MEMORANDUM

TO: Director-elect Trey Glenn, Alabama Department of Environmental Management

FROM: The Alabama Department of Environmental Management Reform Coalition (ARC)

DATE: January 2005

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The ADEM Reform Coalition would like to take this opportunity to welcome you as you prepare to assume the post of Director of the Alabama Department of Environmental Management. We appreciate your willingness to serve the citizens of Alabama in this capacity and look forward to developing a partnership with you in this endeavor. While you have a 2003 copy of the ARC’s "Blue Print for ADEM Reform" outlining in depth our goals for reform at ADEM, the following is a list of issues that are of great concern to our coalition and to the members we represent statewide. We encourage you to endeavor to implement these ideas during your first six months in office. We look forward to communicating with you and working with you to serve the people and environment of Alabama.

I.  Enforcement

-Review and revise ADEM's enforcement and penalty policies and practices to improve effectiveness.  Consider/implement recommendations of the AEMC's Enforcement and Administrative Penalties Stakeholder Committee (recommendations are expected to be submitted to AEMC at the February 11, 2005 meeting), AEMC, ARC ("Blue Print for ADEM Reform") and ARC members. 

-Review each division’s significant non-compliant permit holders and habitual permit violators to develop a priority list and timetable to bring chronic polluters into compliance.

-Increase collaboration with EPA to maintain current Alabama records in EPA’s Environmental Compliance History Online (ECHO) database.

-Initiate development of a publicly accessible database that will allow citizens to know what permit holders are exceeding pollution permit regulations in their communities.

-Review effectiveness of field enforcement programs and develop plan to improve effectiveness.

II.  Organizational Assessment and Change

-Begin to institute a change in the culture of ADEM towards a public service mindset and willingness to seek new solutions, partnerships and ideas.  Infusing the concept into the agency that ADEM’s clients are the citizens of Alabama not only the regulated community.

-Undertake an organizational assessment to improve efficiency and effectiveness and to implement cultural change at ADEM, as reflected in performance expectations of staff.

III.  Public Access

-Increase accessibility of the department to environmental and citizen stakeholders. As part of this, conduct a monthly meeting with the environmental community.

-Decentralize agency workforce by getting employees outside of Montgomery and into the field

-Ensure that no one special interest group has greater access than any other

-Bring ADEM into the public via town hall meetings

-Improve public access to documents; especially file review and copying response time

IV.  Environmental Justice

-Create a Division of Environmental Justice and Health at ADEM

-Appoint someone who is qualified and has the confidence of Alabama’s Environmental Justice community to the Environmental Ombudsman position

-Work cooperatively with the ARC and environmental justice community to develop EJ legislation that will protect citizen health and the environment.

-Develop a plan to increase diversity within the agency

V.  Fiscal Health

-Develop a plan to increase funding through diverse sources

-Conduct a thorough annual financial audit of ADEM, implementing greater transparency

-Actively lobby for legislation that would benefit the department and its programs (e.g., Tipping Fee bill)