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In early 2007,
EPA Region 4 launched a College and University Compliance Incentive Initiative to encourage colleges and universities in the southeastern United States to conduct voluntary environmental self-audits. As such, in February 2007, slightly
over 400 letters to four-year public and private colleges located in EPA Region 4 were mailed. This letter highlighted the opportunity for a college or university to take advantage of EPA's Audit Policy (formerly known as the Incentives
for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, Notice, 65 F.R. 19618, April 11, 2000).
The Audit Policy provides incentives for regulated entities that voluntarily discover (through audits), promptly disclose (within 21 days), and expeditiously correct non-compliance (within 60 days of disclosure). Disclosures meeting the
necessary conditions of the policy may receive a partial or complete reduction in financial penalties.
Utilizing the EPA Compliance Incentive Initiative, HRP Associates, Inc., with legal partner
Halloran & Sage, LLP, negotiated an Audit Agreement with 108 private colleges/universities and two public universities in the states of Alabama, Florida, Georgia, North Carolina, and Tennessee via the Associations for Independent
Colleges and Universities within each respective state. The audit agreement is an effective mechanism for resolving a broad range and number of institution wide violations discovered during environmental audits pursued under EPA's Audit
Policy.
Through the signed Audit Agreement, these colleges and universities are voluntarily cooperating with EPA to conduct audits over the next three years. Furthermore, the audits will be accomplished through the use of peer audit teams, which
should help in identification of new opportunities for conservation, as well as providing the potential for sharing of best practices among institutions.
Peer Audit Program Approach
Under the Peer Audit Program, an experienced college peer audit team (i.e. consultant and attorney) trains approximately four college faculty and staff (i.e. peers) from each college on environmental compliance in a group setting over a
three-day period at a centrally located college campus. These "peer auditors" then audit colleges (other than their own) under the guidance of a professional auditor. The college saves significant dollars by using peer auditors instead of
professional auditors.
The peer audit approach has succeeded because peer auditors are able to elicit unusual cooperation from the faculty and staff of the audited college, reduces the vulnerability (avoidance of fines and "low inspection priority"), provides
cost savings to the colleges, provides opportunities for positive press (institution being viewed as proactive not reactive), and is conducive to fostering a collaborative effort between colleges and universities. A further benefit is that
trained, experienced peer auditors return to their campuses much better equipped to monitor environmental compliance at their own schools, ensuring a safe living and learning environment
The Peer Audit Program utilizes software created by HRP, and it is tailored to college and university requirements, training manuals and teaching modules, with developed templates for use at each stage of the process.
US EPA Region 4 Signing Ceremony
On June 25, 2007, an Audit Agreement signing ceremony between EPA Region 4 and Participating Colleges and Universities was held at Emory University in Atlanta, Georgia. The event allowed the State Associations of Colleges and Universities,
The associated participating colleges/universities, HRP, Halloran & Sage, and EPA Region 4 to celebrate and broadcast the partnership to ensure compliance with environmental laws and promote environmental stewardship among the regional
colleges and universities.
For more information, please contact Tad Goetcheus, P.E. at 800-752-3922 or via
email.
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