PRPA’s Environmental Compliance and Environmental Audit Program (EAP)
The vision is to establish a comprehensive audit/inspection program of Port facilities to contribute to the stewardship and custodial management of Port Lands.
PRPA has custodial responsibility for managing environmental risks and maintaining the value of the properties it administers. These responsibilities also include compliance with environmental legislation and federal land management policies. As such, in September 2021 PRPA established the Environmental Audit Program (EAP) to proactively monitor and report on Port facilities, assets and leased lands.
The EAP is intended to foster and maintain relationships with tenants and Port partners in a way that supports achieving collective environmental objectives.
There are two components to the Environmental Audit Program. The first being a Desktop Review. The Desktop Review is a comprehensive review of all of the necessary documents associated with lease provisions, Terms of Agreements or Environmental Assessment commitments. These may include stormwater management, air emissions monitoring or waste management. The second component is a Site Visit. The Site Visit is arranged between the Manager, Environmental Compliance at PRPA, and the tenant, at a time that suits them both, and all observations are recorded with PRPA following up on any non-compliance issues or concerns.
The implementation of the audit process has a concrete foundation but is adapted to the varying needs of each individual tenant as tenant operations can differ. The process includes the following steps:
- Identification of facilities, locations, and site-specific requirements;
- Audit and site visit frequency is determined between the tenant and PRPA (*for tenants with substantial reporting requirements, this may be on a semi-annual basis (or more) vs. vacant lots that will be audited yearly; **newer operations or tenants that are found to be in non-compliance will require a higher frequency of site visits);
- The EAP will include any of the following: compliance with leases/TOAs, EAs; potential site contamination & containment mitigation; waste management & good housekeeping; air/noise/odor emissions; any other relevant environmental concerns;
- Records from site visits will be prepared, managed and retained by PRPA and will be shared with the relevant program leads and responsible parties.
The compliance hierarchy triangle (featured below) is not meant to cause concern for PRPA’s tenants, but rather, to provide a framework of awareness of the regulatory authority granted to PRPA through federal law. As such, PRPA has the authority to further promote and escalate compliance, when and if needed. While PRPA does have this authority to escalate as required, the Environmental Audit Program is intended to foster and maintain the relationships PRPA has built with our tenants and Port partners. Ultimately, the goal is to work together in a collaborative and effective manner with all of our tenants and Port partners to achieve environmental management objectives, for the benefit of all stakeholders and the lands and waters in which we operate.
Auditing & Compliance Performance
Note that the graphs below will be updated regularly to reflect the number of audits completed throughout the year, as well as the number of resolved issues.
Year-over-Year Auditing Performance (Strictly Tenants and Port Partners)
Year-over-Year Performance (Vacant Lots)
If you’d like more information about PRPA’s Environmental Audit Program (EAP) or have a question related to your organization’s involvement in the program, please contact our Manager, Environmental Compliance at email@example.com.