Abstract
In partnership with the Wisconsin Department of Natural Resources (DNR) and the Office of Enforcement and Compliance Assurance (OECA) at the U.S. Environmental Protection Agency (EPA), we aim to conduct a pilot experiment to compare offsite desk audits and onsite inspections within the context of the Clean Water Act's National Pollution Discharge Elimination System (NPDES) wastewater program in Wisconsin. Within inspector-half year blocks, we will randomly assign facilities to receive an offsite desk audit (treatment group) or an onsite inspection (control group). For decision-making, states are interested in knowing if offsite compliance monitoring (OfCM) activities are no worse than onsite inspections in their ability to uncover violations, rather than whether they are better than onsite inspections. This setting lends itself to a non-inferiority randomized controlled trial (RCT) where we test whether offsite desk audits are no worse than onsite inspections by some predetermined margin of acceptable difference, referred to as the noninferiority margin. The noninferiority margin was elicited from our state partner. Over the course of the experiment, inspectors will fill out a standard inspection form for both groups of facilities. At the conclusion of the experiment, we will extract the data from the forms to determine the number of violations, inspection date, inspector, and monitoring type. We will then perform a noninferiority test on the mean number of violations in the two groups. As secondary outcomes, we will also examine the time spent on monitoring and the cost of monitoring.