Environmental Audit – Barbara Boyle and Marti Ellermann

Residence Hall Capital Plans Off Balance Residence Halls UPD accreditation goals Governor’s Initiative for Energy Savings

Office for Capital Facilities (OCF) Presentation to SUBOA

June 4, 2012

Environmental Auditing

Air Programs Bulk Chemical Storage Emergency Planning and

Community Right-to-Know Act and New York TRI Reporting

Hazardous Substance Release Notifications

Hazardous Waste (RCRA) Oil Pollution Prevention (Oil SPCC) Oil Storage and Release Reporting

(PBS) Pesticide Management

Environmental Auditing Regulated Medical Waste Safe Drinking Water Act Stormwater Permitting

(SWPPP) Toxic Substances (TSCA-Lead-

Based Paint, PCBs, and Asbestos)

Underground Injection Control (UIC)

Universal Waste Used Oil Management Wastewater Discharges (SPDES,

MS4)

Why do we do audits?

Confirm continued compliance.Staff changesProcesses changeFacilities change

More importantly – sound risk management!

SUNY/EPA Audit Agreement and Program 2002 Audit program was prompted by an invitation

from EPA to colleges and universities. Program was managed by Office of University

Counsel. SUNY/EPA agreement modified standard

provisions to make them more amenable to SUNY logistics.

Where have we been?

Audit period was five years.

Woodard & Curran was contracted as third-party auditor for $950,000.

state operated campuses - required to participate community colleges - offered the opportunity

all but Erie participated statutory colleges - not involved

Where have we been? (cont.)

Project costs were assessed on campuses in the year in which the site visit occurred.

Distribution formula was based on gross square feet with certain “environmentally intense” classes (e.g., wet labs) counted twice. Centers: $40-113K Median Comprehensives: $22K Median technology: $17K Median community college: $6K

Where have we been? (cont.)

SUNY was required to audit, disclose and correct findings, and agree to prevent recurrence.

EPA agreed to defer most inspections and waive all gravity-based penalties.

• The EPA did not agree to waive economic benefit penalties, but found all potential fines to be de minimis.

• In subsequent audit agreements, the EPA placed significant importance of the development of formal Environmental Management Systems (EMS) to prevent recurrence of noncompliant conditions.

Basic SUNY/EPA agreement

One thousand violations were disclosed.

All gravity-based penalties were waived EPA estimate: $10M

Audit program was favorably viewed by many groups.

Campuses identified and corrected many poor practices and deficient conditions.

Results

Audits were conduct 2002 through 2007. There has been no formal system-wide follow up. Campuses were expected to maintain corrective actions.

There was no validation of audit responses system-wide.

Typical external environmental auditing interval is 3 to 5 years.

Where are we now?

Several options considered.

No audit mandate or interventionPeer audit (Western NYS model)Peer audit (Georgia model)Central Auditor/EMS (CUNY model)Traditional Third Party

Where should we position ourselves?

Option 1:No audit mandate or intervention

Strengths

Short term cost avoidance

Challenges

Actual liabilityThreat of compliance

enforcementPerceived “bad player”

Option 2:Peer Audit (Western NY model)

expand pilot program and make mandatory

StrengthsLow cost

Campus staff development

BMP sharing opportunities

Supports shared services concept

Challenges

Auditor experience

Lack of specialty and/or bench strength

Auditor objectivity and availability

Option 3:Peer Audit (Georgia Model)

consultant to train campus staff as auditors and to accompany newly trained campus staff to conduct audits of 38 campuses over 4 years

Strengths

Perceived lower cost Specialty consultants readily

available Campus staff developmentShared services/BMP

ChallengesMigrated significantly towards

traditional third-party auditRequired one FTE at central

officeWeakness in auditor

responsivenessCost savings may not have been

as significant as initially assumed

Option 4: Central Auditor/EMS (CUNY Model)

after initial third-party audit, dedicated central position for env audits/EMS support; required campus auditor contributions; supported by consultants

Strengths

Customized solution/fluidity

More permanent solutionSpecialty support availableShared services/BMP

Challenges

Additional FTECUNY central @ 0.7 FTE for 24 campuses on 3 yr

cycle

Some diminution of campus autonomy

Option 5: Traditional Third Party

StrengthsProfessional

Objective

Specialty/bench strength

Challenges

Limited staff development

Arguably more expensive

Use the traditional third-party audit. Mimic much of the 2002-2007 program No agreement with EPA No planned disclosure No shelter from fines and penalties

Goals:Increased compliance levelsImproved risk managementBetter environmental stewardship

Suggested Program

Environment Audit Questions and Discussion

Going out to Campuses soon Cash flow extended out to 10 years No bonded capital appropriation for 12/13, this

will show in your plan as requested but unfunded

Asking campuses to alert us if off-balance sheet housing being considered

Residence Hall Capital Plans

Beds in the Res Hall program ~ 75,000 Off balance sheet beds - less than 7,000 9 Campuses have some type of off-balance housing –

Albany (1,196) , Binghamton (710), UB (2,172), Buff State (507), Canton (305), Delhi (120), ESF (454), Morrisville (440) and Purchase (408)

Survey (handout) includes current data Additional information needed regarding insurance

for buildings and bonds New requests to go off balance include Cobleskill –

156 beds, Buffalo State - 200 Beds

Off Balance Housing

Agencies Accredited (and date of accreditation):SUNY Albany University PD – June 2011SUNY Buffalo University PD – December 2007 (up for reaccreditation this year)SUNY Cortland University PD – March 2011SUNY Stony Brook University PD – December 2010

Recently Completed Assessments to be awarded in JuneSUNY Alfred University PDSUNY Buffalo State College PDSUNY Oneonta University PD

7 campuses Accredited (or have successfully completed assessment) = 25%

UPD accreditation

Applications Received (12):SUNY Canton University PDSUNY Old Westbury University PDSUNY Oswego University PDSUNY Binghamton University PDSUNY Cobleskill University PDSUNY ESF University PDSUNY Farmingdale University PDSUNY IT University PDSUNY Morrisville University PDSUNY New Paltz University PDSUNY Plattsburgh University PDSUNY Purchase University PD

19 campuses engaged in the Accreditation process = 68% Numerous UPD officers trained to be part of accreditation teams

UPD Accreditation (cont.)

Goal - 20% reduction in State Agency energy use

NYPA Energy Audits will be done to identify savings opportunities

NYSERDA opportunities will be highlighted Meeting with Governor’s office next week to

discuss next steps More information to follow

Governor’s Energy Efficiency Initiative