o I Ml c u r O M i - i r u K i M i M

Budget Change Proposal - Cover Sheet DF-46(REV 08/15)

Fiscal Year 2017-18

Business Unit 3970

Department Department of Resources Recycling and Recovery

Priority No. 11

Budget Request Name 3970-011-BCP-2017-GB

Program 3700 - Waste Reduction And Management

Subprogram

Budget Request Description Tire Enforcement Agency (TEA) Program Evaluation

Budget Request Summary The Department of Resources Recycling and Recovery (CalRecycle) requests two (2.0) full-time, permanent Environmental Scientists, and shift the expenditure authority of $168,000 from Local Assistance to State Operations in Tire Recycling Management Fund to evaluate Local Government Waste Tire Enforcement (TEA) Grantee performance.

Requires Legislation

• Yes lEl No

Code Section(s) to be Added/Amended/Repealed

Does this BCP contain information technology (IT) components? • Yes ^ No

If yes, departmental Chief Information Officer must sign.

Department CIO Date

For IT requests, specify the date a Special Project Report (SPR) or Feasibility Study Report (FSR) was approved by the Department of Technology, or previously by the Department of Finance.

FSR SPR Project No. Date:

If proposal affects another department, does other department concur with proposal? Yes No Attach comments of affected department, signed and dated by the department director or designee.

Prepared By Date Reviewed By Date Georgianne Turner Olga Garti

Department Director Date Agency Secretary Date Scott Smithline Matthew Rodriguez

Department of Finance Use Only

Additional Review: Capital Outlay ITCU FSCU OSAE CALSTARS Dept. of Technology

BCP Type: Policy Workload Budget per Government Code 13308.05

Original Signed by Ellen Moratti PPBA PPBA Date submitted to the Legislature

Analysis or KroDiem

Budget Request Summary

The Department of Resources Recycling and Recovery (CalRecycle) requests two (2.0) full-time, permanent Environmental Scientists, and shift the expenditure authority of $168,000 from Local Assistance to State Operations in Tire Recycling Management Fund, to evaluate Local Government Waste Tire Enforcement (TEA) Grantee performance. The additional positions will not change the overall cost or expenditures of the program, as the grant funding for the TEA program will be reduced to cover the costs of the two positions.

In the spring of 2016, CalRecycle saw a reduction of nine jurisdictions applying for TEA grants for a total reduction of 11 jurisdictions since 2014. This has been an approximate 10 percent overall reduction in TEA inspection capability for the State. CalRecycle also found that several TEA programs struggle to maintain consistency with grant requirements. CalRecycle added components to the TEA grant program that require more detailed analysis and evaluation of the work actually performed by the TEA, which requires a higher level of monitoring of the TEA grantees.

Background/History

Authoritv Senate Bill (SB) 876 (Escutia, Chapter 838, Statutes of 2000) was a comprehensive measure enacted to extend and expand California's regulatory program related to the management of waste and used tires. One of the key provisions of SB 876 requires CalRecycle to adopt and submit to the Legislature, a Five-Year Plan that identifies priorities, performance criteria, and budget allocations.

The current Five-Year Plan outlines a comprehensive enforcement program with the primary goal to manage and mitigate the impacts of tires on public health and safety, and the environment, by ensuring that tire businesses comply with tire permitting, storage, movement laws, regulations, and state minimum standards. Compliance is monitored through integrated and consistent permitting, inspection, and enforcement efforts and is carried out by state personnel, and some activities are carried out by local grantees in some jurisdictions, and include:

• Inspecting tire businesses for compliance with permitting, storage, and movement according to the laws, regulations, and state minimum standards

• Educating tire businesses and property owners about tire laws and regulations • Looking for illegal dumping, storage, and movement of tires • Taking enforcement actions as needed to correct violations

Public Resource Code, section 42889 allows for the Department to provide sufficient, stable, and noncompetitive funding to local governments in order to implement specific tire inspection and enforcement duties.

History of TEA Program Starting in 1997, CalRecycle provided minimal funding to a few local governments. However, the program remained small until 2002, when the Five Year Tire Plan allocated $2 million for the Local Government Waste TEA Grant Program and increased the grant funding available to $6 million by 2004.

With the passage of SB 876 and the implementation of the new manifest system, the number of regulated businesses increased from approximately 8,000 in 2002 to 31,000 businesses today. The increased funding for local grants allowed the Department to leverage existing local code enforcement and solid waste enforcement agencies to survey and inspect these businesses. During this timeframe the TEAs increased from eight to thirty-six. In most cases, using local inspectors offered efficiencies due to reduced travel and increased surveillance during their other local work. Since 2010, CalRecycle has had a robust program allocating at least $7 million of the $8 million inspection and enforcement budget (87percent) per year to the Local Government Waste TEA Grant Program.

Analysis of Problem TEA and CalRecycle Duties and Responsibilities

TEAs are reimbursed for costs to perform initial and follow-up inspections for CalRecycle-designated waste tire businesses in their jurisdiction and, when necessary, issue Notice of Violations. They also identify illegal waste tire sites, investigate illegal tire disposal activities, and review waste tire hauler documents. These activities ensure that tire dealers, auto dismantlers, tire haulers, and others comply with all applicable laws, storage standards, and manifest requirements.

CalRecycle conducts inspection duties in jurisdictions where there is no TEA, provides ongoing assistance to TEAs and oversees enforcement statewide, to ensure applicable state laws are enforced consistently. Department staff support grantees by providing formal and informal training, conducting round tables, and reviewing inspection reports. All enforcement past the Notice of Violation stage are referred to CalRecycle for further investigation and development of enforcement cases. CalRecycle subsequently conducts further inspections and investigations, issues cleanup and abatement orders, issues administrative complaints, and in some cases refers a case to the Attorney General or Local District Attorney. Some cases require the Department to work with California Highway Patrol or to conduct surveillance. Furthermore, State staff are responsible for all inspections of the 43 permitted facilities in the state once per year.

Changes to the TEA Grant Program, TEA Coverage and Workload of CalRecycle

Oyer the course of the grant program, CalRecycle has made yarious reyisions to its grant criteria to assure the local agencies are using the funds for the highest priority tire compliance issues, to assure prudent use of state funds, to address stakeholder needs related to assuring full cost recoyery and stable funding, and to assure consistent enforcement of the tire laws throughout the State. In the spring of 2016, CalRecycle made another revision to the grant criteria to improve fiscal efficiencies and improve performance of the TEAs. The revisions were necessary to 1) address TEAs charging high hourly rates; 2) address the fact that in some cases the costs to administer the grant and support the local grantee exceeded the benefit (convenience and fiscal) to the State, specifically in small jurisdictions; and 3) some TEA programs struggle to follow inspection priorities, inspection guidelines and maintain consistency with state requirements even after training.

The following are the key changes that were made in TEA grants for grant cycle 23 (TEA 23) to assure high performance and to make the program a more cost effective and fiscally prudent program:

• Establish personnel cost reimbursement based on employees' actual hourly cost plus fringe benefits. This change was necessary because audits found that TEAs where charging Board of Supervisor rates, higher than their actual costs. Additionally, these rates had high indirect costs in them

• Indirect costs should not exceed 20 percent and must be a separate budget category (not part of an hourly cost)

• Increase the number of active businesses to 100 from 50, for a City to be eligible. This change was made for efficiency purposes

• Apply expertise requirements, requiring all inspectors to be trained by CalRecycle, before they can conduct inspections under the grant and receive reimbursement

• Implement a formal performance evaluation process of TEAs. This will require a detailed analysis and evaluation of the work actually performed by the TEA

In response to these revised grant requirements, nine TEA grantees dropped out of the program; a total loss of 11 grantees since 2014. Based on conversations with the local agencies, it is likely to a few more TEAs next year.

Impact of the Recent Change

The TEA grant program has been stable until this last year; between 45 and 47 TEAs have been covering approximately 74 percent of active waste tire businesses in the State. In the TEA 20 grant cycle, there were 11 cities and 35 counties in the program, leaving the remaining 23 counties and most of the cities in these counties covered by CalRecycle. In TEA 23, the Department lost nine (9.0) TEAs (45 to 36 grantees) who covered inspections for approximately 2,500 businesses (and conducted 1,500 inspections per year); five (5.0) small cities with under 100 businesses each, one large city with over

Mnaiysis OT r roDiem 1,000 businesses, and three (3.0) counties. With the recent loss, the State will be responsible for inspecting an additional 8 percent of the tire handling businesses.

The TEA 23 grant cycle resulted in approximately a $1.45 million reduction in recommended funding (from $7 million in TEA 22). Of this reduction, $622,000 was from TEAs not applying and $828,000 was from reductions in requests. Applicants did not request as much funding this cycle because of the additional restrictions in the grant criteria. The Department is attributing this to the elimination of the high hourly rate which was associated with the jurisdiction's approved Board of Supervisors rate, in conjunction with new limits on overhead / indirect costs.

Resource History (Dollars in thousands)

Program Budget P Y - 4 2011-12

P Y - 3 2012-13

PY - 2 2013-14

P Y - 1 2014-15

PY 2015-16

Allocated Positions* 12.0 12.0 12.0 12.0 12.0

Grantee Support & Training Positions*

3.0 2.0 3.0 2.0 2.0

Grantee Oversight - Review of TEA Inspections

2 3 3 3 3

Formal Evaluation of TEA with Report and Corrective Action

0 0 0 0 0

Routine inspections and Positions*

4 4 3 3. 3

Foiiow-up Inspections and Enforcement and Grantee Enforcement referrals

2 2 1 2 2

Program, Policy, Regulation, Database Development and Support

1 1 2 2 2

FAuthorized Positions 12.0 12.0 12.0 12.0 12.0 Filled Positions 12.0 12.0 12.0 11.0 11.0 Vacancies 0.0 0.0 1.0 1.0 1.0

*Note: Positions were responsible for facility inspections, enforcement activities, review of grantee inspections, grantee training, policy and TEA guidance development, maintenance and development of improvements to database for more cost effective program (i.e. electronic inspections). These are broken out according to percentage duties and total PY.

Workload History

Workload Measure P Y - 4 2011-12

P Y - 3 2012-13

PY - 2 2013-14

PY -1 2014-15

PY 2015-16

TEA Funding Cycle T E A 18 (2010-11 awards)

TEA 19 (2011-12 awards)

TEA 20 (2012-13 awards)

TEA 21 (2013-14 awards)

TEA 22 (2014-15 awards)

Total facilities regulated 29,000 29,000 29,000 30,000 30,000

Number of inspections by CalRecycle

2,200 2,300 1,850 1,850 TBD

Enforcement Actions 10 11 4 13 12

Number of Grantees 46 47 46 47 45

Grant Award $7,775,000 $7,775,000 $7,000,000 $7,440,456 $7,000,000

Grant Expenditure $6,467,448.87 $6,572,396.91 $6,303,029.16 $6,298,607.07 TBD

Percentage of the award used 83% 84% 90% 84% TBD

k Number of inspections covered ' by Grantees

16,500 18,000 19,000 18,000 18,000

Percentage of inspections conducted by TEAs by total sites in state database

55% 62% 65% 60% 60%

Analysis of Problem C. State Level Considerations

Under Senate Bill (SB) 867, CalRecycle is required to adopt and submit to thie legislature a Five-Year-Plan. As part of the Five-Year-Plan, CalRecycle provides non-competitive grant funding to cities, counties, or cities and counties to ensure local waste tire inspection and enforcement activities are adequately carried out as part of the TEA. CalRecycle is proposing to augment CalRecycle enforcement efforts via a TEA Evaluation program to oversee TEA's tire inspection and enforcement the program will provide a method to demonstrate incompetency and support a corrective action process for those TEAs failing to conduct adequate assessment of tire facilities.

D. Justification

The loss of nine (9.0) TEA grantees resulted in losing regulatory oversight coverage of approximately 2,500 businesses; this translates to 1,500 annual inspections. Because of the need to maintain at least minimal regulatory oversight, CalRecycle could assume this workload with two additional positions by reducing the inspection frequency for "generator inspections" (approximately 90 percent of the businesses) to the minimum outlined in the Department's Five Year Tire Plan (i.e., once every three years). This would result in 850 additional annual inspections.

CalRecycle inspectors could conduct approximately 720 additional inspections per year, assuming no enforcement cases. The additional 130 inspections and additional enforcement work will be distributed among the other inspectors. This could be absorbed through time savings from a reduced number of grantees to train and support.

The changes to the grant program overall, as well as the loss of grantees is more cost effective. The TEA 23 grant cycle resulted in approximately a $1.45 million reduction in recommended funding (from $7 million in TEA 22). Furthermore, many of the jurisdictions that dropped out of the program are the ones that were the least effective and they dropped out because of the changes to the program. Grantees offer some specific efficiencies and benefits, 1) they are confined to a specific and smaller geographic area, reducing travel time, 2) they may inspect tire business for tire regulations and other regulations as well resulting in efficiencies, and 3) the grantee may inspect businesses, neighboring tire businesses, or nearby illegal tire activities, providing a greater level of presence in the jurisdiction and side surveillance benefits.

Because this cannot be provided as effectively (due to travel time and resources) by CalRecycle, the Department has balanced keeping as many grantees in the program while keeping it as cost effective as possible; and balancing the risks and benefits with appropriate level of resources allocated. CalRecycle prioritizes its inspectors' work to routine inspections, at the minimum inspection frequency, and enforcement over surveillance and conducting inspections at a more frequent rate. The latter of these are often conducted by grantees and can be beneficial in catching illegal haulers and illegal dumping.

Through prudent changes to the TEA program, the Tire Enforcement program reduced TEA grant requests by $1.4 million; the addition of the two new staff will cost $168,000. CalRecycle will shift $168,000 from Local Assistance to State Operations to offset the cost of these positions. It is not anticipated that after 15 years of growing and analyzing the efficiency of the program that the Department will see significant increase in TEAs joining the program. Staff have been informed by a few jurisdictions they are unlikely to apply next year (2017-18).

Currently, the Department does not conduct performance evaluations of TEAs nor have a corrective action process to reject jurisdictions who continue to fail to implement the program correctly. Based on 10 years of experience managing the TEAs, the Department has found that some TEAs may be meeting the basic terms of the grant but not performing inspections consistent with regulations and statutes even after general training. This level of review requires in-depth analysis of each TEA, not simply a review of grant reports and payment requests. Additionally, through the review of the TEAs inspection reports, CalRecycle found that several TEA programs struggle to maintain consistency with inspection guidelines and grant requirements, even after staff have provided additional guidance and training. Many of the grantees continue to have marginal performance, even after being in the program for years. A formal evaluation process is necessary so that deficiencies can be formally documented.

Analysis or KroDiem sent to decision-makers within the jurisdiction, and to provide evidence for the implementation of a needed corrective action process.

The Department has conducted performance evaluation of local solid waste enforcement agencies and has seen improvement due to the evaluation process. This process allows CalRecycle to identify deficiencies that the local agencies need to correct. In cases where the agency is unable to perform they can be removed from the program. CalRecycle intends to model the TEA evaluation program after this successful program.

This function cannot be absorbed by the CalRecycle Tire Inspectors without significantly reducing the number of inspections and other key policy and regulatory development that are an ongoing needs. Also, staff should be dedicated to the evaluation task, and independently appraise the performance, as well as the Department's guidance and training efforts.

Outcomes and Accountability

The TEA Evaluation Program would conduct evaluations of the TEA performance, and assess if the TEA is complying with the TEA grant agreement by carrying out its inspection and enforcement duties as delegated by CalRecycle, as well as serve as a tool for assessing the appropriateness of TEA grant agreement expenditures. The evaluation process will augment CalRecycle's efforts in overseeing the TEAs and the overall tire enforcement program to assure consistent implementation of the State mandates, as well as assure that the Department is funding high priority work.

CalRecycle will begin to conduct formal in-depth evaluations of the TEA/ grantee performance and assess if the TEA is in compliance with the Grant Agreement; specifically, carrying out its inspection, enforcement, education, and field patrolling duties, as delegated by CalRecycle, consistent with state requirements and the policies and procedures in the TEA 23 cycle (next cycle). The formal in-depth evaluation of the TEAs inspection, enforcement, education and field patrolling will be memorialized in a technical evaluation report. If the TEA is found not fulfilling its duties as required in the grant agreement, the TEA will be placed on an evaluation work plan until compliance is met. If the work plan is not complied with, the grantee will be ineligible for a specified number of future grant cycles.

These positions will allow the Department to; • Conduct 80 inspections per year that would have been performed by former grantees • Assure Department resources are spent prudently • Assure the programs set in place to protect public health and safety, and the environment are

being carried out as intended • Provide a method for CalRecycle to demonstrate TEA competency, and support a corrective action

process for grantees failing to improve performance, so they can conduct adequate assessments of public health and safety issues related to tire facilities

• Assure that the grantee has an opportunity to remedy their deficiencies so that the State does not lose resources it would otherwise gain by having grantees participate in the program

• Provide adequate inspection staff to conduct inspections of sites in non-grantee jurisdictions, and train grantees

• Maintain the same inspection frequency of waste tire facilities and prompt enforcement of facilities not complying with the law, including illegal waste tire sites, as well as illegal storage and hauling of waste tires

Analysis of Problem Projected Outcomes

Workload Measure CY 2016-17

BY 2017-18

BY + 1 2018-19

B Y + 2 2019-20

B Y + 3 2020-21

B Y + 4 2021-22

TEA Funding Cycle TEA 23 (2015-16 awards)

TEA 24 (2016-17 awards)

T E A 25 (2017-18 awards)

TEA 26 (2018-19 awards)

T E A 27 (2019-20 awards)

TEA 28 (2020-21 awards)

Total facilities regulated 30,500 30,500 31,000 31,000 31,000 31,500

Number of inspections by CalRecycle

2,800 3,250 3,650 3,650 3,650 3,650

Enforcement Actions 14 15 19 19 19 20

Number of Grantees 36 32 32 32 32 32

Grant Award 5,700,000 5,500,00 5,600,000 5,600,000 5,600,000 5,600,000

Grant Expenditure 5,000,00 5,000,000 5,300,000 5,300,000 5,400,000 5,400,000

Percentage of the award used

88% 90% 94% 94% 94% 94%

Number of inspections covered by Grantees

15,300 14,000 15,000 15,000 15,000 15,000

Percentage of total businesses inspected by TEAs per year

50% 50% 50% 50% 50% 50%

Grantee Performance Evaluations

6 12 18 30 30 30

F. Analysis of All Feasible Alternatives

Alternative 1: Implement the request

Pro: Fulfill request for two (2.0) full time, permanent Environmental Scientists and shift the expenditure authority of $168,000 from Local Assistance to State Operations in the Tire Recycling Management Fund, to evaluate Local Government Waste TEA Grantee performance on protecting public health and the environment.

Con: Increase the existing authorized staffing level and reduce Local Assistance authority in Tire . Recycling Management Fund to offset staffing cost.

Alternative 2: Funding provided for one (1) Environmental Scientist and $90,000 Tire Recycling Management Fund

Pro: One (1.0) Environmental Scientist will conduct TEA Evaluations and CalRecycle will reprioritize inspections to cover only the highest priority inspections in the 23 counties which are not covered by TEAS.

Con: The ability to continue the same level of oversight inspection currently conducted, potentially risking the stockpiling of tires, fires, and mosquito borne illness risks.

Alternative 3: No action

Pro: Current staffing and funding will remain the same.

Con: CalRecycle will not adequately perform a detailed analysis of work performed by the TEA, and inspection of tire facilities statewide will decrease by approximately 1,500 inspections per year, increasing with each future grant cycle.

Analysis OT KroDiem Implementation Plan

If approved, the proposal would be implemented with the TEA 24 funding cycle (2017-18) with the augmentation of the two (2.0) Environmental Scientists. These Environmental Scientists would address the inspection gap from the loss of the nine grantees, as well as develop and deploy the TEA Evaluation Program starting Fall 2017, including:

• Fall 2017: Hiring of the two Environmental Scientists

• Starting in Fall 2017: Conduct inspections to cover the inspection gap from the loss of TEA grantees (approximately 400 of the 850 inspections which need to be done per year statewide)

• Fall 2017: Develop TEA Evaluation program based on the LEA Evaluation program

• Winter 2017: Conduct evaluation of sample TEA grantees

• January 1, 2018: Start TEA Evaluation for TEAs in the TEA 23 Grant Cycle

Supplemental Information

Request for approval for eligibility criteria and evaluation process for the local government waste tire grant program (2015-16 and 2016-17).

Recommendation

Approve Alternative 1: Grant two (2.0) full time, permanent Environmental Scientists and shift the expenditure authority of $168,000 from Local Assistance to State Operations in the Tire Recycling Management Fund to evaluate Local Government Waste TEA Grantee performance, and to cover the loss of nine TEA grantees.

BCP Title: Tire Enforcement Agency

Budget Request Summary

Personal Services Positions - Permanent

Total Positions

Salaries and Wages Earnings - Permanent

Total Salaries and Wages

Total Staff Benefits Total Personal Services

Operating Expenses and Equipment 5301 - General Expense 5304 - Communications 5306 - Postage 5320 - Travel: In-State 5322 - Training 5324 - Facilities Operation 5344 - Consolidated Data Centers 5346 - Information Tectinology 5368 - Non-Capital Asset Purchases -

Equipment 54XX - Special Items of Expense

Total Operating Expenses and Equipment Fund Summary

Fund Source - State Operations California Tire Recycling Management

" ^ ^^ " Fund Total State Operations Expenditures Fund Source - Local Assistance

0226 California Tire Recycling Management Fund

Total Local Assistance Expenditures

BCP Fiscal Detail Sheet BR Name: 3970-011-BCP-2017-GB

FY17 CY BY BY+1 BY+2 BY+3 BY+4

0.0 2.0 2.0 2.0 2.0 2.0 0.0 2.0 2.0 2.0 2.0 2.0

0 89 89 89 89 89 $0 $89 $89 $89 $89 $89

0 42 42 42 42 42 $0 $131 $131 $131 $131 $131

0 2 2 2 2 2 0 1 1 1 1 1 0 1 1 1 1 1 0 4 4 4 4 4 0 1 1 1 1 1 0 15 15 15 15 15 0 6 6 6 6 6 0 3 3 3 3 3

0 4 0 0 0 0

0 -168 -164 -164 -164 -164 $0 $-131 $-131 $-131 $-131 $-131

0 168 164 164 164 164

$0 $168 $164 $164 $164 $164

0 -168 -164 -164 -164 -164

$0 $-168 $-164 $-164 $-164 $-164

Program Summary Program Funding

Total All Programs

BCP Title: Tire Enforcement Agency BR Name: 3970-011-BCP-2017-GB

Personal Services Details

Salary Information Positions Min Mid Max CY BY BY+1 BY+2 BY+3 BY+4

Environmental Scientist (Eff. 07-01-" ^^^ • 2017) 0.0 2.0 2.0 2.0 2.0 2.0

Total Positions 0.0 2.0 2.0 2.0 2.0 2.0

Salaries and Wages CY BY BY+1 BY+2 BY+3 BY+4 Environmental Scientist (Eff. 07-01-

" 2017) 0 89 89 89 89 89

Total Salaries and Wages $0 $89 $89 $89 $89 $89

Staff Benefits 5150350 - Health Insurance 0 20 20 20 20 20 5150600 - Retirement - General 0 22 22 22 22 22 Total Staff Benefits $0 $42 $42 $42 $42 $42

Total Personal Services $0 $131 $131 $131 $131 $131

POV Year FY17 Department 3970 House GB Working BR Name 3970-011-BCP-2017-GB Run Time 12/15/2016 10:28:01 AM Last Data Refresh 12/15/2016, 10:07 AM

CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY 2017-18 BUDGET YEAR

TIRE ENFORCEMENT AGENCY PROGRAM EVALUATION BCP WORKLOAD MATRIX

POSITION T I T L E : Environmental Scientist BCP # 3970-011-BCP-2017-GB

Position(s) and PY(s) Requested Workload Workload Standard Basis for Standard

1.0 Environmental Scientist

1 PY (1,780 hours/PY)

Overall Position Description: Conduct analysis and evaluation of Tire Enforcement Agencies.

Task #1 Conduct in-depth evaluations of TEA enforcement programs to assure they are effectively carrying out their responsibilities as outlined in the regulations and grant procedures which outline inspection enforcement protocol.

Total Hours: 780 Actual experience with similar program oversight and enforcement.

Task #2 Develop work plans and corrective actions for TEAs that are not adhering to regulation and grant agreements.

Task #3 Coordinate the evaluations with other CalRecycle programs, including as the Grant staff and Tire inspections staff.

Total Hours: 300

Total Hours: 400

Actual experience with similar program oversight and enforcement.

Task #4 Maintain informational database regarding evaluations and workplans including timeframes and deadlines. Actual experience with similar

program oversight and enforcement.

Task #5:

Gain and maintain familiarization with all elements of tire enforcement program and to assure LEAs are adequately carrying out their inspection and enforcement programs to safeguard the public health, safety, and the environment

Task #6: Review and assist in the development and implementation of the section and branch directives, goals and any related regulatory and training efforts. Coordinate program development with all Branches and Divisions in the Program. Routinely update appropriate SharePoint databases. Routinely prepare reports on program status for presentation to the management.

Total Hours: 200

Total Hours: 100

2

Actual experience with similar program oversight and enforcement.

Actual experience with similar program oversight and enforcement.

POSITION T I T L E : Environmental Scientist BCP # 3970-011-BCP-2017-GB

Position(s) and PY(s) Requested Workload Workload Standard Basis for Standard

1.0 Environmental Scientist

1 PY (1,780 hours/PY)

Overall Position Description: Conduct Inspections in non-TEA jurisdictions and prepare enforcement cases and documents for noncomplying businesses.

Task#l Conduct pre-inspection and permit research; collect, analyze, and evaluate site compliance with compliance with state standards through use of basic principles of scientific research, biological, environmental sciences, and investigative techniques.

Total Hours: 380 Actual experience with similar program oversight and enforcement.

Task #2 Conduct site visits to review facility environmental practices and verify compliance with waste and used tire transport and storage regulations.

Total Hours: 600 Actual experience with similar program oversight and enforeement.

Task #3

Perform statistical methods of analysis for counting whole tires and converting altered tires to passenger tire equivalents. Prepare inspection reports documenting environmental compliance analysis and summarize results of violations of the state minimum standards, local fire laws.

Total Hours: 400 Actual experience with similar program oversight and enforcement.

3

Task #4 Develop enforcement cases, including cleanup and abatement orders and statement of facts and associated exhibits to support administrative complaints. Assure sound conclusions ins the development of enforcement recommendations when developing reports, agenda items, and other documents for publication. Testify as an expert witness as needed.

Total Hours: 400 Actual experience with similar program oversight and enforcement.

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