9. New Case Conclusion Data Sheet (CCDS) Guidance – Calculation and Categorization of Environmental Benefits
Purpose: The Office of Compliance finalized the new Case Conclusion Data Sheet (CCDS) guidance (based on the work of the Environmental Outcome Reporting Management Committee). This new guidance describes a new approach to categorizing environmental benefits from EPA’s enforcement cases and provides direction on how to calculate benefits under the new system. Please use this guidance for identifying methodologies and categorizing results from all EPA enforcement cases that conclude in FY 2012 and forward.
The final FY2012 Case Conclusion Data Sheet Guidance (CCDS), released on January 23, 2012, provides a new framework for characterizing environmental benefits from federal concluded enforcement cases. A new “nature of the remedy” approach redefines the way environmental benefits are counted so that it is the complying action remedy that determines how environmental benefits are calculated and reported. The new approach allows benefits from some complying actions to be counted for the first time and considers multi-media environmental benefits for a given case where appropriate. Together, these changes allow enforcement staff to provide a more complete accounting of the benefits accrued from their enforcement actions, and allows OECA to portray a more robust picture of environmental benefits to the public
Enforcement staff are expected to use the new guidance for reporting the results of all federal enforcement cases that are concluded in FY2012. In some instances, where new and/or revised calculation methodologies have been developed, prior environmental benefits calculations completed for any FY2012 case using the old guidance will need to be recalculated to ensure FY2012 reporting consistency. The intranet link to the CCDS guidance and calculator tools is: http://intranet.epa.gov/oeca/oc/pmod/.
OC staff will begin reviewing FY2012 environmental benefits data that has been entered in ICIS, to date, the first week of March and will contact the appropriate staff to request calculations for cases with reductions at or above 5 million units (e.g., pounds, gallons, cubic yards) and air toxics cases that produce 200,000 lbs. or more in air toxics emissions reductions.
A special email box has been established as the mechanism OC will use to track FY2012 environmental benefits calculations and provide feedback on the information provided. Please send environmental benefits calculations via Lotus Notes to the following email address: CCDS EB Reporting@epa.gov . If you have questions about the revised FY2012 CCDS guidance or calculation tools, please contact Donna Inman, 202-564-2511, firstname.lastname@example.org.
Data Entry: Environmental benefit data for FY 2012 is entered to the new Complying Action/Injunctive Relief screen in the Enforcement Actions module in ICIS.
Data Retrieval: Environmental benefit data is retrieved from ICIS using the “Direct and Preventative Environmental Benefits report posted in the Public Folders/Federal Enforcement/Environmental Benefits QA Reports folder.