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Indiana
Program Title/Location
CLEAN Community Challenge, State of Indiana
(Comprehensive Local Environmental Action Network)
State Agency Applicant
Indiana Department of Environmental Management (IDEM)
State Contact Information:
Karen Teliha, Pollution Prevention Branch Chief; IDEM/OPPTA; 402 West Washington St., Rm W04; Indianapolis, IN 46204; Phone: (317) 233-5555; Fax: (317) 233-5627; Email: kteliha@dem.state.in.us
Other Potential Partners:
This project includes hazardous waste management and permitting options under the Resource Conservation and Recovery Act.
This project is not being executed in cooperation with or funded by another federal or EPA program. Although, this program does encourage participation in several federal and EPA programs such as Environmental Management Systems, Smart Growth, LEED Buildings, and more.
No regulatory flexibility from any federal requirements is needed to implement the project
As the attached letter indicates, the IDEM Commissioner knows of and supports this project.
Pre-Proposal Narrative
Introduction
The following proposal is submitted by the Indiana Department of Environmental Management (IDEM) for funding to develop and implement a voluntary program designed to encouraged positive environmental actions, that could include reduced air, land and water emissions and discharges, by Indiana municipalities and businesses . Participants must pledge to be a CLEAN Community and take subscribed actions in order to be lauded on a statewide basis. The Challenge would consist of various action levels that build on each other until ultimately, the participants have planned, developed, and implemented an environmental management system (EMS) that includes input and support from the community and local business. IDEM believes this program demonstrates broad, strategic innovation. Participants must work with other community members to implement environmental programs that could include stormwater issues, recycling, and emission reductions of Indiana's top Chemicals of Concern to the land, air, and water. The goal of this program is to improve Indiana's environment community by community. This program will form new partnerships between the State, local government, and business and will encourage communities to set and achieve their own environmental goals. Participants must submit annual progress reports. Success will be measured by the number of participants, reduced emissions, and increased compliance rates. Other successes will include increased participation in federal programs such as LEED, GREEN Communities, Smart Growth, National Performance Track, and more. Potential benefits to participating communities are being considered and may include reduced recordkeeping and reporting requirements in permits and increased chances of receiving state grants and loans . Benefits to the State may include increased compliance rates with environmental regulations and permits, decreased releases to the environment, increased site remediation and brownfields cleanup, and possibly expedited permits from municipalities to local businesses.
Project Schedule and Timeframe
| Spring 2004 | Finalize development: Bid for contracts to provide technical assistance |
| Summer 2004 | with EMS audits (depending on award amount); Complete any necessary training for staff promoting the program; Finalize partnerships and responsibilities. |
| Summer 2004 | Promotion: Web site complete; Brochures printed and distributed to mayors and other interested parties; Press event held, possibly during Pollution Prevention Week, to announce program. |
| Summer 2004 | Implementation: Responding to requests for assistance; Providing on-site |
| Fall 2004 | assistance to municipalities, offering EMS training programs to municipalities; Accepting applications for municipalities joining the program. |
| Winter 2005 | Implementation and Modifications: Reviewing and announcing municipalities meeting |
| Spring 2005 | the Challenge; Continue assisting municipalities and promoting the program; Speaking at quarterly mayor meetings to promote the program and at municipality conferences; Modifying the program as necessary if problems are encountered; Quantifying success stories through monetary and environmental benefits. |
| Summer 2006 | Implementation and Documentation: Continue program as described above; Begin development of final report; Begin consideration of future of program. |
| Fall 2006 | Final Report: Complete and submit Final Report to EPA; Determine future of program. |
| Winter 2006 | including funding and office responsible for management; Modify program as necessary. |
Program Criteria
a) Target Priority Environmental Areas
This project allows municipalities the flexibility to choose from an endless number of projects to address local environmental issues including greenhouse gases, smog, water quality, and water infrastructure. Each level of recognition builds on the other, assisting the municipality in the planning, development, and implementation of an environmental management system (EMS). The EMS will address continuous improvement and management of environmental issues in the community. The higher the recognition level, the more environmental issues the municipality must address. Participants choose the environmental issues they will include in the EMS. IDEM expects the environmental issues to fall into one or more of the following areas of environmental media: Pollution Prevention, Energy Use, Water Use, Water Discharges, Transportation, Materials Use, Air Emissions, Environmental/Children's Health, Community Sustainability, Solid Waste Generation, Hazardous Waste Generation, Accidental Releases and Emergency Response, Preservation and Restoration, and Vulnerability and Security Issues.
Although IDEM's Office of Pollution Prevention & Technical Assistance will administer this program, many other IDEM offices will be involved in developing the program, reviewing applications from municipalities, and determining compliance histories. Based on discussions with city mayors, IDEM offices such as the Office's of Air, Water, and Land Quality will all be considering which rewards are feasible for this program. Rewards being considered include faster permit turn around time, reduced record-keeping requirements, and providing lower interest SRF loans and extra credit points during grant application reviews. Outside partners, such as the Indiana Department of Commerce, are also planning on participating in the development of the program and possibly in providing awards such as extra credit points when determining grant winners. The Indiana Association of Cities and Towns is assisting in the development of the program and may assist in promoting the program to their constituents. Finally, IDEM is considering partnering with a technical assistance provider for the program. Purdue University's Clean Manufacturing Technology and Safe Materials Institute (CMTI) is one potential partner. CMTI is one of seven local PEER Resource Centers in the nation. PEER, the Public Entity Environmental Management System Resource Center, is a one-stop shop for EMS information and resources for public organizations. As the Local PEER Resource Center, CMTI provides technical expertise, field-tested tools, support for EMS implementation, and local contacts and resources. CMTI also has ISO 14000 certified trainers and evaluators who can assist in environmental plan development and implementation.
b) Likely Improvement in Results from Project Implementation
How does the proposed tool or approach differ from current methods?
As discussed in the Innovation Strategy Report, it is important to emphasize the results rather than the means to achieve them. The CLEAN Community Challenge is designed to be flexible - municipalities choose activities that fit their community goals and proceed through levels of achievement at their own pace. Each recognition level has its own requirements with many options to choose from and always encouraging the municipality to develop new ideas to achieve the results they desire.
Unlike National Performance Track, this project focuses on municipalities. Very few members of National Performance Track are municipal facilities. There appears to be a need to provide them with specialized assistance. Further, although a POTW or Landfill owned by a municipality is eligible for National Performance Track, the entire municipality is not included. Therefore, there are many opportunities to encourage municipalities to look at the "big picture" to include projects beyond the typical environmental facilities in a municipality.
Although EMS programs for local governments already exist, the CLEAN Challenge goes further to actually provide formal recognition to participating municipalities as they work toward implementing an EMS. Currently available programs offer recognition once an EMS has been implemented, but for a municipality, this can be overwhelming. The CLEAN Challenge offers incentives of completing key components and receiving recognition at each step along the way until ultimately, a complete EMS is implemented. This approach is also unique in the benefits to participating municipalities including meeting with the IDEM commissioner on a regular basis to discuss environmental concerns, and other benefits previously mentioned. Finally, a key to the success of this program is ongoing, free on-site, confidential assistance from EMS trained staff at IDEM and CMTI who will help guide municipalities through an EMS.
How does the project build on "lessons learned" from prior experience?
For the past eight years, IDEM has managed several sector specific recognition programs each designed with varying levels of commitment from participating facilities. In addition, IDEM has just completed a Toxic Reduction Challenge for industries. Many lessons have been learned from these programs that will be applied to the CLEAN Challenge including ensuring buy-in from IDEM management, having support in place to assist applicants through the process, working with stakeholders to develop a program they can "sell" and receive benefits from, monitoring and modifying the program when problems are found, and developing a system to track and report progress to participants and stakeholders.
What are the quantifiable improvements in environmental outcomes expected to result from implementation of this innovation?
IDEM plans to see results that include an increase in compliance rates, a reduction in releases to the land, air, and water, and improvements in several environmental media to include water and energy use, waste generation and disposal, reduced environmental impacts from public transportation, environmental remediation, and improvements in vulnerability and security issues related to drinking water plants and hazardous chemical use. Because municipalities will be allowed to choose their environmental goals, Indiana should see results in a variety of areas from decreased asthma rates due to reduced pesticide use and less diesel bus idling in school systems to improved water quality from fully implemented NPDES permits. IDEM will track these results through the annual reports provided by participating municipalities as well as through the Toxic Release Inventory and other environmental data available to IDEM.
What are the measurable improvements in administrative efficiency and program operational costs that may results from the program?
The number of permits generated as well as permit turn-around time will assist in tracking administrative efficiency. It is IDEM's hope all agencies and organizations participating in this program see benefits. Some general benefits may include increased numbers of grant applicants as well as improved quality grant applications, higher frequency of contact with communities through phone and on-site assistance and through conferences and workshops to talk about regulatory requirements, EMSs, and other compliance information. Technical assistance providers such as CMTI will have increased contact with municipalities interested in learning about or implementing an EMS.
What are the quantifiable costs and efficiency improvements for the permit holders/regulated entities resulting from implementation of this innovation?
Pilot programs funded by EPA ( Second EMS Initiative for Government Entities April 2000-March 2002 Final Report, October 2002 ) have shown that the average municipality EMS program needed 4,331 direct labor hours costing $126,223 internal dollars over two years. According to EPA's report referenced above, EMS implementation provides a variety of returns on the investment including economic savings, improved relationships with regulators and stakeholders, practices that reduce costly mistakes, improved operational efficiency, and better public image. In the EPA report, several municipalities provided dollar related rate of return that varied from a $300,000 savings from operating improvements including energy efficiency to an annual cost savings of $868,000 for efficient use of equipment, fuel, and water.
c) Measuring Improvement and Accountability
What are the goals for environmental improvement?
There are several goals for this program: reducing toxics in Indiana's environment, increased implementation of environmental management systems, improved compliance rates, increased efficiencies in permitting, improved partnering between State and local governments, improved communication between local government and citizens, and increased recycling and pollution prevention implementation. It is the goal of this program to require participating municipalities to report annually actual results of having an EMS in place to include: number of BTUs of energy conserved, number of gallons of water conserved, amount of money saved, pounds of hazardous waste prevented or reduced, etc.
What are the indicators that will be used to show environmental improvement?
Compliance rates, number of SEPs for municipalities, toxic releases through the Toxic Release Inventory (TRI), and permitting efficiencies can all be measured by IDEM. Annual reports provided by participating municipalities will describe other environmental successes they may not be reflected in IDEM's data.
How and when will the baseline measurements be developed?
IDEM has been using TRI data to measure trends for several years. Baselines for all measurements will likely be based on 2002 data. IDEM is also considering how to best use permitting and compliance data to track improvements. Data being considered include number of permits issued to municipalities, average length of time to issue a permit or make a modification, etc. is currently available from each program area. Formal baseline development will likely be determined in the Winter of 2004. Applicants to the program may be required to complete an initial survey to assist in determining a baseline.
What is the plan, timeline, and commitment for measuring and evaluating how well the project meets its goals and objectives?
IDEM is committed to track, measure, report, and evaluate results of this program. From the moment the program begins, data will be collected. Site visits and phone assistance provided by IDEM and CMTI will be electronically tracked. Data will include the most common question and roadblocks to municipalities. Results of site visits and meetings with municipalities will also assist in gathering information. Participating municipalities will be tracked. TRI data will be tracked and reported annually. A system of tracking permits issued is already in place at IDEM and will continue to be used to measure success of this program. IDEM currently has a Compliance Enforcement Team that meets bi-weekly to manage the Agencies compliance efforts. This Team will be providing data as to how project goals and objectives are being met. Finally, as previously mentioned, annual reports submitted by municipalities will be extremely helpful in providing data as to the successes occurring at the local level and will also be provided to the public.
To inform stakeholders of the progress, copies of reports will be provided. IDEM will regularly update its web site for this program to provide results on the successes communities see. Annually, IDEM will provide updates through our State of the Environment Report. As requested, IDEM will provide results to EPA including a final report. As problems arise, the program will be evaluated and changes made to accommodate.
What are the expected short-term results to be obtained through this innovation and how will they be measured?
The CLEAN Challenge should increase the quantity and improve quality of grant applications related to recycling, energy, and transportation. Improvements in the permitting process for air, water, and land permits should occur through better communication and the potential for allowing beneficial changes to permits with less IDEM paperwork. Overall partnerships between IDEM, CMTI, the Department of Commerce, Indiana cities and towns, and other should improve.
What are the expected long-term results to be obtained through this innovation, how will they be measured, and what is the time span for those results?
IDEM would like to see this program succeed and eventually develop additional programs for industry to allow them to take advantage of permitting improvements. Improvements to the environment should continue to occur. Increased citizen participation in environmental efforts should grow. Overtime, IDEM hopes to see increased buy-in from other agencies who can offer additional benefits to participants.
d) Transferring Innovation
What methods will be used to document the outcomes and methods of this innovation and make the information available to other jurisdictions?
Press releases and press events will likely occur to share local success stories as a result of this program. Because IDEM has regional offices, there are many opportunities for the directors of these offices to personally recognize a city or town for their dedication to the environment. IDEM provides an annual State of the Environment report and annual Pollution Prevention Report. Both will be used to report the results of the program each year. Further, any result through TRI that can be tied back to this program will be promoted in an annual TRI press release. IDEM staff are members of STAPPA/ALAPCO and the Great Lakes Regional Pollution Prevention Roundtable and both provide forums for sharing programs such as this one. IDEM will also maintain a web site to document the success of the program. A final report will be available and IDEM would be willing to present it at conferences such as the National Pollution Prevention Roundtable and the Great Lakes Regional Pollution Prevention Roundtable.
What is the specific potential for widespread application or use of the tool/approach as a model for "next generation" environmental protection?
This program is transferable to other states without major changes to regulations.
How will the application of this innovation be used to promote organizational system change, or develop a culture of innovative environmental problem-solving as a "way of doing business" within the State or more broadly?
An EMS is an organizational approach to managing environmental issues. With frequent staff turnover at municipalities, it will be beneficial for a plan to be created to meet continue to meet their environmental responsibilities even through change. By teaching municipalities that managing their environmental issues through an EMS, they should be able to identify problems and have a more efficient program for implementing solutions. If this program leads to positive results in permitting, it is likely additional programs can be accepted for industry.
What commitments can the proposing State make to provide consultation and mentoring to other States wishing to adopt similar innovations?
As with other recognition programs developed by IDEM, assistance to other states will be provided. IDEM will document the pros and cons of the program, problems that had to be solved, costs involved, partners needed, and other information that may be helpful to implement a similar program.
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