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Phase 2: Plan Program
- Introduction
- Roadmap
- ERP Resources and Contacts
This phase is a time for you to make key decisions that will shape your ERP. You will lay out the parameters and timeframe for the program, as well as begin to think about who within your agency will be implementing it.
Make Key Strategic Choices
What are key strategic choices about your program that will direct the rest of its development? There are several decisions that can have very broad repercussions for the rest of ERP development.
Questions to consider
- Do you want your ERP to be comprehensive or targeted? In other words, after participating in ERP and self-certification, should facilities understand all of their compliance requirements and best management practices (BMPs), or a group of high priority requirements and BMPs? This choice will influence the development of the inspector checklist, self-certification form, and compliance assistance materials such as the workbook.
- How will you handle facilities that are out of compliance? What will be your strategy for dealing with major versus minor violations? Will facilities that disclose information on a self-certification form be treated more leniently than those that do not? This will affect the tone of program materials and your interactions with stakeholders.
- Sometimes tradeoffs develop between robust statistical measurement and encouraging performance improvement through technical assistance. In these cases, is it more important to you to clearly understand current performance or to improve performance for the future?
- Who will fill out the self-certification form – the owner of the facility, or the operator/manager of the facility? To what will this person certify (e.g., full compliance, improved performance, etc.)?
Develop Program Design Framework
The framework lays out the key dimensions and structure of ERP. It builds on the key decisions made in the previous step.
Questions to consider
- What is the scope of your program, for example:
- Compliance only, or also pollution prevention and BMPs?
- Environmental only, or also other issues such as business licensing, worker health, environmental justice, community quality of life issues?
- Multi-media or single media?
- What is the regulatory context for your program?
- What are this sector's current regulatory and reporting responsibilities (e.g., annual notification, certification)?
- Will ERP certification relate to environmental permitting (For example, will self-certification take the place of facility permits? Will it prepare facilities for general permitting?)
- What rules or legislation need to be made or changed to implement ERP?
- Do you anticipate other (non-ERP related) changes in rules or permitting that may affect ERP in this sector in the foreseeable future?
- Will your ERP be mandatory or voluntary?
- Are there any important sub-populations of this group that will be treated differently from one another?
- What are the incentives for facilities to participate?
- Will there be penalties for facilities that do not participate?
- What are your options for managing data collected through ERP? What options do you have for automating data entry, analysis, and reporting? Is web-based certification viable for your ERP? Information technology (IT) and data management choices may influence the cost of ERP, program efficiency, and your ability to use data you collect more effectively.
Resources to consider
- Regulatory Framework
[Cached version] (PDF, links to page 16 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002)) - Compliance Assurance and Enforcement Under ERP [Cached version] (PDF, links to page 12 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002)) - ERP-Related Legislative/Regulatory Materials
Establish Program Schedule
Planning a schedule for when you will achieve major program milestones will help you identify bottlenecks, develop a realistic timeline, and keep you on track for progress. Program management software can assist with charting project tasks, milestones, and schedules.
Questions to consider
- Will the program begin as a pilot or will it be rolled out all at once?
- Are there any scheduling constraints due to pre-existing deadlines or personnel shortages?
- What are the key dependencies between steps (i.e., what do you have to accomplish first in order to be able to address later tasks)?
- Have you allowed sufficient time for each task in a full round of ERP? Look through the tasks in the remainder of this road map to get an idea of what steps will be required. Remember to plan review cycles into your schedule. For example, developing the inspector checklist typically requires a lot of input from program staff, while developing the certification package requires feedback from both internal and external stakeholders, so it is good to allow ample time and resources for revisions.
Resources to consider
- Program Management Software: Review and Recommendations (PDF, 9 pages, 224 KB, About PDF)
- Decide if you want to pilot ERP or immediately roll it out to a full sector [Cached version] (PDF, links to page 31 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002)) - Project Schedule Overviews and Gantt Charts
Develop Project Budget
In order to make sure you have adequate resources for program development, it is important to establish a project budget and identify the different types of resources you will need (including both staff time and direct funding). Note that some types of project management software can assist in tracking costs by task, tracking resources required over time, and rearranging project schedules to even out resource demands over time.
Questions to consider
- Which tasks will be conducted by internal staff, and which will be shared with other agencies or contracted out?
- How comprehensive will your program materials need to be (e.g., inspector checklists, self-certification forms, workbooks, and workshop materials)? The more issues your program seeks to address, the more resources may be required to develop program materials.
- Have you built in enough resources in your budget to allow for feedback and revisions of program strategy and materials?
- Have you accounted for direct costs such as purchasing needed computer equipment or software and printing, and mailing program materials?
- Have you considered what targeted follow-up will be required after inspections?
- Have you considered talking with staff for other state ERPs to see how they set up their project budgets and what level of resources were required? If you do talk with staff for other programs, keep in mind that resource requirements depend significantly on the scope of the project.
Find Project Resources and Staff
Before progressing too far in ERP development, you will need to assess what personnel and which groups are available to participate in and help with ERP, as well as any monetary or in-kind resources you may be able to access.
Questions to consider
- What internal resources do you have?
- Can you get expert advice from your agency's program staff, lawyers, and statisticians?
- Can you obtain assistance from inspectors and data entry personnel?
- What IT and data management capacities are available for ERP? What are your agency's data management capabilities and limitations? Will your current IT system be able to collect, process, and analyze ERP data? Will you need to expand upon existing systems or build a new system?
- What external resources are available (e.g., EPA, other state/local agencies, trade associations, local media, community groups, non-profits in this sector)?
- Will you be using consultants at any stage in ERP (e.g., program development, statistical, or information technology consultants)?
Resources to consider
- Staffing [Cached version] (PDF, links to page 16 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002)) - Information Management [Cached version] (PDF, links to page 17 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002))
Phase 2: Stakeholder Involvement
Be sure you communicate with key internal and external groups to get buy-in and feedback on key project decisions, and to secure their commitment to assist and/or participate in the project.
Internal
- Involve program staff, inspectors, lawyers, IT staff, and any other internal staff that may contribute to ERP.
External
- Contact other related local and regional governmental agencies (e.g., EPA Region, agencies regulating weights and measures, business licensing departments, fire marshals, health departments, state OSHA officials, vocational schools, etc.) to determine any possible synergies or opportunities to share resources, information, or expertise.
- Discuss the general concept of ERP with the sector and key community stakeholders to generate support for the program and to offer an opportunity for feedback. Note, it is advisable to avoid discussing extensive details of the program until baseline inspections are complete, so as to not bias baseline data.
Internal and external
- Apply for and secure funding and staffing for ERP.
Resources to consider
- Involve Stakeholders [Cached version] (PDF, links to page 31 of a 154 page document, 620 KB, About PDF)
(Excerpt from The Massachusetts Environmental Results Program: User's Guide for Government Agencies (March 2002))