Toward Integrated Approaches to Compliance Assurance

November 2001
Citation:
31
ELR 11266
Issue
11
Author
Mark Stoughton, Jeanne Herb, Jennifer Sullivan, and Michael Crow

Introduction and Overview

The U.S. Environmental Protection Agency (EPA) states that its mission is to "protect human health and safeguard the natural environment — air, water, and land — upon which life depends."1 Most state environmental agencies formulate their missions in similar terms. Because the national environmental statutes remain the primary tools available to achieve these missions, assuring compliance with those laws and the regulations issued under their authority is a key operational goal of EPA and state environmental agencies. The Office of Enforcement and Compliance Assurance (OECA) is the EPA office with primary responsibility for compliance assurance.

There is broad agreement at the federal and state levels that the traditional, exclusive reliance on penalty-based enforcement approaches to compliance assurance is inadequate. The emphasis in the 1990s on a more partnership-focused, less adversarial approach to environmental policy has led to an increased focus on using multiple tools to advance compliance assurance. When EPA consolidated compliance assurance activities into the OECA in late 1994, one stated purpose was to facilitate coordinated and integrated approaches to compliance assurance, both across and within media.2

Mark Stoughton is an associate scientist in Tellus Institute's Business and Sustainability Group. He holds a Ph.D. in Technology, Management, and Policy from the Massachusetts Institute of Technology (MIT), and a Master's degree in Civil and Environmental Engineering. Jeanne Herb is the Manager of the Public Policy Program at Tellus Institute. Prior to joining Tellus in 1998, she was the founding Director of the Pollution Prevention Program at the New Jersey Department of Environmental Protection (DEP). She holds a Bachelor's degree from Rutgers University (Cook College) in Environmental Studies and a Master's degree from New York University in Environmental Journalism. Jennifer Sullivan is an entering doctoral student in public policy at Brandeis University. Formerly a research associate at Tellus Institute, she holds Masters' degrees in Technology and Policy and in Civil and Environmental Engineering from MIT. Michael Crow is an Associate Scientist in Tellus Institute's Business and Sustainability Group, where he specializes in practical research that helps align economic and environmental priorities and/or informs the "reinvention" of environmental policy. He has a Master of City Planning degree from MIT, and previously worked for the Cadmus Group. The authors gratefully acknowledge funding for this research by the National Academy of Public Administration, with particular thanks to DeWitt John and Rick Minard for their insights, encouragement, and support. We are grateful to the many individuals at U.S. Environmental Protection Agency (EPA) headquarters, EPA regional offices, state environmental agencies, and regulated entities whose insights and experience form the basis of the work reported here.

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