Developing an EPA-Tribal Environmental Plan (ETEP) & Strategic Planning

Transcription

1 Developing an EPA-Tribal Environmental Plan (ETEP) & Strategic Planning Josh Simmons Principal Consultant / Attorney August 16, 2016 PLEASE SIGN IN

2 EPA Tribal Environmental Plan (ETEP) = Living, Adaptable Strategic Planning and Management System* *When utilizing Prosper Sustainably s approach

3 Workshop Agenda Introductions & Overview Understanding ETEP Requirements Developing a Tribal Environmental Plan Step by Step Process Group Project Building a TEP Completing an ETEP Strategic Planning 10 minute break at around 10:00am

4 Presenter Introduction Joshua M. Simmons Founding President of Prosper Sustainably Assist individuals, organizations, and tribes develop and implement lasting solutions to meet environmental and sustainability needs o ETEP Development, Strategic Planning, Grant Writing, Program Development o Project Management, Environmental Codes Drafting, Feasibility Studies, Plans Former SYCEO Director ( ) Transformed the Santa Ynez Chumash Environmental Office (SYCEO) into a nation leading tribal environmental agency Secured 42 grants for $4.3 million in funding Training Instructor ETEPs, Grants Writing, Drafting Codes For ITEP, ITCA, OVIWC, FWS, USBR, UCSB, etc.

5 Tribal Consulting Experience GAP Work Plan Development Chemehuevi Indian Tribe Drafting Tribal Codes Cabazon Band of Mission Indians Pala Band of Mission Indians DOE Grant Writing Assistance (funding secured) Pala Band of Mission Indians Integrated Solid Waste Management Plan (ISWMP) Santa Rosa Band of Cahuilla Indians

6 ETEP Experience ETEP & Strategic Planning Projects Rincon Band of Luiseño Indians Pala Band of Mission Indians La Jolla Band of Luiseño Indians Buena Vista Rancheria Yavapai Apache Nation ETEP Trainings ETEP Online Training Course OVIWC Full Day Workshop ITCA Half Day Workshop 2014 & 2015 Tribal-EPA Annual Conference Sessions

7 ETEP Online Training Course 13+ hours of on-demand videos and resources ETEP development and implementation Strategic planning and management Additional videos and resources are added periodically To learn more, visit Prosper Sustainably s table Automatic entry into raffle for free registration

8 Participant Introductions Who are you? Where do you work? Where are you in the ETEP process? What do you want to learn? Please sign in to be ed workshop materials

9 Understanding ETEP Requirements

10 ETEP Background & Context EPA-Tribal Environmental Plan (ETEP) OIG Audit determinations (2008): Tribes don t have plans w/ goals for building environmental capacity Where tribes have plans, progress toward meeting goals not tracked Unclear how GAP is helping tribes meet environmental program goals o No framework had been provided by the EPA to develop goals and track progress GAP Guidance released by EPA headquarters (May 2013) Provides ETEP purpose, goals, and requirements ETEPs being developed and implemented by Regions and Tribes EPA HQ (AIEO) to provide ETEP technical assistance to regions

11 Purpose and Goals 2013 GAP Guidance Define mutual roles and responsibilities for program implementation Establish a joint EPA-tribal planning process to address tribal environmental priorities and ensure federal programs are fully implemented Identify tribal plans to manage authorized environmental programs Identify need for environmental programs assistance and resources Establish intermediate and long-term goals Track GAP progress against long-term goals Ensure linkage of GAP work plan tasks to long-term goals

12 Purpose and Goals 2013 GAP Guidance Improve alignment of GAP work plan activities with long-term goals and priorities Better position tribes and EPA to effectively build environmental program capacity through GAP Streamlined approach for a long-term planning tool that can be modified as needed Intended to be living, usable documents for both tribes and EPA as environmental partners to use in planning and guiding work ETEP = Strategic Planning Documents (Strategic Work Plan)

13 ETEP Functions & Benefits Powerful strategic planning & management system for all staff Manage and implement all programs more efficiently and effectively Keeps all major Environmental Dept activities in easy view at all times Set Goals; Create and Maintain Alignment of Efforts w/ Goals Be proactive rather than reactive with issues and opportunities Avoid chasing funding opportunities that don t meet your highest needs Evaluate issues, opportunities, and activities in full and proper context Develop grant and program work plans using ETEP Protection against setbacks due to turnover Helps to retain staff and easier transition when staff leaves Utilize as a communications tool to gain support Leadership, staff, partners, stakeholders, etc.

14 ETEP Requirements / Format 2013 GAP Guidance Four (4) Required Components: 1. Identification of tribal environmental program priorities, including capacity building and program implementation goals 2. Identification of EPA program priorities and management requirements 3. Inventory of regulated entities 4. Identification of mutual roles and responsibilities ETEP development and format options are flexible Must address four (4) required components Length, level of detail, and format will vary o Maximum flexibility is provided as to how the ETEPs are developed Timeframe No more than 5 year timeframe is recommended by EPA o 4 year ETEP may be best to align with GAP funding cycles o May want to develop a living and continuous 4 year plan ETEPs to be jointly reviewed at least annually and updated as needed Jointly reviewed by tribe and EPA (don t wait for EPA)

15 #1 - Tribal Program Priorities MAIN ELEMENTS REQUIRED: 1. Short description of priority Recommendation: Use program areas as priorities 2. Tribe s long-term environmental program goals That address or support priority / priority program area GAP Work Plans must be aligned with ETEP-long-term goals 3. Intermediate program development milestones / objectives To be accomplished with ETEP timeframe 4. Tribe s plans to manage authorized environmental programs

16 What are plans to manage authorized environmental programs? What are some examples of environmental programs that can be authorized?

17 #1 - Tribal Program Priorities MAIN ELEMENTS REQUIRED: 1. Short description of priority Recommendation: Use program areas as priorities 2. Tribe s long-term environmental program goals That address or support priority / priority program area GAP Work Plans must be aligned with ETEP-long-term goals 3. Intermediate program development milestones / objectives To be accomplished with ETEP timeframe 4. Tribe s plans to manage authorized environmental programs This means plans to assume authority(ies) to manage EPA regulatory programs o E.g. CAA or CWA TAS (each authority must be officially approved by the EPA) 5. Needed Assistance to achieve goals and milestones/objectives E.g. training, technical assistance, EPA direct implementation actions, financial, etc.

18 Plans to Manage Authorized Environmental Programs OPTIONS (in general) EPA Direct Implementation EPA retains responsibility for administering federal environmental laws Tribal participation is optional o E.g. participate in consultations, review and comment on actions (such as permit applications), participate in EPA inspections, community education & outreach Delegation Tribe assumes EPA authority to administer federal environmental laws o Subject to EPA approval o Delegation requirements may be similar to TAS requirments Tribal Direct Implementation (TAS authority) Tribe assumes direct authority to administer federal environmental laws o Subject to EPA approval *To learn more about these in the context of CAA NSR, see:

19 Plans to Manage Authorized Environmental Programs Which Environmental Programs? What authorities can be assumed/managed? CAA CWA CERCLA EPCRA FIFRA RCRA SDWA TSCA AAQS, Designations, FIPS, Permitting (major, minor), etc. WQS, 401 Certification, Permitting (NPDES, dredge & fill), etc. Emergency Response, Site Remediation, Inspections, etc. Emergency Planning, Inspections, Compliance Assistance, etc. Certification Program, Inspections, Compliance Assistance, etc. Inspections, Compliance, (USTs, solid waste facilities) etc. Monitoring, Compliance Assistance (drinking water, UICs), etc. Inspections, Compliance Assistance (lead, asbestos), etc. *This list is limited **Many of these are TAS authorities Recommendation: discuss options with EPA Project Officer(s)

20 #1 - Tribal Programs & Priorities Discuss with EPA regional office staff to identify: 1. Connections between priorities and implementation of the federal environmental programs, and 2. Potential EPA assistance that could be provided to help the tribe Can include non-federal environmental/epa programs in ETEP EPA should review and provide feedback on where they can and cannot provide assistance RECOMMENDATION: Ask the EPA to identify which goals and objectives are GAP eligible (or eligible for other EPA funding)

21 #2 - EPA Program Priorities EPA will review and document tribal status, intentions, and activities with respect to federal environmental programs Federal Statutory Programs are EPA s responsibility by default If a tribe has not assumed the responsibility to manage the program o CAA, CWA, CERCLA, EPCRA, FIFRA, RCRA, SDWA, TSCA Reviewing program implementation activities, including: Permitting, compliance assurance and enforcement, developing inventories of regulated entities, issuing identification numbers for regulated entities, issuing certifications, and other activities. To be done by Regions in coordination with tribes and EPA HQs Request EPA Headquarters involvement and support as needed

22 #3 - Inventory of Regulated Entities EPA will provide a list of known regulated entities to Tribe Regulated under Federal Environmental Statutory Program o Can look up facilities using Facility Registry System: Can enter as objective in ETEP as EPA responsibility Tribe will update with additional regulated entities Can enter as objective in ETEP as tribal responsibility Tribes may want to have a broader inventory That goes beyond Federal Environmental Statutory Regulations o E.g. Septic tanks, individual household wells, ASTs, off-reservation facilities Inventory should be update as appropriate Operating Status Changes, New Facilities, etc. Recommendation: Review and update annually Presence of regulated entities determines which federal environmental statutes are applicable

23 #4 - Mutual Roles & Responsibilities Define activities to be conducted by tribe and EPA, including: What tribe will do to support EPA direct implementation of federal env programs What EPA will do to support tribal program development and implementation What tribes will do to either: o Apply for program approval/delegation, and/or o Build capacities to partner with EPA to implement applicable federal programs Determine through discussion between EPA and tribal staff Once these activities are determined, add as objective(s) into ETEP Include Env Program capacity indicators to be established Plus a general time line for establishing each capacity indicator Add Capacity Indicators (CIs) as objectives; Include CI#s from Guidance Include role for each objective/milestone in the ETEP

24 Additional ETEP Requirements Completion Dates for tribal and EPA activities To allow progress to be measured These are meant to be projections, not firm requirements Annual work plan joint evaluation to include EPA s activities Alignment of GAP work plans w/ ETEP program priorities and mutual roles and responsibilities Living document to be actively used by Tribe and EPA Revise as conditions change (e.g. staff turnover, changed tribal priorities) Support of senior officials of tribe and EPA

25 Developing a Tribal Environmental Plan (TEP) Get your notebook ready!

26 ETEP Required Components 2013 GAP Guidance Four (4) Required Components: 1. Identification of tribal environmental program priorities, including capacity building and program implementation goals 2. Identification of EPA program priorities and management requirements 3. Inventory of regulated entities 4. Identification of mutual roles and responsibilities 26

27 ETEP Component 1: Identification of tribal environmental program priorities = Tribal Environmental Plan (TEP) = ETEP Strategic Work Plan 27

28 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan Scope = Priority Program Areas o Priority Programs = ALL relevant programs o Priority Program Areas Long-Term Goals Objectives ETEP should include all tribal activities/entities regulated by the EPA Which programs and departments are you going to include? o Best to cover all programs of a single department (even non-environmental) This will be the primary department; External and inter-dept activities can be added The ETEP scope may change / evolve as you progress 28

29 Activity: Identify Priority Program Areas Write down existing programs (managed by your dept.) Programs that are within the scope of the EPA What non-epa programs are under your department? o Including non-environmental programs? Write down possible programs What programs will or should your department manage? May need or want to include other departments Especially if they are administering EPA programs 29

30 Example Priority Program Areas Air Resources Indoor v. Outdoor Climate Change Water Resources Water Quality Waste Management Solid v. Hazardous Environmental Emergencies Education & Outreach General Administrative & Financial Energy Sustainability / Greening Cultural Resources / THPO Natural Resources Wildlife & Habitat Landscaping & Agriculture Integrated Pest Management Marketing & Public Relations Land Use & Planning Pollution Prevention / Toxics Public Works 30

31 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders Involve: the Director/Manager and lead for every program o This is the core ETEP development team that should be involved from the start Recommendations: Only have one person prepare initial draft (ideally Dept head) Seek input from leads and staff while preparing and on drafts Seek input from leadership and stakeholders on completed 1 st draft and/or later drafts o You will want to involve your entire department s staff eventually Notify and Eventually Involve: Executive Committee / Tribal Council, Department Committee, Tribal Administrator Consider Involving: Other Executives, Partners, Other Departments (e.g. Facilities, Utilities, Planning), Other Stakeholders

32 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering & Review / Baseline Needs Assessment To identify possible: o Priority Program Areas, Long-Term Goals, Intermediate Milestones / Objectives Most of this information should already exist You are just finding and organizing it Baseline Needs Assessment = Information Gathering/Organizing Process 32

33 What is a Baseline Needs Assessment? 33 PURPOSE See GAP Guidance Appendix I: Capacity Indicator B.5 Environmental resources needing protection Info about existing/potential threats to human health and env Evaluation of potential impact of threats to community & resources Strategic plan w/ long term program development & implementation goals (ETEP overlap) Prioritization of activities by env program to address identified threats (ETEP overlap) Conducting/updating a formal baseline needs assessment can be objective within your ETEP strategic work plan / TEP

34 What is a Baseline Needs Assessment? 34 STEPS See GAP Guidance Appendix II Gather Existing Data This is an essential ETEP development step Collect New Data This is not an essential ETEP development step This can be incorporated as future objectives that focus on different areas o E.g. air, waste, water, natural resources, wildlife & habitat, energy, etc. Recurring activity - there will eventually be new data to gather Analyze Data and Identify Priorities This is what an ETEP Strategic Work Plan does

35 35 Conducting a Baseline Needs Assessment Formal v. Informal FORMAL Produces a Baseline Needs Assessment Report Analysis of existing conditions and needs by program area and then by issue o Describe and analyze know and potential causes Identification and selection of options (may overlap TEP work plan) E.g. Water Quality: o High turbidity; High bacteria; High nutrients; Impaired riparian habitat o Construction runoff; Ranching operation; Ag operation; Off-road vehicles o SWPPP Permitting; Install Fence; Control Fertilizing; Enact Ordinance Alternative Baseline Needs Assessment Formats: Environmental Inventory, Integrate Resource Management Plan May involve gathering new data E.g. sampling, investigations, surveys, questionnaires, public meetings, etc. Can be a lengthy, time-consuming, and expensive process

36 Conducting a Baseline Needs Assessment Formal v. Informal INFORMAL recommended for ETEP development Similar process but no formal report is required Prepare an intermediate research document that organizes findings and/or Enter and organize findings directly in your ETEP Work Plan* Limited new data gathering Focus on gathering existing information and data o Focus on what is readily available; Don t get hung up on info that is difficult to obtain Minimizing gather of new data as much as possible is recommended 36 *This is a shortcut that I use as soon as Program Areas are sufficiently identified

37 Conducting a Baseline Needs Assessment General v. Specific General required for ETEP development process Covers all or most areas of need (environmental and human health issues) o Conducting an informal baseline needs assessment of general applicability is an important ETEP development step (information gathering) 37 Specific Limited to a single or just a few areas of need (e.g. water or air resources) o Specific assessments that go in depth should be included in ETEP work plan as needed Specific & General Can cover organization and administrative needs o Personnel, funding, communications, procedures

38 Baseline Needs Assessment / Information Gathering INFO GATHERING PROCESS GOALS** Identify Existing Priority Program Areas AKA Relevant Departmental and Interdepartmental Programs / Initiatives o Can included needed programs and initiatives (they don t have to currently exist) Identify Existing Long-Term Goals Issues / Needs Goals Identify Existing Objectives (AKA sub-goals) Issues / Needs Objectives 38 **Use these goals to guide and focus your efforts

39 Transforming Needs into Objectives Need Goal/Objective Issue/Problem Activity to Address One is the converse of the other E.g. Open Dumpsite Cleanup Dumpsite* *This is one of multiple options and possible steps 39

40 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering / Baseline Needs Assessment 4. Identify and Select Priority Program Areas (PPA) Optional: Include all program areas, goals, and objectives for your department (including non-environmental) E.g. THPO, Emergency Planning, Landscaping, Land Use, etc.

41 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering / Baseline Needs Assessment 4. Identify and Select Priority Program Areas (PPA) 5. Identify and Select Long-Term Goals For each Priority Program Area (separately) GAP Work Plans must be aligned with ETEP long-term goals GAP Work Plan progress will be measured in terms of ETEP goals Recommendation: Develop broad/general, high-level goals Optional: Include all program areas, goals, and objectives for your department (including non-environmental) E.g. THPO, Emergency Planning, Landscaping, Land Use, etc.

42 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering / Baseline Needs Assessment 4. Identify and Select Priority Program Areas (PPA) 5. Identify and Select Long-Term Goals 6. Identify and Select Intermediate Objectives/Milestone For each Priority Program Area (separately) These must be in alignment with the long-term goals for that PPA Optional: Include all program areas, goals, and objectives for your department (including non-environmental) E.g. THPO, Emergency Planning, Landscaping, Land Use, etc.

43 What is the difference between a long-term goal and an objective?

44 Goals v. Objectives Long-Term Goals v. Intermediate Objectives/Milestones Goals A Significant Aim or Desired Result General and ambitious, but more specific than a mission or vision o Goals should relate to a department/organization s mission and vision Don t have to be achievable within ETEP / strategic plan timeframe Overall v. Program Area Specific o Overall goal eliminate/reduce environmental impacts o Program area goal eliminate/reduce water pollution Objectives What Must be Done to Achieve a Goal (progress) Major Steps / Activities (or sub-goals) o A series of smaller steps/activities/tasks may be required to achieve an objective SMART Specific, Measureable, Achievable, Relevant, Time-based o Developed and organized by program area E.g. Prepare a resources management plan; Complete restoration; etc.

45 Activity Prepare and present 2 to 3 examples of: Priority Program Area Long-Term Goal 2-3 Intermediate Objectives Example: Area: Waste Management Goal: Eliminate and prevent illegal dumping throughout the reservation Objective #1: Identify, pursue, and secure funding to clean up and close [INSERT NAME] illegal dumpsite Objective #2: Develop a clean up and closure plan for [INSERT NAME] illegal dumpsite

46 Info Gathering & Review Steps 1. Identify and log information source (e.g. document, report, etc.) Use document/information tracking template 2. Review information source Look for possible Priority Program Areas Look for possible Long-Term Goals Look for possible Intermediate Objectives 3. Record information gathering & review findings Use intermediate research document and/or Use ETEP Strategic Work Plan template o Use this option if a goal or objective is clear 46

47 Sources of Priority Program Areas, Goals, and Objectives Internal Information Gathering Gather, review, and extract information from relevant internal documents, including (but not limited to): o TEPs, TEAs, Environmental Inventories, Strategic Plans, Policies o Grant Narratives, Work Plans, Budgets, and Reports (past, current, future) Especially General Assistance Program (GAP): current, future, and previous fiscal year Include relevant recent, pending, and unsuccessful grant proposals o Program Narratives, Work Plans, Budgets, and Reports (past, current, future) o Plans, Assessments, Feasibility Studies, Surveys, and related reports Can include plans from other departments where there is overlap with Env Dept o Environmental Codes, Regulations, Resolutions, and Compliance Documents o General Tribal Strategy and Land Use documents o Interviews and discussion with staff, leaders, and other internal stakeholders o Review and record internal staff knowledge *Use a document/information tracking template

48 Sources of Priority Program Areas, Goals, and Objectives External Information Gathering Gather, review, and extract information from relevant external documents, including (but not limited to): o May 2013 GAP Guidance focusing on Capacity Indicators Record relevant capacity indicators number o Environmental Grant Funding Announcements o Environmental Agency Guidance Documents o Interviews and discussion with agency representatives, external stakeholders, etc. o Prosper Sustainably knowledge base (from past projects, experience, and ideas) *Use a document/information tracking template

49 GAP Guidance Capacity Indicators Appendix I Valuable source of potential priority program areas & objectives GAP Program Areas ETEP Priority Program Areas Example: E. Solid Waste, Hazardous Waste, and USTs o This can be split into multiple, separate program areas GAP Capacity Indicators ETEP Objectives/Milestones Example: C.3.10 Tribe has completed an indoor air quality (IAQ) assessment and report Complete an IAQ assessment and report of Record Capacity Indicator numbers for objectives wherever applicable 49

50 Activity: GAP Guidance Appendix I Review Appendix I of GAP Guidance (start w/ B.2) Identify (note/highlight) possible Priority Program Areas That will or may be included in your ETEP strategic work plan E.g. Water Quality Program, Solid Waste Program Identify (note/highlight) possible Intermediate Objectives That your department will or may want to pursue o Begin thinking about the timeframe These are specific Capacity Indicators o E.g. D.3.7 Tribe has established water efficiency policies

51 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering & Review / Baseline Needs Assessment 4. Select Priority Program Areas (PPA) 5. Identify and Select Long-Term Goals 6. Identify and Select Intermediate Objectives/Milestone 7. Preparing Framework/Document of ETEP Strategic Work Plan 51

52 ETEP Strategic Work Plan Mandatory Elements Short description of priority program area Long-term program area goals Intermediate milestones/objectives Completion dates for activities (milestones/objectives) Identification of roles and responsibilities Plans to Manage Federal Environmental Programs Needed Assistance to goals and objectives Indicators of Capacity 52

53 ETEP Strategic Work Plan Recommended Minimum Elements 53 Plan Contents & Overview (Spreadsheet Only) Description of priority program area Long-term program area goals Intermediate milestones/objectives Completion year for milestones/objectives Capacity Indicator numbers For each milestone/objective (if applicable) Roles and responsibilities (Tribe v. EPA v. Both) Plans to Manage Federal Environmental Programs Also include as milestones/objectives Needed Assistance Include as objectives/milestones

54 54 ETEP Strategic Work Plan Elements Recommended & Optional Include Program Area for each Description, Goal, and Objective Recommended Objectives Columns (Excel Spreadsheet only): Category (be consistent) Repeat (Yes/No) o For filtering repetitive objectives Source of Objective Staff Responsibility OPTIONAL Objectives Columns Component, Status, Outputs/Deliverables, Outcomes, Urgency, Due Date, Staff Work Years, GAP Eligible, Possible Funding Sources, Estimated Cost, Funding Secured, Notes, Links/References, etc. Start with Recommended Minimum Elements o AVOID OVERWHELMING/UNMANAGABLE ETEP WORK PLAN

55 Steps for Developing a TEP 1. Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering & Review / Baseline Needs Assessment 4. Select Priority Program Areas (PPA) 5. Identify and Select Long-Term Goals 6. Identify and Select Intermediate Objectives/Milestone 7. Preparing ETEP Strategic Work Plan Framework/Document Excel Spreadsheet Version Template Word Document Version Template 55

56 Steps for Developing a TEP Determine the Initial Scope of your ETEP / Strategic Plan 2. Select Core ETEP Development Team; Identify Stakeholders 3. Information Gathering & Review / Baseline Needs Assessment 4. Select Priority Program Areas (PPA) 5. Identify and Select Long-Term Goals 6. Identify and Select Intermediate Objectives/Milestone 7. Preparing ETEP Strategic Work Plan Framework/Document 8. Insert Information into ETEP Strategic Work Plan Focus on Priority Program Areas, Goals, and Objectives Include required/recommended elements

57 Group Project Building a TEP Choose and Briefly Describe a Priority Program Area This can be a non-epa or non-env program if applicable to your dept Draft 2-3+ Long-Term Goals (use template) Draft 3-5+ Intermediate Objectives / Milestones Per Year Include GAP Capacity Indicator Number(s) (if applicable) o These objectives don t have to come from the GAP Guidebook OPTIONAL: Include primary staff responsibility Present Draft TEP to Class 57

58 58 Review Example TEPs

59 59 Completing an ETEP

60 ETEP Work Flow Helpful ETEP Work Flow developed by EPA Region 9 Presented at January 2016 RTOC Meeting Available at:

61 #1 Tribal Program Priorities Tribal Environmental Plan (TEP) / ETEP Strategic Work Plan Steps: 1. Tribe develops draft Tribal Environmental Plan 2. Tribe submits draft Tribal Environmental Plan to EPA Recommendation: Ask EPA to identify objectives not GAP eligible 3. EPA reviews draft TEP, makes edits and provides comments EPA should also identify areas, goals, objectives not under its authority These should be left alone by the EPA and should remain in the plan 4. Tribe address EPA feedback in TEP and submits final to EPA 61

62 #2 - EPA Program Priorities EPA will review and document tribal status, intentions, and activities with respect to federal environmental programs Federal Statutory Programs are EPA s responsibility by default If a tribe has not assumed the responsibility to manage the program o CAA, CWA, CERCLA, EPCRA, FIFRA, RCRA, SDWA, TSCA Reviewing program implementation activities, including: Permitting, compliance assurance and enforcement, developing inventories of regulated entities, issuing identification numbers for regulated entities, issuing certifications, and other activities. To be done by Region in coordination with Tribe and EPA HQs Request EPA Headquarters involvement and support as needed 62

63 #2 - EPA Program Priorities Goal: mutual understanding of federal env protection program implementation reqs; timeframes; roles; and expected results Precursor to Component #4 Identifying Mutual Roles & Responsibilities 63

64 #2 - EPA Program Priorities Steps: 1. EPA reviews and documents tribal status, intentions, and activities with respect to applicable federal env programs In Region 9 = Areas of Involvement document (AIL) 2. EPA submits document to the Tribe for review and comment 3. Tribe reviews and submits comments on document to EPA 4. EPA updates document, incorporating Tribe s comments 64

65 #3 - Inventory of Regulated Entities 65 EPA will provide a list of known regulated entities to Tribe Regulated under Federal Environmental Statutory Program o Can look up facilities using Facility Registry System: i ndex.html Can enter as objective in ETEP as EPA responsibility Tribe will update with additional regulated entities Can enter as objective in ETEP as tribal responsibility Tribes may want to have a broader inventory That goes beyond Federal Environmental Statutory Regulations o E.g. Septic tanks, individual household wells, off-reservation facilities Inventory should be update as appropriate Operating Status Changes, New Facilities, etc. Presence of regulated entities determines which federal environmental statutes are applicable Influences EPA Priorities under Component #2

66 #3 - Inventory of Regulated Entities Steps: 1. EPA develops Inventory of Regulated Entities document In Region 9 = Regulated Facilities Inventory List (RFIL) 2. EPA submits inventory to the Tribe for review and comment 3. Tribe reviews and submits comments on inventory to EPA Check and update status of identified regulated entities Add missing regulated entities subject to federal env laws Add additional regulated entities that Tribe wants to track (optional) 4. EPA updates inventory, incorporating Tribe s comments 66

67 67 #4 - Mutual Roles & Responsibilities Define activities to be conducted by tribe and EPA, including: What tribe will do to support EPA direct implementation of federal environmental programs What EPA will do to support tribal program development and implementation o EPA to determine What tribes will do to either: o Apply for program approval/delegation, and/or o Build capacities to partner with EPA to implement applicable federal programs Determine through discussion between EPA and tribal staff Once these activities are determined, add as objective(s) in TEP Include Env Program capacity indicators to be established Plus a general time line for establishing each capacity indicator Add Capacity Indicators (CIs) as objectives; Include CI#s from Guidance Include role for each objective/milestone in the TEP

68 Support of Senior Officials 68 The ETEP should have the support of senior officials in both EPA and the tribal government, as they will be used to help prioritize the work that is funded under GAP and the work that EPA is conducting in the tribal area. Support isn t stated as definitely requiring a signed document A signature may not be required (may vary from Region to Region) Tribal Council Resolution should not be required Official means a person with authority to support the ETEP Tribal Government Senior Official varies from Tribe to Tribe The person w/ authority to provide support is determined by the Tribe ETEP meant to be living document No rigid commitment to rigid goals and objectives/milestones o These can and should change as circumstances change Support = commitment to the joint planning process

69 Support of Senior Officials 69 Language recommendations for Support of Senior Officials: ETEP is a living and adaptable document (not rigid commitment) Tribe can change TEP at any time as circumstances / priorities change Support represents commitment to a joint planning process rather than to specific goals and milestones/objectives Current Region 9 Requirements: EPA prepares Cover Memo Tribe reviews Cover Memo Cover Memo bundled with other documents o A signature is optional Requirements will vary from Region to Region Tribe may have to prepare support documentation

70 Final ETEP Package Final Tribal Environmental Plan (Component #1) It is a living TEP that is never actually final o Tribe can change at any time Documentation of EPA Program Priorities (Component #2) Regarding federal env statutory programs applicable to tribe Inventory of Regulated Entities (Component #3) Mutual Roles and Responsibilities (Component #4) May not involve a stand-alone document Likely addressed within other documents Documentation of Support of Senior Tribal and EPA Officials 70

71 Implementing an ETEP Viewing and Tracking Objectives Performance Monitoring Staff Management and Meetings Communicating / Gaining Support Decision-Making Processes Preparing GAP and other Grant Work Plans Review and Updating (at least annually) 71

72 72 Strategic Planning

73 No Strategic Plan A X 1,200 units of [INSERT RESOURCE] expended 73

74 Has Strategic Plan A B 800 units of [INSERT RESOURCE] expended 74

75 Have Living Strategic Plan C A B 75

76 Have Living Strategic Plan C A B 850 units of [INSERT RESOURCE] expended 76

77 Mission, Vision, Values Mission = Purpose of Organization (clear and concise) Guides decisions about priorities, activities, roles, responsibilities, etc. Vision = Ultimate State of Success Can be tied to the organization or change(s) in the world (or both) Core Values = Shared Principles and Beliefs that Guide Behavior How things are done around here (unique, maybe to a fault) Prosper s MISSION is to help individuals, organizations, and communities clarify, pursue, and fulfill their unique potential. Prosper s VISION is widespread empowerment, harmony, and genuineness throughout the world, as a result of the majority of individuals, organizations, and communities taking meaningful steps toward fulfilling their unique potential. 77

78 Activity - Mission, Vision, Values Identify and Describe Mission, Vision, and Values for your Tribe/Org Mission = Purpose of Organization (clear and concise) Guides decisions about priorities, activities, roles, responsibilities, etc. Vision = Ultimate State of Success Can be tied to the organization or change(s) in the world (or both) Core Values = Shared Principles and Beliefs that Guide Behavior How things are done around here (unique, maybe to a fault) 78

79 S.W.O.T. Analysis Strengths internal/existing advantages Weaknesses internal/existing disadvantages Opportunities external/potential advantages Threats external/potential disadvantages 79

80 Activity - S.W.O.T. Analysis Identify and list one of each for your department: Strengths internal/existing advantages Weaknesses internal/existing disadvantages Opportunities external/potential advantages Threats external/potential disadvantages 80

81 Goals & Program Areas Overall Organizational Goals Guides the organization as a whole Defining Strategic Plan Program Areas AKA Business, Functional, or Operational Units; Divisions; Areas; etc. Want to cover all aspects of an organization, including administrative Examples Administration, Financial Management, Solid Waste Management, Water Resources, Natural Resources, Education & Outreach, etc. Program Area Goals Guides each program area 81

82 ETEP Strategic Work Plan Function of Strategic Plan Provides overall direction and guides decision making Evaluate issues, opportunities, needs, and objectives Function of ETEP Strategic Work Plan Blueprint for implementing the Strategic Plan o Provides specific direction and guidance by program area Establishes all major objectives within specific timeframes Track and measure progress, performance, and achievements Understand and allocate resources (financial, human, etc.) Oversee all organizational activities and adjust direction as needed Level of detail / specificity will vary 82

83 Tribal Environmental Department Strategic Planning Process Understanding the Tribal Environmental Department Environmental Needs Assessment Informal or Formal Initial preparation of ETEP Strategic Work Plan o Suggestion Complete a draft of the ETEP Strategic Work Plan before proceeding with remaining strategic planning retreat/meeting to maximize this effort Allows staff and stakeholders to discuss possible goals and objectives rather than having to come up with completely new ones Circulate questionnaire on Mission, Vision, Values, and Goals Focus on staff; Can include tribal leadership and other stakeholders 83

84 Tribal Environmental Department Strategic Planning Process Understanding the Tribal Environmental Department Circulate questionnaire on Mission, Vision, Values, and Goals Conduct Strategic Planning Meetings/Retreat (3 rd Party Facilitator) Mission, Vision, and Values S.W.O.T. Analysis Goals and Objectives Individual, Breakout, and Group Exercises o Each participant records their thoughts and ideas Include or meet with Tribal Council and other stakeholders separately o Optional depends on your tribe s circumstances 84

85 Tribal Environmental Department Strategic Planning Process Draft the Strategic Plan (Mission, Vision, Values, Goals) Circulate draft Strategic Plan and ETEP Strategic Work Plan For staff and stakeholder input and feedback Finalize Strategic Plan and ETEP Strategic Work Plan Utilize ETEP Strategic Work Plan as Management Tool Review and update ETEP Strategic Work Plan At least annually; Can be ongoing Review and update Strategic Plan Review at least annually; Update at least every 5 years 85

86 86 Strategic Plan Template & Sample Strategic Plan

87 Strategic Plan Implementation (Strategic Management) 87 Creating and maintaining a living strategic plan & work plan These should evolve over time as they are put into practice Utilizing and updating the ETEP strategic work plan Develop a perpetual 4-5 year ETEP strategic work plan Reviewing and update each program area annually o Archive year that just passed; Add a year to the plan; Revise years in between Customize and populate with key information Run reports o Adjust work plan accordingly based on report results Utilizing and updating the strategic plan Review Mission, Vision, Values, SWOT, and Goals at least annually In-depth review and revision every 4-5 years Ongoing evaluation tool; Ongoing communication

88 Strategic Planning & Management Human Element Obtain stakeholder input and involvement Including and especially employees at all levels Create buy-in and alignment, Foster sense of respect and belonging Provide a container for new ideas (and concerns) Establish a clear and consistent process for evaluating new ideas In context of mission, vision, values, goals, and other objectives Communicate and model commitment to mission, vision, values Create a sense of meaning and purpose; May even inspire Clarify direction & expectations (goals, objectives, performance) Include people, relationship building, and interpersonal matters Within values, goals, objectives, etc. 88

89 Thank You! Questions? (805) (office) / (805) (cell)