions and voluntary disclosures) and a survey. 

• Amount of pollution reduced as a result of our initiative as 

measured by case-conclusion data sheets and a survey. 

• Number of pollution prevention and best management practices 

undertaken by hospitals as a result of our initiative as measured 

by a survey. 

Environmental measures gathered for our approach to the healthcare 

sector has proven effective in improving the compliance rate and 

environmental footprint of healthcare facilities in our Region. For 

instance, as a result of our initiative: 

• Between 60-65% of hospitals that participated in our workshops 

increased their knowledge of environmental requirements (Note: R2 

also used workshop surveys to measure increased knowledge of the 

requirements which consistently provide results that show increases 

greater than 95%. Due to the large disparity between these results, 

R2 has chosen to use the measured results rather than the increase in 

knowledge reported by the attendees); 

• So far, 57 hospitals/healthcare systems in NY and NJ have joined 

the H2E Program and have pledged to eliminate mercury and reduce 

the volume of waste they generate; 

• More than 2173 violations have been corrected of which 69% 

were RCRA, 4% CWA, 7% EPCRA, 18% CAA, 1% TSCA and 

0% SDWA; 

• At least 11,660 lbs/year of hazardous waste, 80,930 gallons of oil 

and 2100 pounds of chlorofluorocarbons are now being 

appropriately managed; and 

• Approximately 341 residential units are now in compliance with 

lead-based paint rules. 

Tools Selected EPA Region 2 set out to accomplish the above goals through a threeprong strategy. First, we provided environmental assistance to 

healthcare facilities to help them understand their environmental 

obligations, identify P2 opportunities, and develop an EMS. This 

assistance included holding 11 environmental compliance 101 

workshops which gave a general overview of the various statutes that 

applied to hospitals; conducting more than a dozen full-day hospital-
ATTACHMENT D
 

specific hazardous waste identification and management workshops 

since 60% of the violations uncovered at healthcare facilities 

involved hazardous waste; sponsoring EMS tutorials and performing 

environmental management reviews for federal hospitals which are 

required to develop an EMS under Executive Order 13148; and 

developing a healthcare website, a CD-ROM of healthcare 

environmental assistance tools, RCRA decision diagrams, a poster of 

RCRA generator requirements, a handbook of hazardous waste 

management at hospitals and an EMS guide for healthcare facilities. 

Second, we sent a letter to hospitals in December 2002 informing 

them of our intent to target healthcare facilities for inspections and 

enforcement and urging them to perform self-audits and to enter into 

corporate-wide audit agreements under EPA’s voluntary audit policy. 

 A model audit agreement was developed in order to reduce the time 

needed for review and negotiation. So far, 37 hospitals/ hospital 

systems have entered into audit agreements with EPA covering all 

major federal environmental programs. These agreements included 

the first ever audit agreement with the Veterans Healthcare 

Administration which encompassed all the federal VA hospitals in 

New York and New Jersey. To date, more than 1100 violations have 

been corrected under our voluntary audit program and $9,739,076 in 

potential penalties have been waived. 

Finally, we conducted 44 inspections, and issued 24 enforcement 

actions, 10 of which were complaints totaling $1,289,913 in penalties 

under our healthcare compliance initiative. These inspections and 

enforcement actions were done concurrently with the above 

environmental assistance and compliance incentives activities. 

Factors for Tool Selection EPA Region 2 adopted this three-prong strategy for the following 

reasons: 1) a well-publicized enforcement presence throughout the 

initiative promoted accountability, encouraged facilities to take 

advantage of the environmental assistance and compliance 

incentives offered, and addressed serious threats to human health and 

the environment as well as identifying and addressing recalcitrant 

offenders; 2) environmental assistance increased the awareness and 

knowledge of environmental regulations, pollution prevention 

opportunities, and environmental management systems within the 

healthcare sector and provided tools to help healthcare facilities come 

into compliance and reduce their environmental footprint; and 3) the 

use of the audit policy allowed us to reach more healthcare facilities 

than we would have through inspections alone, resulted in permanent 

compliance changes not just quick fixes and allowed us to target our 

inspections toward those hospitals that, for whatever reason, were not 

interested in voluntarily complying with environmental regulations. 
ATTACHMENT D
 

Time Frame 2002-2005 

A. What is the environmental problem or issue and its significance for priority selection? 

There are 480 hospitals (both private and public) in New York, New Jersey, Puerto Rico, and the 

Virgin Islands. Given this large universe, EPA Region 2 did not have the resources to conduct 

inspections at every hospital in the region. Particularly, considering that these are large 

institutions with diverse operations and waste streams. A hospital may have, for example, 

laboratories, operating rooms, pharmacies, radiological facilities, cafeterias, housekeeping and 

laundry units, fleet maintenance facilities, boilers, medical waste incinerators, emergency 

generators, grounds and landscaping facilities, underground or above ground oil and fuel storage 

tanks, air conditioning and refrigeration equipment, morgues, lead-based paint, and asbestos. As 

a result, they are regulated by a myriad of environmental statutes including the Resource 

Conservation and Recovery Act, Clean Air Act, Clean Water Act, Safe Drinking Water Act, Oil 

Pollution Act and the Emergency Planning and Community Right to Know Act, not to mention 

the various state and local regulations that may be more stringent than the federal laws. 

More importantly, the waste and emissions caused by these activities posed a significant risk to 

human health and the environment if not controlled properly. Hospitals, for example, contribute 

to the presence of toxic chemicals such as phthalates, mercury, and dioxin in the environment. 

Mercury, in particular, is of great concern in the Northeast. Rates of mercury deposition are 

estimated to be higher in the northeastern U.S. relative to most other parts of the country and 

extensive scientific data indicate that mercury is pervasive in freshwater fish in the Northeast at 

levels that pose health risks to people and some species of fish eating wildlife. In New York, for 

instance, the Department of Environmental Conservation’s most recent fish advisories had 35 

bodies of water contaminated with mercury throughout the state, and 10 with dioxin. In New 

Jersey, there are 85 different fish advisories (many with 2-4 sub advisories by species of fish) for 

streams, creeks, parts of rivers, lakes and reservoirs for mercury alone. There are also dioxin, 

chlordane and PCB advisories for various species in all of New Jersey’s coastal waters. 

According to a May 2002 New York Academy of Sciences report, hospitals, dental facilities and 

laboratories account for 90% of the mercury being discharged to the New York-New Jersey 

Harbor at this time. 

In addition to mercury, hospitals are generators of a wide variety of hazardous wastes, such as 

chemotherapy and antineoplastic chemicals, epinephrine, pharmaceuticals, solvents, 

formaldehyde, photographic chemicals, radionuclides, and waste anesthetic gases. They also 

produce 2 million tons of solid waste which is 1% of the total municipal solid waste in the 

United States. Furthermore, medical facilities contribute to various air pollution problems 

including smog, climate change, the depletion of the stratospheric ozone layer, and air toxics. 

Finally, random inspections at hospitals in Region 2 and across the country as well as results of 

self-audits being conducted by healthcare facilities under EPA’s audit policy indicated a pattern 

of noncompliance with environmental requirements across much of the sector. Many hospitals, 

in fact, had only one person in charge of all health, safety and environmental issues at the 

hospital and it was very difficult for one person to manage all the environmental aspects of a 

healthcare facility let alone the health and safety issues as well. Sixty-percent of the violations 
ATTACHMENT D 

discovered were related to hazardous waste management. Other violations involved spill 

prevention, control, and countermeasure plans, air conditioning and refrigeration disposal and 

repair, asbestos, Clean Air Act State Implementation Plans, lead paint disclosures for leased 

housing, PCB management, drinking water, and Emergency Planning and Community Right to 

Know Requirements. 

B. What was the approach and methods used to baseline the environmental problem and 

understand the target audience that was contributing to the problem? 

EPA Region 2 used random inspections of hospitals and the establishment of healthcare focus 

groups to baseline the environmental and compliance problems among hospitals and to 

understand the target audience that was contributing to the problem. 

C. Identify each tool (e.g. CM, Enf, CA, CI, EMS, P2, and Sustainability) that was selected 

to address the environmental problem(s) and the factors considered to use that tool? 

EPA Region 2 used all the tools at its disposal to improve the compliance and environmental 

footprint within the healthcare sector for the following reasons: 

Compliance Monitoring/Enforcement: A well-publicized enforcement presence throughout the 

initiative promoted accountability, encouraged facilities to take advantage of the environmental 

assistance and compliance incentives offered, and addressed serious threats to human health and 

the environment as well as recalcitrant offenders. 

Environmental Assistance: Environmental assistance increased the awareness and knowledge of 

environmental regulations, pollution prevention opportunities, and environmental management 

systems within the healthcare sector and provided tools to help healthcare facilities come into 

compliance and reduce their environmental footprint. Please note the use of the term 

environmental assistance instead of compliance assistance. When EPA Region 2 conducts 

workshops, and develops guides, fact sheets, and websites, we include information on pollution 

prevention, environmental management systems, and sustainability along with regulatory 

information because we believe these other tools promote long-term compliance. If a hospital 

eliminates mercury from its hospital, for instance, then the hospital does not need to worry about 

the hazardous waste, air, and water regulations associated with mercury. 

Compliance Incentives: The promotion of voluntary audits and corporate-wide audit agreements 

under EPA’s audit policy allowed us to reach more healthcare facilities than we would have 

through inspections alone, resulted in permanent compliance changes not just quick fixes and 

allowed us to target our inspections toward those hospitals that, for whatever reason, were not 

interested in voluntarily complying with environmental regulations. 

D. Where more than one tool was selected to address the environmental problem discuss 

the relationship between the tools and the factors considered in sequencing and 

segmentation? 
ATTACHMENT D 

EPA Region 2 used environmental assistance, compliance incentives, compliance monitoring, 

and enforcement concurrently throughout our initiative. There was no waiting period prior to 

enforcement. This was a lesson-learned from our college and university initiative where we told 

academic institutions that they had a year before enforcement would start believing that would 

give them time to take advantage of the environmental assistance and compliance incentives 

offered prior to inspectors going out in the field. However, we found out that some colleges, 

instead of trying to come into compliance during this year grace period, actually cut their 

environmental budget when they knew we would not be inspecting them for a year. 

Also, by using all the tools concurrently we were able to take advantage of information gathered 

from each aspect of our initiative to improve the cost-effectiveness of the other elements. For 

example, it was through inspections and audit disclosures that we learned that 60% of the 

violations at healthcare facilities were related to hazardous waste which prompted us to develop 

the first-ever healthcare-specific workshop on hazardous waste identification and management 

that has been widely acclaimed among healthcare facilities nationwide. Also, regional 

enforcement personal can better target their healthcare inspections by taking into account the 

hospitals that are participating in our voluntary audit program. 

E. Describe any changes from the initial strategy during implementation and factors 

contributing to those change(s)? 

EPA Region 2 developed a strategy that was designed to be flexible and adaptable. We have 

 learned through previous compliance initiatives that the strategy is a living document that needs 

 to be modified several times during implementation to take into account unanticipated 

 situations, changes in rules or policies, changes in emphasis based upon compliance findings, 

etc. For this initiative, the changes that we made mainly concerned the level of outreach that 

 was needed to address RCRA violations (i.e., development of full-day RCRA Waste 

 Identification Workshop and associated tools, and adding more seminars than anticipated) and 

in 

increasing the emphasis on certain hospital wastes (e.g., chemotherapy wastes, universal wastes, 

 pharmaceutical wastes, waste epinephrine, etc.) and certain waste management practices (e.g., 

 handling of universal wastes, chemo wastes, bulb crushing operations, and non-mercury 

 alternatives for devices other than temperature and blood pressure measurement.) 

F. What were the goals of the strategy and the measures that addressed them? What were 

the results of this approach? 

EPA Region 2’s healthcare compliance initiative was undertaken for the purposes of improving 

environmental compliance and safety at main and off-site healthcare facilities; changing the 

culture of the healthcare community to one in which environmental compliance is a priority; 

promoting compliance of the entire sector; not just those reached through inspections; and 

ensuring continued compliance by implementing permanent changes such as through the 

development of environmental management systems. We also encouraged as part of our 

initiative that hospitals join Hospitals for a Healthy environment, a voluntary program that is 

trying to educate healthcare professionals about pollution prevention opportunities in hospitals 
ATTACHMENT D 

with the goal of reducing the environmental footprint of the healthcare sector. 

The success of our healthcare strategy was measured in the following way: 

• Increased awareness among the healthcare community regarding environmental requirements 

based on pre/post tests given at seminars/workshops and a survey; 

• Increased number of healthcare facilities in Region 2 participating in Hospitals for a Healthy 

Environment; 

• Number of violations corrected by hospitals as a result of our initiative as measured by caseconclusion data sheets and a survey. 

• Amount of pollution reduced as a result of our initiative as measured by case-conclusion data 

sheets and a survey. 

• Number of pollution prevention and best management practices undertaken by hospitals as a 

result of our initiative as measured by a survey. 

Although we are still awaiting responses from our survey that we sent out to all the hospitals in 

New York, New Jersey, and the Caribbean, the environmental measures we have gathered so far 

show that our approach to the healthcare sector has proven effective in improving the 

compliance rate and environmental footprint of healthcare facilities in our Region. For instance, 

as a result of our initiative: 

• Between 60-65% of hospitals that participated in our workshops increased their knowledge 

of environmental requirements; 

• So far, 57 hospitals/healthcare systems in NY and NJ have joined the H2E Program and have 

pledged to eliminate mercury and reduce the volume of the waste they generate. 

• More than 1100 violations have been corrected of which 60% were RCRA, 17% CWA, 12% 

EPCRA, 7% CAA, 3% TSCA and 1% SDWA; 

• At least 11,660 lbs/year of hazardous waste, 80,930 gallons of oil and 2100 pounds of 

chlorofluorocarbons are now being appropriately managed; and 

• Approximately 341 residential units are now in compliance with lead-based paint rules. 

G. Describe the mechanisms used to communicate the strategy to internal (EPA managers 

and staff) and external (partners in implementing strategy, targeted audience and 

public) stakeholders. 

EPA Region 2’s healthcare compliance initiative would not have been successful without 

coordination and communication both internally within EPA Region 2 as well as externally with 

other EPA offices and Regions, hospital associations, state/local environmental and health 

agencies and other federal government agencies. Internal communication was accomplished 

through the R2’s Multimedia Enforcement Team (MET – an ad hoc group of senior enforcement 

staff in various media programs that provides support to senior managers), the R2 Multi Program 

Enforcement Steering Committee (MPESC – a group of enforcement program branch chiefs and 

others that coordinate multimedia inspection and enforcement activities), the R2 Pollution 

Prevention Council (R2P2C – a multi-Divisional workgroup that advises regional management 

of issues related to pollution prevention, sustainability, and outreach), and the Regional LAN. 

Communication with other EPA offices and Regions was accomplished through the monthly 
ATTACHMENT D 

pollution prevention, federal facility, and compliance assistance conference calls and through Email as needed. As for our external stakeholders, we developed a healthcare focus group in New 

York State which included representatives from state/local environment and health 

organizations, trade associations, and major NY hospitals. We also participated in conference 

calls/meetings with Hospital for a Healthy Environment and the Veterans Health Administration 

and with a national workgroup for issues related to EMS development for hospitals. We also 

awarded a grant to H2E to work with NYC hospitals to promote compliance, mercury 

elimination, and pollution prevention, and sent a number of mailings and emails to hospitals in 

the region to provide compliance assistance and regulatory updates. Finally, we asked for 

feedback on our workshop evaluation forms and tracked the requests for information that we 

received for additional explanations of various regulations and practices. 

H. Identify and discuss the resources and deployment of resources used to develop and 

implement the strategy. Address the impact of deploying resources on this priority 

with regard to other priorities. 

This initiative required 4.0 FTEs in resources internally each year from Region 2 in order to 

conduct the necessary environmental assistance and enforcement. We also needed the help of 

external stakeholders such as hospital associations and other government agencies. Moreover, 

we used federal facility, pollution prevention, environmental priority, and compliance assistance 

extramural funds as needed and available to develop tools and hold workshops. The deployment 

of these resources on this priority did not greatly affect any national priorities or other regional 

priorities since resources were reassigned accordingly. It, however, did impact to some extent a 

few core programs. However, Region 2 believes that the environmental results gained from this 

initiative far outweigh any losses in the core program. We would not have achieved such an 

improvement in the compliance rate and the environmental footprint within the healthcare sector 

if we had relied on our traditional compliance and enforcement techniques. 

I. What steps were taken to monitor and evaluate the strategy’s progress? 

Although the ultimate success of our healthcare strategy was determined by the outcome 

measures listed in Section F above, EPA Region 2 throughout the initiative looked at various 

output measures (e.g. # of inspections, enforcement actions, penalties, workshops, compliance 

assistance tools developed, audit agreements, disclosures, entities reached through compliance 

assistance, etc) to assess the strategy’s progress. We also evaluated any feedback we received 

from our external stakeholders through workshop evaluations, meetings, conference calls, and 

focus groups to ascertain if we were on the right track in achieving our goals. 

J. What factors or situational changes occurred during implementation of the strategy to 

justify exiting or continuing/expanding? 

EPA Region 2 believes that the majority of the healthcare facilities in NY, NJ, PR, and the VI 

have been given ample opportunity to participate in our workshops and our voluntary audit 

program. Furthermore, of the 480 hospitals in Region 2, --- % are either conducting their own 

self audits or have been inspected. Thus, we have decided to put healthcare facilities back into 
ATTACHMENT D 

the core program. As such, we will continue to conduct random inspections of hospitals, answer 

any regulatory questions that hospitals may have, maintain our healthcare website, and process 

any audit disclosures that are received. However, we will not be holding any more workshops, 

developing new tools, or actively promoting the audit program. 

K. Discuss any barriers/challenges in developing or implementing the strategy and 

opportunities for addressing them in the future. 

The major barrier to this initiative was the lack of environmental data on hospitals in the 

enforcement databases when we started. Very few inspections had been conducted at hospitals 

and thus, little was known about the compliance status of healthcare facilities at that time. Many 

at EPA, particularly Headquarters, are leery about starting compliance initiatives or even doing 

inspections in sectors that have never been targeted before. This led to much push back from 

EPA management in Headquarters. However, Regional management was willing, giving the 

limited data we had ascertained, to take a chance and target our limited compliance assistance 

and enforcement resources at hospitals. As you can see from our results, this risk taking on the 

part of Regional management paid off and several other Regions, seeing the results obtained by 

Region 2, are now seriously considering starting healthcare initiatives themselves. Another 

major barrier was the lack of clear, understandable compliance assistance information that 

healthcare facilities could use to identify the regulatory requirements that applied to them and to 

determine their compliance status. During the initiative, R2 developed or helped to develop 

many tools to assist healthcare facilities with these tasks including: the Healthcare 

Environmental Resource Center, the sector notebook, an EMS guide for healthcare facilities, 

many presentations and workshop materials, and a CD/ROM that contains all of these resources 

and links to additional information (e.g., pollution prevention and green building information for 

healthcare facilities.) The last major barrier was the lack of experienced staff in both the 

compliance assistance and the compliance monitoring and enforcement staff related to hospital 

operations (e.g., typical hospital waste streams and waste generating processes, alternatives to 

hazardous components, health and safety concerns, etc.) 
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���

United States
 Office of Enforcement EPA 300-N-03-001 

Environmental Protection and Compliance
 

Agency Assurance (2248A)
 

Enforcement nforcement Alert lert

Volume 6, Number 1 Office of Regulatory Enforcement March 2003 

EPA Strategically Addressing Raw Sewage Discharges 

Across Nation to Protect Public, Environment 

EPA Reaches Settlements with Baltimore, 

Other Municipalities to Stop Sewage 

Overflows, Overhaul Sewer Systems 

Sanitary sewer systems that are 

properly designed, operated, and 

maintained, collect and transport all of 

About 

Enforcement Alert 

Enforcement Alert is published 

periodically by the EPA’s Office of 

Regulatory Enforcement, Office of 

Enforcement 

Assurance to inform and educate 

the public and regulated community 

of 

enforcement issues, recent trends 

and 

actions. 

This information should help the 

regulated community anticipate 

and prevent violations of federal 

environmental 

otherwise lead to enforcement 

action. Reproduction and wide 

dissemination of this publication 

are encouraged. For information 

on how you can receive this 

newsletter electronically, send an 

email to the editor . 

Director, Office of Regulatory 

Enforcement: Walker B. Smith 

Editor: Virginia Bueno 

bueno.virginia@epa.gov 

and Compliance

important environmental

significant enforcement

thatlaw could

the sewage and indus­
 

trial wastewater that
 

flow into them to a
 

publicly owned treat­
 

ment works (POTW)
 

for appropriate treat­
 

ment before being dis­
 

charged into our
 

nation’s rivers,
 

streams, and other water bodies. How-
 

ever, when sanitary sewer systems are
 

not maintained, or lack adequate ca­
 

pacity, discharges of raw sewage and
 

industrial wastewater can occur with-
 

out receiving appropriate treatment. In
 

some systems, these sanitary sewer dis­
 

charges occur on a regular basis.
 

These discharges, called sanitary 

sewer overflows (SSOs), occur when 

there is an overflow, spill, or release of 

raw or partially-treated sewage from a 

sanitary sewer collection system before it reaches a 

sewage treatment 

plant. Such releases 

regularly contaminate our nation’s 

waters, degrade 

water quality, and 

expose humans to 

pathogens and viruses that can 

cause serious illness. In addition,
 

One of EPA’s ongoing ment works must 

enforcement priorities is meet technologybased effluent limita­ to identify and correct	 tions based upon sec­ these raw sewage ondary treatment, and 

discharges to protect any, more stringent 

limits to meet water public health and the 

environment. 

these discharges can occur as base­
 

ment backups, causing property dam-
 

age and further threatening public
 

Some sanitary sewer overflows can 

occur at deteriorated manholes. 

(Photo courtesy of the Orange 

County Sanitation District.) 

health. EPA estimates that there are 

20,000 separate sanitary sewer systems, and thousands of overflows occur each year. 

Section 301 of the Clean Water Act 

prohibits the discharge of any pollutant 

to waters of the United States from a 

point source, unless the discharge is authorized by a permit. Limits in permits 

for discharges from 

publicly owned treatquality standards. In 

addition, permits require proper operation 

and maintenance for sewage collection 

systems and treatment facilities, for 
���

���

Enforcement Alert 

example, to ensure continued system 

integrity and prevention of unauthorized 

overflows of untreated wastewater. 

Sanitary sewer overflows are prohibited as unpermitted discharges, and 

when they are prohibited in a permit. 

Given the seriousness of the problem 

in many major municipalities, one of 

EPA’s ongoing enforcement priorities is 

to identify and correct these raw sewage discharges to protect public health 

and the environment. 

SSOs Endanger Public 

Health and the Environment 

People can be exposed to raw sewage through recreational contact such 

as swimming and fishing, in their homes 

and neighborhoods because of basement 

or street flooding, and through drinking contaminated water. Contact with 

raw sewage exposes people to a variety of pathogenic microogranisms, viruses, and intestinal worms that can 

cause serious illnesses such as cholera, dysentery, infectious hepatitis, and 

gastroenteritis. Sensitive populations— 

children, the elderly, and those with 

weakened immune systems—are at a 

higher risk of illness. 

Beach closures and recreational 

water warnings are designed to limit the 

human health impacts of bacteria and 

pathogens present in water, whether 

from SSOs, stormwater, or urban runoff. 

Sanitary sewer overflows degrade 

the environment by polluting our waterways, adversely affecting fish and 

other wildlife species. For example, 

sewage can cause the explosion of algal growth, depleting oxygen in the 

water and killing fish. Raw sewage discharges cause property damage and 

public health problems when overflows 

flood homes and businesses that subsequently require cleanup, large scale 

disinfection, and the replacement of 

rugs, furniture, wallboard panels, and 

flooring. Raw sewage discharges also 

can lead to a drop in tourism and ecoWhen sanitary sewer systems are not maintained, or 

lack adequate capacity, discharges of raw sewage and 

industrial wastewater can occur and potentially endanger the public and environment. (U.S. EPA photonomic loss from beach closures and 

shellfish and fishing restrictions. 

Why SSOs Occur 

Separate sanitary collection systems 

are intended to collect sewage that flows 

into them, and transport those flows 

for treatment. Municipalities must evaluate their collection systems to identify 

the causes of SSOs so that they can be 

anticipated and stopped before they 

harm public health and the environment. 

Chronic SSOs can be the result of 

excessive amounts of rainfall or snowmelt seeping through the ground and 

overwhelming leaky sewers (infiltration), and excess rainwater feeding into 

sewers through illegally-connected roof 

drains, or basement sump pumps (inflow). In addition, municipalities with 

poor operation and maintenance programs may experience SSOs as a result of system deterioration. Pipes can, 

and often do, settle and crack, and need 

repair and replacement on a regular 

schedule. Sediment, grease, and other 

debris can build up and cause pipes to 

plug, break, and collapse. SSOs also 

may be caused by a lack of system capacity to collect, store, and/or convey 

flows for treatment. 

To Eliminate SSOs, EPA 

Uses Mix of Compliance, 

Enforcement Tools 

EPA’s compliance goal is to eliminate SSOs from municipal collection 

systems and to ensure that sanitary 

graphs.) 

March 2003 2 
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Enforcement Alert 

wastewater is being conveyed to treatment plants for treatment in accordance 

with the requirements of the Clean Water Act. EPA uses a variety of compliance and enforcement tools to achieve 

environmental and human health improvements, including enforcement actions, compliance assistance, and compliance incentives. 

Enforcement 

To date, EPA’s enforcement actions 

have resulted in the elimination of billions of gallons of raw sewage discharges and the assessment of significant penalties. States also have joined 

EPA as co-plaintiffs in many lawsuits. 

In these enforcement actions, EPA 

typically places municipalities under a 

compliance schedule that is as expeditious as practical (up to 15 years) to 

address deficiencies in their systems. 

Under settlement agreements, municipalities must assess their systems to 

understand the scope of the problem, 

then create a plan to improve, update, 

and repair their wastewater collection 

system. These municipalities also are 

usually required to develop and implement effective operation and maintenance programs. 

Baltimore Settlement 

On Sept. 30, 2002, a consent decree implementing a significant settlement with Baltimore to eliminate unpermitted discharges of raw sewage from 

the city’s sanitary waste collection system was entered in federal court. All of 

the waterbodies affected by these discharges fail to meet permit effluent limits based on Maryland’s water quality 

standards for total coliform, an indicator of disease-carrying pathogens. 

Baltimore owns and operates two 

sewage treatment plants and 1,312 miles 

of collection system that transport 

wastewater to the plants. The plants 

SSOs One Cause of 

Beach Closings 

Agencies participating in EPA’s 

annual beach survey reported 

that of the 2,445 beaches reported 

in 2001, 672 were affected by advisories or closings, most often 

due to elevated bacteria levels. 

Sanitary sewer overflows were 

identified as one of the sources of 

pollution that resulted in these advisories or closings. The number 

of such beach advisories and closures reported every year is on the 

rise. 

Municipalities must strive to 

eliminate the discharges, which 

often can lead to serious illness 

and disease. People who swim 

near storm drains or off beaches 

polluted by sewage can become 

ill with fever, nausea, gastroenteritis, and flu-like symptoms, or more 

serious diseases. 

serve a population of approximately 1.8 

million people. The anticipated reduction in raw sewage discharges attributable to this settlement is more than 30 

million gallons a year. 

The settlement requires Baltimore to 

implement injunctive relief valued at approximately $940 million over the next 

14 years. The City will spend more than 

$260 million to eliminate 54 sanitary 

sewer structures, increase the capacity of the collection system associated 

with these structures, and completely 

separate the combined portion (where 

sanitary wastewater and storm water 

are conveyed through a single pipe for 

treatment) of the system. 

The City also will undertake a comprehensive, systematic investigation of 

its entire collection system, and implement and complete action plans to remedy problems identified during the investigation. Baltimore plans to install and 

maintain a computerized collection and 

transmission system model to evaluate 

the impact of various remedial action 

projects on the transmission capacity 

and performance of the collection system. The City also will undertake a significant construction program to repair 

and rehabilitate pumping stations. 

Baltimore also agreed to spend significant additional funds to identify and 

enforce against illegal sewer connections, implement an information management system program, develop and 

implement an emergency response plan 

for unpermitted discharges, improve the 

operation and maintenance program for 

the collection system, and report all unpermitted discharge events. 

Finally, Baltimore agreed to pay a 

civil penalty of $600,000, and implement a supplemental environmental 

project estimated at $2.72 million designed to remove nitrogen from wastewater and improve water quality in the 

Chesapeake Bay. 

Other Recent Settlements 

An agreement reached with Baton 

Rouge and East Baton Rouge, La., will 

reduce discharges of untreated sewage 

to public areas and U.S. waters by more 

than 1.2 billion gallons annually. Baton 

Rouge and East Baton Rouge paid a 

$729,500 penalty and are spending up 

to $461 million on selecting and implementing a comprehensive collection 

system improvement plan. 

Also, a recent agreement with Toledo, Ohio, which has both a combined 

and a separate sanitary sewer system, 

will eliminate roughly 800 million gallons of untreated sewage annually. 

As part of case settlements such as 

these, EPA also encourages municipalities to perform supplemental environmental projects to help lessen the environmental impacts of their violations 

and secure additional environmental benMarch 2003 3 
���

United States
 

Environmental Protection Agency
 

Office of Regulatory Enforcement
 

(2248A)
 

Washington, D.C. 20460
 

Official Business
 

Penalty for Private Use $300
 

‘Enforcement Alert’ newsletter 

efits. For example, Baltimore will design a $2.7 million biological nutrient 

reduction facility at its treatment plant 

to remove nitrogen from wastewater. 

Under a settlement with the Water 

and Sewer Board of Mobile, Ala., the 

Board agreed to spend $2.5 million to 

purchase and preserve valuable habitat 

in Mobile County and the Dog River 

watershed, repair private residential service laterals in low-income areas, and 

partially fund a database of water quality monitoring data that is available to 

the public. 

Compliance Assistance 

EPA provides guidance, training, 

compliance assistance, and other technical and financial assistance tools to 

state and local agency personnel. EPA’s 

regional offices lead these efforts, conducting training and workshops, participating in workshops, and conducting site visits to assess municipalities’ 

progress in improving the capacity, 

management, operation, and maintenance (CMOM) of their sewage collection systems to eliminate and prevent SSOs. 

Municipal officials looking for SSOrelated information will find a wealth 

of regulatory, technical, and financial 

assistance on a number of EPA 

websites. For example, on the Office 

of Water’s website at www.epa.gov/ 

npdes/sso, EPA offers fact sheets on 

financing capital improvements for SSO 

abatement and implementing an asset 

management approach. Links to guides 

for operating and managing sewage collection systems and developing sanitary 

sewer overflow response plans are also 

included. Users also will soon have 

online access to the Office of Water’s 

CMOM self-assessment checklist. 

For more information about sanitary sewer overflows, see websites in 

“Useful Compliance Resources” column at right. 

For information regarding cases 

discussed in this Enforcement Alert, 

contact Amanda A. Gibson, (202) 564­

4239, Email: gibson.amanda@epa.gov, 

or Kevin Bell (202) 564-4027, Email: 

bell.kevin@epa.gov, Water Enforcement Division, Office of Regulatory 

Enforcement, Office of Enforcement 

and Compliance Assurance. 

For compliance assistance information, contact Sharie Centilla, (202) 

564-0697, Email: centilla.sharie@epa.gov, 

or Walter Brodtman,(202) 564-4181, 

Email: brodtman.walter@epa.gov, Office 

of Compliance, Office of Enforcement 

and Compliance Assurance. 

Useful Compliance 

Assistance Resources 

Office of Enforcement and 

Compliance Assurance: 

http://www.epa.gov/compliance 

Office of Water: 

http://www.epa.gov/npdes/sso 

Local Government Environmental 

Assistance Network: 

http://www.lgean.org 

National Small Flows Clearinghouse (aids small communities 

with wastewater problems): 

http://www.nesc.wvu.edu/nsfc 

Region 4 POTW Management, 

Operation and Maintenance 

Program (MOM): 

http://www.epa.gov/region04/water/ 

wpeb/momproject/index.html 

National Compliance Assistance 

Clearinghouse: 

http://www.epa.gov/clearinghouse 

Compliance Assistance Centers: 

http://www.assistancecenters.net 

Small Business Gateway: 

http://www.epa.gov/smallbusiness 

EPA’s Audit Policy: 

http://oecaftp.sdc-moses.com/ 

compliance/incentives/auditing/ 

auditpolicy.html 

Recycled/Recyclable. Printed with Soy/Canola Ink on paper that contains at least 30% recycled fiber 
 

 

 

 

 

 

 

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ATTACHMENT E 

EVALUATION OF OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE 

FRAMEWORK FOR A PROBLEM-BASED APPROACH 

TO INTEGRATED STRATEGIES (Final, 11/25/02) 

and 

GUIDE TO IMPLEMENTING THE INTEGRATED STRATEGIES FRAMEWORK” 

(Interim Draft, June 2003) 

Part A. Framework Work for a Problem-based Approach to Integrated Strategies (IS) (Final, 

11/25/02) 

Objective: The purpose of these questions is to evaluate whether the Framework for a Problem-based Approach to 

Integrated Strategies, (Framework) issued 11/25/02, meets its goal of “encouraging pro-active consideration of the 

elements of an integrated strategy; including 1) data gathering to further define the problem and universe and develop 

compliance baselines, 2) tool selection and sequencing to effectively address the environmental problems (s), 3) up 

front development of measures to assess progress and outcomes and 4) communication with stakeholders, partners 

and the public. 

1. In what capacity did you receive a copy of the Framework? Please select your primary position: 

EPA Regions EPA Headquarters (HQ) 

“ Regional IS Project Leader “ HQ Project Leader 

“ Regional IS Project Contributor “ HQ project contributor 

“ Regional Compliance Assistance Coordinator “ HQ Program Manager 

“ Regional Enforcement Program Manager “ HQ Compliance Assurance Manager 

“ Regional Compliance Assurance Manager “ Other ____________________________ 

“ Other ____________________________ 

Yes No Not Certain 

2. Have you read the entire Framework? ___ __ _____ 

3. Is the Framework easy to understand? ___ __ _____ 

4. Do you understand what the term “integrated strategy” means? ___ __ _____ 

5. Have you used the Framework to plan, design or develop an integrated strategy ___ __ _____ 

pilot project or other project? 

6. Which elements of the Framework did you use? (Select all that apply.) 

L None (If you choose “None,” do not select any other option below; continue 

to question 7.) 

_____________________________________________________________ 

Elements of Framework Methodology Very

Rating of Elements

 Somewhat Not 

Helpful Helpful Helpful

“ 1) Define the environmental problem, the universe or develop a compliance ______ ______ ______ 

baseline? 

L 2) Consider all compliance assurance and enforcement tools available to ______ ______ ______ 

address the problem? 

“ 3) Select and sequence tools to effectively address the environmental ______ ______ ______ 

problem(s) 

“ 4) Develop measures to assess progress and outcomes? ______ ______ ______ 

“ 5) Define and acquire resources needed to implement the approach? _____ ______ ______ 

L 6) Create an implementation schedule? 

“ 7) Define roles and responsibilities of involved stakeholders? _____ ______ ______ 

“ 8) Create an effective communications strategy with all stakeholders? ______ ______ ______ 

“ 9) Create a means of monitoring and evaluating progress through all stages ______ ______ ______ of the strategy? 

NA 

___ 

7. Would you recommend to a colleague that s/he read and use the Framework? Yes No Not 

Certain 

___ __ _______ 

__ 
 

 

 

 

___ 

___ 

___ 

___ 

___ __ _______ 

__ 

8. Please comment on the Framework as follows:
 

a) Were the questions under each element of the Framework useful to you in developing that part of the
 

strategy?
 

b) Can you suggest additional questions or points to consider under each element?
 

9. Please provide your comments and suggestions to improve the Framework , e.g. additions, deletions,
 

corrections. Please be as specific as possible.
 

10. How would you assess the overall effectiveness/ usefulness of the Framework in developing and
 

implementing an Integrated Strategy Pilot Project?
 

Part B. Guide for Implementing the Integrated Strategies Framework (IS Guide) (Interim draft, June 2003) 

Objective: The IS Guide has been developed to provide further assistance in planning for and piloting the initial 

group of eight regional integrated strategies. The purpose of the following questions is to evaluate whether the 

supplemental guidance meets the purposes stated: 1 ) ensure consistency in the planning, evaluation, and 

measurement of outcomes processes across the IS pilots; 2) identify and explain expectations for the IS pilots; 3) 

elaborate on and provide examples to illustrate select sections of the Framework; and 4) help document the decisionmaking process used in selecting tools to address environmental problems (knowledge management). 

Yes No Not Certain 

2. Have you read the IS Guide ?	 ___ __ _____ 

3. Is the IS Guide easy to understand?	 ___ __ _____ 

4. Have you used the IS Guide to plan, design or develop an integrated strategy pilot ___ __ _____ 

project or other project? 

5. Which elements of the IS Guide did you use? (Select all that apply.) 

L None (If you choose “None,” do not select any other option below; continue 

to question 6.) 

_____________________________________________________________ Rating of Elements

Elements of IS Guide Methodology Very Somewhat Not 

Helpful Helpful Helpful

“ 1) Develop measures to assess progress and outcomes? ______ 

L 2) Consider factors listed for selection, sequencing and segmentation of ______ _______ ______ 

compliance assurance and enforcement tools available to address the 

problem? ______ ______ ______ 

“ 3) Define and acquire resources needed to implement the approach? 

L 4) Create an effective communications plan with all stakeholders? ______ ______ ______ 

“ 5) Create a means of monitoring and evaluating progress through all stages ______ ______ ______ 

of the strategy? ______ ______ ______ 

6. 	Would you recommend to a colleague that s/he read and use the IS Guide? Yes No Not 

Certain 

7. Please comment on the IS Guide as follows:
 

a) Were the questions under each element of the IS Guide useful to you in developing that part of the strategy?
 

b) Can you suggest additional questions or points to consider under each element?
 

NA 

___ 

2
 
8. Please provide your comments and suggestions to improve the IS Guide , e.g. additions, deletions, corrections. 

Please be as specific as possible. 

9. How would you assess the overall effectiveness/usefulness of the IS Guide in developing and implementing an 

Integrated Strategy Pilot Project? 

3