Environmental Management and Compliance

1
Environmental Management and Compliance

• for the
• Arizona Department of Transportation

Update June, 2005
2
Early Study Conclusions

• ADOT does not have a single environmental
  management organization to lead activities.
• ADOT has some serious environmental
  non-compliance problems.
• Management of environmental responsibilities is
  not systematic and comprehensive and without
  adequate environmental goals, objectives,
  measures, policies, procedures and training.
• Top management is strongly emphasizing proactive
  environmental compliance and stewardship.
• Environmental compliance is heavily oriented to
  project development, not planning, construction,
  maintenance and operations.

3
Recommendations

• Create an Office of Environmental Services
• Develop and implement Environmental Management
  Plan
• Conduct a Department-wide staffing needs
  analysis, staffing plan and implementation
  strategy
• Develop a communications outreach plan
• Assess environmental training needs and develop
  plan

4
Organizational Objectives

• Decrease fragmentation of environmental functions
  to achieve better communications, consistency in
  approach efficiencies of operations.
• Elevate visibility of environmental functions in
  ADOT.
• Provide environmental expertise in/to the
  Districts
• Provide a single-point of environmental contact,
  clearinghouse and quality assurance function in
  ADOT
• Locating environmental services in organization
  to service all units of ADOT.

5
Steering Committee Recommendations

• Adopt environmental ethic for ADOT
• Adopt new environmental structure for ADOT to
  meet organizational objectives
• Identify and address the need for additional
  resources for expanded environmental services.
• Ensure consistency of environmental compliance
  across the organization.
• Clarify and articulate respective missions and
  roles for environmental responsibilities
  accountability.
• Focus stewardship on compliance activities in the
  early years.

6
Environmental Structure
Director Deputy Director Chief of Staff
TPD
ITD State Engineer
TSG
MVD
Office of Environmental Services
Development
Operations
Districts
Report
Environmental Planner
Support
7
Office of Environmental Services
Environmental Manager
Permits Coordinator
Natural Resources
Storm Water Coordinator
Compliance Coordinator
Project Development

• Air Quality
• Asbestos
• Emissions
• Water Quality
• Surface water
• Groundwater
• Drinking water
• Solid/Haz Waste
• RCRA generation
• TRI and PP
• UST/AST-SPCC
• Mining
• (matl sources)

District Envir. staff coordination Facilities,
Operations Maintenance compliance
assistance Mitigation Monitoring and
tracking Environmental haz. mat. cleanup
coordination
Storm water Oversight and Management Technical
Support
Vegetation Management Natural Resources
Planning Wildlife Research Management Erosion
control management
Planning/NEPA doc -Project development Technical
Support -Air and Noise teams
Existing positions New positions
8
ADOT Decisions

• Establish new Office of Environmental Services
  by July 1, 2005.
• Reporting to State Engineer
• Prepare PDQs for the new positions and recruit
  qualified professionals for the new Office
  as follows
• OES Manager
• Compliance Coordinator
• Permit Coordinator
• Storm Water Coordinator
• Evaluate the merger of EEG and NRMS or portions
  thereof into the Office.
• Continue with refinements to the Environmental
  program.

9
Environmental Implementation

• Organizational structure Refine roles and
  responsibilities for new environmental office.
• Prepare job descriptions for key environmental
  positions.
• Design program for coordination and delivery of
  environmental services to all parts of ADOT.
• Design and adopt environmental training program
  for all ADOT employees.
• Prepare an Environmental Communications Plan
• Adopt environmental compliance and mitigation
  tracking system for entire transportation
  process.
• Design consolidated program for environmental
  permits.

10
Implementation Schedule
11
Operational Impacts

• New and revised specifications104.09
• Erosion Control Coordinator
• SWPPP, NOI and NOT
• Unique, Impaired and Non-Attaining Waters
• EPA versus ADEQ

12
ADEQ Consent Order

• Individual Permit Process is beginning
• Maintenance BMPs are being developed
• Truck wash stations are being installed
• SWAT Team activities are on going

13
The Journey of a Thousand Miles Sometimes Ends
Very, Very Badly
14
Senior Leadership New Environment Office
Deputy
Field Inspectors