Cal/EPA Environmental Management System Project
Final Model Pilot Project Work Plan
Adopted June 20, 2000

The Model Pilot Project Work Plan serves as a template for the development of specific work plans that will describe how each pilot project will be conducted and completed.   The specific work plans will include descriptions of roles and responsibilities, schedules, research objectives, stakeholder involvement, data management procedures, and data assessment and analysis techniques.  Prior to adoption, the specific Pilot Project Work Plans will receive input from either the Southern or Northern California Working Group, depending on the location of the respective pilot facility.  The Pilot Project Work Plans shall not be considered contracts or legal agreements and do not bind the pilots or Cal/EPA to any particular action.

The final Model Pilot Project Work Plan is written in plain and italicized text.   Language that is to be included in all work plans is indicated by plain text.   Italicized text in the model indicates specific information that is to be written into each Pilot Project Work Plan.

Section 1. Introduction

1.1. Cal/EPA Environmental Management System (EMS) Project
Finding effective and innovative ways to achieve superior environmental protection is the primary goal of the Cal/EPA Innovation Initiative Environmental Management System (EMS) Project.  Increasing use of EMSs by industry and government provides an opportunity to examine the benefits EMSs bring in protecting and enhancing California’s environment.

In order to examine the potential environmental benefits of EMSs, Cal/EPA has selected seven pilot projects. The information collected through the pilot projects will be reported to the Governor and Legislature quarterly, with the final analysis due January 1, 2002.

1.2. Purpose of Pilot Project Work Plan
The purpose of the Pilot Project Work Plan is to describe how the work of the Pilot Projects will be carried out and the goals of the program accomplished. This includes describing roles and responsibilities, schedules and milestones, research objectives, stakeholder involvement, data management procedures, and data assessment and analysis techniques. The Pilot Project Work Plan shall not be considered a contract or legal agreement and does not bind the Pilot or Cal/EPA to any particular action.

Section 2. Project Management

2.1. Project Description

2.1.1. Background
This section shall include a description of the Pilot Project. The description shall include the activity or function of the entity, the number of employees, and its location.

2.1.2. Project Scope
This section shall describe the scope and maturity of the pilot’s EMS and shall identify any unique aspects of Pilot Project including involvement in other innovative regulatory programs.

2.1.3. Research Objectives of the Cal/EPA EMS Project
Organizations are increasingly turning to EMS as a means to ensure compliance with environmental regulations and to drive their environmental performance beyond what is required by law and regulations. Anecdotal evidence suggests that the use of an EMS can result in improved environmental performance; however, very few empirical studies exist to support this claim. The objective of the Cal/EPA EMS Project is to collect empirical data necessary to determine what effect, if any, an EMS has on an organization’s environmental performance and on the quality and quantity of environmental information shared with the public.

California law (Assembly Bill 1102, 1999) specifies that the Cal/EPA Innovation Initiative EMS Project shall answer the following questions:

1. Whether and how the use of an environmental management system by a regulated entity that participates in a Pilot Project:

a) increases public health and environmental protection over those protections provided through the issuance, enforcement, and monitoring of any permit, requirement, authorization, standard, certification, or other approval issued by a federal, state, regional, or local agency to the regulated entity for the protection of public health or the environment.

b) provides the public with greater information on the nature and extent of the public health or environmental effects of activities or processes engaged in by the regulated entity than that information provided through the issuance, enforcement, and monitoring of any permit, requirement, authorization, standard, certification, or other approval issued to the regulated entity by a federal, state, regional, or local agency for the protection of public health or the environment, or any other law or regulation governing the disclosure of public information.

2.1.4 Research Objectives of the Pilot Project
While the above stated Research Objectives are general and relate to the questions presented in AB1102, Pilot-specific research objectives should be described here. The purpose of the Pilot-specific research objectives is to specify how the Pilot intends to address and answer the questions presented in AB1102. For example, the Pilot may state that an objective is to demonstrate improvements in public health and environmental protection by reporting the accomplishments of their Zero Waste program. An agricultural Pilot might state that through measuring biodiversity on the farm, conclusions could be drawn relating to the environmental benefits of their permaculture program. The Pilot Project research objectives will likely relate to the objectives and targets specified in their EMSs. The Pilot Project research objectives should help focus data collection, ensure that all appropriate data is collected and create a database that will support conclusions of the Pilot Project.

2.2. Pilot Project Organization, Roles and Responsibilities

2.2.1. Cal/EPA

As the administrator of the Pilot Project, Cal/EPA will:

• Provide data collection protocols;
• Provide a project manager to coordinate the collection of data; represent Cal/EPA, and provide technical assistance to the pilot;
• Assist in data collection;
• Coordinate data input to the national database on EMSs maintained at the University of North Carolina;
• Facilitate communication with stakeholders and coordinate Northern/Southern California Working Group;
• Provide training on the subject of Environmental Management Systems;
• Communicate to the California Legislature and Governor on the progress and conclusions of the Pilot Project;
• Communicate with stakeholders on the progress and conclusions of the Pilot Project.

Cal/EPA Project Manager and Primary Contact

Name, title
Address
Phone
Facsimile
E-mail address

Cal/EPA EMS Project Director

Ms. Jennifer Smith Grubb
Cal/EPA, Department of Toxic Substances Control
2151 Berkeley Way, Room 515
Berkeley, California 94704

Assistant Secretary for Environmental Management and Sustainability, Cal/EPA

Dr. Robert Stephens
2151 Berkeley Way, Room 515
Berkeley, California 94704

2.2.2. Pilot Project
As the Pilot, (pilot’s name) will:

• Contribute data on the design and operational performance of their Environmental Management System that is consistent with the data collection protocols of the Cal/EPA EMS Pilot Project;
• Participate in one of the Stakeholder Regional Working Groups;
• Communicate with stakeholders about the design and performance of their EMS.

Pilot Project Manager and Primary Contact

Name, title
Address
Phone
Facsimile
E-mail address

2.2.3. University of North Carolina and Environmental Law Institute
The University of North Carolina (UNC) and the Environmental Law Institute (ELI) maintain the national Database on Environmental Management Systems. Information is provided to the national database by states conducting Pilot Projects in the Multi-State Working Group (MSWG). The MSWG is a coalition of states, non-governmental organizations and businesses interested in the application of EMS in public policy.

UNC and ELI will:
Enter pilot data into the national EMS database;

• Review data for completeness;
• Respond to the Pilot Project and Cal/EPA detailing missing data, questions, or need for clarification;
• Return data to pilot and state for accuracy review;
• Maintain web site at www.eli.org/isopilots.htm where data protocols can be accessed;
• Publish public reports on national Pilot Projects.

UNC Project Leader

Deborah Amaral, Ph.D.
Adjunct Associate Professor
CB#3435, Abernathy Hall
Chapel Hill, NC 27599-3435
(919) 962-9827; fax (919) 962-5824
NDEMS@unc.edu

2.3. Project Schedule
To be completed by the project managers and Cal/EPA.

2.4. Stakeholder Involvement

2.4.1 Activities of the Pilot Project
The involvement of interested parties is described in this section including the Pilot Project’s participation in a Regional Working Group, and in some cases a Local Advisory Group. Any other planned vehicles for stakeholder participation or public information should be included, for example facility tours, web sites, news letters, advisory committees. At a minimum, the Pilot shall participate in one of the Regional Working Groups.

2.4.2. Regional Working Groups
The Regional Working Groups (Northern and Southern California) are the primary vehicle for stakeholder involvement in the Cal/EPA EMS Pilot Project. A stakeholder is any interested party (organization or individual) who may be affected by the activities of Cal/EPA, or of a Pilot, and is interested in contributing to the Cal/EPA EMS Pilot Project.

The purpose of the Working Groups is to act as a public forum for the evaluation, analysis, and discussion of Environmental Management Systems in general and the EMSs of the Pilot Projects specifically. The working groups should take an active role in evaluating the Pilot’s EMS, assist in analyzing data generated by the Pilot Project, and participate in answering the questions presented in AB1102. The Working Group may also provide suggestions to Pilots for improving their EMSs.

The Working Groups shall be a forum for education, networking, and open communication between industry, regulatory agencies, environmental or community interest groups, and academics. Establishing cooperative working relationships between various stakeholders is a primary goal of the working group.

Cal/EPA will coordinate the Regional Working Groups. Meetings will occur approximately 3 to 4 times per year. The Pilot, Cal/EPA and the Working Group should also participate in training and facility tours.

2.5. Reporting
Cal/EPA will prepare quarterly reports to the Legislature between January 1, 2000 and January 1, 2002. The reports will include baseline conditions at the pilots, updates on the progress of the Pilot Projects, and activities of the Cal/EPA EMS Pilot Project. The conclusions of the studies, including the answers to the questions presented in AB 1102 will be presented in the final report, due January 1, 2002.

Section 3. Data Collection and Management

In order to meet the objectives of the Pilot Project and answer the questions presented in AB1102, data will be collected in the following categories:

• environmental performance,
• regulatory compliance,
• use of pollution prevention techniques,
• continual improvement,
• employee involvement,
• involvement of interested parties,
• quality and quantity of environmental information produced,
• EMS design, and
• EMS costs and benefits.

Pilots will contribute baseline data on environmental performance prior to the introduction of the EMS, descriptive information about EMS design, and four semiannual updates of data on environmental performance following the introduction of the EMS. In coordination with other states, detailed data protocols have been developed by the Multi-State Working Group. With the assistance of the University of North Carolina and the Environmental Law Institute, the MSWG maintains a national database on EMS design and performance. The California Pilot Projects are part of an effort that includes close to 100 Pilot Projects nation wide.

The Pilot will provide data through the completion of the MSWG EMS data protocols and the few additional questions added by Cal/EPA. Pilot Projects are provided with electronic and printed versions of the protocols. The data protocols are available on the world wide web at http:www.eli.org/isopilots.htm. After the pilot’s data entry is complete, the protocols are sent to the Cal/EPA project manager. If requested, Cal/EPA will assist in data collection.

After review, the data is then sent to the UNC and ELI, where they will:

• Enter pilot data into the national EMS database;
• Review data for completeness;
• Respond to Cal/EPA and the Pilot Project manager detailing missing data, questions, or need for clarification;
• Return data to pilot and state for accuracy review.

Data collected through the Pilot Projects will be available to interested parties and summarized in the reports to the Legislature.

Section 4. Data Quality Assessment, Validation and Usability

The Cal/EPA Pilot Project managers and the staff at ELI/UNC shall assess data quality. This shall be accomplished by looking at the following data quality aspects:

• completeness (is all data included);
• appropriateness (scope and detail appropriate to support research objectives);
• accuracy (level of accuracy appropriate to questions being asked)
• precision (description of desired measurement)
• relevance (adds information that supports research objectives)
• comparability (to other California pilots and other studies on EMS performance)

In the event that problems or omissions are encountered with the data, UNC will inform both the facility and the Cal/EPA Pilot Project manager, who will review the data with a facility representative. Any incorrect or unreported data will be corrected or added and forwarded to UNC for inclusion in the database.

After the data has been entered into the national EMS database, UNC will return the data to the Pilot and Cal/EPA. The project managers will review the data for accuracy ensuring that the data keyed into the national data is the same information submitted by the Pilot Project.

The Cal/EPA Pilot Project manager will identify the descriptive data and performance statistics that are relevant to the questions posed by AB 1102.

Section 5. Data Analysis

The questions posed in AB 1102 will be answered through the analysis of relevant data collected. Analysis shall involve comparing baseline data on EMS performance and regulatory compliance, and on the public’s access to environmental information, with performance in these areas after EMS implementation. Improvements of performance over baseline performance will indicate improved environmental protection and information. Performance, including information sharing, shall also be compared to regulatory requirements in these areas.

The collected data and analysis will be presented to the Northern and Southern California Working Groups. The Working Groups, Cal/EPA and the Pilot will analyze the data and determine the answers to the questions posed by AB 1102. The final conclusions, and subsequent report to the legislature, will be drawn from the data from all of the California Pilot Projects, not from any individual project. Case studies and examples drawn from the Pilots may be used to illustrate conclusions.

Announcement of Pilot Project Selection and Adoption of Final Documents

Final Selection Criteria and Descriptions of Pilot Projects

Final Evaluation and Monitoring Parameters