OEC Environmental Compliance Functions

Environmental Compliance refers to the responsibilities that any private or public entity has to comply with established federal, state and local environmental laws and regulations. Those responsibilities affect specific aspects of operation in both the public and private sectors. Carroll County's environmental legal and regulatory compliance responsibility effects and influences many aspects of County government operations. Compliance responsibilities affect the way services are provided, the length of time needed to perform those services as well as the direct cost of those services. Environmental regulatory compliance is a legal responsibility that carries legal implications if not carried out. Compliance with environmental law and regulation manages potential environmental impacts, minimizes the County's potential liability, as it relates to not complying with the law.

As the County government is both a regulator and part of the regulated community, its compliance with federal, state, and its own environmental laws helps to set an example in the regulated community. Compliance with environmental rules not only helps to minimize and control potential legal liability the County may have, but also raises the perception of the County Government as an entity within the Community.

Carroll County Government is responsible for the effective management of its responsibilities under each element of each applicable law. Those laws are not only focused on specific functions and activities but on overall management philosophy. Agencies such as Public Works, General Services and Planning as well as functions such as infrastructure construction and management, facility construction and maintenance, road construction and maintenance, fleet management and land management are subject to a variety of resource specific laws. The laws are intended to manage and protect environmental resources, but also have the potential to affect each and all of the County's individual Departments and programs. Although the agency that holds the permit is ultimately responsible for its management and as such, the County's compliance with that permit, the Office of Environmental Compliance (OEC) provides assistance to other agencies in matters of permit compliance. ECO staff work with issues involving compliance with the County's environmental code, as well as with Maryland state and federal regulatory requirements. Carroll County's goal is compliance with all levels of environmental requirement. To help achieve that goal the OEC is available to assist any County agency in matters of environmental management and environmental regulatory compliance.

INTERNAL COMPLIANCE RESPONSIBILITIES

The County's compliance with environmental law and regulation involves the assessment and monitoring of County programs and activities to determine compliance responsibility under those laws. Those responsibilities may take one of three forms:

  1. Conditions required under long-term permits that are issued to allow the County to implement a regular activity necessary to perform some institutional service, i.e. wastewater discharge or water appropriation permits;
  2. Activities that require short-term permits for temporary activities that will have temporary impacts That must be controlled, i.e. wetland permits, etc.; and
  3. Compliance with general requirements of environmental law and regulation, i.e. making sure that permits are secured and that no activity occurs that would conflict with the law.

Compliance activities are also broken down by impacted resource or media. The first task in determining the appropriate assistance approach is to determine what that is. Compliance responsibilities are not exclusive to anyone Department, but rather are related to function. The primary categories that those activities fall in to are as follows:

  1. Those activities that involve either the use of water or anything that may impact either the quality or quantity of water as a resource including the use and disturbance of the land;
  2. Activities that involve potential impacts to air quality as well as the quality of the atmosphere as it relates to the community and within public structures; and
  3. Lastly those activities that generate any type of waste and as such result in the need to manage it.

Generally, OEC compliance assistance categories include the following:

  • Assistance to any County agency in achieving or maintaining compliance and permit management,
  • Assistance to any County agency with resource management investigations or management decisions,
  • Assistance to the Towns regarding environmental compliance and specifically, in support of their MS4 NPDES responsibilities, and for public support regarding regulatory and compliance efforts, and
  • The maintenance and management of specified omnibus permit programs, including the municipal storm sewer (MS4) NPDES permit and a number of other related facility and function specific permits and to ensure the County's compliance with applicable state and federal environmental law and regulation.

More specifically, the OEC's may also provide specific tasks that are defined by the need to maintain compliance with the identified laws and regulation or are designed to minimize the County's liability to those laws. Examples of such tasks may include the following:

  1. Environmental site assessments;
  2. Compliance audits of County facilities and programs;
  3. Assistance to agencies with permit management planning and implementation efforts;
  4. Pollution prevention planning and implementation;
  5. Participation in infrastructure planning (including water and sewer) efforts;
  6. Assistance with facility and program monitoring;
  7. Contaminated site assessment, remediation planning, implementation and ongoing management;
  8. Compliance program development and management, including Environmental Management System implementation;
  9. Assistance to County agencies regarding the compliance aspects of County projects and the specification and design of required environmental control elements;
  10. Technical Support for permit application and renewal;
  11. Technical support to litigation defense to County Attorney's Office on environmental technical and compliance topics;
  12. Coordination with State and Federal agencies regarding contaminated sites;
  13. Participation in the Carroll County Local Emergency pranning Committee (LEPC);
  14. Development, coordination, and implementation of seminars and workshops on environmental regulatory compliance topics for government personnel, local business, and the general public;
  15. Environmental Regulatory Compliance assistance to County businesses on an as- needed basis.