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Chapter 2
Organizational Environmental Stewardship Practices
2.7. Environmental Staffing, Roles, and Responsibilities

An effective environmental management system requires, roles, responsibilities, and authorities to be defined and communicated. Also essential are the necessary resources, including human resources and specialized skills, technology and financial resources, to implement an organization's environmental objectives.

 

2.7.1 Clarifying Roles and Responsibilities to Ensure Environmental Performance
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As part of environmental performance and process improvement efforts, some DOTs have also sought to clarify environmental roles and responsibilities. As of 2002, DOTs that indicated having identified environmental roles across their organizations included: Alabama, Connecticut, Florida, Georgia, Hawaii, Iowa, Kansas, Kentucky, Michigan, Minnesota, North Carolina, New York, Puerto Rico, Texas, Utah, Virginia, and Wisconsin, in addition to the examples which follow. Tables are sometimes used to ensure all responsibilities have been assigned, communication is clear, and no gaps are present.

Mass Highway District Environmental Roles and Responsibilities and Associated Training

Mass Highway's EMS manual describes organizational roles and responsibilities relative to environmental compliance management at Mass Highway facilities. Personnel within the major Organization Offices, Divisions, Districts and Sections that affect compliance with Mass Highway environmental requirements are identified. To "foster the integration of environmental stewardship into facility operations…roles and responsibilities for environmental management have been established and employees shall be educated as how to best carry out their environmental related duties."(33) The sections listed in the Appendix provide an overview of Mass Highway EMS roles and responsibilities for personnel in the Organization Offices, Divisions, Districts and Sections and illustrate the degree to which the success of such an environmental process improvement program depends upon broad involvement and responsibility. These sections are: Mass Highway Environmental Roles and Responsibilities, Section EMS Roles and Responsibilities, Operations Division EMS Roles, and Responsibilities, District EMS Roles and Responsibilities. Training expectations have been tied to each of these roles as well as roles and responsibilities accompanying the training program and are also listed in the Appendix.

The environmental review process encompasses a number of other EMS roles and responsibilities. For example, in that process at Mass Highway, the Chief Engineer assumes ultimate responsibility for ensuring an annual review of the environmental management system is conducted and the Deputy Chief Engineer Environmental assumes responsibility for the EMS Program review, coordinates Senior Management Review and the EMS Task Force reviews. The Deputy Chief engineer also coordinates independent audits and ensures implementation of recommendations from the review. The EMS Supervisor HazMat/HazWaste Unit conducts the annual EMS Task Force review meeting and prepares a summary of EMS Task Force recommendations for the Deputy Chief Engineer, Environmental Section, Chief Engineer, District Highway Directors, Deputy Chiefs, and Department/Section Heads. The EMS Supervisor also participates in the annual Senior Management Review process, represents District/Operation by providing input on current operations and EMS implementation, and reviews bi-annual independent audits and makes recommendations on correction and implementation of audit findings. The EMS Task Force participates in the annual EMS Task Force review process, provides comments on EMS effectiveness and makes recommendations for improvements. An independent EMS reviewer conducts bi-annual EMS program reviews and prepares a summary of findings for submission to the Deputy Chief Engineer.

PennDOT Environmental Role and Responsibility Identification for SEMP Implementation

PennDOT's Engineering & Maintenance District 10 is using the Responsibility Table listed in the Appendix to ensure that responsibilities in delivering its Strategic Environmental Management Program are assigned and carried out. Training requirements to support each position in carrying out their responsibilities are included in the Training Table, also listed in the Appendix.

Caltrans Construction Compliance and Stormwater Roles and Responsibilities

The Caltrans Construction manual specifies that "the district construction deputy director is responsible for ensuring that environmental and permit requirements are enforced. To meet legal requirements, district construction staff must receive appropriate training, possess appropriate skills, and understand their role in successfully carrying out environmental measures. Within the district construction division, appropriate environmental coordinators must be appointed." [N] Caltrans extensively delineates roles and responsibilities as part of the agency's Construction Stormwater Coordinator Guidance Manual see pp. 2-8.

 

2.7.2 Staffing: Environmental Support for Construction & Maintenance
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Several state DOTs have added environmental staff devoted to assisting Construction and/or Maintenance staff. In response to the agency's increased focus on environmental sensitivity, Mass Highway established a separate environmental program within its Construction Division. Working with environmental and construction staff in headquarters and District offices, the program provides quality assurance reviews on construction projects, compliance assistance to staff, coordination with regulatory agencies, training and written guidance. NYSDOT and Virginia DOT provide the most far-reaching and staff rich models focused on construction and maintenance. Virginia has placed 29 staff around the state in residencies, primarily to support maintenance operations. Another 19 Environmental Monitors serve as erosion and sedimentation control experts around the state and monitor the full range of environmental commitments. NYSDOT has placed 22 senior environmental specialists in Regions, 11 to support construction and 11 for maintenance.

Mn/DOT and WSDOT Environmental Staff Supporting Maintenance & Operations

Many states have environmental staff in regions or districts that are focused on NEPA compliance and project development and who also provide some support to waste management and environmental compliance/commitment follow-through. Mn/DOT and WSDOT have added environmental staff supporting maintenance and operations. In Washington , assistance is supplied by Regional Maintenance Environmental Coordinator (REMC) who obtains necessary permits and provides on site and telephone consultation.

NCDOT's Environmental Coordinators in the Field

NCDOT has also recently added regional environmental coordinators. Each of North Carolina 's 14 statewide transportation divisions employs a Division Environmental Officer to assist, coordinate, and facilitate environmental issues that may occur in the field. The Division Environmental Officer acts as a liaison between field operations and the resource agencies and ensures NCDOT's implementation of environmental commitments.

Indiana DOT's Environmental Compliance Coordinator

Indiana DOT (INDOT) employs an environmental coordinator for non-NEPA compliance in each INDOT district who is responsible for monitoring compliance within INDOT's operations. The position focuses on applicable regulations protecting air, water, soil, and other resources. The Environmental Coordinator is responsible for training construction and maintenance personnel on environmental permitting, regulations, and methodologies to ensure that highways are environmentally "friendly" and conform to all laws and regulations. Likewise, the environmental coordinators assist in developing and undertaking environmental research projects, best management practices, and the establishment of environmental policy. They are also responsible for inspecting construction sites to ensure compliance with permits and mitigation.

Virginia DOT's Residency Environmental Specialists for Maintenance

Virginia DOT (VDOT)'s 29 Residency Environmental Specialists (RESs) cover 45 residencies, with the objective of facilitating delivery of the transportation program by providing regulatory compliance, leadership, management, and accountability, primarily for maintenance. The positions provide daily guidance, assistance, and leadership to residency and field personnel to ensure that their operations are performed in compliance with regulations and best management practice. The RESs also serve as liaisons between the residency office and the district environmental staff. RESs advise staff on the need for permits and reviews and assist with training of staff and planning of operations. The RES determines whether permits are needed, assists in the development of permits and erosion control plans, and reviews and approves borrow pit and disposal areas for maintenance and operations. The RES reviews environmental commitments with the project manager and/or Residency Engineer prior to commencement of operations to ensure compliance with best practices and permit requirements, and provides periodic review of controls. The RES also works with district environmental staff to develop training needs assessments for the residency and formulate training modules to keep staff up to date with environmental changes that affect the residency.

In addition to basic knowledge of environmental laws and regulations, permit requirements, erosion control issues, and wetland identification, the RESs require skills working with people of a variety of educational levels, planning and directing environmentally compliant operations, and working to develop an environmental ethic with regard to transportation operations. VDOT has developed a training program and manual for the RESs, specifically focused on erosion control and water-related issues. While Resident Engineers were initially skeptical about placing what they viewed as auditors in their residencies, the RESs were quickly seen as indispensable additions who greatly reduced environmental risks and liabilities for Resident Engineers individually and for the agency as a whole. Unlike NYSDOT's program a description of which follows, VDOT designed their RES program to have entry level personnel who were then trained and could serve as an RES feeder program for more senior level headquarters environmental staff.

NYSDOT Construction & Maintenance Environmental Coordinators

NYSDOT's investment in new senior environmental coordinators for Construction and Maintenance Districts has been significant considering that the department is downsizing overall. As previously mentioned, NYSDOT hired 11 environmental coordinators (ECs) to support Construction and the same number to support Maintenance. These 22 environmental coordinators are senior NYSDOT staff selected by upper management to focus on regional priorities while providing oversight, quality assurance, and technical advice. This program is designed to minimize permitting problems and inconsistencies in overall regional approaches, including meeting environmental commitments throughout the project development lifetime. NYSDOT decided to place the ECs directly into Regional Construction and Maintenance Groups in order to address specific areas for department-wide environmental improvement in Construction and Maintenance, as follows: 1) increased environmental field presence; 2) increased familiarity with maintenance staff, activities and issues; 3) improved responsiveness to maintenance environmental needs; 4) greater leadership and follow-through on priority environmental issues in maintenance; 5) improved environmental training for maintenance staff; and 6.) improved intra-regional communication on environmental issues.

Upon hiring, the ECs were directed to spend about 50 percent of their time "in the field" observing, learning, advising and proactively identifying environmental stewardship opportunities. [N] Maintenance forces in particular are often called upon to react immediately to a safety situation due to storms, accidents, etc. and need timely environmental advice and recommendations. As the first point of contact, the Maintenance Environmental Coordinator (MEC) helps bring about improved coordination and faster response to environmental needs. By focusing solely on environmental issues in maintenance, the MECs are also able to learn what issues are priorities and commonplace and then prepare regional guidance and training to address these areas in a proactive and programmatic manner. Furthermore, through their sole focus on maintenance issues, MECs have the support, time and ability to identify and coordinate the follow-through on environmental stewardship opportunities, many of which may have been missed in the past.

So that the ECs could "hit the ground running, learn as a group and be integrated with other department programs, a system was set-up immediately upon their hiring that: 1.) provided a clear description of the EC role and responsibilities; 2.) provided comprehensive training in priority environmental areas; 3.) provided bi-annual statewide EC coordination meetings; and 4.) provided for each EC to submit a monthly activity report. [N] These activities have been intended to improve EC effectiveness through direction, knowledge, shared experience and communication.

Table 6 : NYSDOT Sample Performance Program for Environmental Support Staff in Construction

TASKS AND OBJECTIVES

PERFORMANCE STANDARDS

Ensure that constructability issues regarding environmental impacts are understood by designers and appropriately incorporated into projects.

1A. Represent regional construction group at meetings during all phases of project development, e.g. pre-scoping, scoping, etc., and provide recommendations regarding constructability issues related to environmental impacts.

1B. Review project plans at Preliminary and Advanced Detail Plan stage to ensure that constructability issues relating to environmental impacts are adequately addressed.

1C. Assist in development of ECOPAC materials during project development.

1D. Review project materials, including ECOPAC, at final Plans, Specifications and Estimates stage to ensure that constructability issues related to environmental impacts are adequately addressed.

Ensure that Regional Construction staff, Contractors and Consultants are thoroughly familiar with the environmental context and requirements of projects.

2A. Attend Preconstruction and Get Start meetings and take lead in discussion of environmental issues using ECOPAC and applicable plan sheets, specifications, notes, etc.

Provide Quality Assurance services to ensure that environmental commitments and obligations are fully implemented during project construction activities.

3A. Assist with development and implementation of necessary and desirable project modifications that may affect environmental impacts.

3B. Ensure that an adequate level of environmental monitoring occurs at critical project stages, e.g. wetland construction.

3C. Ensure appropriate notification, coordination and documentation of environmental obligations during project construction, e.g. update SPPP.

Provide Support Services to ensure that policies, procedures and training contribute to improved environmental performance in construction.

4A. Review , revise and generate procedures, guidance and specifications, as appropriate, to ensure full consideration of environmental issues and opportunities during project construction .

4B. Identify and provide/coordinate appropriate environmental training to construction staff in a timely and efficient manner.

Serve as Regional Construction Coordinator for Erosion and Sediment Control issues.

5A. Provide early and continuous input to design staff regarding erosion and sediment control plan development.

5B. Review final erosion and sediment control plan and provide recommendation prior to construction sign-off.

5C. Discuss Erosion and Sediment Control Plan with Construction staff, Contractor and Consultants prior to construction activities.

5D. Review Contractors required written Erosion/Sediment Control Plan and provide recommendation prior to EIC approval.

5E. Review necessary modifications to original Erosion and Sediment Control Plan that occur during project construction and provide recommendation prior to EIC approval

5F. Ensure that required Erosion and Sediment Control records are maintained in the project file.

Serve as Regional Construction Coordinator for Department Environmental Ethic and Stewardship Programs.

6A. Proactively identify and implement programmatic and project specific opportunities to incorporate environmental betterments into construction projects and activities.

6B. Provide/coordinate timely and appropriate environmental awareness training for construction staff.

Provide liaison between Regional Construction Unit and Regional Landscape Architecture/ Environmental Services Unit, The Environmental Analysis Bureau and Regulatory Agencies.

7A. Attend RLAES Unit staff meetings and provide feedback regarding construction/environmental issues and activities.

7B. Attend statewide Construction/Environmental Coordination Meetings to exchange information with other regions and EAB Coordinator.

7C. Attend annual NYSDOT Environmental Conference.

7D. Serve as general point of contact regarding environmental issues during project construction by directly providing technical and procedural advice to construction staff or coordinating same with RLAES Unit, external groups and agencies, as appropriate.

Assist with conduct of Regional Environmental Audit.

8A. Ensure that Environmental Audit materials relating to construction activities are completed in a timely, thorough and accurate manner.

8B. Provide annual Environmental Audit Training for responsible Regional Construction staff.

To share experiences, establish priorities, identify issues of common concern, and increase knowledge and awareness within the larger agency, NYSDOT Construction Environmental Coordinators and Maintenance Environmental Coordinators submit brief monthly reports on activities in the following ten core areas.

Quality Assurance

  • Review Preliminary, Advanced Detail and Final Plans for Constructability (Erosion and Sediment Control, etc.)
  • Inventory/Disposal of Residency Hazardous Materials
  • Review Department Practices and Operations (Salt Storage/Handling, Bridge Washing, Herbicide Applications, Mowing, Ditch Cleaning, etc.)
  • Review ECOPAC
  • Attend Preconstruction and Get Start Meetings
  • Compliance with Permit Conditions and Regulations
  • Review Staging, Spoil, Borrow and Field Office Locations
  • Attend Scoping Meetings

Environmental Stewardship

  • Specific Projects (Nest Boxes, etc.)
  • General Environmental Awareness

Liaison

  • Attend RLAES Unit Staff Meetings
  • Meet with RLAEM
  • Meet with Regulatory and Resource Agencies
  • Meet with Environmental Groups
  • Attend Regional Committee Meetings (Environmental Initiative, etc.)
  • Respond to Public Inquiries, Complaints, etc.
  • Attend Statewide Operations Environmental Coordinator Meetings

Technical Advice

  • Provide Informal Technical Advice to Field Staff
  • Residency Visits
  • Project Visits

Training

  • Prepare Training Materials and Conduct Training Classes
  • Coordinate Training Classes

Permitting

  • Prepare, Review, Coordinate Permit Materials
  • Develop Programmatic Agreements
  • NPDES Phase 2 Compliance
  • Review Highway Work Permit Applications

Programmatic Guidance

  • Prepare written Guidance/Procedures
  • Prepare or Revise Specifications

Assistance to Other Units

  • Design, Construction, Maintenance, and Main Office

Environmental Audit

  • Prepare or Advise on Audit Reports and Follow-up on Audit Violations

Personal Development

  • Attend Training Courses and Attend Conferences/Seminars
  • Miscellaneous
    • Salt Contamination Investigation
    • GIS
    • SPDES

This information and an estimated ratio of percent of time spent in the field vs. in the office is tracked by a headquarters program coordinator to ensure that field staff receive further guidance, support, or training as needed. The Main Office Coordinator meets biweekly with representatives from the Main Office Construction, Maintenance and Design Divisions and regularly travels to meeting with regional maintenance and construction staff and environmental groups. Regions regularly introduce new and innovative environmental practices in construction and maintenance activities, which are communicated to other regions to ensure statewide benefit.

 

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Continue to Section 2.8»
 
Table of Contents
 
Chapter 2
Organizational Environmental Stewardship Practices
2.1 DOT Environmental Policies and Mission Statements
2.2 Environmental Strategic Planning at Transportation Agencies
2.3 Setting Objectives and Targets & Tracking Environmental Commitments
2.4 Environmental Management Systems - Benefits & Approaches
2.5 Operational Controls, Procedures, and Practices
2.6 Measuring Environmental Performance
2.7 Environmental Staffing, Roles, and Responsibilities
2.8 Environmental Training and Certification
2.9 Regional DOT Stewardship Practice Exchange & Discussion
   
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