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REPORT TO CONGRESS
STATUS OF THE STATE SMALL BUSINESS
STATIONARY SOURCE TECHNICAL AND ENVIRONMENTAL
COMPLIANCE ASSISTANCE PROGRAM (SBTCP)
FOR THE REPORTING PERIOD
JANUARY - DECEMBER 1997
PRESENTED BY:
KAREN V. BROWN
SMALL BUSINESS OMBUDSMAN
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC
DECEMBER 1998
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ACKNOWLEDGMENTS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
grateful for the support of the dedicated staff of the State Small Business Stationary
Source Technical and Environmental Compliance Assistance Programs (SBTCP),
including the Small Business Ombudsmen (SBOs), Small Business Assistance
Programs (SBAPs), and the Compliance Advisory Panels (CAPs) in the preparation of
this third Annual Report to Congress. All states and territories submitted timely
reports to make this report complete and comprehensive.
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENTS I
LIST OF COMMON ACRONYMS iv
EXECUTIVE SUMMARY v
1.0 INTRODUCTION AND REPORT OVERVIEW 1-1
1.1 Rationale and Objective of the Report to Congress 1-1
1.2 Data Collection Methodology 1-1
1.3 Organization of the Report 1-3
2.0 OVERVIEW OF THE SBTCP . 2-1
2.1 Small Business Ombudsman 2-1
2.2 Small Business Assistance Program 2-2
2.3 Compliance Advisory Panel 2-2
2.4 EPA's Responsibilities Under Section 507 of the CAA 2-3
2.5 Federal Small Business Assistance Program 2-3
3.0 SBTCP STATUS, BUDGETS, STAFFING AND ORGANIZATION 3-1
3.1 Operating Status 3-1
3.2 Budgets 3-3
3.3 Staffing Levels 3-9
3.4 Administrative Locations of SBO and SBAP Components 3-12
4.0 SBTCP ACTIVITIES AND SERVICES 4-1
4.1 Industry Sectors Assisted by the SBTCPs 4-1
4.2 Principal SBO, SBAP, and CAP Activities and Services 4-3
4.3 SBTCP Financial Assistance Programs 4-8
4.4 Minimizing Duplication Through Cooperative Efforts 4-9
4.5 SBTCP Compliance with Section 507{dH2) 4-12
5.0 PROGRAM EFFECTIVENESS 5-1
5.1 Comments Received on SBTCPs 5-1
5.2 Concerns/Inquiries Received and Resolution Strategies Employed . 5-1
5.3 Program Highlights and Accomplishments 5-3
6.0 COMPLIANCE ASSURANCE ISSUES 6-1
6.1 Common Compliance Problems 6-1
6.2 Improvements in Regulatory Understanding and Compliance .... 6-3
6.3 Recommended Changes to Facilitate Small Business
Compliance with the CAA 6-5
6.4 Program Confidentiality and Conflict of Interest 6-7
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TABLE OF CONTENTS
(Continued)
LIST OF TABLES
Table No.
Title
Page
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
3-10
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
6-1
6-2
6-3
Operating Status of the SBTCP Components 3-2
Start of Operations for SBTCP Functions 3-2
1997 SBTCP Operating Budget Ranges 3-4
1997 SBO Operating Budget Ranges 3-5
1997 SBAP Operating Budget Ranges 3-6
1997 CAP Operating Budget Ranges 3-7
SBTCP Reporting Period Budget Comparisons 3-8
Staffing Levels (as FTEs) Serving the SBO & SBAP Functions . . 3-11
CAP Appointments 3-12
Administrative Locations of SBO and SBAP 3-12
SBO/SBAP Outreach Activities 4-4
Information Available on SBAP WWW Pages and BBS 4-5
Major CAP Activities 4-6
Frequency of Meetings Among SBOs, SBAPs, and CAPs 4-7
Financial Assistance Programs 4-8
Programs That Report Cooperative Efforts for
SBTCP Functions 4-10
SBTCP Mechanisms for Avoiding Duplication 4-11
SBTCP Activities to Follow the Intent of the Paperwork
Reduction Act 4-13
SBTCP Activities to Follow the Intent of the Regulatory
Flexibility Act 4-14
SBTCP Activities to Follow the Intent of the Equal Access
to Justice Act 4-15
Common Compliance Problems 6-2
Improvements in Regulatory Understanding 6-3
SBTCP Recommendations for Improving Compliance 6-6
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D
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F
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APPENDICES
1997 SBTCP Reporting Form
Federal Small Business Ombudsman
Federal Small Business Assistance Program
SBTCP Status, Budgets, Staffing, and Organization
SBTCP Activities and Services
Program Effectiveness
Compliance Assurance Issues
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LIST OF COMMON ACRONYMS
Provided below is a list of the major abbreviations and acronyms which are commonly
used in this report.
CAA Clean Air Act as amended in 1990
CAP Compliance Advisory Panel
COI Conflict of Interest
EPA Environmental Protection Agency
FTE Full-time Equivalent
ICR Information Collection Request
OECA Office of Enforcement and Compliance Assurance
OMB Office of Management and Budget
P2 Pollution Prevention
SBAP Small Business Assistance Program
SBO Small Business Ombudsman
SBTCP Small Business Stationary Source Technical and Environmental
Compliance Assistance Program
SIC Standard Industrial Classification
SIP State Implementation Plan
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IV
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman
(SBO) is pleased to submit this third Annual Report to Congress describing the
activities and accomplishments of the state Small Business Stationary Source
Technical and Environmental Compliance Assistance Programs (SBTCPs) during the
reporting period, January 1 - December 31, 1997.
This report is being submitted in accordance with Section 507(d), Monitoring, of the
Clean Air Act, as amended in 1990 (CAA), which directs EPA to provide Congress
with periodic reports on the status of the SBTCPs. This oversight responsibility has
been delegated by the EPA Administrator to EPA's Small Business Ombudsman (SBO).
The Report also includes a general report on the SBO's actions to monitor the
SBTCPs.
This report addresses two of the EPA SBO's key oversight responsibilities:
* Render advisory opinions on the overall effectiveness of the SBTCPs,
difficulties encountered, and degree and severity of enforcement [507(d)(1)J.
* Make periodic reports to Congress on compliance of the SBTCPs with the
Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access
to Justice Act [507(d){2)].
The SBTCPs are designed to assist small businesses in complying with the
requirements of the CAA through state-operated programs. Each SBTCP is required
to include three components or functions: an SBO, a Small Business Assistance
Program (SBAP), and a Compliance Advisory Panel (CAP).
During this third year of monitoring the SBTCPs, over 78,500 small businesses have
been directly reached, and almost 6,000 on-site consultations have been conducted
(as tallied by industry sector assists). SBTCP staff members continue to fill an
important role as facilitator or mediator between small business owners/operators and
regulatory agencies, enhancing communication to promote understanding and
sensitivity on both sides. Based on the information reported, improvements in
compliance occur because businesses have someone to turn to for assistance and
advice, and to act as an effective liaison with regulatory agencies.
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SBTCP yearly operational growth has remained fairly steady for the past several
years. As of the end of 1997, 50 SBOs {94 percent), 52 SBAPs (98 percent), and
39 CAPs (74 percent) were operational. The SBTCPs are staffed with two or fewer
full time equivalents (FTEs) in 77 percent of the SBO functions and 4 or fewer FTEs
in 70 percent of the SBAP functions; these figures are the same as the last two years.
Fifty-eight percent of programs (the same as last year) report that at least the required
7 members have been appointed to their CAPs.
Budgets for the SBTCPs have a wide range from $13,000 to over $2,000,000 for
1996. 98 percent of SBOs (42 of 43) with their own budgets operate their programs
with less than $200,000. Similarly, of the 44 SBAPs with their own budgets, 93
percent are allotted less than $400,000. As programs mature and the cost of
establishing programs stabilize, more programs are projecting fairly consistent budgets
for the next reporting period (39 this year versus 26 last year). The number of
programs projecting budget increases has declined from 11 last year to 6 this year.
Ninety-one percent of SBTCPs provided specific information on the types of industry
sectors and number of facilities that their programs assisted. Seventy-one industry
sectors received assistance in 1997 (the number of industry sectors has been
consolidated from 1996). The top ten industry sectors receiving assistance (general
and on-site) by SBTCPs in 1997 were:
1. Printing/Graphic Arts
2. Other (not classified)
3. Auto/Body Maintenance, Refinishing, Repair
4. Dry Cleaners/Laundry Services
5. Machine/Equipment Manufacturing & Repair
6. Metal Fabricating/Finishing
7. Government
8. Manufacturing, Miscellaneous
9. Gasoline Distribution (Wholesale/Retail)
10. Furniture Manufacturing/Repair/Wood Finishing.
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On-site visits were characterized as being highly effective in providing the
individualized attention often required to assist a facility in achieving compliance. The
top ten industry sectors that received on-site assistance were:
1. Auto/Body Maintenance, Refinishing, Repair
2. Gasoline Distribution (Wholesale/Retail)
3. Dry Cleaning/Laundry Services
4. Other (not classified)
5. Metal Fabricating/Finishing
6. Paints & Painting/Coatings
7. Printing/Graphic Arts
8. Saw Mills/Logging/Wood Products
9. Manufacturing, Miscellaneous
10. Construction/Contractor.
The top ten industry sectors that received assistance from the most programs were:
1. Dry Cleaning/Laundry Services (39 programs)
2. Auto/Body Maintenance, Refinishing, Repair (37 programs)
3. Printing/Graphic Arts (36 programs)
4. Furniture Manufacturing/Repair/Wood Finishing (27 programs)
5. Other (not classified) (26 programs)
6. Electroplating/Chrome Plating (23 programs)
7. Metal Fabricating/Finishing (21 programs)
8. Manufacturing, Miscellaneous (20 programs)
9. Gasoline Distribution (Wholesale/Retail) (19 programs)
10. Sawmills/Logging/Wood Products (18 programs).
Toll-free hotlines, fact sheets, brochures, seminars, and meetings are among the wide
range of outreach mechanisms used to serve the small business community. Other
state-of-the-art outreach activities, such as Internet home pages, are seeing increased
use. The number of programs with web pages more than doubled from 13 in 1995
to 28 in 1996, and rose again in 1997 to 41.
Seventy-nine percent of SBOs (down from 87 percent in 1996), 91 percent of SBAPs
(up from 87 percent in 1996), and 49 percent of CAPs (up from 38 percent in 1996)
report some sharing of resources within their state/territory. Generally, programs
recognize the efficiency and value of coordinating their efforts with each other and
also with environmental agency departments, state agencies, and other organizations.
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Ninety-eight percent of programs (as compared to 92 percent last year) report actions
have been taken to minimize duplication of efforts among SBTCPs. Sharing
information is a practical approach to maximizing program efficiency while enhancing
the cost-effectiveness of funding spent on individual programs.
Section 507 directs EPA's SBO to monitor the SBTCPs' efforts to follow the intent of
the provisions of the Paperwork Reduction, Regulatory Flexibility, and Equal Access
to Justice Acts.
* Eighty-nine percent of programs (as compared to 58 percent last year) report
taking specific actions associated with paperwork reduction, with the most
common action being the production of concise, easy-to-read summary
documents.
• Eighty-nine percent of programs (up from 51 percent) report taking specific
actions consistent with the intent of the Regulatory Flexibility Act. The primary
activity by programs was reviewing SBTCP documents for compliance.
• Seventy-five percent of SBTCPs (as compared to 34 percent last year) reported
specific actions similar to those associated with the Equal Access to Justice
Act. These include the establishment of pro bono legal services, the
availability of funding for technical assistance services for citizen groups
aggrieved by permit actions of a regulatory agency, and the review of SBTCP
documents for compliance.
The number of programs reporting specific actions to follow the intent of the
provisions of these Acts grew in 1996 and again in 1997. The steps being taken
appear to be better targeted to the specific intent of each Act and in addressing the
unique needs of small businesses.
Seventy-two percent of SBTCPs report that small businesses provided comments on
the assistance programs and that feedback was overwhelmingly positive. Common
themes were similar to those in 1995 and 1996. Small businesses appreciated the
availability of non-regulatory assistance for certain problems and the personalized
guidance through the many regulatory processes leading to compliance.
Forty-seven percent of programs provided examples of concerns/inquiries received
and resolution strategies employed. Resolution of issues between the small business
and regulatory communities comprises a significant portion of the SBTCPs' activities,
which included:
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• Developing plain language explanations of regulatory requirements.
• Providing one-on-one guidance through the paperwork process.
• Facilitating communication about regulatory flexibility and compliance
assistance issues between small business and regulatory agencies.
Ninety-six percent of the SBTCPs (the same as 1996) provided insight on the types
of compliance issues addressed during the course of providing technical assistance
to small businesses. The two most common compliance problems mentioned by small
businesses were, "Not understanding the regulatory requirements," and "Uncertain
how to determine emission inventories." Programs reported, "More open
communication between sources and agencies," and "Greater understanding and
awareness of regulations," as results of program outreach efforts.
Generally, programs report that small businesses want to comply with environmental
regulations; however, they may be afraid to ask for help. When a non-threatening
assistance program, such as the SBTCP, is available, small businesses are eager to
take advantage of the services, as this help increases chances of survival and
profitability.
Forty-two SBTCPs provided recommendations for changes to facilitate small business
compiiance with the CAA. As in 1995 and 1996, the most frequent recommendation
was flexibility in applying regulations to small businesses (28 percent of programs).
In addition to inquiries regarding air issues, many programs have or are considering
expanding their services to encompass multimedia issues. Twenty-six percent of
programs recommended expanding assistance to cover multimedia programs (i.e., air,
water, solid waste) for enhancing compliance.
Programs were asked to describe how their SBTCP avoids internal or external
conflicts of interest or the perception that their program may not be confidential.
Eighty-five percent of programs reported no problems concerning confidentiality or
with conflict of interest issues during the course of providing services regardless of
whether a confidentiality policy is in place. Program structures range from a
guarantee of confidentiality (most common) to offering no confidentiality. Many
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programs have policies that protect small businesses from penalties if violations are
discovered during the course of their receiving technical assistance.
The SBTCPs offer important one-on-one contacts, provide valuable information such
as the need to have operating permits, maintaining records, compliance options,
pollution prevention technologies and techniques, and compliance requirements. This
assistance enables small businesses to arrive at informed decisions and more
effectively come into compliance.
CONCLUSIONS AND RECOMMENDATIONS
As has been noted since 1995, SBTCPs are being run by hardworking,
dedicated staffs who operate successful programs with often limited budgets
and resources. Small businesses are grateful for the technical assistance and
personalized attention from people they can trust. In this third year of
gathering information from the programs, over 78,500 small businesses have
been reached, and almost 6,000 on-site consultations have been performed (as
tallied by industry sector).
SBTCPs facilitate dialog between the small business community and the
regulatory community, fostering trust, and improving attitudes and awareness
towards regulatory compliance.
SBTCPs have significant expertise and are increasingly becoming multimedia
as states want to offer this type of assistance, and small businesses are
requesting it. Programs are seeking ways to expand the scope and quality of
the services they offer and the means to fund the enhanced services. To
maximize their budgets and staffing capabilities and to minimize duplication of
effort, programs are encouraged to use the resources of the national SBO and
SBAP.
Commonly identified compliance problems include not understanding regulatory
requirements and uncertainties as to determining emission inventories. SBTCPs
indicated that reasons for these problems included the overwhelming volume
of regulations and the lack of small business' technical expertise needed to
comply. Many current SBTCP activities have remedied such problems. The
concerns regarding these problems underscore the critical role of the SBTCP
in providing vital technical assistance and promoting compliance by establishing
trust and greater understanding.
Programs are to be commended for their accomplishments in continuing to
promote compliance. Highlights include more open communication between
sources and agencies and greater understanding/awareness of regulations by
small businesses. Award programs and loan programs have proved to be
effective in providing incentives, both for small businesses and the programs
themselves. Programs should consider developing award and loan programs
as incentives for their small business customers.
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In conducting the Federal program, EPA has followed the requirements of the
Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts.
EPA's SBO has monitored SBTCP's activities for following the intent of the
provisions of these three Acts. The number of programs reporting specific
activities associated with these Acts significantly increased in 1997. The
careful review of SBTCP documents and the development of simplified forms
and permits are among the positive actions implemented to fulfill the intent of
the Acts.
Program activities primarily emphasize mechanisms to reach larger audiences
(e.g., mailings, hotlines). However, pne-on-one assistance has been reported
as the most effective method in bringing small businesses into compliance, and
programs are encouraged to increase their emphasis on personalized
assistance. Allocation of adequate resources to permit on-site visits by
program staff is important. On-site visits (as tallied by industry sector)
increased to almost 6,000 in 1997 from over 3,800 in 1996.
With the strong small business technical assistance infrastructure in place
through the SBTCPs, programs should explore their potential to expand into
multimedia assistance. A number of programs already offer multimedia
assistance and industry-specific permitting, which can ease the regulatory
burden on small businesses and promote compliance, and several programs are
investigating expansion into multimedia services.
Efficiency of information transfer (among SBTCPs and to small businesses) can
be realized through the increased use of Internet home pages (and to a lesser
extent electronic bulletin boards, which have become less common).
Presently, 77 percent of programs operate some type of electronic information
transfer, up from 53 percent last year. Such electronic services also would be
promising mechanisms to avoid duplication of effort among programs.
Programs again are encouraged to explore the potential of the Internet for
sharing information with small businesses and with other SBTCPs.
Programs are encouraged to explore the potential for sponsoring or facilitating
financial assistance programs for pollution control or pollution prevention
capital expenses. (Only 13 percent of SBTCPs reported the availability of
financial assistance programs in 1996, up slightly from 11 percent last year.)
Small businesses have expressed their need for creative financing mechanisms,
which was recommended by 21 percent of SBTCPs as a method for enhancing
compliance.
SBTCPs are often underfunded and understaffed ^as they provide their current
level of services. Because of this, they are likely to be challenged to expand
their function both in air-related outreach and multimedia technical assistance.
SBTCPs are encouraged to better utilize the expertise of their CAP members to
enhance improvements in their technical assistance programs. As has been
noted in the two previous Reports, several states still do not have operational
CAPs. A number of CAPs also need to address vacancies of the CAP due to
expired terms.
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1.0 INTRODUCTION AND REPORT OVERVIEW
1.1 RATIONALE AND OBJECTIVE OF THE REPORT TO CONGRESS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
pleased to submit this Report to Congress describing the accomplishments and
activities of the state/territory Small Business Stationary Source Technical and
Environmental Compliance Assistance Programs (SBTCP) during the January 1 -
December 31, 1997 reporting period.
This report represents the third Annuai Report to Congress on this important program
designed to help the small business community understand and cost-effectively
comply with the requirements of the Clean Air Act Amendments {CAA) as amended
in 1990.
This report is being submitted in accordance with Section 507{d), Monitoring, of the
CAA, which directs the EPA to provide Congress with an Annual Report on the
SBTCP. This oversight and reporting responsibility has been delegated by the EPA
Administrator to the EPA Small Business Ombudsman (SBO).
This report is intended to address two of the EPA SBO's responsibilities with respect
to the SBTCP.
Render advisory opinions on the overall effectiveness of the SBTCPs,
difficulties encountered, and seventy of enforcement [507(dHD].
Make periodic reports to Congress on compliance of the SBTCPs with the
Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access
to Justice Act [507(d){2)].
1.2 DATA COLLECTION METHODOLOGY
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Information to assess the SBTCPs was collected through a relatively simple,
standardized Annual Reporting Form, which is designed to streamline the reporting
process.
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During the fall of 1994, EPA's SBO, with assistance from SBTCP personnel,
developed the criteria for a standardized Reporting Form. A draft Form was
distributed to the state programs for review in November 1994, and the Form was
further refined during the National SBO/SBAP Conference in January 1995. Programs
also were asked to comment on EPA's Office of Enforcement and Compliance
Assurance's (OECA's) sample questions regarding compliance assessment.
In March 1995, EPA's SBO submitted a "Request for Information Collection Request
(ICR) Approval" to the Office of Management and Budget (OMB) for the Annual
Reporting Form. The Form subsequently was approved and was assigned OMB
Number 2060-0337, expiration date 7/31/98.
In December 1997, EPA's SBO distributed copies of the SBTCP Annual Reporting
Form (for the reporting period January through December 1997) to state/territory
SBTCP contacts (primarily SBOs). These contacts were requested to coordinate
completion of this Form among their SBO, SBAP, and CAP. The Annual Reporting
Form was provided in hard copy and on computer disk for ease of completion and to
reduce the reporting burden. A copy of the 1997 SBTCP Reporting Form is enclosed
as Appendix A.
Programs were not asked to create information that they did not have; therefore,
some SBTCPs were not able to answer all questions posed. Based on the information
requested in the Reporting Form from the first year of reporting, programs were
encouraged to revise the types of statistics they track for subsequent years for
simplicity in completing future reports.
Programs were asked to provide the information requested in the Annual Reporting
Form and submit the Form to the EPA's SBO by February 15, 1998. The information
provided in the Forms was compiled and analyzed to produce this report. The 50
states, plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands,
submitted SBTCP Annual Reports (53 programs total) to EPA's SBO.
In addition, Arizona, California, and Kentucky have distinct air quality districts or
counties with regulatory jurisdiction within their states, which also submitted full or
partial reports, in Arizona, Maricopa County submitted a separate report. For
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California, Kern County and the South Coast Air Quality Management District
submitted full reports; partial reports or informational letters were submitted by the
following Air Quality Management Districts: Bay Area, Mojave Desert, Monterey Bay,
Northern Sonoma County, Sacramento, San Joaquin Valley, San Luis Obispo County,
Santa Barbara County, Tuolumne, Ventura County, and Yolo-Solano. For Kentucky,
Jefferson County submitted a report. For statistical purposes of this report, data from
states that submitted multiple reports have not been combined except where noted.
Raw data for the separate air quality districts are shown in the appendices.
Percentages have been rounded.
According to the Federal Register of November 13, 1996, Volume 61, Number 220,
Pages 58284-94, EPA promulgated a direct final rule conditionally exempting the
Territory of American Samoa, the Commonwealth of the Northern Mariana Islands
(CNMI), and the Territory of Guam from the requirements of Title V of the CAA.
Therefore, reports were not received from American Samoa, CNMI, and Guam.
1.3 ORGANIZATION OF THE REPORT
As detailed below, this report is organized into six main sections, the Executive
Summary, and Appendices.
Section 1.0
Section 2.0
Section 3.0
Section 4.0
Introduction and Report Overview
Overview of the SBTCP -- This section provides an overview of
the three components of the SBTCP (i.e., the SBO, the SBAP, and
the CAP) as well as EPA's responsibilities under Section 507.
SBTCP Status, Budgets, Staffing, and Organization -- This section
encompasses these four categories of information about the
SBTCPs.
SBTCP Activities and Services - In this section, types and levels
of services provided by the three components of the states'
SBTCPs are discussed including efforts to comply with the
Paperwork Reduction, Regulatory Flexibility, and Equal Access to
Justice Acts. Financial assistance program information also is
included.
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Section 5.0 Program Effectiveness — A discussion of program effectiveness
based on comments received by the SBO or CAP, as well as
resolution strategies for any negative comments are provided.
General information on some of the accomplishments and
highlights of the programs in 1997 also are outlined.
Section 6.0 Compliance Assurance Issues ~ Information on the effectiveness
of the three components of the SBTCPs in providing compliance
assistance support to state small businesses is provided in this
section.
Additional details on the information provided by the individual SBTCPs are included
in the various appendices to this report.
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2.0 OVERVIEW OF THE SBTCP
As part of Section 507 of the CAA, the U.S. Congress mandated that each
state/territory establish a SBTCP to assist small businesses comply with the
requirements of this Act through state-operated programs. Each SBTCP (also
commonly referred to as a "Section 507 program") is required to include the following
three components or functions:
Smatl Business Ombudsman (SBO)
Small Business Assistance Program (SBAP)
Compliance Advisory Panel (CAP).
KAREN - PLEASE UPDATE THE NEXT PARAGRAPH AND THE 3
BULLETS!!
The CAA also required states/territories to develop a State Implementation Plan (SIP)
for implementing an SBTCP by November 1992. As of December 31, 1997, xx of 53
states/territories (xx percent) had received approval. from EPA for their SIPs
implementing Section 507 of the CAA. States/territories whose SIPs have not yet
been submitted/approved are:
xxHawaii -- not yet submitted
xxRhode Island -- submitted, but not yet approved
xxVermont -- submitted draft.
2.1 SMALL BUSINESS OMBUDSMAN
The state/territory SBOs serve as the small business community's representative
where small businesses are impacted by the CAA. The SBO's key responsibilities
may include:
Reviewing and provide recommendations to EPA and state/local air pollution
control authorities regarding development and implementation of regulations
impacting small businesses.
Assisting in dissemination of information about upcoming air regulations,
control requirements, and other matters relevant to small businesses.
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• Refering small businesses to appropriate specialists for help with specific
needs.
• Conducting studies to evaluate the effects of the CAA on state and local
economies, and on small businesses generally.
2.2 SMALL BUSINESS ASSISTANCE PROGRAM
The SBAPs provide information and assistance to small businesses on matters of:
Determining applicable requirements under the Act and permitting assistance
The rights of small businesses under the Act
Compliance methods and acceptable control technologies
Pollution prevention and accidental release prevention and detection
Audit programs.
2.3 COMPLIANCE ADVISORY PANEL
The CAPs are created at the state level and are comprised of at least seven members:
• 2 members who are not owners of small business stationary sources --
selected by the Governor to represent the public.
• 2 members who are owners of small business stationary sources - selected by
the lower house of the state legislature.
• 2 members who are owners of small business stationary sources - selected by
the upper house of the state legislature.
• 1 member from the state air pollution permit program — selected by the head
of that agency.
The responsibilities of the CAP are to:
• Render advisory opinions concerning the effectiveness of the S6TCP,
difficulties encountered, and degree and severity of enforcement.
• Report on the compliance of the SBTCP with the Paperwork Reduction Act, the
Regulatory Flexibility Act, and the Equal Access to Justice Act.
• Submit periodic reports to EPA's SBO.
• Review information for small business stationary sources to ensure it is
understandable to the layperson.
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2.4 EPA's RESPONSIBILITIES UNDER SECTION 507 OF THE CAA
Section 507(d), Monitoring, directs the EPA to monitor the SBTCPs and to provide a
report to Congress. This responsibility has been delegated to EPA's SBO, whose
oversight duties are to:
• Render advisory opinions on the overall effectiveness of the SBTCP, difficulties
encountered, and degree and severity of enforcement [507(d)(1}].
• Make periodic reports to Congress on the compliance of the Paperwork
Reduction Act, the Regulatory Flexibility Act, and the Equai Access to Justice
Act [507(d)(2)J.
• Review information issued by the SBTCPs to ensure that it is understandable
to the layperson {507{d)(3)].
• Have the federal SBAP serve as the secretariat for the development and
dissemination of reports and advisory opinions [507(d)(4>].
Further information on the activities and accomplishments of EPA's Office of the
Small Business Ombudsman may be found in Appendix B.
2.5 FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM
EPA, through the Federal SBAP, provides technical guidance for the use of the
SBTCPs in the implementation of their programs. Information on the activities of the
Federal SBAP may be found in Appendix C.
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3.0 SBTCP STATUS, BUDGETS, STAFFING,
AND ORGANIZATION
Information on the operating status (Section 3.1), budgets {Section 3.2), staffing
levels (Section 3.3), and the administrative location of the three components of the
SBTCPs (SBOs, SBAPs, and CAPs) within their states/territories (Section 3.4) for the
January - December 1997 reporting period may be found in this chapter.
A listing of state/territory Ombudsman, SBAP, and alternate SBAP contacts is
included in Appendix D-1.
3.1 OPERATING STATUS
Importantly, by December 31, 1997, 50 SBOs (94 percent of the 53 states and U.S.
territories) and 52 SBAPs (98 percent) had been established and were providing
assistance to small businesses. Only 39 programs reported that their CAPs were
operating; however, 45 programs reported that the CAPs had been established.
The number of established and operational SBOs remained at 50, the same as 1995
and 1996. The number of established and operational SBAPs remained unchanged
at 52 for 1997. Four additional CAPs were established in 1997 (45, up from 41 in
1996), and 3 more CAPs became operational (39 in 1997 versus 36 in 1996).
Operating status for each of the three components of the SBTCPs is shown in Table
3-1 and also identifies those programs whose SBOs, SBAPs, and CAPs are not yet
established or operational.
3-1
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TABLE 3-1
OPERATING STATUS OF THE SBTCP COMPONENTS
SBO2
SBAP3
CAP4
COMPONENTS ESTABLISHED1
# Programs
50
52
45
% Programs
94
98
85
COMPONENTS OPERATIONAL1
# Programs
50
52
39
% Programs
94
98
74
Note 1: Programs indicated if their SBO, SBAPs, or CAPs had been established (i.e., created by
legislation), and if they were also providing services. Programs were considered operational
if the SBOs had been appointed, SBAPs were providing services, and CAPs had conducted
at least one meeting, even if not all CAP members had been appointed.
Note 2: As of 12/31/97, SBOs were reported not to be established or operating in Hawaii,
Massachusetts or Vermont.
Note 3: As of 12/31/97, an SBAP was reported not to be established or operating in Hawaii.
Note 4: As of 12/31/97, CAPs were reported not to be established or operating in 8 programs:
California, Hawaii, Illinois, Iowa, Maryland, Massachusetts, Rhode Island, or the Virgin
Islands. In addition, 6 other states reported that their CAPs had been established, but not
yet operating: Alabama, Arizona, Delaware, District of Columbia, Missouri, and Tennessee.
Details on actual dates (month/year) when the SBOs, SBAPs, and CAPs were reported
to be established and operational may be found in Appendix D-2. A summary of the
start of operations for the three SBTCP functions is shown in Table 3*2.
TABLE 3-2
START OF OPERATIONS FOR SBTCP FUNCTIONS
Pre-1 990
1991
1992
1993
1994
1995
1996
1997
% operational by
12/31/97
SBO
Number
12
20
10
7
1
Total
12
32
42
49
50
94%
SBAP
Number
1
1
11
17
16
5
1
Total
1
2
13
30
46
51
52
98%
CAP
Number
1
8
12
11
4
3
Total
1
9
21
32
36
39
' 74%
3-2
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3.2 BUDGETS
information about the total SBTCP operating budgets may be found in Section 3.2.1,
with details on the SBO, SBAP, and CAP budgets contained in Sections 3.2.2, 3.2.3,
and 3.2.4, respectively. A comparison of the program budgets for 1996, 1997, and
(projected) 1998 is shown in Section 3.2.5.
3.2.1 1997 Reporting Period
As detailed in the paragraphs and tables below, the total operating budgets for the
SBTCPs varied from $13,000 to over $2,000,000 for the 1997 reporting year. These
extremes include $ 13,000 for the District of Columbia, whose CAP has not yet begun
operations, to New York, reporting a total operating budget of $2,174,000
1997 operating budget ranges for the SBTCPs are shown in Table 3-3; 1996 and
1995 ranges also are shown for comparison. Details on the operating budgets, by
program, for the individual SBO, SBAP, and CAP components, including the source
of these funds, may be found in Appendix D-3.
3-3
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TABLE 3-3
1997, 1996, and 1995 SBTCP OPERATING BUDGET RANGES
BUDGET*
0
1 - 100,000
100,001 -200,000
200,001 - 300,000
300,001 - 400,000
400,001 - 500,000
500,001 - 600,000
600,001 - 700,000
700,001 - 800,000
800,001 - 900,000
> 1 ,000,0002
>2,000,0003
Report submitted,
no data provided*
TOTAL
1997
»
Programs
10
15
7
12
3
1
1
1
1
1
1
53
%
Programs1
19
28
13
23
6
2
2
2
2
2
2
1996
#
Programs
1
9
19
5
9
2
2
1
2
1
1
1
53
%
Programs1
2
17
36
9
17
4
4
2
4
2
2
2
1995
#
Programs
2
9
14
9
7
2
3
1
2
1
1
2
%
Programs1
4
17
26
17
13
4
6
2
4
2
2
4
Note 1: County budgets are not combined with state budgets, nor are they counted separately.
Note 2: Texas.
Note 3: New York.
Note 4: Hawaii (1997, 1996, and 1995), Florida (1995 only).
The balance of this section provides summary details on the operating budgets for the
SBOs, SBAPs, and the CAPs.
3.2.2 SBO Operating Budgets
Forty-three SBOs have their own budgets (versus having their budgets combined with
other SBTCP functions). Budgets for these SBOs are concentrated in a range below
$200,000, with 42 of 43 SBOs (98 percent) reporting budgets between $0 and
$200,000. (The one exception is New York's SBO, who reports a budget of
$1,170,000.) The primary source of funding for all programs is Title V fees (49
percent), which are collected at the state/territory level. Other sources of funding
3-4
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include EPA 105 Grant funds (provided for in Section 105 of the CAA, these funds
flow to the states through EPA regional offices), non-Title V air fees, and state permit
fees.
The range of 1997 operating budgets for the SBOs with their own budgets is shown
in Table 3-4. A comparison of SBO budgets for the past three years is not practical,
as a different number of SBOs have had their own budgets each year.
TABLE 3-4
1997 SBO OPERATING BUDGET RANGES
443 non-combined budgets)
Budget ($1
0 • 25,000
25,001 - 50,000
50,001 - 75,000
75,001 - 100,000
100,001 -200,000
> 1 ,000,000
Combined budgets1
Report submitted, no data provided2
TOTAL
# Programs
12
10
7
6
7
1
8
2
53
% Total Programs
23
19
13
11
13
2
15
4
Note 1: Eight SBOs have combined budgets. If a program combined the budget for two SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the
budget of the third component of the program also was tallied separately (e.g., a program reporting a
combined SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for
the SBO/CAP budget and with SBAPs for the SBAP budget).
Note 2 Ha-.vati and Massachusetts.
3.2.3 SBAP Operating Budgets
Forty-four SBAPs have their own budgets. SBAP budgets are spread across a wider
dollar range as compared to the SBOs with 15 of 44 programs (34 percent) between
$0 and $100,000, 13 of 44 programs (30 percent) between $100,001 and
$200,000, and 7 of 44 programs (16 percent between $200,001 and $300,000.
Title V fees again are the main funding source (43 percent of all programs); funds
3-5
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from EPA 105 Grants, non-Title V fees, indirect funds, and permit fees are also used
to support SBAPs.
The range of 1997 operating budgets for the SBAPs with their own budgets is shown
in Table 3-5. A comparison of SBAP budgets for the past three years is not practical,
as a different number of SBAPs have had their own budgets each year.
TABLE 3-5
1997 SBAP OPERATING BUDGET RANGES
(44 non-combined budgets)
Budget ($)
0 - 25,000
25,001 - 50,000
50,001 • 75,000
75,001 - 100,000
100,001 -200,000
200,001 - 300,000
300,001 - 400,000
400,001 - 500,000
600,001 - 700,000
900,001 - 1,000,000
Combined budgets1
Report submitted, no data provided2
TOTAL
# Programs
2
3
7
3
13
7
6
1
1
1
8
1
53
% Total Programs
4
6
13
6
25
13
11
2
2
2
15
2
Note 1: Eight SBAPs have combined budgets. If a program combined the budget for two SBTCP functions {i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the
budget of the third component of the program also was tallied separately (e.g., a program reporting a
combined SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for
the SBO/CAP budget and with SBAPs for the SBAP budget).
Note 2: Hawaii.
3-6
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3.2.4 CAP Operating Budgets
Forty CAPs have their own budgets; even though only 39 CAPs are operational,
administratively, 40 CAPs are indicated to have their own budgets. CAP funding
ranges from $0 to a high of $15,000 (one program, Vermont). Eighty-eight percent
of CAPs with their own budget operate with a budget of $5,000 or less. Title V fees
are the most commonly listed funding source for all CAPs (45 percent).
The range of 1 997 CAP operating budgets is shown in Table 3-6. A comparison of
CAP budgets for the past three years is not practical, as a different number of CAPs
have had their own budgets each year.
TABLE 3-6
1 997 CAP OPERATING BUDGET RANGES
(40 non-combined budgets)
Budget ($)
O1
1 - 1,000
1,001 -2,000
2,001 • 3,000
3,001 - 4,000
4,001 - 5,000
9,001 - 10,000
14,001 - 15,000
Combined budgets2
Report submitted, no data provided3
TOTAL
# Programs
13
3
6
5
1
7
4
1
10
3
53
% Total Programs
25
6
11
9
2
13
8
2
19
6
100
Note 1: CAPs reporting "N/A* or "as needed' also were counted as "0" if they administratively were assigned their
own budgets.
Note 2: 10 CAPs have combined budgets. If a program combined the budget for two SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the
budget of the third component of the program also was tallied separately (e.g., a program reporting a
combined SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for
the SBO/CAP budget and with SBAPs for the SBAP budget).
Note 3: Alabama, Hawaii, Virgin Islands.
3-7
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3.2.5 Comparison of Previous and Projected Budgets
A comparison of budgets from 1996, 1997, and 1998 (projected) is valuable in
tracking program growth and resource allocation. Programs were asked to indicate
significant budget changes (greater than ten percent) from year to year and to provide
insight into any major shifts (more than ten percent) in funding levels. SBTCP
reporting period budget comparisons are shown in Table 3-7.
TABLE 3-7
SBTCP REPORTING PERIOD BUDGET COMPARISONS
1936 to
1997
Reporting
Period
1997to
1998
Reporting
Period
BUDGET DECREASE
(> 10% change)
»
Programs
6
5
%
Program*
9
9
BUDGET CONSISTENT
« 10%ehana«)
*
Program*
35
39
%
Program*
66
74
BUDGET INCREASE
(> 10% chang*)
*
Program*
12
6
%
Programs
23
11
INSUFFICIENT DATA
FOR COMPARISON1
#
Program*
1s
33
%
Program*
2
6
Note 1: Not all programs provided budget amounts. In order to establish trends, combined budgets for the SBO,
SBAP, and CAP were examined. This was necessary, as some programs indicate combined budgets for
two or three facets of their programs, white other programs may have had one or two facets of their
programs inactive during the previous reporting period.
Note 2: Hawaii.
Note 3: Hawaii, Montana, South Carolina.
In reviewing the combined budgets for the SBO, SBAP, and CAP functions of the
SBTCPs, 12 programs (23 percent) indicated a budget increase (of at least ten
percent) from the 1996 to 1997 reporting periods. Six programs (11 percent)
*
showed an increase from the 1997 to 1998 reporting periods.
As programs mature and the cost of establishing programs stabilizes, more programs
are projecting fairly consistent budgets for the next reporting period (39 this year as
compared to 36 last year). The number of programs projecting a budget increase for
the subsequent reporting period continues to decline from 11 last year to six this
year.
3-8
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^R} According to responses received, projected budget increases primarily were related
to the growth and expansion of SBTCP services and staff additions. Examples of
reasons given for budget increases greater than ten percent are provided below:
• In the District of Columbia, a funding increase for 1998 is due to the
establishment of the CAP. ($13,000/1997 to $15,000/1998)
• Missouri's funding increased in 1998, because a federal grant was obtained to
inform the public of the 112(r) requirements. Also, additional general revenue
funding was used to provide air assistance due to the number of assistance
requests received. ($395,000/19997 to $505,000/1998)
• Utah's SBO spending increases will be derived from the EPA "Partnership in
Compliance" grant. ($248,000/1997 to $332,000/1998)
Thirty five programs (66 percent) report steady budget levels (less than a ten percent
change) for the 1996 to 1997 reporting periods, and 39 programs (74 percent)
indicate consistent budget levels from the 1997 to 1998 reporting periods.
Seven programs (19 percent) showed a decrease (more than ten percent) from the
^t 1996 to 1997 reporting periods, and five programs (nine percent) also projected a
decrease from the 1997 to 1998 periods. Budget reductions are often attributed to
program reorganizations and consolidations and lower projected costs to maintain a
program (versus the higher resource requirements to develop a program).
Eighty-five percent of the programs reported either a consistent or increasing budget
from the 1997 to 1998 reporting periods.
Budgets for the 1996, 1997, and 1998 reporting periods for the SBO function, SBAP
function, and CAP function may be found in Appendix D-4.
3.3 STAFFING LEVELS
Forty-one programs (77 percent) report operating their SBOs with two or fewer full-
time equivalents (FTEs) as shown in Table 3-8. This number remained unchanged
from 1996. -
3-9
-------
In 1997, as in 1996, 37 programs (70 percent) operate their SBAPs with four or
fewer FTEs, which include both paid and unpaid staff and may include retired
engineers. There are some notable exceptions to these staffing levels, such as
Louisiana, Indiana, and California, which report using 11, 12, and 20 FTEs,
respectively, to support their SBAP function. Also, Texas reported the services of
over 50 unpaid "EnvrroMentors" who assist with SBAP duties.
Specific details on the number of FTEs, by program, for the SBO and SBAP functions
may be found in Appendix D-5.
3-10
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TABLE 3-8
STAFFING LEVELS (as FTEs1) SERVING THE SBO & SBAP FUNCTIONS
#FTEs
0 - 0.09
0.1 -1
1.1 -2
2.1 -3
3.1 -4
4.1 -5
5.1 -6
6.1 -7
7.1 -8
10.1 - 11
11.1 • 12
12.1 - 13
19.1 -20
20 +
N/A
TOTAL
# Programs
SBO
3
28
10
5
1
1
1
1
50
SBAP
13
10
11
3
4
1
3
1
1
1
1
1
50
Combined Staffing
1
1
1
3
Note 1: An FTE is considered to work 40 hours/week. For example, two people working 20
hours/week would be equivalent to one FTE.
Note 2: Three states (Delaware, Florida and Texas) combined their SBO and SBAP functions. TX
reported 15.5 paid SBO/SBAP staff plus 50 volunteer "EnviroMentors" serving the SBAP.
Note 3: Not applicable: SBO-Massachusetts, SBAP-f ennessee.
Fifty-eight percent of programs (the same as percent last year) report that at least the
required seven members have been appointed to their CAPs. An overview of CAP
appointments is shown in Table 3-9. In CAPs with fewer than seven members,
several programs indicated that expired terms on their CAPs have not yet been filled
or that their CAPs have not yet been established. Program statistics of the number
of CAP members in each category (small business, state agency, general public, not
yet appointed, other) may be found in Appendix D-6.
3-11
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TABLE 3-9
CAP APPOINTMENTS
Minimum 7 members appointed
Less than 7 members appointed
Not established1
# Programs
31
21
1
% Programs
58
40
2
Note 1: Hawaii.
3.4 ADMINISTRATIVE LOCATION OF SBO AND SBAP COMPONENTS
As shown in Table 3-10, 52 programs indicated that their SBOs are located within a
state/territory-related agency, typically the environmental agency {not necessarily a
regulatory section). The majority of programs (50) report to have located their SBAPs
within a state/territory-related agency, typically the environmental agency. Three
programs (Kansas, Kentucky, and Pennsylvania) contract their SBAP function to an
outside agency.
As defined in Section 507, the CAPs are to be independent entities, operating outside
of any agency.
TABLE 3-10
ADMINISTRATIVE LOCATIONS OF SBO AND SBAP
Location
State-related agency
University-related (contracted)
Private contractor
No response
TOTAL
SBO
# Programs1
52
1
53
% Programs
98
2
100
SBAP
# Programs1
50
2
1
53
% Programs
94
4
2
100
Note 1: Numbers are higher than those reported in Table 3-1. Programs without established SBOs or SBAPs
indicated where those functions are intended to be located once established.
Complete information for the administrative location of each SBO, SBAP, and CAP
may be found in Appendix D-7.
3-12
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4.0 SBTCP ACTIVITIES AND SERVICES
Information regarding the services and activities of the three components of the
SBTCPs is provided in this section. Industry sectors assisted by the SBTCPs are
discussed in Section 4.1. An overview of SBO, SBAP, and CAP activities and
services is provided in Section 4.2. SBTCP financial assistance services are outlined
in Section 4.3. A discussion of how programs minimize duplication through
cooperative efforts may be found in Section 4.4. SBTCP efforts to comply with the
Paperwork Reduction Act, Regulatory Flexibility Act, and the Equal Access to Justice
Act are summarized in Section 4.5.
4.1 INDUSTRY SECTORS ASSISTED BY THE SBTCPs
Forty-eight SBTCPs (91 percent) (data from county and air district programs were
included with their state's activities) provided specific information on the types of
industry sectors and number of facilities that their programs assisted in 1997. Small
businesses in 71 industry sectors (the number of industry sectors has been
consolidated from 1996) were identified as having been assisted by SBTCPs. Certain
industry sectors, such as dry cleaning/laundry services and printing/graphic arts,
received more assistance, as these sectors are strongly impacted by the CAA.
Programs also may have targeted certain industry sectors for assistance based on
their anticipated impact by the CAA and the number of small businesses in that
industry sector.
The top ten industry sectors receiving assistance (general and on-site) by SBTCPs in
1997 were:
1. Printing/Graphic Arts
2. Other (not classified)
3. Auto/Body Maintenance, Refinishing, Repair
4. Dry Cleaners/Laundry Services
5. Machine/Equipment Manufacturing & Repair
6. Metal Fabricating/Finishing
7. Government
8. Manufacturing, Miscellaneous
9. Gasoline Distribution (Wholesale/Retail)
10. Furniture Manufacturing/Repair/Wood Finishing.
4-1
-------
The top ten industry sectors that received on-site assistance were:
1. Auto/Body Maintenance, Refinishing, Repair
2. Gasoline Distribution (Wholesale/Retail)
3. Dry Cleaning/Laundry Services
4. Other (not classified)
5. Metal Fabricating/Finishing
6. Paints & Painting/Coatings
7. Printing/Graphic Arts
8. Saw Milts/Logging/Wood Products
9. Manufacturing, Miscellaneous
10. Construction/Contractor.
The top ten industry sectors that received assistance from the most programs were:
1. Dry Cleaning/Laundry Services (39 programs)
2. Auto/Body Maintenance, Refinishing, Repair (37 programs)
3. Printing/Graphic Arts (36 programs)
4. Furniture Manufacturing/Repair/Wood Finishing (27 programs)
5. Other (not classified) (26 programs)
6. Electroplating/Chrome Plating (23 programs)
7. Metal Fabricating/Finishing (21 programs)
8. Manufacturing, Miscellaneous (20 programs)
9. Gasoline Distribution (Wholesale/Retail) (19 programs)
10. Sawmills/Logging/Wood Products (18 programs).
As in previous years, industry sectors that received the most overall types of
assistance generally received the greatest number of on-site visits. In comments
provided by the SBTCPs, the majority indicated that the most notable improvements
in compliance were the result of on-site visits.
A list of the industry sectors receiving assistance (by number of programs) may be
found in Appendix E-1. This same list also has been reordered by total number of
assistance efforts (Appendix E-2) and by on-site assistance efforts (Appendix E-3).
Individual program responses by number of general, on-site, and total assists are
shown in Appendix E-4. The fifteen most active programs, with over 1,000
assistance efforts (as tallied by specific industry sectors) were:
4-2
-------
1. Kansas
2. California
3. Illinois
4. Texas
5. Colorado
6. Connecticut
7. Tennessee
8. Wisconsin
9. Missouri
10. Georgia
11. New York
12. Iowa
13. Maine
14. Louisiana
15. Oklahoma.
4.2 PRINCIPAL SBO, SBAP, AND CAP ACTIVITIES AND SERVICES
An overview of activities and services provided by the three SBTCP functions is
discussed in this section.
4.2.1 SBO/SBAP Activities and Services
An aggregate of the outreach services offered by the SBOs and SBAPs during the
1997 reporting period is presented in Table 4-1. These outreach activities and
services are designed to introduce small business people to the available assistance
services and to identify common problems and issues to be addressed on a more
specific basis.
For 1997, programs could report their outreach statistics either for their SBO and
SBAP separately or combined (depending on how they gathered their information).
Twenty-six programs reported separate statistics for their SBO and SBAP, and 27
programs reported combined statistics.
4-3
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TABLE 4-1
SBO/SBAP OUTREACH ACTIVITIES
ACTIVITY
Seminars, workshops, speaking events
On-site visits
Brochures, manuals, information packets
Mailings & correspondence
Permit & compliance assistance
Hotline calls
Meetings
Information booths
Pollution prevention assistance
Newsletters
Teleconferences
Regulatory overview
Media coverage
Other
# Programs1
51
48
48
46
45
44
44
41
32
31
29
27
26
16
% Programs
96
91
91
87
85
83
83
77
60
58
55
51
49
30
Note 1:
Does not include county or regional activities.
The most common outreach activities, offered by at least 85 percent of programs,
were:
Seminars, workshops, speaking events.
On-site visits.
Brochures, manuals, information packets.
Mailings and correspondence.
Permit and compliance assistance.
The first four activities remain as some of the most common services offered by the
programs. Permit and compliance assistance, however, greatly increased from 1996,
where 12 programs provided such assistance as compared to 45 programs in 1997.
Detailed information, by program, about the number of occurrences and the number
of people reached by each reported SBO/SBAP activity is presented in Appendix E-5.
Details of the SBO and SBAP hotlines are shown in Appendix E-6.
4-4
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4.2.2 Web Pages and Electronic Bulletin Boards
Of particular note is the number of programs that are using World Wide Web (WWW)
home pages and Bulletin Board Services (BBSs) to disseminate technical assistance
information. Forty-one programs currently are using home pages or BBSs, up from
28 last year. (County/regional air district programs operating their own home pages
are counted as one with the state.) One state indicated it plans on launching a home
page in 1998. Home pages are far more common than BBSs, with only six programs
operating a BBS (also in conjunction with a home page).
The types of information available via these home pages or BBSs are listed in Table
4-2; detailed information on the BBSs and home pages, by program, may be found
in Appendix E-7.
TABLE 4-2
INFORMATION AVAILABLE ON SBAP WWW
Type of Information
Program description
Contact listings
Links
Permitting information
Regulations
Guidance documents/fact sheets
Pollution prevention information
List of publications
Permit forms
Calendar of events
Policies
Emissions inventory
CAP information
Other
PAGES AND BBS
9 Programs
38
38
34
33
32
32
28
27
26
25
23
13
12
9
% Programs
72
72
64
62
60
60
53
51
49
47
43
25
23
17
Internet home pages (and BBSs, which are becoming less common) are efficient
mechanisms for SBTCPs to disseminate information to small businesses, as evidenced
4-5
-------
by the increasing use of electronic media over the last two years. Because the
Internet and BBSs also are practical for information transfer from the federal SBO and
SBAP, between SBAPs, and to the small business community, increased access to the
Internet and expanded web page content should continue to be pursued by the
programs.
4.2.3 CAP Activities and Services
Thirty-nine CAPs indicated they were operational during the 1997 reporting period,
37 of which reported activities. The primary CAP activities, as reported by 28 CAPs,
were review of SBTCP documents for compliance and review of SBO/SBAP outreach
efforts. This was followed by defining CAP responsibilities (reported by 23 CAPs}.
Major activities of the CAPs during the 1997 reporting period are summarized in Table
4-3. A program summary of CAP activities may be found in Appendix E-8.
TABLE 4-3
MAJOR CAP ACTIVITIES
Activity
Review of SBTCP documents
Review of SBO/SBAP outreach efforts
Define CAP responsibilities
Review/comment on new regulations, policies, etc.
Appoint staff/elect officers
Attend training seminars, conferences, etc.
Meet with small businesses/trade associations
Other
9 Programs
28
28
23
21
19
16
14
6
% Programs
53
53
43
40
36
30
26
11
CAPs are pursuing many diverse avenues in becoming effective partners in the
technical assistance programs. The unique roles and specialized skills of the members
make them valuable resources in the development of th'e SBTCPs. Effective
communication among the three components of the programs and among CAPs in all
programs will continue to effectively and efficiently define the role of the CAP and
4-6
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fully maximize the skills of CAP members in assisting small businesses. The value
added activities of these CAPs underscore the need for states without operational
CAPs to complete the appointment/reappointment process and initiate the CAP
function.
4.2.4 SBO/SBAP/CAP Meetings
As shown in Table 4-4, SBTCPs have recognized the importance of meetings among
the three functions to ensure effective coordination of efforts and use of resources.
Two-thirds of SBOs and SBAPs have scheduled meetings at least quarterly, and
almost one-half of programs report scheduled meetings among SBOs, SBAPs, and
CAPs at least once a year.
TABLE 4-4
FREQUENCY OF MEETINGS AMONG SBOs. SBAPs, AND CAPs
(number of programs reporting such frequency)
Frequency
Daily
Weekly
Bi-monthly
Monthly
Quarterly
Bi-annually
Annually
Occasionally
Other
TOTAL
SBO & SBAP
15
4
6
4
7
1
1
5
43
SBO & CAP
2
8
3
1
6
2
20
SBO, SBAP, & CAP
1
14
8
2
3
3
31
SBAP & CAP
1
9
3
2
•
6
2
23
Meetings between SBOs and SBAPs were the most common form of contact,
occurring in 43 programs (81 percent). A majority of these meetings (38 of 43
programs or 88 percent) were regularly scheduled, with frequencies ranging from
daily to annually. The most commonly scheduled frequency of meeting between
SBOs and SBAPs, reported for 15 of the 43 programs (35 percent), was daily.
4-7
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Meetings between SBOs and CAPs were reported for 38 percent of programs (20 of
53). The majority of these meetings, 14 of 20 (70 percent), were regularly
scheduled. The most common frequency of meetings between SBOs and CAPs was
quarterly, reported for 8 of 20 programs, or 40 percent.
Thirty-one programs (58 percent) reported meetings involving SBOs, SBAPs, and
CAPs. Most of these meetings, 28 of 31 (90 percent), were regularly scheduled, and
the common frequency was quarterly, reported for 14 of 31 programs (45 percent).
Meetings between SBAPs and CAPs were reported in 23 programs (43 percent). Of
these, 17 of 23 {74 percent) were regularly scheduled, and the most common
frequency was quarterly, reported for 9 of 23 programs (39 percent).
i
Detailed information, by program, about meetings between SBTCP functions, is
presented in Appendix E-9.
4.3 SBTCP FINANCIAL ASSISTANCE PROGRAMS
Information about financial assistance programs offered to small businesses to
address environmental compliance needs is provided in Table 4-5.
TABLE 4-5
FINANCIAL ASSISTANCE PROGRAMS
Programs offering grants/loans
Grants/loans offered
Programs planning grants/loans
#
7
101
9
Note 1: Some SBTCPs offer more than one financial assistance program.
Seven SBTCPs (13 percent) offered ten financial assistance programs during the 1997
reporting period. Nine SBTCPs have plans to offer financial assistance programs to
small businesses in the near future. This is up from 8 financial assistance programs
offered by 6 states in 1996. Detailed information about these financial assistance
programs is provided in Appendix E-10.
4-8
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Only 13 percent of SBTCP programs offer some type of financial assistance to help
small business with capital expenses associated with pollution prevention or control
equipment. Creative financing mechanisms fulfill a need conveyed to programs by
small businesses; offering financial assistance was a common recommendation made
for improving compliance by SBTCPs themselves. The addition of grant or loan
programs planned by nine additional states will be of great benefit to small businesses
in these states.
4.4 MINIMIZING DUPLICATION THROUGH COOPERATIVE EFFORTS
Programs reported on the extent to which they utilized existing state/territorial
agencies and departments, organizations, and other resources to maximize efficiency
and minimize redundancy, as discussed in Section 4.1.1. Programs also provided
information on their strategies to exchange information and resources with other
SBTCPs, which is summarized in Section 4.4.2.
4.4.1 Cooperative Efforts
Information provided in this section is vital to understanding how some programs with
limited budgets and resources are functioning. Generally, programs report that ail
three components of their SBTCPs recognize the efficiency and value of coordinating
their efforts with each other and with other environmental agency departments, state
agencies, and organizations. A summary of the number of SBTCP functions that
cooperatively manage resources is shown in Table 4-6. Descriptions of programs'
cooperative efforts may be found in Appendix E-11.
4-9
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TABLE 4-6
PROGRAMS THAT REPORT COOPERATIVE EFFORTS
FOR SBTCP FUNCTIONS
SBO
SBAP
CAP
# Programs
42
48
26
% Programs
79
91
49
Forty-two programs (79 percent) report some level of cooperative effort to enhance
the SBO function. The SBO often coordinates information development and
dissemination, training, and workshops/seminars with such entities as other state
agencies, Chambers of Commerce, trade associations, non-profits, public utilities, and
Small Business Development Centers. The overall concerns of small businesses are
being taken into account, as many SBOs provide multimedia information, coordinate
outreach with non-air programs, or intervene on behalf of a small business with other
agencies. Some SBOs also serve in other roles within the state environmental
agency.
Forty-eight programs (91 percent) indicate some level of cooperative effort by the
SBAP function in order to maximize their programs' effectiveness. Strategies and
sources of assistance are quite similar to those used by the SBOs.
Twenty-six CAPs (49 percent) report leveraging resources within their state/territory.
While the CAPs, by design, are independent entities, many receive administrative
support and technical resources from the state/territory environmental agency, the
SBO, or the SBAP.
V
4.4.2 Minimizing Duplication of Efforts Among SBTCPs
Fifty-two programs (98 percent) report some action to minimize duplication of efforts
among SBTCPs. The sharing or exchanging of information among SBTCPs is a
practical method for avoiding duplication of effort, thus increasing the overall cost-
effectiveness of individual programs. As an example, industry-specific information
developed by one program would have wide applicability to other programs involved
4-10
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with similar industries. Mechanisms that programs employ to avoid duplication of
effort are presented in Table 4-7; program details for this topic are found in Appendix
E-12.
TABLE 4-7
SBTCP MECHANISMS FOR AVOIDING DUPLICATION
Mechanism
Communication with other SBTCPs & state agencies
Contact with other SBTCPs within EPA regions
Gathering information from electronic sources
Review of documents from other sources
Review of EPA documents and/or contact with EPA
Contacts with state/regional air groups
Subscribe to SBO or government ombudsman listserve
Other
# Programs
52
50
46
45
45
38
30
15
% Programs
98
11
94
87
85
85
72
57
28
The most common technique (in 98 percent of programs) to avoid duplication of
effort was communication and networking with SBTCP and state agency personnel
via phone, mailing lists, etc. The second most common method for avoiding
duplication was contact with other programs within the same EPA region through
conference calls and other means. This technique was utilized during the 1997
reporting period by 50 programs (94 percent).
Gathering information from electronic sources, including use of the Internet for
information transfer, continues to be one of the most promising mechanisms for
avoiding duplication of effort among programs. Use of this method greatly increased
in 1997 and was reported by 46 programs, up from 18 in 1996. This parallels the
rise in the number of web pages available, as previously noted. Posting of
information from the federal SBO and SBAP, other private and university sources, and
state programs facilitate efficient use of resources and would encompass all of the
mechanisms to avoid duplication. Additionally, 30 programs reported subscribing to
applicable listserves. (A listserve is a program that allows users to mass-distribute
4-11
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electronic mail messages. 1997 was the first year this reporting category was
solicited.)
4.5 SBTCP COMPLIANCE WITH SECTION 507(d)(2)
Section 507(d)(2) of the CAA requires EPA's SBO to periodically report to Congress
on SBTCP actions to follow the intent of the provisions of the Paperwork Reduction
Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act. EPA's SBO
has conducted a number of significant outreach actions toward assisting the SBTCPs
in this effort.
Key EPA SBO outreach activities under the CAA Section 507(b) pursuant to these
statutes include:
• Conducted educational activities at the EPA SBO Regional Liaison Conference,
Arlington, VA, August 1997.
• Provided information on statutes at the 1997 National/State SBO/SBAP
Conference in Charleston, SC.
* Responded to telephone hotline inquiries in regard to the three statutes.
• Distributed copies of the three statutes by request to state contacts.
• Provided states with copies of the 1996 Small Business Regulatory
Enforcement Fairness Act (SBREFA), which strengthens and amends the
Regulatory Fairness Act.
* Offered information on the three statutes on the small business environmental
home page.
4.5.1 SBTCP Activities Associated with the Paperwork Reduction Act
Forty-seven programs (89 percent) reported specific activities associated with the
intent of the Paperwork Reduction Act, up from 32 programs in 1996. This Act was
designed to minimize the burden and maximize the practical utility and public benefit
associated with the collection of information by or for a federal agency.
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The two most common action taken to follow the intent of the provisions of this act
were development of concise, easy-to-read summary documents (77 percent of
programs) and receiving/providing information electronically (72 percent of programs).
Overall, these actions show an increasing number of SBTCPs have continued to take
significant steps during the 1997 reporting period in following the intent of the
provisions of the Paperwork Reduction Act.
Actions taken by SBTCPs in following the intent of the provisions of the Paperwork
Reduction Act are listed in Table 4-8 and are detailed, by program, in Appendix E-13.
TABLE 4-8
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE PAPERWORK REDUCTION ACT
Activity
Producing concise, easy-to-read summary documents
Receiving/providing documents electronically
Reviewing documents for compliance
Using general, industry-specific permits
Using simplified/consolidated permits/forms
Increasing exemptions for "insignificant" activities
# Programs
41
38
37
30
30
20
% Programs
77
72
70
57
57
38
4.5.2 SBTCP Activities Associated with the Regulatory Flexibility Act
Forty-seven programs (89 percent) reported activities to follow the intent of the
provisions of the Regulatory Flexibility Act during 1997. This is an increase from 27
programs in 1996. The Regulatory Flexibility Act requires that when a number of
regulations will have a significant economic impact on a substantial number of small
entities, "a regulatory analysis must be performed to explore options for minimizing
those impacts." Those actions most often implemented are prioritized in Table 4-9.
4-13
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TABLE 4-9
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE REGULATORY FLEXIBILITY ACT
Activity
Reviewing documents for compfiance
Reviewing/commenting on new air regulations
Using simplified/consolidated permits/forms
Implementing an amnesty program
Increasing exemptions for "insignificant" actions
Other
# Programs
38
33
28
23
22
2
% Programs
72
63
53
43
42
4
SBTCPs have played a major role in ensuring awareness of the effects of regulatory
requirements on small businesses as well as promoting environmental compliance in
the small business community. SBTCP personnel made significant strides in
promoting the effects of legislation/regulations on small businesses to regulatory
agencies through their role as mediators between these two groups. The primary
activity reported by programs in following the intent of the Regulatory Flexibility Act
{38 programs, or 72 percent) was the review of SBTCP documents for compliance.
SBTCPs continue to be effective advocates of the small business perspective and
have helped negotiate flexible application of regulatory requirements that provided
great benefits to small businesses. Actions taken by SBTCPs in response to the
Regulatory Flexibility Act, by program, may be found in Appendix E-14.
4.5.3 SBTCP Activities Associated with the Equal Access to Justice Act
Forty programs (75 percent) reported specific activities to follow the intent of the
provisions of the Equal Access to Justice Act, up from, 18 programs in 1996. The
purpose of this Act is to provide certain parties who prevail over the Federal
government with covered litigation in an award of attorneys' fees and other expenses
under appropriate circumstances. Specific actions include the routine review of
SBTCP documents for compliance (the most common activity, conducted by 34
programs), the provision of technical assistance to groups aggrieved by permit actions
of a regulatory agency, and the establishment of pro bono legal services.
4-14
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SBTCP actions to follow the intent of the provisions of the Equal Access to Justice
Act are shown in Table 4-TO and detailed, by program, in Appendix E-15.
TABLE 4-10
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE EQUAL ACCESS TO JUSTICE ACT
Activity
Reviewing of documents
for compliance
Providing technical assistance for groups aggrieved by
regulatory actions
Offering pro bono legal services
Other
# Programs
34
17
1
3
% Programs
64
32
2
6
4-15
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5.0 PROGRAM EFFECTIVENESS
External assessments of the SBTCPs' program effectiveness are reviewed in this
section. Comments regarding the SBTCP are discussed in Section 5.1. Concerns or
other inquiries received by SBTCPs and resolution strategies are presented in Section
5.2. Finally, program highlights and accomplishments are found in Section 5.3.
5.1 COMMENTS RECEIVED ON SBTCPs
Thirty-eight programs (72 percent) reported that comments were received regarding
their programs. Comments were overwhelmingly positive, generally expressing
appreciation for the availability of services and the way in which these services were
provided. A detailed synopsis of comments received by the programs is presented
in Appendix F-1.
Common themes repeated by small business clients of numerous programs include:
• Pleasant surprise to get knowledgeable, responsive, and pleasant service from
a government agency.
• Expressions that SBTCP services filled an existing need in the small business
community for personalized guidance through the many regulatory processes
involved in compliance. Many small businesses cited specific SBO/SBAP staff
members for their dedicated and professional service.
• Relocating and start-up businesses found SBTCP services especially helpful.
5.2 CONCERNS/INQUIRIES RECEIVED AND RESOLUTION STRATEGIES EMPLOYED
SBTCP staff members fill an important role as facilitator or mediator between small
business owners/operators and regulatory agencies, enhancing communication to
promote understanding and sensitivity on both sides. Based on information reported,
most problems seem to be resolved when businesses have someone to turn to for
non-regulatory assistance, advice, and effective liaison with regulatory agencies.
Information was requested about concerns or inquiries raised by small business
representatives and how these issues were resolved. Lessons learned by one
program can be shared with other programs, which thereby can benefit from these
experiences.
5-1
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Twenty-five programs {47 percent) provided examples of inquiries received and
resolution strategies employed. Major themes of the issues reported have not
changed significantly from the last reporting period.
• Lengthy amount of time for permit approval.
• A need for improved communication between businesses and regulatory
agencies.
• Requests for simplified forms and procedures.
• Confusion by small business as to which regulations applied to them, how
these regulations affected their specific operations, and how they can be met
in a time- and cost-effective manner.
• The need for specialized one-on-one assistance for identifying and completing
paperwork associated with regulatory requirements and submitting it on
schedule.
• The need for flexibility in applying regulations to small businesses (e.g., the use
of general permits, amnesty programs, exemptions).
* Overwhelming number of regulations.
* Desire for financing assistance programs.
Resolution strategies (for the above issues) similar to those noted last year were
employed and typically involved SBTCP personnel:
* Providing "plain English" explanations of regulatory requirements.
* Giving one-on-one guidance through the paper work processes.
• Facilitating communication about flexibility and compliance assistance issues
between businesses and regulatory agencies.
• Investigating, developing, or institutionalizing financial assistance programs.
• Working with regulatory personnel to ensure consistent answers to inquiries
and consistent application of enforcement actions.
Specific issues addressed by the SBTCPs and resolution strategies taken to address
small business concerns are presented in Appendix F-2.
5-2
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5.3 PROGRAM HIGHLIGHTS AND ACCOMPLISHMENTS
Forty-one SBTCPs (77 percent) reported on important accomplishments, awards, and
recognitions for their work with the small business community.
The SBTCPs continue to facilitate dialog and improve trust between the regulatory
agencies and small businesses. Many programs have forged strong partnerships with
such groups as trade associations, small business development centers, and small
business associations to broaden outreach efforts to the small business community.
Many states also have developed industry-specific initiatives that include compliance
manuals, workshops, and on-site visits.
In this section, key accomplishments are highlighted based on the frequency in which
they were mentioned. An overview of program accomplishments and highlights for
1996 are provided in Appendix F-3.
1. Forging partnerships with other organizations and agencies was mentioned by
30 programs (57 percent) as being a significant accomplishment.
• Florida's SBAP is actively developing partnerships with Small Business
Development Centers to expand outreach efforts to as many small
businesses, new or established, about all environmental regulatory
requirements.
• Kansas' SBO developed an interagency workgroup comprised of the
Small Business Association, Small Business Development Centers, the
Kansas Department of Commerce, the Kansas Department of Human
Resources, the Kansas Department on Aging, the Secretary of State,
and other agencies that work with businesses.
• Maryland's SBAP cooperated in developing the Maryland Green Printers
Initiative with the Printing Industries of Maryland , EPA Region III, the
Environmental Project at Catonsville Community College, and Maryland
Department of the Environment's P2 Program.
• Over a two year period in Virginia, a committee composed of the
Department of Environmental Quality central office staff from permit
assistance and the small business/air toxics sections, DEQ regional
permitting staff, and representatives from several major furniture
manufacturers and the American Furniture Manufacturers Association
developed a model Title V permit.
5-3
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3.
Improved synergy between the regulatory agency and small business was
noted by 26 programs (49 percent).
• The Texas SBAP expanded its EnviroMentor program, a volunteer effort
of environmental professionals coordinated through the SBAP. To date,
the 50+ volunteers have saved businesses $15,717.50 through 18 site
visits.
* The California ombudsman's office responded to over 300 help-line calls
and over 900 e-mail inquiries. The office routinely investigated and
resolved stakeholder concerns. Customer service is emphasized,
tracking a particular individual's request to its conclusion and ensuring
the individual is satisfied.
• Connecticut's CAP and SBAP had great success in working with the
metal finishing association on how to achieve compliance. Contacts
between CAP members and industry were key in establishing a
relationship for meaningful dialogue.
• Georgia's SBAP mailed a dry cleaning brochure to 1,000 facilities
requesting perc usage data, offering videos for training, and notifying
them of upcoming compiiance inspections. The SBAP received over 200
requests for videos and information of perc use. The SBAP also mailed
letters to hard chromium users reminding them that the notification of
compliance status form was due on 2/24/97. All hard chromium users
responded and are in compliance.
Sponsorship of or making presentations at workshops and forums was
highlighted by 20 programs {38 percent).
• The Illinois SBAP coordinated degreaser workshops, dry cleaner town
hall meetings, a Green and Profitable Printing teleconference, a dry
cleaner survey of compliance assistance effectiveness, and the Southern
Illinois Environmental Managers Association annual conference.
• Michigan's SBAP presented a series of New Source Review (Permit to
Install) workshops focusing on applicability and how to fill out the Permit
to Install application. The workshops were developed and delivered by
SBAP staff.
• Pennsylvania's CAP chairperson represented small business perspectives
on air quality issues, including CAP activities, on these occasions:
testified before the U.S. Senate in April 1997, interviewed by CBS
Evening News in June 1997, and testified before the U.S. House of
Representatives in October 1997.
5-4
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4. Sixteen programs (30 percent) were pleased with the publication of various
documents.
• Colorado sent out 900 dry cleaner books and letters to further assist dry
cleaners understand requirements. Helped create guidance documents
for chrome plating with information for inspectors, permit writers, and
sources.
• Iowa's program published the "Air Emissions Guide for Chromium
Electroplaters," "Resource Guide to Small Business Air Emissions
Assistance," and "112(r) Applicability Guide."
• Minnesota's SBAP coordinated the development of a comprehensive
multimedia guide for automotive repair and body shops. The
"Environmental Guide for Automotive Service Providers" contains fact
sheets and self-audit checklists on regulatory requirements and P2
opportunities for the subject business sector.
• Utah developed forms and documents for small source permitting,
including the registration form, a brochure explaining the new rule, and
emission estimate guides for criteria pollutants and hazardous air
pollutants. These guidance documents have been developed for
printers, wood furniture finishers and refinishers, and auto body.
5. Nine programs (17 percent) reported work on multimedia projects or moving
their whole assistance program to multimedia leadership.
• Kentucky's program initiated meetings with the Natural Resources and
Environmental Protection Cabinet to evaluate the program and
emphasize the need for a multimedia small business assistance program.
• Maine helped to develop and implement the "Environmental Leader"
program, a multimedia compliance assistance program for gasoline
stations and associated automotive repair facilities.
• Nebraska's Department of Environmental Quality is very proactive in
developing a balanced approach to compliance assistance and
enforcement. The agency has provided the Public Advocate with
technical assistance in all areas. This assistance has made the SBAP a
true multimedia program.
• North Carolina's newly established Environmental Permit Information
Center provides multimedia information 6n permit requirements, key
contacts for specific permitting programs, and other advice to clients.
5-5
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6.0 COMPLIANCE ASSURANCE ISSUES
EPA's Office of Enforcement and Compliance Assurance (OECA) requested
information on the effectiveness of the SBTCPs in providing compliance assistance
to small businesses. Common compliance problems are discussed in Section 6.1P
improvements in regulatory understanding and compliance are detailed in Section 6.2,
and recommendations to facilitate compliance are outlined in Section 6.3. Program
confidentiality issues are outlined in Section 6.4.
6.1 COMMON COMPLIANCE PROBLEMS
Fifty-one SBTCPs (96 percent) provided insight on the types of compliance issues
addressed during the course of providing technical assistance to small businesses.
Common compliance problems, listed by decreasing occurrence for 1997, are shown
in Table 6-1 and are compared with responses from 1996 and 1995; responses for
1997 are detailed, by program, in Appendix G-1. (Responses from the ten county/air
board programs that also answered this question are included in the appendix.)
6-1
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TABLE 6-1
COMMON COMPLIANCE PROBLEMS
Compliance Problem
Not understanding regulatory
requirements
Uncertain how to determine
emission inventories/lack of
technical expertise
Uncertain how to complete
forms/complicated paperwork
Incomplete recordkeeping
Fear of arbitrary regulatory
enforcement/regulatory
agency
Operating without a permit
Uncertain of permitting
requirements
Financing for pollution control
requirements
Improper storage/disposal of
hazardous waste
Operating outside NSPS or
MACT
Failure to use or finding
proper equipment/technology
to comply with applicable
standards
Other
1997
*
Programs
49
45
44
42
42
39
37
31
29
23
12
5
%
Programs
92
85
83
81
81
74
70
58
55
43
23
9
1996
*
Programs
28
12
10
16
6
26
14
10
7
10
6
%
Programs
53
23
19
30
11
49
26
19
13
19
11
1995
*
Programs
22
5
4
8
3
19
17
5
4
4
%
Programs
42
9
8
15
6
36
32
9
8
8
Examples of less frequently-cited compliance concerns as identified by small
businesses and programs are shown below.
• Language barriers (non-English).
• Failure to understand how to comply when two regulations from the same or
different agencies conflict.
• Failure to understand the universal waste regulations.
* Failure to accurately complete the Toxics Release Inventory Report.
* Lack of P2 knowledge.
6-2
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Compliance issues have remained consistent from year to year. Identifying key
*
problems and gaps in understanding by the small businesses have helped the SBTCPs
to best target their assistance efforts.
6.2 IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Programs reported on improvements in understanding and awareness of regulatory
requirements, behavioral changes, and environmental improvements (if tracked) that
they fee! have resulted from their compliance assistance activities.
Fifty programs (94 percent) provided insight as to improvements in regulatory
understanding and compliance. The most common responses, listed by number and
percentage of programs for 1997, 1996 , and 1995, are provided in Table 6-2 and
are detailed, by program for 1997, in Appendix G-2. (The appendix also includes
responses from the ten county/air board programs that also responded.)
TABLE 6-2
IMPROVEMENTS IN REGULATORY UNDERSTANDING
Response ,_
More open communication
between sources and
agencies
Greater
understanding/awareness of
regulations
Increased compliance
Reduced apprehension of
regulatory agencies and
environmental compliance
Better recordkeeping
Improvements in pollution
prevention practices
Increased registration and
permitting of existing
sources
Other
1997
#
Programs
46
46
43
39
37
36
35
3
%
Programs
87
87
81
74
70
68
66
6
1996
#
Programs
30
18
20
12
4
10
11
%
Programs
57
34
38
23
8
19
21
199S
#
Programs
26
20
23
18
5
5
5
%
Programs
49
38
43
34
9
9
9
6-3
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Generally, SBTCPs report that businesses want to comply with environmental
regulations; however, they may be afraid to ask for assistance. When a non-
threatening assistance program, such as the SBTCP, is available, small businesses are
most anxious to take advantage of the services. The SBTCPs have offered important
one-on-one contacts, which have provided valuable information to those who were
previously unaware of their compliance requirements. Such information included: the
need to have operating permits and how to obtain and complete them; the need to
maintain records; and information on available compliance options such as
reformulation, pollution prevention, or control equipment.
SBTCPs help small business understand how the regulations apply to their
operations/facilities and offer information on the available alternatives to achieve
voluntary compliance. Two of the most common compliance problems mentioned by
small businesses, "not understanding regulatory requirements", and "uncertain how
to determine emission inventories/lack of technical expertise", were represented
positively by facilities as compliments to program effectiveness, with programs
reporting "greater understanding and awareness of the regulations," and "improved
communication between sources and agencies." This indicates that the SBTCPs are
working to understand the small business community and provide quality service
where it is most needed.
All areas attributed to improvements in regulatory understanding showed strong
increases by doubling or tripling in the number of programs reporting improvements
from 1996 to 1997.
Texas devised a system to measure improvements in compliance and reported specific
improvements in compliance as a result of their outreach efforts to specific industry
sectors and reported the following results:
• Foundries -41 percent increase in air issues (to 87 percent) and 18 percent
increase in waste issues (to 92 percent).
• Dry Cleaners - 18 percent increase in air issues (to 87 percent) and 18 percent
increase in waste issues (to 92 percent).
* Auto Body - 13 percent increase in waste issues (to 96 percent).
6-4
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Texas notes that the responses from callers and from questions at workshops indicate
an improving level of environmental knowledge. Assistance is requested concerning
application of various rules rather than, "rules, what rules?" questions.
In general, programs are reporting an increased level of trust and awareness by the
small business community. Their knowledge of environmental issues and regulations
is steadily improving, and the inquiries made to the programs are becoming more
sophisticated.
6.3 RECOMMENDED CHANGES TO FACILITATE SMALL BUSINESS COMPLIANCE
WITH THE CAA
Recommendations made by 42 SBTCPs for changes, at the state or federal level, that
would help small businesses comply with the CAA are summarized in Table 6-3.
SBTCP staff members are uniquely qualified to make such recommendations, since
they address current CAA compliance problems encountered by small business and
attempt to provide effective solutions. Specific program responses may be found in
Appendix G-3.
6-5
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TABLE 6-3
1997 SBTCP RECOMMENDATIONS FOR IMPROVING COMPLIANCE
Recommendation
Allow flexibility/simplification in applying regulations to small
businesses
Multimedia pollution control and compliance assistance
Increased funding/continued adequate funding for SBTCPs
Mechanisms for financing pollution control equipment
Generic outreach and training materials
Expand/facilitate effective communication between state and federal
agencies
Simplify paperwork/reporting requirements
# Programs
15
14
14
11
8
7
7
% Programs
28
26
26
21
15
13
13
Forty-two programs (79 percent) provided at least one recommendation for changes
to improve small business compliance with the CAA. Priority of responses for 1997
parallel those of 1996.
Allowing flexibility and simplification in applying regulations to small businesses was
mentioned by 15 programs (28 percent) as being the prime recommendation for
improving compliance. Another common recommendation stressed by 14 programs
(26 percent) involves the expansion of technical assistance into a multimedia effort,
addressing small business concerns about groundwater, soil, and hazardous waste
issues. Many states have already expanded their programs to encompass multimedia
assistance or are planning to do so in response to small business requests.
The third most common recommendation, also mentioned by 14 programs, was for
continued and increased funding for the state SBTCPs. As previously noted, a
number of states operate with limited budgets and staffs. The personalized approach
to technical and compliance assistance has been shown to be effective in reaching
the small business community, and 26 percent of state programs believe that
adequate financial resources are vital to continued and expanding high quality service.
6-6
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6.4 PROGRAM CONFIDENTIALITY AND CONFLICT OF INTEREST
In early 1995, EPA's SBO worked with the SBTCPs and EPA's Office of Enforcement
and Compliance Assurance to reach an agreement regarding the confidentiality of
assistance provided to businesses via the SBTCP.
Programs were asked how they avoid conflicts of interest (COI) and maintain
confidentiality, particularly in those cases where the SBAP is located within the
regulatory agency.
Forty-five programs (85 percent) reported no problems with COI or confidentiality
issues regardless of whether a confidentiality policy is in place. Seven programs did
not respond to the question, and only one program indicated it is working to avoid the
perception of COI.
Program structures range from guaranty of confidentiality (more common) to
providing no confidentiality. For example, assistance programs may be housed in
non-regulatory departments, or a program may refer a business in need of technical
assistance to such a provider that will guaranty confidentiality. Most programs
provide for confidentiality of trade secrets. Many programs have policies that protect
small businesses from penalties if violations are discovered during the course of their
receiving technical assistance. Program responses to the issue of COI and
confidentiality may be found in Appendix G-4.
The following example responses reflect the range of COI issues and resolutions (from
having an established confidentiality policy to having no such policy).
• in Idaho, this hasn't been a big problem (at least it hasn't been expressed).
The agency, as a whole, is working on showing businesses that we are there
to assist them in compliance. We are taking a more proactive approach to
problem solving. Confidentiality isn't something we have tried to maintain.
We are more concerned with trust, so we don't guarantee something we can't.
• Louisiana law prohibits the SBAP from operating in a confidential manner. We
do not voluntarily give any information regarding small business activity. Over
the last five years, the program has developed a reputation of trust among the
small business community, so that the lack of professed confidentiality has not
been a drawback to the program.
6-7
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New Hampshire's SBO/SBAP offers smalt businesses several options when
dealing with confidentiality. State laws have been passed, which grant
businesses audit privilege for self-audits and confidentiality when accessing
assistance programs. In addition, businesses can take advantage of the EPA
Small Business Compliance Incentives Policy for enforcement protection.
Nevada's SBAP operates separately and independently from the enforcement
group of the agency. The Department of Environmental Protection director has
given strong assurances that the confidentiality of all assistance programs shall
be respected.
6-8
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APPENDIX A
1997 ANNUAL REPORTING FORM
-------
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STATE SMALL BUSINESS STATIONARY SOURCE
TECHNICAL AND ENVIRONMENTAL COMPLIANCE
ASSISTANCE PROGRAM (SBTCP)
ANNUAL REPORTING FORM
FOR THE PERIOD 1/1/97 TO 12/31/97
OMB NO.: 2060-0337
EXPIRATION DATE: 7/31/98
INSTRUCTIONS FOR COMPLETING THIS FORM
Enclosed is a blank copy of the Annual Reporting Form for the State Small Business Stationary Source
Technical and Environmental Compliance Assistance Program {SBTCP}. The questions are the same as
those asked last year, but the format in which you can answer certain questions has been adjusted to
mirror the current reporting format in the Report to Congress and to make reporting easier for you. To
streamline the reporting, this Form is designed to collect standardized information on each of the three
components of the SBTCP, listed below, in a single document.
• Small Business Ombudsman (SBO)
• Small Business Assistance Program (SBAP)
• Compliance Advisory Panel (CAP)
The period of time covered by this report is January through December 1997.
For your convenience, electronic copies of the form are provided on the enclosed disk in WordPerfect
(SBTCP97.WP) and Microsoft Word (SBTCP97.DOC). Information previously requested in Table 3-1 is not
being requested this year.
Please record your complete answers to each question on the Reporting Form. Please do not answer
questions by referring to attached documents or previous SBTCP reports. Then, please return the disk and
a completed hardcopy of the Repotting Form using the enclosed, pre-addressed mailer.
If this mailer is missing, please return the disk and a completed hardcopy to:
Ms. Karen V. Brown
Small Business Ombudsman
U.S. Environmental Protection Agency (2131)
401 M Street, SW
Waterside Mall, Room 3423
Washington, D.C. 20460
ATTN: SBTCP Annual Report
If you use your own mailer, please include on the mailer the words, "Electronic Media Enclosed."
Completed forms are due by February 15,1998.
If you have any comments or questions regarding this form, please contact the U.S. EPA Small Business
Ombudsman (EPA SBO) at the numbers listed below. Please note that the telephone and facsimile numbers
are new! The SBO can be reached Monday through Friday from 8:30 a.m. to 5:00 p.m. (EST). After these
hours, messages can be left on an answering machine, which is connected to the toll-free 800 number.
(202) 260-0490 (Telephone)
(800) 368-5888 (Toll-free Hotline)
(202) 401 -2302 (Facsimile)
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WHY ARE WE REQUESTING THIS FORM?
As part of the Clean Air Act CAA as amended in 1990, the U.S. Congress included, as Section 507, the
requirement that each state establish a Smalt Business Stationary Source Technical and Environmental
Compliance Assistance Program (SBTCP) to assist small businesses in complying with this Act.
As part of its normal reporting requirements to Congress, EPA will also provide the Congress with a report
on the SBTCP program, including overall effectiveness, difficulties encountered, and the degree and
severity of enforcement. EPA has internally delegated responsibility for completion of this report to its
Small Business Ombudsman (EPA SBO).
The EPA SBO intends to use the information contained in this Form, as reported by the states, to prepare
the Report to Congress, including the need for such technical assistance programs and how they should
be changed, if necessary. The goal of this Form is to standardize the information reported by the state
SBTCPs.
Any suggestions or recommendations to improve this reporting format would be appreciated. Please feel
free to contact EPA's SBO to discuss any recommendations using the address and telephone numbers
listed on page 1 - Please note that the Reporting Form is being revised for the 1998 reporting year and will
go through the OMB review process.
SUGGESTIONS FOR COMPLETING THIS FORM
• Gathering information for this report is definitely a team effort! You may wish to provide hard
copies of this form to key contacts from the SBO, the SBAP, and the CAP, and indicate who will
be responsible for the various parts of the report. Once all information is collected, one person
should take responsibility for completing and submitting this form (most likely the SBO).
• We are looking to collect objective information on each state SBTCP. This report is not meant to
be an evaluation of any facet of your program.
• We are seeking information you should be already collecting for you own purposes. We are not
asking you to create information you do not have. If a question asks for information you do not
have, please provide a brief explanation as to why the information is not available.
• You may wish to refer to last year's Report to Congress and the information you provided on your
Reporting Form last year when completing this year's Reporting Form.
• For future reports, you are encouraged to continually gather your statistics during the reporting
period. Based on the information requested in this Form, you may need to revise the types of
statistics you track for your SBTCP for subsequent years.
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SECTION 1
SOURCE OF THE INFORMATION
This section is designed to collect standardized information about the state SBTCPs completing this Form,
and whom to contact if we should have any questions.
1.1 Name of state or territory for which this report is being submitted.
1.2 Period of time (calendar year) covered by this report.
1997
1.3 Who should be contacted (primary and alternate contacts) if there are any
questions regarding the information contained in this Form?
The most typical answer for this Question will be the CAP Chairperson or the state Small Business
Ombudsman, for the question 'Relationship to SBTCP', we would like to know the relationship
of that person to the SBTCP program (i.e., CAP Chairperson, SBO, etc.). Be sure to include the
area code for the telephone and facsimile numbers. Also include a telephone extension if
appropriate.
Name
Title
Relationship to SBTCP
Organization
Address
Address
Chy, State, Zip
Telephone Number
Facsimile Number
E-mail
PRIMARY CONTACT
ALTERNATE CONTACT
*
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SECTION 2
STATUS, BUDGETS, STAFFING, ORGANIZATION
This section is designed to collect four types of standardized information about your state's SBTCP:
Status, Budgets, Staffing Levels, and Organization. The information you provided in last year's report will
be helpful in answering the questions in this section.
STATUS
2.1 When was your SBTCP established?
Please note that in Question 2.2, we are asking when each component of your SBTCP actually
began to operate (provide services}, which may be different
SBTCP Component
SBO
SBAP
CAP
Month and Year of Establishment
2.2 When did the SBTCP begin to provide operations (month and year)?
To be consistent, for the SBO, indicate the effective date (month/year) of appointment; for the
SBAP, indicate the date (month/year) it began providing assistance to small businesses; and for
the CAP, indicate the date (month/year) of the first meeting — even if not all members of the CAP
were appointed by the time of the first meeting.
SBTCP Component
SBO
SBAP
CAP
Month and Year Operations Began
BUDGETS
2.3 Please provide summary information on the funding for each component of your
state's SBTCP (for the period January through December 1997). Please indicate
the source of funding.
For example, sources of funding might include: Title V fees, specific appropriation of state funds,
the operating budgets of existing programs, or some combination.
These budgets should include direct salaries, fringe benefits, materials & supplies, etc.
To keep it simple, please round your budgets to the nearest $5,000.
-------
SBO
SBAP
CAP
TOTAL
1997 BUDGET ($)
SOURCE OF FUNDING {please describe)
2.4 What was the SBTCP's budget in 1996? What is the expected SBTCP budget
during the next reporting period (January through December 1998)7
As with the previous question, please round all numbers to the nearest $5,000. If these programs
did not exist (or were not active} in 1996, please complete this Question with such words as,
'inactive * or 'did not exist. *
SBO
SBAP
CAP
TOTAL
1996 BUDGET <$)
1998 PROJECTED BUDGET <*)
2.5 Briefly describe any significant changes (more than 10%) in the level of funding
between the 1996, 1997, and 1998 annual budget periods.
For example, a previous period may have seen a high level of fines that were credited to the
SBTCP program; perhaps Title V revenues were lower than projected; or state appropriations may
have been reduced or eliminated.
STAFFING
With these questions, we are interested in knowing how many people are supporting each component of
your state's SBTCP.
2.6 How many people, measured as full-time equivalents (FTEs), support the SBO
function?
Please complete this question for the staffing levels that are current as of December 1997. An
FTEis considered to work 40 hours/week. For example, 2 people working 20 hours/week would
be equivalent to 1 FTE. It is possible that the SBO has other responsibilities and does not perform
this function on a full time basis. For example, if they perform this function approximately 20
hours/week for 50% of their time), this would be equivalent to an 0.5 FTE.
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SBO Function
SiO
Other staff
TOTAL STAFF
Number of FTEs
2.7 How many people, measured as full-time equivalents (FTEs). support the SBAP
function? How many of these people are paid or serve as (unpaid) volunteers?
How many of these people would be considered retired engineers?
Please complete this question for the staffing levels that are current as of December 1997. Use
the same definition for an FTE as discussed in Question 2.6, We are interested in knowing if the
states are utilizing unpaid volunteers as well as "retired engineer' programs (or their equivalent)
to support the SBAPs.
SBAP Staff
Paid
Unpaid Volunteers
Retired Engineers
TOTAL STAFF
Number of FTEs
2.8 How many people are currently serving on your CAP?
Please answer this question by indicating how many people have been appointed to your CAP as
of December 1997. Please indicate the affiliation of each CAP member (i.e., small business, state
regulatory agency, general public, etc.)
If appropriate, please indicate the number of people who have not been appointed to your CAP as
of December 1997.
When complete, this table should list a total of at least 7 people (including appointed and not yet
appointed).
AFFILIATION
Owner (or representative) of small business
State regulatory agency
General public
Not yet appointed
Other (please specify)
NUMBER OF PEOPLE ON CAP
V
6
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ORGANIZATION
2.9 Please briefly describe where each component of your SBTCP is
located/organized.
Please indicate if the component is located in a state regulatory agency, another state agency, a
university, etc. For example, in some states, the SBAP is located within the state regulatory
agency. If so, please list the name of the agency and the appropriate department, division, etc.
(for example: Department of Environmental Protection, Bureau of Waste Management). If your
state has subcontracted your SBAP to an outside company, please complete Question 2.11.
Generally, the CAP is independent and is located outside of all agencies, with each individual
appointed as defined in Section 507.
SBTCP COMPONENT
SBO
SBAP
CAP
BRIEF DESCRIPTION OF ADMINISTRATIVE LOCATION
2.10 Has management of the SBAP been contracted to an outside company?
If YES, please complete Question 2.11.
YES
NO
2.11 Who is the outside company that is operating your SBAP?
. For the section, 'Budget During the Current Reporting Period", please complete for the time period
January through December 1997. Please indicate (or estimate) the budget to the nearest $5,000.
Company
Address
Address
City, State, Zip
Telephone Number
Facsimile Number
Project Manager (or
principal point of contact)
1997 Budget
Term of Contract
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SECTION 3
SERVICES PROVIDED/ACTIVITIES CONDUCTED
This section is designed to collect standardized information about the type and level of services provided
by the three components of the state's SBTCPprogram: SBO, SBAP, and CAP. As YOU complete tfiis.
section, please seek assistance from the SBAP (primarily} and CAP.
3.1 Does your SBTCP have one or more information hotlines? Please enter the
appropriate telephone numbers into the chart below to indicate your response to
the following questions.
• Does your SBO/SBAP have an information hotline number? (If not, write
none.)
• Is the number toll-free?
• If toll-free, is the number accessible nationally or in-state only?
SBTCP
Component
SBO
SBAP
Toll-frM Hotline
National Access
In-state Only Access
Not Toll-free
3.2 Briefly describe the assistance services of your SBO and SBAP.
This year, we are asking for this information in a different format from previous years to simplify
and streamline the reporting process. (This question combines the old questions 3.2 and 3.3.) We
are interested in compiling statistics on the types of assistances and number of people/businesses
reached through a variety of assistance services by the SBO and SBAP.
A list of activities is sufficients however, the number of occurrences of these activities when
available, is preferred (e.g., 12 speaking engagements reaching 160 people; 3 training seminars
reaching 72 participants; preparation and distribution of 8 industry-specific brochures, 500 copies
of each).
To help you in completing Ms question, the following table is provided in which you can list the
number of occurrences and the number of people reached, if those statistics are available. If you
only track whether these activities occurred (and not the specific number of occurrences), please
simply indicate 'YES' in the 'NUMBER OF SERVICES PROVIDED ' column.
If you tally statistics separately for your SBO and SBAP, please complete Table A, which follows.
If you combine your statistics for your SBO and SBAP, please complete Table B.
For help in filling out the table, please refer to the following partial sample of Table A.
NOTE: If available, please include a list of documents, that were prepared and distributed by your
SBTCP during the 1997 reporting period.
8
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£
I
I
8
is
-------
\
o
111
S
i
*
I
*
-
CO
o
il
!
I
1
t
s
-------
Number of Service* Provided / Number of Parsons or Businesses Reached II
| TABLE 8
«•!
BB 1
— '
9
Si
s
«
1
1
i
1
s
Seminara,
Workahopa.
Spaaking Eventa
3
|
1
^^—^S^^H-
— —
Combined
Program
Regulatory
1
formati
Booths
i
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3.5 Do SBTCP services include an electronic bulletin board or Internet home page?
If YES, what is the address of the bulletin board or home page?
If your SBAP has an electronic bulletin board or home page, obese indicate, if available, its level
of usage (i.e., how many times was it accessed during the 1997 reporting period)?
Please list the information that is accessible through this bulletin board or home page.
To make it easy to complete this question, the table below lists some possibilities. Please add
additional items as appropriate.
Information Available Through
the Bulletin Board or Home Page
Program description
Contact listings
Copies of regulations
Permitting information
Permit forms
Emission inventory
Policies
Guidance documents, fact sheets, etc.
Information on P2 options
List of available publications
CAP information
Calendar of events
Links to related sites
Other (please list)
Please check all
appropriate boxes
^
12
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Was it helpful to its users?
With this question, we are asking if you have received ANY comments from the bulletin board or
homepage users. Please indicate if any component of the SBTCP is soliciting feedback from users
as to information/topics they would like to see on the bulletin board or homepage.
COMPUANCE ADVISORY PANEL
3.6 What were the major activities of the CAP during this reporting period?
To make it easy to complete this question, the table below lists some possibilities. Please add
additional items as appropriate.
Major CAP Activities
Review of documents for readability and/or content
Appointment/hiring of staff and/or election of officers
Review/advisement on SBO/SBAP outreach activities
Review/comment on new/proposed regulations
Defining CAP responsibilities
Attendance by CAP members at training sessions
Meeting with small businesses/associations
Other (please list)
Please check all
appropriate boxes
3.7 Please indicate the number of meetings that occurred between the SBO, SBAP,
and CAP during the 1997 reporting period.
We are interested in comparing how much communication occurred between the different
components of each state SBTCP during the 1997 reporting period, and if these were regularly
scheduled or occasional meetings.
To make it easy to complete this question, the table below lists all possible combinations of
meetings between these groups. For the question of 'Frequency*, please indicate if the meetings
between these groups are regularly scheduled (i.e., monthly, quarterly, or biannuallyl, or
occasional.
13
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MEETINGS BETWEEN
WHOM
SBOandSBAP
SBO and CAP
SBO and CAP and SBAP
SBAP and CAP
NUMBER OF
MEETINGS DURING
THE REPORTING
PERIOD
FREQUENCY
(Pleas* indicate if monthly, quarterly,
biannually, ate.)
OTHER SERVICES/CONDUCT OF ACTIVITIES
3.8 Does your state have or is your state planning a grant or loan program?
Please indicate if your state has or is planning a financial assistance program to help small
businesses comply with the requirements of the CAA.
YES
NO
If YES, please indicate the data (month/year) such a grant or loan program became/will become
available and the funding levels for each.
DATE
AVAILABLE
NAME OF GRANT OR LOAN PROGRAM
FUNDING LEVEL
14
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3.9 Briefly describe how each component of the SBTCP (i.e., SBO, SBAP, and CAP)
leverages existing personnel resources (within the state).
This question is critical to understanding how some states, with limited budgets and resources
(typically with the SBAP and SBO components) are functioning. For example, have personnel from
any other departments been assigned to assist with the program?
SBTCP COMPONENT
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
3.10 How does your state SBAP avoid duplication of efforts with SBTCPs in other
states?
With this question, we are hoping to find out to what extent states are sharing/exchanging
information with SBTCPs in other states. For example, what factsheets or information packets
were developed by another state and used {with minimal editing) in your state? To make it easy,
please check all appropriate strategies listed below.
Strategy to Avoid Duplication of Efforts
Communication/networking within own SBTCP and state
agency personnel via phone, e-mail . mailing lists, etc.
Meetings, conference calls, and other contacts with SBO/SBAP
personnel within EPA region
Networking through state or regional air group meetings (such
as WESTAR-Westem States Air Resources)
Review of EPA documents/contacts with EPA
Review of documents from other public, private, and/or
university sources
Information gathering from electronic sources
Subscribe to SBO listserve or government ombudsman listserve
Other (please list)
Please check all
appropriate boxes
15
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3.11 Please indicate what actions were initiated by your SBTCP/CAP to follow the
intent of the provisions of the Paperwork Reduction Act, the Regulatory Flexibility
Act, and the Equal Access to Justice Act.
One of the responsibilities of the CAP is to critique tftc SBTCP in following the intent of the
provisions of these three federal acts. To make it easy to complete this Question, various
possibilities for each Act are listed in the tables below. Please add additional items as appropriate.
PAPERWORK REDUCTION ACT
Routine review of SBTCP documents for compliance
Receiving/providing information electronically
Simplified/consolidated permits or forms
ciirranaiing unnecessary pennies oy utmeosiim BAenipuons tor
insignificant actions
.
General permits for certain types of industries
Concise, easy-to-raad summary documents
Other (please list)
Please check all
appropriate boxes
•
REGULATORY FLEXIBILITY ACT
Routine review of SBTCP documents for compliance
Simplified/consolidated permits or forms
Eliminating unnecessary permits by increasing exemptions for
insignificant actions
Amnesty program
Review/comment of new air regulations
Other (please list)
Please check all
appropriate boxes
EQUAL ACCESS TO JUSTICE ACT
Routine review of SBTCP documents for compliance
Pro bono legal services
actions
Other (please list)
Please check aH
appropriate boxes
16
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SECTION 4
PROGRAM EFFECTIVENESS
The questions in tfi/s section are designed to collect some external assessments of the SBTCP's program
effectiveness and how it is providing a useful service.
We suggest that the questions in this section be completed by either the SBO or the CAP.
4.1 What were some comments (positive or negative) received by the SBO or the CAP
on the SBTCP?
To answer this question, we are looking for comments that the SBO or CAP may have received.
Additionally, you might wish to attach copies of relevant letters, memos, etc. that your office
received.
4.2 What was the nature of the complaints received/initiated by the SBO or the CAP,
and how were they resolved?
By collecting some representative information on the type of complaints received and how they
were addressed, we believe that there may be some lessons learned that could be shared with
other state SBTCPs.
COMPLAINTS
RESOLUTION OF COMPLAINTS
17
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4.3 Please feel free to include any information about your program that you would like
to highlight (i.e., significant accomplishments, awards, recognitions, etc.)
To answer this question, please invite the SBO, SBAP, and the CAP to include any information they
believe is appropriate. Use as much space as necessary.
18
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SECTION 5
COMPLIANCE ASSURANCE
The first three questions in this section have been included at the request of EPA's Office of Enforcement
and Compliance Assurance (OECA).
5.1 What is the total number of eligible facilities identified by your program, by
industry sector, that have received assistance by your program from January
through December 1996?
NOTE: An eligible facility is defined as a stationary source that: (1) is owned and operated by a
person that employs 100 or fewer individuals; (2) is a small business concern as defined by the
Small Business Act; (3) is not a major stationary source; (4) does not emit 50 tons or more per year
of any regulated pollutant; and (5) emits less that 75 tons per year of all regulated pol/utantsj
Please distinguish between general assistance and on-site assistance. What percentage is this of
the total eligible pool of facilities? Please photocopy the table on the next page if additional space
is needed.
INDUSTRY
SECTOR
Example:
Dry Cleaners
A
#OF
GENERAL
ASSISTANCE
71
B
#OF
ON-SiTE
ASSISTANCE
14
C
TOTAL # OF
FACILITIES
ASSISTED
(A+B)
85
-
D
#OF
ELIGIBLE
FACILITIES
IN YOUR
STATE
400
•
E
%OF
TOTAL
ELIGIBLE
POOL OF
FACILITIES
(C/DJ'100
21%
19
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INDUSTRY
SECTOR
A
#OF
GENERAL
ASSISTANCE
B
#OP
ON-S1TE
ASSISTANCE
C
TOTAL # OF
FACILITIES
ASSISTED
(A + B)
D
#OF
ELIGIBLE
FACILITIES
IN YOUR
STATE
E
%OF
TOTAL
ELIGIBLE
POOL OF
FACILITIES
(C/D)*100
20
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5.2 What are the most common compliance problems identified fay the facilities?
In the course of providing technical assistance, what have been the most common compliance
issues addressed? Examples of compliance problems may include incomplete reports, lack of
permits for new equipment or changes in processes, operating outside of MACT standard, or
unpermitted emissions. Please indicate if certain problems are prevalent in any particular industry
sector, A number of possible answers are listed below. Please check all those appropriate.
Common Compliance Problem*
Not understanding regulatory requirements
Operating without a permit
Incomplete recordkeeping
Uncertain of permitting requirements/need for multiple permits
Uncertain how to determine emission inventories/general lack of technical
experience
Uncertain how to complete forms/complicated paperwork
Lack of financing for pollution control equipment/technologies
Operating outside NSPS or MACT
Improper storage/disposal of hazardous waste
Fear of regulatory agency/arbitrary regulatory enforcement
Failure to use or find the right equipment to comply with applicable
standards
Other (please list)
Please check all
appropriate boxes
Please add any additional comments you have regarding common compliance
problems.
21
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5.3 What have been the improvements in understanding and awareness of regulatory
requirements, behavioral changes, and environmental improvements (if tracked)
that have resulted from your compliance assistance activities?
From the perspective of the SBAPand SBO, what changes have you seen in businesses as a result
of your technical assistance activities? Do you see a relationship between your activities (on-site
consultations, hotline, seminars, publications, etc.) and improvements in compliance? Please use
as much space as necessary.
Improvements in Compliance as a Result of
Compliance Assistance Activities
More open communication between sources and regulatory agencies
Increased compliance
Greater understanding of the regulations
compliance
Increased registration/permitting of existing sources
improvements in pollution prevention practice*
Better recordkeeping
Other (please list)
Please check all
appropriate boxes
Please add any additional comments you have regarding improvements in
compliance.
22
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5.4 What changes would you recommend, at either the state or federal level, to assist
small businesses to comply with the CAA?
Please list any suggestions you have. We intend to compile the list of recommendations and
highlight these in the report to Congress,
23
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5.5 Briefly describe how the SBTCP avoids internal or external conflicts of interest
(COD or perception that this program may not be confidential. Briefly describe
any issues that may have developed and how they were resolved.
In early 1995, EPA's SBO worked with the SBTCPs and EPA's Office of Enforcement and
Compliance Assurance to reach an agreement regarding the confidentiality of assistance provided
to businesses via the SBTCP.
V\fith this question we are interested in knowing how the states are avoiding COI and maintaining
confidentiality - particularly in those cases where the S8AP is located within the regulatory
agency.
This is the end of the 1997 SBTCP Annual Reporting Form. Thank you. and all
contributors, for the completeness and accuracy of your state's Report. A copy of the
EPA 1997 Report to Congress will be provided upon its submrttal.
24
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APPENDIX B
t>
FEDERAL SMALL BUSINESS OMBUDSMAN
-------
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APPENDIX B
OFFICE OF THE EPA SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
401 M STREET, SW (2131)
WATERSIDE MALL, ROOM 3424
WASHINGTON, DC 20460
800-368-5888
202-260-0490 {in DC area)
202-401-2302 (fax)
The Office of the Small Business Ombudsman serves as an effective conduit for small
businesses to access EPA and facilitates communications between the small business
community and the Agency. The Office reviews and resolves disputes with EPA and works
with EPA personnel to increase their understanding of small businesses in the development
and enforcement of environmental regulations.
The SBO's primary customer group is the nation's small business community. Significant
secondary customer groups include state and EPA regional small business ombudsmen and
national trade associations serving small businesses.
In response to the identified needs of the Office's target customer groups, the SBO has
undertaken a variety of major outreach efforts including:
* Serving as liaison between small businesses and the EPA to promote understanding
of Agency policy and small business needs and concerns.
• Staffing a small business hotline that provides regulatory and technical assistance
information.
• Maintaining and distributing an extensive collection of informational and technical
literature developed by the various EPA program offices.
• Making personal appearances as a speaker or panelist at small business-related
meetings.
* Interfacing on an on-going basis with over 60 key national trade associations
representing several million small businesses and with'state and regional ombudsmen
who serve businesses on the local level. Also in contact with over 400 additional
national organizations that represent millions of small businesses.
• Providing guidance on the development of national policies and regulations that
impact small businesses.
The SBO actively seeks feedback on its responsiveness to small business' inquiries and ever-
evolving needs, primarily in the areas of technical assistance and advocacy. The SBO can
-------
"package" relevant information for the most effective and efficient delivery -- be it through
training seminars, fact sheets, or position papers ~ to its target audience.
Individual outreach activities are tracked and reported by the SBO on a monthly basis. Key
statistics include numbers and types of hotline calls and written inquiries; nature and results
of small business advocacy efforts; and personal appearances at conferences, seminars, and
training sessions. Random, informal quality checks of customer satisfaction ensures that
program performance meets or exceeds customer expectations.
The SBO also serves as the Agency's Asbestos Ombudsman. Information concerning
asbestos management may be obtained through the same toll-free hotline service as that
which serves small business needs.
SBO STAFF
EPA's Small Business Ombudsman is Karen V. Brown, who was appointed to this position
by Administrator Lee Thomas in 1985. In 1988, she was named the Agency's Asbestos
Ombudsman in addition to her small business duties. Ms. Brown has served the Agency
since 1981 holding a series of management positions. She is a graduate biologist and
chemist.
Robert C. Rose, an Industrial Engineer, joined the Office of Asbestos and Small Business
Ombudsman as Deputy Ombudsman in 1991. He has over 28 years of management service
with EPA.
Staff Assistants to the Ombudsman are James Malcolm, Chemical Engineer; Arnold B.
Medbury, P.E., Mechanical Engineer; Larry 0. Tessier, P.E., Civil Engineer; and Thomas J.
Nakley, Civil Engineer.
TOLL-FREE HOTLINE SERVICE
The Ombudsman operates a toll-free hotline for the convenience of small businesses, trade
associations, and others seeking access to the Ombudsman. A member of the
Ombudsman's staff will answer between 8:30 AM and 4:30 PM EST. Message-recording
devices for calls during non-business hours and overload periods are provided. All calls are
personally handled on a fast turn-around basis.
-------
The toll-free hotline number is:
800-368-5888
• 202-260-0490 (in DC area)
Callers request information on a variety of topics including:
Clean Air Act regulations
Underground storage tank notification
Small quantity generator requirements
Effluent standard guidelines
Used oil
Asbestos compliance
Waste minimization/pollution prevention
Pesticide registration fees
Increases in the number of direct-dial calls and hotline calls (from 4,000 calls per year in the
early 1980s to the current level of 1,000 - 1,500 calls per month) and the associated
distribution of technical and informational literature, growth in requests for personal
appearances at conferences and workshops, and an expansion in participation in policy-
making activities are evidence of the customer groups' confidence in the integrity and
proactive stance of the SBO.
REGULATORY TRACKING AND ANALYSIS
The SBO performs a careful review of all proposed regulatory actions published in the
biannual regulatory agenda to make a prima facia determination of small business impact.
From the agenda, certain proposed regulations are selected that appear to have the potential
for adverse impact on small businesses. In 1997, the SBO reviewed and/or monitored over
100 regulatory actions with some significant degree of intensity. In all instances, the SBO
endeavored to minimize the requirements (especially reporting and record keeping) on small
businesses. Equally significant is the level of voluntary compliance with EPA regulations by
the small business community as a result of the rapport established between the
Ombudsman and trade associations during the developmental phase of the regulations.
MAJOR INITIATIVES IN 1997
The SBO's efforts to assist the small business community continue at a high level. Key
accomplishments and activities for 1997 (some of which are on-going) include:
Hosted fourth National Small Business Ombudsman and Technical Assistance
Program Conference in Charleston, SC, which was attended by 43 states and 2
territories (167 participants). Set plans for a fifth conference in March 1998 in
Scottsdale, AZ.
-------
Developed external stakeholder guidance and acted as a principal participant in the
Agency's Eighth Regulatory Tiering (prioritizing) Process.
Served as principal role player in the development of a new EPA policy offering
compliance initiatives to small businesses in all media (e.g., waste, water, toxics).
Coordinated individual meetings and follow-up meetings among major small business
trade associations and the EPA Deputy Administrator and Assistant Administrators to
discuss small business issues.
Developed small business regulatory impact studies for several small business trade
associations. Preparing "look-back" regulatory impact study justification.
Participated as key player in the joint Small Business Administration and Office of
Management and Budget SBREFA Panel Process.
Finalized EPA's 1996 Small Business Ombudsman Report to Congress under Section
507 of the 1990 Clean Air Act Amendments.
Cooperatively managing the Small Business Regulatory Enforcement Fairness Act of
1996 Small Business Entity Outreach Sub-group to implement Act requirements.
Conducted Small Business Liaison Conference for EPA Regional Small Business
Representatives in August 1997.
Developing an EPA Small Business Ombudsman Internet home page.
Conducted a Compliance Advisory Panel Training and Networking Meeting in
Scottsdale, AZ on September 21, 1997.
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APPENDIX C
FEDERAL SMALL BUSINESS
ASSISTANCE PROGRAM
-------
-------
APPENDIX C
ERA'S FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM
The EPA provides technical guidance for the use of the states/territories in the implementation
of their programs. The Federal Small Business Technical Assistance Program (Federal SBAP)
is coordinated by the Information Transfer Group (ITG) of the Office of Air Quality Planning and
Standards (OAQPS). Other EPA programs participating in activities to assist the states include
the Office of Compliance, the Chemical Emergency Preparedness and Prevention Office, and
the Pollution Prevention Division.
ELECTRONIC ACCESS
The Federal SBAP is actively involved in expanding the use of electronic media as a tool for
access to EPA information by small businesses, state SBAPs, and the general public.
• The SBAP home page on the World Wide Web, part of the Technology Transfer
Network, provides access to EPA small business assistance information and materials.
Links to other small business-related sites also are provided. The SBAP home page
address is www.epa.gov/ttn/sbap. in 1997, users retrieved over 1,000,000 files from
the TTN.
• The SBAP home page serves as a communication link for state SBAPs and includes a list
of state and EPA small business program contacts. The home page also provides a
forum to share information and outreach materials developed specifically for small
businesses.
• The Office of Air and Radiation, Policy and Guidance home page, also part of the
Technology Transfer Network, contains proposed and final rules; background, guidance,
and plain-English fact sheets; and implementation strategy updates and schedules.
PLAIN ENGLISH GUIDANCE MATERIALS
The Federal SBAP prepares materials for use by the states to explain new EPA CAA rules in
plain English. These include detailed guidebooks with options for compliance, including
pollution prevention; sample reporting and recordkeeping forms; and example calculations.
These are distributed to state SBAPs as well as directly to small businesses; both hard copy and
electronic formats are provided to allow for state-specific customization and reproduction as
needed.
• Halogenated Solvent Cleaning (completed May 1995).
• Chromium Electroplating and Anodizing (completed May 1995).
• Wood Furniture (completed September 1997 - over 300 copies of this document were
downloaded from the SBAP home page in a three week period).
Work has started on guidance for Potential-To-Emit (PTE) to assist businesses with PTE
calculations. This document will be available in late 1998.
-------
SATELLITE SEMINARS
The Federal SBAP is working with EPA's Small Business Ombudsman (SBO) and OAQPS's
Education and Outreach Group to present a series of satellite downlink seminars to educate
small businesses on new EPA air regulations. These seminars include:
• Perc Drycleaners (May 1994) had 3,000 participants at 197 sites in 48 states, one
Canadian site, and two in Mexico.
• Halogenated Solvent Cleaning/Degreasing {May 1995) had 1,300 participants at 101
sites in 45 states, one site in Canada, and two in Mexico.
• Chromium Electroplating (November 1995) had 2,000 participants at 140 sites in 43
states.
* Green and Profitable Printing (May 1996) was presented in cooperation with EPA's
Office of Compliance through the Printer's National Environmental Assistance Center.
• Wood Furniture Manufacturing (September 1996) had approximately 1,900 participants
at 140 sites in 34 states.
• Consumer Products expected to be broadcast in late 1998.
ANNUAL CONFERENCE
EPA holds an annual SBO/SBAP Conference, which is co-sponsored by OAQPS's Federal SBAP
and the EPA SBO with participation by the Office of Compliance, the Pollution Prevention
Division, and the Chemical Emergency Planning and Prevention Office. The majority of the
conference planning and presentations was carried out by the states. The 1997 meeting was
held in Charleston, SC with 167 attendees from 45 states and territories, and six local agencies.
The purpose of this meeting was to:
• Facilitate communication among the state programs.
• Facilitate implementation and operation of small business assistance programs.
• Interpret regulatory and policy developments affecting small businesses.
• Share EPA activities and programs to assist state SBAPs.
OTHER PARTNERSHIP ACTIVITIES
The Federal SBAP is working with staff from EPA's Office of Policy, Office of Compliance, and
Pollution Prevention Division to determine a strategy to encourage all of the various small
business assistance providers (i.e., SBAPs, Small Business Development Centers, pollution
prevention programs. Manufacturing Extension Programs, etc.) to coordinate efforts within their
state. This would provide small businesses with easier access to comprehensive business and
environmental assistance.
-------
APPENDIX D
SBTCP STATUS, BUDGETS, STAFFING
AND ORGANIZATION
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E-mail addresses for the California Air Pollution Control Districts are shown in the
following table.
CALIFORNIA AIR POLLUTION CONTROL DISTRICT
Amador County
Antelope Valley
Bay Area
Butte County
Calaveras County
Colusa County
El Dorado County
Feather River
Glenn County
Great Basin
Imperial County
Kern County
Lake County
Lassen County
Mariposa County
Mendocino County
Mbdoc County
Mojave Desert
Monterey Bay
North Coast
Northern Sierra
Northern Sonoma County
Placer County
Sacramento Metro
San Diego County
San Joaquin Valley
San Luis Obispo County
Santa Barbara County
E-MAIL ADDRESS
amaair@cdepot.net
fwohosky@mdaqmd.ca.flov
webmaster@baaqmd.gov
ccagair@colusanet.com
gcairag@maxinet.com
ICAPCD@quix.net
kcapcd@kemcounty.com
bobr@pacific.net
fwohosky@mdaqmd.ca.gov
dquetin@mbuapcd.org
nsaqmd@nccn.net
nsc@sonic.net
cleanair@sloaqcd.dst.ca.us
apcd@apcd.santa-barbara.ca.us
15
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TABLE D-1
(Continued)
CALIFORNIA AIR POLLUTION CONTROL DISTRICT
Shasta County
Siskiyou County
South Coast
Tehama County
Tuoiumne County
Ventura County
Yolo-Solano
E-MAIL ADDRESS I!
scaqmd@snowcrest.net
sbao@aqmd.gov
tehapcd@snowcrest.net
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requirements. Also, addition.
iceived.
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The funding increased for 1 998, because a federal grant was obtained to inform the public of the 1 1
General Revenue funding was used to provide air assistance due to the amount of assistance reques
p grant, which was passed
which include position
acant for 6 months in 1 997
z w. >
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Budget changes from 1996 to 1997 were due to appropriation of the EPA Pollution Prevention Lead*
through to the UNR-BEP Program. The 1996 and 1997 budget information reflects actual expenditui
vacancies; the SBAP technical assistance position was not filled until 1 997, and the SBO position w
due to transfer of staff.
ees collected from Operating
I
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During 1 996, the Environmental Permit Information Center (EPIC) was started under the SBO, and fu
furniture, and equipment for opening this office. During 1 997, some additional expense for equipme
not reoccur in 1998.
•ember. SBO: Variations in
E
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available revenue, new staff added at end of 1997.
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calendar year. Very little will be spent in 1998.
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TABLE D-4
(Continued)
g at a 1 .35 FTE staffing level, or 1.0 FTE less than 1995. The program is expected to
position was reassigned in the Air Quality Division in 1 995 and is involved with special
nual budget reduction was partially, offset by an EPA grant awarded to Region X (AK, ID,
000 ($150,000 Leadership + $50.000 105 Grant) is $25,000 each for 1996 and 1997, for
it money existed at the end of 1 997 and was carried over into 1 998. The leftover grant
8. The grant money is funding special projects through the Pacific Northwest Pollution
. The SBAP also spent $35,000 of EPA 105 Grant money on a NESHAP area source
r and will be spent in 1 998 to complete this project. No other staff additions or reductions
•^W(oOwCT)>>
W 0 _ 0 0,- > 0
During 1 997, the SBAP continued opei
continue with 1.35 FTE in 1998. The 1
education projects. The 1 996 $96,43(
OR, WA» SBAPs. OR's share of the $2
a total of $50,000. A small surplus of
money will be spent by March or April
Prevention Resource Center in Seattle,
outreach project. $33,000 was carried
or revenues are anticipated in 1 998.
from the SBO being in office only 5 months and the SBAP participating in fewer activities
•o
to
The reduction in the 1 997 budget resul
than expected.
1. Title V staff were used in assisting small business.
3
u
Title V revenues were lower than proje
assigned to small business assistance. Increase due to hiring a full time Principal
o>
1996 SBAP budget includes P2 person
Environmental Planner.
the fiscal year. Two unfilled positions assigned to the program were eliminated. An
and determined not to be needed by the program, was abolished. An administrative services
ther division within the department. The department has provided an administrative services
tion/Environmental Awareness Division where the technical assistance program is housed.
the SBTCAP, provides program support.
**Si*
~= * > 3
TN experienced a reduction in force du
account clerk position, which was unfil
assistant 3 position was transferred to
assistant 5 position to the Pollution Pre
This position, although not funded thro
State appropriations reduced.
result of changes in the Department. These changes include a FTE change in the SBO from
for consultant services. SBO spending increases will to be coming from the EPA
CO y
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Significant changes in SBO spending ai
1 .0 FTE to 0.5 FTE and a pending cont
"Partnership for Compliance'' Grant.
as hired as the Small Business Compliance Advisory Program Engineer. This marks the first
cally to assist small businesses. The money to fund this position was allocated by the State
the first time. Prior to and since the meeting, DEC staff have allocated a portion of their
*5 o
In December 1996, a full time employe
time a full time employee was hired spi
of VT. In October 1 997, the CAP met
time to CAP-associated work efforts.
let changes.
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A consultant sent the following message: "Thanks again for your
help regarding the permitting process for the proposed soy bean
processing facility that we are evaluating for our client. 1 also
wanted to reiterate my comments regarding your web site and how
useful it has been in providing permit guidance. 1 have yet to see
another web page from another state that does such a thorough job
in this regard. Our client is quite impressed also, which hopefully
will lead to a significant project in South Dakota. We will keep you
appraised of our progress. Thanks again for your assistance."
An attorney told department personnel that our web page was great
and was "one of the best sites* he had seen. He liked the ability to
download important information from the page.
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Received very positive comments from some users. For example:
"Definitely a useful tool.* "The information included on you web
site is very useful to manufacturers of all sizes, not just small
businesses. When 1 do Internet Resources training for environmental
managers, 1 always go to your site as an example of a great
resource."
Site provides e-mail interface, which has not been utilized as much
as would have been hoped. A portion of the comments, such as
those above, have been provided as a result of other types of
forums. It is important to note that the site is being developed under
an EPA Leadership Grant, and one of the questions we hope to
answer is concerning the usefulness of the resource.
*
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TABLE E-9
MEETINGS AMONG SBO, S8AP, AND CAP
FREQUENCY
Daily
Weekly
Bimonthly
Monthly
Quarterly
Biannually
Annually
Occasionally
Other*'
SBO & SBAP
AK, CT, GA, KS,
ME, MT, NV, NH,
NC, SC, VA, VI,
WA, Wl, WY
CA, IL, ND, WV
AZ, SCAQMD,
CO, DC, MN, TN,
UT
ID*, Jefferson,
LA, NJ, NM
AL, IN, IA, ICY,
NY, OH, Rl
MS,
Maricopa, OK
MO, Ml, OR, PA,
SD
SBO & CAP
MT, Wl
CT, GA, IN*.
KS, KY,
Jefferson, ME,
NV, PA
LA, ND, WV
NM,
Ml, NH, NC, OR,
SD, VA
AK, AR
SBO, SBAP, & CAP
Wl
CO, CT, GA, IN*,
KY, LA, ME, MS,
NV, NJ, PA, UT, VA,
WY
FL, MT, NE, NY, ND,
SD, TX, WV
KS, NM
Ml, NC, OR
AK, AR, OH
SBAP & CAP
Wl
CT, GA, IN*,
KY, LA, ME.
NV, OR, PA
ND, VT, WV
MT, NM
Ml, NC, OK.
PR, SD, VA
AK, AR
•Notes:
County programs not counted separately.
DE No response.
HI Not applicable.
ID Established monthly meetings, but only met 3 times during reporting period.
IN Met once during the year due to scheduling conflicts. Typically meets quarterly.
MA Not applicable.
MO Did not meet in 1997, but SBO/CAP/SBAP and SBAP/CAP will meet quarterly in 1998.
NV 7 meetings with SBO/SBAP and contractors - 3 with BEP-UNR and 2 each with Washoe and
Clark Counties.
••Other:
AK Every 4 months (3 per year).
AR Every 4 months (3 per year).
OH Every 2 months.
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Under AK law, all files and information retained by the SBAP and SBO are open to public rev
information that is traditionally recognized as confidential (e.g.. attorney-client, ongoing enfc
records). Since the SBAP/SBO is non-enforcement, it does not use any of the attorney-clien
Personnel records are not relevant to the businesses we assist.
The SBAP/SBO has an on-going dialogue with the Department's Air Quality Section. There
Air Quality Program will not review the SBAP/SBO files. The Air Quality Program agrees thi
regulations need to be discovered and documented by an Air Quality Inspector. This approa
that request assistance by the SBAP. In addition, the SBAP is in a separate division of the I
enforcement branch.
The SBAP/SBO does provide technical information to sources that call in and do not identify
state web pages, businesses are able to obtain information anonymously.
To date, there have not been any problems with the other sections of the department reque:
have been no requests from the public requesting to view or CODV the SBAP files on busines
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Existing policies, strong support from the ADEQ Director, and good working relationships wi
deal to maintain our credibility as a source of assistance that can be used without risk of ex
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To date, we have not had any problems with a company not complying due to confidentialit
internal conflict of interest » at what stage does a company lose its "protective shield* fron
compliance (soon enough or at all).
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LA law prohibits the SBAP from operating in a confidential manner. We do not voluntarily give any enlorcemi
business activity. Over the last five years the program has developed a reputation of trust among the small I
community so that the lack of professed confidentiality has not been a drawback to the program.
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OTA's programs are confidential by legislative directive. DEP and OTA's client companies are fully aware of
no COI arising from this issue. We have suggested as an MOU with DEP, which would allow companies to u
letters to self-report violations as proof of good-faith intent and demonstrate that they are working with a coi
assistance unit to remedy the problem. This has not yet been adopted. However, on a case-by-case basis, v
we have been able to achieve limited success in providing business with penalty-free return to compliance pli
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External Conflicts of Interest -- Confidentiality is not as an issue, because the current services provided by th
proactive. The SBAP is eluding the confidentiality issue by developing guidance publications, holding worksh
conducting phone consultations. At present, these activities do not warrant the collection of sensitive data.
SBAP does not perform on-site audits, so facility-specific information is not collected. The SBTCP is in the p
developing a policy that explains how the program will respond when it becomes aware of a violation by a fa
assistance. The policy also will explain that information contained in the SBTCP files or databases will not b.
regulatory agency (Ml Air Quality Division). Mi's SBTCP cannot claim that this information is "confidential" «
invokes a provision in Mi's recently-enacted "Environmental Audit Privilege and Immunity" law, which design
confidentiality between a facility and the regulatory agency in a "confidentiality agreement." A summary of
anached.
Internal Conflicts of Interest - The SBTCP works closely with the regulatory agency, the Ml Air Quality Divis
and executes all of its program objectives. SBAP staff are included in and advised of all policy developments
implementation of the CAA. Mi's SBAP acts as as an education, outreach, and marketing arm for the state'!
oroaram. and that role has assisted the SBAP in avoiding internal conflicts of interest.
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: The environmental programs of the Department's Environmental Health
oriented, with enforcement reserved for recalcitrant violators or where d
Even prior to the establishment of the SBAP and SBO, the Department's
regulated community to achieve compliance. So with the establishment
compliance hasn't noticeably changed. However, with the establishmei
activity.
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Any contact with the regulatory agency is okayed with the company in advance. W<
potential enforcement actions to assist a business in coming into compliance. We cc
that we have no enforcement authority. We have a good working relationship with t
routinely make referrals to us. We have frequent communications with the regulator
regulatory agencies.
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TX's confidentiality policy states: All contact with the Small Business Assistance Pr<
division of the TNRCC cannot seek information regarding these contacts.
This policy has allowed us to work with our enforcement offices on a number of proj
Foundry Initiative, and still maintain the confidentiality of the businesses that contaci
with our enforcement offices on a project, we are aWe to increase compliance for ns
that there is as an increased chance they may receive a visit from one of our inspect
Many businesses like our confidentiality policy and have said that it gives them confi
uses our services, they will contact us again. Because we have a high satisfaction ri
callers. However, even with this policy, some small businesses are still afraid to con
regulator.
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policy on compliance incentives for small business (issued May 20, 1996).
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SBAP is located in a non-regulatory division of the VT DEC. The state's statute on p
SBAP from being "confidential." However, a separate SBAP documents policy was :
some degree of confidentiality to the small businesses.
The documents policy requires a "sign-off" by Department heads for access to occur
restricts the use of the file information by Department personnel. This information m
inspections or initiating enforcement actions. Businesses are notified should access •
The regulatory program staff have been most supportive of the program and have sh
files. As a matter of fact, the regulatory staff has forwarded more business (to date!
There has been no inquiries (to datel for access to SBAP files.
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