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The chart below shows the complexities to consider when selecting indicators:

Complexity of Indicators

Single Media

Multi Media

Regulatory or Good

Both Regulatory

Practices Only

and Good Practices

Few Requirements

Many

Requirements

Clear Cut

Subjective

Requirements

Requirements

Easier to Collect

Harder to Collect

Good Data

Good Data

Other Factors to Consider in Selecting a Group

  • The similarity of regulatory requirements within a group across state.

  • The number of facilities across the states, e.g. were there enough facilities in each of the states to make the analysis worthwhile.

  • Whether states include federal as well as state regulatory requirements.

  • The environmental importance of the group, e.g., does group candidate for measurement have the potential for a significant impact on the environment if it is performing poorly.

  • Whether the measurement can be linked to an environmental outcome, e.g. pounds of pollution reduced.

  • Whether the investment of time working on a small universe yields sufficient environmental benefit.

  • Whether the group is so “problematic” that it may be too difficult to use in a common measures project, i.e. resource intensive because of follow-up enforcement actions that would need to be undertaken.

  • Difficulty in identifying a universe, e.g., not regulated by the state as a group and has no existing information, or because the state has not focused resources on identifying all the facilities subject to the program so many are “outside the regulatory system.”

  • Whether the group to be measured is subject to a mandatory or voluntary program.

The purpose of this session was to review these considerations. There were no final decisions made during this meeting because the purpose was to provide background and context for selecting a group or groups to measure. States were given a “summer work

The States Common Measures Project Final Report

28

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