Office for Capital Facilities (OCF)
Presentation to SUBOA
June 4, 2012
 Environmental Audit – Barbara Boyle and Marti
Ellermann
 Residence Hall Capital Plans
 Off Balance Residence Halls
 UPD accreditation goals
 Governor’s Initiative for Energy Savings
Environmental Auditing
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
 Regulated Medical Waste
 Safe Drinking Water Act
 Stormwater Permitting
(SWPPP)
 Toxic Substances (TSCA-LeadBased 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 changes
– Processes change
– Facilities change
• More importantly – sound risk management!
Where have we been?
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? (cont.)
 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
Basic SUNY/EPA agreement
 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.
Results
 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.
Where are we now?
 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 should we position ourselves?
 Several options considered.
 No audit mandate or intervention
 Peer audit (Western NYS model)
 Peer audit (Georgia model)
 Central Auditor/EMS (CUNY model)
 Traditional Third Party
Option 1:
No audit mandate or intervention
Strengths
Challenges
Short term cost avoidance
Actual liability
Threat of compliance
enforcement
Perceived “bad player”
Option 2:
Peer Audit (Western NY model)
expand pilot program and make mandatory
Strengths
Challenges
Low cost
Auditor experience
Campus staff development
BMP sharing opportunities
Lack of specialty and/or
bench strength
Supports shared services
concept
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
Challenges
Perceived lower cost
Specialty consultants readily
available
Campus staff development
Shared services/BMP
Migrated significantly towards
traditional third-party audit
Required one FTE at central
office
Weakness in auditor
responsiveness
Cost 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
Challenges
Customized
Additional FTE
solution/fluidity
CUNY central @ 0.7 FTE
More permanent solution
for 24 campuses on 3 yr
cycle
Specialty support available
Shared services/BMP
Some diminution of
campus autonomy
Option 5:
Traditional Third Party
Strengths
Challenges
Professional
Limited staff development
Objective
Arguably more expensive
Specialty/bench strength
Suggested Program
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 levels
Improved risk management
Better environmental stewardship
Environment Audit Questions and
Discussion
Residence Hall Capital Plans
 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
Off Balance Housing
 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
UPD accreditation
 Agencies Accredited (and date of accreditation):
SUNY Albany University PD – June 2011
SUNY Buffalo University PD – December 2007 (up for reaccreditation this year)
SUNY Cortland University PD – March 2011
SUNY Stony Brook University PD – December 2010
 Recently Completed Assessments to be awarded in June
SUNY Alfred University PD
SUNY Buffalo State College PD
SUNY Oneonta University PD
 7 campuses Accredited (or have successfully completed
assessment) = 25%
UPD Accreditation (cont.)
 Applications Received (12):
SUNY Canton University PD
SUNY Old Westbury University PD
SUNY Oswego University PD
SUNY Binghamton University PD
SUNY Cobleskill University PD
SUNY ESF University PD
SUNY Farmingdale University PD
SUNY IT University PD
SUNY Morrisville University PD
SUNY New Paltz University PD
SUNY Plattsburgh University PD
SUNY Purchase University PD
 19 campuses engaged in the Accreditation process = 68%
 Numerous UPD officers trained to be part of accreditation
teams
Governor’s Energy Efficiency Initiative
 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