What is a SCEPP?

A Small Community Environmental Protection Plan (SCEPP) is a "less robust" Environmental Management System (EMS) that was developed by the Arizona Department of Environmental Quality (ADEQ) for small communities who elect to participate. View A Guide for Developing and Implementing a Small Community Environmental Protection Plan (SCEPP)

• The ADEQ Small Community Policy acknowledges the resource constraints facing many small communities, including the necessary resources for assuring environmental compliance. The guidance and self-assessment questionnaires and the template are tools designed to promote the development and implementation of a meaningful and effective SCEPP.
• A SCEPP has the same structure, terminology and process steps as an ISO 14001-based EMS, with emphasis being placed on complying with environmental regulations. However, it is flexible enough to address environmental issues not covered by regulations (e.g. energy and water conservation).
• An effective SCEPP will help your Small Community meet environmental commitments and allow your community to avoid the reactive approach to regulatory compliance.

What is involved?

Review the Appendix B Template Small Community Environmental Protection Plan Instructions, Examples, & Forms for making, identifying or measuring the following:

• Commitment - Making a good faith commitment and defining an environmental policy that guides the Small Communities' approach and commitment to environmental management. Sections 1 and 2;
• Impact - Understanding applicable environmental regulations and evaluating the operations and activities under the control of the Small Communities to determine how they impact the environment. Sections 3, 4, and 5;
• Risks - Evaluating the extent of risks posed by identified environmental issues. Section 4;
• Procedures - Establishing and maintaining specific procedures to ensure that work activities minimize or eliminate a negative impact to the environment. Sections 6, 7, 10, 11 and 12;
• Responsibilities - Communicating responsibilities and work instructions throughout the organization and training employees to effectively carry out their obligations. Sections 8, and 9;
• Performance - Monitoring and measuring performance against established standards and indicators. Sections 13, 14, and 15;
• Communication - Communicating with people inside and outside the organization about the organization's progress. Section 16;
• Continual Improvement - Continue to revise and improve the system based on the monitoring results. The fundamental basis of the Plan-Do-Check-Act model.

When is my plan ready for review?

Participating communities must provide a first copy of their completed SCEPP to ADEQ within one year of enrolling in the program. ADEQ will review the plan to ensure that the key elements are present and may offer additional suggestions for improvement. The SCEPP is a "living document" and should be routinely revised and improved by the participating community. However, changes and revisions do NOT have to be submitted to ADEQ for approval.

We already have a compliance program why do we need this?

An SCEPP can help you to comply with regulations more consistently and effectively. It also can help you identify and capitalize on environmental opportunities that go beyond compliance. Also, these materials may be used by municipal managers to train staff on environmental requirements, or as a marketing tool for attracting investment in their communities or prospective employees.

Integrating and implementing a SCEPP based upon strategic planning and continual improvement can increase customer's understanding, support, and confidence that your organization can provide economical and high quality services.

How big does an organization need to be to participate?

SCEPPs are applicable to organizations ranging in size from a couple of dozen employees to many thousands of employees. The elements (as described in the guidance documents) are flexible by design to accommodate a wide range of organizational types and sizes.

Will the plan help to prevent pollution and minimize waste?

A commitment to pollution prevention and waste minimization are cornerstones of an effective SCEPP and this commitment should be reflected in an organization's policy, objectives and plan elements.

How will the plan affect my existing compliance obligations?

A SCEPP will not result in more or less stringent legal compliance obligations but it should improve your efforts to comply with legal obligations, and, in some cases, may lead to more flexible compliance requirements (self-reporting violations).

Do we need to be in 100% compliance to participate?

No. The concept of continual improvement assumes that no organization is perfect. While a SCEPP should help your organization improve compliance and other measures of performance, this does not mean that problems will never occur. However, an effective plan should help you "find and fix" these problems and prevent them from recurring.

What is ISO 14001?

ISO 14001 is an internationally recognized standard for the environment. It provides a systematic approach patterned after a model of plan, do, check and act. It is one of a series of Environmental Standards developed by the International Organization for Standardization . The standard includes all of the elements needed to develop an environmental management system (EMS) in an organization. The SCEPP requirements, being a "less robust" EMS, are consistent with the ISO 14001 standard.

What are the benefits?

A SCEPP provides tools to help manage your organization's environmental impacts efficiently and effectively and to improve the impact of an organization's environmental "footprint." Public organizations who have implemented a a similiar management system have realized the following benefits:

• Cost savings;
• Reduced risk to the environment and employee;
• Increased operational efficiency;
• Positive external relations and public image;
• Improved communication;
• Improved public relations.

How will the plan benefit Small Communities or Special Districts?

Acceptance into this program may qualify a Small Community or Special District for up to a 100% penalty reduction from ADEQ for future violations.

What are the hurdles?

It is important to realize that developing and implementing a SCEPP requires an investment of time and effort. Along the way there can be challenges such as:

• Difficulty managing organizational change;
• Maintaining top management visibility and involvement;
• Inviting public awareness and understanding;
• Maintaining momentum (especially at the frontline), and;
• Political uncertainties.

Is the plan compatible with other management systems?

Yes. Whether you have a quality management system, asset management system, or participate in the National Biosolids Partnership a SCEPP is compatible and can be integrated with any systems-type approach. For example, procedural methods for handling operational and environmental records and providing training are universal and should integrate well. Furthermore, the process of identifying environmental and operational priorities, setting targets and checking progress on those targets will be very similar in any management system's approach.

Where in my operations would a SCEPP be appropriate?

It can be applied in one or more departments or operations across an organization. You should examine the organization's activities and services and determine where it would best serve needs and organizational goals. The department(s) or facility(ies) incorporated are considered to be within the "fenceline" of the SCEPP.

Do we have to start from scratch?

Much of what you have in place now for environmental management probably can be incorporated into a SCEPP. There is no need to "start over" and re-invent the wheel for environmental and other organizational programs that are in place. A review or gap analysis is a great way to determine what parts of the plan may already exist.

What is the purpose of a Gap Analysis?

A Gap Analysis allows an organization to compare the requirements of a SCEPP against an organization's existing management and environmental programs. This analysis allows the organization to determine what modifications, if any, are needed to bring a current process up to the standard established in the plan guidance. The gap analysis can also be used to determine program priorities and for planning the path ahead for implementation.

How much will this cost?

Implemention costs will vary depending on the Scope of Operations covered by the SCEPP (i.e. the "fenceline"). However, using existing policies, procedures, work instructions, etc., could reduce the overall cost.

Can I implement the plan without consultants?

Yes, although your current consultants can be a valuable resource for reviewing environmental compliance and assisting with other SCEPP tasks, we recommend you use them only as needed. Remember, this is your SCEPP. Take ownership by involving your own management and staff in implementation activities.

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