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Improving Environmental Enforcement Effectiveness in the Environmental Protection Agency’s Drinking Water Program Open Access

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The purpose of this study was to determine if the Environmental Protection Agency’s (EPA) currently implemented 2009 Enforcement Response Policy (ERP) positively impacted the effectiveness of state and national enforcement and remediation of the most significant drinking water violations. The first question addressed by this study compares the effectiveness of the Enforcement Targeting Tool (ETT) to the Alternate Enforcement Targeting Tool (Alternate ETT; described in EPA’s 2009 Enforcement Response Policy) at returning systems to compliance when prioritizing drinking water systems with significant violations. To address the first research question, the data were analyzed by looking at a subset of the priority Public Water Systems (PWSs) to identify the degree to which the PWSs with the highest ETT scores returned to compliance within six months or had a formal enforcement action taken against them. The hypothesis developed to test the first research question examined compliance rates utilizing ETT scoring compared to Alternate ETT scoring.The study also addressed the second research question of whether a decision support tool, developed utilizing a multiple-criteria decision analysis methodology, would better enable prioritization by federal and state regulators of significant violations at drinking water systems. The author chose the analytic hierarchy process (AHP) as the multiple-criteria decision analysis (MCDA) method for investigating the second research question. After choosing AHP as the prioritization framework, the author convened a group of eleven subject matter experts (SMEs) who had expertise and experience in safe drinking water enforcement at national and state levels and recent experience with the SDWA ERP and utilization of the ETT. In addressing the first research question, the results of the statistical analysis were consistent with the hypothesized relationship, namely that more systems considered “high-priority” returned to compliance within six months of being identified by the Alternate ETT list than under the ETT. Further analysis showed that regulators appeared to be incorporating a population factor (namely, larger populations get priority) into their decision-making on addressing significant violators. In addressing the second research question, utilization of the AHP method showed that SMEs found the “severity of violations in terms of public health risk” to be the most significant factor when prioritizing significant violators that are addressed. Further analysis of the ETT shows that though “severity of violations” is an element of the ETT scoring, other elements may be masking the severity element. Since its release in December 2009, the ERP and the resultant ETT process has had a beneficial effect on the universe of drinking water systems in significant non-compliance. However, to show increased benefits, and for the health of our public water systems, further analysis and refinements of the ERP should be undertaken and implemented.

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