1. ECOS Resource Flexibility and the PPA March 21, 2007 Thomas W. Easterly, P.E., DEE, QEP Commissioner IN Department of Environmental Management

2. Goal: Increase Compliance Improve Efficiency Traditional compliance programs brought us to existing levels Identification of significant sources of emissions Confidence in knowledge of large and heavily regulated sources Measurement of pollution levels Identification of top performers and underperformers

3. Current Status Environmental challenges remain Some industry sectors require increased attention Universe of regulated entities in some sectors not complete Some regulations poorly implemented Compliance status unknown in areas Limited resources to address these issues

4. Resources vs. Challenges Most compliance and enforcement resources allocated to satisfy PPA & CMS commitments Program revenue on downward trend in some programs - Title V, RCRA Compliance results have become predictable Gaps in programs and ongoing challenges not adequately addressed

5. Percent of Activities Meeting Regulations

6. Evolution of Programs Programs should move towards balance of maintenance and continuous improvement Environmental challenges, data gaps and implementation deficiencies should be addressed Question: How do we accomplish new goals using traditional compliance and enforcement strategies and expectations?

7. Resource Flexibility Goals in balanced compliance strategy are similar to traditional goals, target of activity may be different Goals are based on each states’ needs Results attained in these new initiatives comparable to traditional results Results attained through these new initiatives not attained through current CMS requirements The Performance Partnership Agreement (PPA) and associated funding process can provide opportunities to discuss allocation of limited resources

8. Resource Flexibility - Indiana Each media program has goals and challenges identified that existing CMS does not allow staff time to accomplish Programs with CMS requirements propose reduction in past CMS numbers to free up resources to accomplish these new goals EPA and state agree on CMS revisions and intent of new initiatives Specific results of new initiatives are undetermined, but goals and type of measurement can be included in PPA

9. Indiana Initiatives Office of Air Quality PM 2.5 anomalies NESHAP compliance using Environmental Results Program (ERP) approach Office of Water Quality Small & medium-sized municipalities (ERP) Collaborative approach to watershed quality improvement Office of Land Quality RCRA non-notifiers and downgraded status (ERP) Auto Salvage Initiative (ERP) Agency Wide Collaborative SEPs Financial incentives for environmental improvement

10. Current Status Initial notification of intent sent to EPA Region 5 on February 9 th Media programs of both agencies meeting to close out existing PPA and discuss content of upcoming PPA April 10 th, agency management teams meeting to discuss content of next PPA

11. Questions? Tom Easterly 100 N. Senate Ave. IGCN 1301 Indianapolis, IN 46204 (317) 232-8611 Fax (317) 233-6647 teasterly@idem.in.gov