The EPA has recently announced a national priority sites methodology for determining which licensed sites are an enforcement priority. This new reporting/enforcement tool is principally based on a site’s licence compliance and enforcement history.
Priority lists have been used by the Office of Environmental Enforcement (OEE) for a number of years now in order to focus resources on underperforming sites. However it is intended that this list will be published. It is important to note that this National Priority Site List is not intended to replace the Risk-Based Methodology for Enforcement (RBME), but instead work alongside it. The RBME focuses on fixed attributes such as location, proximity to receptors, class of activity, etc., whereas the Priority List methodology is based on the environmental issues and compliance record of a site.The priority list is effectively a scoring system for a licensee’s compliance over the previous year. The OEE will re-calculate this score every 3 months on a rolling basis. As such this means that the priority list is dynamic whereby licensees move up and down the list based on their score for the previous 12 months only.
The idea behind re-evaluating on a quarterly basis is to ensure that both improvements and deteriorations on sites are reflected on the list.There are four main “scoring” aspects to the methodology:
Incidents received by the Agency from the licensee;
Complaints received by the Agency; and,
Non-compliances issued by the Agency.