State Innovation Grants

EPA 2005-2006 State Innovation Grants Competition Pre-Proposals

Project Title: Encouraging Superior Environmental Performance Through Management Systems, Recognition, and Rewards.
Location: Statewide, New Hampshire
Applicant: New Hampshire Department of Environmental Services (NHDES)
Contact:
Robert P. Minicucci II, PE
NHDES
29 Hazen Drive, PO Box 95
Concord, NH 03302-0095
(p) 603-271-2941
(f) 603-271-2456
rminicucci@des.state.nh.us

RCRA: This project is not focused on hazardous waste management and permitting under the Resource Conservation and Recovery Act.

Other federal program involvement: As proposed, this project is not being implemented in cooperation with, or funded by, any other federal program.

Federal regulatory flexibility: Federal regulatory flexibility is not anticipated to implement this proposed project. If the project is successful and new programs are started, regulatory flexibility may be sought at a later time.

Endorsement: The work described in this pre-proposal is contained within an identified “Area

for Collaboration” in the approved 2005-2007 NHDES-USEPA Performance Partnership Agreement (PPA), which can be found at: http://www.des.nh.gov/ppa/pdf/FFY2005-2007PPAFinal_02.25.05.pdf . The Area of Collaboration, titled “Encourage Systematic Management for Better Environmental Performance” is on page 26 of the PPA.

This pre-proposal was chosen through a competitive process by an internal review team comprised of the NHDES Assistant Commissioner, Public Information Officer, and Chief of Planning and Policy. Four projects were considered. If this pre-proposal is selected as a finalist, a letter expressing senior leadership endorsement will be included with the final application and proposal.

Summary Budget Information

State: New Hampshire
Agency: New Hampshire Department of Environmental Services (NHDES)
Contact:
Robert P. Minicucci II, PE
NHDES
29 Hazen Drive, PO Box 95
Concord, NH 03302-0095
(p) 603-271-2941
(f) 603-271-2456
rminicucci@des.state.nh.us
Project Title: Encouraging Superior Environmental Performance Through Management Systems, Recognition, and Rewards.

[Budget information removed by EPA]

The State leverage funds listed represent non-federal, in-kind, staff salaries and benefits which will be used to help carry out this project.

Pre-Proposal Summary

This pre-proposal is being submitted under the category “National Environmental Performance Track Program and State Performance-Based Environmental Leadership Programs.” The proposed work plan articulates NHDES’ intentions to encourage systematic environmental management for better environmental performance, within and outside of those areas traditionally regulated, and specifically addresses the agency’s intentions to establish a New Hampshire-based Environmental Leadership Program. It should be noted that NHDES staff have supported EPA’s Performance Track Program since its inception, have participated in past environmental management system-based initiatives, and remain very active regionally, and nationally, notably in the Multi-state Working Group. This grant opportunity is timely in that the 2005-2007 NHDES/USEPA PPA, signed in March 2005, includes an “Area for Collaboration” dedicated to a broad array of environmental management system-based initiatives. There is internal staff enthusiasm and interest in this area to be tapped, in addition to an extensive network of state and federal environmental management system and environmental leadership program experts. The State Innovation Grant provides critical financial resources which will afford NHDES staff the time and attention necessary to build the program as envisioned in the current PPA and in the proposed work plan below. Over the anticipated three-year project period, NHDES will work to:

Increase internal and external awareness and acceptance of the value of a systematic approach to managing environmental responsibilities;
Promote and achieve better environmental performance in regulated areas (e.g., air emissions, water quality, hazardous waste generation, etc);
Promote and achieve better environmental performance in areas not traditionally regulated (e.g., energy use, water consumption, habitat protection, etc); and
Re-allocate limited agency resources based on need and risk by building a system of differentiating organizations on a performance basis.

Proposed Project Work Plan

( Note: Tasks listed from simple to more complex)

Task	Timeline
1. Update and publicize NHDES’ policy on encouraging systematic environmental management.	Grant Award + 30 days
2. Establish enhanced NHDES website resources for EMS-related information.	Grant Award + 90 days
3. Establish and maintain an Advisory/ Stakeholder group. Re-establishes previous group that was active in 1997–2000. May morph into a NH Sustainable Business Roundtable. Meetings held at least quarterly.	Group established by Grant Award + 90 days, then ongoing throughout grant period.
4. Offer assistance in EMS implementation, separately for public and private sectors. See discussion below.	Depends on strategy chosen for delivering the training, but should start by Grant Award + 9 months, then ongoing throughout grant period.
5. Take actions to improve management skills in the SME sector. See discussion below, under Task 4.	Start by Grant Award + 90 days, then ongoing.
6. Encourage larger organizations to mentor smaller ones. May include “greening the supply chain” projects, but not necessarily limited to this area. See discussion below.	Start by Grant Award + 180 days, then ongoing.
7. Establish a multi-tiered Reward and Recognition Program, one tier of which would be equivalent to the existing National Environmental Performance Track. Current working title “NH Environmental Sagamore Program.” See discussion below.	Start by Grant Award + 90 days, then ongoing. Legislation modeled on NH RSA 125:C-6a in 2006 or 2007 session.
8. Project Reports.	Quarterly and at the close of the project period.

The following expands on some of the above-listed tasks:

Task 4: In order to offer assistance in EMS implementation, we will:

Seek opportunities to partner with academic institutions and business service providers in order to expand existing offerings and curricula to include the benefits of a systematic approach to environmental management. The college/university system of NH and business/management schools in the state would be targeted. This work would be supportive of a new “Virtual EMS” project currently being led by Dartmouth College and the University of NH. DES would also explore partnerships with internal and external service providers such as the New Hampshire Pollution Prevention Program, the Small Business Technical Assistance Program, Occupational Safety and Health Consultation, as well the WasteCap Resource Conservation Network, the Small Business Development Center, Manufacturing Extension Partnership, Granite State Quality Council, Sustainable Step New England, NH Businesses for Social Responsibility, etc.
Offer several one-day, introductory seminars on Environmental Management Systems (EMSs) for several different audiences: 1) the State, including NHDES staff and other state agency representatives; 2) Regulated entities - this would likely be repeated a number of times on a sector-specific basis, and perhaps offered through trade organizations/service providers. A focus on the public sector may be desired, in which case, we should partner with the NH Municipal Association and the NH Public Works Academy; and 3) the public.
Note: The one-day seminars could be followed by training courses. These would probably be done on a group basis – several customers enter a training course together and are brought through the EMS design and implementation process similar to the process used in the OWM-sponsored EMS work NHDES completed several years ago and by many others. Two thoughts on this follow-up training: 1) a n NHDES unit, perhaps the 10 mgd wastewater treatment plant the agency operates, or the NHDES laboratory, should be a member of the first training group, as a good opportunity to “lead by example;” and 2) the trainings will be conducted by NHDES staff, with the assistance of a contractor which would be hired through a competitive RFP process.

Task 6: “Greening the Supply Chain” projects are a current interest at EPA Region 1 and also at NHDES. While it is envisioned that the mentoring project described in Task 6 would be broader than just supply-chain relationships, we intend to use this vehicle to support supply-chain projects. It may turn out that establishing mentoring relationships outside of the supply chain is beyond our reach at this time.

Task 7: There are several key sub-steps in establishing the envisioned reward-and-recognition program that are described below:

One is determining the appropriate level and mix of rewards and recognition, and it is expected that the proposed stakeholder group will re-visit NHDES’s conclusions from its work on this subject in the 1990s and experience from the national scene since then. Because past findings indicates that there was no “short list” of effective rewards upon which all parties could agree, NHDES’s current focus is on a contract-based program at the highest tier. At the time, we found that effective rewards and recognition tends to be company-specific, but we do expect that this question will be re-examined through this grant project. We hope to fold in prioritization towards agreed-upon state or regional environmental goals into this discussion.
A key sub-step is improving the acceptance of the base concepts within NHDES. This work not only supports NHDES’s proposed work, but also facilitates delivery of the already-established incentives at the federal level by EPA for Performance Track.
It is essential that NHDES staff work cooperatively with the program offices at the state and EPA-Regional level to change goals and targets to allow work related to Performance Track and New Hampshire’s program to be credited for program-specific purposes. This is absolutely necessary if NHDES is going to be able to fully deliver such incentives as EPA’s “low priority for routine inspections” for members of Performance Track.
Another important sub-step is establishing a Memorandum of Understanding/Agreement with EPA to allow maximum cooperation between Performance Track and New Hampshire’s Environmental Leadership Program. One reason NHDES is interested in establishing a state program is that neither the federal, nor the state program can independently deliver a system of government environmental oversight that allows for differentiation of better “customers” and rewards and recognition of these. In fact, experience has shown that state programs founder on federal requirements, while federal programs are dependent on the states to deliver the incentives and rewards. Both complementary programs need to be in place for maximum effectiveness.
An issue that must be addressed here, and through the work of the stakeholder group (Task 3), is maintaining fairness for Small to medium-sized Enterprises (SMEs). While there is no theoretical reason why SMEs cannot implement EMSs, they very seldom do so for a variety of institutional reasons. There may be legal barriers to giving rewards and recognitions while functionally excluding the majority of New Hampshire’s private sector; the SMEs. The potential for an SME-specific tier in NH’s recognition program will be explored as part of this project. Support to the SME community on management skills in general may be what is needed.
Currently, the proposed program tiers are as follows: 1) a tier which is functionally equivalent to the existing Performance Track program that would have more members, and which could potentially be implemented more quickly; 2) a contract-based tier which would have fewer members, and would take longer to implement; and 3) an “on-ramp” tier which would help companies, particularly the SMEs, slowly gear up for the more rigorous program tiers. This approach will allow the SMEs and those larger companies which may just be starting out to slowly move up to the more rigorous tiers, while at the same time, supporting a continuous improvement ethic.

Program Benefits

We anticipate that the work to be carried out under this proposal would fully support EPA’s Strategy for Determining the Role of Environmental Management Systems in Regulatory Programs, EPA’s Innovations Strategy, and the January 2005 ECOS report Survey of State Support for Performance-Based Environmental Programs and Recommendations for Improved Effectiveness to Administrator Leavitt on National Environmental Performance Track.

NHDES proposes to address the actions outlined above on a continuum that extends from small and simple, to larger and more complex. All of these actions are focused on the following goals for NHDES:

Increasing internal (NHDES) and external (other state agencies, businesses, municipalities, the public) awareness and acceptance of the value of a systematic approach to managing environmental responsibilities;
Getting improved multi-media management of environmental concerns, whether within traditionally regulated or unregulated areas, throughout the state.
Broadening the acceptance in the business community, especially for SMEs, of the concept that good environmental performance leads to better economic performance.
Testing new systems where the recognition and reward of “good” performance produces comparable (and measurable) results to those accomplished through punitive actions for “bad” performance, while at the same time enhancing public involvement, and giving NHDES flexibility in how it allocates limited staff resources for the essential tasks of targeting, inspecting, and enforcing within the regulated community.

Measures of Effectiveness:

As measurements of effectiveness, two areas are proposed. Administrative measures (i.e., “outputs”) would include: 1) the number of trainings offered; 2) the number of parties attending provided training opportunities; 3) the diversity and participation of the proposed stakeholder group; 4) the number of organizations entering mentoring relationships; 5) the participation rate in the new Rewards and Recognition Program and Performance Track Program; 6) the number of voluntary environmental projects initiated by program participants; and 7) other qualitative and quantitative measures of success associated with implementing a state Rewards and Recognition Program.

Environmental/Results-based measures (i.e., “outcomes”) are envisioned to follow the pattern set by the National Environmental Performance Track (“Performance Track”) program, which would allow better comparability and aggregation of data between the agencies. We anticipate linking facility-specific measurements with already established national (EPA), regional (EPA Reg 1) and DES priorities wherever possible. We also anticipate examining the new Facilities Reporting Project (offline as of 09-04-12) to see if that could be used.

The following is offered specifically in reference to criteria in Section 5.2 of the Solicitation Notice:

The proposed approach differs from traditional approaches in that it is holistically Environmental and in that it focuses on positive reinforcement for environmental behavior.
The project builds on the experience gained by NHDES staff through the Office of Wastewater Management’s EMS research project in the late 1990’s, through NHDES participation in the Multi-State Working Group, and through NHDES participation in Performance Track and the earlier (Region 1-specific) StarTrack programs, each of which has given us access to lessons learned from design and implementation of similar programs around the country. The proposed work plans are built on this essential experience.
The quantifiable improvements in environmental outcomes are expected to mirror that which has already been seen in Performance Track. This information would be made available to the public, through our website, as expeditiously as possible. Press releases may be issued, or other means used, to alert people that the information exists. We expect to address the “baseline” issue by seeing how results for a given facility change over time, that is, a facility’s first report would be considered its baseline.
We expect that there will be measurable improvements in NHDES efficiency and operational costs, but this may take longer to become manifest and to measure.
Cost savings and efficiencies gained by the regulated entities that work with the proposed program will be captured to the extent possible. NHDES does not propose to burden such parties with additional reporting requirements; rather, we will encourage them to consolidate and share information.
Public involvement processes must be robust for the proposed program to succeed. The past NHDES stakeholder group (“The NHDES ISO 14001 Advisory Committee”) was a productive, multi-sector group. This is the custom in New Hampshire, and we expect this tradition to continue. As the proposed program represents some basic changes to the more traditional/formal NHDES/regulated entity relationship, public buy-in will be essential to success. We anticipate the new stakeholder group/sustainable business roundtable meeting at least quarterly. Press releases will be issued. Outreach will be proactive.
Environmental justice concerns are difficult to assess for a project of this nature. Where there are such concerns in the area of a given facility or in the design of programs in general, NHDES will assure full compliance with the letter and the spirit of EPA and NHDES Environmental Justice policies. This would probably take the form of specific ad-hoc stakeholder outreach to address specific issues.

Quarterly program reports, and a full project report, including environmental outcomes to date, will be prepared and submitted to EPA, as required. We anticipate this work will be disseminated through the stakeholder group, which will play an advisory role in its preparation, through the New England-regional media organizations and the New England Governors’ Council, through MSWG’s and Performance Track’s networks. There will also be a press release at this stage. We hope that this will help build the momentum experienced around the country for adding reward-and-recognition programs to the mix of government environmental programs.

This project will help build lasting change within NHDES, and elsewhere, and will create renewed energy and focus around a cutting edge topic. The attention garnered by this project will hopefully create additional benefits not directly addressed by this proposal. For instance, this project may prove helpful in developing a proposed “Green State Initiative” for state agencies and for advancing sustainability concepts at NHDES. Refer to the DES/EPA PPA, page 26. We hope it will provide evidence that looking beyond media-specific programs can yield better results, and we are prepared to carry the message forward by consulting and/or mentoring with other states.

The actions proposed in this document support the core environmental quality goals in both EPA’s and NHDES’s Strategic Plans, and as such, will help both agencies meet their respective missions. Further, like all EMS-related projects which are fundamentally holistic in scope, this work will support several cross-media/cross-goal objectives/sub-objectives for both agencies. Based on experience, especially through Performance Track, we anticipate being able to document environmental performance beyond regulatory requirements in the areas described in the EPA Goals of Clean Air and Global Climate Change (#1); Clean and Safe Water (#2); and Compliance and Environmental Stewardship (#5). Specifically, building a NH-based Environmental Leadership (Rewards and Recognition Program) directly supports EPA Sub-Objective 5.2.3 - Business and Community Innovation: “Through 2008, achieve measurably improved environmental performance through sector-based approaches, performance-based programs, and assistance to small business.” Several objectives from the NHDES Strategic Plan are also positively influenced by the proposed work. The work outlined above directly relates to NHDES Objectives 8.2.1, 8.2.2, 8.2.3, and especially 8.3.3, “By July 2005, develop and implement a program to encourage all organizations to move toward sustainability and fully institutionalize an environmental ethic through the use of formal environmental management systems.” In all instances, we will seek qualitative information in addition to quantitative.

In the mere course of building NH’s first Environmental Leadership Program, new, lasting relationships will be forged with the business community, real environmental improvements will be gained in regulated and non-regulated areas, effective partnerships will be created with a diverse set of stakeholders, and a new level of two-way communications and problem-solving will be achieved, both within NHDES, and between NHDES and EPA. Thank you for the opportunity to apply for funding for this work.

State Innovation Grants

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