CEEC® continues to be the only cross-industry coalition
where company legal, environmental and government affairs professionals
can advocate, interact and benchmark environmental compliance
and enforcement issues and policies. CEEC members for 2011 include:
Abbott Laboratories
Alcoa Inc.
Bristol-Myers Squibb Company
Cabot Corporation
Constellation Energy
DuPont Company
Eli Lilly and Company
General Electric Company
Halliburton Company
Honeywell International
ITT Corporation
Johnson Controls, Inc.
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Koch Industries
LyondellBasell
Merck & Co., Inc.
Momentive Performance Materials
Northrop Grumman Corporation
Occidental International Corporation
Pfizer Inc
Procter and Gamble
Progress Rail Services Corp.
SABIC Innovative Plastics
Smithfield Foods, Inc.
Tyco International |
Founded in 1994, CEEC’s present activities center around
four key goals that continue to be the focus of the organization.
These four goals include:
- Addressing significant environmental compliance
and enforcement issues in the regulatory, legislative and
judicial contexts.
- Serving as a key information source
to CEEC members through quarterly meetings and conference calls
as well as providing up-to-date "alerts" on key federal, state
and international enforcement initiatives with a focus on their
practical impacts on industry.
- Maintaining an ongoing dialogue and input
with external stakeholders including the Administration,
Federal agencies, Congress, the States and other key stakeholders
on the challenges and opportunities for business related to
enforcement policies and activities.
- Providing a forum, from a cross-industry perspective,
to benchmark practices utilized by others in industry
to minimize potential environmental liabilities.
The following is an update on activities that have been conducted
during 2011 with regard to each of these goals.
I. Addressing significant environmental compliance
and enforcement issues in the regulatory, legislative and
judicial contexts.
• Environmental Justice – CEEC Outreach
with the Department of Justice and EPA – CEEC
maintained an ongoing dialogue with the Department of Justice
and EPA on Environmental Justice issues. CEEC participated in
EPA’s “Listening Sessions on EJ 2014” and CEEC
also filed comments on EPA’s “EJ Permitting Initiative.”
On March 15, CEEC met with fifteen top officials from DOJ and
EPA to discuss EJ initiatives (the list of EPA and DOJ attendees
is below).
EPA Office of Enforcement and Compliance Assurance
(OECA)
Cynthia Giles, Assistant Administrator for OECA
Adam Kushner, Director of Office of Civil Enforcement
Pam Mazakas, Deputy Director of Office of Civil Enforcement
Carol Holmes, Office of Civil Enforcement
Kyndall Barry, Special Assistant to the Assistant Administrator
for OECA
EPA Office of General Counsel
Scott Fulton, General Counsel
Carol Ann Siciliano, Associate General Counsel
DOJ Environment and Natural Resources Division
Ignacia Moreno, Assistant Attorney General
Patrice Simms, Deputy Assistant Attorney General
John Cruden, Deputy Assistant Attorney General
Natalia Sorgente, Chief of Staff
Jeff Prieto, Counsel to Assistant Attorney General
Paulo Palugod, Special Assistant to Assistant Attorney General
Peter McVeigh, Attorney Advisor, Law and Policy Section
Jim Payne, Senior Counsel, Law and Policy Section
• CEEC Comments on ECHO Database
– CEEC was directly solicited by EPA concerning how data
errors and corrections can be made to data in ECHO. CEEC canvased
the membership asking for feedback and input on EPA’s public
website dealing with compliance and enforcement information.
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II. Serving as a key information source to CEEC
members through meetings and up-to-date" alerts" on key federal,
state and international environmental compliance and enforcement
initiatives with a focus on their practical impacts on industry.
• CEEC held membership meetings in Washington, DC in March,
September and December as well as a membership meeting in Atlanta,
GA in June, hosted by Koch and Georgia-Pacific. These meetings
provide CEEC members with updates on key regulatory and legislative
developments in the environmental enforcement area, and similar
information on judicial or administrative proceedings impacting
environmental enforcement; interaction with key environmental
enforcement officials; benchmarking sessions and networking opportunities.
• During the year, Ken Meade, WilmerHale, provided the
CEEC membership with a comprehensive summary of enforcement developments
report following membership meetings.
• CEEC distributed written legal “alerts”
to members summarizing enforcement activities and judicial decisions,
including: key environmental cases before the Supreme Court, developments
at EPA, including civil and criminal enforcement activities; International
enforcement trends; SEC disclosure developments and related Climate
Change implications; as well as numerous issues of interest to
the membership. Each of these “alerts” was also made
available on CEEC’s “Members Only” website.
• CEEC updated and expanded the information available through
its website, www.ceecinc.org,
including a members only section were all membership meeting
information (including presentations and enforcement reports),
along with conference call, articles and other key issues and
information is included and updated.
• Developed “CEEC Bulletins” that provided
members with timely updates on key issues identified by the CEEC
membership.
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III. Maintaining an ongoing dialogue and input to
external stakeholders including the Administration, Federal
agencies, Congress, the States and other key stakeholders.
• Environmental compliance and enforcement officials and
other key stakeholders with whom CEEC met in 2011 included:
o Dr. Tom Lovejoy, The Heinz Foundation
o Donald Boesch, Member, National Commission on the BP Deepwater
Horizon Oil Spill
o Stan Meiburg, Deputy Regional Administrator, EPA Region 4
o Carol Ann Siciliano, Associate General Counsel, EPA
o Lisa Lund, Director, OECA Office of Compliance, EPA
o Pam Mazakas, Deputy Director, OECA Office of Civil Enforcement,
EPA
o Susan O’Keefe, OECA, Head of EPA Audit Policy Team,
EPA
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IV. Providing a forum, from a cross-industry perspective,
to benchmark practices utilized by others in industry to
minimize potential environmental liabilities.
• Addressing the practical needs of its members, CEEC provided
a forum, through meetings, conference calls or member-to-member
communications to benchmark practices utilized by others in industry
to address and/or minimize potential environmental liabilities.
Topics in 2011 included:
o Company EHS Legal Training – An Overview of GE’s
Operating Managers Training Program
o Koch Industries: Capability Integration to Achieve Compliance
Excellence
o How Companies Manage their Community Advisory Panels
o Title V Compliance Assurance Company Programs
o Member Company Management of E,H &S Legal Issues
o Superfund Liability Risk Transfer
o HAZMAT Management Structures within Company’s: Experiences
Interacting with Customs & Trade as well as Import/Export
Disciplines
o Internal Process/Procedures on Investigating Workplace Fatalities
– How and when is the ESH Team brought in?
• CEEC distributed ten member requests to the CEEC list
serve seeking input, guidance and recommendations from members
on a variety of environmental issues, including among others:
Brownfield redevelopment of an industrial site, employee transportation
of samples of chemical products from labs, R&D locations or
other company properties in personal vehicles, best practices
for PRP Group Trust Account management, hiring of outside lawyers
to conduct HS&E compliance audits of their facilities, member
company policies on distracted driving and how our sites handle
extra sampling for their NPDES permits.
In addition, the CEEC Executive Committee recognized the need
for assessing CEEC’s value to the member companies. Therefore
a survey tool with nine questions was created to solicit comment
and input on CEEC’s activities, interviews were conducted
with a majority of the CEEC membership and a final report was
shared with the member companies as a foundation for the development
of CEEC’s strategic plan for 2012.
Highlights of the report included:
• Positive comments on the unique value that CEEC provides
• Identification of ways that CEEC can add value
• Identifying key issues that present increased challenges
and opportunities
• A clear statement that CEEC should begin addressing Health
and Safety issues in addition to environmental issues
• A broad identification of federal agencies activities
that are addressed by members
• Identification of potential members that could add value
to the present CEEC membership
• Confirming that the present meeting structure of quarterly
meetings with one meeting outside Washington, DC efficiently meets
the needs of the members
