Measuring compliance and enforcement

2012 EEN Forum

Led by Yvonne Watson

Program design- evaluation. Use baseline information to enforce and help prevent non compliance, but too much data and work therefore now using control group versus research group. Maybe use a baseline compliance rate for each company you are looking at and incorporate it in your evaluation.

Metrics for Compliance. Are they using compliance and enforcement under the same metrics, but not possible? Need to specify the measure. New Jersey example, where many inspections were not providing violations, but they were reporting larger issues that can be clearly identified and resolved. How sensitive do measures need to be? Does it impact the methodology? Need to revisit protocol and methods from improvement. NOAA- enforcement very output based for performance measuring. Look at enforcement as a process that incorporates steps and compliance. Does budget have an effect on compliance assistance? NOAA- measure are based on number of investigations, hours on patrol, and hours of outreach.

How to define success and what is the evidence for it? What are the metrics for inspecting an industry? Ultimate goal to have more people more in compliance, then non-compliance. Metrics right now in water quality facilities are not dealing with human risk, just the number of facilities that are in compliance. Issues of measure of deterrence and preventative. How to write better permits and standards to avoid non compliance? Who are we selling success to? Need to know who your audience is when presenting results. Evidence based enforcement strategies now in guidance for all EPA office from OMB. Evidence is data to make a decision. Is that a low standard? Data is not alway numerical. Evidence used in the court of law authentic relative and probative. So it depends on context.

Methods for dealing with a mixture of data are important. Where are they?

Doing a comparative analysis for different types of enforcement.

Open discussion. No products.

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