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College Peer Audit Program Progress Report |
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The following summary has been prepared to report on the progress of the HRP Associates, Inc./Halloran & Sage, LLP College Peer Audit Program. It is our hope that, as we move forward, we can
provide these updates as there is news to report.
We prepared this report now because we have just returned from meetings with EPA, both at the headquarters in Washington, D.C. and in the Region 3 office in Philadelphia. We are pleased to report that the HRP/Halloran & Sage College Peer
Audit Program is well received, perhaps very well received. EPA offered suggestions to expedite execution of the program and to simplify and streamline the process. One of the goals of this report is to share that information with all who
have an interest in the program.
First, we will provide an update on where we are in each Region of the country:
REGION 2
In Region 2, we conducted a program under the auspices of the Association of Independent Colleges and Universities in New Jersey (AICUNJ). AICUNJ organized a program involving 12 New Jersey campuses in concert with New Jersey Council of
County Colleges (NJCCC). Training was conducted at Centenary College in late Spring of 2006. Audits began in Fall of 2006 and carried over into Spring of 2007 when they were concluded.
We have
attached various letters received by participating colleges and universities which show the total amount of fines and penalties waived by EPA Region 2, as well as a breakdown revealing which fines were for hazardous waste, air
pollution, water pollution, etc. These numbers were provided by EPA and are exciting.
On March 4th of this year, AICUNJ is hosting a get together for all of the New Jersey peer auditors, college contacts, college administrators, and others associated with the program in New Jersey. The object is to discuss lessons learned
and environmental management systems (EMS), but perhaps more importantly is the chance to get everybody together again, have a good meal and trade stories.
REGION 4
On February 2, 2007, EPA Region 4 mailed a letter to all of the colleges in Region 4 "inviting" those colleges to self-audit and gives notice of their intention to do so within 30 days. The obvious consequence of not giving that notice was
that all non-notifying schools would be placed on a list of colleges to be inspected by EPA with violations fully subject to fines. As this letter was addressed to "Dear College/University Administrator", it did not often end up in the
office of the College President. Consequently, it was two weeks before the various State Associations became aware of the letter. When the letter was discovered, the action of the Associations of Independent Colleges was heroic. In
Tennessee, (TICUA), Claude Pressnell and Susanna Baxter; North Carolina (NCICU), A. Hope Williams and Francis Fontaine; Florida (ICUF and FICURMA), Ed Moore and Ben Donatelli; Georgia (GFIC), Hank Hector; Alabama (AAICU), General Hankins
and Audrey Klein asked us to quickly brief them about the Peer-Audit Program. They, in turn, arranged meetings, primarily by teleconference, with their member colleges and, in a period of two to three weeks, organized programs in five
states. Simultaneously, they authorized us to meet with EPA Region 4 in Atlanta to obtain additional time and negotiate a contract under which the colleges could obtain the benefits of maximum penalty reduction. Very quickly, 109 colleges
joined the program and in May and June of 2007, over 300 peer auditors were trained on college campuses in each of the five states, courtesy of Lipscomb University, Duke University, Nova Southeastern University, Emory University, and
Birmingham Southern College.
Following the training, Emory University hosted a ceremony at which agreements were formally signed between EPA and each of the State Associations and their constituent colleges. This ceremony was conducted as part of Emory's
sustainability conference and was attended by EPA Regional Administrator, Jimmy Palmer.
In the fall of 2007, we conducted audits on 25 campuses in Region 4, (five colleges in each state). All 25 have disclosed violations to EPA. Most have completed their sixty (60) day correction period and are preparing Final Completion
Reports. We are moving promptly to conclude those compliance reports before the start of the next round of 25 audits this Spring.
REGION 5
In Indiana (ICI), under the guidance of Bob Hodge, a task force was formed to investigate the Peer Auditing Program. We were able to present the Webinars to the task force and, shortly after the first of the year, Bob called to authorize
us to open negotiations with EPA Region 5 in Chicago. Those negotiations are underway and meetings have been set for February 25th and 26th to meet with colleges in Indiana (and perhaps some "visitors" from other states in Region 5). We
may run the Webinars at the same time so that other Indiana colleges and other Region 5 colleges and associations might be able to participate.
There is interest in Ohio as well. We have run the Webinar for the "Ohio 5", under the direction of Susan Palmer. Bob Burke from AICUO viewed that Webinars and has participated in various conference calls about the program. We hope that
colleges in Ohio will flatter us with their participation as well.
Similarly, at the invitation of Don Hartz (MCF), last Fall we presented the program to college CFOs in Michigan, and Don has remained in contact with us since and has requested a meeting in early February, 2008.
REGION 7
In December 2007, we were flattered to receive a call from Doug Penner of the Kansas Independent College Association (KICA) and Fund (KICF), which authorized us to open negotiations with EPA Region 7 in Kansas City to provide an agreement
under which the Kansas colleges could enjoy the benefits of the Peer Auditing Program. We had previously spoken to a meeting of college CFOs in Iowa, so colleges in that state are aware of the program as well. Negotiations for an agreement
are underway between Halloran & Sage and regional counsel in Kansas City.
IMPROVEMENTS
During the fall and into the winter, HRP continued to improve its software program based on the experience of the Fall audits. We are proud of the way it is running, and smiled broadly as that software was reviewed last week at EPA
headquarters and the EPA regional office in Philadelphia. That software is becoming an advertisement for the program.
In addition, we created "Webinars" so that we no longer have to rely on telephone conferences or opportunities to get large numbers of people in a room. Now the Webinars about peer auditing can be presented to anyone who has a computer,
and the audio can be broadcasted to anyone who has a telephone, all on an interactive basis. You are welcome to call to arrange a presentation wherever you might feel it helpful.
MEETINGS WITH EPA
On January 24 and 25, 2008, Tad Goetcheus from HRP Associates, Inc. and David Losee from Halloran & Sage, LLP met with EPA officials at the Region 3 office in Philadelphia and the headquarters in Washington, D.C. The EPA had general
observations, suggestions for streamlining the program, and requests for expansion of the Peer Audit Program, as we will explain. Every EPA official to whom we spoke was supportive of the College Peer Audit Program.
EPA representatives revealed that they have been on some of the campuses at which we have completed the programs and they found a number of things. First, the audits being conducted appear to be of high quality. They conclude this because
upon visiting the campus, they did not find evidence of non-compliance that auditors might have missed. Second, the items of non-compliance noted in the final compliance report, which were documented to be fixed were, in fact, fixed.
Third, there really does seem to be a "cultural change" at the audited campuses. Environmental compliance becomes a positive thing, is part of "what this community does". Fourth, it appears that colleges are moving toward sustainability
and formally or informally are developing Environmental Management Systems (EMS).
It appears that EPA officials in Regions 2, 3, 4, and 5 have been discussing the Peer Audit Program and how it might be improved. Not surprisingly, EPA was concerned about making their review of our submissions streamlined in the direction
of what EPA needs to know. Consequently, they asked us to provide a section within our disclosures and compliance reports on duration of the violations, quantities of substances illegally discharged or in violation, to determine permit
needs and generator status during the audit rather than after disclosure, and to reduce the amount of narrative of the reports in favor of more exhaustive spreadsheets in the reports. Of course, as many of you know who have gone through
the on campus audit and reporting, we began making those adjustments last Fall and will have them fully implemented this Spring via electronic data collection. Apparently, our internal review of the program coincided with EPA's review, and
we are pleased to report that we independently came to the same conclusions, which are being implemented!
EPA also offered us some direction. First, EPA continues to believe that EMS is an effective tool to: (1) obviate the need for future audits, (2) complete and sustain the cultural change, and (3) move colleges toward the ultimate goal of
sustainability. EPA has offered their support, materials, and advice as we move ahead toward EMS for the colleges. As some of you know, it is our intention to "roll out" an EMS program for consideration by our participating colleges on or
about March 1, 2008.
Second, EPA seems puzzled by independent colleges that did not take advantage of this program, as well as hesitation of the community colleges and public colleges in states where the independent colleges have taken the lead. We discussed
the logistical problems with which state and community colleges are burdened. It appears that EPA is prepared to enter into a separate contract which would allow participation by public colleges in a manner which honors their purchasing
requirements and funding hurdles, etc. EPA seemed to be hoping that participation by the independent colleges could help bring the public colleges into the program. EPA was also interested in why in EPA Regions 3, 4, 5, and 7 some of the
state associations and constituent colleges have elected not to participate. (It should be noted that we only discussed with EPA those states that allowed us to discuss their participation in the program). We explained that we could not
speak for anyone other than those who had authorized us to speak for them but would try to get the word out.
SUMMARY
Our impression from meeting with EPA is:
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EPA is very supportive of the College Peer Auditing Program.
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EPA's support is based on their review of the work that has been completed. While we would like to take credit for running an effective program, it is you, the colleges and universities, who participated in this program who have made it
successful.
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High-ranking officials at the EPA are enthusiastic about your efforts, which is very much to your credit.
It has been and will continue to be a pleasure working with all of you. We welcome your comments and suggestions. The HRP/Halloran & Sage team has the Webinars available wherever you feel it might be useful. Please feel free to contact us.
Our team is also available to come to your annual meetings or wherever else we might be of service to you. We look forward to an exciting and successful 2008!
Tad A. Goetcheus, P.E.
HRP Associates, Inc.
800-752-3922
tad.goetcheus@hrpassociates.com
David B. Losee
Halloran & Sage, LLP
860-297-4659
losee@halloran-sage.com
Please Note:
The preceeding information is being shared with the participants in the College Audit Program. Please respect its confidentialty. Thank you.
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