Auditing Environmental
Sustainability
ASSOCIATION OF LOCAL
GOVERNMENT AUDITORS
ANNUAL CONFERENCE
MAY 5, 2014 - TAMPA, FLORIDA
Kip Memmott, Director of Audit Services
Chris Wedor, Audit Supervisor
Katja Freeman, Lead Auditor
Emily Owens, Senior Auditor
City and County of Denver - Office of the Auditor
Session Overview & Objectives
2
 Environmental Performance Auditing:
 Opportunity
for increased impact and relevancy
 Risk and reward considerations
 Session Objectives:
 Key
planning concepts
 Scope and objective possibilities
 Technical competency limitations
 Tips for report writing
 Lessons learned
Session Overview & Objectives
3
 Three Case Studies:



Denver International Airport – Environmental Programs
Denver Public Works – Street Maintenance
Denver Public Library – Special Collections
 Q+A / Group Discussion:


Emerging area of competency
Your experiences
Denver International Airport:
Environmental Programs
Management
DIA’s Environmental Program
5
 Focus on:
 Sustainability
 Environmental
Stewardship
 Bedrocks of DIA’s environmental program:
 Compliance with environmental laws and
regulations
 Timely reactions to environmental emergencies
 High training standards
Auditing an Airport
6
 Rules and regulations that apply to airports:
 Federal:
Environmental Protection Agency (EPA)
 Federal Aviation Administration (FAA)


State:


Colorado Department of Public Health and Environment (CDPHE)
Local:

City and County of Denver
 Third-party audits
 Airport’s environmental division
 Airport’s goals and initiatives
Scope
7
 Scope included:

DIA’s programs and processes governing environmental
safety

Risk assessment of environmental risks

Review of:

Stormwater Program

De-icing fluid recovery

Air Program

Environmental Management System (EMS)

Strategic initiatives
Objectives
8
 Objectives of the audit:

Assess DIA’s environmental programs

Determine if DIA is in compliance with various federal,
state, and local government rules and regulations

Included a review of DIA’s:

Water quality

De-icing fluid reclamation

Air quality

Environmental Management System

Strategic initiatives
What We Found
9
 Full compliance with rules and
regulations
 Compliance substantiated by:

Verifying bi-annual external audits

Verifying ISO 14001 certification
 No fines for environmental
violations
 No material findings resulting
from external audits
Challenges & Lessons Learned
10
 Technical nature of topic:

Complex material and steep learning curve

Various knowledge background of team members

Significant Introduction and Background sections required
 Time investment:

Planning phase – learn and understand the regulations

Documentation, write-ups, and review of work

Work load and team size

Report writing
Street Sweeping as an
Environmental Compliance Tool
Sustainability
12
 EPA’s Definition of Sustainability:
 The
continued protection of human
health and the environment while
fostering economic prosperity and
societal wellbeing
Street Sweeping in Denver
13
 Collected 42,000+ cubic
yards of dirt and debris
(2012)
 $50 fine for not moving car
on sweeping days
 Compliance:
 Denver now in compliance with
air quality standards (PM10)
 Ozone compliance still a
problem
2013 Audit Plan
14
 Review of strategic planning and cost
containment practices for Street
Maintenance
 Analysis of geographical distribution and
equity of maintenance activities
Scope
15
 Scope:
 Review
of Annual Pavement Plan
(assurance)
 Scoped out Snow Removal Program – had
been audited two years ago
 Review of Public Works Department’s
street sweeping program
Objective
16
 Evaluate whether sweeping operations are
strategically related to compliance with air
and water quality regulations
 Reviewed:
 City’s
Street Sweeping Plan
 Signs prohibiting parking on street sweeping days
 Ticketing and towing practices
Methodology
17
 Analyzed environmental compliance
information (federal, state, and local level)
 Interviewed key Street Maintenance
personnel and industry experts
 Researched best practices
 Reviewed:
 Relevant
policies and procedures
 Related audits to identify potential risk areas
Air Pollution
18
 Reasons for street sweeping
 Maintaining
a clean and appealing business and
residential environment
 Protecting public health
 EPA
standards for six pollutants
 Reduce PM10 particulate matter
 Maintaining
 Daily
compliance
fines for non-compliance
 Linked to transportation funding
Air Pollution
19
 Street Sanding - Local Regulations:
 Sanding
materials must be picked up within four
days
 Standard for how much of a certain area needs to
be swept within timeframe
 Denver complies voluntarily with stricter
standards compared to surrounding areas
Air Pollution
20
Sand Reduction / Emission Reduction
80%
PerCent Change from 1989 Baseline
70%
60%
50%
40%
30%
20%
10%
0%
92- 93- 94- 95- 96- 97- 98- 99- 00- 01- 02- 03- 04- 05- 06- 07- 08- 09- 10- 1193 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12
Applied Sand Reduction
Percent Swept
Water Pollution
21
 Reasons for street sweeping:

Reduce stormwater pollution from reaching water bodies
 Forms of pollution:

Sediment

Petroleum products

Trash

Metals

Bacteria

Vegetation
Water Pollution
22
 Water Pollution Regulations/Requirements:
 Federal:
Clean Water Act
 National Pollutant Discharge Elimination System (NPDES)
stormwater permit


State:


Municipal Separate Storm Sewer System (MS4) permit
Local:

Denver’s Wastewater Management Division uses seven different
programs to reduce pollution in water run-off
 EPA considers street sweeping a best practice
Ticketing
23
 City claims environmental compliance is linked to
vehicle owners not parking their cars on the side of
the road on street sweeping day

Parked cars are an obstacle to street sweeper

Cars don’t get towed but ticketed

Unknown how much parked cars deter compliance with
environmental requirements

Inequity with regard to parking and ticketing practices in
Denver neighborhoods
What We Found
24
 Public Works does not know how their sweeping
activities keep them in compliance






Unknown if sweeping frequency is ideal
Unknown which areas of the city accumulate more/less debris
Unknown how ticketing practices help city to stay in
compliance with environmental regulations
Sweeping routes have been the same for 10 years even though
Denver’s neighborhood’s have changed and the population has
increased
Disconnected from compliance evaluation process (outside
entity monitors Street Maintenance’s compliance)
Different sweepers yield different results
Challenges & Opportunities
25
 Agency agreed with our recommendations
 Denver is growing; funding is not
 Technical nature of this audit
 Limited access to academic literature
 Limited best practice data from other
jurisdictions
 Buy-in from agency was low (expensive to
analyze “dirt hot-spots”)
Lessons Learned
26
 Local agencies tend to not question how to stay in
compliance with federal and state regulations

Lack of strategic and innovative planning to possibly do
compliance work more efficiently and effectively

That type of analysis is complicated and costly; agency
buy-in is low since they think it is not their job or they do
not have the staff to conduct this type of analysis

Little comparable research available from other
jurisdictions
Mechanical Sweeper 2013
27
Regenerative Air Sweeper 2013
28
Denver Public Library Audit:
Special Collections Environment
Audit Backdrop
30
 New audit client
 DPL funding
limitations

Challenging for finding
and recommendation
development
 Expertise and passion
of DPL staff
 Variety of audit topics
Special Collections
31
 Unique and often
irreplaceable materials





Art
Books / Magazines
Manuscripts
Maps
Photographs / Film
 Special environmental
requirements


Heat, humidity, light, etc.
Risk of damage or
deterioration
Examples of DPL Special
Collection Materials
Photos of 1964 Beatles concert at Red
Rocks Amphitheatre
First edition of the Book of Mormon
Early manuscript of Aldo Leopold’s
Sand County Almanac
Pikes Peak Gold Rush Diary of 1859
Early Colorado Territorial Letters
from mid-1800s
Manumission (emancipation) papers
from 1830s
Diary describing Colorado flu
epidemic of 1918
Public/Exhibit Areas
32
Public/Exhibit Areas
33
Storage Areas
34
Storage Areas
35
Planning Strategy
36
 Educate auditors
 What/Who/Why/How
 Learn landscape of DPL special
collections:
 Location
– building; storage vs. exhibit
 Types
 Previous
studies
 Assess time and resources
Planning Strategy (cont.)
37
 Leverage existing analyses
 Tap internal and external experts
 Known
areas of concern at DPL
 Common
methods
challenges and mitigation
Scope
38
 Assess environmental and security controls at:
 Central Library
 Blair Caldwell African-American Research Library
 Audit plan:
 Test:
Current environment and security conditions
 Stability of environmental conditions over time


Compare to:
Criteria (i.e., best practice)
 Survey data

Testing
39
 Overall

Guiding policies:
Environment settings
 Monitoring of environment
 Strategic plan

 Environment



Collect original temperature and relative humidity data*
Assess stability of environment
Assess building design risks
 Security



Observe locks, cameras, public access, etc.
Analyze frequency of security alarms
Assess building design risks
Findings – Environment
40
 No policy for control of special collections
environments
 Environmental conditions – both libraries
 9 of 10 areas above allowable temperature range
 6 of 10 areas above allowable relative humidity
levels
 Stability of environment – Blair-Caldwell only
 Over 4,000 alarms indicating deviations in
temperature over 3-month period
Findings – Environment/Building Design
41
Findings – Security
42
 No policy for control of special collections’
security
 Unlocked storage areas
 Special collections storage combined with
staff work areas
 Special collections in public area not
properly monitored
Findings – Security
43
Impact
44
 Implementation began two months after audit:
 One environment recommendation
 Two security recommendations
 Examples
Complete strategic plan for growth of special collections
 Two unsecured areas have been locked
 Re-organized Blair-Caldwell exhibit area to improve proctor
surveillance of the special collection materials

 Future implementation:
 Expect five more to be implemented by 5/31
 Most by 9/30
Challenges & Opportunities
45
 New audit client


Communicate
Cultivate collaborative relationship
 Funding limitations

Be realistic with recommendations to maximize timely
improvements
 Audit report content


Organize report with reader in mind
Sensitive information
Final Thoughts
46
 New Territory
 Environmental auditing can mean different things
 Impact of federal- and state-level regulations
 Audit Team Challenges
 Identifying and applying the right criteria
 Technical material requires time to gather and understand
 Report writing may require extra time
 Auditee Relations
 New type of engagement may require setting new expectations
 Recommendations could be costly to implement
Questions & Discussion
47
 More questions? Please
contact us:

Kip Memmott –
[email protected]

Chris Wedor –
[email protected]

Katja Freeman –
[email protected]

Emily Owens –
[email protected]