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6. Management Responsibilities |
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6.1 Management Commitment
· The EEP Director has dedicated resources to the development of this Policy, Process, and Procedure Manual (PPPM). The guiding principle is to develop and maintain a well managed, documented, and transparent system that will improve effectiveness and ensure continuing program success. As a result, this PPPM is structured around the quality management principles of ISO 9004-2000.
The Director, along with all Management staff, will communicate to staff the importance of meeting customer and regulatory requirements, establish a quality policy, establish quality objectives, conduct management reviews of this system, and provide all necessary resources for any PPPM system requirements.
The Analysis and Procedure Manager has primary responsibility for ensuring that annual system review and reporting occurs.
The Director and Managers will conduct an annual system review and report the review findings to the DENR Quality Director and EEP staff. The review will include a check to ensure that the sequence and interaction of processes and procedures are designed to achieve the desired results based on customer requirements; ensure that process inputs, activities, and outputs are clearly defined and controlled; monitor inputs and outputs to verify that individual processes and procedures are linked and operating effectively and efficiently; identify and manage risks and opportunities and provide performance improvement opportunities; conduct data analysis to facilitate continual improvement; identify process owners and give them full responsibility and authority; manage processes to achieve objectives; and satisfy the needs and expectations of interested parties.
Managers will review processes and procedures to ensure that customer requirements and client expectations are met. Managers are responsible for implementing policies, processes, and procedures; for ensuring continual improvement of policies, processes, and procedures; and for providing and communicating performance metrics to staff.
6.2 Customer Focus
6.2.1 Identification of Customers and Other Interested Parties
· EEP serves, directly or indirectly, the citizens of the State of North Carolina. EEP provides advance, programmatic mitigation and ecosystem enhancement services to NCDOT through the execution of a tri-party Memorandum of Agreement (MOA) among NCDOT, DENR, and USACE (Wilmington District). This agreement specifies program mitigation requirements in terms of regulation compliance and timing to offset unavoidable and unminimizable impacts to the environment as a result of planned and programmed transportation improvements. There is a second, two-party, MOA between NCDOT and DENR that further defines the fiscal and reporting systems between the two state agencies. EEP provides services to the general public through an in-lieu-fee program that is legislated under the Wetlands Restoration Program. The in-lieu-fee program is made available to all citizens and developers as part of an agreement between DENR and USACE. EEP provides numerous services to other entities through collaboration and contracting. A partial listing of these customers and suppliers includes engineering and biological firms, contractors, full delivery providers, land trusts, mitigation bankers, landowners, communities seeking restoration and partnering agreements, developers, and constructors, and includes institutions such as the North Carolinians for Commerce, Business and Industry; the Carolinas Associated General Contractors; the North Carolina American Council of Engineering Companies; the North Carolina Environmental Restoration Association; the U.S. Environmental Protection Agency (EPA); the Southern Environmental Law Center; and the Environmental Defense Fund, to mention a few.
The EEP Director, Operations Director, Managers, and staff will maintain close contact with customers to ensure that requirements are met or exceeded and that customer service is enhanced through effective and efficient operations provided through professionalism and dedication to service.
6.2.2 Analysis of Needs and Expectations
· The state and people of North Carolina are committed to balancing development and environmental protection. A state of vast natural resources and a growing economy, North Carolina’s quality of life has spurred growth, bringing the need for appropriate transportation infrastructure and overall economic development to accommodate a burgeoning population.
During the mid-1990s, NCDOT began to experience increased project delays in its transportation infrastructure program because of unavoidable environmental impacts in its transportation infrastructure development. At the time, NCDOT tried to satisfy most of its mitigation needs through internal staffing and outsourcing to the private sector. In 1997, the state founded under DENR a wetlands-oriented mitigation program for development. NCDOT and DENR mitigation programs functioned independently and with different operating processes, a situation that failed to meet the satisfaction of either federal and state regulatory agencies or environmental interest groups. Obstacles identified included inadequate communication, undefined roles and responsibilities, poor synchronization in executing existing mitigation and permitting processes, and a lack of clearly understood mitigation success objectives.
The State of North Carolina created EEP with the expectation that responsible economic growth could occur while providing high-quality ecosystem enhancement to offset impacts from development.
6.2.3 Statutory and Regulatory Requirements
· Refer to Normative References contained in Section 2.0 for detailed descriptions of requirements. The primary function of EEP is to provide compensatory mitigation for permits authorized under Section 404 of the Clean Water Act, 33 USCA § 1344, and Section 10 of the Rivers and Harbors Act, 33 USCA § 403. Relative to mitigation, other guidance is provided through
· An MOA between EPA and the Department of the Army concerning the Determination of Mitigation Under the Clean Water Act Section 404(b)(1) Guidelines (1990)
· Federal Guidance on the Establishment, Use, and Operation of Mitigation Banks (November 28, 1995)
· Federal Guidance on the Use of In-Lieu-Fee Arrangements for Compensatory Mitigation under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act (October 2000)
· Regulatory Guidance Letter, Subject: Guidance on Compensatory Mitigation Projects for Aquatic Resource Impacts Under the Corps Regulatory Program Pursuant to §404 of the Clean Water Act and §10 of the Rivers and Harbors Act of 1899 (December 26, 2002).
· NC General Statutes establishing the Wetlands Restoration Program, NC General Statutes 143-214.8 through 143-214.13 and NC Administrative Code 15A NCAC 02R.
EEP also operates under policies and procedures of DENR to include procurement services under the Division of Purchase and Services (DP&S) and other DENR standard operating protocols. EEP uses services of other North Carolina Departments, including the State Property Office (SPO) for land acquisition and conservation services and the State Building Commission (SBC) for construction and professional service contracting.
6.3 Quality Policy
· EEP will ensure organizational excellence by continually improving the effectiveness, efficiency, and quality of operations consistent with customer requirements, stakeholder expectations, and the overall mission of the organization. The EEP Quality Policy is consistent with the DENR Organizational Excellence and Quality Policy.
· EEP shall
· Understand and focus on customer requirements
· Provide and sustain a leadership system in support of high performance, individual development, initiative, organizational learning, and promotion of partnerships
· Provide resources to, and authorize and empower supervisors and staff for process implementation
· Be committed to continual review and improvement of policies, processes, and procedures in support of efficient and effective operations
· Use a factual knowledge management approach to decision making
· Ensure a beneficial relationship with customers, suppliers, stakeholders, the regulatory community, and staff.
6.4 Management System Planning
6.4.1 Strategic Goals and Objectives
· The EEP Director disseminates quality objectives applicable to the PPPM and to EEP’s mission. The EEP Director assigns responsibility to his or her direct reports for the monitoring, measurement, and analysis of the quality objectives. The EEP quality objectives are presented in section 5.3.
6.4.2 Management Planning
· The Director, his or her direct reports, and the PPPM Manager plan and periodically review the EEP quality management system to ensure that the requirements and quality objectives identified in Section 5 of the standard are met and that the integrity of the PPPM is maintained when changes to it result from the continual improvement process.
6.5 Responsibility, Authority, and Communication
6.5.1 Management Responsibility and Authority
· The EEP Director is given the authority by DENR to manage all aspects of EEP operations within the WRP statute and the MOAs. The Director is responsible for ensuring that the Quality Policy and the PPPM are understood and implemented at all levels of the organization that fall within the scope of the PPPM. All EEP managers and supervisors are responsible for ensuring that their employees operate in compliance with the PPPM and make appropriate notification of processes that do not produce the required quality.
6.5.2 PPPM Manager
· The EEP Director appoints a PPPM Manager who is responsible for
· Ensuring that processes needed for the quality management system are established, implemented, and maintained
· Conducting internal quality audits of the PPPM
· Reporting to the EEEP Director and his or her direct reports on the performance of the quality system and on any need for improvement
· Ensuring the promotion of awareness of customer requirements throughout EEP.
6.5.3 Internal Communication
· Internal Communication in EEP takes on a variety of forms, all with the goal of disseminating information about the quality activities within EEP. These include
o Weekly meeting between the Program Director(s) and their direct reports
o Internal Quality Audit reports
o Report of the Management Reviews
o Report of the state of the PPPM
6.5.3.1 ADM.POL.02.01.01, Communications Policy [reserved]
6.5.3.2 ADM.PMP.02.02.01, General correspondence
6.5.3.3 ADM.PMP.02.02.02, Special correspondence
6.6 Management Review Process
6.6.1 General
· EEP management conducts a review of the PPPM at least twice a year to ensure its continuing suitability, adequacy, and effectiveness. The Quality Manager Review (QMR) follows an agenda that includes assessing opportunities for improvement and the need for changes to the PPPM, including the quality policy and quality objectives. Results of the review are documented in a report that is maintained as a quality record.
6.6.2 Review Inputs
· The Analysis and Procedures Manager is responsible for gathering inputs and generating the agenda for the QMR. Inputs to the review include results of audits (both internal and external); customer feedback; process performance and product conformity; status of preventive and corrective actions; follow up actions from previous management reviews; changes that could affect the PPPM; and recommendations for improvement.
6.6.3 Review Outputs
· The Analysis and Procedures Manager is responsible for keeping the minutes of the quality management review and for publishing the associated report. Results or outputs of the review will include, at a minimum, any decisions and actions related to improvement of product related to customer requirements; improvement of the effectiveness of the PPPM and its processes; and resource needs.
6.7 Training Identification
6.7.1 General
· Document 6.7.1 lists EEP procedures by title, document number, and PPPM section. This list identifies parties who have a role and responsibility in the procedure. This list is a reference for training identification.
6.7.1 ADM.PRO.06.07.01, Training Identification