Thank you for the question. Gwen already did a good job of describing the PERC project. She and I actually worked on it together in more junior positions at the time. That's how we got to know each other.
She was talking about the blitz of inspections. That enforcement approach is very different from how we usually work. Typically we're looking to find non-compliance by using intelligence and other means of analysis to do fewer inspections, but looking specifically for non-compliance. To do the kind of compliance-rate project she mentioned, we had to establish a statistically valid compliance rate. That meant doing a lot more inspections on one particular area—not looking for non-compliance, just doing a random sample, establishing a compliance rate, and then developing a targeted intervention. Part of it was compliance promotion. Part of it was enforcement. Then you go back in and sample again.
That is a significant undertaking, and that's why we saw so many inspections being done on PERC.
At the time we were also testing the methodology to see if we could use it in other ways. The audit mentions that during that period of time, they would have expected to see that we had done that kind of project on other things.
We actually did. We ended up using that methodology for a couple of different cases involving the Fisheries Act and associated regulations. That just wasn't captured by the audit because it was specifically looking at CEPA toxics.
You asked a question about the improvements we've seen, and I really appreciate that question. I've been with the program for about nine years and I've been able to see this incredible evolution. We had peace officer powers about 20 years ago. About 12 years ago we became a separate branch. The audits on CEPA toxics and other things came at key points in our development. I've seen over the years how seriously our department took those recommendations and how much work we've done. The sophistication, the way we're playing right now and the level at which we're playing have improved dramatically.
I'm on the board of the pollution crime working group of Interpol, so I interact with a lot of international colleagues. I'm proud to say that we are among the best in the world at what we do. There is still so much work to be done. That's why I appreciate audits and appreciate the work of the commissioner for highlighting areas where we have to go.
There is so much work yet to be done, but there has been significant progress, so thank you as well to the commissioner for recognizing that.