Texas Environmental Compliance Consortium

EPA Initiative

This initiative, started in 2008, has grown into the Texas Environmental Compliance Peer Audit Program.  It includes a consortium of over 50 higher education institutions and represents the first time all three sectors (private, public and community) have joined forces to tackle a significant campus problem.

Program Description 

The EPA has conducted on-site campus inspections of both public and private colleges and universities in Regions 1, 2, 3, and 4 with associated fines.  It is believed that it is only a matter of time before these inspections/audits are conducted in Texas, EPA Region 6.  In order to assist its membership with this large potential liability, ICUT presented and received approval to pursue the Peer Audit program used by other state associations.

The Peer-Audit and the Audit Agreement approach blends the best elements of a self-audit and a third-party independent audit by enabling trained peers from participating schools to audit each other’s campus under the direction of an experienced professional auditor.  Each peer auditor brings inherent knowledge and experience of the campus environment yet, with the compliance training that the program provides, the auditors also provide third-party objectivity.  Of equal importance, each peer-auditor learns from their experience conducting audits on other campuses and brings that knowledge and expertise back to their own campus.  Furthermore, the relationships built during this audit program have opened up dialogue between the participating institutions regarding environmental initiatives and compliance strategies.  The peer-audit program fosters an atmosphere of change and cultural sustainability previously unseen on college and university campuses in such large scale.


In the late 1990’s, the Federal EPA began an enforcement initiative against colleges and universities by conducting multimedia (air, water, waste) inspections of campuses to ensure compliance with federal and state environmental regulations.  The inspections began in New England (EPA Region 1), resulting in fines in the range of $600,000.  The initiative then moved south to New York and New Jersey (EPA Region 2), which caused the Association of Independent Colleges and Universities of Pennsylvania (AICUP) to seek a way to avoid potential fines for its colleges in EPA Region3 (See EPA Region Map). 

The solution was a “peer environmental audit” program, approved by EPA, which allowed each institution to self-audit using college personnel trained on environmental regulations and armed with auditing software.  This program was such a success in Pennsylvania and New Jersey that it is now being implemented in the six states in southeast (EPA Region 4) three states in Region 5, and one state in Region 7.  Texas and Arkansas are the two newest states to join and represent Region 6.

Contact Lois Hollis, ICUT's Director of Member Services, with any questions.