Policy, Planning, EPA 239-R-96-001
Environmental Protection And Evalution September 1996
Agency (1230C)
&EFA Status Of The State
Small Business Stationary
Source Technical And
Environmental Compliance
Assistance Program (SBTCP)
Report To Congress
For The Period
January To December 1995
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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 1995
PRESENTED BY:
KAREN V. BROWN
SMALL BUSINESS OMBUDSMAN
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC
SEPTEMBER 1996
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ACKNOWLEDGEMENTS
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 first 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
ACKNOWLEDGEMENTS 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 3-2
3.3 Staffing Levels 3-9
3.4 Administrative Locations of SBTCP Components 3-10
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 4-9
4.4 Leveraging of Resources and Minimizing Duplication of Efforts . 4-10
4.5 SBTCP Compliance with Section 507(d)(2) 4-13
5.0 PROGRAM EFFECTIVENESS 5-1
5.1 Comments Received by SBO or CAP on SBTCP 5-1
5.2 Complaints received by SBO or CAP and Resolution Strategies . . 5-2
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 .... 6-2
6.3 Recommended Changes to Facilitate Small Business
Compliance with the CAA 6-5
6.4 Program Confidentiality 6-7
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TABLE OF CONTENTS
(Continued)
LIST OF TABLES
Table No. Title Page
3-1 Operating Status of the SBTCP Components 3-1
3-2 Start of Operations for SBTCP Functions 3-2
3-3 1995 SBTCP Operating Budget Ranges 3-3
3-4 1995 SBO Operating Budget Ranges 3-4
3-5 1995 SBAP Operating Budget Ranges 3-5
3-6 1995 CAP Operating Budget Ranges 3-6
3-7 SBTCP Reporting Period Budget Comparisons 3-7
3-8 Staffing Levels (as FTEs) Serving the SBO & SBAP Functions ... 3-9
3-9 CAP Appointments . . . . , 3-10
3-10 Administrative Locations of SBO, SBAP, and CAP 3-11
4-1 SBO Outreach Activities 4-4
4-2 SBAP Outreach Activities 4-5
4-3 Information Available on SBAP BBS and WWW Pages 4-6
4-4 Major CAP Activities 4-7
4-5 Frequency of Meetings Among SBOs, SBAPs, and CAPs 4-8
4-6 Financial Assistance Programs 4-9
4-7 Programs That Report Leveraging of Resources for
SBTCP Functions 4-10
4-8 SBTCP Mechanisms for Avoiding Duplication 4-12
4-9 SBTCP Activities to Follow the Intent of the Paperwork
Reduction Act 4-14
4-10 SBTCP Activities to Follow the Intent of the Regulatory
Flexibility Act 4-14
4-11 SBTCP Activities to Follow the Intent of the Equal Access
to Justice Act 4-16
6-1 Common Compliance Problems 6-1
6-2 Improvements in Regulatory Understanding 6-3
6-3 SBTCP Recommendations for Improving Compliance 6-6
APPENDICES
A 1995 SBTCP Reporting Form
B Federal Small Business Ombudsman
C Federal Small Business Assistance Program
D SBTCP Status, Budgets, Staffing, and Organization
E SBTCP Activities and Services
F Program Effectiveness
G 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
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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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman
(SBO) is pleased to submit this first 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, 1995.
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 SBO. The Report also includes a
general report on the Small Business Ombudsman'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)].
• 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 comply with the requirements of
the CAA through state-operated programs. Each SBTCP is required to include three
components: a Small Business Ombudsman (SBO), a Small Business Assistance
Program (SBAP), and a Compliance Advisory Panel (CAP).
In the first year of monitoring the SBTCPs, over 75,000 small businesses have been
directly reached, and over 2,000 on-site consultations have been conducted. 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 the information reported,
improvements in compliance occur because businesses have someone to turn to for
assistance, advice, and effective liaison with regulatory agencies.
SBTCP yearly operational growth has been continuous since 1990. Presently, 50
SBOs (94 percent), 49 SBAPs (92 percent), and 32 CAPs (60 percent) are operational.
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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. 49
percent of programs report that at least the required 7 members have been appointed
to their CAPs.
Budgets for the SBTCPs have a wide range from $0 to over $2,000,000 for 1995.
98 percent of SBOs (39 of 40) with their own budgets operate their programs with
less than $200,000. For all 53 programs, 21 percent operate with budgets of
between $0 and $25,000; 22 percent operate with budgets of between $25,001 and
$50,000; 9 percent operate with budgets of between $50,001 and $75,000; and 8
percent operate with budgets of between $75,001 and $100,000.
Similarly, of the 41 SBAPs with their own budgets, 88 percent are allotted less than
$400,000. For all 53 programs, 11 percent operate with budgets of between $0 and
$25,000; 8 percent operate with budgets of between $25,001 and $50,000; 8
percent operate with budgets of between $50,001 and $75,000; and 8 percent
operate with budgets of between $75,001 and $100,000. Projected budgets reflect
positively on the programs, as 75 percent of all programs report either a consistent
or increasing budget for 1996.
72 percent of SBTCPs provided specific information on the types of industry sectors
and number of facilities that their programs assisted. 105 specific industry sectors
received assistance in 1995. The top 10 industry sectors that received assistance by
SBTCPs were:
vehicle maintenance and repair
metal fabrication
degreasing
dry cleaning
printing
gasoline distribution
consulting
chrome plating
regulated storage tanks
government.
On-site visits were characterized as being the most effective in providing the
individualized attention often required to assist a facility in achieving compliance. The
top ten industry sectors receiving on-site assistance were:
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dry cleaning
vehicle maintenance and repair
dentistry
cleaning/laundry services
metal fabrication
printing
chemicals
chrome plating
plastics and plastic products
cut/crushed stone and products.
The top ten industry sectors receiving assistance from the most programs were:
dry cleaning (29 programs)
vehicle maintenance (24 programs)
printing (22 programs)
chrome plating (19 programs)
degreasing (18 programs)
metal fabricating (13 programs)
chemicals (11 programs)
gasoline distributing (9 programs)
hospitals/medical/health services (9 programs)
paints and painting (9 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 electronic bulletin board services and
World Wide Web pages are being used, but could be more widely integrated.
66 percent of SBOs, 81 percent of SBAPs, and 40 percent of CAPs 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.
83 percent of the programs 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.
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• 42 percent of programs report taking specific actions associated with the
Paperwork Reduction Act, with the most common action being CAP review of
SBTCP documents.
• 42 percent of programs report taking specific actions with respect to the
Regulatory Flexibility Act. The most common actions included development of
simplified/consolidated permits and forms and increased exemptions for
"insignificant actions."
• 30 percent of SBTCPs reported specific actions associated with the Equal
Access to Justice Act through the establishment of pro bono lenal services and
the availability of funding for engineering services for citizen gi j ups aggrieved
by permit actions of a regulatory agency. Primary actions listed by the
programs include routine review of documents for compliance, increasing
exemptions for "insignificant actions," and use of general industry-specific
permits to reduce the number or complexity of permits.
While the number of programs reporting specific actions to follow the intent of the
provisions of these Acts is small, the steps being taken appear to be fairly effective
in addressing the unique need of small businesses.
81 percent of SBTCPs report that small businesses provided comments on the
assistance programs and that feedback was overwhelmingly positive. Common
themes repeated by small businesses include appreciation for the availability of a non-
regulatory approach for certain problems and for personalized guidance through the
many regulatory processes leading to compliance.
49 percent of programs provided examples of complaints 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:
• Developing explanations of regulatory requirements in "plain language."
• Providing personalized assistance in the permitting process.
• Facilitating communication about regulatory flexibility issues between small
business and regulatory agencies.
85 percent of the SBTCPs provided insight on the types of compliance issues
addressed during the course of providing technical assistance to small businesses.
Two of the three most common compliance problems mentioned by small businesses
were, "Not understanding the regulatory requirements," and "Operating without a
permit." Programs reported, "Greater understanding of the regulations," and
"Increased compliance," as a result of program outreach efforts.
Generally, small businesses want to comply with environmental regulations; however,
they may be afraid to ask for help. When a non-threatening assistance program, such
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as the SBTCP, is available, small businesses are eager to take advantage of the
services, as this help increases chances of survival and profitability.
44 SBTCPs provided recommendations for changes to facilitate small business
compliance with the CAA. The most frequent recommendation was flexibility in
applying regulations to small businesses (30 percent of programs).
In addition to inquiries regarding air issues, many programs are being contacted about
multi-media problems as well. 26 percent of programs suggested expanding
assistance to cover multi-media programs (i.e., air, water, solid waste).
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. 89 percent
of programs reported no problems concerning confidentiality or with conflict of
interest issues during the course of providing services. Program structures range from
a guarantee of confidentiality (most common) to offering no confidentiality. Many
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.
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CONCLUSIONS AND RECOMMENDATIONS
• 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 first year of gathering information from the programs,
over 75,000 small businesses have been reached, and over 2,000 on-site
consultations have been performed.
• SBTCPs facilitate dialog between the small business community and the
regulatory community, fostering improved attitudes towards regulatory
compliance.
• Programs have significant expertise and are increasingly becoming multi-media
as states want to offer this type of assistance, and small businesses are
requesting it.
• Commonly identified compliance problems include not understanding regulatory
requirements and operating without a permit. SBTCPs suggested reasons for
these problems may be the overwhelming volume of regulations, businesses'
fear of talking to regulators, and the difficulty of businesses in contacting
regulatory agencies. 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 promoting
compliance in 1995. Highlights include improved synergy between the
regulatory agencies and the small business community, and increased
cooperation among SBTCPs. Award programs have proved to be effective in
providing incentives, both for small businesses and the programs themselves.
Programs should consider developing award programs as incentives for their
small business customers.
• 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 Acts. 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, one-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.
It is important that adequate resources are allocated to permit on-site visits by
their staff.
• With the strong small business technical assistance infrastructure in place
through the SBTCPs, programs should explore their potential to expand into
multi-media assistance. A number of programs already offer multi-media
assistance and permitting, which can ease the regulatory burden on small
businesses and promote compliance.
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Efficiency of information transfer (among SBTCPs and to small businesses) can
be realized through the increased use of electronic bulletin boards and Internet
home pages. Presently, only 25 percent of programs operate some type of
electronic information transfer. Such electronic services also would be
promising mechanisms to avoid duplication of effort among programs.
Programs are encouraged to explore the potential of the Internet or bulletin
board services for sharing information with small businesses and with other
SBTCPs.
Only 9 percent of SBTCPs report utilizing a formalized approach to evaluating
their own programs' effectiveness (using standardized evaluation forms,
surveys, and workshop evaluations). Increasing the use of formal feedback
mechanisms may allow programs to accurately identify the strengths and
weaknesses and to modify their services to better meet small business needs.
Programs should interact with those SBTCPs that have developed formal
evaluation mechanisms and develop strategies to integrate some level of formal
evaluation into their programs to more effectively track the value of services
provided and compliance.
Programs are encouraged to explore the potential for sponsoring or facilitating
financial assistance programs for pollution control or pollution prevention capital
expenses. (Only 19 percent of SBTCPs reported the availability of financial
assistance programs in 1995.) Small businesses have expressed their need for
creative financing mechanisms, which was a common recommendation 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 multi-media technical assistance.
SBTCPs are encouraged to better utilize the expertise of their CAP members to
enhance improvements in their technical assistance programs. States without
functioning CAPs should activate their CAPs during the next reporting year.
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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, 1995 reporting period.
This report represents the first Annual 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 as amended in 1990
(CAA) of 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.
1. Render advisory opinions on the overall effectiveness of the SBTCPs, difficulties
encountered, and severity of enforcement [507(d)(1)].
2. 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
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 November 1995, EPA's SBO distributed copies of the SBTCP Annual Reporting
Form (for the reporting period January through December 1995) 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 1995 SBTCP Reporting Form is enclosed
as Appendix A.
Since this was the first time that information was gathered from the SBTCPs, it was
anticipated that some programs may not collect all the types of information that were
requested in the Form. 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, 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 March 31, 1996. 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). All 53 programs filed their
1995 Reports with EPA's SBO by March 31, 1996.
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In addition, Arizona and New Mexico have distinct air quality districts within their
states, which also submitted reports. In Arizona, Final County, Maricopa County, and
Pima County and Tucson submitted separate reports. In New Mexico, Bernalillo
County reported separately. State reports from Arizona and New Mexico do not
include the data shown in the reports from the air quality districts. For statistical
purposes of this report, data from states that submitted multiple reports have been
combined. Raw data for the separate air quality districts are shown in the appendices.
According to an EPA proposed action in 60 Federal Register 47515, the EPA is
proposing to grant conditional waivers from the requirement that the Territory of
American Samoa and Commonwealth of the Northern Mariana Islands (CNMI) adopt
and submit title V operating permit programs. The EPA is proposing to grant the
Territory of Guam a three-year extension of the deadlines of title V. The EPA is also
proposing to exempt sources from the requirements to, obtain a federal title V permit
during the period of the waivers, except for certain major sources of hazardous air
pollutants. 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 Introduction and Report Overview
Section 2.0 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.
Section 3.0 SBTCP Status, Budgets, Staffing, and Organization -- This section
encompasses these four categories of information about the
SBTCPs.
Section 4.0 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 1995 also are outlined.
Section 6.0 Compliance Assurance -- 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
This section provides an overview of the Small Business Stationary Source Technical
and Environmental Compliance Assistance Programs (SBTCPs).
As part of Section 507 of the Clean Air Act Amendments, as amended in 1990
(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 "Section 507
programs") is required to include the following three components:
• Small Business Ombudsman (SBO)
• Small Business Assistance Program (SBAP)
• Compliance Advisory Panel (CAP).
The CAA also required states/territories to develop a State Implementation Plan (SIP)
for implementing an SBTCP by November 1992. As of December 31, 1995, 50 of
53 states/territories (94 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:
• Hawaii -- not yet submitted
• Rhode Island -- submitted, but not yet final
• Vermont -- 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:
• Review and provide recommendations to EPA and state/local air pollution
control authorities regarding development and implementation of regulations
impacting small businesses.
• Assist in dissemination of information about upcoming air regulations, control
requirements, and other matters relevant to small businesses.
• Refer small businesses to appropriate specialists for help with specific needs.
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• Conduct 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 should provide sufficient communications with small businesses through
the collection and dissemination of information to the small businesses on matters of:
Determining applicable requirements under the Act and permit issuance.
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 SBTCP,
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 Equal Access to Justice
Act [507(d)(2)].
• Review information issued by the SBTCPs to ensure that it is understandable
to the layperson [507(d)(3)j.
• Have the federal SBAP serve as the secretariat for the development and
dissemination of reports and advisory opinions [507(d)(4)J.
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 provides technical guidance for the use of the SBTCPs in the implementation of
their programs. The Federal SBAP provides this service, which is coordinated by the
Control Technology Center within the Information Transfer Group of the Office of Air
Quality Planning and Standards. 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
This section presents 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 1995 reporting period.
A listing of each state/territory Ombudsman, SBAP, and alternate SBAP contacts is
included in Appendix D-1.
3.1 OPERATING STATUS
Importantly, by December 31, 1995, 50 programs (94 percent of the 53 states and
U.S. territories) had been established and were providing assistance to small
businesses through their SBOs and SBAPs. Only 32 programs reported that their
CAPs were operating; however, 40 programs reported that the CAPs had been
established.
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.
TABLE 3-1
OPERATING STATUS OF THE SBTCP COMPONENTS
SBO2
SBAP3
CAP4
COMPONENTS ESTABLISHED1
# Programs
50
50
40
% Programs
94
94
75
COMPONENTS OPERATIONAL1
# Programs
50
49
32
% Programs
94
92
60
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 12/31/95, SBOs were reported not to be established or operating in Massachusetts
or Vermont. Hawaii did not provide a response and was counted as not being operational.
3-1
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Note 3: As of 12/31/95, SBAPs were reported not to be established or operating in Rhode Island
or Vermont. (However, Rhode Island's Department of Environmental Management staff
have been responding to inquiries.) Nevada's SBAP was established, but not yet operating.
Hawaii did not provide a response and was counted as being not operational.
Note 4: As of 12/31/95, CAPs were reported not to be established or operating in 13 programs:
California, Delaware, District of Columbia, Hawaii, Iowa, Illinois, Maryland, Massachusetts,
New York, Oklahoma, Ohio, Rhode Island, Vermont, or the U.S. Virgin Islands. In addition,
6 other states reported that their CAPs had been established, but not yet operating:
Alabama, Arizona, Missouri, New Hampshire, Oklahoma, Ohio, Puerto Rico, and Tennessee.
Appendix D-2 contains details on the actual dates (month/year) when the SBOs,
SBAPs, and CAPs were reported to be established and operational.
As seen in Table 3-2, the majority of the SBOs, SBAPs, and CAPs did not begin
operations until 1993. Since that time, 38 (72 percent) SBOs, 35 (66 percent)
SBAPs, and 32 (60 percent) CAPs became operational.
TABLE 3-2
START OF OPERATIONS FOR SBTCP FUNCTIONS
1990
1991
1992
1993
1994
1995
% operational by
12/31/95
SBO
Number
12
20
10
8
Total
12
32
42
50
94%
SBAP
Number
1
1
12
16
16
3
Total
1
2
14
30
46
49
92%
CAP
Number
9
12
11
Total
9
21
32
60%
3.2 BUDGETS
3.2.1 1995 Reporting Period
As detailed in the paragraphs and tables below, the total operating budgets for the
SBTCPs varied from $0 to over $2,000,000 for the 1995 reporting year. These
extremes include $0 for Massachusetts and Vermont, whose SBO/CAP and
SBO/SBAP/CAP, respectively, have not yet begun operations, to Texas, reporting a
3-2
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total operating budget of $ 1,470,000 for its SBTCP program and New York, reporting
a total operating budget of $2,156,000.
1995 operating budget ranges for the SBTCPs are shown in Table 3-3. 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.
TABLE 3-3
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
900,001 - 1,000,000
>1,000,0001
>2,000,0002
Report submitted, no data provided3
TOTAL
# Programs
2
9
14
9
7
2
3
1
0
2
0
1
1
2
53
% Programs
4
17
26
17
13
4
5
2
0
4
0
2
2
4
100
Note 1:
Note 2:
Note 3:
Texas
New York
Florida, Hawaii.
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
40 SBOs have their own budgets. Budgets for these SBOs are concentrated in a
range below $200,000, with 39 of 40 SBOs (98 percent) reporting budgets between
$0 and $200,000. The primary source of funding for all programs is Title V fees (53
3-3
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percent), which are collected at the state/territory level. Other sources of funding
include EPA 105 Grant funds (provided for in Section 105 of the CAA, these funds
flow to the states through EPA regional offices), non-Title V air fees, and state permit
fees.
The range of 1995 operating budgets for the SBOs is shown in Table 3-4.
TABLE 3-4
1995 SBO OPERATING BUDGET RANGES
(40 non-combined budgets)
Budget ($)
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
n Programs
11
12
5
4
7
1
11
2
53
% Total Programs
21
22
9
8
13
2
21
4
100
Note 1: 11 programs (21 percent) indicate that two or three of the three SBTCP functions share
a combined budget. 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). 11 SBOs have combined budgets.
Note 2: Florida (indicated a combined budget, but did not provide an amount and was tallied as,
"no response."), Hawaii.
3.2.3 SBAP Operating Budgets
41 SBAPs have their own budgets. SBAP budgets are spread across a wider dollar
range with 18 of 41 programs (44 percent) between $0 and $100,000, 8 of 41
programs (20 percent) between $100,001 and $200,000, and 6 of 41 programs (15
percent between $200,001 and $300,000. Title V fees again are the main funding
source (58 percent of all programs); funds from EPA 105 Grants, non-Title V fees,
indirect funds, and permit fees are also used to support SBAPs.
3-4
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Ten SBAPS have combined budgets of less than $400,000. One program
(Tennessee) has a combined budget of between $850,001 and $900,000 (reflecting
all three functions), and one program (Texas) has a combined budget of over
$1,000,000 (for all three functions).
The range of 1995 operating budgets for the SBAPs is shown in Table 3-5.
TABLE 3-5
1995 SBAP OPERATING BUDGET RANGES
(41 non-combined budgets)
Budget ($)
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
6
4
4
4
8
6
4
3
1
1
10
2
53
% Total Programs
11
8
8
8
15
11
8
6
2
2
19
4
100
Note 1:
Note 2:
11 programs (21 percent) indicate that two or three of the three SBTCP functions share
a combined budget. 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). 10 SBAPs have combined budgets.
Florida (indicated a combined budget, but did not provide an amount and was tallied as,
"no response."), Hawaii.
3-5
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3.2.4 CAP Operating Budgets
43 CAPs have their own budgets. CAP funding ranges from $0 (42 percent of
programs with their own budgets) to a high of $30,000 (one program, New York).
88 percent of CAPs operate with a budget of $5,000 or less. Title V fees are the
most commonly listed funding source for all CAPs (40 percent).
The range of 1995 CAP operating budgets is shown in Table 3-6.
TABLE 3-6
1995 CAP OPERATING BUDGET RANGES
(43 non -combined budgets)
Budget ($)
0
1 1,000
1,001 - 2,000
2,001 3,000
3,001 - 4,000
4,001 - 5,000
9,001 10,000
29,001 - 30,000
Combined budgets1
Report submitted, no data provided2
TOTAL
# Programs
18
3
3
4
0
10
4
1
8
2
53
% Total Programs
34
6
6
8
0
19
8
2
15
4
100
Note 1: 11 programs (21 percent) indicate that two or three of the three SBTCP functions share
a combined budget. 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). 8 CAPs have combined budgets.
Note 2: Florida (One program (Florida) indicated a combined budget but did not provide an amount,
and was tallied as, "no response."), Hawaii.
3.2.5 Comparison of Previous and Projected Budgets
A comparison of budgets from 1994, 1995, and 1996 (projected) is valuable in
tracking program growth and resource allocation. Programs were asked to indicate
significant budget changes (greater than 10 percent) from year to year and to provide
3-6
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insight into any major shifts (more than 10 percent) in funding levels. SBTCP
reporting period budget comparisons are shown in Table 3-7.
TABLE 3-7
SBTCP REPORTING PERIOD BUDGET COMPARISONS
1994 to
1995
Reporting
Period
1995 to
1996
Reporting
Period
BUDGET DECREASE
(> 10% change)
#
Programs
2
5
%
Programs
4
9
BUDGET CONSISTENT
« 10% change)
#
Programs
20
25
%
Programs
38
47
BUDGET INCREASE
(> 10% change)
#
Programs
28
15
%
Programs
53
^8
INSUFFICIENT DATA
FOR COMPARISON'
#
Programs
32
83
%
Programs
6
15
Note 1: Not all programs provided budget amounts. 13 programs (25 percent) did not have an
established SBTCP during the previous reporting period. 8 programs (15 percent) were
unable to project their budgets for the next reporting period. 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, while
other programs may have had one or two facets of their programs inactive during the
previous reporting period.
Note 2: Florida, Hawaii, Vermont
Note 3: Florida, Hawaii, Minnesota, Nevada, New Hampshire, North Carolina, Puerto Rico, Vermont
In reviewing the combined budgets for the SBO, SBAP, and CAP functions of the
SBTCPs, 28 programs (53 percent) indicate a budget increase (of at least 10 percent)
from the 1994 to 1995 reporting periods. 15 programs (28 percent) show an
increase from the 1995 to 1996 reporting periods.
According to responses received, 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 10 percent are provided below:
• Connecticut projects a budgetary increase ($210,000/1995 - $330,500/1996)
for the 1996 calendar year. The SBTCP will see an increase in funding due to
$150,000 SBAP Leadership Grant as well as the addition of two staff people.
• New York moved into full SBTCP implementation. Appropriations increased to
cover expanded scope of services ($2,156,000/1995 - $2,230,000/1996).
3-7
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• Iowa's funding levels have systematically increased ($306,500/1995
$394,500/1996) because of Department of Natural Resources-Air Quality
Board budget increase through collection of Title V revenue and because of
DNR's and businesses' recognition of Iowa's success in assisting small
businesses with improving compliance rates and emission reduction rates.
20 programs (38 percent) report steady budget levels (less than a 10 percent change)
for the 1994 to 1995 reporting periods, and 25 programs (47 percent) indicate
consistent budget levels from the 1995 to 1996 reporting periods.
Only 2 programs (4 percent) show a decrease (more than 10 percent) from the 1994
to 1995 reporting periods, and 5 programs (9 percent) report a decrease from the
1995 to 1996 periods.
Budget reductions could be attributed to program reorganizations and consolidations
and lower projected costs to maintain a program (versus the higher resource
requirements to develop a program). Program examples of reasons given for budget
reductions greater than 10 percent are shown below:
• Louisiana SBO contract was reduced by the funding agency ($450,000/1995
$400,000/1996).
• For the first half of 1995, Maryland SBAP was funded for three engineers and
a dedicated secretary. As a result of the Maryland Department of the
Environment's reorganization, the program was reduced to one engineer and 15
percent of a secretary. The scope of the program was changed from air-only
assistance to multi-media assistance. Funding was moved from the Air and
Radiation Management Administration to the indirect funds from the Office of
the Secretary ($210,000/1995 $60,000/1996).
• The last 2 calendar years required more resources in the development of the
programs than will be required to maintain the programs, particularly the SBAP.
This is based on: 1) past demand for SBAP resources, and 2) estimated small
number of small businesses in North Dakota that will be affected by new rules
in the next year ($60,000/1995 $46,000/1996).
• Texas SBO and SBAP offices were consolidated and four positions eliminated
due to agency-wide staff reduction plan. The elimination of these positions
was responsible for the 14 percent reduction in funding ($1,470,000/1995
$1,260,000/1996).
75 percent of the programs reported either a consistent or increasing budget from the
1995 to 1996 reporting periods.
3-8
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Budgets for the 1994, 1995, and 1996 reporting periods for the SBO function, SBAP
function, and CAP function may be found in Appendix D-4.
3.3 STAFFING LEVELS
41 programs (77 percent) report operating their SBOs with 2 or fewer full-time
equivalents (FTEs) as shown in Table 3-8.
37 programs (70 percent) operate their SBAPs with 4 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 Puerto Rico, Louisiana, and Indiana, which
report using 10, 11, and 12 FTEs, respectively, to support their SBAP function.
Specific details on the number of FTEs, by program, for the SBO and SBAP functions
may be found in Appendix D-5.
TABLE 3-8
STAFFING LEVELS (as FTEs1) SERVING THE SBO & SBAP FUNCTIONS
# FTEs
0
1
2
3
4
5
6
7
10
11
12
TOTAL2
SBO
# Programs
1
28
12
4
1
1
3
50
% Programs
2
53
23
8
2
2
6
SBAP
# Programs
1
15
8
7
7
3
4
2
1
1
1
50
% Programs
2
28
15
13
13
6
8
4
2
2
2
Note 1:
Note 2:
An FTE is considered to work 40 hours/week. For example, 2 people working 20
hours/week would be equivalent to 1 FTE.
2 states (Connecticut and Texas) combined their SBO and SBAP functions and are report
4 and 20.5 FTEs, respectively. Hawaii did not provide information on their SBO or SBAP.
3-9
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49 percent of programs report that at least 7 members have been appointed to their
CAPs. An overview of CAP appointments is shown in Table 3-9. 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.
TABLE 3-9
CAP APPOINTMENTS
Minimum 7 members appointed
Less than 7 members appointed
No response1
# Programs
26
23
4
% Programs
49
43
8
Note 1:
Hawaii, Maryland, Vermont, Virgin Islands
3.4 ADMINISTRATIVE LOCATION OF SBTCP COMPONENTS
As shown in Table 3-10, the 52 programs indicated that their SBOs are located within
a state/territory-related agency, typically the environmental agency (not necessarily
a regulatory section). (Two programs whose SBO function has not been established
indicated the intended location for this function.) The majority of programs (47)
report to have located their SBAPs within a state/territory-related agency, typically the
environmental agency.
As defined in Section 507, the CAPs are to be independent entities, operating outside
of any agency. In addition to this independent status, 13 programs also indicated that
administrative support is provided to the CAPs by some facet of their state
environmental agency or SBO/SBAP.
3-10
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TABLE 3-10
ADMINISTRATIVE LOCATIONS OF SBO, SBAP, AND CAP
Location
State-related
agency
University-
related
Private
contractor
Independent
Not
established
TOTAL
SBO
# Programs
52'
1
53
% Programs
98
2
100
SBAP
# Programs
47
1
3
1
1
53
% Programs
88
2
6
2
2
100
CAP
tt Programs
432
10
53
% Programs
81
19
100
Note 1:
Note 2:
This number is higher than that reported in Table 3-1. Programs without established SBOs
indicated where the SBO is intended to be located once established.
This number is higher than that reported in Table 3-1. Programs without established CAPs
indicated that they are intended to be independent once established.
Complete information for the administrative location of each SBO, SBAP, and CAP
may be found in Appendix D-7.
3-11
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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 leverage resources and minimize
duplication of 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
38 SBTCPs (72 percent) provided specific information on the types of industry sectors
and number of facilities that their programs assisted in 1995. Small businesses in
105 specific industry sectors were identified as having been assisted by SBTCPs.
Certain industry sectors, such as dry cleaning and vehicle maintenance and repair,
received larger numbers of assists, 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
1995 were:
Vehicle maintenance and repair
Metal fabrication
Degreasing
Dry cleaning
Printing
Gasoline distribution
Consultants
Chrome platers
Regulated storage tanks
Government.
4-1
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The top ten industry sectors that received on-site assistance were:
Dry cleaning
Vehicle maintenance and repair
Dentistry
Cleaning/laundry services
Metal fabrication
Printing
Chemicals
Chrome platers
Plastics and plastic products
Cut/crushed stone and products.
The top ten industry sectors that received assistance from the most programs were:
Dry cleaning (29 programs)
Vehicle maintenance (24 programs)
Printing (22 programs)
Chrome plating (19 programs)
Degreasing (18 programs)
Metal fabricating (13 programs)
Chemicals (11 programs)
Gasoline distributing (9 programs)
Hospitals/medical/health services (9 programs)
Paints and painting (9 programs).
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 thirteen most active programs, with over 1,000
assistance efforts were:
California
Indiana
Louisiana
Maine
Maryland
4-2
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Massachusetts
Mississippi
Missouri
Montana
New York
Ohio
Texas
Wyoming.
Of special note, Texas reported 40,618 general assists and 126 on-site assists. Of
this total, 34,532 general and 27 on-site assists were to non-specific industries.
A summary of specific industry sectors receiving assistance, by program, may be
found in Appendix E-5.
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 Activities and Services
Outreach services offered by the SBOs during the 1995 reporting period are
summarized in Table 4-1. Outreach activities offer a means of informing the small
business community about the technical assistance services available from SBOs and
providing technical information to small businesses.
The three most common SBO activities, reported in more than 70 percent of
programs, were meetings, speaking engagements, and distribution of brochures/flyers.
Personal assistance activities, including answering hotline inquiries, providing step-by-
step guidance in completing permits and other forms, and other individualized
services, also were conducted by 68 percent of SBOs.
4-3
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TABLE 4-1
SBO OUTREACH ACTIVITIES
ACTIVITY
Meetings
Speaking engagements
Brochures/flyers
Personal assistance (including toll-free hotlines)
Training sessions
Press coverage
Information booths
On-site visits
Other1
# Programs
42
40
39
36
31
8
7
6
13
% Programs
79
75
74
68
58
15
13
11
25
Note 1: SBO activities classified as "other" included:
Permit application and compliance assistance
Technical evaluations
Water line extensions
Outreach on state legislation and an environmental fax network
Teleconferences
Contacts with Chamber of Commerce offices
Development of a small business working group
Informational mailings about regulations, etc.
Support group seminars
Participation in regulatory development
Formation of an Environmental Assistance Coalition and Panel Secretariat.
Detailed information, by program, about the number of occurrences and the number
of people reached by each reported SBO activity is presented in Appendix E-6. Details
of the SBOs toll-free hotlines are shown in Appendix E-7.
4.2.2 SBAP Activities and Services
An aggregate of the outreach services offered by the SBAPs during the 1995
reporting period is presented in Table 4-2. These outreach services/activities are
designed to introduce the available assistance services to small businesses, provide
general information, and identify common problems and issues to be addressed on a
more specific basis.
4-4
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The four most common outreach services offered by at least 80 percent of SBTCPs
were:
Seminars, workshops and meetings
General assistance (including assistance provided via telephone hotlines)
Distribution of printed materials such as factsheets
On-site consultations.
TABLE 4-2
SBAP OUTREACH ACTIVITIES
ACTIVITY
Seminars, workshops, meetings, etc.
General assistance (including telephone hotlines)
Fact sheets, manuals, etc.
On-site consultations
Bulletin board services/World-Wide Web page
Permit and compliance assistance
Teleconferences
Newsletters
Pollution prevention assistance
Other1
# Programs
51
50
49
44
12
9
4
3
3
13
% Programs
96
94
92
83
23
17
8
6
6
25
Note 1: SBAP services classified as "other" included the following:
Sector-based activities
Technical Reference Center
Technical evaluations
Water line extensions
Coordination with Regional Permit Assistance Centers
Staff training
Enforcement negotiations
Fax-back and customer connect service
Information booths at state fairs, trade shows, or conferences
Referrals to the Small Business Resource Center
Multi-media assistance
Loan programs
Surveys
Advisement panel
Amnesty programs
Regulation development.
Detailed information, by program, about the number of occurrences and the number
of people reached by each SBAP during the 1995 reporting period is shown in
Appendix E-8. SBAP telephone hotline information is listed in Appendix E-9.
4-5
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Of particular note is the number of SBAPs that are using Bulletin Board Services
(BBSs) and World Wide Web (WWW) home pages to disseminate technical assistance
information. The 13 programs that are currently using BBSs or WWW home pages
are: California, Illinois, Louisiana, Massachusetts, Missouri, New Jersey, New Mexico,
Ohio, Pennsylvania, Texas, Utah, West Virginia, and Wyoming.
The types of information available via these BBSs or WWW home pages are listed in
Table 4-3; detailed information on these BBSs and home pages, by program, may be
found in Appendix E-10.
TABLE 4-3
INFORMATION AVAILABLE ON SBAP BBS AND WWW PAGES
Type of Information
Regulations
Pollution Prevention
Application Forms
Policies
Other1
n Programs
12
8
6
3
12
% Programs
23
15
11
6
23
Note 1: "Other" information available from SBAP bulletin boards includes:
Fact sheets and checklists
Documents to view and/or order
Meeting and workshop schedules
Emission calculation data and inventory forms
Contact names and telephone numbers
Reporting deadlines
Financial assistance information
Office of Technology Assessment (OTA) case studies
OTA and EPA software packages
Meteorological data
Compliance history forms
Business assistance
District rules database
Air Toxics Program
Consumer products
Reformulated Gasoline Program
Message center
News releases.
BBSs and Internet home pages are efficient mechanisms for SBTCPs to disseminate
information to small businesses, as evidenced by the increasing use of electronic
media. Because the Internet and BBSs are also efficient ways to transfer information
from the federal SBO and SBAP, between SBAPs, and to the small business
community, increased access to the Internet should be pursued by SBAPs.
4-6
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4.2.3 CAP Activities and Services
32 CAPs were operational during the 1995 reporting period, all of which reported
activities. The primary CAP activity, as reported by 17 CAPs, was the review of
SBTCP documents. The appointment of staff/election of officers was noted by 15
CAPs.
Major activities of the CAPs during the 1995 reporting period are summarized in Table
4-4. A program summary of CAP activities may be found in Appendix E-11
TABLE 4-4
MAJOR CAP ACTIVITIES
Activity
Review SBTCP documents
Appoint staff/elect officers
Review of SBO/SBAP outreach efforts
Define CAP responsibilities
Review/comment on new regulations, policies, etc.
Attend training seminars, conferences, etc.
Assess small business concerns
Suggest effective outreach activities
Other1
n Programs
17
15
12
9
9
9
7
5
12
% Programs
32
28
23
17
17
17
13
9
23
Note 1: Less frequently-reported CAP activities classified as "other" included:
• Reviewing operational activities, voluntary compliance policies, and grant applications to provide
improved small business services.
• Providing advice concerning implementation of SBTCP internal administrative procedures.
• Offering suggestions on leveraging resources through trade associations, vendors, suppliers, and
small business trade publications.
• Assessing feedback or interviewing small business persons assisted by SBO/SBAP to determine the
effects of the programs.
• Referring small businesses to SBTCP for assistance.
• Reviewing regulatory complexity and financing assistance issues.
• Working to ensure independence of SBO and staff.
• Expanding assistance to media other than air.
• Promoting permit reviews.
• Reviewing and commenting on the effect of state environmental agency confidentiality and multi-
media policies on the SBTCP.
• Discussing Small Business Development Center partnerships.
4-7
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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 the SBTCPs. Effective
communication among the three components of the programs and among CAPs in all
programs will effectively and efficiently define the role of the CAP and fully maximize
the skills of CAP members in assisting small businesses.
4.2.4 SBO/SBAP/CAP Meetings
As shown in Table 4-5, SBTCPs have recognized the importance of meetings among
the three functions to ensure effective coordination of efforts and use of resources.
One-half of SBOs and SBAPs have scheduled meetings at least quarterly, and nearly
one-half of programs report scheduled meetings among SBOs, SBAPs, and CAPs at
least once a year.
TABLE 4-5
FREQUENCY OF MEETINGS AMONG SBOs, SBAPs, AND CAPs
(number of programs reporting such frequency)
Frequency
Daily
Weekly
Bi-weekly
Monthly
Bi-monthly
Quarterly
Semi-annually
Bi-annually
Annually
Occasionally
TOTAL
SBO & SBAP
11
3
4
5
1
4
1
16
45
SBO & CAP
3
10
1
1
2
8
25
SBO, SBAP, & CAP
2
18
1
5
2
1
29
SBAP & CAP
2
7
1
1
2
6
19
Meetings between SBOs and SBAPs were the most common form of contact,
occurring in 45 programs (85 percent). A majority of these meetings (29 of 45
programs or 64 percent) were regularly scheduled, with frequencies ranging from daily
to biannually. The most commonly scheduled frequency of meeting between SBOs
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and SBAPs, reported for 11 of the 45 programs (24 percent), was daily (Arizona,
Maine, Montana, Nebraska, New Hampshire, North Carolina, South Carolina,
Tennessee, and Washington).
Meetings between SBOs and CAPs were reported for 47 percent of programs (25 of
53). The majority of these meetings, 17 of 25 (68 percent), were regularly scheduled.
The most common frequency of meetings between SBOs and CAPs was quarterly,
reported for 10 of 25 programs, or 40 percent,
29 programs (55 percent) reported meetings involving SBOs, SBAPs, and CAPs.
Nearly all of these meetings, 28 of 29 (97 percent), were regularly scheduled, and the
common frequency was quarterly, reported for 18 of 29 programs (62 percent).
Meetings between SBAPs and CAPs were least often reported, in only 19 programs
(36 percent). Of these, 13 of 19 (68 percent) were regularly scheduled, and the most
common frequency was quarterly, reported for 7 of 19 programs (37 percent).
Detailed information, by program, about meetings between SBTCP functions, is
presented in Appendix E-12.
4.3 SBTCP FINANCIAL ASSISTANCE PROGRAMS
Information about financial assistance programs offered to small businesses to address
environmental compliance needs is provided in Table 4-6.
TABLE 4-6
FINANCIAL ASSISTANCE PROGRAMS
Type of Assistance
Loan Fund
Grant
Loan Guarantee
Tax Exemption
Bonds
# Programs1
6
3
2
2
1
% Programs
11
6
4'
4
2
Note 1: Some SBTCPs offer more than 1 financial assistance program.
4-9
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14 financial assistance programs were offered by 10 of 53 SBTCPs (19 percent)
during the 1995 reporting period. 6 SBTCPs have plans to offer financial assistance
programs to small businesses in the near future. Detailed information about these
financial assistance programs is provided in Appendix E-13.
Only 19 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.
4.4 LEVERAGING OF RESOURCES AND MINIMIZING DUPLICATION OF EFFORTS
Programs reported on the extent to which they leverage resources within their
state/territory, as discussed in Section 4.4.1. SBTCP strategies to exchange
information and resources with other programs is provided in Section 4.4.2.
4.4.1 Leveraging of Resources
Information provided in this section is vital to understanding how some programs with
limited budgets and resources are functioning. Generally, programs report that all
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
leverage resources is shown in Table 4-7. Descriptions of how programs leverage
resources for their SBOs, SBAPs, and CAPs may be found in Appendix E-14.
TABLE 4-7
PROGRAMS THAT REPORT LEVERAGING OF RESOURCES
FOR SBTCP FUNCTIONS
SBO
SBAP
CAP
n Programs
35
43
21
% Programs
66
81
40
4-10
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35 programs (66 percent) indicate some level of leveraging resources for 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 multi-media information or coordinate
outreach with non-air programs to best serve the small business community. Some
SBOs also serve in other roles within the state environmental agency.
43 programs (81 percent) indicate some level of leveraging resources for the SBAP
function in order to maximize their programs' effectiveness. Strategies and sources
of assistance are quite similar to those used by the SBOs.
21 CAPs (40 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. Many CAPs also report receiving a small level of funding for travel and per
diem expenses.
4.4.2 Minimizing Duplication of Efforts Among SBTCPs
44 programs (83 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
with similar industries. Mechanisms that SBAPs employ to avoid duplication of effort
are presented in Table 4-8; program details for this topic are found in Appendix E-15.
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TABLE 4-8
SBTCP MECHANISMS FOR AVOIDING DUPLICATION
Mechanism
Communication with other SBTCPs
Contact with other SBTCPs within EPA regions
Review of EPA documents and/or contact with EPA
Contacts with state and regional air groups
Review of documents from other sources
Gathering of information from electronic sources
# Programs
37
17
8
7
6
6
% Programs
70
32
15
13
1 1
1 1
The most common technique (in 70 percent of programs) employed by SBAPs to
avoid duplication of effort was communication, generally informal, with other SBTCP
personnel or review of documents prepared by other SBTCPs. This technique involved
contact with counterparts in other programs via the telephone or by networking at
events such as conferences and meetings. Discussions of available information and
sharing of this information often resulted from these contacts. Mailing lists also were
used to facilitate information transfer among SBTCPs.
The second most common method for avoiding duplication was contact, generally
formal, with other programs within the same EPA region through conference calls and
other means. This technique was utilized during the 1995 reporting period by 17
programs (32 percent).
The use the Internet for information transfer, although not the most commonly
reported method, may be the most promising mechanism for avoiding duplication of
effort among SBAPs. Posting of information from the federal SBO and SBAP, other
private and university sources, and state SBAPs facilitate efficient use of resources
and would encompass all of the mechanisms currently utilized by SBAPs for avoiding
duplication.
7 programs (13 percent) reported taking no specific actions to avoid duplication of
efforts during the 1995 period.
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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. Of special note, the state programs are not required to comply with
these Federal statutes; thus actions by the states are either voluntary or may be
pursuant to state laws with intents similar to the above-listed Federal statutes.
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, July 1995.
• Conducted educational activities at the Compliance Advisory Panel Training
Program, Pittsburgh, PA, October 1995.
• Responded to telephone hotline inquiries in regard to the three statutes.
• Distributed copies of the three statutes by request to state contacts.
• Provided copies of the three statutes with the 1995 SBTCP Reporting Form.
4.5.1 SBTCP Activities Associated with the Paperwork Reduction Act
22 programs (42 percent) reported specific activities associated with the intent of the
Paperwork Reduction Act. 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.
The most common action taken to follow the intent of the provisions of this act was
CAP review of SBTCP documents to monitor compliance with this Act. In addition,
SBTCPs are working to reduce the number or complexity of permits through the
development of general permits for particular industry sectors and by eliminating
unnecessary permits through increasing exemptions for "insignificant" activities.
Producing concise, easy-to-read documents that summarize regulatory issues also was
cited as an effective activity, since these summaries eliminate the need for small
4-13
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businesses to have copies of full legislative documentation. Overall, these actions
show that many SBTCPs have begun taking significant steps during the 1995
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 4-9 and are detailed, by program, in Appendix E-16.
TABLE 4-9
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE PAPERWORK REDUCTION ACT
Activity
Routine review of documents for compliance
Receiving/providing documents electronically
Simplified/consolidated permits and/or forms
Increasing exemptions for "insignificant" activities
Use of general industry-specific permits
Producing concise, easy-to-read summary documents
n Programs
7
5
5
5
4
3
% Programs
13
9
9
9
8
6
4.5.2 SBTCP Activities Associated with the Regulatory Flexibility Act
22 programs (42 percent) reported activities to follow the intent of the provisions of
the Regulatory Flexibility Act during 1995, as shown in Table 4-10. 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."
TABLE 4-10
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE REGULATORY FLEXIBILITY ACT
Activity
Simplified/consolidated permits and/or forms
Increased exemptions for "insignificant" activities
Use of general industry-specific permits
Routine review of documents for compliance
Amnesty program
Assessing impact of new regulation, policies, etc.
# Programs
5
5
4
4
4
3
% Programs
9
9
8
8
8
6
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SBTCPs have played a major role in ensuring awareness of the effects of regulatory
requirements on small businesses. 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. SBTCPs have
proven 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-17.
4.5.3 SBTCP Activities Associated with the Equal Access to Justice Act
16 programs (30 percent) reported specific activities to follow the intent of the
provisions of the Equal Access to Justice Act, whose purpose 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 by CAPs, the establishment
of pro bono legal services, and the availability of funds for engineering services for
citizen groups aggrieved by permit actions of a regulatory agency. Although programs
mentioned such actions as reductions in the numbers or complexity of permits through
the development of general permits for particular industry sectors, and the elimination
of unnecessary permits through increasing exemptions for "insignificant "activities,
these actions do not adequately address the intent of this Act. The EPA SBO will
work with the programs in 1996 to improve their understanding of the Act and to
develop appropriate actions towards the intent of the Act.
SBTCP actions to follow the intent of the provisions of the Equal Access to Justice
Act are shown in Table 4-11 and detailed, by program, in Appendix E-18.
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TABLE 4-1 1
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE EQUAL ACCESS TO JUSTICE ACT
Activity
Routine review
of documents for compliance
Increasing exemptions for "insignificant" activities
Use of general
industry-specific permits
Other
# Programs
4
3
3
6
% Programs
8
6
6
1 1
Note 1 Other actions, taken by 6 programs, to follow the intent of the Equal Access to Justice Act
are as follows:
• Making funds available to citizens groups aggrieved by permit actions of a regulatory agency for
engineering services.
• Developing and providing information on financial assistance programs to help with capital
expenses.
• Facilitating low permit fees for small businesses.
• Minimizing recordkeeping and reporting requirements by developing limits for types of operations
cited in an exclusionary rule that defines potential emission sources as actual or by allowing small
facilities to use more realistic emissions calculations.
• Establishing pro bono legal services.
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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. Complaints
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 BY SBO OR CAP ON SBTCP
43 programs (81 percent) reported that comments were received by their SBOs or
CAPs on the SBTCP. Comments were overwhelmingly positive, generally expressing
appreciation for the availability of services and the way in which these services were
provided. A detailed list of comments received by SBOs and CAPs on their SBTCPs
is presented in Appendix F-1.
Common themes repeated by small business clients of numerous programs include:
• Appreciation for the availability of a non-regulatory approach to environmental
issues (e.g, a feeling of "partnership" in compliance; or "assistance first,
enforcement second" rather than an "adversarial" approach.
• Expressions that SBTCP services filled an existing need in the small business
community for personalized guidance through the many regulatory processes
involved in compliance.
Only 5 programs (9 percent) reported utilizing a formalized approach to gathering and
recording feedback from clients served. These programs were: Idaho, Iowa,
Minnesota, Tennessee, and West Virginia. Such approaches included:
• Standardized forms to track client evaluations.
• Surveys sent to randomly-selected clients.
• Workshop evaluations.
Attempts to increase the use of formal feedback mechanisms may improve assistance
activities by facilitating the reporting of both positive and negative comments. This
information then could be used to modify existing activities to better serve the needs
of the small business community.
5-1
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5.2 COMPLAINTS RECEIVED BY SBO OR CAP AND RESOLUTION STRATEGIES
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 complaints or issues raised by small business
representatives about SBTCP services and how these issues were resolved. Lessons
learned by one program can be shared with other programs, which thereby can benefit
from these experiences.
26 programs (49 percent) provided examples of complaints received and resolution
strategies employed. 25 programs (47 percent) did not provide information on
complaints received. Only 2 programs (4 percent) indicated that specific complaints
had not been resolved.
Major themes of the issues reported were:
• A lack of communication between businesses and regulatory agencies.
• Widespread misunderstanding 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).
• The need for programs to assist small businesses in financing pollution control
and prevention capital expenses.
Resolution of these issues usually involved SBTCP personnel:
• Providing explanations of regulatory requirements in "plain language."
• Giving one-on-one guidance through the paper work processes.
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• Facilitating communication about flexibility issues between businesses and
regulatory agencies.
• Investigating, developing, or institutionalizing financial assistance programs.
A list of specific issues addressed by SBOs and CAPs and actions taken to resolve the
concerns expressed by the complainants is presented in Appendix F-2.
5.3 PROGRAM HIGHLIGHTS AND ACCOMPLISHMENTS
33 SBTCPs (62 percent) reported on important accomplishments, awards, and
recognitions for their work with the small business community.
The SBTCPs have provided the foundation for better synergy between the regulatory
agencies and small businesses. Through improved communication and cooperation
among SBAPs, programs in such states as Iowa, Louisiana, and Texas have been
active in helping train other programs in assisting small businesses. Amnesty
programs have been supported through the SBTCPs in New York, Kentucky, and Utah,
and these programs have been well received by small businesses that now welcome
the opportunity to achieve compliance. Awards also have been tremendous incentives
for both small businesses and the individual programs.
In this section, key accomplishments are highlighted based on the frequency in which
they were mentioned. An overview of program accomplishments and highlights for
1995 are provided in Appendix F-3.
1. Better synergy between the regulatory agencies and small business was the
most common theme, mentioned directly by 26 percent of the programs
reporting.
2. Improved cooperation among various SBOs and SBAPs was mentioned by 15
percent of the programs.
• Iowa has taken part in training other SBAPs through the EPA SBO's Peer
Match Program.
• The Louisiana SBAP has helped many other programs including North
Dakota's SBO and SBAP.
• Texas was awarded a $25,000 Peer Match Grant to provide training to
other programs on how to set-up small business assistance.
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3. Awards and grants also have been received by individual programs that have
displayed exceptional vision and leadership. 1 1 percent of the programs
reported receiving grants. This funding is valuable in helping not only the
program awarded, but also transitions to other programs in term of shared
support. Many of the programs that received assistance, including Texas and
Louisiana, provided direct support and training to other programs.
• The Colorado SBAP received the "Customer Service Award" from the
Colorado Department of Public Health and Environment.
• The Florida SBAP presently is coordinating an EPA Leadership Grant with
the Florida Small Business Development Centers to provide technical
information to a targeted audience.
• Kansas was awarded a Small Business Leadership Grant in September
1995.
• The Louisiana Small Business Assistance Program received the "Special
Achievement by a Team" award from the secretary of the Department
of Environmental Quality in December 1995.
• Rhode Island's Pollution Prevention Program received recognition and
awards from three separate sources: The National Environmental Awards
Council in 1990, the Robert Rodale National Environmental Achievement
Award in 1991, and a Certificate of Environmental Achievement from
Renew America and the National Awards Council for Environmental
Sustainability in 1995.
• Texas received grants totaling $200,000 in 1995.
4. Awards programs have been effective in providing incentives and role models
for small businesses. This was reported by 8 percent of the programs.
• Arizona's first Annual Small Business Awards Conference was a
tremendous success.
• Montana's SBO helped create a small business environmental awards
program.
• In Utah, the SBO has been actively involved with the Salt Lake Rotary
Club's Environmental Committee as Vice Chair. The "Clear the Air"
Awards Program for vehicular emissions reduction was initiated in
September.
5. SBTCPs found that amnesty programs provide an incentive for small businesses
to achieve compliance by eliminating penalties if violations are corrected in a
specific time frame. 6 percent of the programs reported active amnesty
programs.
• New York has an amnesty program that eliminates penalties for small
businesses that commit to correct violations within 120 days.
5-4
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In August 1995, the Jefferson County (KY) Air Pollution Control District
approved a pilot amnesty program for small business.
In Utah, the preliminary results of the small business permit application
amnesty program indicates that small businesses welcome the
opportunity to achieve compliance.
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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 6.1,
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
45 SBTCPs (85 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, are shown in Table
6-1 and are detailed, by program, in Appendix G-1.
TABLE 6-1
COMMON COMPLIANCE PROBLEMS
Compliance Problem
Not understanding regulatory requirements
Operating without a permit
Uncertain of permitting requirements
Incomplete record keeping
Financing for control requirements
Uncertain how to determine emission inventories
Uncertain how to complete forms
Operating outside NSPS or MACT
Improper disposal of hazardous waste
Fear of arbitrary regulatory enforcement
Overwhelmed by quantity of regulations
Lack of sufficient notification by regulatory agency
No manifest for special or hazardous waste
Uncertain as to which government agency to contact
Labeling of storage areas
Need for multi-media permits
n Programs
22
19
17
8
5
5
4
4
4
3
2
2
1
1
1
1
% Programs
42
36
32
15
9
9
8
8
8
6
4
4
2
2
2
2
6-1
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Examples of less frequently-cited compliance concerns as identified by small
businesses and programs are shown below.
• Concerns about the amount of time required to prepare permits applications and
to maintain records.
• Fear that regulatory enforcement will be arbitrary and capricious.
• Difficulty in completing required mathematical calculations to determine the
Potential to Emit (PTE).
• Not having an operation permit for an air contamination source.
• Not understanding the requirements of an operation permit.
• Not maintaining records to document emissions.
• Not being aware of environmental requirements at state and federal levels.
• Lack of sufficient notification by regulatory agencies.
• Difficulty of small business obtaining a clear and straightforward answer from
the regulatory agency about what is needed to achieve compliance.
• Difficulty in obtaining answers from regulatory agencies, as lines are often busy
and at times regulatory staff do not return calls.
• Fear that talking to regulators will cause a small business to be targeted for
additional scrutiny by the regulators.
• Unavailable regulator flexibility for special conditions including small emitters
and companies manufacturing specialty products.
• Frustration with the multiple layers of regulatory requirements.
• Incorrect assumption by small businesses that if they apply for and are issued
one permit, then they are in compliance with all requirements.
6.2 IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Programs reported on their observations of improvements in understanding and
awareness of regulatory requirements, behavioral changes, and environmental
improvements (if tracked) that they feel have resulted from their compliance
assistance activities.
6-2
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45 programs (85 percent) provided insight as to improvements in regulatory
understanding and compliance. The most common responses, listed by number and
percentage of programs, are provided in Table 6-2 and are detailed, by program, in
Appendix G-2.
TABLE 6-2
IMPROVEMENTS IN REGULATORY UNDERSTANDING
Response
More open communication between sources and
agencies
Increased compliance
Greater understanding of regulations
Reduced apprehension of regulatory agencies and
environmental compliance
Improved attitude about compliance
Businesses including compliance strategies early in their
business plans
Increased registration and permitting of existing sources
Better record keeping
Improvements in pollution prevention practices
Promotion of compliance through on-site visits
Recycling and reuse
Better hazardous waste disposal
# Programs
26
23
20
18
17
9
5
5
5
3
1
1
% Programs
49
43
38
34
32
17
9
9
9
6
2
2
Generally, 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; 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 top three most common compliance problems
mentioned by small businesses, "Not understanding regulatory requirements", and
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"Operating without a permit", were represented positively by facilities as compliments
to program effectiveness, with programs reporting "Greater understanding of the
regulations," and "Increased compliance." This indicates that the SBTCPs are working
to understand the small business community and provide quality service where it is
most needed.
A majority of the programs reported that the most notable improvements in
compliance have been a result of on-site visits. Many of the businesses visited by the
SBAP were not aware of regulations or pollution prevention opportunities and were
eager to be given a chance to comply without the threat of enforcement action.
Seminars and publications were valuable, but not as effective as site visits. The SBAP
has found it more difficult to establish relationships with small businesses through
seminars than with direct personal contact.
The toll-free hot line has been an efficient tool for the SBAPs. Much of the initial
contact between the SBAP and small business owners occurs at this level. The SBAP
often makes telephone contact several times with a small business before being
invited to make a site visit. This resource management tool ensures that on-site visits
are used in the most effective manner to help assist facilities that have the greatest
need.
Two programs, Iowa and Texas, have developed mechanisms to track compliance as
a result of their outreach efforts. The following examples provide statistics that
reflect an improvement in compliance.
• Iowa reported a significant increase in compliance for targeted processes such
as spray painting. Nearly all auto body shops in the state are now aware that
permits are required, and about 500 have been introduced to the state permit-
by-rule option. This has resulted in about 500 fewer permit applications that
need to be processed. An improvement in compliance exists as a result of on-
site activities because clients are provided with assistance until they are in
compliance or until they chose to remain out of compliance.
• Texas provided data on how site visits resulted in an increase in regulatory
compliance in organic finishing processes. Compliance was measured at the
beginning of the site visit using checklists, and compliance was measured again
after the visit. The following improvements in compliance were measured:
— Spray booths: 3 percent increase (from 90 to 93 percent)
- Gun cleaners: 6 percent increase (from 82 to 88 percent)
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— High-volume Low-pressure (HVLP) guns: 5 percent increase (from 92 to
97 percent)
— Prep areas: 14 percent increase (from 73 to 87 percent)
— Low VOC solvents and paints: 32 percent increase (from 36 to 69
percent)
— Stack: 31 percent increase (from 62 to 93 percent)
The following two example responses from New York and Ohio reflect the general
sentiment of many of the programs.
• The State of New York wrote, "SBTCP plays an important role in helping the
regulator to understand the value and needs for compliance assistance in
conjunction with an enforcement element rather than solely an
enforcement/penalty approach to achieving compliance."
• The State of Ohio provided insight into the SBAP experience in helping
businesses, "It is important to stress that these businesses are asking for help
because they want to be in compliance with environmental regulations, but
have been afraid to look closely for fear of what they might find. This fear is
very rarely based upon an actual personal bad experience with the regulating
agency; more often, it is based on industry legend, or stories about what
happened to a similar operation. The businesses visited to date are pleasantly
surprised that they have stumbled upon a government program which can be
of immediate and direct benefit to them."
6.3 RECOMMENDED CHANGES TO FACILITATE SMALL BUSINESS COMPLIANCE
WITH THE CAA
Recommendations made by 44 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 responses, grouped by category and
listed by program, may be found in Appendix G-3.
6-5
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TABLE 6-3
SBTCP RECOMMENDATIONS FOR IMPROVING COMPLIANCE
Recommendation
Flexibility in applying regulations to small businesses
Multi-media pollution control and compliance assistance
Increased funding / continued adequate funding
Mechanisms for financing pollution control equipment
Generic outreach and training materials
Use of Internet for information transfer
# Programs
16
14
13
12
9
5
% Programs
30
26
25
23
17
9
83 percent of all of programs (44) provided at least one recommendation for changes
to improve small business compliance with the CAA. The recommendations most
commonly offered by SBTCPs mirror many of the ideas presented as response actions
to the Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts,
and represent concerns expressed by small business people to SBTCP personnel.
Several of these recommendations reflect dominant themes repeated in data relating
to SBO/SBAP outreach activities, CAP activities, comments from small businesses,
methods of avoiding duplication, and responses to the above-mentioned regulatory
Acts. Major issues addressed through technical assistance include the application of
regulations to small businesses in a flexible manner and the development of financing
mechanisms to assist in the purchase of pollution prevention/control equipment.
Another common recommendation stressed by SBTCPs (26 percent of programs)
involves the expansion of technical assistance into a multi-media effort, addressing
small business concerns about groundwater, soil, and hazardous waste issues.
Generic outreach and training materials, developed on a national level and distributed
to individual programs, represent an effective means of utilizing the limited program
resources to the maximum benefit of small businesses. Federally-produced assistance
materials, prepared for common industry sectors or commonly-experienced compliance
problems, could be used by multiple SBTCPs with minimal modifications. This would
be a time-and cost-effective way of providing the best possible technical assistance
information to the most small businesses at the lowest cost. Combining this
suggestion with the recommendation of further utilizing the potential of the Internet
6-6
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(by providing access to these materials electronically) increases the efficiency of this
approach.
6.4 PROGRAM CONFIDENTIALITY
In early 1 995, 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.
47 programs (89 percent) report no problems with COI or confidentiality issues. 3
programs (6 percent) indicate that no confidentiality program or guarantee of
confidentiality is in place. (3 programs did not respond to the question.)
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 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).
• To maintain confidentiality, businesses can work through the Ombudsman's
office, which is placed under the Director of the Alabama Department of
Environmental Management and not under any regulatory divisions. When SBO
staff receive a call for information and go to the regulatory divisions for
answers, it is understood that the source of these questions is to be kept
confidential unless there is an imminent threat to public health or the
environment.
• Connecticut's program does not offer confidentiality and probably never will.
The State has a liberal Freedom of Information Act that provides for only a few
limited exceptions to the general policy of disclosing governmental documents.
6-7
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CT's program works closely with other service providers, some of which do
offer confidentiality. In situations where confidentiality is an issue, the SBTCP
refers clients to programs within the state that do offer confidentiality...
The SBTCP is working to establish a policy/protocol with the Air Bureau's
Enforcement Division to provide some level of predictability for small businesses
seeking assistance. This policy/protocol likely will take the form of a
Compliance Assistance Agreement that provides for delivery of technical
assistance as part of the Air Bureau's Enforcement Response Policy. CT's
Regulations of Connecticut State Agencies provide for confidentiality
exceptions for company trade secrets.
SBAP is under contract, which states that specific information regarding
businesses (such as name, specialty, specific nature of inquiry, or other trade
information) will not be reported to the regulatory agency; only numbers by
type (SIC codes) are reported. The Kansas Ombudsman (Public Advocate) has
the approval by the Division Director and Bureau Directors to keep information
confidential. Confidentiality has not been an issue.
As structured, the North Dakota SBAP and SBO may not appear to be free of
COI. Although the SBAP staff are part of the permit section, whicn is separate
from the compliance section, it is difficult to know whether small businesses
may be reluctant to request assistance from SBAP, since the SBAP staff are
part of the air pollution control regulatory program. Also, it is unknown
whether small businesses are reluctant to request assistance or confide in the
SBO, since the Ombudsman is housed within and employed the Department of
Health...
With respect to confidentiality, dialogue between the SBO and SBAP has
resulted in the understanding that small businesses may reveal certain
information to the SBO that may be treated as confidential and not disclosed
to, or sought to be disclosed from, the SBAP. Information disclosed by small
businesses directly to SBAP staff is not turned over to the compliance program
staff for enforcement purposes; however, it is expected that a plan for
correcting any violations will be developed. When needed, compliance
assistance will be provided from the SBAP.
It is the SBAP's and SBO's position that confidentiality (disclosure of violations
to enforcement staff) is really a non-issue in North Dakota.
6-8
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APPENDIX A
1995 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 1/1/95 TO 12/31/95
OMB NO.: 2060-0337
EXPIRATION DATE: 7/31/98
INSTRUCTIONS FOR COMPLETING THIS FORM
Provided on the enclosed computer disk is a blank copy of the Annual Reporting Form for the State
Small Business Stationary Source Technical and Environmental Compliance Assistance Program
(SBTCP). 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 first report is January through December 1995.
The blank form on the enclosed disk is provided in two commonly available word processing formats:
WordPerfect 5.1 (SBTCP95.WPF) and Microsoft Word (SBTCP95.MSW). Additionally, Table 3-1 is
provided in a spreadsheet format in Lotus!23 (TABLE3-1 .WK3) and Microsoft ExceKTABLE3-1.XLS).
Please answer the questions on this Form, and return the disk and a hardcopy of the Reporting Form
using the enclosed, pre-addressed mailer.
If this mailer is missing, please return the disk and a hardcopy to:
Ms. Karen V. Brown
Small Business Ombudsman
U.S. Environmental Protection Agency (1230C)
401 M Street, SW
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 January 31, 1996. Please note that this is a new date.
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. 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.
(703) 305-5938 (Telephone)
(800) 368-5888 (Toll-free Hotline)
(703) 305-6462 (Facsimile)
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WHY ARE WE REQUESTING THIS FORM?
As part of the Clean Air Act Amendments of 1990 (CAAA), the U.S. Congress included, as Section
507, the requirement that each state establish a Small 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. Providing the
Form as a blank word processing document on a computer disk is intended to reduce the time required
to prepare the Form and to assist EPA's SBO efforts to compile the information from each state and
prepare the report to Congress.
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.
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 of each state SBTCP. This report is not meant
to be an evaluation of any facet of your program.
• The period covered by this report ,s January through December 1995.
• 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.
• 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.
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
City, State, Zip
Telephone Number
Facsimile Number
PRIMARY CONTACT
ALTERNATE CONTACT
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SECTION 2
ORGANIZATION, STAFFING, OPERATIONS, BUDGET
This section is designed to collect four types of standardized information about your state's SBTCP,
including: Organizational Structure, Staffing Levels, Operations, and Budget.
ORGANIZATION
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 servicesl, 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
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2.3
Please briefly describe where each component of your SBTCP is
located/organized.
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 2.4. In the case
of the SBO, for example, some states have located this component within the Department of
Commerce. Generally, the CAP is located outside of all agencies, with each individual
appointed as defined in Section 507,
SBTCP COMPONENT
SBO
SBAP
CAP
BRIEF DESCRIPTION OF LOCATION
2.4 Has management of the SBAP been contracted to an outside company?
If YES, please complete Question 2.5. If NO, please skip to Question 2.6.
YES
NO
2.5
Who is the outside company that is operating your SBAP?
For the sect/on, "Budget During the Current Reporting Period", please complete for the time
period January through December 1995. 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)
Budget During the Current
Reporting Period
Term of Contract
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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 1995.
An FTE is considered to work 40 hours/week. For example, 2 people working 20 hc~rs/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.
SBO Function
SBO
Other staff (as FTEs)
Number of FTEs
2.7 How many people, measured as full-time equivalents (FTEs), support the SBAP
function?
Please complete this question for the staffing levels that are current as of December 1995.
Use the same definition for an FTE as discussed in Question 2.6.
SBAP Function
All Staff
Number of FTEs
2.8 With respect to the SBAP, how many of these people are paid or serve as (un-
paid) volunteers?
Please complete this question based on the information in Question 2.7, a/so reporting the
results as FTEs. The total should be the same as the total number of FTEs in Question 2.7.
SBAP Staff
Paid
Un-paid Volunteers
Number of FTEs
2.9 How many of the people identified in Question 2.7 would be considered retired
engineers?
Please complete this question based on the information in Question 2.7, also reporting the
results as FTEs. We are interested in knowing if the states are utilizing "retired engineer"
programs (or their equivalent) to support the SBAPs.
SBAP Staff
Retired Engineers
Number of FTEs
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2.10 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 1995. 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 1995.
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
OPERATIONS
2.11 Briefly describe how each component of the SBTCP (i.e., SBO, SBAP, and CAP)
leverages existing personnel resources (within the state).
This quest/on 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
SBO
SBAP
CAP
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
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2.12 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
With this question we are interested in knowing how the states are avoiding COI and
maintaining confidentiality -- particularly in those cases where the SBAP is located within the
regulatory agency.
BUDGET
2.13 Please provide summary information on the funding for each component of your
state's SBTCP (for the period January through December 1995). 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 $5,000.
SBO
SBAP
CAP
BUDGET ($)
SOURCE OF FUNDING (please describe)
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2.14 What was the SBTCP's budget during the previous reporting period {prior to
January 1995)? What is the expected SBTCP budget during the next reporting
period (January through December 1996)?
As with the previous question, please round all numbers to the nearest $5,000. If these
programs did not exist (or were not active) in the previous reporting period, please complete
this question with such words as inactive or did not exist.
SBO
SBAP
CAP
BUDGET DURING PREVIOUS
REPORTING PERIOD ($)
EXPECTED BUDGET FOR NEXT
REPORTING PERIOD ($)
2.15 Briefly describe any significant changes (more than 10%) in the level of funding
between the previous, current, and the next 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.
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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 SBTCP program: SBO, SBAP, and CAP. As you
complete this section, please seek assistance from the SBAP (primarily} and CAP.
SMALL BUSINESS OMBUDSMAN
3.1 Does your state's SBO have a toll-free Hotline?
YES
NO
If YES, is the hotline number accessible nationally or in-state only?
National
In-state only
If YES, please list this number.
3.2 Briefly describe the state SBO's outreach program.
With this question we are interested in compiling statistics on the types and number of people
reached through a variety of outreach activities by the SBO, such as meetings with trade
associations, speeches, mailings, etc. during the 1995 reporting period.
A list of activities is sufficient, 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 this 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 "DID THIS ACTIVITY OCCUR" column.
10
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OUTREACH
ACTIVITY
Meetings
Speaking
Engagements
Brochures/Flyers
Training Sessions
Others (please
specify)
DID THIS ACTIVITY
OCCUR? (YES OR NO)
NUMBER OF
OCCURRENCES DURING
REPORTING PERIOD
NUMBER OF
PEOPLE REACHED
3.3 Please indicate the number of meetings that occurred between the CAP, SBAP,
and SBO during the 1995 reporting period.
We are interested in comparing how much communication occurred between the different
components of each state SBTCP during the 1995 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, orbiannually),
or occasional.
MEETINGS BETWEEN
WHOM
SBO and SBAP
SBO and CAP
SBO and CAP and SBAP
SBAP and CAP
NUMBER OF
MEETINGS DURING
THE REPORTING
PERIOD
FREQUENCY
(Please indicate if monthly, quarterly,
biannually, or occasional)
11
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SMALL BUSINESS ASSISTANCE PROGRAM (SBAP)
3.4 What assistance services are offered by your state's SBAP?
This question requests the most detailed information of your state's SBTCP.
At a minimum, we would like to compile a list of the services offered by your state's SBAP.
The table below /ists these services. Please check those boxes that apply, list additional
services as appropriate and, if possible, indicate the number of services provided, and/or
individua/s/b usin esses reached.
Preferably, but only if you are maintaining such statistics, we would like to compile the number
of businesses helped/reached by the SBAP's services (e.g., general assistance via telephone,
letters, etc.; on-site consultations; seminars/workshops/meetings/etc.; distribution of
fachsheets/manua/s/information packets/etc.) by three-digit Standard Industrial Classification
(SIC) codes. Please complete Table 3.1, which is attached. Computer copies of this table are
provided in both Lotus123 (TABLES-1.WK3) and Excel (TABLE3-1.XLS) formats.
ASSISTANCE SERVICE
GENERAL ASSISTANCE
ON-SITE VISITS
SEMINARS, WORKSHOPS,
MEETINGS, ETC.
FACTSHEETS, MANUALS,
INFORMATION PACKETS
OTHERS
(please specify)
SERVICE
PROVIDED?
(YES OR NO)
# OF SERVICES
PROVIDED DURING
THE REPORTING
PERIOD
n OF INDIVIDUALS
OR BUSINESSES
REACHED
3.5 Does your state's SBAP have a telephone Hotline?
YES
NO
If YES, is this a toll-free number?
YES
NO
12
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If YES, is the number accessible nationally or in-state only?
National
•• =
In-state only
Please list the number.
3.6 Does the SBAP conduct on-site consultations?
3.7 Did your SBAP conduct seminars, workshops, or make any presentations during
the reporting period?
YES
3.8 Did your SBAP prepare and distribute any fact sheets, information packets,
manuals, or other printed materials during the 1995 reporting period?
NOTE: If available, please include a list of documents, that were prepared and distributed by
your SBTCP during the 1995 reporting period.
3.9 Does the SBAP program services include an electronic bulletin board?
If YES, what is the address of the bulletin board?
13
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Please list what information is accessible through this bulletin board.
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
Copies of Regulations
Information on P2 options
Others (please specify)
Please check all
appropriate boxes
If your SBAP has an electronic bulletin board, please indicate, if available, its level of usage
(i.e., how many times was it accessed during the 1995 reporting period)?
Was it helpful?
With this question, we are asking if you have received ANY comments from the bulletin board
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.
14
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3.10 How does your state SBAP avoid duplication of efforts among other state
SBTCPs?
With this question, we are hoping to find out to what extent states are sharing/exchanging
information with other state SBTCPs. For example, what factsheets or information packets
were developed by another state and used (with minimal editing) in your state?
COMPLIANCE ADVISORY PANEL
3.11 What were the major activities of the CAP during this reporting period?
For example, the CAP may have: reviewed documents for readability, assessed small business
concerns, reviewed technical assistance outreach efforts by the SBTCP, established
procedures, or appointed a chairperson.
15
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3.12 Please briefly describe what actions were initiated by the SBTCP/CAP regarding
compliance of the SBTCP with the general principles 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 the SBTCP for compliance with these three
federal acts. To help you, hard copy summaries of these three acts have been included with
this Annual Reporting Form.
16
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SECTION 4
PROGRAM EFFECTIVENESS
7"/7e questions in this section are designed to collect some external assessments of the SBTCP's
program effectiveness and how it is providing a useful service.
We suggest thai 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 CAP or SBO 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 ho w 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 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 1990 CAAA.
YES
NO
If YES, please indicate the date (month/year) such a grant or loan program became/will become
available for each.
If YES, please indicate the funding levels for each grant or loan program.
NAME OF GRANT OR LOAN PROGRAM
FUNDING LEVEL
18
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4.4 What changes would you recommend, at either the state or federal level, to
assist small businesses to comply with the CAAA?
Please list any suggestions you have. We intend to compile the list of recommendations and
highlight these in the report to Congress.
19
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SECTION 5
OTHER INFORMATION
5.1 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 be/ieve is appropriate. Use as much space as necessary.
20
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SECTION 6
COMPLIANCE ASSURANCE
The three questions in this section have been included at the request of EPA's Office of Enforcement
and Compliance Assurance (OECA).
6.1 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 1995?
NOTE: An eligible facility is defined as a stationary source that: 111 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
pollutants.i
Please distinguish between general assistance and on-site assistance. What percentage is this
of the total eligible pool of facilities? Please add additional lines to this table as needed.
INDUSTRY
SECTOR
Example:
Dry Cleaners
A
#OF
GENERAL
ASSISTANCE
71
B
#OF
ON-SITE
ASSISTANCE
14
C
TOTAL n
OF
FACILITIES
ASSISTED
(A + B)
85
D
#OF
ELIGIBLE
FACILITIES
IN YOUR
STATE
400
E
% OF
TOTAL
ELIGIBLE
POOL OF
FACILITIES
(C/D)»100
21%
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6.2 What are the most common compliance problems identified by 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.
6.3 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 SBAP and 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.
This is the end of the SBTCP Annual Reporting Form. Thank you, and all contributors,
to the completeness and accuracy of your state's Report. A copy of the EPA Report
to Congress will be provided upon its submittal.
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APPENDIX B
FEDERAL SMALL BUSINESS OMBUDSMAN
-------
APPENDIX B
OFFICE OF THE EPA SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
401 M STREET, SW (1230-C)
WASHINGTON, DC 20460
800-368-5888
703-305-5938 (in DC area)
703-305-6462 (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 45 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 25 years of management
service with EPA.
Staff Assistants to the Ombudsman are James Malcolm, Chemical Engineer; Arnold B.
Medbury, P.E., Mechanical Engineer; Larry O. 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
703-305-5938 (in DC area)
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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 1,100 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 1995, the SBO reviewed and
monitored 22 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 1995
The SBO's efforts to assist the small business community continue at a high level. Key
accomplishments and activities for 1995 (some of which are on-going) include:
• Hosted second National Small Business Ombudsman and Technical Assistance
Conference attended by 47 states and 2 territories (200 participants).
• Developed external stakeholder guidance and acted as a principal participant in the
Agency's fourth 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).
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Coordinated individual meetings and follow-up meetings among major small
business trade associations and the EPA Administrator, Deputy Administrator, and
four Assistant Administrators to discuss small business issues.
Issued first environmental auditing newsletter entitled, "Small Talk," with a small
business focus in cooperation with the University of Maryland at Baltimore and the
Institute of Environmental Auditing.
Was EPA link to the White House Conference on Small Business, and continue to
work with the EPA senior managers and Small Business Administration to
implement conference recommendations made to EPA.
Developed small business regulatory impact studies for several small business trade
associations.
Participated as a key player in the joint Small Business Administration and Office of
Management and Budget Regulatory Reform Initiative.
Completed, with th.e University of Tennessee's Industrial Services Center and the
EPA Office of Air Quality Planning and Standards, a Third National Satellite
Teleconference on chromium electroplating.
Implemented a grant for the development of on-site environmental auditing and
assessment education and training materials for February 1996 field testing.
Issued a grant for the development of materials and participated in a state
Compliance Advisory Panel training program. This training program was conducted
by the grantee in October 1995.
Conducted EPA Small Business Regional Liaison's Annual Conference in August
1995.
Served as advocate for small businesses in activities of EPA's Permit Improvement
Team.
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APPENDIX C
FEDERAL SMALL BUSINESS
ASSISTANCE PROGRAM
-------
APPENDIX C
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 Control Technology Center (CTC) within the Information Transfer Group
of the Office of Air Quality Planning & Standards (OAQPS).
FEDERAL SBAP ACTIVITIES
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. One
example is the SBAP Bulletin Board System (BBS) on the OAQPS Technology Transfer
Network (TTN), which became operational in December 1995. This system was developed
to assist the state SBAPs with communications and information sharing; it includes a list of
state and EPA small business contacts and programs, and provides an avenue to share
information and outreach materials developed specifically for small businesses. As of March
1996, the SBAP BBS has over 1,600 accesses, with 28 percent of the users representing
state or local SBAPs. A total of almost 500 documents have been downloaded from this
system. At present, there are about 70 to 75 unique users and 30 to 35 items being
downloaded each week.
In addition to the SBAP BBS, the TTN also provides access to the Clean Air Act Amendments
(CAAA) BBS, which provides access to proposed and final rules, background and guidance
documents, plain-English fact sheets, as well as implementation strategy updates and
schedules. TTN access may be obtained by calling 919-541-5742 (for modems up to 14,400
bps), and communications parameters set as follows:
8 data bits
N parity
1 stop bit
terminal emulation of VT100 or VT/ANSI
full duplex.
Also recently available is the SBAP Home Page on the Internet World Wide Web. This Web
site provides access to EPA small business assistance information and materials, as well as
pointers to other Web sites that relate to small business issues. The SBAP Home Page
address is: http://www.epa.gov/oar/oaqps/sbap.html.
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Plain English Guidance Materials
The Federal SBAP is preparing materials for use by the states to explain new EPA CAAA rules
in plain English. These items include short, introductory brochures and more detailed
guidebooks that contain information on options for compliance (including pollution prevention
measures), sample reporting and recordkeeping forms, and example calculations. The
materials are distributed to all state programs in both hard copy and electronic format; this
allows them to customize the items and reproduce as many as needed.
The materials for the Halogenated Solvent Cleaning and Chromium Electroplating and
Anodizing CAAA rules were completed in May 1995. In addition to those distributed by the
state programs, almost 500 hard copies have been distributed directly by the Federal SBAP,
and over 1,300 electronic copies have been downloaded from the OAQPS TTN. Guidance
materials for the Wood Furniture Manufacturing CAAA rule are expected to be completed by
Summer 1996.
Satellite Seminars
The Federal SBAP is working with EPA's Small Business Ombudsman and OAQPS's Education
and Outreach Group through a grant with the University of Tennessee to present a series of
satellite downlink seminars to educate small businesses on new EPA air regulations.
Broadcast statistics are shown in Table 1.
TABLE 1
SATELLITE DOWNLINK SEMINARS
Date
May 1994
May 1995
November 1995
Topic
Dry Cleaning
Degreasing
Chromium Electroplating
# Participants
3,000
1,300
2,000
# Sites
197 sites in 48 states
1 site in Canada
2 sites in Mexico
101 sites in 45 states
1 site in Canada
2 sites in Mexico
140 sites in 43 states
A similar broadcast for Wood Furniture Manufacturing is scheduled for September 1996.
Annual Conference
An annual SBO and SBAP Conference is held by EPA (co-sponsored by OAQPS's Federal
SBAP and the EPA SBO). The purpose of this conference is to facilitate communication
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among the states about issues they face in the implementation and operation of their
programs and to communicate with EPA staff concerning regulatory and policy developments
affecting small businesses. The 1995 meeting was held on January 25-27, in New Orleans,
Louisiana, with over 150 attendees representing 47 states and 2 territories. The 1996
meeting was held on February 28 March 1 in San Diego, California, with 1 50 attendees from
44 states and 2 territories, as well as representatives of many small business industry
associations.
Leadership Grants
In September 1 995, the Federal SBAP awarded the "Leadership Grants to State CAAA Small
Business Centers," funded through the Environmental Technology Initiative. This one-time
program provided $1.5 million for ten model small business assistance projects in 1 5 states.
These grants will assist in the development of model programs and activities that strive to
attain the goals of pollution prevention as the preferred approach, integrate with existing
technical and small business assistance providers, and offer cross-media technical and
compliance assistance. The objective of the Leadership Grant Program is to learn from the
experiences of the awarded centers so as to develop models that can demonstrate to others
effective ways of providing such assistance to small businesses. A list of the awarded
projects, and contacts for each is shown in Table 2.
TABLE 2
LEADERSHIP GRANT PROJECTS
Project Title
Contact
Coordinated Compliance and Pollution Prevention
Assistance for Small Businesses with Metal
Finishing Operations
Tracy Babbidge
Connecticut Department of Environmental
Protection
79 Elm Street
Hartford, CT 06106
203-424-3382
Model Project to Deliver Compliance and Pollution
Prevention Technical Assistance to Small
Businesses Through an On-line Computer System
Richard Rasmussen
VA Department of Environmental Quality
P.O. Box 10009
Richmond, VA 23240-0009
804-762-4020
Development of Multi-media Assistance Through
Small Business Development Centers
Joseph Schlessel
Small Business Assistance Program
FL Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-1344
Support Compliance Assistance and Pollution
Prevention in the Wood Finishing Industry
Leo Raudys
Small Business Assistance Program
MN Pollution Control Agency
Air Quality Division
520 Lafayette Road
St. Paul, MN 55155
612-297-2316
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TABLE 2
LEADERSHIP GRANT PROJECTS
Project Title
Contact
Establish Comprehensive Management System to
Enable Small Businesses to Determine
Environmental Costs
For Accounting System Work and Regulation
Trigger Manual:
Kerry Drake
TX Natural Resource Conservation Commission
P.O. Box 13087
Austin, TX 78711-3087
512-239-1112
For Support Documents for the Environmental
Management System:
Lany Weaver
NM Small Business Assistance Program
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502-6110
505-627-0043
For Measurement System to Assess the Amounts
of Pollution Avoided or Reduced:
Kyle Arthur
OK Department of Air Quality
1000 N.E. Tenth Street
Oklahoma City, OK 73711-1212
405-271-1400
Establish Industrial Mentor-Protege Partnership
Robert Graham
AR Department of Pollution Control and Ecology
8001 National Drive
P.O. Box 8913
Little Rock, AR 72219-8913
501-562-7444
Develop Series of Environmental Training Modules
for Small Business Representatives
Janet Neff
KS Department of Health and Environment
Office of Pollution Prevention
Forbes Field, Building 283
Topeka, KS 66620-0001
913-296-0669
Partnership for Compliance Through Multi-media
Environmental Outreach and Management
Tamara Wharton
UT Department of Environmental Quality
Division of Air Quality
Small Business Ombudsman
150 North 1950 West
P.O. Box 144840
Salt Lake City, UT 84116-3085
801-536-4231
Pollution Prevention
EPA's Pollution Prevention Division, as part of their role in the Federal SBAP, is coordinating
with the National Pollution Prevention Roundtable to assist states in working with their
existing pollution prevention programs to help small businesses.
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Chemical Accident Prevention
The Chemical Emergency Preparedness and Prevention Office is preparing materials to help
states incorporate chemical accident prevention into their programs.
CONTROL TECHNOLOGY CENTER
Affiliation with the CTC provides Federal SBAP "customers" with ready access to EPA
information and expertise through services such as:
• CTC Hotline: 919-541-0800
• Technical Guidance Materials: documents and software
• CTC News: quarterly newsletter that includes a "Small Business Update" section for
Federal SBAP news and activities.
Further information may be obtained from Deborah M. Elmore, Federal SBAP Coordinator,
EPA/OAQPS at:
• 919-541-5437 (telephone)
• 919-541-0242 (fax)
• elmore.deborah@epamail.epa.gov (e-mail).
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APPENDIX D
SBTCP STATUS, BUDGETS, STAFFING
AND ORGANIZATION
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TABLE D-1
PRIMARY AND ALTERNATE CONTACTS
FOR 1995 SBTCP REPORT
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Alabama
Blake Roper, Ombudsman
AL Department of Environmental Management
P.O. Box 301463
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36130-1463
334-271-7925
334-271-7950 fax
Mike Sherman or Jim Moore
Chief, Light Industrial Section
AL Department of Environmental Management
P.O. Box 301463
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36130-1463
334-271-7861
334-279-3044 fax
Alaska
Priscilla P. Wohl, Compliance Assistance
Manager
SBAP Advocate
Department of Environmental Conservation
Compliance Assistance Section
555 Cordova Street
Anchorage, AK 99501
907-269-7591
907-269-7600 fax
Scott Lytle, SBAP Program Manager
Department of Environmental Conservation
Compliance Assistance Section
555 Cordova Street
Anchorage, AK 99501
907-269-7500
907-269-7600 fax
Arizona
Martin Todd Dorris, Technical Assistance
Manager
Small Business Ombudsman
AZ Department of Environmental Quality
3033 N. Central Avenue
Phoenix. AZ 85012
602-207-4337
602-207-4872 fax
Pinal County
Donald P. Gabrielson, Director
SBAP Director/SBO
Pinal County Air Quality Control District
P.O. Box 987
Florence, AZ 85232
520-868-6760
520-868-6754 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Maricopa County
Richard Polito, Program Manager SBEAP
Maricopa County SBEAP
Environmental Services Department
2406 S. 24th Street, Suite C-106
Phoenix, AZ 85034
602-506-5102
602-506-6669 fax
Greg Workman, Environmental Engineer
SBEAP
Maricopa County SBEAP
Environmental Services Department
2406 S. 24th Street, Suite C-106
Phoenix, AZ 85034
602-506-5149
602-506-6669 fax
Pima County &
Tucson
John A. Bernardo, Program Manager
Pima County Department of Environmental
Quality
130 W. Congress Street
2nd Floor
Tucson, AZ 85701-1317
520-740-3342
520-882-7709 fax
David M. Esposito
Pima County Department of Environmental
Quality
130 W. Congress Street
3rd Floor
Tucson, AZ 85701-1317
520-740-3340
520-882-7709 fax
Arkansas
Robert Graham, Ombudsman
Pollution Control and Ecology
8001 National Drive
P.O. Box 8913
Little Rock, AR 72219
501-682-0708
501-682-0707 fax
Elizabeth Boggs, Service Representative
Small Business Assistance Program
Pollution Control and Ecology
8001 National Drive
P.O. Box 8913
Little Rock, AR 72219
501-682-0709
501-682-0707 fax
California
Jim Schoning, Ombudsman
California Air Resources Board
2020 L Street
Sacramento, CA 95814
916-323-6791
916-323-2393 fax
Jon E. Pederson, Air Pollution Specialist
California Air Resources Board
2020 L Street
Sacramento, CA 95814
916-322-2825
916-322-3906 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Colorado
Jocelyn Mills, Small Business Ombudsman
Office of Regulatory Reform
1560 Broadway, Suite 1530
Denver, CO 80202
303-894-7826
303-894-7834 fax
Nick Melliadis, SBAP Coordinator
Small Business Assistance Program
CO Department of Public Health and
Environment
Air Pollution Control Division
4300 Cherry Creek Drive, S
Denver, CO 80222-1530
303-692-3175
303-782-5493 fax
Connecticut
Tracy Babbidge, Small Business Ombudsman
CT DEP
79 Elm Street
Hartford, CT 06106
860-424-3382
860-424-4063 fax
Kristen Cohen, Environmental Analyst
CT DEP
79 Elm Street
Hartford, CT 06106
860-424-3548
860-424-4063 fax
Delaware
George Petitgout, Ombudsman
Department of Natural Resources &
Environmental Control
P.O. Box 1401
Dover, DE 19903
302-739-6400
302-739-6242 fax
gpetitgout@dnrec.state.de.us
Phil Cherry, Director, Business and Permitting
Department of Natural Resources &
Environmental Control
P.O. Box 1401
Dover, DE 19903
302-739-6400
302-739-6242 fax
pcherry@dnrec.state.de. us
District of Columbia
Henry Lopez, Ombudsman
DCRA
2100 Martin Luther King, Jr. Avenue, SE
Room 203
Washington, DC 20020
202-645-6617 x3087
202-645-6622 fax
Olivia Achuko, Environmental Engineer
DCRA
2100 Martin Luther King, Jr. Avenue, SE
Room 203
Washington, DC 20020
202-645-6617 x3017
202-645-6102 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Florida
Joseph H. Schlessel, Ombudsman
FL Department of Environmental Protection
MS 5505
2600 Blair Stone Road
Tallahassee, FL 32399
904-488-1344
904-922-6979 fax
Georgia
Marvin M. Lowry, Ombudsman/Program
Manager
DNR/EPD/Air Protection
4244 International Parkway
Suite 120
Atlanta, GA 30354
404-363-7020
404-363-7100 fax
Anita Dorsey-Word, Coordinator
DNR/EPD/Air Protection
4244 International Parkway
Suite 120
Atlanta, GA 30354
404-362-4842
404-363-7100 fax
Hawaii
Robert Tam, EHS III
Clean Air Branch
P.O. Box 3378
Honolulu, HI 96801
808-586-4200
808-586-4370 fax
Wilfred Nagamini, Program Manager
Clean Air Branch
P.O. Box 3378
Honolulu, HI 96801
808-586-4200
-808-586-4370 fax
Idaho
Doug McRoberts, Policy Analyst
SBO
Division of Environmental Quality
1410 North Hilton
Boise, ID 83706
208-373-0497
208-373-0169 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Illinois
Don Squires, Ombudsman
Illinois EPA
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
217-785-1625
217-782-9039 fax
Mark Enstrom, SBAP Manager
IL Department of Commerce & Community
Affairs
620 East Adams Street
Third Floor
Springfield, IL 62701
217-524-0169
217-785-6328 fax
Indiana
Rainford Hunter, Senior Environmental
Manager
Small Business Assistance Liaison
Indiana Department of Environmental
Management
150 W. Market Street, Suite 703
P.O. Box 6015
Indianapolis, IN 46206-6015
317-233-0726
317-233-5627 fax
Steve Rogers, Director, Office of Business
Relations
Small Business Ombudsman
Indiana Department of Environmental
Management
100 N. Senate Avenue
P.O. Box 6015
Indianapolis, IN 46206-6015
317-232-8598
317-232-8564 fax
Iowa
John Konefes, Director, Iowa Waste Reduction
Center
Iowa Waste Reduction Center
75 BRC
University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
319-273-2926 fax
Mark Trapani, Manager, Iowa Air Emissions
Assistance Program
Iowa Waste Reduction Center
75 BRC
University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
319-273-2926 fax
Kansas
Janet E. Neff, Public Advocate
Ombudsman
KS Department of Health and Environment
Building 283, Forbes Field
Topeka, KS 66620
913-296-0669
913-291-3266 fax
Theresa Hodges, Director, Office of Pollution
Prevention
KS Department of Health and Environment
Building 283, Forbes Field
Topeka, KS 66620
913-296-6603
913-291-3266 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Kentucky
Rose Marie Wilmoth, Air Quality Ombudsman
Natural Resources & Environmental Protection
Cabinet
Office of the Secretary
5th Floor, Capital Plaza Tower
Frankfort, KY 40601
502-564-3350
502-564-3354 fax
Patti R. Kirk, Deputy Commissioner
Department of Community Development
Economic Development Cabinet
Capital Plaza Tower, 23rd Floor
Frankfort, KY 40601
502-564-7140
502-564-3256 fax
Louisiana
Johnny Dykes, Ombudsman
Governor's Office
P.O. Box 94004
Baton Rouge, LA 70804-9004
504-922-3252
504-922-3255 fax
Victor Tompkins, SBAP Program Manager
Department of Environmental Quality
P.O. Box 82135
Baton Rouge, LA 70884-2135
504-765 0102
504-765-0921 fax
Maine
Brian Kavanah, Coordinator, SBTAP
Maine DEP
Station 17
Augusta, ME 04333
207-287-6188
207-287-2814 fax
Ron Dyer, SBO
Maine DEP
Station 17
Augusta, ME 04333
207-287-4152
207-287-2814 fax
Maryland
Linda B. Moran, Program Coordinator
Maryland Department of the Environment
Small Business Assistance Program
2500 Broening Highway
Baltimore, MD 21224
410-631-3165 or 800-433-1247
410-631-5165 fax
John Mitchell, Small Business Ombudsman
Maryland Department of the Environment
OPICA
2500 Broening Highway
Baltimore, MD 21224
410-631-3000
410-631-3936 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Massachusetts
George Frantz, SBAP Manager
Executive Office of Environmental Affairs
Office of Technical Assistance for Toxics Use
Reduction
100 Cambridge Street, #2109
Boston, MA 02202
617-727-3260 x631
617-727-3827 fax
John Raschko, Special Projects Manager
Executive Office of Environmental Affairs
Office of Technical Assistance for Toxics Use
Reduction
100 Cambridge Street, #2109
Boston, MA 02202
617-727-3260 x698
617-727-3827 fax
Michigan
David Fiedler, Manager, Ml Clean Air
Assistance Program
Ml Department of Environmental Quality,
Environmental Assistance Division
P.O. Box 30457
11 6 W. Allegan Street
Lansing, Ml 48909
517-373-0607
517-335-4729 fax
Donna Davis, Technical Assistance
Coordinator, Ml Clean Air Assistance Program
Ml Department of Environmental Quality,
Environmental Assistance Division
P.O. Box 30457
116 W. Allegan Street
Lansing, Ml 48909
517-335-2874
517-335-4729 fax
Minnesota
Mississippi
Laurel Mezner, Ombudsman
MPCA-EPRO
520 Lafayette Road
St. Paul, MN 55155-4194
612-297-8615
612-297-8324 fax
Leo Raudys, SBCAP Coordinator
MPCA-AQD
520 Lafayette Road
St. Paul, MN 55155-4194
612-297-2316
612-297-7709 fax
Jesse Thompson, Jr., SBO & Technical
Assistance Director
Department of Environmental Quality
2380 Highway 80 West
P.O. Box 10385
Jackson, MS 39209
601-961-5171
601-961-5742 fax
Danny Jackson, Chief Air Toxics
Department of Environmental Quality
2380 Highway 80 West
P.O. Box 10385
Jackson, MS 39209
601 961-5171
601-961-5742 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Missouri
Byron F. Shaw, Jr., P.E.
Small Business Technical Assistance Unit Chief
Department of Natural Resources-TAP
1659 E. Elm Street
P.O. Box 176
Jefferson City, MO 65102
573-526-6627
573-526-5808 fax
James F. Penfold, Director, Technical
Assistance Program
Department of Natural Resources - TAP
1659 E. Elm Street
P.O. Box 176
Jefferson City, MO 65102
573-526-6627
573-526-5808 fax
Montana
Jeff Essman, Chairman
Compliance Advisory Panel
2804 Grand Avenue
Billings, MT 59102
406-655-9420
406-655-9421 fax
Mark Lambrecht, Ombudsman
Small Business Assistance Program
1424 9th Avenue
P.O. Box 200501
Helena, MT 59620 0501
406-444-2960
800-433-8773
406-444-1872 fax
Nebraska
Daniel M. Eddinger, Public Advocate
Director of SBAP/Ombudsman
NE Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-3413
402-471-2909 fax
Tom Lamberson, Deputy Director
NE Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-4235
402-471-2909 fax
Nevada
Ralph Capurro, Small Business Ombudsman
NV Division of Environmental Protection
333 W. Nye Lane
Carson City, NV 89710
702-687-4670 x3162
702-687-5856 fax
David Cowperthwaite, SBTCP Administrator
NV Department of Environmental Protection
333 W. Nye Lane
Carson City, NV 89710
702-687-4670 x3118
702-687-5856 fax
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TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
New Hampshire
Rudolph A. Cartier, Jr., Ombudsman
NH Small Business Technical Assistance
Program
64 North Main Street
Concord, NH 03301
603-271-1379
603-271-1381 fax
New Jersey
John J. Serkies, Small Business Ombudsman
NJ Department of Commerce
20 West State Street
CN 823
Trenton, NJ 08625
609-633-7308
609-777-3106 fax
Chuck McCarty, Manager, SBAP
NJ Department of Environmental Protection
401 East State Street
CN 423
Trenton, NJ 08625
609-292-3600
609-777-1330 fax
New Mexico (except
Bernalillo County)
Edgar Thornton, Deputy Secretary NMED,
Ombudsman
New Mexico Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2855
505-827-2836 fax
Cecilia Williams, Chief, Air Quality Bureau
New Mexico Environment Department/Air
Quality Bureau
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-0042
505-827-0045 fax
Bernalillo County
John J. Liberatore, Environmental Health
Specialist II
Albuquerque Environmental Health
One Civic Plaza
P.O. Box 1293
Albuquerque, NM 87103
505-768-1964
505-768-1977 fax
Alana Eager, Manager, Air Pollution Control
Albuquerque Environmental Health
One Civic Plaza
P.O. Box 1293
Albuquerque, NM 87103
505-768-2620
505-768-2617 fax
-------
TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
New York
Tria Case
Acting Small Business Ombudsman
Empire State Development
633 Third Avenue, 32 Floor
New York, NY 10017
212-803-2282
212-803-2309 fax
Marian J. Mudar, PhD, Program Manager
Small Business Assistance Program
NY State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
518-457-3833
518-485-8494 fax
North Carolina
Edythe McKinney, Ombudsman
Small Business Ombudsman's Office
P.O. Box 229583
Raleigh, NC 27626-0583
919-733-1267
919-715-6794 fax
Fin Johnson, Engineer
SBAP
Small Business Ombudsman's Office
P.O. Box 29583
Raleigh, NC 27626-0583
919-733-1267
919-715 6794 fax
North Dakota
Jeff Burgess, Ombudsman
ND Department of Health
P.O. Box 5520
Bismarck, ND 58506-5520
701-328-5153
701-328-5200 fax
Stan Brannin, Vice Chairman, CAP
Basin Hydraulic Company
P.O. Box 970
Dickinson, ND 58602-0970
701-225-8685
701-225-8755 fax
Ohio
Mark R. Shanahan, Ombudsman
Ohio Air Quality Development Authority
50 W. Broad Street
Columbus, OH 43512
614-728-3540
614-752-9188 fax
Richard Carleski, SBAP Manager
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43216-1049
614-728-1742
614-644-3681 fax
Oklahoma
Kyle Arthur, Environmental Specialist II
OK Department of Environmental Quality
1000 N.E. 10th Street
Oklahoma City, OK 73117-1212
405-271-1400
405-271-1317 fax
-------
TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Oregon
Peter Pedone, Sr., CAP Vice Chairperson
OR Department of Environmental Quality
P.O. Box 3818
#16 Ollalie
Sunriver, OR 97707
541-593-7438
Paul Burnet, Ombudsman
OR Department of Environmental Quality
811 SW Sixth Avenue
Portland, OR 97204
503-229-5776
503-229-6124 fax
Pennsylvania
Jon Miller, Air Quality Program Specialist
PA Department of Environmental Protection
P.O. Box 8468
400 Market Street
Harrisburg, PA 17105
717-787-1663
717-772-2302 fax
Puerto Rico
John Woodroffe, Small Business Ombudsman
Commercial Development Administration
P.O. Box S-4275
San Juan, PR 00902
787-728-5585
787-724-4247 fax
Francisco Claudio Rios
SBAP
Environmental Quality Board
Ponce De Leon 431, Hato Rey
P.O. Box 11488
Santurce, PR 00910
787-767-8025
787-756-5906 fax
Rhode Island
Roger Greene, Assistant to the Director
Small Business Ombudsman
Rl DEM Director's Office
9 Hayes Street
Providence, Rl 02903-1037
401-277-2771
401-277-6802 fax
Richard Enander, Principal Environmental
Scientist
Small Business Assistance Program
Rl DEM Pollution Prevention Program
83 Park Street
Providence, Rl 02903-1037
401-277-3434, x4414
401-277-2591 fax
11
-------
TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
South Carolina
Robin S. Stephens, Small Business
Ombudsman
SC DHEC
EQC Administration
2600 Bull Street
Columbia, SC 29201
803-734-6487
803-734-9196 fax
Willie J. Morgan, Permitting Liaison
SC DHEC
EQC Administration
2600 Bull Street
Columbia, SD 29201
803-734-5179
803-734-9196 fax
South Dakota
Joe Nadenicek, Small Business Ombudsman
SD DENR
523 East Capitol
Pierre, SD 57501
605-773-3836
605-773-6035 fax
Brian Gustafson, Natural Resources Engineer
Small Business Assistance Program
SD DENR
523 East Capitol
Pierre, SD 57501
605-773-3351
605-773-4068 fax
Tennessee
Ernest C. Blankenship, Advocate
TN Department of Environment & Conservation
8th Floor, L & C Annex
401 Church Street
Nashville, TN 37243
615-532-8012
615-532-0614 fax
Linda F. Sadler, Manager, CAAP
TN Department of Environment &
Conservation
8th Floor, L & C Annex
401 Church Street
Nashville, TN 37243
615-532-8012
615-532-0614 fax
Texas
Tamra-Shae Oatman, Small Business Advocate
Small Business Ombudsman
TNRCC
P.O. Box 13087, MC 106
Austin, TX 78711
512-239-1066
512-239-1065 fax
Kerry J. Drake, Manager, Technical
Assistance
TNRCC
P.O. Box 13087
Austin, TX 78711
512-239-1066
512-239-1065 fax
1 2
-------
TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Utah
Tamara Wharton, Small Business Ombudsman
Utah Department of Environmental Quality
Division of Air Quality
150 N. 1950 W. North Temple Street
Salt Lake City, UT 84116
801-536-4231
801-536-4099 fax
Frances Bernards, SBAP Coordinator
Small Business Assistance Program
Utah Department of Environmental Quality
Division of Air Quality
150 N. 1950 W. North Temple Street
Salt Lake City, UT 84116
801-536-4056
801-536-4099 fax
Vermont
Kevin J. Bracey, Air Quality Permit Assistant
Acting Ombudsman
Air Pollution Control Division
103 South Main Street
Building 3, South
Waterbury, VT 05671-0402
802-241-3841
802-241-2590
Virginia
John M. Daniel, Jr., Air Division Director
Small Business Ombudsman
Virginia Department of Environmental Quality
P.O. Box 10009
629 E. Main Street
Richmond, VA 23240
804-698-4311
804-698-4510 fax
Richard G. Rasmussen, Jr.. Director SBAP
Small Business Assistance Program
Virginia Department of Environmental Quality
P.O. Box 10009
629 E. Main Street
Richmond, VA 23240
804-698-4394
804-698-4510 fax
Virgin Islands
Austin Moorehead, Director, Division of
Environmental Protection
Department of Planning and Natural Resources
Building 111, Water Gut Homes
St. Croix, VI 00820
809-773-0565
809-773-9310 fax
Marylyn A. Stapleton, SBTAP Coordinator,
DEP
Department of Planning and Natural
Resources
Wheatley Shopping Center II
St. Thomas, VI 00802
809-777-4577
809-774-5416 fax
13
-------
TABLE D-1
(Continued)
STATE OR TERRITORY
PRIMARY CONTACT
ALTERNATE CONTACT
Washington
Bernard Brady, Environmental Engineer
BAP Implementation Coordinator
Washington Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
360-407-6803
360-407-6802 fax
Leighton Pratt, Environmental Planner IV
BAP Ombudsman
Washington Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
360-407-7018
360-407-6802 fax
West Virginia
Ken Shaw, Small Business Ombudsman
WV Division of Environmental Protection
1558 Washington Street, East
Charleston, WV 25311-2599
304-558-1218
304-558-1222 fax
Fred Durham, SBAP Manager
Small Business Assistance Program
WV Division of Environmental Protection
Office of Air Quality
1558 Washington Street, East
Charleston, WV 25311-2599
304-558-1217
304-558-1222 fax
Wisconsin
Roger Nacker, Director, Office of Permit
Information & Environmental Services
Small Business Clean Air Ombudsman
Wisconsin Department of Development
123 West Washington Avenue
P.O. Box 7970
Madison, Wl 53707
608-266-1386
608-267-0436 fax
Clifford Fleener, Clean Air Specialist
Wisconsin Department of Development
1 23 West Washington Avenue
P.O. Box 7970
Madison, Wl 53707
608-264-6153
608-267-0436 fax
Wyoming
Charles N. Raffelson, SBA Coordinator
DEQ/AQD
Herschler Building
122 W. 25th Street
Cheyenne, WY 82002
307-777-7391
307-777-5616 fax
Kelly Pelissier, Management Consultant
Small Business Ombudsman
DEQ
Herschler Building
122 W. 25th Street
Cheyenne, WY 82002
307-777-7758
307-777-7682 fax
-------
TABLE D-2
DATES OF ESTABLISHMENT AND COMMENCEMENT OF SBTCP OPERATIONS
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Final Cty.
Maricopa
Cty.
Pima Cty. &
Tucson
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
MONTH & YEAR OF ESTABLISHMENT
SBO
11/92
6/95
1/93
11/93
N.E.
N.E.
11/93
10/92
7/92
4/93
12/95
12/93
11/92
2/92
SBAP
11/92
6/95
1/93
11/93
1/95
12/93
11/93
before 1990
7/92
4/93
12/95
1/94
11/92
11/92
CAP
11/92
6/95
1/93
N.E.
N.E.
N.E.
6/95
N.E.
7/92
12/94
N.E.
N.E.
1/95
5/93
MONTH & YEAR OPERATIONS BEGAN
SBO
5/93
6/95
1/93
11/93
N.O.
N.O.
11/93
4/95
9/92
4/93
12/95
9/95
11/32
7/92
SBAP
8/94
6/95
3/94
11/93
2/95
12/93
11/93
before 1990
9/92
4/93
12/95
1/94
11/92
7/93
CAP
N.O.
11/95
N.O.
N.O.
N.O.
N.O.
6/95
N.O.
4/94
12/94
N.O.
N.O.
1/95
11/94
No response
10/93
5/92
3/93
10/94
11/93
4/94
9/92
7/94
10/92
3/94
5/94
N.E.
7/95
N.E.
12/93
10/93
5/92
3/93
10/94
11/93
4/94
11/94
7/94
10/92
3/94
5/94
N.O.
11/95
N.O.
12/93
-------
TABLE D-2
(Continued)
STATE OR
TERRITORY
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico (except
Bernalillo County)
Bernalillo County
New York
North Carolina
North Dakota
Ohio
MONTH & YEAR OF ESTABLISHMENT
SBO
6/92
11/92
10/93
4/94
N.E.
10/95
4/92
7/93
8/92
12/93
9/92
1/95
11/94
3/93
10/92
10/92
4/92
1/93
4/92
10/94
SBAP
7/94
11/92
10/93
4/94
9/93
9/94
4/92
7/93
8/92
12/93
9/92
1/95
1/93
11/92
10/92
10/92
4/92
8/93
4/92
10/94
CAP
10/94
11/92
10/93
N.E.
N.E.
9/94
4/92
7/93
8/92
2/93
2/93
1/95
11/95
12/95
10/94
10/94
N.E.
11/94
5/92
10/94
MONTH & YEAR OPERATIONS BEGAN
SBO
6/92
11/92
11/93
4/94
N.O.
10/95
6/93
7/93
5/94
12/93
11/92
3/95
11/94
3/93
9/94
11/95
1/93
1/93
4/92
12/94
SBAP
10/94
11/92
4/94
4/94
11/93
9/94
7/93
7/93
5/94
12/93
11/92
*
1/93
1 1 /92
1/93
3/95
4/92
8/93
4/92
5/95
CAP
3/95
10/93
4/94
N.O.
N.O.
9/94
9/93
7/93
N.O.
2/93
2/93
12/95
3/96
N.O.
11/95
11/95
N.O.
11/94
6/93
1/96
-------
TABLE D-2
(Continued)
STATE OR
TERRITORY
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
US Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MONTH & YEAR OF ESTABLISHMENT
SBO
6/94
8/91
11/92
1/95
5/95
8/93
11/93
1/93
2/92
1/94
N.E.
8/92
1/93
Fall 92
4/94
4/92
3/92
SBAP
6/94
8/91
11/92
11/94
N.E.
8/93
11/92
1/93
1/92
1/94
N.E.
3/93
1/93
Summer 92
11/93
4/92
3/92
CAP
N.E.
1/94
11/92
1/96
N.E.
8/94
4/94
1/93
11/92
11/94
N.E.
11/95
N.E.
Summer 93
1/95
4/92
3/92
MONTH & YEAR OPERATIONS BEGAN
SBO
6/94
1/92
5/93
1/95
5/95
8/93
11/93
3/93
2/92
5/94
N.O.
4/93
1/93
Fall 92
12/94
11/92
5/94
SBAP
10/94
11/91
1/94
11/94
N.O.
8/93
11/92
11/93
1/92
1/93
N.O.
7/93
1/93
Summer 92
5/94
12/92
11/93
CAP
N.O.
11/94
4/93
N.O.
N.O.
8/94
4/94
N.O.
11/94
6/95
N.O.
11/95
N.O.
Fall 93
3 .'9 5
8/94
5/95
N.E. = Not Established; N.O. = Not Operational
* Technical Assistance Coordinator not hired as of 12/95. SBO and Administrator/Program Manager of SBTCP provide technical
assistance services on a limited basis.
-------
TABLE D-3
1995 SBTCP BUDGET INFORMATION AND FUNDING SOURCES
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Final Cty.
Maricopa
Cty.
Pima Cty.
& Tucson
Arkansas
California
Colorado
Connecticut
BUDGET ($)
SBO
165,000
200,000
(FY96 7/95-6/96)
165,000
combined
10,000
73,132
200,000
90,000
160,000
(SBO & SBAP)
SBAP
50,000
combined
10,000
75,000
100,000
89,643
340,000
1 20,000
combined w/SBO
CAP
0
combined
2,100
0
0
5,000
SOURCE OF FUNDING
SBO
Title V fees.
Hazardous Waste
Funds, Solid
Waste Funds,
Surface Water
Funds
Indirect funding
from all programs
including general
fund and program
receipts
Air Quality Permit
Fees (combined)
County's general
fund
EPA allocation and
Title V fees
State Budget Act
Stationary Sources
Cash Fund, from
permitting and
annual fees
State fund that
supports Clean Air
Act - vehicle
registration fees
SBAP
Title V fees,
federal air grant
same
Non-Title V permit
fees
Permit fees &
existing programs
Title V fees,
Hazardous
Materials Landfill
Tipping Fee,
General Operating
Fund
EPA allocation and
Title V fees
State Budget Act
Stationary Sources
Cash Fund, from
permitting and
annual fees
CAP
same
EPA allocation
and Title V fees
0
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
BUDGET {$)
SBO
80,000
30,000
All funded through
SBAP
50,000
No response
65,000
55,000
1 50,000
74,500
200,000
90,000
(40,000 JCAPCD
SBO)
50,000
40,000
0
SBAP
as needed from
SBO
20,000
All funded through
SBAP
55,000
No response
30,000
1 90,000
700,000
232,000
300,000
250,000
400,000
75,000
210,000
CAP
as needed from
SBO
5,000
5,000
No response
5,000
0
3,000
N/A-
from SBO
2,000
0
as needed
N/A
SOURCE OF FUNDING
SBO
Title V
Air grant
Title V fees
Title V fees
No response
Title V fees
Permit &
inspection funds
General
revenues/Title V
fees
Title V fees
Air emission fees
Title V fees
EPA 105 Grant
and County
general funds
Interagency
transfer
Toxics Use
Reduction Program
N/A
SBAP
Air grant
Title V fees
No response
Special projects
funding - federal
grant
EPA 1 05 grant
from IEPA, CAAP
fees
General
revenues/Title V
fees/enforcement
fines
Title V fees
Air emission fees
Title V fees
105 grant, self-
generated
Title V fees
Air general funds,
indirect funds
CAP
District
appropriation
Title V fees
No response
Title V fees
N/A
Legislative
Services Agency
N/A
Air emission fees
Title V fees
N/A
Toxics Use
Reduction
Program
N/A
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
(except Bernalillo
County)
Bernalillo County
New York
BUDGET ($)
SBO
0 (supported by
OTA wmJRA
budget)
80,000
(FY 94-95)
93,000
1 50,000
45,273
1 30,000
105,000
(combined)
46,900
25,000
40,000
10,000
0
1,200,000
SBAP
0
466,000
(FY 94-95)
430,000
150,000
292,528
combined w/SBO
combined
0
75,000
0
205,000
40,000
926,000
CAP
N/A
0
3,000
5,000
10,000
1,000
combined
600
Included in SBAP
0
< 1 ,000
0
30,000
SOURCE OF FUNDING
SBO
N/A
State & County
fees, restricted
funds
Air fees (non-Title
V), 105 grant
Title V fees
Title V fees and
other fees
Air Operating
Permit fees
Title V, 105 Air,
Pollution,
Groundwater, &
Grant Flex
programs
Indirect cost fund
from NDEP
bureaus
Permit fees, 105
grant
Title V fees
Title V fees
Title V fees
NY Clean Air
Fund/Title V fees
SBAP
N/A
State & County
fees, restricted
funds
Air fees (non-Title
V), 105 grant,
EPA grant
Title V fees
Title V fees and
general revenue
Included w/SBO
Indirect cost fund
from NDEP
bureaus
Permit fees, 1 05
grant
Title V fees
Title V fees
Title V fees
NY Clean Air
Fund/Title V fees
CAP
N/A
Unfunded
Air fees (non-Title
V), 105 grant
Title V fees
Title V fees
Air Operating
Permit fees
Clean Air
Management fund
N/A
Title V fees
Title V fees
NY Clean Air
Fund/Title V fees
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
BUDGET ($)
SBO
320,000 (SBO &
SBAP)
30,000
185,000
10,000
30,963
185,000
25,000
64,938
35,000
25,000
900,000 (SBO &
SBAP)
1 ,470,000
1 20,000
0
20,000
SBAP
SBO & SBAP
combined
30,000
195,000
1 1 5,000
173,675
460,000
100,000
42,258
85,000
10,000
SBO & SBAP
SBO, SBAP, CAP
combined; for
fiscal year
135,000
0
310,000
CAP
5,000
0
0
0
2,000
10,000
10,000
0
1,500
5,000
SBO & SBAP
combined
5,000
0
5,000
SOURCE OF FUNDING
SBO
Title V fees
105 grant, state
permit fees. Title
Vfees
Title V fees,
OAQDA resources
Agency indirect
costs
Title V fees
Title V fees
Title V
State P2 Hard-to-
dispose Materials
Account
Title V fees
Title V fees
Title V fees
151 funds, 102
grant funds
Title V fees, EPA
grant "Utah State
Air Fair," EPA
grant "Partnership
for Compliance"
General funds &
federal trust
SBAP
Title V fees
105 grant, state
permit fees. Title
V fees
Title V fees
Air Quality Title V
fees
Title V fees
Title V fees
Title V
State P2 Hard-to-
dispose Materials
Account
Title V fees
Title V fees
Title V fees
combined
Title V fees
Federal trust,
permit fees, and
general fund.
CAP
Title V fees
105 grant, state
permit fees. Title
V fees
N/A
Title V fees
Title V fees
Title V
N/A
Title V fees
Title V fees
Title V fees
combined
Title V fees
General funds &
federal trust.
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
BUDGET ($)
SBO
0
40,000
50,000
5,000
25,000
SBAP
55,000
225,000
90,000
117,000
75,000
CAP
0
5,000
5,000
3,000
10,000
SOURCE OF FUNDING
SBO
Title V fees
Title V fees &
Agency penalties
Program revenue
permit fees
Title V fees
SBAP
Title V fees
Title V fees, 105
grant
Title V fees &
Agency penalties
Program revenue
permit fees
Title V fees
CAP
Title V fees
Agency penalties
Program revenue
permit fees
Title V fees
EPA 105 grants are provided for in the CAAA, Section 105. Funding is distributed to the states through the EPA regional offices.
Leadership grants (Research and Development grants to the states) flow from EPA'a Office of Research and Development through the Innovative Technology Control Program Funding comes
from the President's Environmental Technology Initiative (ETI). funded at $68 for FY 96.
-------
TABLE D-4
SBTCP BUDGETS FOR 1994 AND 1996 REPORTING PERIODS
DESCRIPTIONS OF SIGNIFICANT FUNDING CHANGES
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Final Cty.
Maricopa
Cty.
Pima Cty.
& Tucson
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
BUDGET FOR 1994 REPORTING PERIOD (6)
SBO
1 65,000
0
1 65,000
combined
10,000
70,000
200.000
90,000
100,000
0
30,000
0
50,000
0
65,000
0
50,000
SBAP
50,000
0
combined
10,000
100,000
50,000
340,000
1 20,000
0
0
20,000
256,500
50,000
0
30,000
80,000
300,000
CAP
0
0
combined
600
N/A
0
0
0
10,000
0
1,000
0
5,000
0
0
BUDGET FOR 1996 REPORTING PERIOD ($>
SBO
170,000
200,000
165,000
combined
10,000
80,000
200,000
90,000
325,000
80,000
30,000
No response
55,000
0
65,000
73,000
150,000
SBAP
50,000
combined
combined
10,000
200,000
50,000
146,242
340,000
1 20,000
0
as needed from
SBO
20,000
No response
100,000
0
N/A
450,000
700,000
CAP
0
combined
combined
4,200
Budget
reallocations as
necessary
0
5,500
as needed from
SBO
10,000
No response
7,000
0
5,000
0
3,000
-------
TABLE D-4
(Continued)
STATE OR
TERRITORY
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
(except Bernalillo
County)
Bernalillo County
BUDGET FOR 1994 REPORTING PERIOD ($)
SBO
18,625
150,000
10,000
(0: JCAPCD)
75,000
40,000
0
Not est.
0
0
1 5,000
31,191
1 30,000
105,000
N/A
25,000
0
Inactive
Inactive
SBAP
210,000
250,000
250,000
400,000
90,000
90,000
N/A All activities
funded to date
through OTA as
part of multi-
media P2
programs
0
0
45,000
200,807
combined w/SBO
0
N/A
75,000
0
100,000
Inactive
CAP
0
travel only
400
0
as needed
N/A
N/A
0
0
5,000
0
1,000
0
N/A
0
0
Inactive
Inactive
BUDGET FOR 1996 REPORTING PERIOD ($)
SBO
84,500
200,000
107,000
(46,000: JCAPCD)
unknown
40,000
0
Not est.
79,000
0
1 50,000
47,557
130,000
105,000
No response
80,000
10,000
25,OOO
SBAP
310,000
300,000
250,000
400,000
75,000
60,000
N/A
462,000
0
1 50,000
329,411
combined w/SBO
0
No response
0
260,000
105,000
CAP
0
travel only
2,000
0
as needed
N/A
N/A
0
0
5,000
10,000
1,000
0
No response
0
<3,000
Funded by NM
program
-------
TABLE D-4
(Continued)
STATE OR
TERRITORY
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
BUDGET FOR 1994 REPORTING PERIOD ($)
SBO
950,000
2 10,000 SBO &
SBAP
30,000
Not operational
10,000
29,727
180,000
0
0
35,000
25,000
900,000 SBO &
SBAP
1,160,000 (SBO,
SBAP, CAP
combined; fiscal
year)
70,000
No response
20,000
Inactive
40,000
0
5,000
SBAP
584,250
SBO & SBAP
combined
30,000
Not operational
1 1 5,000
171,807
450,000
0
0
85,000
10,000
SBO & SBAP
combined
combined
1 30,000
310,000
Inactive
230,000
70,000
114,000
CAP
30,000
1,000
1,000
Not operational
0
1,500
10,000
0
0
1,500
5,000
Inactive
combined
N/A
5,000
Inactive
5,000
0
3,000
BUDGET FOR 1996 REPORTING PERIOD ($)
SBO
1,200,000
30,000
560,000
10,000
31,756
190,000
no response
92,000
35,000
50,000
900,000 SBO &
SBAP
1,260,000 (SBO,
SBAP, CAP
combined; fiscal
year)
200,000
20,000
Unknown
40,000
50,000
5,000
SBAP
1,000,000
15,000
375,000
115,000
172,855
500,000
no response
100,000
85,000
10,000
SBO & SBAP
combined
combined
140,000
310,000
65,000
200,000
100,000
117,000
CAP
30,000
1,000
combined
w/SBAP
0
2,120
10,000
no response
10,000
1,500
5,000
included w/SBO
combined
15,000
5,000
5,000
5,000
5,000
3,000
-------
TABLE D-4
(Continued)
STATE OR
TERRITORY
Wyoming
BUDGET FOR 1994 REPORTING PERIOD <$)
SBO
25,000
SBAP
50,000
CAP
0
BUDGET FOR 1996 REPORTING PERIOD ($)
SBO
25,000
SBAP
75,000
CAP
10,000
-------
TABLE D-4
(Continued)
Significant changes (more than 10%) in the level of funding between the 1994, 1995, and 1996 annual budget periods are
described below.
STATE
Alaska
Arizona - Maricopa
County
Arizona - Pima County
& Tucson
Arkansas
Connecticut
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
DESCRIPTION OF SIGNIFICANT BUDGET CHANGES
Program not established during previous reporting period.
There will be a significant increase in the SBEAP budget next year due to the increased revenue generated by bringing new
companies under permit. This increase will be used to expand services provided (P2, hazardous waste, wastewater),
market SBEAP to increase the number of businesses helped while reducing apprehension for entering the system, and
develop educational materials and workshops.
Hazardous Materials Landfill Fee has been redesignated for other uses, more department programs are dependent on
general operating funds, and revisions to county air quality code have delayed reissuance of permits and reduced number
of permitted sources. Resultant drop in revenue and funding will severely affect program operations.
Program has experienced growth in staffing levels and expenses. Added Service Representative to SBAP between
previous and current period. Ran to add Technical Writer following current reporting period.
A projected budgetary increase is expected for the 1 996 calendar year. CTSBTCP will see an increase in funding due to
$1 50,000 SBAP Leadership Grant as well as the addition of two staff people.
The addition of an engineer to the small business program resulted in an increase in the SBAP budget.
SBAP portion was funded primarily through 105b special projects fund. This line item is no longer available. Current
funding for FTE in the SBAP is not known at this time.
SBAP funding has increased each year since we began developing the program. Program development funding was from
grant from IEPA to DCCA. IEPA provided dollars from their 105 grant. Beginning October 1995, (start of FY 96), the
SBAP has been funded and will continue to be funded with Title V fees. Increases in budgets have been due to staff
increase, and since 11/94, due to program activity increases. On 12/31/95, SBAP had 5 staff working with the program:
a program manager, clearinghouse coordinator, outreach coordinator, help line coordinator, and an administrative assistant.
Program start-up required larger budget.
IAEAP funding levels have systematically increased because of DNR-AQB budget increased through collection of Title V
revenues and because of DNR's and businesses' recognition of lAEAP's success in assisting small businesses with
improving compliance rates and emission reduction rates.
Increases needed as the program became fully operational.
In February 1995, Ombudsman employed on a full-time basis to work with the Program. Prior to then, an Ombudsman
was assigned on a part-time basis. CAP members were appointed October 1994; first meeting held March 1995.
JCAPCD SBO was employed during August 1995.
SBO contract was reduced by the funding agency.
-------
TABLE D-4
(Continued)
STATE
Maryland
Minnesota
Mississippi
Missouri
Nevada
New Mexico (except
Bernalillo County)
Bernalillo County
New York
North Carolina
North Dakota
Ohio
Oregon
DESCRIPTION OF SIGNIFICANT BUDGET CHANGES
For the first half of 1995, SBAP funded for three engineers and a dedicated secretary. As a result of MDE's
reorganization, the program was reduced to one engineer and 1 5% of a secretary. The scope of the program was changed
from air-only assistance to multi-media assistance. Funding was moved from the Air and Radiation Management
Administration to the indirect funds from the Office of the Secretary. The program is expected to remain the same for
1996.
96-97 EPA Leadership Grant of $150,000 to provide compliance and P2 assistance to the wood finishing industry.
1995 budget revealed an increase over 10% because of the hiring of the Ombudsman, a Secretary, and a Public Relations
Representative. The Ombudsman Office also entered into a contract with MISSTAP to provide technical assistance visits.
SBO: Addition of clerical assistance was required.
SBAP: The 6 existing FTE have been employed during the previous and current budget periods. It is hoped that removal of
funding constraints will allow recruitment for the 2 vacancies later this budget period of in the next annual period.
CAP: Committee has not been appointed at this time.
This program was only established in January 1995. The increase is expected budget for FY 1996 stems from fact that a
technical assistance person in SBAP has yet to be hired. Additional funds for CAP reflect fact that it only started meeting
in December 1995.
Funding increased from previous year as staffing increased. Future funding will be influenced by lower state appropriations
and competition for Title V resources.
For 1996, anticipate 2.00 FTE and active SBO.
Moved into full SBTCP implementation. Appropriations increased to cover expanded scope of services.
New engineer to be added to SBAP will result in increase in salary, fringes and operations. In addition, a substantial
increase in rent for office space increases budget requirements.
The last 2 calendar years required more resources in the development of the programs than will be required to maintain the
programs, particularly the SBAP. This is based on: 1) past demand for SBAP resources, and 2) estimated small number of
small businesses in ND that will be affected by new rules in the next year.
Budget for SBAP in calendar year 1995 actually covers July-December 1995, which is the first half of the State Fiscal Year
1996. This was the first budget for which these activities had appropriated funds. Calendar year 1996 figures are based
on current projections of both program expenditures and Title V fee revenues. The same applies to the state-appropriated
funds supporting the Ombudsman program. In addition, the Ombudsman program includes funds set aside for providing
financing assistance to small businesses. The revenue source for these funds is a fifty cents per ton fee within the Title V
fee structure.
SBAP is funding some special projects with non-Title V fees. An EPA 105 Grant was awarded to fund a dry cleaner green
sticker project. Additionally, the four Region X SBAPs (Alaska, Idaho, Oregon, Washington) are funding special research
projects through Pacific Northwest Pollution Prevention Research Center in Seattle. Oregon's share of the $200,000
($150,000 Leadership Grant + $50,000 105 Grant) is $25,000 for 1996 and 1997 ($50,000 total). Otherwise, no
increase or decrease in SBAP funding is anticipated.
-------
TABLE D-4
(Continued)
STATE
Puerto Rico
Rhode Island
Texas
Utah
Virgin Islands
Washington
West Virgjnia
DESCRIPTION OF SIGNIFICANT BUDGET CHANGES
Beginning on March 27, 1996, EQB will provide funds through Title V depending on the need of each section.
Change in funding from previous (SBO/SBAP/CAP did not exist) to current (using existing staff to cover SBAP
responsibilities) to next annual budget period reflects SBAP and SBO programs coming on-line.
SBO and SBAP offices were consolidated and four positions eliminated due to agency-wide staff reduction plan. The
elimination of these positions was responsible for the 1 4% reduction in funding.
Ombudsman position was vacated in late 1994, then filled March 1995. The Voluntary Assistance Program (courtesy
inspector) was filled in May. The 1995 budget reflects funds utilized according to these hire dates, as well as professional
development training and operational set-up.
This past summer, two grants were submitted to EPA by the Ombudsman's office. These grants were awarded for 1 )
Utah State Air Fair/small business booth ($10,000 in outreach funds) and 2) Partnership for Compliance/Small Business
Leadership Grant ($150,000 three year project focusing on P2, multi-media, and leveraging with businesses). The 1996
budget projection incorporates the numerous Leadership project outreach activities, which includes business scoping,
summit, and multi-media "road shows" to outlying areas of the state.
Utah's Small Business Advisory Committee was not operational prior to 6/1/95. Since then, the Committee has been
highly active through monthly meetings, outreach efforts, and most recently, subcommittee work. Their projected budget
reflects these projects and also allows for some limited training and coordination opportunities.
Additionally, budgets for all three years includes a 5% inflation increase.
SBAP support provided by the Small Business Development Agency of the University of the Virgin Islands until the second
quarter of 1995.
Expected budget for next reporting period may be lower if 105 grant funds from EPA are not appropriated for state SBAPs.
SBO & SBAP did not operate prior to 1995. SBAP added staff in 1994.
-------
TABLE D-4
(Continued)
COMPARISON OF 1994, 1995. AND 1996 BUDGETS
STATE OH
THwrronv
Alabama
Alaaka
Arizona
Final County
Marlcopa County
Plma County &
Tucaon
Arkanaaa
California
Colorado
Connecticut
Dataware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kanaaa
Kentucky
Maine
Buooer ftm IBM RStmrma PBTOD it)
88O
1 66,000
o
1 86,000
combined
1O.OOO
7O.OOO
2OO.OOO
90.OOO
1OO.OOO
O
30.OOO
O
60.OOO
MAP
6O.OOO
O
combined
10.000
100.000
60,000
34O.OOO
1 2O.OOO
O
O
2O.OOO
268,600
6O.OOO
CAP
O
O
combined
900
N/A
0
O
0
10.000
0
1.000
TOTAL
21 6. OOO
O
1 86.OOO
1O.OOO
100.000
120.6OO
64O.OOO
210.000
1OO.OOO
0
eo.ooo
268.6OO
1 10.OOO
BUDGET FOR 1»95 RB>ORTINa PBVOO It I
SBO
1 86.OOO
2OO.OOO
1 86.OOO
combined
73,132
2OO.OOO
8O.OOO
1 BO.OOO
8O.OOO
3O.OOO
funded
through
SBAP
60.OOO
MAP
6O.OOO
combined
combined
88,843
34O.OOO
12O.OOO
combined
a» needed
from SBO
2O.OOO
funded
through
SBAP
66.0OO
No reeponee.
66.OOO
O
6O.OOO
18,626
16O.OOO
10.OOO
10:
JCAPCD]
76.OOO
4O.OOO
30.000
8O.OOO
3OO.OOO
21O.OOO
26O.OOO
2EO.OOO
4OO.OOO
90,000
6,000
o
o
o
travel only
4OO
O
a* needed
1OO.OOO
8O.OOO
36O.OOO
228.826
4OO.OOO
28O.4OO
47S.OOO
13O.OOO
86.OOO
66.OOO
16O.OOO
74.6OO
2OO.OOO
9O.OOO
(4O.OOO
JCAPCDI
6O.OOO
40.000
3O.OOO
190,OOO
7OO.OOO
232.OOO
3OO.OOO
26O.OOO
4OO.OOO
76,000
CAP
O
combined
combined
2.1OO
O
0
6.0OO
e> needed
from SBO
e> needed
from SBO
funded
through
SBAP
6.0OO
6.OOO
0
3.00O
O
from SBO
2.OOO
0
n needed
TOTAL
216 OOO
2OO.OOO
1 86,000
184,876
640.0OO
210.OOO
21O.OOO
BO.OOO
6O.OOO
NR
1 10.OOO
1OO.OOO
246.OOO
863. OOO
306.6OO
6OO.OOO
342. OOO
I + 40.OOO
JCAPCDI
460.OOO
1 1 6.000
BUDGET FOR 1996 REPORTING PBVOD (•)
SBO
1 70,000
200,000
1 66.0OO
combined
10,000
80,000
200,000
9O.OOO
326.0OO
80.0OO
30.000
NR
66.OOO
SBAP
60, OOO
combined
combined
10.00O
2OO.OOO
60,000
148,242
34O.OOO
1 20.000
O
as needed
from SBO
2O.OOO
NR
100.0OO
CAP
0
combined
combined
4,200
combined
0
6, BOO
as needed
from SBO
10.OOO
NR
7. OOO
TOTAL
220 OOO
200.OOO
166, OOO
230,442
640,000
210.OOO
330.600
80.000
80,000
NR
162,000
66.OOO
73,000
1 60.OOO
84.6OO
2OO.OOO
107. OOO
I46.OOO:
JCAPCDI
unknown
4O.OOO
N/A
460,000
700.0OO
310,000
300,000
260. OOO
4OO.OOO
76, OOO
6,000
0
3,000
0
travd only
2,000
O
as needed
70,000
623, OOO
863.OOO
394,600
600,000
369. OOO
1 + 46,00
0
JCAPCD)
4OO.OOO
1 16, OOO
-------
TABLE D-4
(Continued)
•TATE OR
THOTTORY
Maryland
Maeeacruetta
Mtehtaan
Mirmeeota
Mlialaatppi
Miaapuri
Montana
Nebraska
Nevada
Now Hampehlre
New Jeroev
New Mexico
(except Bernallllo
County)
BarnaUno County
Now York
North Carolina
North Dakota
Ohio
BUDGET FOR 1t»4 REPORTINO PERIOD (»)
SBO
O
Not en.
O
O
16.OOO
31.181
130,000
106.000
N/A
26.OOO
O
Inactive
Inactive
96O.OOO
210.000
SBO ft
SBAP
3O.OOO
Not
operational
1O.OOO
29.727
18O.OOO
O
MAP
90.000
N/A All
aotlvrbea
funded to
date
through
OTAe>
pen of
multi-media
P2
programs
O
O
46.OOO
2OO.8O7
combined
w/SBO
0
N/A
76.000
O
1OO.OOO
Inactive
684,260
SBO ft
SBAP
combined
3O.OOO
Not
operational
116.OOO
171.8O7
46O.OOO
O
CAP
N/A
N/A
0
O
6.OOO
O
LOCO
O
N/A
O
O
Inactive
Inactive
30.000
1.OOO
1.OOO
Not
operational
O
l.BOO
1O.OOO
O
TOTAX
9O.OOO
0
0
O
66.OOO
231.998
13 1.OOO
1O6.OOO
O
1OO.OOO
O
1OO.OOO
1 ,664.260
211.000
81 .OOO
O
126.000
2O3.O34
640.OOO
0
BUDGET FOR 1996 REPORTINO PERIOD 1*1
SBO
O
0
80.000
93.OOO
160.OOO
46.273
130.0OO
1O6.OOO
46.9OO
26.000
40.000
10.000
O
1.2OO.OOO
32O.OOO
3O.OOO
1 86.OOO
1O.OOO
3O.983
186.0OO
26.OOO
SBAP
2 1O.OOO
O
468.OOO
43O.OOO
1 6O.OOO
292.628
combined
w/SBO
combined
O
76.OOO
O
2O6.OOO
4O.OOO
926, OOO
combined
30.000
196.OOO
11 6. OOO
173,676
4 SO, OOO
100.OOO
CAP
0
O
0
3,000
6, OOO
1O.OOO
1.OOO
O
BOO
0
O
<1.OOO
O
3O.OOO
6.OOO
0
O
0
2. OOO
10.OOO
1O.OOO
TOTAL
21O.OOO
O
646,000
526.OOO
306.OOO
347.8O1
131 ,OOO
106.OOO
47.6OO
1OO.OOO
40. OOO
216.OOO
40.OOO
2.168.OOO
326.OOO
80. OOO
38O.OOO
126.OOO
206,838
666.OOO
136,000
BUDGET FOR 1996 REPORTINO PERIOD »|
SBO
0
Not eat.
79 OOO
SBAP
60 OOO
N/A
462, OOO
CAP
N/A
N/A
0
TOTAL
8O OOO
0
641 OOO
No response.
1 60. OOO
47,667
130.OOO
106.OOO
160, OOO
329,411
combined
w/SBO
O
6, OOO
lO.OOO
1.OOO
O
306 OOO
386,968
131.00O
1O6.OOO
No response.
No response
80.OOO
10.0OO
26,000
1.2OO.OOO
No response.
30.OOO
6 60, OOO
1O.OOO
31,766
190. OOO
O
26O.OOO
106.OOO
1.OOO.OOO
0
< 3.OOO
Funded by
NM
program
3O.OOO
16,000
376.000
116.000
172,866
600.000
1.OOO
combined
vu/SBAP
0
2,120
10. OOO
8O.OOO
273.OOO
17O.OOO
2.23O.OO
0
46.OOO
936.OOO
126.00O
206,731
700.OOO
No response
-------
TABLE D-4
(Continued)
STATE OR
TBOUTORY
Rhode Mand
South Carolina
South Dakota
Tanneaaae
Taxaa
Utah
Vermont
Virginia
Virgin lalanda
Washington
Weat Virginia
^/yomlng
BUDGET FOR 1994 REPORTING PERIOD (»)
WO
Not
operational
3B.OOO
26.OOO
9OO.OOO
6BO &
SBAP
1,160.000
ISBO,
SBAP, CAP
combined;
fiacal year)
70,OOO
S8AP
Not
operational
B6.OOO
10.OOO
SBO &
SBAP
combined
combined
13O.OOO
CAP
Not
operational
1,600
B.OOO
Inactive
combined
N/A
TOTAL
O
121. BOO
40.OOO
9OO.OOO
1.16O.OOO
2OO.OOO
No raaponae
2O.OOO
O
4O.OOO
O
6.OOO
26 OOO
310.OOO
O
23O.OOO
7O.OOO
11 4. OOO
eo.ooo
O
0
B.OOO
O
3.000
O
33O.OOO
0
276, OOO
7O.OOO
122,000
7B.OOO
BUDGET FOR 1996 REPORTING PERIOD (»)
9»O
64,938
36.OOO
26. OOO
900.OOO
1,470,000
1 20.OOO
0
2O.OOO
O
4O.OOO
BO.OOO
B.OOO
26, OOO
SBAP
42.268
B6.OOO
10.000
combined
combined
136.0OO
O
3 1O, OOO
66.OOO
226,000
90.OOO
1 1 7. OOO
76, OOO
CAP
0
1,600
6. OOO
combined
combined
6,000
O
6,000
0
6,000
6. OOO
3, OOO
1O.OOO
TOTAL
1O7.196
121.60O
4O.OOO
9OO.OOO
1.4 7O.OOO
260,000
0
336,000
66.0OO
2 70, OOO
146.000
1 26.OOO
1 1 0.OOO
BUDGET FOR 1998 REPORTING PERIOD |J|
SBO
92,000
36,000
60. OOO
900,000 SBO 8,
SBAP
1,280,000
ISBO. SBAP.
CAP combined;
fiscal Year)
200. OOO
SBAP
1OO.OOO
86.OOO
10,000
SBO &
SBAP
combined
combined
140,000
CAP
10.OOO
l.bOO
6,000
Included
w/SBO
combined
I6.0OO
TOTAI
202.OOO
121,600
66,000
9OO.OOO
1.260.OO
0
366,000
No response
20,000
unknown
40.0OO
60,000
6.OOO
26,000
J 1O, OOO
86.OOO
20O.OOO
1 0O.OOO
11 7, OOO
76, OOO
6.000
6. OOO
6.OOO
6,000
3,000
10.0OO
336,000
70.000
246,000
166. OOO
126,000
1 1 0,OOO
10
-------
TABLE D-5
STAFFING INFORMATION
A summary of the number of full time equivalents (FTEs) that support the SBO function and SBAP function are shown in
Table D-5. With respect to the SBAP, the number of paid and unpaid staff are shown separately. The utilization of retired
engineers to serve the SBAP also is indicated.
STATE OR TERRITORY
Alabama
Alaska
Arizona
Final County
Maricopa County
Pima County & Tucson
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
SBO FUNCTION (NO. FTEs)
SBO
1.00
1.00
0.25
1.00
2.00
1.50
*2.00
1.00
0.50
1.00
0.50
1.00
1.50
0.75
1.00
1.00
OTHER STAFF
2.00
0.25
0.25
3.00
*2.00
0.50
0.25
0.50
0.50
SBAP FUNCTION (NO. FTEs)
ALL STAFF
1.00
1.50
2.25
0.25
2.00
1.50
5.50
4.00
2.00
*
1.00
0.50
3.00
3.00
1.00
4.50
12.00
4.00
3.50
PAID
1.00
1.50
0.25
2.00
1.50
5.50
4.00
2.00
*4.00
1.00
0.50
NA
3.00
1.00
4.50
12.00
4.00
3.50
UNPAID
NA
RETIRED
ENGINEERS
2.00
NA
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico (except
Bernalillo County
Bernalillo County
New York
North Carolina
North Dakota
Ohio
SBO FUNCTION (NO. FTEs)
SBO
1.50
* + 1 .00
1.50
1.00
0.20
1.00
1.00
3.00
1.00
1.00
1.00
1.00
0.25
1.00
0.25
0
5.00
1.50
0.50
0.70
OTHER STAFF
0.10
2.50
0.30
4.20
1.00
1.00
0.70
SBAP FUNCTION (NO. FTEs)
ALL STAFF
3.10
11.00
1.00
1.15
1.75
5.00
4.00
6.50
6.00
1.00
1.00
0.30
0.75
1.00
4.20
1.00
4.00
2.50
0.50
3.00
PAID
3.10
11.00
1.00
1.15
1.75
5.00
4.00
6.50
6.00
1.00
1.00
0.30
1.00
1.00
4.20
1.00
4.00
2.50
0.50
3.00
UNPAID
0.33
RETIRED
ENGINEERS
3.00
0
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
SBO FUNCTION (NO. FTEs)
SBO
0.10
0.15
1.00
5.00
1.00
1.00
0.50
2.00
20.50
SBO & SBAP
1.00
0.05
0.10
1.00
0.50
1.00
1.00
0.10
OTHER STAFF
0.20
0.75
1.00
1.00
0.90
0.13
2.00
SBAP FUNCTION (NO. FTEs)
ALL STAFF
3.20
2.35
4.50
10.00
0.50
1.50
0.14
7.00
1.50
1.30
1.00
2.50
1.70
2.50
0.90
PAID
3.20
2.35
10.00
0.50
1.50
0.14
7.00
20.5
1.50
1.30
1.00
2.50
1.70
2.50
0.90
UNPAID
RETIRED
ENGINEERS
Connecticut's SBO and SBAP are merged and have not been established as separate program components.
Kentucky's Jefferson County Air Pollution Control District employed 1 FTE SBO beginning 8/95.
-------
TABLE D-6
CAP STAFFING
STATE OR TERRITORY
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
3
4
4
4
3
3
4
5
4
4
1
4
4
4
2
2
STATE
REGULATORY
EMPLOYEE
1
1
1
1
1
2
1
1
1
1
1
1
1
1
2
2
GENERAL
PUBLIC
2
2
2
2
2
2
1
2
2
4
NOT YET
APPOINTED
3
7
1
3
7
2
2
5
1
7
3
OTHER
6 (non-voting)
1
2
9
-------
TABLE C-6
(Continued)
STATE OR TERRITORY
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico (except Bernalillo
County)
Bernalillo County
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
2
3
4
5
4
4
4
3
3
4
4
2
3
4
5
3
STATE
REGULATORY
EMPLOYEE
1
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
GENERAL
PUBLIC
2
2
2
1
2
2
2
1
1
2
3
2
2
2
2
3
2
NOT YET
APPOINTED
7
1
7
7
2
2
6
2
1
1
OTHER
2
1 (non-voting)
0
1
2
-------
TABLE C-6
(Continued)
STATE OR TERRITORY
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
3
4
4
4
4
2
4
3
3
STATE
REGULATORY
EMPLOYEE
1
1
1
1
1
1
1
1
1
GENERAL
PUBLIC
2
2
2
2
2
1
2
3
2
NOT YET
APPOINTED
7
1
7
unknown
2
1
1
OTHER
1
2
-------
TABLE D-7
ADMINISTRATIVE LOCATION OF SBTCP COMPONENTS
STATE OR TERRITORY
Alabama
Alaska
Arizona
Final County
Maricopa County
Pima County and
Tucson
Arkansas
California
BRIEF DESCRIPTION OF LOCATION
SBO
AL Department of
Environmental Management
Department of
Environmental Conservation,
Compliance Assistance
Section
AZ Department of
Environmental Quality,
Office of Customer Service
& External Affairs
SBAP/SBO functions are
integrated directly into our
permitting and inspection
processes.
AR Department of Pollution
Control and Ecology
(regulatory agency)
CA Air Resources Board
SBAP
AL Department of
Environmental Management,
Air Division & Office of
Public Affairs
Department of
Environmental Conservation,
Compliance Assistance
Section
AZ Department of
Environmental Quality,
Office of Customer Service
& External Affairs
SBAP/SBO functions are
integrated directly into our
permitting and inspection
processes.
Maricopa County
Environmental Services
Department
Pima County Department of
Environmental Quality
AR Department of Pollution
Control and Ecology
(regulatory agency)
CA Air Resources Board
CAP
Independent
Independent, but assisted
by Department of
Environmental
Conservation, Compliance
Assistance Section
Independent, but managed
by AZ Department of
Environmental Quality,
Office of Customer Service
& External Affairs
N/A
Independent, but managed
by AR Department of
Pollution Control and
Ecology (regulatory agency)
Not established
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
BRIEF DESCRIPTION OF LOCATION
SBO
CO Department of
Regulatory Agencies, Office
of Regulatory Reform
CT Department of
Environmental Protection,
Bureau of Air Management
DE Department of Natural
Resources & Environmental
Control, Office of the
Secretary
Environmental Regulation
Administration, Department
of Consumer & Regulatory
Affairs
FL Department of
Environmental Regulation,
Division of Air Resource
Management
Environmental Protection
Division, Air Protection
Branch
Director of Health
Division of Environmental
Quality, Planning and
Support Services Division,
Performance Management
Bureau
SBAP
CO Department of Public
Health and Environment, Air
Pollution Control Division
CT Department of
Environmental Protection,
Bureau of Air Management
DE Department of Natural
Resources & Environmental
Control, Office of the
Secretary
Environmental Regulation
Administration, Department
of Consumer & Regulatory
Affairs
FL Department ot
Environmental Regulation,
Division of Air Resource
Management
Environmental Protection
Division, Air Protection
Branch
Clean Air Bureau (state
regulatory agency)
Division of Environmental
Quality, Permits and
Enforcement Division,
Technical Services Bureau
CAP
Independent
Managed by CT Department
of Environmental Protection,
Bureau of Air Management
Not established
Independent
Independent
Independent
Independent
Independent
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
BRIEF DESCRIPTION OF LOCATION
SBO
IL Environmental Protection
Agency Small Business
Office
IN Department of
Environmental Management,
Office of Business Relations
Iowa Citizens' Aide /
Ombudsman Office
KS Department of Health
and Environment - Office of
Pollution Prevention
Office of the Secretary,
Natural Resources and
Environmental Protection
Cabinet
Governor's Office of Permits
Department of
Environmental Protection
MD Department of the
Environment, Office of
Community Assistance
SBAP
IL Department of Commerce
& Community Affairs
Regulatory Assistance Office
IN Department of
Environmental Management,
Office of Pollution
Prevention and Technical
Assistance
Iowa Waste Reduction
Center, University of
Northern Iowa
Contracted - see table below
Center for Business
Development, College of
Business and Economics,
University of Kentucky
Department of
Environmental Quality, Air
Quality Division
Department of
Environmental Protection
MD Department of the
Environment - Air &
Radiation Management
Administration (Jan-June),
Office of the Secretary
(July-Dec)
CAP
Independent (not yet
appointed)
Independent
Not yet appointed
Independent
Independent
Independent
Independent
Independent
-------
TABLE D 7
(Continued)
STATE OR TERRITORY
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
BRIEF DESCRIPTION OF LOCATION
SBO
Not established
Ml Jobs Commission,
Business Ombudsman Office
MPCA - Environmental
Planning and Review Office
Department of
Environmental Quality, Air
Division
Governor's Office
Small Business Development
Center, MT Department of
Commerce
NE Department of
Environmental Quality,
Office of Public Advocate
Division of Environmental
Protection, Office of the
Administrator
SBAP
Executive Office of
Environmental Affairs at
OTA
Ml Department of
Environmental Quality,
Environmental Assistance
Division
MPCA - Air Quality Division,
Manager's Office
Outside
Department of Natural
Resources (DNR), Division of
Environmental Quality
(DEQ), Technical Assistance
Program (TAP)
Air Quality Division, MT
Department of
Environmental Quality
NE Department of
Environmental Quality,
Office of Public Advocate
Division of Environmental
Protection, Office of the
Administrator
CAP
Not established
Independent
Independent
Independent, but
administrative support
provided by SBAP staff
Independent; staffed by Air
Quality Division, MT
Department of
Environmental Quality
Managed by NE Department
of Environmental Quality,
Office of Public Advocate
Independent; staffed by
SBO & SBAP
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
BRIEF DESCRIPTION OF LOCATION
SBO
SBAP
CAP
New Hampshire
NH Department of
Environmental Services, Air
Resources Division
NH Department of
Environmental Services, Air
Resources Division
Independent; staffed by NH
Department of
Environmental Services, Air
Resources Division
New Jersey
NJ Department of
Commerce & Economic
Development, Division of
Economic Development
NJ Department of
Environmental Protection,
Office of Permit Information
Assistance
Managed by NJ Department
of Environmental Protection
New Mexico (except
Bernalillo County)
Bernalillo County
NM Environment Department
Environmental Health
Department - Environmental
Services Division
NM Environment
Department, Air Quality
Bureau
Environmental Health
Department - Air Pollution
Control Division
Independent
Independent
New York
Empire State Development,
Division for Small Business
(non-regulatory)
NY State Environmental
Facilities Corporation (non-
regulatory)
Independent (NY State
Department of
Environmental
Conservation, coordinator)
North Carolina
NC Department of
Environment, Health, and
Natural Resources, Division
of Environmental
Management
NC Department of
Environment, Health, and
Natural Resources, Division
of Environmental
Management
Independent
North Dakota
Department of Health,
Environmental Health
Section Chief's Office
Department of Health,
Division of Environmental
Engineering, Air Pollution
Control Program
Independent
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
BRIEF DESCRIPTION OF LOCATION
SBO
Ohio Air Quality
Development Authority
(independent, non-
regulatory)
ODEQ, Executive Director's
Office
Department of
Environmental Quality,
Director's Office
PA Department of
Commerce, Entrepreneurial
Assistance Office
Commercial Development
Administration Executive
Office
Rl Department of
Environmental Management,
Office of the Director
Department of Health and
Environmental Control,
Environmental Quality
Control Administration
SBAP
Ohio Environmental
Protection Agency, Division
of Air Pollution Control
ODEQ, Customer Services
Division
Department of
Environmental Quality, AQ
Program Ops
PA Department of
Environmental Protection,
Bureau of Air Quality
(services contracted - see
table below)
Environmental Quality Board,
Air Quality Area Planning
Division
Rl Department of
Environmental Management,
Office of Environmental
Coordination, Pollution
Prevention Section
Department of Health and
Environmental Control,
Environmental Quality
Control Administration
CAP
Independent
Independent, but assisted
by ODEQ, Customer
Services Division
Independent
Not assigned yet.
Independent
Independent
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
US Virgin Islands
Washington
BRIEF DESCRIPTION OF LOCATION
SBO
Department of Environment
and Natural Resources
TN Department of
Environment and
Conservation, Deputy
Commissioner's Office
TX Natural Resource
Conservation Commission
Department of
Environmental Quality,
Division of Air Quality,
Director's Office
Voluntary Assistance
Program (VAP) located in
SBO Office
Department of Environment
Conservation, Air Pollution
Control Division
Department of
Environmental Quality - Air
Division
Small Business Development
Agency of the Department
of Tourism
Washington Department of
Ecology
SBAP
Department of Environment
and Natural Resources,
Division of Environmental
Services
TN Department of
Environment and
Conservation, Pollution
Prevention/Environmental
Awareness Division
TX Natural Resource
Conservation Commission
Department of
Environmental Quality,
Division of Air Quality,
Permits Section
Not operating
Department of
Environmental Quality - Air
Division
Department of Planning and
Natural Resources
Washington Department of
Ecology
CAP
Independent
Not operating
Independent
Department of
Environmental Quality,
Division of Air Quality, SBO
Office
Not operating
Independent
Not established
Independent
-------
TABLE D 7
(Continued)
STATE OR TERRITORY
West Virginia
Wisconsin
Wyoming
BRIEF DESCRIPTION Of LOCATION
SBO
WV Division of
Environmental Protection
Department of Development,
Office of Permit Information
and Environmental Services
Department of
Environmental Quality,
Administration Division
SBAP
WV Division of
Environmental Protection,
Office of Air Quality
Department of Development,
Office of Permit Information
and Environmental
Services/Department of
Natural Resources, Bureau
of Air Management
Department of
Environmental Quality, Air
Quality Division
CAP
Independent
Independent
Independent
-------
TABLE D-7
(Continued)
Three states have contracted the management of the SBAP to an outside entity.
below.
Information on SBAP contractors is provided
STATE
CONTRACTED COMPANY
Kansas
Mr. Frank Orzulak
University of Kansas - Center for Environmental Education and Training
Continuing Education Building
University of Kansas
Lawrence, KS 66045-2608
913-864-3968
913-864-5827 (fax)
Budget: $300,000
Term of Contract: 1 year
Kentucky
Mr. Greg Copley, Director
Center for Business Development
College of Business and Economics
University of Kentucky
227 Business & Economics Building
Lexington, KY 40506-0034
606-257-1131
606-323-1907 fax
Budget: $250,000
Term of Contract: 1 year (7/1/95-6/30/96)
Pennsylvania
Mr. Joseph Knox
PRC Environmental Management, Inc.
1800 John F. Kennedy Boulevard
Sixth Floor
Philadelphia, PA 19103
215-972-0444
SBAP Hotline: 800-722-4743
215-972-0484 (fax)
Budget: $310,000
Term of Contract: 5 years
-------
APPENDIX E
SBTCP ACTIVITIES AND SERVICES
-------
TABLE E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Dry Cleaners
Vehicle Maintenance and Repair
Printers and Printing Industry
Chrome Platers
Degreasers
Metal Fabrication/Finishing/Forging
Others (Not Identified)
Chemicals (Inorganic and Organic)
Paints and Painting
Plumbing/HVAC
Hospitals/Medical/Health Services
Gasoline Distribution (Wholesale, Retail)
Furniture Manufacturing/Repair & Sales
Plastics and Plastic Products
Sawmills, Planing, Wood Products, Etc.
Electroplating
Agriculture/Farming/Crop Services
Wood Furniture
Cut/Crushed Stone and Products
Consultants
Food Products
Construction (Commercial, Residential)
Contractors
Drugs/Pharmaceuticals
Government (City /County/State/Federal)
Asphalt and Asphalt Paving
Cutlery and Handtools
Schools (Colleges, Vocational, etc.)
Utilities
Metalworking Machinery
Manufacturers/Manufacturing
Home/Office Furniture
Textiles and Products
Cleaning/Laundry Services
Concrete
Petroleum/Petroleum Products/Storage
Attorneys/Lawyers
Machinery Manufacturing and Repair
Transportation Services/Equipment
NUMBER
OF
STATES
29
NUMBER OF
ASSISTANCES
GENERAL
4,096
24 | 8,858
22
19
18
13
12
11
2,412
837
4,837
4,953
39,250
384
9 | 308
9 48
Q
9
8
8
8
7
7
^
Q
6
6
5
5
5
5
5
4
4
4
4
A
4
4
4
3
3
3
3
3
186
1,707
46
53
141
119
67
189
507
881
76
173
118
114
520
13
98
92
44
27
426
299
112
247
65
49
50
45
11
ON-SITE
608
193
105
53
16
106
254
55
9
25
22
4
7
45
29
10
2
10
42
2
5
27
5
18
1
1
35
18
20
122
6
1
5
0
TOTAL
4,704
9,051
2,517
890
4,853
5,059
39,504
439
317
73
208
1,711
53
98
170
129
69
199
549
883
81
200
118
119
538
13
98
92
45
28
461
317
132
369
71
50
50
50
11
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Business Organizations/Services
Airports and Air Transportation
Foundries/Smelters
PCB/Electronics
Grain Elevators
Fiberglass Manufacturing/Products
Research and Testing Facilities
Paper and Paper Products
Funeral Services
Electric Equipment and Repair
Glass Manufacturing and Products
Real Estate and Agent/Operators
Aerospace
Media
Boat Manufacturing
Foam/Sytrofoam Products & Manufactur
Welding
Toys & Sporting
Printed Circuit Board Manufacturers
Mining and Mineral Processing
CFC Users
Private Citizen
Oil and Gas Producers
Miscellaneous Repair Shops
Waste/Waste Hauler
Suppliers/Vendors
Non Profit Organizations
Recyclers
Nail Salons
Fabricated Structural Metal
Landscaping
Packaging
Clothing
Opthalmic Goods
Remediation
Hotel/Motel
Rubber Products
Pest Control
Household Appliances
NUMBER
OF
STATES
3
3
3
3
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
135
12
7
15
268
13
6
3
4
111
14
37
21
14
4
2
9
10
25
26
368
215
222
97
61
200
30
28
2
2
0
2
1
1
2
2
1
1
1
2
2
2
4
15
2
2
2
0
2
1
1
4
0
0
10
0
1
0
2
TOTAL
137
14
9
19
283
15
6
5
4
111
16
37
21
14
6
3
10
14
25
26
368
215
232
97
61
201
30
28
2
2
2
2
1
1
2
2
1
1
1
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Ceramics
Wastewater Facilities
Leather
Dairy Products
Pyrolysis Plant
Railroad Equipment
Screw Machinery Products
Maintenance
Coal Preparation
Livestock Feeders
Stone/Glass/Clay
Auto Wrecker Yards
Marine
Trailer Manufacturers
Cotton Gins
Title VI Impacted Businesses
Regulated Storage Tanks
Beauty Shops
Wood Treatment
Asbestos Contractors
Denistry
Tool and Die Industry
Tribal (Native American)
Tires, Scrap
Pollution Control Equipment
Bakery Products
Breweries
TOTALS
NUMBER
OF
STATES
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NUMBER OF
ASSISTANCES
GENERAL
1
1
1
1
0
1
3
4
12
10
10
28
10
25
45
48
584
3
3
10
230
8
8
250
6
5
1
75,738
ON-SITE
1
1
2
9
0
5
3
0
0
1
125
0
0
15
2,075
TOTAL
1
1
1
1
1
1
3
4
13
12
19
28
15
28
45
48
584
3
4
10
355
8
8
250
6
20
1
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Others (Not Identified)
Vehicle Maintenance and Repair
Metal Fabrication/Finishing/Forging
Degreasers
Dry Cleaners
Printers and Printing Industry
Gasoline Distribution (Wholesale, Retail)
Chrome Platers
Consultants
Regulated Storage Tanks
Cut/Crushed Stone and Products
Government (City/County/State/Federal)
Manufacturers/Manufacturing
Chemicals (Inorganic and Organic)
Cleaning/Laundry Services
CFC Users
Denistry
Home/Office Furniture
Paints and Painting
Grain Elevators
Tires, Scrap
Oil and Gas Producers
Private Citizen
Hospitals/Medical/Health Services
Suppliers/Vendors
Construction (Commercial, Residential)
Wood Furniture
Sawmills, Planing, Wood Products, Etc.
Business Organizations/Services
Textiles and Products
Electroplating
Drugs/Pharmaceuticals
Contractors
Electric Equipment and Repair
Plastics and Plastic Products
Cutlery and Handtools
Miscellaneous Repair Shops
Schools (Colleges, Vocational, etc.)
Food Products
NUMBER
OF
OTATpC
w 1 f\ I C.&
12
24
13
18
29
22
9
19
6
1
6
5
4
11
4
2
1
4
9
3
1
2
2
9
2
5
7
8
3
4
7
5
5
3
8
4
2
4
6
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
39,250 254
8,858 193
4,953 106
4,837 16
4,096 608
2,412 105
1,707 4
837 53
881 2
584 0
507 42
520 18
426 35
384 55
247 122
368
230 125
299 18
308 9
268 15
250 0
222 10
215
186 22
200 1
173 27
189 10
141 29
135 2
112 20
119 10
114 5
118
111
53 45
98
97
92
76 5
TOTAL
39,504
9,051
5,059
4,853
4,704
2,517
1,711
890
883
584
549
538
461
439
369
368
355
317
317
283
250
232
215
208
201
200
199
170
137
132
129
119
118
111
98
98
97
92
81
H:\PUBLIC\EPA507YTABLE-E.WK3
-------
TABLE E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Plumbing/HVAC
Concrete
Agriculture/Farming/Crop Services
Waste/Waste Hauler
Furniture Manufacturing/Repair & Sales
Machinery Manufacturing and Repair
Attorneys/Lawyers
Petroleum/Petroleum Products/Storage
Title VI Impacted Businesses
Cotton Gins
Utilities
Real Estate and Agent/Operators
Non Profit Organizations
Metalworking Machinery
Trailer Manufacturers
Auto Wrecker Yards
Recyclers
Mining and Mineral Processing
Printed Circuit Board Manufacturers
Aerospace
Bakery Products
PCB/Electronics
Stone/Glass/Clay
Glass Manufacturing and Products
Marine
Fiberglass Manufacturing/Products
Airports and Air Transportation
Media
Toys & Sporting
Asphalt and Asphalt Paving
Coal Preparation
Livestock Feeders
Transportation Services/Equipment
Welding
Asbestos Contractors
Foundries/Smelters
Tool and Die Industry
Tribal (Native American)
Boat Manufacturing
NUMBER
OF
STATES
9
3
7
2
8
3
3
3
1
1
4
3
2
4
1
1
2
2
2
2
1
3
1
3
1
3
3
2
2
5
1
1
3
2
1
3
1
1
2
NUMBER OF
ASSISTANCES
GENERAL
48
65
67
61
46
45
50
49
48
45
44
37
30
27
25
28
28
26
25
21
5
15
10
14
10
13
12
14
10
13
12
, 10
11
9
10
7
8
8
4
ON-SITE
25
6
2
0
7
5
1
0
1
0
1
3
0
0
0
0
15
4
9
2
5
2
2
4
1
2
0
1
2
0
2
TOTAL
73
71
69
61
53
50
50
50
48
45
45
37
30
28
28
28
28
26
25
21
20
19
19
16
15
15
14
14
14
13
13
12
11
10
10
9
8
8
6
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Pollution Control Equipment
Research and Testing Facilities
Paper and Paper Products
Maintenance
Funeral Services
Wood Treatment
Beauty Shops
Foam/Sytrofoam Products & Manufactur
Screw Machinery Products
Landscaping
Packaging
Remediation
Hotel/Motel
Nail Salons
Fabricated Structural Metal
Household Appliances
Ceramics
Dairy Products
Pyrolysis Plant
Railroad Equipment
Pest Control
Rubber Products
Leather
Wastewater Facilities
Opthalmic Goods
Clothing
Breweries
TOTALS
NUMBER
OF
CT ATF *?
w i n i &w
1
3
3
1
3
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
6
6
3 2
4
4
3 1
3
2 1
3
0 2
2
2
2
2
2
1
1
1
0 1
1
1
1
1
1
1
1
1
75,738 2,075
TOTAL
6
6
5
4
4
4
3
3
3
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Dry Cleaners
Others (Not Identified)
Vehicle Maintenance and Repair
Denistry
Cleaning/Laundry Services
Metal Fabrication/Finishing/Forging
Printers and Printing Industry
Chemicals (Inorganic and Organic)
Chrome Platers
Plastics and Plastic Products
Cut/Crushed Stone and Products
Manufacturers/Manufacturing
Sawmills, Planing, Wood Products, Etc.
Construction (Commercial, Residential)
Plumbing/HVAC
Hospitals/Medical/Health Services
Textiles and Products
Home/Office Furniture
Government (City/County/State/Federal)
Degreasers
Bakery Products
Grain Elevators
Wood Furniture
Electroplating
Oil and Gas Producers
Stone/Glass/Clay
Paints and Painting
Furniture Manufacturing/Repair & Sales
Concrete
Marine
Food Products
Machinery Manufacturing and Repair
Drugs/Pharmaceuticals
Gasoline Distribution (Wholesale, Retail)
Toys & Sporting
PCB/Electronics
Trailer Manufacturers
Livestock Feeders
Agriculture/Farming/Crop Services
NUMBER
OF
STATF"?
*j i r*\ i ^\j
29
12
24
1
4
13
22
11
19
8
6
4
8
5
9
9
4
4
5
18
1
3
7
7
2
1
9
8
3
1
6
3
5
9
2
3
1
1
7
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
4,096 608
39,250 254
8,858 193
230 125
247 122
4,953 106
2,412 105
384 55
837 53
53 45
507 42
426 35
141 29
173 27
48 25
186 22
112 20
299 18
520 18
4,837 16
5 15
268 15
189 10
119 10
222 10
10 9
308 9
46 7
65 6
10 5
76 5
45 5
114 5
1 ,707 4
10 4
15 4
25 3
10 2
67 2
TOTAL
4,704
39,504
9,051
355
369
5,059
2,517
439
890
98
549
461
170
200
73
208
132
317
538
4,853
20
283
199
129
232
19
317
53
71
15
81
50
119
1,711
14
19
28
12
69
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR NUMBER
OF
STATES
Consultants
Airports and Air Transportation
Business Organizations/Services
Boat Manufacturing
Paper and Paper Products
Foundries/Smelters
Fiberglass Manufacturing/Products
Landscaping
Glass Manufacturing and Products
Welding
Foam/Sytrofoam Products & Manufactur
Coal Preparation
Suppliers/Vendors
Petroleum/Petroleum Products/Storage
Pyrolysis Plant
Wood Treatment
Metalworking Machinery
Utilities
Non Profit Organizations
Printed Circuit Board Manufacturers
Aerospace
Waste/Waste Hauler
Cotton Gins
Mining and Mineral Processing
Regulated Storage Tanks
Tires, Scrap
Transportation Services/Equipment
Tribal (Native American)
Auto Wrecker Yards
Screw Machinery Products
Rubber Products
Leather
Opthalmic Goods
Beauty Shops
Maintenance
Asbestos Contractors
Title VI Impacted Businesses
Tool and Die Industry
Pollution Control Equipment
6
3
3
2
3
3
3
1
3
2
2
1
2
3
1
1
4
4
2
2
2
2
1
2
1
1
3
1
1
1
1
1
1
1
1
1
1
1
1
NUMBER OF
ASSISTANCES
I
GENERAL ON-SITE
881
12
135
4
3
7
13
0
14
9
2
12
200
49
0
3
27
44
30
25
21
61
45
26
584
250
11
8
28
3
1
1
1
3
4
10
48
8
6
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
0
0
0
0
0
0
0
0
0
0
0
TOTAL
883
14
137
6
5
9
15
2
16
10
3
13
201
50
1
4
28
45
30
25
21
61
45
26
584
250
11
8
28
3
1
1
1
3
4
10
48
8
6
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
TABLE E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1995 SECTION 507 REPORT)
INDUSTRY SECTOR
Clothing
Private Citizen
Research and Testing Facilities
Schools (Colleges, Vocational, etc.)
Attorneys/Lawyers
Electric Equipment and Repair
Funeral Services
Media
Real Estate and Agent/Operators
CFC Users
Cutlery and Handtools
Asphalt and Asphalt Paving
Contractors
Miscellaneous Repair Shops
Hotel/Motel
Pest Control
Fabricated Structural Metal
Wastewater Facilities
Dairy Products
Ceramics
Household Appliances
Packaging
Recyclers
Railroad Equipment
Nail Salons
Remediation
Breweries
TOTALS
NUMBER
OF
CTATF*;
\j i n i i_w
1
2
3
4
3
3
3
2
3
2
4
5
5
2
1
1
1
1
1
1
1
1
2
1
1
1
1
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
1
215
6
92
50
111
4
14
37
368
98
13
118
97
2
1
2
1
1
1
1
2
28
1
2
2
1
75,738 2,075
TOTAL
1
215
6
92
50
111
4
14
37
368
98
13
118
97
2
1
2
1
1
1
1
2
28
1
2
2
1
H:\PUBLIC\EPA507\TABLE-E.WK3
-------
APPENDIX E 4
SUMMARY OF STATES RESPONDING TO SECTION 6.0 QUESTIONS
AND THE NUMBER OF ASSISTANCES PROVIDED
STATE
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
RETURNED
FORM (Y/N)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
COMPLETED QUESTIONS
(Y/N)
6.1
Y
N
N
Y
Y
Y
N
N
Y
Y
Y
N
N
N
Y
Y
Y
Y
Y
Y
6.2
Y
N
N
Y
Y
Y
Y
Y
Y
N
Y
N
N
Y
Y
Y
Y
Y
Y
Y
6.3
Y
N
Y
Y
Y
Y
Y
Y
N
Y
N
N
Y
Y
Y
Y
Y
Y
Y
RESPONSE TO QUESTION 6.1
# General
Assistance
33
875
# On-site
Assistance
0
28
10,000+ (not specified)
1,670
45
83
43
1,800
913
244
36
1,003
1,613
20
6
0
10
189
74
17
141
5
Total Facilities
Assisted
33
903
10,000 +
940
51
83
53
1,989
987
261
36
1,144
1,618
-------
APPENDIX E-4
(Continued)
STATE
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
RETURNED
FORM (Y/N)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
COMPLETED QUESTIONS
(Y/N)
6.1
Y
Y
N
N
Y
Y
Y
Y
N
N
Y
y
Y
Y
Y
Y
Y
Y
N
Y
Y
6.2
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
Y
Y
6.3
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
Y
Y
RESPONSE TO QUESTION 6.1
n General
Assistance
1,595
5,260
1,357
1,636
790
448
330
65
1,409
245
300
1,292
154
65
130
79
n On-site
Assistance
3
13
72
134
69
46
214
16
8
8
10
24
15
4
200
45
Total Facilities
Assisted
1,598
5,273
1,429
1,770
859
494
544
81
1,417
253
310
1,316
169
69
330
124
-------
APPENDIX E-4
(Continued)
STATE
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
U.S. Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyoming
RETURNED
FORM (Y/N)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
COMPLETED QUESTIONS
IY/N)
6.1
N
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
6.2
Y
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
6.3
Y
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
_ Y
TOTALS
RESPONSE TO QUESTION 6.1
n General
Assistance
302
715
40,618
95
41
123
70
150
281
1,820
77,728
» On-site
Assistance
3
8
126
7
20
1
382
10
17
4
1,949
Total Facilities
Assisted
305
723
40,744
102
61
124
452
160
298
1,824
78,797
-------
TABLE £-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE, BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
AK
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
AR
AR
AR
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
CA
CO
CO
CO
CO
CO
CO
CT
CT
INDUSTRY SECTOR |
| GENERAL
Asbestos Contractors
Chemicals (Inorganic and Organic)
Chrome Platers
CufCrushed Stone and Products
Degreasers
Dry Cleaners
Foundries/Smelters
Gasoline Distribution (Wholesale, Retail)
Printers and Printing Industry
Wood Furniture
Concrete
Dry Cleaners
Food Products
Furniture Manufacturing/Repair & Sales
Machinery Manufacturing and Repair
Metal Fabrlcatlon/Flnshing/Forglng
Regulated Storage Tanks
Saw Mills, Planing, Wood Products, Etc.
Aerospace
Agrfcutture/Farmlng^rop Services
Airports and Air Transportation
Attorneys /Lawyers
Business Organizations/Services
Business Organizations/Services
Chemicals (Inorganic and Organic)
Construction (CommerclaJ, Residential)
Consultants
Dry Cleaners
Electroplating
Food Products
Fou n dries /Smelters
Furniture ManufacturhgyRepaJr & Sales
Government (City/County/State/Federal)
Government (City/County/State/Federal)
Government (City/County/State/Federal)
Government (City/County/State/Federal)
Government (City/County/State/Federal)
Hospltals/Medcal/Health Services
Landscaping
Machinery Manufacturing and Repair
Media
Metal Fabrlcatlon/Finlshing/ForgIng
Metalworklng Machinery
Mining and Mineral Processing
Non Profit Organizations
Others (Not Identified)
Others (Not Identified)
Paints and Painting
Plastics and Plastic Products
Printed Circuit Board Manufactures
Printed Circuit Board Manufacturers
Printers and Printing Industry
Private Citizen
Recycle™
Schools (Colleges, Vocational, etc.)
Stone/Glass/Clay
Supplers/Vendors
Textiles and Products
Transportation Services/Equipment
Tribal (Native American)
Utilities
Vehicle Maintenance and Repair
Waste/Waste Mauler
Wood Treatment
Agricurture/FarmingX>op Services
Degreasers
Dry Cleaners
Electroplating
Printers and Printing Industry
Vehicle Maintenance and Repair
Agrcutture/FarmingX^rop Services
Asphalt and Asphalt Paving
(A)
NUMBER OF
ASSISTANCES
ON-SITE TOTAL
(B) (A +
B)
NO INFORMATION PROVIDED
10
1
3
3
5
4
1
4
1
1
81
a
37
12
39
51
584
S3
19
2
4
15
2
5
11
34
107
14
5
2
2
3
116
1
31
36
25
4
0
4
13
15
3
20
28
79
134
2
9
7
3
21
208
13
28
10
19
1
4
8
15
25
4
3
6
0
4
1
4
5
0
8
0
0
1
0
2
0
1
13
0
0
0
1
0
0
0
0
1
0
2
1
2
1
0
1
0
0
0
0
0
1
0
0
0
2
0
0
0
9
0
0
0
0
0
0
0
1
10
t
3
3
5
4
1
4
1
1
87
8
41
13
43
56
584
91
19
2
5
15
4
5
12
47
107
14
5
3
2
3
tie
1
32
36
27
5
2
5
13
16
3
20
26
79
134
3
9
7
3
23
206
13
28
19
19
1
4
a
15
2S
4
4
NO INFORMATION PROVIDED
20
200
800
10
40
800
2
2
2
0
10
2
a
0
22
200
610
12
46
800
2
2
NUMBER
OF
ELIGIBLE
FACILITIES
(C|
250
89
151
97
326
213
13,000
789
100
900
500
800
% OF
TOTAL
ELIGIBLE
FACILITIES
(A + B)-100/C
268
8 988764
27 1 523 1 8
13,402062
13.190184
2629108
4.4823077
1 1 533587
22
67.777778
9.2
100
H \PUBLIO£PA507\TABLE-E WK3
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE, BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
DC
DE
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
INDUSTRY SECTOR
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic}
Chemicals (Inorganic and Organic)
Cleaning/laundry Services
Construction (Commercial, Residential)
Construction (Commercial, Residential)
Construction (Commercial, Residential)
Consultants
Contractors
Cutlery and Handtools
Cut/Crushed Stone and Products
Cut/Crushed Stone and Products
Cut/Crushed Stone and Products
Drugs/Pharmaceuticals
Food Products
Funeral Services
Glass Manufacturing and Products
Home/Office Furniture
Home/Office Furniture
Home/Office Furniture
Hospitals/Medcal/Heatth Services
Metal Fabrication/Finehing/Forging
Metal Fabrlcatlon/Flnishing/Forging
Metalworking Machinery
Paper and Paper Products
Plastics and Plastic Products
Plumbing/HVAC
Printers and Printing Industry
Printers and Printing Industry
Research and Testing Facilities
Saw Mills, Planing, Wood Products, Etc.
Toys & Sporting
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Dry Cleaners
Agrfcurture/FarmlngyCrop Services
Asphalt and Asphalt Paving
Attorneys/Lawyers
Boat Manufacturing
Business Organ cations/Services
Business Organizations/Services
Chemicals (Inorganic and Organic)
Consultants
Contractors
Cutlery and Handtools
Dry Cleaners
Electric Equcment and Repair
Electric Equpment and Repair
Funeral Services
Furniture Manufacturing/Repair & Sales
Furniture Manufacturing/Repair & Sales
Gasoline Distribution (Wholesale, Retail)
Gasoline Distribution (Wholesale, Retail)
Government (Clty/County/State/Federal)
Hospltals/Medcal/Health Services
Household Appltances
Metal Fabrlcation/Flnishing/Forging
Metal Fabrlcatlon/Flneriing/Forging
Metal Fabrication/Flnlshlng/Forglng
Metal Fabrlcatlon/Flnfchlng/Forging
Metal Fabrlcatlon/Flnlshing/Forging
Miscellaneous Repair Shops
Nail Salons
Oil and Gas Producers
Others (Not Identified)
Others (Not Identified)
Paints and Painting
Painti and Painting
PCB/Electronlcs
Plastics and Plastic Products
Plumbing, HVAC
Printers and Printing Industry
Printers and Printing Industry
GENERAL
(A)
3
1
150
80
2
5
14
237
50
48
100
129
1
50
3
1
1
2
73
72
2
66
241
8
1
3
5
3
255
2
13
5
4
3
45
NO INFORM/
1
1
16
1
4
S
1
64
1
1
91
1
3
2
2
3
3
1
77
3
16
82
2
1
14
1
2
3
11
7
e
i
7
NUMBER OF '
ASSISTANCES
ON -SITE TOTAL
(8) (A+B)
3 6
1 2
10 160
21 101
2
2 7
5 19
1 238
50
48
5 105
16 145
1
50
3
1
1 2
2 4
2 75
5 77
2
13 78
21 262
8
1 2
3
5
1 4
17 272
2
9 18
2 7
4
3
6 51
WON PflOVIDED
1
1
16
1
4
5
1
64
1
1
81
1
3
2
2
3
3
1
77
3
1
1
1
1
1
16
92
2
1
14
1
2
3
11
7
e
1
7
NUMBER
OF
pi If^lQI C
CLIUlOLC
FACILITIES
(C)
250
%OF
TOTAL
cLIufbLt
FACILITIES
(A + B)'100/t
20.4
H:\PUBLIOEPA507\TABLE - E .WK3
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
GA
GA
GA
HI
IA
IA
IA
IA
IA
IA
10
IL
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
LA
MA
MA
MA
MA
MO
INDUSTRY SECTOR
Private Citizen
Real Estate and Agent/Operators
Research and Testing Facilities
Rubber Products
Schools (Colleges, Vocational, etc )
Transportation Services/Equipment
Utilities
Utilities
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Wastewater Facilities
Chrome Platers
Degreasers
Dry Cleaners
Dry Cleaners
Grain Elevators
Manufacturers /Manufacturing
Others (Not Identified)
Printers and Printing Industry
Vehicle Maintenance and Repair
Chrome Platers
Cut/Crushed Stone and Products
Degreasers
Denistry
Dry Cleaners
HospteJs/MedcaJ/Health Services
Tires, Scrap
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Agrfculture/Farming/Crop Service*
Airports and Air Transportation
Chrome Platen
Construction (Commercial, Residential]
Drugs/Pharmaceutical*
Dry Cleaners
Fiberglass Manufacturing/Products
Furniture Manufacturing/Repair & Sales
Hospitals/Medcal/Health Services
MetaJworking Machinery
Paints and Painting
Plumblng/HVAC
Printers and Printing Industry
Utilities
Vehicle Maintenance and Repair
Agrfculture/FarmlngX5rop Service*
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic)
Concrete
Cutlery and Handtools
Electric Equipment and Repair
Electric Equipment and Repair
Fabricated Structural Metal
Furniture Manufacturing/Repair & Sale*
Home/Office Furniture
Home/Office Furniture
Machinery Manufacturing and Repair
Machinery Manufacturing and Repair
Metal Fabrlcation/Flnhhing/Forging
Opthalmlc Goods
Petroleum/Petroleum Products/Storage
Plastics and Plastic Product*
Printer* and Printing Industry
Railroad Equipment
Saw Mills, Planing, Wood Product*, Etc.
Saw Mills, Planing, Wood Product!, Etc.
Others (Not Identified)
Metal FabrlcatJon/Flnlshlng/Forglna
PCB/Electronlci
Printer* and Printing Industry
Vehicle Maintenance and Repair
Chrome Plater*
| NUMBER OF
ASSISTANCES
GENERAL ON-SITE TOTAL
(A) (B) (A+B)
6 e
6 6
2 2
1 1
2 2
2 2
2 2
1 1
a 9
21 21
1 1
13 0 13
11 0 11
19 10 26
NO INFORMATION PROVIDED
25 3 28
25 3 28
150 20 170
188 9 197
25 6 31
500 33 533
NO INFORMATION PROVIDED
NO INFORMATION PROVIDED
60 0 80
30 0 30
40 0 40
230 125 355
430 30 460
152 20 172
250 0 250
808 8 816
088
36 38
4 1 5
38 2 40
1 1
4 4
40 2 42
2 2
9211
17 1 18
8 1 9
14 2 16
1 1
36 3 38
13 1 14
18 2 20
1
1
1
1
1
1
1
2
1
1
3
1
1
3
1
7
1
1
1
3
3
1003 141 1144
4000 3 4003
4 4
1040 6 1046
280 1 281
20 0 20
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
15
11
661
150
700
2,400
2,000
700
1,100
80
25O
105
230
845
152
1,400
2.0OO
400
0
0
800
0
20
% OF
TOTAL
ELIGIBLE
FACILITIES
(A + B)*100/r.
86666667
100
4387292
18S66667
4
7.0833333
9.85
4.4285714
48.454545
75
12
38.095238
154.34783
54.43787
113.15789
17.857143
30.8
10.5
100
100
H :\PUBLIC\£PA50ATABLE - E .WK3
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE INDUSTRY SECTOR |
MD
MD
MD
MD
MD
ME
ME
ME
Ml
MN
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MS
MS
MS
MS
MT
MT
MT
MT
MT
NO
NO
NO
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
ND
NO
NO
ND
Deg'easers
Dry Cleaners
Gasonne Distribution (Wholesale. Retail)
Others (Not Identified)
Vehicle Maintenance and Repair
CFC Users
Degreasers
Paints and Painting
Others (Not Identified)
Agrculture/F arming/Crop Services
Asphalt and Asphalt Paving
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic)
CleaningA-aundry Services
Construction (Commercial, Residential)
Construction (Commercial, Residential)
Construction (Commercial, Residential)
Consultants
Contractors
Cutlery and Handtools
Cut/Crushed Stone and Products
Cut/Crushed Stone and Products
Cut/Crushed Stone and Products
Drugs/Pharmaceuticals
Food Products
Funeral Services
Glass Manufacturing and Products
Home/Office Furniture
Home/Office Furniture
Home/Otflce Furniture
Hospitals/Medcal/Heal* Services
Metal Fabrlcation/Finbhlng/Forglng
Metal Fabricatlon/Finbhlng/Forglng
Metalworking Machinery
Paper and Paper Products
Plastics and Plastic Products
Plumbing/HVAC
Printers and Printing Industry
Printers and Printing Industry
Research and Testing Facilities
Saw Mills, Planing, Wood Products, Etc.
Toys & Sporting
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Chrome Platers
Degreasers
Degreasers
Dry Cleaners
Chrome Platers
Dry Cleaners
Printers and Printing Industry
Vehicle Maintenance and Repair
Wood Furniture
Boat Manufacturing
Chrome Platen
Cotton Qlns
CufCrmh«d Stone and Products
Degrea**ni
Dry Cleaners
Electric Equfcment and Repair
Electric Equipment and Repair
Gasoline Distribution (Wholesale, Retail)
Grain Elevators
Metal Fabrlcation/Flnishlng/Forging
Printers and Printing Industry
Saw Mills, Planing, Wood Products, Etc.
Textiles and Products
Textiles and Products
Wood Furniture
Degreasers
Electroplating
Gasoline Distribution (Wholesale, Retail)
Oil and Gas Producers
GENERAL
(A)
200
25
500
50
800
365
1150
96
NUMBER OF
ASSISTANCES
ON-SITE TOTAL
(B) (A
0
3
0
0
0
4
1
tB)
200
28
500
50
800
365
1154
96
NO INFORMATION PROVIDED
2718
2
2
150
3
80
2
14
5
237
50
48
100
1
129
50
3
1
1
72
73
2
2
66
241
8
1
3
5
255
3
2
13
S
3
4
10
20
1004
323
86
271
342
111
3
40
45
5
a
100
100
5
> 1,000
35
5
3
4
50
50
5
6
11
10
221
70
10
3
21
5
2
1
5
18
1
5
2
2
13
21
1
17
1
6
2
0
0
0
72
a
30
7
23
1
2
1
0
0
0
3
0
0
0 >1
0
3
1
4
2
3
3
10
2788
2
2
160
8
101
2
19
7
238
50
48
105
1
145
50
3
1
2
77
75
4
2
79
262
a
2
3
5
272
4
2
19
7
3
4
10
20
1004
395
8
96
278
365
112
5
41
45
5
8
103
100
5
000
35
a
4
8
52
S3
8
e
11
10
231
NUMBER
OF
PI tr^ipi P
CLIUlDLC
FACILITIES
(C)
50,000
750
5.000
100,000
2,000
8.0OO
1,154
99
15
30
1500
385
8
96
350
500
1124
100
100
45
40
500
100
100
> 1,000
100
500
210
200
500
6
3
5
%OF
TOTAL
Ft IAIRI P
CLtulDLC
FACILITIES
(A + B|'100/[
0.4
3 7333333
10
0.05
40
100
66.886687
86.866667
66.933333
100
100
100
79.428571
73
9.9644128
5
41
100
12.5
20.6
100
5
100
35
1.6
24.761905
26.5
16
100
100
100
H \PUBllCtPA507\TABLE-E.WK3
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
ND
NE
NE
ME
NE
NE
NE
NE
NE
NE
NE
NH
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NM
NM
NM
NV
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
INDUSTRY SECTOR | NUMBER OF
ASSISTANCES
Wood Furniture
Degreasers
Dry Cleaners
Electroplating
Fiberglass Manufacturing/Products
Government (City/County/State/Federal)
Gram Elevators
Livestock Feeders
Manulacturers/Manufacturng
Vehicle Maintenance and Repair
Welding
Asphalt and Asphalt Paving
Bakery Products
Beauty Shops
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic)
Chemicals (Inorganic and Organic)
Cleaning/Laundry Services
Dairy Products
Drugs/Pharmaceuticals
Food Products
Food Products
Furniture Manufacturing/Repair & Sales
Gasoline Distribution (Wholesale, Retail)
Gasoline Distribution (Wholesale, Retail)
Glass Manufacturing and Products
Glass Manufacturing and Products
Government (City/County/State/Federal)
Home/Office Furniture
Hospltals/Medcal/Hearth Services
Hotel/Motel
Metal Fabrlcadon/Flnbhlng/Forging
Metal Fabrlcation/Flnbhing/Forglng
Metal Fabrlcation/Flnlshlng/ForgIng
Miscellaneous Repair Shops
Others (Not Identified)
Others (Not Identified)
Paints and Painting
Petroleum/Petroleum Products/Storage
Plastics and Plastic Products
Plastics and Plastic Products
Plumbing/HVAC
Printers and Printing Industry
Printers and Printing Industry
Real Estate and Agent/Operators
Real Estate and Agent/Operators
Recyclers
Schools (Colleges, Vocational, etc.)
Schools (Colleges, Vocational, Etc.)
Schools (Colleges, Vocational, Etc.)
Screw Machinery Products
Vehicle Maintenance and Repair
Chrome Platen
Degreasers
Dry Cleaners
Airports and Air Transportation
Attorneys/Law yen
Breweries
Business Organizations/Services
Business Organizations/Services
Business OrganteationsyServices
Business Organteations/Services
Ceramics
Chemicals (Inorganic and Organic)
CleaningXaundry Services
Clothing
Construction (Commercial, Residential)
Consultants
Contractors
Drugs/Pharmaceuticals
Dry Cleaners
GENERAL ON-SITE TOTAL
(A) (8) (A +
52
28 1
12 2
8 1
8 2
130 15
208 12
10 2
28 8
10 2
8 1
NO INFORMATION PROVIDED
2
5
3
1
3
2
7
85
1
3
2
3
1
13
6
10
2
2
1
1
2
20
4
3
5
3
3
4
3
15
5
8
2
14
13
7
15
3
16
16
3
19
30 3
900 3
65 16
NO INFORMATION PROVIDED
4
19
1
12
77
21
9
1
6
2
1
96
229
14
7
38
B)
52
29
14
9
8
145
220
12
36
12
9
2
20
3
1
3
2
17
165
1
6
2
3
1
18
a
10
2
2
1
1
2
20
4
3
5
3
3
4
4
45
20
26
2
34
13
7
15
3
16
16
3
30
33
903
61
4
19
1
12
77
21
9
1
6
2
1
98
229
14
7
38
NUMBER
OF
PI I("*1PI C
CLIuloLc
FACILITIES
(C)
52
234
11
12
535
470
>7.5OO
>280
4
50
71
79
5
294
875
944
67
4,536
% OF
TOTAL
ELIGIBLE
FACILITIES
(A + B)*100/C
100
>5
5 982906
81 818182
66 666667
27 102804
46808511
> 1
>5
>1
>1
100
100
100
5.0632911
20
0.3401361
08368888
0.1056322
10.447761
08377425
HAPUBLIC
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE, BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OK
OK
OK
OK
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
PA
PR
PR
PR
Rl
Rl
Rl
Rl
Rl
Rl
Rl
«
SC
INDUSTRY SECTOR
Food Products
Gasoline Distribution [Wholesale. Retail)
Government (Crty/County/State/Federal)
Leather
Maintenance
Media
Metal Fabncation/Finshing/Forging
Non Profit Organizations
Others (Not I denoted)
Others (Not Identified)
Packaging
Paints and Painting
Paper and Paper Products
Pest Control
Petroleum/Petroleum Products/Storage
Plastic and Plastic Products
Plastics and Plastic Products
Plumbing, HVAC
Pollution Control Equipment
Printed Circuit Board Manufacturers
Printers and Printing Industry
Printers and Printing Industry
Real Estate and Agent/Operators
Remediation
Saw Mills, Planing, Wood Products, Etc.
Saw Mills, Planing, Wood Products, Etc.
Schools (Colleges, Vocational etc.)
Textiles and Products
Tool and Die Industry
Transportation Services/Equipment
Utilities
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Welding
Chrome Platen
Degreaseri
Dry Cleaners
Foundrles^melter!
Metal Fabrlcation/Finehlng/Fofglng
Printers and Printing Industry
Vehicle Maintenance and Repair
Wood Furniture
Degreasers
Dry Cleaners
Electroplating
Trailer Manufacturer!
Vehicle Maintenance and Repair
Wood Furniture
CFC Users
Chrome Plater!
Contractor!
Flberglais Manufacturing/Product!
Foam/Sytrofoam Product! & Manufacture
Furniture Manufacturing/Repair & SeJee
Hceprtmre/MecfceJ/Hear* Service.
Painti and Painting
Palna and Painting
PCB/ElectronkM
Printer! and Printing Industry
Vehicle Maintenance and Repair
Vehicle Maintenance and Repair
Chemical! (Inorganic and Organic)
Chrome Platen
Dry Clean en
Chemical! (Inorganic and Organic)
Chrome Plater!
Marine
Metal Fabrlcation/Finehlnfl/Forglng
Prlnten and Printing Industry
Sawmllli, Planing, Wood Product!, Etc.
TextilM and Product!
Vehicle Maintenance and Repair
GENERAL
(A)
26
64
102
1
4
1
78
2
181
65
2
19
1
1
39
1
9
5
6
15
122
5
11
2
20
1
27
1
8
5
13
14
20
1
309
700
20
4
115
140
4
4
70
10
20
25
2!
4
3
11
3
5
2
3
2
7
8
4
4
2
a
NUMBER Of
ASSISTANCES
ON -SITE TOTAL
(B) (A +
7
1
3
0
4
2
10
0
3
2
5
1
3
3
0
3
1
1
B)
28
64
102
1
4
1
78
2
188
65
2
19
1
1
38
1
8
5
6
15
123
9
11
2
20
1
27
1
8
9
13
14
20
1
306
700
24
6
129
140
7
8
79
11
23
28
29
7
3
11
3
9
2
8
2
7
8
4
9
2
9
NO INFORMATION PROVIDED
30
40
60
1
0
10
20
3
0
10
38
15
29
30
2
2
S
19
4
2
15
0
49
68
00
3
2
15
35
7
2
29
38
NUMBER
OF
ELIGIBLE
FACILfTIES
(C)
543
4.477
78
2,120
2,077
2
381
154
442
see
3,824
387
268
424
272
1,307
220
2,423
1,911
600
39
100
2,500
170
788
93
98
730
178
290
156
8
150
2,183
390
884
416
59
100
129
se
20
40
313
60
107
108
%OF
TOTAL
PI lf~IQI C
CLIUIULC
FACILITIES
(A+arioo/r.
4.7882136
1 4285287
1 2820513
3 6792453
90515186
100
0 2557545
25.324675
2.0361991
2.5167785
3.2165272
1.2819897
7.4626866
0.2358491
0.3678471
0.6120888
2.2727273
0.5777881
1 .3236267
1.8333333
85.714288
28
1
4.1178471
0.3621896
20.794717
9.1724136
0.6849315
1.1238899
2.4
1.2858228
87.9
5.3333333
0.1832341
1.4286714
02237136
2.1634618
61.818182
69
72
8.1724136
10
37,5
11.182108
11.680887
1.6681880
23.148148
400 8.75
NO INFORMATION PROVIDED
H.\PUSLIC
-------
TABLE E-5
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1995 SECTION 507 REPORT)
STATE
SD
SO
3D
TN
TN
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
UT
UT
UT
UT
UT
VA
VA
VA
VA
VI
VI
VI
VI
VT
WA
WA
WA
WA
WA
Wl
Wl
Wl
Wl
Wl
Wl
Wl
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
wv
WY
WY
WY
WY
WY
INDUSTRY SECTOR | NUMBER OF
ASSISTANCES
Chrome Platers
Degreasers
Dry Cleaners
Chrome Platers
Degreasers
Dry Cleaners
Others (Not Identifed)
Printers and Printing Industry
Title VI Impacted Businesses
Chrome Platers
Dry Cleaners
Gasoline Distribution (Wholesale, Retail)
Manufacturers /Manufacturrg
Others (Not Identified)
Paints and Painting
Printers and Printing Industry
Supplers/Vendors
Vehicle Maintenance and Repair
Waste/Waste Hauler
Dry Cleaners
Furniture Manutacturrig/Repalr & Sales
Plumblng/HVAC
Printers and Printing Industry
Vehicle Maintenance and Repair
Degreasers
Dry Cleaners
Electroplating
Hospltals/Medcal/Health Services
Dry Cleaners
Plumbing, HV AC
Printers and Printing Industry
Vehicle Maintenance and Repair
Chrome Platers
Degreasers
Dry Cleaners
Foem/Styrofoem Product* & Manufacture
Pyrolysi* Plant
Aerospace
Chemicals (Inorganic and Organic)
Chrome Platers
CuVCruehed Stone and Products
Oegreasers
Vehicle Maintenance and Repair
Wood Furniture
Asphalt and Asphalt Paving
Coal Preparation
Concrete
Consultant!
Dry Cleaners
Electroplating
Gasoline Distribution (Wholesale, Retell)
Manufacturers /Manufacture
Metal Fabrlcation/Flnkhlng/Forglng
Mining and Mineral Processing
Others (Not Identlfed)
Palnti and Painting
Plumbing, HVAC
Printers and Printing Industry
Vehicle Maintenance and RepaJr
Auto Wrecker Yard*
Chrome Platers
Dry Cleaners
Saw Mills, Planing, Wood Products, Etc.
Vehicle Maintenance and Repair
GENERAL ON-SITE TOTAL
(A) (B) (A +
32 1
260 0
10 2
70 3
11 1
185 3
260
70 4
46
116 4
1792
101
236 4
B)
33
260
12
73
12
186
260
74
48
120
1792
101
242
34532 27 34559
138 4
33 0
181 1
3430 86
57
15 0
10 3
10
45 3
15 1
35 0
40 0
49 1
3 0
18 0
9 9
10 9
10 10
NO INFORMATION PROVIDED
23 0
22 0
25 360
0 1
0 1
2 0
12 0
22 1
9 0
167 2
46 3
12 1
8
12 1
3
7
11
20 3
5 1
10 3
9 1
6
19
13 1
9
2
26
28 0
4 0
7 1
1 3
1780 0
142
33
182
3518
57
15
13
10
46
18
35
40
48
3
18
10
19
20
23
22
406
1
1
2
12
23
9
18S
49
13
6
13
3
7
11
23
6
13
8
8
19
14
9
2
26
28
4
6
4
1780
NUMBER | % OF
OF TOTAL
ELIGIBLE ELIGIBLE
FACILITIES FACILFTIES
(C) | (A + B)*100/I
j
32 103.125
260 100
75 16
70 100
11 100
700 26.857143
3,000 8S666667
1,200
130
3,314
3,710
11,069
32,138
3,247
6,384
200
200
270
257
750
80
18
84
32
199
23
22
890
2
1
190
90
120
190
2,000
400
425
too
4SO
100
23
90
28
4
40
8
6.1666667
92.307692
54 073627
2 722372
2 186268
107.53963
1.0163228
54.969052
7.5
8.5
17.777778
6.2256809
5.3333333
57.5
100
11.904782
46.879
10.29641
100
100
47.647058
90
100
1.3333333
24
19.186867
8
8.49
12.29
3.0588239
8
2.8888889
11
100
12
100
100
20
86.686687
H:\PUBUOEPA907\TABLE-E.WK3
-------
TABLE E-6
SBO OUTREACH ACTIVITIES
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
Ml
MN
Number of Service* Provided / Number of Bu*ine**e* or Individua 8 Reached
Meeting*
12
60
60 +
8
15
1
Yes
31
10
36
20b
12
6
46
3OO
Yos
14
4
26b
_
36
300
400 +
40-60
660
62
NO
100b
260b
60
60
3OOb
66
1OO
6.6OO
NO
1,100b
ND
1,OOOb
SpeaUng Event*
19
2
27
2
3
3
10
Yes
9
3
10
6b
2
4
12
160
Yes
12
6b
998
160
1.060
76
260 +
3O-40
600
ND
600 +
96b
160
60Ob
60b
310
400
2,600
ND
960
2OO
Brochure*/
Flyer*
8
20 +
16
6
Yes
1
Yes
6
3
26
27,000
2
1
4
Yes
.
Yes
2
6,200
I.OOOs
1.800
6,000
ND
ND
ND
1 ,OOO +
3,600
10,000
ND
6,000 +
1,190
8,000
ND
ND
6OO
Training S«**k>n*
10
38
6
2
10
1
Yes
2
.
6
.
9
7
1
10
Yes
6
10b
.
418
876
1,000s
10
1,200
.
ND
ND
200
310
.
260
ND
40
260
ND
162
1,000
On-*rte Vltlt.'
1
-
4
.
.
.
.
.
10
8
.
Information Booth*
3
1
10b
500
25,000b
3.OOO
Preas Releaae*/
Media Coverage
.
5
7
5
4
5-8
ND
ND
14,650
1,000,000 +
1,000b
Correspondence
100s
19
500
100s
19
500
Other
41
2
1
8
ND
5
52
17
17
41
2
45
500 700
49,250
28
ND
1 7
1 7
-------
TABLE E-6
(Continued)
Program
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
Number of Service* Provided / Number of Bu*ine**e* or Individual* Reached
Me.
3
.
14
22
1
40"
2
26
34
12
Yes
26
.
Yes
130
.
12
Yes
20
50
96'
9O
Yes
-
rtnna
UIRIIV
84
76
390
60
4OOb
1O
2OO
ND
2.200
ND
66
.
ND«
ND
72
ND
100
200
948"
170
_
ND
-
6 peeking Event*
8
_
16
12
2
12b
1
4
2O
8
_
6
.
Yes
6
.
1
10
4
26
_h
6
.
Yes
-
400
.
1,000
240
176
6OOb
2O
80
4,282
226
276
.
ND"
18Ob
_
60
ND
160
2.5OO
.
4OO
.
ND
Brochure*/
Rye re
12
6
2
1
4b
1
1
ND
3
Yes
5.0OO
Yes
Yes
_
-
4
2OO
6
Yes
6
-
Yes
-
68.000
1,600
2.420
36
3,OOOb
100
1,600
10.40O
400
ND
6.OOO +
_
ND"
ND
-
2,500
ND
2.OOO
30,264'
6.43O
ND
-
Training Se**k»n*
6
2
14
_
.
_
9
2
_
Yes
7
,
-
4
1
616
Yes
3
-
Yes
-
233
200
1,106
_
.
-
600
20"
_
.
ND"
ND
160
60
ND
35
ND
On-«He Vtorti*
Yes
_
_
_
27
_
12
21
-
-
-
ND
.
_
.
24
.
ND
.
30
-
-
Information Booth*
.
20
_
.
,
_
-
-
3
-
6.774
.
6.6OO
Pre*» Releave*/
Media Coverage
65
1
.
10
ND
1,000
578,000
Correspondence
554
125
25
3.324J
554
.
125
25
ND
Other
3
6
2d
1d
.
.
1
4
Yes
100
75,827
113
172
442
800
ND
-------
TABLE EG
(Continued)
Program
WA
WV
Wl
WY
TOTAL1
Number of Service* Provided / Number of Businesses or Individual* Beached
Meeting*
6
Yes
14
,
1,244
ND
ND
60
.
16.026
SpwridflaEwrt.
2
Yes
6
_
424
ND
ND
660
.
19.866
Brochure*/
rtym
3
Ye,
3
_
32,342
ND
ND
1.2OO
.
166.939
Training Sessions
3
Yes
.
.
683
ND
ND
_
,
7,999
On-«He Visits*
.
.
.
.
65
.
72
Information Booth*
4
Yes
.
41
ND
ND
.
.
39,774
Pre» Releaie*/
Media Coverage
105
1,594.650
Correspondence
4,647
1,323
Other
_
Yes
1
.
656
ND
40
127,694
• Includes on-site audits and inspections.
b Estimated.
c 2 at 14 sites.
d 1 at 9 sites.
e Due to staff turnover, SBO activities were transferred to the director's office in 11 /95. No record of previous
activities could be located.
f Average of 8 per month.
g Average of 79 per month. Combined total for SBO and SBAP.
ti Included in number reported for meetings.
i Average of 2.622 per month. Combined total for SBO and SBAP.
j Responses to requests for assistance. Average of 277 per month.
k Includes reported quantities of 27.OOO for Iowa and 6,000 for Ohio.
I Totals do not reflect programs indicating a "yes" answer or programs indicating a number such as "6OO + ."
ND Not determined.
Other activities:
AZ: Permit application assistance.
AR: Technical evaluations.
Water line extensions.
CO: Outreach on state legislation.
Environmental fax network.
IA: Contacts with Chambers of Commerce offices.
KS: Development of a small business working group.
KY: Compliance assistance.
MT: Teleconferences.
NY Mailings about regulations.
Teleconferences.
Support group seminars.
PA: Mailing about regulations.
SO: Mailings about regulations.
VA: Participation in regulation development.
WV: Environmental Assistance Coalition and Panel Secretariat.
Wl: Teleconference.
-------
TABLE E-7
SBO TOLL-FREE HOTLINE INFORMATION
PROGRAM
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
NATIONAL
800-533-2336
None
800-333-7798
None
.
None
.
None
None
None
None
800-358-5510
800-357-6087
800-926-8111
.
None
None
None
.
800-725-6112
None
800-433-8773
None
-
-
IN-STATE ONLY
_,
800-510-2332
800-234-5677
800-272-4572
800-789-4599
800-722-7457
800-451-6027
.
800-256-1488
800-789-9802
.
.
800-985-4247
.
800-992-0900
Ext. 4670
800-837-0656
-------
TABLE E-7
(Continued)
PROGRAM
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
NATIONAL
800-643-6090
800-810-7227
800-829-4841
.
None
None
.
800-819-9001
.
800-447-2827
None
None
None
.
800-435-7287
None
IN-STATE ONLY
800-782-8369
800-755-1625
800-225-5051
800-452-401 1
Not reported
800-932-1000
.
800-438-3367
800-734-3619
800-270-4440
800-592-5482
.
800-982-2474
,
-
-------
TABLE E-8
SBAP OUTREACH ACTIVITIES
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
Ml
MN
Number of Services Provide! / Number of Bu»lne»ei or Individuals Reached
Qanaraf
260
Yes
1,122
600 +
6OO
620-1,676«b
Yes
Yes
676
.
Yes
6
ND
887
236
Yes
1,003
368
26O
120'
629
4,017
260
ND
1,122
600 +
6OO
735
ND
ND
676
.
ND
1,360
1,000
ND
236
ND
1,O03
358
250
1OO*
629
4,017.
On-Sha Vtarta
2
41
Yes
20
Limited
Yes
Yes
.
14
Yes
.
-
74
21
31
141
7
10
11
16
70
2
41
ND
20-26
ND
ND
.
14
.
ND
ND
21
23
141
7
10
11
16
70 +
Samlnara, Work* hops.
Meeting*, etc.
60
Yes
10
1OO
Yes
26
12
Yes
1
Yes
41
Yes
Yes
20
40
16
26
41
8
16
18
14
31
Yes
1,200
650
418
1,260
ND
400-600
1,200
ND
64
ND
1.000 +
ND
ND
1,300
1,600
ND
200 +
ND
64
486
1,100
600a
2,287
1.OOO-6.0OO
Fact Sheeti, Manual*,
Information Packet!
3
Yes
8
Yes
16
10
Yes
Yes
Yes
5
Yes
325
3
4
6
20
Yes
3
6.OOO
3
588
-
666
ND
6,200
ND
1,800
1,000
ND
ND
ND
1,500 +
.
ND
800
26,000
ND
3,800 +
ND
ND
1,378
5.00O
5,326
688
Newilettcra
.
.
ND
4
.
.
7.OOO
8,000 +
Pollution
Prevention
A!!l!tance
Yes
-
.
ND
Permit and
Compliance
A!*i!tance
20
144
150
20
ND
150
Teleconference*
41
1
1
2
41
35
27
198
Other
Yes
2
1
Yes
2
5
1
1
5
6
ND
2
45
ND
80
6
2,673
787
ND
1.000
-------
TABLE E 8
(Continued)
Program
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
Number of Service* Provide* / Number of Bu*lne**ee or Individual* Reached
General
3,120
1.637
1,261
B64
2"
375"
350
1O8
ND
20O
ND
Yes
3.OOO*
110
1 ,356
Yes
50
Yes
50
9OO
ND
ND
Yes
3,120
1,637
1,261
554
10*
325"
250
125
610
200
50O- 1.OOO
ND
3.00O'
11O +
900'
ND
50
ND
50
900
324°
620
ND
On-Stt* Vl.lt*
17
138
101
35
Yes
24"
30
ND
20
2
24
50
4
18
15
Yes
12
45
17
16
3
17
138
75
35
ND
24"
25
8
20
2
24
60
4
18
15
ND
ND
40
17
15
3
Seminar*, Workshop*,
Meeting*, etc.
4
39
76
36
Yes
8"
26
12
24
12
7
_
2O
44
4
3
4
Yes
20
91
96d
18
31
148
39
1.00O
1,496
ND
22O"
360
250
1,272
750
70
3OO
301
20
200"
185
ND
100
2,200
948"
53O
.
195
Fact Sheet*. Manual*.
Information Packet*
6
Yes
39
2
Yes
1"
365
2
Yes
5
10
Yes
5
50
10
Yes
3
Yes
4
10
ND
6
2
45,103
ND
1.OOO
2,420
ND
300'
365
1.50O
ND
ND
400°
ND
100
4,442
74
200"
100
ND
800
1,300
3O,264f
2.405
ND
Newsletter*
3
3,000
.
Pollution
Prevention
A*vi*tance
8
20
Permit and
Compliance
A**i*tance
2O
2
62
ND
20
2
6?
90
Teleconference*
Other
520 780ab
Yes
15
1
4
ND
Yes
()0()
ND
1b
EiOO
20
62 /
ND
-------
TABLE E-8
(Continued)
Program
VI
WA
WV
Wl
WY
TOTALS
Number of Service* Provide* / Number of Bu*ine**e* or Individual* Reached
Qeneral
60
160
16O
323
1OO
26,823
60
ND
120
323
100
28,363
On-Sttm Vlclt*
60
4
10
19
1
1,112
60
ND
1O
19
1
991
Seminar*, Workshop*,
Meeting*, etc.
3
16
6
83
3
1,162
60
ND
15
2,040
76
31,472
Fact Sheet*, Manual*,
Information Packet*
60
3
ND
22
10
6.699
60
ND
800'
16,605
1,780
162,964
Newsletter*
.
.
.
7
.
1 8.0OO
Pollution
Prevention
A**i*tance
.
1
9
.
1
21
Permit and
Compliance
A**i*tance
7
4
409
7
4
355
Teleconference*
45
301
Other
823
6, 1fa4
a Estimated.
t Average of 2 to 3 per day. Combined total for SBO and SBAP.
c Average of 27 per month. Combined total for SBO and SBAP.
d Average of 8 per month. Combined total for SBO and SBAP.
e Average of 79 per month. Combined total for SBO and SBAP.
f Average of 2,622 per month. Combined total for SBO and SBAP.
g Totals do not reflect programs answering "Yes "only or answers such as "60O + .
ND Not determined.
Other activities:
AK: Sector-based efforts (Pitstops)
Technical Reference Center
AR: Technical evaluations.
Water line extensions.
CA: Meeting and coordinating with regional permit assistance centers
CO: Staff training
CT: Enforcement negotations.
IN: Faxback and customer connect services.
KY: Information booth.
MD: Information booth.
ND: Refferals to Small Business Resource Centers
PA: Referrals to Small Business Resource Centers
Loan programs.
TN: Surveys.
UT: Advisement panel,
Amnesty program,
VA: Regulation development.
-------
TABLE E-9
SBAP TELEPHONE HOTLINE INFORMATION
PROGRAM
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
TOLL-FREE
NATIONAL
800-533-2336
None
None
None
None
None
800-422-3109
800-578-8898
800-562-2327
.
_
800-433-1247
None
800-662-9278
.
None
800-361-4827
800-433-8773
None
IN-STATE ONLY
800-510-2332
800-234-4337
Ext. 4337
800-272-4572
800-760-7036
800-789-4599
800-722-7457
800-252-3998
800-451-6027
-
800-259-2890
800-789-9802
.
-
800-657-3938
.
_
-
NOT
TOLL-FREE
202-645-6093
Ext. 3071
.
-
.
-
.
_
-
-------
TABLE E-9
(Continued)
PROGRAM
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
TOLL-FREE
NATIONAL
800-810-7227
800-829-4841
800-869-1400
800-722-4743
800-819-9001
None
800-447-2827
800-270-4440
None
.
None
800-435-7287
None
IN-STATE ONLY
800-992-0900
Ext. 4670
800-837-0656
800-780-7227
800-755-1625
800-452-4011
800-543-4674
_
800-734-3619
.
800-592-5482
.
.
800-982-2474
.
NOT
TOLL-FREE
609-292-3600
Not reported
787-767-8025
360-407-6803
-------
TABLE E-10
INFORMATION ON STATE SBAP ELECTRONIC BULLETIN BOARDS OR WEB PAGES
PROGRAM
California
Illinois
Louisiana
Massachusetts
Missouri
New Jersey
New Mexico
Ohio
Pennsylvania
Texas
Utah
West Virginia
Wyoming
BULLETIN BOARD OR WEB PAGE
ADDRESS
91 6-322-2826 (by telephone)
http://arbis.arb.gov
217-787-6255,
Settings: 8,N ANSI.1
http://www.accessil.com/dcca
504-763-3976
OTA Online: 617-727-5621
http://www.state.mo.us/dnr/deq/smbus.htm
NJDEP BBS, Air Small Business: 609-292-2006
505-827-1552
Division of Air Pollution BBS: 614-644-3901
Web home page: http://arcboy.epa.ohio.gov
1-800-864-7594
Settings: N, 8,1, Full
TNRCCBB: 512-239-0700
SBAP home page:
http://www.state.tx.us/homepgs/smbus.html
http://www.its.state.ut.us/~deq/hmpgs/
2lyrhmpg/smlbus.html
304-558-3053
DEQ/AQD: 307-777-5465
USAGE
DURING
REPORT
PERIOD
1,045
500
ND
52
ND
ND
2,000
ND
1,668
400
(home page)
ND
ND
ND
INFORMATION AVAILABLE
Regulations
X
X
X
X
,
X
X
X
X
X
X
X
X
P2 Information
X
X
X
_
X
X
X
X
-
X
Application
Forms
X
X
X
X
X
X
Policies
X
.
_
X
X
-
-
Other
X
X
X
X
X
X
X
X
X
X
-
X
X
ND = Not determined
- = Not reported.
Bulletin board comments:
CA: Feedback has been received and is carefully considered.
IL: Users requested multi-media permit forms
PA: A few callers commented on the usefulness of the service, especially the 24-hour access.
A few messages suggested specific documents to be placed on the bulletin board.
-------
TABLE E-11
MAJOR CAP ACTIVITIES
State
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
Ml
Review of
documents for
readablrty
•nd/or content
-
-
-
-
-
-
X
-
X
-
-
-
-
X
X
X
X
-
Appointment/
hiring of ctaff
•nd/or election
of officer*
-
-
X
X
-
X
-
-
X
-
X
-
-
-
-
X
X
-
Review of
SBO/SBAP
outreach
effort*
-
-
-
-
-
-
-
-
X
-
-
-
-
-
X
-
-
-
Review/
comment on
proposed/
new regulations"
-
-
-
-
-
-
X
-
-
-
-
X
-
-
Definition of
CAP
res ports ibiitiesb
-
-
-
-
X
X
-
X
-
-
-
-
Attendance
by CAP
members at
training
sessions, etc.
-
-
-
-
-
X
X
-
-
X
-
Advisement
about effective
outreach
activities0
X
X
X
X
Assessing
small
business
concerns
based on
contacts
X
Other
(See below)
X
X
X
X
-------
TABLE E-11
(Continued)
State
MN
MS
MO
MT
NE
NV
NJ
NH
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
Review of
documents for
readablity
and/or content
-
-
-
-
-
X
-
X
X
-
-
X
-
-
X
X
X
Appointment/
hfring of staff
and/or election
of officers
-
-
X
-
X
-
-
X
-
.
-
-
-
X
X
-
-
-
-
X
Review of
SBO/SBAP
outreach
efforts
X
X
X
-
-
-
X
-
-
X
X
-
Review/
comment on
proposed/
new regulations0
X
-
-
X
-
X
X
-
-
-
Definition of
CAP
responsibilities
X
-
X
-
X
-
-
-
X
Attendance
by CAP
members at
training
sessions, etc.
X
X
X
Advisement
about effective
outreach
activities0
-
X
X
-
Assessing
small
business
concerns
based on
contacts
X
-
X
Other
(See below)
X
X
X
X
X
-------
TABLE E-11
(Continued)
State
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Review of
documents for
readability
and/or content
X
-
-
X
X
X
17
Appointment/
hilng of staff
and/or election
of officers
-
-
-
X
-
-
X
15
Review of
SBO/SBAP
outreach
efforts
X
-
-
-
X
X
-
X
12
Review/
comment on
proposed/
new regulations0
X
-
-
-
-
X
X
-
9
Definition of
CAP
responsibilities
X
X
9
Attendance
by CAP
members at
training
sessions, etc.
X
X
X
9
Advisement
about effective
outreach
activities0
X
7
Assessing
small
business
concerns
based on
contacts
X
X
5
Other
(See below)
X
X
X
12
a Includes policies, guidelines, etc.
b Includes establishing internal procedures, defining meaningful roles for members, and developing means of measuring effectiveness
c Such as marketing and review of training programs, guidance document development, etc.
No activities reported: CA, MA, NJ, NY, VT
CAP has not met yet: AL, AK, AZ, DE, HI, IL, IA, MD, MO, NH, PR, Rl, TN, OH, OK, VI
Other activities:
AR: Reviewing operational activities, voluntary compliance policies, and grant applications to provide improved small business services
CT: Providing suggestions on leveraging resources through trade associations, vendors, suppliers, and small business trade publications
LA: Interviewing small business persons that had been assisted by the program to determine effectiveness.
Referring small business to SBTCP for assistance.
Ml: Advisement concerning implementation of SBTCP internal administrative procedures.
MN: Discussions on regulatory complexity and financing assistance issues.
MS: Working to ensure the independence of the SBO through direct access to the director of state environmental agency, thereby maintaining distance from regulatory
arm of agency.
-------
TABLE E-11
(Continued)
Developing plans to give SBO and staff more independence and expanding assistance to media other than air.
Attendance by Chairman at meetings of an air advisory fee panel made up of large industries to represent small business concerns.
NE: Permit reviews.
Providing feedback as to the effect of the SBAP on small businesses.
NC: Spreading information about SBTCP via speaking engagements at local civic and community organizations.
OR: Invited guest speakers to CAP meetings to discuss small business concerns.
Critiqued proposals affecting small business technical assistance activities and offered comments.
CAP Chair wrote a guest article for the Air Quality Division's newsletter.
WA: Participated in "Success Methods" survey in EPA region.
Wl: Reviewed and commented on pollution prevention videos produced by Wl DNR.
Had discussions concerning Small Business Development Center partnerships.
Commented on article published by Mr. Donald Croysdale criticizing CAA.
WY: Concentrated efforts on assuring that small businesses would not be penalized for seeking assistance.
Expressed intentions that SBTCP would be more effective with confidentiality and multimedia policies.
-------
TABLEE-12
MEETINGS AMONG SBO, SBAP, AND CAP
FREQUENCY
Daily
Weekly
Biweekly
Monthly
Bimonthly
Quarterly
Semiannually
Biannually
Annually
Occasionally
SBO & SBAP
9 programs
AZ". ME, MT,
NE, NH*, NC, SC,
TN, WA
3 programs
FL, GA, WV
4 programs
IL, IN, MN, Wl
5 programs
DC", NV, NJ,
NY", OHb
1 program
CO
4 programs
CA, IAb, KS°, KY
-
1 program
UTb
-
1 5 programs
AL, ID, LA, MD,
Ml, MS, NM,
NDf, OK, OR, PA,
Rl, SD, VA8, WY
SBO & CAP
-
3 programs
D.C.b, MTb, UTb
-
1 0 programs
GA, ME, Ml,
MS, NV, NH",
PA, SC, WV,
Wl
1 program
NC'
1 program
NM
1 program
FL
6 programs
MN, NE, ND,
OR, SD, VAd
SBO, SBAP, & CAP
2 programs
D.C.b, UT
1 7 programs
AR, CO, CT, GA,
KY, LA, ME, Ml,
MN, NHd, PA, SC,
VA, WA, WV, Wl,
WY
1 program
NC9
5 programs
MT, NM, ND,
SD",TX
1 program
FL
1 programs
OR
SBAP & CAP
2 programs
D.C.b, MTb
7 programs
GA, ME, Ml,
NHd, SC, WV,
Wl
1 program
NC9
1 program
NM
1 program
FL
5 programs
ND, ORh, SD,
VAd, WY
a = SBO and SBAP have dual roles.
b = Also occasionally meetings.
c = Also informal daily meetings.
d = Planned frequency.
e = Minimum frequency.
f = At least 3 per month.
g = Almost daily.
h = Every 2 to 3 months
-------
TABLE E-13
FINANCIAL ASSISTANCE PROGRAMS TO HELP SMALL BUSINESSES
COMPLY WITH CAA REQUIREMENTS
PROGRAM
Arkansas
Connecticut
Illinois
Indiana
Iowa
Maine
Minnesota
Montana
Nebraska
New York
DATE AVAILABLE
TBD
9/94
Summer 1997
NR
NR
Currently available
Unknown
1 /95
7 795
1 /97
7 /92
TBD
NAME OF GRANT/LOAN
SBAP is planning to employ a part-time loan
packager.
Financial Assistance for Vapor Recovery
Systems (FAVRS) Loan Guarantee Program
TBD
Capital Access Program, Indiana Development
Finance Authority
Loan Guaranty Programs, Indiana Development
Finance Authority
Pollution Prevention Grants
Property and sales tax exemptions
Green Fund
Small Business Environmental Loan Program
TBD
Sales tax rebate for installing environmental
equipment
TBD
FUNDING LEVEL
TBD
$5 million revolving loan fund for
Stage II and P2
TBD
Varies
Up to $2,000,000 for large projects.
$200,000 the last two years Usually
in small increments up to $25,000.
N/A
$250,000
$250,000
(pilot)
TBD
100% rebate
TBD
-------
TABLEE-13
(Continued)
PROGRAM
Ohio
Pennsylvania
Texas
Utah
West Virginia
Wisconsin
DATE AVAILABLE
Currently available
Currently available
Currently available
Spring 1 996
1 /94
TBD'
4/96
TBD
12/94
12/94
NAME OF GRANT/LOAN
Ohio Air Quality Development Authority bonds
Small Business Assistance Fund
Pollution Prevention Low Interest Loan Program
Grant program
Air Quality Improvement Fund
TBD
P2 Grant Program for Small Businesses
TBD
WHEDA Clean Air Fund
WHEDA Ozone Protection Fund
FUNDING LEVEL
Based on specific projects and what
the market will bear
$100,000 - 250,000 annually
$10,000,000 available for all media
TBD
$3,000,000
$10,000,000
$40,000"
TBD
$1,000 - $50,000
$1,000 - $50,000
TBD To be determined.
a Draft legislation for 1/97 legislative session.
b $20,000 EPA grant + $20,000 match.
-------
TABLE E-14
LEVERAGING OF RESOURCES
Descriptions of how each component of the SBTCP leverages existing personnel resources (within the state) are provided in
Table E-14. (Comments edited for space.)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Alabama
Staff responds to environmental
questions on all media, not just air.
Funding comes from other programs
(water, hazardous waste) as well as
air.
Staffed with technical personnel in Air
Program, who provide these services
along with their other duties.
CAP has not yet met. The only funding
is Air Division Chief's time and possibly a
per diem allowance to cover members'
travel expenses to meetings.
Alaska
SBO is manager of Compliance
Assistance section of Statewide Public
Service Division. P2 program and
multi-media compliance assistance
program are also included in this
section. All programs work as a team
to provide assistance to the public.
Other division's program staff can be
called upon for assistance or technical
advice.
Same as SBO.
CAP has had only one meeting since it
was established. The services of the
Compliance Assistance section and other
programs in the department are available
as needed in support of the CAP.
-------
TABLE E 14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Arizona
Final Cty.
Maricopa
Cty.
Pima Cty.
& Tucson
Agency Ombudsman assists with
complaints from small businesses.
The District Director functions as SBO.
The elected board of supervisors holds
ultimate legal authority for air quality
regulation by the County. They
exercise that authority on an elective,
rather than mandatory basis. Business
operators in the County generally know
elected Board members. Maintaining
an awareness and appreciation for
scope, nature, and sensibility of
burdens imposed on small business
constitutes a principal obligation of the
District Director.
No response.
No response.
Agency Permitting Engineers and
Compliance Inspectors frequently refer
businesses to the SBAP and assist
with workshops, training sessions,
publications development, etc.
Pinal County has relatively stable
inventory of sources. SBAP/SBO
functions integrated directly into
permitting and inspection process.
Maricopa County SBEAP works with
state agencies, industry associations,
chambers of commerce, community
colleges, and small businesses to pool
resources to provide high quality, low
cost educational materials and
workshops. This allows SBEAP to
operate efficiently with limited staff
resources.
Program Manager for Information
Services (public awareness, public
education and business interface
duties) manages the Business
Assistance Program for Pima County
DEQ. Reports directly to department
director and has access to permitting
and enforcement staff, files, and
training.
The Agency appointed CAP member is
the Deputy Director of the Agency.
N/A
No response.
No response.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Arkansas
Operates through multi-media, 12
member Advocacy Council, a single
member appointed from each operating
division of the Agency by the Director.
Individual council members provide
advice and counsel on the operations
of small business assistance program.
Sponsors Agency's P2 program.
Currently has an entitlement from US
EPA under contract with Technology
Transfer Center, School of Engineering,
University of Arkansas at Fayetteville.
Uses multi-media inspection team from
Agency to perform voluntary
compliance audits. SBAP recipient of
US EPA Leadership Grant Award.
No response.
California
Appointed by Governor, supported by
Cabinet. Other state agencies
involved.
Some local air districts have this
function and some local SBAPs are
largely independent. Many state
departments assist.
Not yet appointed.
Colorado
SBO is an advocate for small
businesses in the air regulatory arena.
Contacts have been established with
trade groups, chambers of commerce,
and other associations to help get
information, provide assistance and
advocacy to small businesses in CO in
complying with the Clean Air Act.
SBO reviews all environmental rules
being proposed and represents small
business interests before regulating
authorities. In addition, SBO works
with SBAP to provide services as a
means of getting the most out of our
limited budgets.
SBAP provides technical assistance
services. Contacts have been
established with trade groups,
chambers of commerce, and other
associations to provide technical to
small businesses in CO in complying
with the Clean Air Act. SBAP has
written simplified reporting forms for
certain industries, created easy to
understand fact sheets, and performed
on-site visits to help calculate
emissions. SBO and SBAP have
developed a memorandum of
understanding and a joint work-plan.
SBAP works with SBO to develop
materials, put on workshops, etc. as a
means of getting the most out of
limited budgets.
CAP members are all volunteers and they
help SBAP and SBO provide the best
services possible to citizens of CO. Role
of the CAP is to review materials,
provide guidance and oversight on what
types of projects etc. that the SBAP/SBO
focus on and provide contacts in industry
to help get the word out.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CT's SBO and SBAP are merged and collectively the program leverages technical
staff from the Air Bureau to provide compliance assistance on air quality issues.
The program uses staff from other Bureaus for multi-media assistance. The
program can regularly access technical staff from the Air Bureau for permitting
assistance, development of informational materials and fact sheets, and
participation in seminars and workshops around the state. The program has been
used to cross-train staff from other Divisions in the Bureau to enhance
professional development while providing additional resources to the program.
Additional resources are leveraged through partnerships with trade associations,
other state agencies, quasi-public agencies, public utilities, local chambers of
commerce, and non-profits.
Ombudsman uses regulatory and
engineering personnel to answer
technical questions. No one has been
assigned to assist the Ombudsman.
None
The Program has an EPA leadership
grant. With this grant, we have
contracted with the Small Business
Development Centers to conduct site
audits.
SBO also is the program manager for
the Permitting Program.
No response.
Ombudsman also serves as the SBAP
None
Same.
Used 2 Environmental Protection
Division employees and 1 EPA-IPA
employee.
No response.
CAP
CT's CAP has 10 members. Other
interested individuals attend meetings
regularly to provide a larger forum for
small business interests Opening the
CAP to include non-voting members has
broadened the expertise of the panel
while providing additional resources to
participate in the development of
subcommittees
Not established
D.C. appropriations funded agency
representative's participation ($5,000).
No response.
N/A
No response.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Idaho
Illinois
Indiana
Iowa
Kansas
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBO has worked extensively with the
Department of Commerce, Small
Business Development Centers,
Technical and Industrial Extension
Service, and Division of Environmental
Quality's Pollution Prevention
Coordinator. For workshops, vendors,
INEL representatives, local POTW
managers, ID's universities, banking
representatives, and DEQ regional
office personnel have been utilized.
SBO has worked closely with other
Region X states (WA, OR, AK) to
discuss common problems and recently
entered into an agreement with the P2
Research Center to provide assistance
with P2 issues under a leadership grant
that is managed by Washington State.
None
SBO works in cooperation with SBTAP.
SBO hires student interns as needed.
The office makes extensive use of
Chambers of Commerce and
association personnel for information
dissemination and gathering. The
Citizens' Aide/Ombudsman, Deputy
Ombudsman, and office staff
contribute their time as necessary to
facilitate the duties of the SBO.
SBO provides multimedia assistance,
develops documents related to
business concerns and assists the
Director of Pollution Prevention as
needed.
SBAP
SBAP works with all sections of DEQ
to get correct and complete
information to businesses. They also
work with professionals in other media
to make sure that cross media
concerns are addressed.
Leverage is 0.5 (administrative
assistant) paid by state general
revenue funds
SBTAP operates with full support of
Office of Pollution Prevention and
Technical Assistance.
The Iowa Air Emissions Assistance
Program hires part- and full-time
student assistants and interns from the
University of Northern Iowa to help
with client assistance during periods of
heavy demand.
SBAP is contracted. There is some
overlap and synergism between P2
staff and SBEAP staff. Uses technical
expertise available through KSU
College of Engineering and Engineering
Extension.
CAP
No response.
None
Personnel from Legislative Services
Agency (LSA) and SBTAP assist the
CAP.
Not appointed
CAP is an appointed advisory board.
Members are not paid to serve.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Kentucky
Louisiana
Maine
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBO meets with Division for Air
Quality (DAQ) staff and is part of
Cabinet efforts to improve permitting
and customer service. DAQ has
contact person to assist in training
SBO and SBO for Jefferson County
APCD. Jefferson County SBO has
access to all resources of the District.
Assignments made within the SBO
staff, however additional personnel
from the Governor's staff available as
needed.
SBO works closely with SBAP and
other business service providers, such
as Department of Economic
Development, to maximize
effectiveness.
SBAP
SBAP uses Small Business
Development Center network, which
includes 14 locations throughout KY to
promote its availability. SBAP has
obtained assistance from local
business organizations & individual
businesses in co-sponsoring seminars.
Jefferson County APCD Program to
provide technical assistance is under
development
All assignments made within the SBAP
staff. Uses services of the permit,
water, solid and hazardous waste and
legal sections.
SBAP staff of one is able to use staff
from Department's Pollution Prevention
Program and from other bureaus.
CAP
SBO serves as staff person to the CAP.
A variety of environmental management
staff & business people have spoken to
the Panel without charging a fee.
Assignments made within the CAP
members. SBO and SBAP staff are
available for secretarial and other
activities.
Panel is joint panel comprised of 1 6
members. Functions of SBAP oversight
were merged with an existing panel
charged with oversight of Pollution
Prevention Program.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Maryland
No added resources are leveraged for
the SBO function.
The SBAP leverages extensive
resources in and out of MDE. From
Jan-June, 25% of two air permit
engineers' time spent on small
business air quality permits. From
July-Dec, 50% of one air permit
engineer's time spent on small
business air quality permits.
Designated SBAP contact in every
media administration to coordinate
regulatory and permitting assistance.
All outreach projects conducted jointly
with Pollution Prevention Program and
received funding from that program.
From July-Dec, three permitting
engineers of MDE's Environmental
Permits Service Center are designated
resources for regulatory and permitting
information. MDE's Office of
Community Assistance coordinates
logistics for all outreach activities.
Department of Business and
Employment Development's Small
Business Development Centers and
SBA's Small Business Resource Center
partners with SBAP to host and
advertise outreach seminars.
N/A
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Massachusetts
Michigan
Minnesota
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
Ombudsman not appointed. SBAP
manager receives SBO mailings and
tries to function as SBO. Because of
agency chain of command, access to
Governor's office is not possible.
Secretary of Environmental Affairs
routinely meets with business leaders
to solicit input on problems and
programs.
100% restricted funds generated from
state and county fee assessments.
SBAP
In addition to SBAP manager (0.75
FTE), chemical engineer (0.25 FTE)
assists with SBAP functions and 1 .00
FTE program assistant. Full access to
24 OTA technical staff. The agency
has functioned since 1989 providing
confidential, non-regulatory technical
assistance to MA companies seeking
to implement Toxic Use Reduction
projects. These staff come at no
expense to the SBAP program, but
have real limitations on time, since
companies that pay Toxic Use
Reduction (TUR) fees (typically larger
firms) actually pay for the operation of
the agency.
TUR Act allows for providing technical
assistance to smaller quantity users of
toxic materials, including compliance
assistance, but there are limits.
Currently operating within appropriate
limits, but TURA program cannot
adequately serve intended SBAP
clients without dedicated funding.
MA DEP provides some technical
assistance for companies seeking
permitting or compliance assistance
through use of Customer Assistance
staff in the state's 4 regions.
100% restricted funds generated from
state and county fee assessments.
SBCAP contracted with MnTAP
(Minnesota's P2 assistance
organization, which operated at
University of Michigan, funded of OEA)
for joint outreach and educational
assistance for NESHAPs. This was 0.3
FTE for FY95 and 0.4 FTE for FY96.
MnTAP will provide another 0.6 FTE in
FY96 for EPA Leadership Grant.
CAP
No CAP Potential members
recommended to Governor's office.
Unfunded.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
No response.
DNR's Technical Assistance Program
assists with responding to requests for
assistance from small businesses.
SBO is employed by the Department of
Environmental Quality, but is located at
the Department of Commerce's Small
Business Development Center to take
advantage of that program's business
expertise and contacts.
Public Advocate/SBO funded by
different areas within DEQ dependent
upon the area in which the Public
Advocate works.
SBO is NDEP employee whose full-time
function is to act as the SBO for all
media issues, not just air quality.
Administrative assistance and support
services provided by Air Resources
Division.
One person from NJ Department of
Commerce and Economic
Development.
SBAP
No response.
DNR's regulatory programs provide
highly technical information if TAP
cannot respond to the request itself.
The regulatory programs are not given
information to allow them to identify
the facility in question.
SBAP is a partnership between the
SBO's office and Department of
Environmental Quality's Small Business
Engineer.
SBAP assistance, on-site visits,
workshops, flyers, phone calls, and
materials funded through Title V funds
from the Air Program.
Assistant to the Administrator also is
the Program Manager, which includes
State Environmental Commission staff,
of which he also is Executive
Secretary.
Program utilizes existing pollution
prevention program for P2 assistance.
Regulatory personnel are utilized on an
as needed basis for consultation.
Coordinates with Air Permit, Air
Enforcement and Pollution Prevention
staffs within NJ Department of
Environmental Protection. Coordinates
with NJ Institute of Technology TAP
for P2 assistance.
CAP
No response.
CAP has not been appointed.
CAP consists of five small business
owners, one representative of the
general public, and one representative of
the Department of Environmental
Quality. SBO serves as Secretary to the
CAP and the Small Business Engineer
provides technical information to the
members.
CAP's expenses paid through Title V
funds.
6 of 7 members are appointed by
Governor or legislative leaders. They are
unpaid, but are given 'per diem."
Seventh member is NDEP's Air Quality
Bureau Chief.
Support/administrative services provided
by Air Resources Division (regulatory
agency charged with CAAA
administration).
N/A
-------
TABLE E 14
(Continued)
STATE OR
TERRITORY
New Mexico
(except Bernalillo
County)
Bernalillo County
New York
North Carolina
North Dakota
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
Coordinating small business programs
throughout the Department. Leading
implementation of P2 initiatives.
N/A
All professional positions were new in
1 993-94 before a statewide hiring
freeze. Support staff reassigned.
NC Air Quality Section and Office of
Waste Reduction have provided
technical support. Developed
information and workshops jointly with
support by trade associations.
No personnel from other departments
assigned to assist SBTCP. SBDC's and
Governor's office asked to assist in
providing small businesses with certain
SBTCP information. Within the
Department, SBO makes direct
requests for assistance from Division
Directors and their staff.
SBAP
Training of SBAP staff provided in part
by permit/enforcement engineers.
Other agencies, such as Economic
Development and Small Business
Development Centers, help SBAP with
outreach. SBAP networks with other
state and local programs to share
information and documents.
Previous position for 1 .00 FTE involved
compliance, inspection, and
registration/permit work. Further
support given by Air Pollution Control
staff and State of NM SBAP.
Able to subcontract with technical
assistance providers (County).
Same
SBAP is organizationally inseparable
from air pollution control program,
whose SBAP staff work closely with
the SBO on assistance matters.
Although not formally recognized as
part of the SBAP, other media
programs (other than air) also work
with SBO on assistance matters.
CAP
Legal assistance provided by Assistant
Attorney General.
Legal assistance provided by Assistant
Attorney General.
State regulatory agency designated as
secretariat for CAP
Same
CAP relies on information from SBO and
SBAP to provide important feedback to
them. CAP receives information during
CAP meetings with SBO and SBAP staff
present in addition to receiving periodic
informational mailings. Outside agency
resources have not been leveraged by
the CAP to date.
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Ohio
Ombudsman program has been made
part of an existing agency whose staff
focuses on financing challenges of air
quality mandates. Ohio Air Quality
Development Authority chose to
commit financial and personnel
resources to the Ombudsman program
before Title V permit fee revenue was
available. This enabled the program to
accomplish a significant amount of
preparatory work prior to official
appointment of the Ombudsman,
which in Ohio, is a gubernatorial
appointment. The Authority can
provide benefits of its financing
structures to Ombudsman program. It
has used more than $100,000 in
research and special projects funds to
support Ombudsman program.
SBAP is located in the same building as
other Division of Air Pollution Control
sections (i.e., permitting, field
operations, new source review)
allowing direct access to answer
questions and receive policy
interpretation. Program uses the five
district offices and ten local air
agencies to help publicize SBAP
statewide through brochure
distribution, etc.
Did not function in 1995.
held in January 1996.
First meeting
Oklahoma
Assistant Executive Director serves as
SBO and is supported by SBAP staff.
We have 3.2 FTE as staff, who do the
bulk of work as it relates to fulfilling
SBAP mission.
Appointments have been made, but CAP
has not officially met.
Oregon
SBO functions were reassigned to the
director's office 11/95. As a member
of upper management team, SBO has
direct access to the director,
department heads, and other
regulatory agencies. SBO is presently
developing agency-wide cross-media
P2 program. As the single point
coordinator of P2 within and outside
agency, more efficient use of limited
resources will be possible in the future.
SBO also serves as liaison to CAP,
SBAP, small business community, and
general public on regulatory matters.
SBAP conducts joint technical
assistance visits with other program
staff. Small businesses and the public
are provided free educational and
technical assistance through the
Pollution Prevention Outreach Team (a
consortium of 7 Portland area
regulatory agencies). Printed materials
produced by Air Quality Division and
other programs are modified to fit
small business needs. SBAP
distributes information to small
businesses through their trade
associations, equipment and chemical
suppliers, and other service providers.
A CAP member represented Oregon at
the White House Conference on Small
Business. Many elements of the White
House Conference were integrated into
OR's Small Business Communication
Plan. CAP and SBAP are collaborating
with Small Business Development Center
on a pilot education project. Special
workshops are held as part of regularly
scheduled CAP meetings to provide small
business technical assistance outreach.
Korean translations of the dry cleaning
regulation have been made by a Korean-
speaking member of the CAP
1 1
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBO funded by Department of
Environmental Protection and uses
local service providers, which are
funded by the Department of
Commerce.
Those expenses identified as travel,
transportation, reproduction, seminars
are reimbursed by Title V.
SBO (1 FTE) funded entirely from state
revenues not associated with the CAA
program. A second position will be
funded from the CAA program.
SBO supervised by Secretary of the
Department. SBO has direct contact
with SBAP.
Funded by industry fees.
SBAP
Department of Environmental
Protection contracted many SBAP
services to a private contractor. SBAP
received cooperation from trade
associations, utilities, and district
libraries in delivering services.
Use our Planning Division technical
staff in assisting small business.
SBAP integrated into Department's
existing P2 program. 0.5 FTE currently
providing limited services. (Rl DEM is
awaiting formal approval to hire 1
environmental planner and 1 air quality
engineer to staff SBAP. In the interim,
the Department's existing P2 staff
respond to industry inquiries.
0.50 FTE dedicated by air staff to
provide air dispersion modeling for
qualified small businesses.
The individuals that work in the air
program all contribute to the success
of the SBAP.
Funded by industry fees.
CAP
Department of Environmental Protection
provides administrative support to CAP
CAP meetings held in the Department's
building.
Any expenses related with travel,
transportation, reproduction, etc. are
reimbursed by Title V.
N/A
CAP made up of individuals across South
Dakota. Good mixture of private
individuals and small business owners.
To be funded by industry fees.
12
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Texas
Voluntary Consultant Program (10
active members).
Five Small Business Advisory
Committees (total 95 members).
Small Business Development Centers
(62 Centers).
Train workers to educate business
owners (5 sessions/181 trained).
Work with suppliers and banks (30
banks).
Work with TNRCC regional offices and
municipalities to coordinate activities
and information. Form partnerships
with trade associations. This leads to
increased attendance and increased
numbers of workshops funded by
associations.
SBO & SBAP combined.
Diverse membership - meet twice per
year around the state.
-------
TABLEE-14
(Continued)
STATE OR
TERRITORY
Utah
Vermont
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBO office has met with each Division
and received some support for cross-
referencing among division services
and Utah's small businesses. One
Division created brochure specifically
to assist small businesses in becoming
familiar with their services. Internal
Division committee created to improve
coordination and develop a small
business policy (to be complete spring
96). One outcome of this committee
was the regional award of the Small
Business Leadership Grant "Partnership
for Compliance," which increases the
"team" approach through outreach,
networking, and P2 activities.
Voluntary Assistance Program (VAP)
developed to provide small business
on-site compliance support through
coordinated effort with Division and
Department's P2 Program. In
coordination with Utah's P2 Program,
EPA grant provided funding to
establish this as a new position in SBO
office. As requests increase for VAP
on-site services, citizen volunteer
program targeted for start-up in near
future (three consultant volunteers
have agreed to participate).
Acting SBO employed by Air Pollution
Control Division. Official title is "Air
Quality Permit Assistant"; major duties
include providing administrative
support to Air Division Director and
Permitting section.
SBAP
SBAP receives technical support from
Department's P2 Program. SBAP also
received grant funds from the P2
Program to support a P2 Small
Business Grant Program.
N/A
CAP
Small Business Advisory Committee
received support from existing division
and department resources. For example,
Department's consulting organizational
facilitator has spent many hours working
with the Committee to establish working
priorities and action plans. Division's
Executive Director's Office provided
clerical support to prepare agendas,
minutes, and workplans.
N/A
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
Virginia
Utilizes the experience and expertise of
SBAP Director, other DEQ staff,
contacts within SBDC Network, and
trade/business organizations maintain
the pulse of the small business
community vis-a-vis air regulatory
impacts.
SBAP Director is also responsible for
Air Division Air Toxics Program.
Leveraging of 2 staff senior air toxic
engineers for implementation of MACT
provides the 0.3 FTE. Coordination
and utilization of DEQ's P2, and
Compliance & Enforcement Programs'
resources also compliments SBAP
activities. There are assigned SBAP
Liaisons (permit engineers in each of
DEQ's regional offices) that function
on an ad hoc, as-needed basis for
outreach, compliance assistance, etc.
Coordination and utilization of
resources (people & material) from
trade associations, SBDC Network, and
business groups provide a base of
outreach support.
Compliance Advisory Board (CAB) is in
the infancy of its activities. They have
begun to review materials for
understanding of the full program and
the mechanisms to achieve the desired
result of regulatory compliance for the
small businesses of the Commonwealth.
They have begun to review and edit a
permitting guide.
Virgin Islands
Director of VI Small Business
Development Agency has been
appointed to serve in the SBO function
without additional compensation. His
support staff may be compensated.
Washington
SBO is agency representative to
Governor's Small Business
Improvement Council composed of
small business owners and various
state agencies responsible for
regulating state's businesses. SBO is
agency representative to Unified
Business Identifier (UBI) Board
composed of state and federal
regulatory agencies impacting primarily
small businesses.
SBAP supports and is supported by the
following relationships. Technical
assistance staff for business-related
pollution control/prevention exist in
several other Ecology programs.
Outreach and assistance staff in four
of state's seven local air authorities.
Moderate risk waste staff in states 39
counties.
One CAP member is legislative liaison for
Air Quality Program. All other CAP
members are unpaid volunteers (per
diem, travel, lodging, and meals
reimbursed). Staff support provided by
SBAP
-------
TABLE E-14
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
West Virginia
SBO works closely vyith SBAP
personnel to evaluate technical aspects
of small business issues. DEP
personnel outside air office are
available for consultation.
SBAP works with other air quality
staff, when necessary, to evaluate
permit and Title V applicability for
small business. Other DEP staff,
especially P2 Services, are available to
help coordinate assistance to small
business. SBAP coordinating its
efforts with other outside assistance
groups, including University and Small
Business Development Center efforts.
All members serve on a volunteer basis.
Wisconsin
Wyoming
Numerous experts (development
finance, permit assistance,
environmental compliance/safety)
provide assistance, as needed, to SBO.
DNR personnel periodically provide
technical review of publications for
completeness and accuracy, help
formulate outreach strategy, and
suggest work plans.
Personnel from SBAP coordinate meeting
locations, develop agenda topics and
organize quarterly CAP meetings. Others
from Wl Department of Natural
Resources, Wl Department of
Development, and University of
Wisconsin Solid and Hazardous Waste
Education advise and inform the CAP on
an as-needed ';asis.
Since apart from SBO function, the
designated SBO also has
responsibilities working with each of
the departments 7 divisions;
coordinates activities affecting small
businesses, especially outreach
activities. SBTCP able to tap into
networks and venues already
developed by the established P2
programs in the Solid and Hazardous
Waste Division and in the underground
storage tank program. Although not
under the auspices of the SBTCP, the
SBO is positioned to ensure the
department's other divisions and
programs, where appropriate, are
sensitive to the concerns of small
businesses.
SBAP leverages limited resources
though outreach to affected small
businesses through trade associations
and professional organizations such as:
WY Trucking Association, WY Auto
Dealer Association, WY Mining
Association, WY Federation of
Independent Businesses, and American
Society of Safety Engineers. SBAP
established information sharing
relationships with other WESTAR
SBAPs and uses their ideas and
outreach material.
Department strategic plan calls for its
other small business assistance programs
to coordinate with the CAP and SBO
where appropriate.
-------
TABLE E-15
SBAP MECHANISMS FOR AVOIDING DUPLICATION AMONG SBTCPs
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
Communication/
networking with
SBTCP and state
agency personnel via
phone, mailing lists,
etc.
-
X
X
X
-
X
X
-
X
X
X
-
-
-
Meetings.
conference calls and
other contacts with
SBPA/SBO
personnel within
EPA region
-
X
-
-
-
-
-
-
-
X
X
-
X
X
Review of
EPA
documents/
Contact with
EPA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Networking through
state or regional air
group meetings
such as WESTAR
(Western States Air
Resources)
-
X
-
-
-
X
X
-
-
-
-
-
-
-
Review of
documents from
other public.
private, and/or
university
sources
-
-
-
-
-
X
Information
gathering from
electronic
sources '
-
-
-
-
-
-
X
-
X
-
-------
TABLE E-15
(Continued)
Program
IN
IA
KS
KY
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
Communication/
networking with
SBTCP and state
agency personnel via
phone, mailing lists,
etc.
X
X
X
X
X
X
-
-
X
X
-
X
-
X
-
Meetings,
conference calls and
other contacts with
SBPA/SBO
personnel within
EPA region
X
-
-
-
-
-
-
-
X
X
-
X
-
X
-
Review of
EPA
documents/
Contact with
EPA
X
-
X
-
-
X
X
-
-
-
X
-
-
-
-
Networking through
state or regional air
group meetings
such as WESTAR
(Western States Air
Resources)
-
-
-
-
-
-
-
-
-
-
-
-
-
Review of
documents from
other public,
private, and/or
university
sources
-
-
X
-
-
-
-
-
-
X
X
-
Information
gathering from
electronic
sources °
-
-
-
X
-
-
X
-
-
-
-
-
-------
TABLE E-15
(Continued)
Program
NJ
NH
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
Communication/
networking with
SBTCP and state
agency personnel via
phone, mafling lists,
etc.
X
X
X
X
X
X
X
X
-
X
-
X
X
X
X
Meetings,
conference calls and
other contacts with
SBPA/SBO
personnel within
EPA region
-
-
-
X
X
X
-
-
-
-
-
-
-
-
-
Review of
EPA
documents/
Contact with
EPA
X
-
X
-
-
-
X
-
-
-
-
-
-
-
-
Networking through
state or regional air
group meetings
such as WESTAR
(Western States Air
Resources)
X
-
-
-
-
-
-
-
-
-
-
-
-
X
-
Review of
documents from
other public,
private, and/or
university
sources
-
-
-
-
-
-
-
-
-
-
-
-
Information
gathering from
electronic
sources *
-
-
-
-
-
-
-
-
-
-
-
-
-
X
-
-------
TABLE E-15
(Continued)
Program
TX
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Communication/
networking with
SBTCP and state
agency personnel via
phone, mailing lists,
etc.
X
X
-
X
-
X
X
X
-
37
Meetings,
conference calls and
other contacts with
SBPA/SBO
personnel within
EPA region
X
-
-
-
-
X
-
X
X
17
Review of
EPA
documents/
Contact with
EPA
-
-
-
-
-
-
-
-
-
8
Networking through
state or regional air
group meetings
such as WESTAR
(Western States Air
Resources!
-
-
-
-
-
X
-
-
X
7
Review of
documents from
other public,
private, and/or
university
sources
-
-
-
-
-
-
X
X
6
Information
gathering from
electronic
sources *
X
-
-
-
-
-
-
-
-
6
a: Includes bulletin board services, web pages, and e-mail networks.
-------
TABLE E-16
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE PAPERWORK REDUCTION ACT
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
Routine review
of SBTCP
documents lor
compliance
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Receiving /
providing
information
electronically
-
X
-
-
-
-
-
-
-
-
-
-
-
-
Simplified /
consolidated
permits and/or
forms
-
-
-
-
-
-
-
-
-
-
X
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
-
-
X
-
-
-
X
-
-
-
General
permits for
certain types
of industries
-
-
-
-
-
-
X
-
-
-
-
-
-
-
Concise easy-
to-read
summary
documents
-
-
-
X
-
-
-
-
-
-
-
Other
(See below)
-
-
-
-
-
-
-
-
X
-
-
-
-
-
-------
TABLEE-16
(Continued)
Program
IN
IA
KS
KY
LA
ME
MO
MA
Ml
MN
MS
MO
MT
NE
NV
Routine review
of SBTCP
documents for
compliance
-
-
X
X
-
X
-
-
-
-
-
-
-
-
-
Receiving /
providing
information
electronically
-
-
-
-
X
-
-
-
-
-
-
X
-
-
-
Simplified /
consolidated
permits and/or
forms
-
-
-
-
X
-
-
-
-
X
-
-
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
General
permits for
certain types
of industries
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Concise easy-
to-read
summary
documents
-
-
-
-
-
-
-
-
-
-
-
Other
(See below)
-
-
-
-
-
-
-
-
X
X
-
X
-
-
-
-------
TABLE E-16
(Continued)
Program
NJ
NH
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
Routine review
of SBTCP
documents for
compliance
-
-
-
-
-
-
-
-
-
-
-
-
X
-
-
Receiving /
providing
information
electronically
-
-
X
-
-
-
-
-
-
-
-
-
-
-
-
Simplified /
consolidated
permits and/or
forms
-
-
-
-
X
-
-
-
-
-
-
-
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
X
-
-
-
X
-
-
-
-
-
-
General
permits for
certain types
of industries
-
-
X
-
X
-
-
-
-
-
-
-
-
-
-
Concise easy-
to-read
summary
documents
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Other
(See below)
-
-
X
-
-
-
-
-
X
-
-
-
-
-
-
-------
TABLE E-16
(Continued)
Program
TX
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Routine review
of SBTCP
documents for
compliance
-
X
-
-
-
-
-
X
X
7
Receiving /
providing
information
electronically
-
-
-
-
-
-
-
X
-
5
Simplified /
consolidated
permits and/or
forms
-
-
-
-
-
-
X
-
-
5
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
-
X
-
-
-
5
General
permits for
certain types
of industries
-
-
-
-
-
-
X
-
-
4
Concise easy-
to-read
summary
documents
X
-
-
-
X
-
3
Other
(See below)
-
-
-
-
-
X
X
X
-
9
Other Actions:
DC: Facilitation of penalty avoidance by arranging to allow dry cleaners to review facilities prior to compliance inspections.
Use of multi-media inspections, reducing forms from 3 to 1.
Ml: Reduction and recycling of paper whenever possible.
MM: Working with rule writers to minimize complexity of modifications to regulations while still achieving NESHAP authorization.
-------
TABLE E-16
(Continued)
MO: Performing RACT analysis for several facilities to compare results with existing state regulations.
NM: Reduction and recycling of paper whenever possible.
OR: Exploring options to regulate and monitor compliance while reducing paperwork, including prohibitory rule, permit by rule, and
general permits.
WA: Assistance in design of permit applications and permit shells to minimize complexity and maximize understanding.
One-on-one report/permit preparation guidance allowing small businesses to comply without having to read regulations.
WV: Solicitation of input from industry on current regulations for use in developing future regulations.
Wl: Cooperation and sharing of information and written materials from other states, universities, and other organizations to prevent
duplication of effort.
-------
TABLE E-17
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE REGULATORY FLEXIBILITY ACT
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
Simplified/
consolidated
permits and/or
forms
-
-
-
-
-
-
-
-
-
-
X
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
-
-
-
-
-
-
X
-
-
-
General
permits for
certain types
of industries
-
-
-
-
-
-
X
-
-
-
-
-
-
-
Routine review
of SBTCP
documents
for compliance
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Amnesty
program
-
-
-
-
-
-
-
-
-
-
-
Review/comment
on new air
regulations to
evaluate impacts
-
-
-
-
X
-
-
-
-
-
-
-
Other
(See below)
-
-
-
X
-
-
X
X
-
X
-
-
-------
TABLE E-17
(Continued)
Program
IN
IA
KS
KY
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
Simplified/
consolidated
permits and/or
forms
-
-
-
-
X
-
-
-
-
X
-
-
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
.
-
-
-
-
-
-
-
-
-
-
-
X
-
-
General
permits for
certain types
of industries
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine review
of SBTCP
documents
for compliance
-
-
X
-
-
X
-
-
-
-
-
-
-
-
-
Amnesty
program
-
-
-
-
-
-
-
X
-
-
-
-
-
Review/comment
on new air
regulations to
evaluate impacts
-
-
-
-
-
-
Other
(See below)
-
-
-
-
-
-
-
-
-
-
-
-
-
-------
TABLE E-17
(Continued)
Program
NJ
NH
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
Simplified/
consolidated
permits and/or
forms
-
-
-
-
X
-
-
-
_ -
-
-
-
-
-
-
Eliminating
unnecessary
permits by
increasing
exemptions
-
-
-
-
X
-
-
-
-
-
-
-
-
-
-
General
permits for
certain types
of industries
-
-
X
-
X
-
-
-
-
-
-
-
-
-
-
Routine review
of SBTCP
documents
for compliance
-
-
-
-
-
-
-
-
-
-
-
-
X
-
-
Amnesty
program
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Review/comment
on new air
regulations to
evaluate impacts
-
-
-
-
-
-
-
-
Other
(See below)
-
-
-
-
-
-
-
X
-
-
-
-
-
-------
TABLEE-17
(Continued)
Program
TX
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Simplified/
consolidated
permits and/or
forms
-
-
-
-
-
-
X
-
-
5
Eliminating
unnecessary
permits by
increasing
exemptions
X
-
-
-
-
X
-
-
-
5
General
permits for
certain types
of industries
-
-
-
-
-
-
X
-
-
4
Routine review
of SBTCP
documents
for compliance
-
-
-
-
-
-
X
-
-
4
Amnesty
program
X
X
-
-
-
-
-
-
-
3
Review/comment
on new air
regulations to
evaluate impacts
X
-
-
-
-
X
-
3
Other
(See below)
X
-
-
-
-
-
X
X
-
8
Other Actions:
AR: Publication of regulatory documents that are more user-friendly.
CT: Developed and provided information on financial assistance programs to help with capital expenses involved in compliance with CAAAs.
DC: Facilitation of penalty avoidance by arranging to allow dry cleaners to review facilities prior to compliance inspections.
GA: Bringing proposed legislation to CAP for review.
-------
TABLE E-17
(Continued)
OR: Allowing use of "potential to emit" to apply for Title V permits for small businesses with actual emissions less than 50% of major source thresholds.
Deferring non-major PCE dry cleaning, chrome electroplating and anodizing, ethylene sterilizing, and users of halogenated solvents for 5 yedrb, in accordance with
EPA policy. If approved by EPA, chrome electroplaters and anodizers will be permanently exempted from acquiring Title V permits
TX: Development of working groups to ensure that rules do not create unnecessary burdens for small business.
Assisting in the streamlining of rules.
WV: Solicitation of input from industry on current regulations for use in developing future regulations.
Wl: Bringing proposed legislation to CAP for review.
Ensuring that CAP comments on proposed legislation are presented to appropriate legislators or regulatory agency officials.
Providing direct assistance to small businesses, such as help with calculations, clarification of rules and standards, and sponsorship of industry specific seminars.
Working closely with trade organizations to develop outreach materials and obtain feedback on regulations affecting industries they represent.
Developed a regulatory flexibility notification network to notify industries about legislation that may affect them, and where possible, giving them the opportunity
to comment.
-------
TABLE E-18
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE EQUAL ACCESS TO JUSTICE ACT
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
Routine review of SBTCP
documents for compliance
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Eliminating unnecessary
permits by increasing
exemptions
-
-
-
-
-
-
-
-
-
-
X
-
-
-
-
-
General permits for
certain types of
industries
-
-
-
-
-
-
X
-
-
-
-
-
-
-
-
-
Other
(See below)
-
-
-
X
-
X
-
-
-
-
-
-
-
-------
TABLE E-18
(Continued)
Program
KS
KY
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NJ
NH
NM
NY
Routine review of SBTCP
documents for compliance
Eliminating unnecessary
permits by increasing
exemptions
General permits for
certain types of
industries
Other
(See below)
X
-------
TABLE E-18
(Continued)
Program
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
Routine review of SBTCP
documents for compliance
-
-
-
-
-
-
-
-
X
-
-
-
-
-
-
-
-
Eliminating unnecessary
permits by increasing
exemptions
X
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
X
General permits for
certain types of
industries
X
-
-
-
-
-
-
-
-
-
-
-
-
-
Other
(See below)
X
-
-
-
-
-
-
-
X
-
-
-
-
-
-------
TABLE E-18
(Continued)
Program
WV
Wl
WY
TOTAL
Routine review of SBTCP
documents for compliance
-
-
X
4
Eliminating unnecessary
permits by increasing
exemptions
-
-
-
3
General permits for
certain types of
industries
-
-
-
3
Other
(See below)
6
Other Actions:
AR: Funds made available for engineering services for citizen groups aggrieved by permit actions of regulatory agency.
CT: Developed and provided information on financial assistance programs to help with capital expenses.
Proposed and had accepted low permit fees for small businesses.
Targeting small businesses that may lack capital or human resources to comply with CAAAs.
LA:
MO:
NC:
TX:
Minimization of recordkeeping and reporting requirements by developing cutoffs for types of operations included in an exclusionary rule that defines potential
emissions as actual or by allowing small facilities to use more realistic emissions calculations.
ADR services.
Pro bono legal services established.
-------
APPENDIX F
PROGRAM EFFECTIVENESS
-------
TABLE F-1
COMMENTS RECEIVED BY THE SBO OR THE CAP ON THE SBTCP
(Comments edited for space.)
Program
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Comment Received
Hotline callers expressed appreciation for services offered, registered complaints about pollution sources, and
complained about the hotline not being answered 24 hours a day.
Regularly receives positive comments on the type of information provided, the timeliness of the information
the services provided.
, and
Those who have received assistance found it to be a valuable resource.
Comments concerning Department of Pollution Control and on workshops about regulatory issues:
"The commitment to spend more time assisting, instead of fining, is very encouraging.'
"They try to help - good."
"Should have had this four years ago. The need to start a statewide liability fund for dry cleaners is very
important.11
"We need all the plain English materials we can get."
"We appreciate your efforts to help us and our industry."
Mostly favorable comments in helping the public successfully and working with the permitting process.
All comments received by the CAP and SBO were favorable.
We received thanks for creating simple-to-use application materials, for putting on workshops, for sharing
knowledge we gained from industry with our permit review and performance staff, which led to more workable
permit conditions, and thanks from individual business owners for help with forms and determining their permit
report and reporting requirements.
Businesses have commented that services provided were extremely helpful.
Financial Assistance for Vapor Recovery Systems (FAVRS) has been recognized by EPA as a national model
compliance assistance efforts and received favorable local press coverage.
for
Receive excellent support and backing of State Chamber of Congress.
-------
TABLE F-1
(Continued)
Program
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Comment Received
SBO: Outreach done by one individual, visiting facilities on his own time.
SBAP: Information systems will be on-line.
CAP: Great organizational skills.
The Ombudsman has received numerous positive comments from the regulated community and others regarding
the operations of the SBAP.
"Your office is very helpful.1
"The small business staff is very responsive!"
"The help provided by your office is greatly appreciated."
No comments provided.
A survey was given for all workshops. The general consensus was that the workshops were helpful and that we
should do more of them. All comments received have been favorable to the program, asking us to do more in the
future.
Business association members have expressed that DCCA staff are responding to their needs in a timely and
professional manner.
Individual companies contacted were pleased that a nonregulatory, small business assistance agency was available
for help and information on environmental compliance issues.
Received several positive comments regarding the services being offered, most notably in the areas of phone
assistance and outreach.
IAEAP tracks client evaluations on a standardized form. Based on 85 respondents, 95% rate service as excellent,
2% as good. Of the same respondents, 91 % rated the service as very helpful and 9% as somewhat helpful.
Verbal accounts received at SBO outreach meetings have indicated that citizens are pleased that such a resource is
available for their use at no cost. Businesses served by IAEAP have been exceptionally pleased with the assistance
they have received.
Many callers have expressed appreciation for prompt service. Several callers have suggested newsletter article
ideas, asked questions related to the newsletter, and given compliments on information supplied.
-------
TABLE F-1
(Continued)
Program
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Comment Received
State trade association directors and state Chamber of Commerce members indicated that the SBTCP was needed
to assist small businesses with the CAAA due to the complexity of the regulations and the limited resources of the
permitees. Same group expressed the need for similar programs dealing with soil and water regulatory issues.
"The SBAP has been very helpful when assistance has been requested."
"I cannot tell you how much I appreciate all tru work you've done for us over the past seven months. Clearly,
without your input I would have been unable to fulfill the requirements for compliance with the Air Quality
Standards."
"Increased awareness of small businesses of the activities of the SBAP and SBO would be helpful.
Overall very positive responses to the program by the small business community.
No comments provided.
No comments provided.
The CAP indirectly received an appraisal letter regarding outreach training initiated by the SBAP
The results of a survey sent to 267 randomly-selected SBAP clients indicated that 72% rated assistance as 'very
helpful," 25% rated it as "somewhat helpful," and 3% as "not that helpful." In addition, 95% of respondents
would recommend the SBAP to other businesses.
Numerous positive comments about the assistance provided, including comments such as "[The SBAP] made me
feel like a partner rather than an adversary in the pollution control business. '
"On behalf of the dry cleaning industry, I'd like to say thank you for your efforts to help us comply."
"I wanted to thank you and your staff for a truly great program. The staff is very knowledgeable and also very
open to suggestion."
"This program creates a cost effective way for us to comply with EPA Regulations. We appreciate the assistance
and will inform others about this great program."
No comments provided.
The SRO and the Small Business Engineer received personal thanks from the owner of a polystyrene insulation
manufacturing plant for the service they provided during the permitting process.
-------
TABLE F-1
(Continued)
Program
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Comment Received
"A breath of fresh air, we now have someone at the regulatory agency that will answer questions that concern us,
without talking to an inspector."
"You have done more in two hours to help me than the last two years of going to meetings put on by others. '
Douglas Manufacturing, Crete, NE.
"Before your office was established, we just could not seem to get the answers we needed. JBL Sound Systems,
Kearney, NE.
"It is a good working relationship between your agency and ours when a new business wants to come to
Nebraska. The SBAP is a positive step." Paraphrased from John Conners, NE Dept. of Economic Development.
No comments provided.
Appreciative to have someone to discuss regulations without fear of enforcement.
Glad that someone could help identify which regulations are and are not applicable.
Appreciated having a resource to help guide them through the regulatory process.
Assistance in interpretation of regulations beneficial.
Dry cleaner industry has commented positively on the materials developed for them.
The SBO has received positive feedback that the program is going in the right direction.
Numerous positive news articles in trade journals.
Numerous positive correspondence from clients, including comments such as "[SBAP] staff are generally perceived
to be very well informed, helpful, responsive, professional, etc."
"We certainly would have been floundering without your invaluable assistance."
"Thank you for your help in walking us through the Permit to Construct process. You helped make the process
easier than I expected it to be. ..Your organization is a tremendous asset to a small business like ours."
"Your office is a glowing example of a government body that provides help and considerable expertise to small
business that is needed." (wood products manufacturer)
"I've been in business for 41 years and this is the first time someone from the government has explained how
these environmental rules affect my business." (owner of a small metal finishing shop)
No comments provided.
-------
TABLE F-1
(Continued)
Program
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
Comment Received
Most frequent comments express relief that the state was providing technical assistance on complex CAA
requirements. Initial concerns about confidentiality were somewhat alleviated by protections in Ohio law.
There was a positive response to the concept of targeting special assistance to small business. Requested site
visits have been well received.
Financial assistance is cited as a necessary component of this program. Many small businesses face the double
challenge of needing financing in an amount considered small by many capital sources and associated with the
perception of high risk because it is an "environmental" loan.
Without exception, the comments received by agency management have been extremely positive toward the work
that the SBAP is doing, as well as the entire Customer Assistance Program (within which the SBAP is housed).
Particularly, the regulated community is most impressed with the access to information, the willingness to take an
"assistance first, enforcement second" approach, and our dedication to representing the needs of the small
business community.
In general, there is greater acceptance of the Small Business Assistance Program. Several individuals attending the
November 15, 1995 chrome electroplating and anodizing teleconference mentioned it was very worthwhile. A
Decorative electroplating business mentioned that the fume suppressants placed into its tanks resulted in
noticeable reduction in workplace odors. Several inquiries were received about filling out and submitting
notification forms. Two dry cleaning and one lighting fixture company, with assistance from SBAP, were brought
into air compliance and are requesting assistance in applying for pollution prevention tax credits. A small painting
company treating aluminum electronic parts in a chrome conversion tank thanked the SBAP for its assistance in
meeting fire marshall requirements.
The few comments received are usually positive.
No comments provided.
SBO has received positive comments on the SBTCP from assisted businesses and from the State's Economic
Development Corporation (EDO, which has been working with SBO to assist companies that CAA-related
compliance issues.
-------
TABLE F-1
(Continued)
Program
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Comment Received
We have received numerous comments on how this type of technical assistance has made ihe difference in being
able to get permits and come into compliance. Statements have been made to the effect that if it were noi for our
assistance, they would not have come forward due to the cost of private consultants.
Contacts with SBO have been generally positive.
Contacts to SBO regarding assistance from Small Business Assistance Program have been very favorable.
The Tennessee Air Pollution Control Board, which has the authority to establish the program's funding level, I
been complimentary of program efforts.
A regional business publication included a four column article on the program.
Program workshops received press coverage in the business section of a major newspaper.
Four out-of-state program and a foreign country representatives attended program workshops.
One business owner commented after a Clean Air Act review workshop that the statement "I'm from the
government and I'm here to help" is really true.
Workshop evaluations indicated the participants found the workshop to be good to excellent.
The Tennessee Association of Business complimented activities conducted by the program.
as
"We would like to take the this opportunity to commend Tamra-Shae Oatman and Adam Haynes, Small Business
Advocates Office, for their assistance and advice in establishing the SAMA Small Business Environmental Advisory
Committee."
Excellent work that has been done by the TNRCC Small Business Advocate Office during the past two years.
Keep providing up-to-date, easy to understand information for small business owners.
Better interpretation of Clean Air Act (CAA).
Feedback consistently indicates that the information is accurate, accessible, timely, and supportive. However,
there continues to be a lack of program recognition, despite many outreach efforts.
No comments provided.
No comments provided.
No comments provided.
-------
TABLE F-1
(Continued)
Program
Washington
West Virginia
Wisconsin
Wyoming
Comment Received
SBO: General program activities too "young" to provide meaningful comments.
The WV Cleaners and Launderers Association has commented that the SBAP was very helpful m meeting federal
MACT requirements.
The Chrome Electroplating Workshop evaluations resulted in ratings of 8.6 for the workshop and 9.1 for SBAP
presenter (out of 10).
The SBAP and SBO have received several verbal comments that praise their assistance efforts.
No negative comments have been received to date.
Numerous small business representatives have commented that they appreciate the ability of the program to
provide clear and understandable guidance regarding environmental regulations. They also appreciated the prompt
service and turn around time on information they received.
"This type of cooperation with business in helping reduce paperwork burden is real evidence of Wisconsin
government's commitment to improve the business climate in our state."
During a CAP meting, a representative of the National Federation of Independent Small Businesses (NFISB)
commented on the effectiveness of the SBTCP and that the agency will not seek penalties when businesses work
in good faith to come into compliance.
-------
TABLE F-2
NATURE OF COMPLAINTS RECEIVED/INITIATED BY THE SBO OR THE CAP
AND INFORMATION OF THEIR RESOLUTION
(Responses edited for space.)
Program
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Complaint/Comment
Hotline not answered 24 hours a day.
No complaints/comments provided.
Permitting staff not responsive to applicant needs.
Permit application approval takes too long.
No response.
Forms need to be simplified. Not knowing how to
proceed.
Resolution
No resolution.
Re-established lines of communication between
applicants and Permit Engineers.
Helped develop general permits to shorten approval
times.
Complaints are generally routed to our Public
Information Agency or received by the Director and
assigned to a Division for resolution.
Streamline and speed up the process. Helped work
through the form, made connections with appropriate
people.
No complaints/comments provided.
One CAP member commented that the SBO needs to
return phone calls in a more timely manner.
Seminar/workshop attendees complained that
announcements did not give enough advance notice.
Permit applications required too much time to complete
and unnecessary paperwork was sent.
Phone calls will be returned within 24 hours of receipt.
Efforts underway to increase staff resources.
Seminar/workshop announcements will be mailed at
least 3 weeks in advance of the event.
Regulatory personnel worked with business over the
phone to resolve confusion. They admitted that
unnecessary and confusing paperwork was sent.
No complaints/comments provided.
No complaints/comments provided.
Complaint regarding regulatory inflexibility and economic
hardship imposed by Georgia Air Quality Rules.
Worked with company involved and recommended the
revision of an Air rule that eliminated obstacles to
production and growth.
-------
TABLE F-2
(Continued)
Program
Hawaii
Idaho
Illinois
Indiana
Iowa
Complaint/Comment
Resolution
No complaints/comments provided.
No complaints/comments provided.
The toll-free helpline used in early 1 995 was automated,
and it took three button pushes to reach the SBAP staff.
In July, 1 995, a new toll-free helpline was installed that
rings directly on SBAP staff desks.
No complaints/comments provided.
Air quality permit denied.
Air quality regulations as they pertain to open burning
and community inaction toward institution of a burning
ban.
Air quality regulations as they apply to concrete dust
generated in road projects.
Auto body shop compliance problem with IDNR referred
to SBO by IAEAP.
Financial assistance/availability complaints and
questions.
Complaints regarding complexity of construction permits
and operating permits.
Two cases involving dry cleaners and asbestos
regulations.
Clarified situation with complainant and IDNR.
Referred complainant to IDNR for rule specifics.
Directed to Clean Air Act Amendments regulations
regarding fugitive dust emissions.
Rectified by IDNR and auto body shop the day SBO
was notified of the problem.
Investigated funding options. Met with Small Business
Administration to encourage promotion of their
Pollution Control Loan. Introduced legislation to allow
pollution control equipment purchased by service
businesses to be included in current property and sales
tax exemption law.
Currently serving on a task force reviewing and revising
the construction permits.
Not yet resolved.
-------
TABLE F-2
(Continued)
Program
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Missouri
Michigan
Complaint/Comment
General miscommunications or misunderstandings
between regulators and businesses.
Complaints about pending legislation.
In several instances, businesses complained about staff
(i.e. personnel instances).
Compliance schedules were questioned.
Professional engineers expressed concern that SBAP
would ultimately cut into market for their services.
Resolution
Investigated the complaints and clarified the
miscommunications.
Businesses were informed of procedures to contact
their legislators. Articles and a brochure were written
about the legislative process, how to present
testimony, and how to effectively contact a legislator.
Each complaint was handled differently based on
needs. In general, supervisors were consulted.
When possible, additional time was provided.
SBO met with Executive Director of Kentucky Society
of Professional Engineers and spoke to the Kentucky
Council of Consulting Engineers to give them accurate
information about the program.
No complaints/comments provided.
Fear of enforcement.
Companies do not know about the program.
Formulated a policy.
Development of outreach effort for 1 996.
No complaints/comments provided.
No complaints/comments provided.
No complaints/comments provided.
Applicability of New Source Review.
Applicability of Title V.
Status of application for Permit to install.
Difficulties with local regulatory agency district office.
Mercury Pollution Task Force.
VOC exemptions.
Applicability of NESHAP.
Outdoor burning bans.
Enforcement intercession.
Pollution control tax exemption certificates.
Attainment vs. non-attainment areas.
All complaints were resolved satisfactorily.
-------
TABLE F-2
(Continued)
Program
Minnesota
Mississippi
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
Complaint/Comment
Compliance initiative for sand and gravel industry
thought to be unfair by industry.
Dry cleaner became involved in a Superfund site with
multiple owners. Complaint concerned how the
business was "treated."
A chemical distributer expressed concern, echoed by
DEQ Air Toxics Section, that dry cleaners needed hands-
on assistance with the MACT standard.
No complaints/comments provided.
Forms are too complicated.
Don't understand what is needed.
"Your agency is picking on me because 1 cannot afford
to fight you."
No complaints/comments provided.
Permit application fees are too high/not equitable.
Recordkeeping/reporting requirements burdensome.
Regulations seen as costly.
No complaints/comments provided.
No complaints/comments provided.
Resolution
Worked with AQ staff and trade association to ease
some provisions, especially penalty matrix for very
small operators.
Worked with owner and MPCA site response staff to
help them understand that a very small business
operates differently than a large business. Sought
more understanding of their situation and "simple
English" stating of the facts and options.
Three workshops were organized and presented in
three different areas of the state
Worked through the form, either by phone or in person.
On-site visits to discuss requirements.
Expressed understanding and explained requirements to
report. Offered to help him through the process.
Permit fees eliminated and emissions-based fees
instituted.
Allow for prediction/purchase records to be used for
compliance assistance.
Developed specific analysis showing compliance
reducing costs and increasing profits and quality
through reductions in material usage and waste.
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TABLE F-2
(Continued)
Program
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
Complaint/Comment
Businesses don't have access to funds for
environmental compliance equipment and services.
The state regulatory agency takes too long processing
permit applications at the expense of business
operations.
Many small businesses didn't know about regulations
and are in non-compliance. They are afraid to come
forward voluntarily because of penalties.
The paperwork associated with complying with state
regulations is too cumbersome.
Conflicting information from consultants and regulators.
Cost of permit, especially with PE seal requirement.
Permit requirements are too complex.
The cost of complying is too high.
Resolution
Working with banks to initiate a financing program.
Works with regional offices to expedite paperwork.
Worked with the state regulatory agency to establish a
small business amnesty program.
Worked with regulatory agency to streamline
paperwork such as implementing a registration
program.
Briefed clients on regulatory requirements and met all
interested parties to clarify issues.
Encouraged the use of general permits which preclude
the need for a PE and cost half the normal permit fee.
Developing a permit guide to accompany simplified
permit application.
Expanded the list of insignificant activities and
exemptions for smaller businesses in the rules.
No complaints/comments provided.
Most "complaints" have centered on lack of
understanding of air regulations and requirements, most
specifically determining emissions.
Businesses have been referred to the SBAP at OEPA for
in depth assistance; response has been favorable.
No complaints/comments provided.
No complaints/comments provided.
No complaints/comments provided.
No complaints/comments pso-'ided.
Difficulty in meeting emissions caps and other limits.
A process has been established to resolve complaints
through technical assistance, SBO, and regulatory staff.
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TABLE F 2
(Continued)
Program
South Carolina
South Dakota
Tennessee
Texas
Complaint/Comment
Resolution
No complaints/comments provided.
Don't know who to talk to about a particular issue or
concern.
Don't have proper information on a subject.
Don't know what permits are required for my business.
Directed party to appropriate DENR person, usually in
the Small Business Assistance Program.
Provided information and directed party to Small
Business Assistance Program or other DENR staff for
additional information.
Provided party with DENR permitting guide and direct
them to appropriate DENR staff.
No complaints/comments provided.
Small businesses find recordkeeping and reporting time-
consuming and redundant.
Environmental laws are not clearly communicated to
small businesses.
Small businesses find it difficult to acquire funds to
purchase compliance equipment.
The SBAP is working with other divisions in the agency
to consolidate reporting requirements.
The SBAP initiated a plain language program to insure
that all materials sent to small businesses are easy to
read and understand.
The SBAP has initiated a financial assistance program
to assist small businesses in finding funding to
purchase needed equipment.
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TABLE F-2
(Continued)
Program
Complaint/Comment
Resolution
Utah
Many businesses expressed concern that the length of
the Amnesty Program was too short of an opportunity
for businesses to become aware of the program in order
to participate.
Small Business Advisory Committee (SBAC)
unanimously requested extension of the program to
allow greater participation. The Director concurred and
extended the program until January 30, 1996.
Some businesses did not qualify for the Amnesty
Program due to the structured criteria.
Formal "Amnesty Exception" review process
established under Director's authority to review
individual company situations and to make final
determination. In nearly every case, "Amnesty
Exceptions" were granted. Where companies clearly
did not qualify, an individual compliance support
process was put into effect.
Divisions were unfamiliar with services provided within
the Department, and that often their limited coordination
created a delay in small businesses receiving timely and
accurate information.
Individual meetings held with each Division to increase
coordination and to create cross referencing and multi-
media opportunities. One division produced and
distributed a small business brochure as a result of this
effort.
There did not appear to be consistent division-wide
understanding of existing small business services and
that an increased level of coordination was needed.
An internal Division Small Business Coordinating
Committee was established to help develop a unified
small business operating policy.
A complaint was registered against a municipal
permitting office regarding inaccurate information on
obtaining Approval Orders in time for construction of a
paint booth, which created construction delays. The
owner was also given an inaccurate phone number for
the SBO office.
Referrals were made to appropriate contacts and to
SBAP. Additionally, Amnesty and SBAP brochures
were supplied to municipalities and will be updated and
distributed statewide in the near future.
Several complaints involved venting frustrations on
various issues.
Individuals are invited to meet face-to-face to discuss
their concerns and to receive immediate responses.
Four such meetings were held with positive results.
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TABLE F 2
(Continued)
Program
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Complaint/Comment
A complaint was made against a consulting company for
overcharging, delaying responses, and providing
haphazard submittals.
Resolution
Issue still pending. Several means of informing
businesses about their consultants' progress are being
considered. To date, discussions include reducing the
company's permit fee by billing significant portions
under training when the Division is "educating" the
consultant, holding training workshops for consultants,
and providing copies of all correspondence with
consultants to the hiring company. Currently, draft
legislation is in motion to establish a certification
program for consultants.
No complaints/comments provided.
Do not understand the regulations.
Regulatory development is very complicated and we are
never involved.
Assisted with understanding.
Provided opportunity for participation in the regulatory
development process.
No complaints/comments provided.
SBO: Expressions of general concerns, usually
procedural in nature.
The SBO has intervened in several enforcement actions
involving small businesses. In these cases, the SBO felt
that the agency had not adequately considered the
needs and financial resources of the alleged violator in
assessing penalties and permit fees.
Article by Donald Croysdale criticizing the Clean Air Act.
Critique of publication quality (non-content).
Very few, primarily involving reports of possible
violations.
Concerns referred to local air authorities BAP or
appropriate Ecology regional office for resolution. SBO
provided follow-up to ensure resolution.
Response letter written by CAP member addressing
concerns.
Purchased updated desk-top publishing software and a
scanner to improve publications.
Discussed issue with CAP which advised that small
businesses may be cutting costs by violating
regulations and competitors may call in such
complaints.
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TABLE F-3
SIGNIFICANT PROGRAM ACCOMPLISHMENTS, AWARDS, AND RECOGNITIONS
Program
Alabama
Alaska
Arizona
Final Cty.
Maricopa Cty.
Pima Cty. &
Tucson
Arkansas
California
Accomplishments
No comments.
No comments.
No comments.
No comments.
In its first year, Maricopa County SBEAP made great strides in developing partnerships with industry organizations, local and state
government agencies, chamber of commerce, small business organizations, and local businesses. By working with the Home Builders
Association, Printing Industries Association of AZ, American Electroplaters & Surface Finishers, AZ Association of Industries, AZ Small
business Association, AZ Small Business Connection, and Maricopa County Community Colleges, a large number of businesses have
been reached and provided with a new resource. By working closely with regulatory agencies, SBEAP has taken away some of the fear
of the unknown that many companies have regarding rules and possible fines for non-compliance.
SBEAP's first annual Small Business Environmental Awareness Conference, "Navigating the Air Quality Maze, was a tremendous
success. The event was attended by over 100 people and included speakers from local, state, and federal environmental agencies,
environmental attorneys, P2 specialists and industry professionals. The next conference will be in October 1996 and will include topics
suggested by businesses.
In May 1995, Maricopa County Environmental Services Department, SBEAP, and AZ Association of Industries (AAI) initiated a
cooperative effort in response to the business community to improve the air permitting process in the County. An Air Permitting
Improvement Committee was developed to determine how to make the process more streamlined, consistent, predictable, and timely.
Four subcommittees were tasked with specific focus areas, and meeting were held over the summer. A final report was presented to
the Maricopa County Board of Supervisors with suggested courses of action. This cooperative effort between government and industry
has improved their working relationship. SBEAP represented the small business person on committees dealing with such issues as
streamlining the air permitting process, permit fees, standard exemptions, and thresholds for emissions. It is critical their voice be heard
when developing policy at the local or state level.
Continually increasing requests from businesses and the regulated community indicate the PDEQ Business Assistance Program is
working, essential, and appreciated.
No comments.
A small business meeting group has been formed with local Air Districts and business representatives.
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TABLE F 3
(Continued)
Program
Accomplishments
Colorado
A Memorandum of Understanding was established between the SBAP and the SBO. A joint workplan will be attached each year,
outlining joint projects. CO is connected with all other western states through WESTAR. These alliances have helped the overall
program. CO's SBAP/SBO has a working relationship with WY's SBAP, helping both programs. SBAP received the "Customer Service
Award" from the CO Department of Public Health and Environment. An "Automotive Refinishing Requirements" book was written by the
SBAP and was a huge undertaking involving the automotive trade group. This book has been considered very useful by the industry.
Connecticut
FAVRS (Financial Assistance for Vapor Recovery Systems) cited as a national model by EPA Administrator, Caiol Browner.
Small Business Leadership Grant.
Recipient of
Delaware
No comments.
District of
Columbia
Florida
During the year, the resources of the SBAP of the Nation's Capital grew considerably from a one-person effort to a three-person team,
with the addition of the SBO and the agency CAP member. Progress was made towards completing the composition of the CAP, which
should become operational in 1996.
Program has done some on-site assessments for auto body shops and conducted a presentation during a Title V workshop to further
inform businesses about the program. 'Also made preparations for a small business workshop on Environmental Cost Accounting and
Budgeting for next year's program.
Florida SBAP has an active partnership with the pollution prevention section of the DEP P2 is one of the key goals established by the
Secretary of the Agency. Florida SBAP has effectively communicated to a majority of the small business community through outreach
using teleconference programs and timely mailings regarding pending federal and state regulations. Florida SBAP developed and is now
distributing copies of a multi-media guide for the dry cleaning industry. This information is reflective of future projects. Florida SBAP
presently is coordinating an EPA.Leadership Grant with the Florida Small Business Development Centers to provide technical information
to a targeted audience.
Georgia
SBO finalized an agreement between a small business and Environmental Protection Division allowing the business to increase its
production. The Division also decided to provide similar relief to other facilities by revising the VOC rules to allow up to 10 tons per year
of VOC before being subject to limitations.
SBAP staff performed 10 dry cleaner site visits and 3 compliance audits, and participated in 3 environmental expositions.
SBO resolved a conflict between Air Protection Branch and a small business.
SBAP staff prepared 4 articles for inclusion in an environmental journal and 2 small business newsletters.
SBAP staff provided assistance to over 200 businesses with questions about degreasers; only eleven of the businesses met the criteria
for a small business.
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TABLE F-3
(Continued)
Program
Accomplishments
Hawaii
No comment.
Idaho
During 1995, SBAP sponsored and participated in 6 statewide workshops for solvent/degreaser users. Working in cooperation with
Idaho's P2 coordinator and other DEQ staff, a multi-media approach was provided that describes water, air, and hazardous waste issues
associated with solvents. Participants talked to vendors about solvent substitutes and waste reduction. Approximately 200 people
attended the 6 six-hour workshops.
In October 1995, SBO met with small business programs from 11 western states. Since then, the group, known as WESTAR has
worked together to better use scarce resources, avoid duplication of efforts, and address problems unique to the west.
During 1994, the SBAP sponsored and participated in a dry cleaner teleconference delivered by EPA and the University of Tennessee.
partnering with the University of Idaho, Idaho State University, Boise State University, Lewis-Clark State University, and DEQ regional
offices, teleconference was presented around the state. Approximately 75 of 112 dry cleaners in the state participated. This was an
ideal example of how a one person operation (at the time) could utilize different resources to assist a large audience simultaneously
throughout the state.
By
Illinois
SBAP has been a part of many related and exciting projects during the past year. Efforts in IL have been „ partnership with DCCA (the
SBAP) and the lEPA-Small Business Office. The Governor's Small Business Environmental Task Force provided 39 recommendations to
assist small companies in dealing with environmental compliance issues. The report, completed in 1994, has been our road map in new
activities. In December 1995, the U.S. SBA provided the Task Force with national recognition for their efforts. The award was one of
35 presented for "innovative and effective initiatives on behalf of small businesses," and was presented at the SBA National Legislative
Conference by the Office of Advocacy.
To date, we have implemented or began implementation on 19 of 39 recommendations. One of these was an environmental amnesty
project. A pilot project in a two-county area near Rockford, IL was recognized by Governor Edgar. The pilot, which ran during Spring
1995, was deemed a success in helping small businesses. In November, Governor Edgar announced that "Clean Break" would become
statewide in 1996. We are now seeking printers and autobody shops access this new opportunity to learn their compliance
requirements, seek the assistance they need, and reach compliance with state regulations without the fear of enforcement. This
innovative approach is helping the environment in IL and providing for communication between government and small businesses as
never seen before.
Indiana
Five-Star Integrated Education Program for dry cleaners (including the development of a multi-media compliance manual and a recognition
program). Five-Star Integrated Education Program for minerals aggregate industry (pending); this program will include the development
of multi-media compliance manual and recognition program). Electronic fax-back and custom connect services. Consultant list
application for Title V program. Open houses for scrap tire compliance. 40 presentations/workshops on Title V air permitting program.
On-site compliance assistance program in southern Indiana (presently focusing on the Agency's new auto refinishing rule). Chromium
electroplating symposium. Indiana's compliance assistance program is multi-media.
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TABLE F-3
(Continued)
Program
Accomplishments
Iowa
Iowa EAR provides a full range of compliance and P2 services and provided brief assistance to over 3,500 clients and detailed assistance
to over 700 clients. We trained approximately 12 other state SBAPs through the EPA SBO's Peer Match Program and are working with
the SBO's office to develop a site visit training program.
Iowa SBO unique in that the position functions under the direction of the Iowa Citizens' Aide/Ombudsman office, which is a legislative
office with statutory powers to keep investigative records confidential and issue subpoenas. It is a non-partisan, independent agency
where action can be taken to resolve complaints. This provides the SBO with support and information plus the distinct advantage of
independence from any regulatory agency.
SBO identified communication problems regarding information dissemination to small businesses. A major concern is the negative
feelings small businesses have for the government and regulatory community. To further clarify and rectify these problems, SBO
requested an additional $10,000 from the IDNR to develop an outreach/educational plan. SBO also applied for a National Environmental
Education Training Foundation grant to implement an electronic-based method of information distribution.
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TABLE F-3
(Continued)
Program
Accomplishments
Kansas
Kansas was awarded a Small Business Leadership Grant in September 1995 for the development of training modules for small business
environmental staff. The manuals will include basic science and P2 information. The grant, obtained and supervised by Kansas
Department of Health and Environment, has been contracted to the SBAP component at the University of Kansas.
Program has received positive comments when contacted by telephone. We receive many comments like, "You are really fast to
respond," and "We have enjoyed working with you." These brief, unwritten comments serve to reward us for our work. We also know
our printed materials are used, because requests for copies from businesses who "heard about it" from a friend or competitor. We have
noted an increase in "repeat" callers.
One of the first contacts made by SBO was with KS Department of Commerce and Housing, First Stop Clearinghouse (a service provided
to thousands of new businesses each year). Commerce staff and SBO developed a workgroup of state, federal, and local agency staff
who work with businesses, especially small ones. This Small Business Assistance Group is now comprised of staff from KDHE, KS
Department of Commerce and Housing, SBA (Kansas City), KS Department of Human Resources, KS Department of Revenue, KS
Department of Agriculture, Small Business Development Centers, and EPA Region VII. The group meets quarterly and various agencies
describe their business services. The group's purpose is to foster a spirit of cooperation, ensure accurate referrals, share information
about upcoming events (business fairs, conferences, workshops), and distribute other's printed materials. Special events are listed in
various newsletters, where space is available for articles by other agencies. (For example, KS AIRLines SBAP newsletter provided space
for an article written by KS Department of Revenue staff relating to a new tax for dry cleaners.) This group has been successful and at
the request of industry, plans to develop business-specific materials.
An Air Emissions Inventory Workshop was presented in 3 KS cities. Answers in a post-workshop questionnaire indicated all attendees
rated the presentations as excellent or above average. The overall rating indicated most felt it was ''excellent" with only one ''average'1
rating.
A survey was taken to gain opinions on the quality of technical assistance provided. Most responded with a "very helpful" rating and all
would recommend the program to other businesses. One comment indicated, "This was the only place I could get answers."
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TABLE F 3
(Continued)
Program
Accomplishments
Kentucky
Press conference held 3/1/95 to announce the Program and to introduce members of Small Business Stationary Source Advisory Panel,
Director of Business Environmental Assistance Program (BEAP), and Air Quality Ombudsman.
In 3/95, the owner of a printing business that had received assistance from BEAP testified before a legislative committee in support of
the Program. She described to the committee how the assistance she received brought her business into compliance and the savings to
her.
Air Quality Ombudsman and a representative from the Division for Air Quality provided assistance to the Environmental Committee of the
Kentucky Fabricare Association on legislation to be proposed during the 1996 legislative season. Purpose of the KY Drycleaner
Remediation Act is to create a fund to clean up sites contaminated by drycleaning solvents with minimum state financial involvement.
Assistance included copies of current regulations and resource materials on compliance with the CAAA along with copies of current
mailing lists.
In August 1995, the Jefferson County Air Pollution Control District employed a full time Ombudsman. On November 15, 1995, the
Board of the District approved a pilot amnesty program for small business, which will be effective through 1996.
A Program Plan was developed by SBTCP stating goals and objectives, describing eligible businesses, summarizing the duties of each
Program component, and discussing legal issues. Plan will be finalized and distributed within KY and nationally during the first quarter of
1996.
SBO and SBAP participate in quarterly program planning meetings with Division for Air Quality.
SBAP provides information to clients on state pollution control tax exemption certificates. This exemption has traditionally been used by
multi-million dollar manufacturing businesses, but is available to any KY business.
In 11/95, SBO was contacted by the Printing Industries Association of Southern Ohio. The Association was completing training seminars
on CAAA compliance for Southern Ohio printers and was interested in sponsoring similar seminars in KY. In late November, SBO met
with representatives from the Association and three printing companies to discuss possible educational activities to be co-sponsored in
KY during 1996.
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TABLE F-3
(Continued)
Program
Accomplishments
Louisiana
LA SBAP received the "Special Achievement by a Team" award from the Secretary of the Department of Environmental Quality in
December 1995. The citation read: With the passage of the Clean Air Act Amendments of 1990, each state was required to assist smal
businesses in complying with the Act. Many small businesses do not have the expertise or the finances to comply with the regulations.
LA's SBAP has accomplished this goal in an outstanding manner. The programs is so well respected that is has been assisting other
states in developing their SBAPs. The program has also received much praise from the small businesses that is has assisted. One
business wrote, "I can't tell you how much I appreciate all the work you have done for us over the past seven months. Clearly, without
your input, I would have been unable to fulfill the requirements for compliance with the Air Quality Standards.
The Technical Assistance Group assisted the LA SBO in holding the first state Small Business Conference in New Orleans in January
1993, and cosponsored the EPA-sponsored State SBO/SBAP Conference in New Orleans in January 1995.
The Technical Assistance Group, in conjunction with the SBO, has assisted many other states in developing their SBAPs.
In 1995, SBAP assisted 141 small businesses with EIQs and permit applications and were contacted by another 1,003 small businesses
to solve other environmental problems.
Maine
SBAP recently adopted Small Business Compliance Incentives Policy based on EPA guidelines.
Maryland
No comments.
Massachusetts
MA Printers Partnership (MP2) formed. Developed self-certification statement for printers, 40 detailed questions on environmental issues
to which printers must certify their performance and a workbook explaining each of the questions and providing additional information on
compliance. Members are provided with window decals and frameable MP2 membership certificates.
Michigan
Fall 1995, Ml SBAP, also known as Clean Air Assistance Program (CAAP), presented its first set of training on the state's Renewable
Operating (RO) permit program. The training was developed and delivered by SBAP staff at 10 statewide sites for business and industry
and at one site for air quality consultants. Information was provided on Mi's RO permit program and how to complete the RO permit
application. Attendance exceeded 1,700.
In conjunction with the RO training. Mi's CAAP also presented a series of 10 statewide fall workshops for the autobody industry in
cooperation with Mi's Automotive Service Association (ASA). More than 600 attendees learned about the RO program and mechanisms
for "opting out" of the RO permit program.
Since its inception, Mi's CAAP has developed several guidance publications for businesses seeking assistance with air quality matters.
Mi's CAAP is part of a wider, multi-media agency called the Environmental Assistance Division (EAD). EAD is dedicated to providing
timely and effective information and assistance to Mi's businesses, public agencies, and the general public in understanding and meeting
their environmental protection responsibilities.
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TABLE F-3
(Continued)
Program
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
Accomplishments
MN 1995 Annual Report.
No comments.
Department of Natural Resources' Technical Assistance Program is multi-media and has assisted many small businesses in Missouri.
They have responded in a timely and professional manner. Several businesses that received assistance wrote thank you letters
commending the Technical Assistance Program for their efforts. These efforts have brought many small businesses into compliance with
environmental regulations.
U.S. Small Business Administration sent a letter thanking the SBO for assembling a guide of regulatory obstacles and recommendations
for small businesses in Montana.
SBO received numerous compliments for presentations delivered at three national environmental conferences.
SBO was selected as the Region 8 representative for the national SBO/SBAP Steering Committee. SBO helped create a small business
environmental awards program in Montana.
SBO helped create a small business environmental awards program in MT with Small Business Administration, MT Chamber of
Commerce, and MT State Pollution Prevention Program.
The program is "alive and well and will continue to grow." For a large state in area and a small program in staff, NE
quite well.
's SBAP is doing
A Strategic Plan was created for the program to provide a clear direction to activities.
Developed a multi-media "Small Business Guide" to environmental awareness.
Presentations: 1995 SBO/SBAP National Conference, 1995 (Spring) National P2 Roundtable Conference, 1995 N.H.
Conference.
Pollution Prevention
No comments.
With the assistance of a University intern (August-December 1995) from its Public Administration Program, the Air Quality Assistance
Program for Small Businesses in Albuquerque was able to develop a directory of over 100 businesses (mostly within New Mexico) that
can provide environmental service assistance to the regulated businesses community. This is especially necessary to businesses that
may require assistance beyond the scope of the SBAP.
8
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TABLE F-3
(Continued)
Program
Accomplishments
New York
Amnesty program established in NY due to persistent efforts of SBTCP. Over a year of negotiations with the regulatory agency led to
the establishment of the program, which eliminates penalties for small businesses that commit to correct violations within 120 days. For
example, an autobody shop was issued a summons by an Environmental Conservation Officer (ECO) for not having a Certificate to
Operate. The ECO was not aware of the Department's small business amnesty policy in which a source is should be given a "notice to
cure" rather than having an enforcement action initiated. The SBAP worked with Central Office legal staff to have the ECO informed of
the new policy and dismiss the case. SBAP is working with the source owner to file a letter of intent under the amnesty program and to
apply for the proposed small source exemption, since the source's annual emissions are about 100 pounds per year. The source is in
compliance with the state's surface coating regulation by using compliant coatings.
Many businesses without certificates to operate called the SBO, but were in compliance with the substantive regulations. SBO helped
businesses send "letters of intent" to the regulatory agency so that the businesses could obtain a certificate to operate.
Until recently, regulators did not consider the effects of compliance on production capacity. With the increased awareness of the
importance of maintaining jobs and protecting the environment, the CAAA assistance programs provide assistance to ensure both goals
are met. For example, an upstate surface coater was helped to comply with regulations by switching to water-based coatings. While
this switch took care of the firm's compliance problems, it created a new problem: with the use of waterborne coatings came slower
application and curing rates. To remedy this situation, the firm installed an additional spray booth to maintain previous production levels.
To complete the circle of assistance, the SBAP helped the firm prepare its application for a permit to construct the new booth. The
regulatory agency was happy, because the firm complied, and the firm was happy, because it was in compliance and maintained
production capacity.
Through SBTCP's input during the regulatory process, streamlined permitting procedures for small businesses have been incorporated
into NY's operating permit program, which will reduce costs to permit minor sources. During the rulemaking process, the regulated
community frequently is not aware of the ramifications these amendments will have on their facilities. This is the case with the
amendments NY has proposed regarding permitting regulation, for which SBTCP prepared comments. NY proposed to use the same
permit application for both major (Title V) and minor sources, which would have resulted in tremendous regulatory burden for small
businesses with no environmental benefit achieved. Through SBTCP's efforts, NY revised its proposal to include a simplified registration
process for minor sources. This reduces the permitting burden for small businesses and improves the technical assistance program by
allowing it to focus on prevention or control programs (MACT, RACT, P2). SBTCP was successful in adding exemptions to states'
permitting requirements for unregulated minor sources (batch bakery ovens and pad printing processes).
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TABLE F-3
(Continued)
Program
Accomplishments
North Carolina
Rule changes advocated by this Office have resulted in the elimination of the need for permits for several thousand small businesses
otherwise required to have a permit under North Carolina Air Quality Regulations. Small business sectors served include: gasoline service
stations, cotton gins, small grain elevators, dry cleaners, sawmills, small electric motor repair businesses, coatings, solvent cleaners,
graphic arts, emergency generators, hosiery manufacturers, and peak shaving generators.
Small businesses now regularly has a seat at the table as air rules and procedures are developed through participation by the SBO/SBAP
staff on internal Air Quality workgroups and an outside involvement workgroup.
A permit reform initiative has been undertaken in NC. The SBO was appointed to a Task Force of 10 members to make
recommendations to the Secretary of the Department of the Environment, Health, and Natural Resources and the NC General Assembly
on how to improve the environmental permit process and expand permit assistance.
North Dakota
SBO can conveniently walk across the hall and visit the Director of the Air Pollution Control Program (who also is a CAP member), SBAP
Coordinator, or any member of the Air Pollution Control Program. This arrangement is conducive for informal and frequent meetings
between the SBO and SBAP/Air Pollution Control staff.
SBO is invited to attend the Environmental Health Section Division Directors' meetings, which are held twice a month. This helps the
SBO to be aware of media program and policy developments that may have an impact on small business and provides an opportunity for
SBO to present new concepts (self-audit policy).
SBO working directly with media programs to standardize, where possible, the permit process.
SBO serves as a clearinghouse for P2 documents for the Environmental Health section.
SBO and SBAP received training from Louisiana SBAP in 1995.
Ohio
With significant funding from OH Air Quality Development Authority and OH Environmental Education Fund, SBO and SBAP cooperated
closely with Printing Industry of OH. PIO initiated "Enviroprint Ohio," which produced a self-help guide to environmentally sound printing
operations. The project is conducting a series of training sessions around the state. By the end of 1995, these sessions had reached
100 printers. Mailings also have been sent to over 2,500 printers.
Oklahoma
No comments.
Oregon
Adopted a Mission Statement and a Communications Ran. Implemented a confidential multi-faceted small business technical assistance
program. Charter member of the Portland Pollution Prevention Outreach Team. SBAP Small Business Development Center Education
Project. Small business cross-media dry cleaner "Green Sticker" project. VOC Limited Amnesty Project Charter member of WESTAR
(SBAP network group). Member national and regional pollution prevention roundtables.
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TABLE F-3
(Continued)
Program
Accomplishments
Pennsylvania
No comments.
Puerto Rico
No comments.
Rhode Island
Rl OEM's P2 program awards received include: Environmental Achievement Award from the National Environmental Awards Council,
1990; Robert Rodale National Environmental Achievement Award, 1991; Certificates of Environmental Achievement from Renew
America and National Awards Council for Environmental Sustainability, 1995.
Rl OEM's P2 program is responsible for bringing in over $900,000 in funding to help industry sectors such as autobody, fish processing,
and textiles. Also assisted state's largest POTW to set up its own P2/technical assistance program.
Ran a $700,000 grants program where 12 industries studied and/or implemented P2 techniques and technologies in their facilities.
Projects included elimination of methyl-ethyl-ketone from a chemical manufacturer and implementation of high-transfer efficiency coating
techniques in the boat-building industry.
South Carolina
No comments.
South Dakota
No comments.
Tennessee
TN Air Pollution Control Board, which has the authority to establish the program's funding level, has been complimentary of program
efforts following program update presentations. TN Association of Business complimented activities conducted by the program.
A regional business publication included a four-column article on the program
Program workshops received press coverage, including mention on the front page of a major newspaper and a front page article in the
business section.
Two state SBAPs and a foreign country representative attended program workshops.
One business owner commented after a CAA Overview workshop that the statement, "I'm the government and I'm here to help" is really
true.
Workshop evaluations indicated the participants found the workshop to be "good" to "excellent."
National teleconferences were initiated by TN on regulatory compliance for small businesses. Teleconferences targeted the first small
business industry groups regulated under CAAA, which include dry cleaners, chrome platers, and vapor degreasers.
11
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TABLE F-3
(Continued)
Program
Texas
Utah
Vermont
U.S. Virgin
Islands
Virginia
Washington
Accomplishments
Peer Match Grant ($25,000) to provide training to other states on how to set-up small business assistance programs. Leadership Grant
($93,750) to establish a simple method that enables small businesses determine true environmental cost of doing business. RCRA Grant
($44,000) to assist small businesses with the management of their hazardous waste. P2 Grant ($37,214) for proper spray booth use
and demonstration.
Preliminary results of the small business permit application Amnesty Program indicate that small businesses welcome the opportunity to
achieve compliance. Many small businesses were unaware of the Division's permit requirements and assistance available.
SBO has been actively involved with the Salt Lake Rotary Club's Environmental Committee as Vice Chair. The "Clear the Air" Awards
Program for vehicular emissions reduction was initiated in September. Through the end of 1995 during Rotary meetings, where a
standard 250 members attended, a "Clear the Air" spirit theme was introduced with informational flyers, brochures, and promotional
items.
In 12/95, 9 category award winners were selected from 27 entries in the "Clear the Air" Awards Program. Awards were based on
commitment, innovation, and leadership criterion. Lt. Governor and DEQ and DAQ Directors presented awards at a luncheon. 1996
program will expand into business emission reductions and technologies and unique pollution prevention methods.
During the past six months a closer working relationship with DAQ small business services has resulted in greater customer service
efforts. Division Director called for development of unified small business mission statement and workplan, which will track and review
activities and identify gaps and duplication in service delivery.
Vermont does not have an SBAP, however current programs of the Air Pollution Control Division have effectively assisted small business
for several years. This assistance includes free workshops for industry (e.g., Operating Permits Workshop) and occasional on-site
assistance. The staff of engineers are accessible to businesses and provide requested information on a regular basis.
No comment.
No comment.
"We try to do our stuff with cross-program, multi-media focus in mind."
12
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TABLE F-3
(Continued)
Program
West Virginia
Wisconsin
Wyoming
Accomplishments
SBAP and SBO have coordinated five periodic meetings with various other agencies and organizations providing environmental
compliance and pollution prevention assistance. These include WVDEP Pollution Prevention Services; WVDEP Waste Minimization;
Marshall University Center for Environmental, Geotechnical, and Applied Sciences; Marshall University Procurement Technical Assistance
Center; Robert C. Byrd Institute for Advanced Flexible Manufacturing; West Virginia University Industrial Extension Service; and National
Institute for Chemical Studies.
SBO has made significant progress in influencing enforcement supervisors to place a higher emphasis on considering the ability to pay for
small businesses in assessing penalties.
Wl CAP member attended the CAP training session in Pittsburgh, 10/95. Wl DOD staff member represents Region V in periodic staff
meetings via national conference calls with all 10 EPA regions. 22 publications have been created in 1995 and the program has reached
over 18,000 Wl businesses.
No comments.
-------
APPENDIX G
COMPLIANCE ASSURANCE ISSUES
-------
TABLE G-1
COMMON COMPLIANCE PROBLEMS
Compliance Problem
Not understanding regulatory requirements
Operating without a permit
Uncertain of permitting requirements
Incomplete record keeping
# Programs
22
19
17
8
% Programs
42
36
32
15
Programs Responding (by EPA Region)
Region 1: MA, ME, NH
Region 2: NY
Region 3: DC, MD
Region 4: AL, MS
Region 5: IN, Ml, OH
Region 6: AR, LA, OK
Region 7: IA, KS, MO, NE
Region 8: CO, NE
Region 10: OR, WA
Region 1: ME, NH
Region 3: MD
Region 4: GA, KY, NC, SC
Region 5: IL, IN, MN
Region 6: LA, OK, NM
Region 7: IA, KS
Region 8: CO, UT
Region 9: AZ
Region 10: OR
Region 1: ME, NH
Region 2: PR
Region 3: DC, MD
Region 4: AL, NC, TN
Region 5: IN, IL, OH
Region 6: LA, NM
Region 7: MO
Region 8: CO, UT
Region 10: WA
Region 2: NY
Region 4: GA, NC
Region 6: LA, NM, TX
Region 7: NE
Region 10: OR
-------
TABLE G-1
(Continued)
Compliance Problem
Financing for control requirements
Uncertain how to determine emission inventories
Uncertain how to complete forms
Operating outside NSPS or MACT
Improper disposal of hazardous waste
Fear of arbitrary regulatory enforcement
Overwhelmed by quantity of regulations
Lack of sufficient notification by regulatory agency
No manifest for special or hazardous waste
# Programs
5
5
4
4
4
3
2
2
1
% Programs
9
9
8
8
8
6
4
4
2
Programs Responding (by EPA Region)
Region 2: PR
Region 4: TN
Region 5: OH, Wl
Region 8: CO
Region 4: NC
Region 5: Wl
Region 6: LA
Region 8: NE
Region 10: OR
Region 2: PR
Region 4: TN
Region 7; MO
Region 9: AZ
Region 4: MS
Region 6: LA
Region 7: NM
Region 8: WY
Region 1 : MA
Region 4: AL, KY
Region 6: LA
Region 2: NY
Region 5: Wl
Region 6: AR
Region 2: NY
Region 5: Ml
Region 2: NY
Region 5: IN
Region 5: IL
-------
TABLE G-1
(Continued)
Compliance Problem
Uncertain as to which government agency to contact
Labeling of storage areas
Need for multi-media permits
# Programs
1
1
1
% Programs
2
2
2
Programs Responding (by EPA Region)
Region 5: IN
Region 1 : MA
Region 5: IN
-------
TABLE G-1
(Continued)
PROGRAM RESPONSES
Programs were asked for information on the most common compliance issues addressed during the course of providing technical assistance.
Individual program responses are listed below. Comments are edited for space.
PROGRAM
Alabama
Alaska
COMPLIANCE ISSUES
Since the assistance provided through SBO is multi-media, we tend to field many more questions on solid/hazardous waste and water
discharges than on air issues. The majority of calls received from small businesses center on whether or not they are required to have a
permit for a particular process, and if so, what their permitting options are and how to apply for a permit.
Since the hotline is open to the public to register complaints, we receive many complaints about small businesses, primarily on improper
use and disposal of chemicals, dust, odor, and noise. While some of these problems are a result of illegal activities, many are a result of
activities that are not regulated. The root cause of the unregulated activities is poor zoning or lack of zoning.
No response.
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TABLE G-1
(Continued)
Arizona
Final Cty.
Maricopa Cty.
Pima Cty. &
Tucson
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
No response.
The most pervasive "compliance" problem discovered arises from the reality that (1) permit files have traditionally lacked a comprehensive,
but concise, disclosure and analysis of facility operations and a meaningful analysis of potential emissions; (2) permits have traditionally
been meaningless bread sandwiches that contained more or less language, but no substance, and certainly no compliance regimen that
produced emission limitations that were enforceable as a practical matter; and (3) the necessary consequence was that no one could afford
to devote the effort to even figure out what a source was doing, much less whether it was in compliance with applicable requirements.
About 40% of business assistance contacts involved incorrect or incomplete permit applications. Of these, about 80% were due to lack of
knowledge. Most businesses had problems with portions of the application forms. Once they understood what was being asked or how to
prepare their data, they were able to complete the application on their own.
About 30% of businesses referred to the Business Assistance Program by enforcement section staff were operating without a permit.
Most owners did not know that air quality rules existed or that they applied to their businesses. These businesses accounted for about
15% of all business assistance contacts.
Small autobody repair facilities made up the largest portion of businesses that were operating without a permit.
Knowledge of regulations. Fear of regulatory agencies.
Since the Local Air Districts issue the permits, this is largely inapplicable at our state level.
Lack of money to implement control technology. Confusion about regulations. Lack of permits. Lack of knowledge about what is required
by law.
Unpermitted emissions. Confusion over reporting requirements. Lack of information on new requirements.
Program not in existence long enough to have this information.
Facility operations do not understand what they are required to do in order to comply. SBO concentrated on explaining the regulations to
them.
No response.
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TABLE G-1
(Continued)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Inadequate record keeping and facilities operating without permits.
No response.
We did not gather information for this question.
Unpermitted equipment in manufacturing and metal parts fabricating, operating permits and pollution control device permits for air
emissions. No manifests for hazardous and special wastes. Auto repair/air conditioning Title V not certified; some have air permits and no
land permit. Businesses need multi-media permits.
Contacting the right Agency staff regarding specific regulatory requirements. Not award of specific regulatory responsibilities (Title V,
NESHAP. MACT). Lack of adequate communications between Agency and businesses. Rules are too complex. Lack of permits for new
equipment or changes in processes. Unpermitted emissions.
Nearly all clients need to get New Source Review Permits, and many need Operating Permits or Voluntary Operating Permits. Very few are
aware that they need to comply with any requirements.
Lack of understanding of regulations. When explained in plain English, most facilities are willing to comply. There is frustration from
overworked, non-technical people who have been given the responsibility for environmental issues without proper background or training.
Some industries did not understand that a permit was required, but when explained, were willing to comply.
SBAP assisted 3 facilities that did not have construction and operating permits.
Companies operating without air permits. Improper disposal of hazardous waste. Incomplete record keeping Updating emissions.
Operating outside regulated limits. Difficulty in understanding regulations.
Businesses not knowing they were subject to certain regulations. Not understanding regulatory requirements. Not having necessary
permits. Problems are across all industry sectors.
Confusion about applicable compliance requirements. Lack of state air permits. Record keeping did not meet prescriptive requirements of
federal rules. Confusion about waste regulations.
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TABLE G-1
(Continued)
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
In general, the greatest area of non-compliance has been minor hazardous waste violations (e.g., labelling storage areas). Another
significant area is unpermitted operations and lack of permits for new equipment. Massachusetts has begun a major renovation of its
outreach and permitting activities. This "Environmental Results Project" (ERP) is designed to simplify or eliminate from permitting
requirements many of the small sources that have had problems understanding permitting requirements until now
The MP2 program (printers partnership) is the first wave of that effort and may be more process-specific than later ERP efforts will be.
However, because of its industry-specific nature and self-certification structure, it is viewed as a possible template for later ERP efforts.
We'll know more when the moratorium is completed and the project is evaluated for effectiveness. We will be looking at the percentage of
possible printers that enrolled, how many previously un-permitted sources came into the system under the program, and where possible,
quantify emission reductions from specific program facets and overall emission reductions.
Difficulty in understanding the exact requirements as stated in the regulations has led to increased efforts to publish "plain language"
summaries of the regulations in addition to their statutory language.
In Michigan, businesses must comply with a tremendous volume of government regulations on a day-to-day basis ranging from
environmental to labor force. For some businesses, this is overwhelming. The states' SBAP should be or are synthesizing these
regulations/requirements into more simple and understandable terms for such businesses. To address this issue, Michigan is in the process
of developing handbooks for specific industries (e.g., dry cleaners) that contain a comprehensive, yet simple organization of the
requirements.
MN 1995 Annual Report.
Dry Cleaning Industry: incomplete reports and operating outside of MACT.
Dry Cleaning Industry (Petroleum) NSPS: incomplete reports and operating outside NSPS.
Missouri Department of Natural Resources' Technical Assistance Program is multi-media and receives requests for all types of
environmental compliance assistance. In regard to requests for CAAA assistance, Emission Inventory Questionnaires (EIQ), construction,
and operating permit assistance ranks at the top. Many small businesses have never completed an EIQ and request our assistance. Other
requests are from facilities that were not aware they needed a construction permit before they installed their equipment and subsequently
received a "Notice of Violation" (NOV) when they were inspected by the department's air inspectors. These facilities are referred to us for
assistance in completing an application for a construction permit. Others request assistance in completing their construction permit
application before installation. The operating permit is a new requirement for MO's small businesses and they have been requesting training
and assistance in completing these applications.
Unpermitted emissions. Operating outside MACT standards. Operating outside state standards (particularly prevalent in automobile
refinishing).
Not knowing how to figure emission inventories, poor understanding of the rules and regulations, incomplete or inaccurate information.
N/A
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TABLE G-1
(Continued)
New
Hampshire
New Jersey
New Mexico
Bernalillo Cty.
New York
North Carolina
North Dakota
Lack of a formal system for assuring regulatory compliance or exemption. Lack of information on how to comply with new regulations.
Lack of evaluation of the potential impact of operations on the general public or the environment. Lack of permits to limit PTE.
No response.
The most common compliance problem identified of facilities subject to MACT are incomplete reports and incomplete paper work.
Operating without a construction permit is the most common compliance problem for sources not subject to MAC! standard.
For MACT standards, common problem is lack of information and therefore incomplete reporting/recordkeepmg.
Other compliance problems involve general lack of information and knowledge of local air regulations involving registration or permitting of
sources.
Problems are consistent across all industry sectors. Not having an operating permit for air contamination sources. Not understanding
requirements of an operating permit. Not maintaining records to document emissions. Not being aware of environmental requirements at
state, federal, and local levels. Lack of sufficient notification of businesses by regulatory agency. Difficulty of small businesses in
obtaining a clear and straightforward answer from regulatory agency about what is needed to achieve compliance. Small businesses are
frequently not able to get answers from regulatory agencies; many times access is limited because telephone lines are constantly busy, and
if able to get through, regulatory staff often do not return calls. Businesses fear that by talking to regulators, this will cause their facilities
to be targeted for additional scrutiny; some companies voluntarily approaching regulatory agencies then are penalized, while other
companies that do not come into compliance are overlooked by the agency. Regulatory flexibility not available for special conditions
including small emitters and companies manufacturing specialty products. Permit applications are complicated and there is a long lag time
from applying to receiving permits. Businesses are frustrated by the multiple layers of regulatory requirements. Businesses frequently are
under the impression that if the apply for and are issued one permit, then they are in compliance with all requirements.
Unpermitted facilities. Confusion about whether an air quality permit is required. Lack of technical expertise to identify air pollutants,
emission sources or points, and calculating emissions.
NC Air Quality Section has about 4,000 permitted facilities in North Carolina. The number of facilities not complying with air quality
regulations is unknown.
The most common problem is small businesses understanding the regulations, which should be written in a manner that is much easier to
understand. EPA should change their "once in - always in" policy for MACT standards.
-------
TABLE G-1
(Continued)
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
The single most common "compliance problem" identified to the SBO is inability to understand the regulations or rules and how they apply
to a particular business. This lack of "plain English" explanations is a problem with both federal and state programs The second most
frequent problem is determining how to pay the costs of compliance.
SBAP experience identifies the following: lack of permits, misunderstanding permit application forms, and lack of awareness of air pollution
regulations. These problems are common to all industry sectors.
The most notable compliance problem that has been observed is those facilities that need an air quality permit and do not have one. Up to
this point, most facilities out of compliance with permitting need a state permit. However, with recent final interim approval of our state's
Part 70 program, there are an increasing number of facilities that are in need of Title V permits or at least synthetic minor (state) permits.
Secondly would simply be the ignorance of the small business community regarding air quality regulatory issues. NIESHAP vs. NSPS vs.
Title V vs. state requirements vs. federal requirements. They don't even begin to know how to talk the language, make their way through
the complex flow chart of decisions that need to be made, and where they are trying to go.
Don't understand regulations. Don't keep accurate records. Don't practice P2. Have not calculated emissions. Operating without a
permit. Don't understand cross-media emissions transfer. Lack of knowledge of alternative technologies.
No response.
Submitting permit applications with the required documents including evidence of Planning Board permits. Efficient control equipment for
businesses at low cost.
The most common compliance issue has been the reduction of emissions to bring companies under emissions caps. A small number of
facilities have approached us with specific process problems.
Unpermitted emissions. Permits for new equipment or process changes.
South Dakota has not experienced a compliance problem.
Not understanding how to complete forms. Not understanding required controls (dry cleaners). Uncertain of permit requirements,
particularly for process change. Understanding which government agency to contact. Financing for control requirements.
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TABLE G-1
(Continued)
Texas
Concern about leasing property to printers, dry cleaners, gas stations, etc. that might generate toxic or hazardous waste. Lack of funds to
purchase compliance equipment. Lack of awareness of environmental regulations (i.e., do not know generator status). Lack of guidance
for classification as either an industrial or non-industrial generator.
Dry Cleaners: Lack of funds to purchase equipment. Soil contamination clean-up problems related to the uniform standards established
under RCRA. States need flexibility to assess the risks associated with each site rather than imposing universal clean-up standards for all
sites.
Printers: New inks and solvents may not be compatible with existing equipment; would be expensive to replace.
Metal Finishers: Lack of funds for pollution abatement equipment. Unable to get stacks tested. Recordkeeping and storage for hazardous
waste.
Autobody Shops: Unable to meet wipe-down solution standards.
product available is 6.2 pounds.
The allowable pounds VOC per gallon is 1.4. The VOCs per gallon of
Gas Stations: Lack of funds for control equipment. Soil contamination from leaking petroleum storage tanks TX is prohibited from
offering extensions for installation of stage II equipment at some small gas stations due to the definition of an Independent Small Business
Marketer of Gasoline as defined in the CAAA.
Thermoset Resin: Nuisance odors.
Utah
Stack Testing and Control Equipment Requirements: Several small businesses that are subject to hard chromium electroplating emissions
limitations have expressed concern about complying with the stack testing and control equipment requirements. Many such facility owners
are concerned, since they use less than 10 pounds of chrome annually.
Basic Permit Information Simplification Needs: Due to regulatory complexities, many small businesses lack knowledge or the terminology to
comprehend permitting requirements and do not obtain necessary permits (e.g., wood furniture coating, foundries, and chromium
electroplater industries). Businesses experience difficulty in understanding how to complete inventory sheets, read MSDSs, or determine
when permits are required due to process change or expansion. Simplification of this information would be helpful in providing compliance
opportunities where none seem present. This became apparent when conducting a targeted industry outreach effort with the printing
industry, yet this is a common issue.
Continued Technical Support Needs: Often, small businesses lack necessary equipment and expertise to perform monitoring requirements
for MACT standards and the state air quality permits.
Vermont
No response.
10
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TABLE G-1
(Continued)
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
VA's compliance assistance efforts have been primarily directed at the source categories coming under regulation by the Maximum
Achievable Control Technology (MACT) standards. The most common problem has been the difficulty of the foreign national ownership ot
the dry cleaners to fully grasp what information was necessary on the initial notification report form and the pollution prevention
compliance report form. In particular, the most difficult concept has been that of the twelve month rolling average A great deal of time
has been spent coaching the dry cleaners in the correct preparation of the necessary compliance forms.
With respect to the small businesses that have had some form of regulatory responsibility, the most common difficulty has been their lack
of knowledge that they were a regulated entity and consequently operating without a permit. This situation has not arisen too many times
yet, but as we begin to expand the compliance outreach efforts to printers, wood finishers, and other solvent users, it is expected that the
size of this problem will increase.
No response.
Complexity of regulations.
For new requirements, such as MACT, businesses either have not been aware of the rule or do not know the specific requirements. We
have many clients who were apparently unaware of state requirements that have existed for many years. Some confusion may arise due
to changing agency policy and focuses over the long term. Generally, companies that have some level of environmental awareness are
primarily concerned about solid and hazardous waste issues where long-term liability may become a major exposure.
Cost of new equipment or modifications required by environmental regulation. Concerns about the amount of time required to prepare
permits or record keeping. Fear that regulatory enforcement will be arbitrary and capricious. Difficulty in completing required mathematical
calculations to determine MTE and PTE.
Understanding MACT standards by dry cleaning businesses. Understanding MSDS sheets by solvent/degreaser businesses. Applicability of
CFC regulations by auto wrecking yards.
11
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TABLE G-2
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Improvements
More open communication between sources and
regulatory agencies
Increased compliance
Greater understanding of the regulations
# Programs
26
23
20
% Programs
49
43
38
Programs Responding (by EPA Region)
Region 1: NH, Rl
Region 2: NY, VI
Region 4: AL, KY, SC, TN
Region 5: IL, IN, Ml, MN, OH
Region 6: AR, NM, OK, TX
Region 7: MO, NE
Region 8: CO, UT, WY
Region 9: AZ, CA
Region 10: OR, WA
Region 1: MA, ME, Rl
Region 2: NY, VI
Region 4: AL, NC, TN, SC
Region 5: IL, IN, Wl
Region 6: OK, TX
Region 7: IA
Region 8: CO, ND, SD, WY
Region 9: AZ, CA
Region 10: OR, WA
Region 1: MA, NH
Region 2: NY, VI
Region 3: MD
Region 4: KY, NC, TN
Region 5: IN, Wl
Region 6: NM
Region 7: IA, NE
Region 8: CO, ND, SD, UT
Region 9: AZ, CA
Region 10: WA
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TABLE G-2
(Continued)
Improvements
Reduced apprehension regarding environmental
compliance
Improved attitudes about complying with regulations
Inclusion of environmental compliance early in business
plans
Increased registration and permitting of existing
sources
# Programs
18
17
9
5
% Programs
34
32
17
9
Programs Responding (by EPA Region)
Region 1: NH
Region 2: NY, VI
Region 4: AL, KY, SC
Region 5: IL, IN, Ml, OH
Region 6: AR, OK
Region 7: MO, NE
Region 8: CO, WY
Region 9: AZ
Region 10: WA
Region 1: NH, Rl
Region 2: NY, VI
Region 4: AL, SC
Region 5: IN, Ml, OH
Region 6: OK, NM
Region 7: NE
Region 8: CO, UT, WY
Region 9: AZ, CA
Region 2: VI
Region 3: DC
Region 4: TN
Region 5: Ml, MN, Wl
Region 6: NM
Region 9: CA
Region 10: OR
Region 3: MD
Region 4: NC
Region 5: Wl
Region 6: MN
Region 8: ND
-------
TABLE G-2
(Continued)
Improvements
Better record keeping
Improvement in pollution prevention management
practices
Greater environmental understanding through on-site
visits (versus phone calls or mailings)
Recycling and reuse
Better hazardous waste disposal
# Programs
5
5
3
1
1
% Programs
9
9
6
2
2
Programs Responding (by EPA Region)
Region 2: NY
Region 3: MD
Region 4: NC
Region 7: IA, NE
Region 3: DC
Region 5: MN
Region 6: NM
Region 10: OR, WA
Region 1 : MA, ME
Region 5: OH
Region 6: NM
Region 6: NM
-------
TABLE G-2
(Continued)
PROGRAM RESPONSES
Programs were asked for information on the improvements in regulatory understanding and compliance.
below. Comments are edited for space.
Individual program responses are listed
PROGRAM
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Alabama
More small business people are calling early on in the planning process of a new business or facility expansion to find out what
environmental regulations apply and what permits are needed. This allows them to better factor in the costs and time requirements of
starting the new operation and avoid "surprises."
Alaska
No response.
-------
TABLE G-2
(Continued)
Arizona
Final Cty.
Maricopa Cty.
Pima Cty. &
Tucson
No response.
Our "compliance assistance" constitutes an integral element of day-to-day permitting and inspection activities Our permit reviews and
permit documents have hopefully improved to the extent that they enable meaningful compliance reports and meaningful inspections.
Accordingly, we can offer far better assurance that sources are in compliance. (That doesn't mean they weren't in compliance earlier, just
that we had no way to formulate a meaningful opinion as to what situation existed.)
The department's education program, consisting of seminars, publications, site visits, etc. has begun to impact a large percentage of the
entire small business community. Evidence of this is shown through the increased awareness of environmental concerns, primarily air and
waste, articulated by small business owners during their contacts with staff.
There has been a steady increase in the number of businesses seeking assistance. It is believed that business assistance activities have
helped owners overcome the normal reluctance to seek assistance from the department. Additionally, business owners have acknowledged
a change in the department's approach toward sincerely helping businesses find workable environmental solutions before pursuing
enforcement actions. Business assistance activities, including outreach and education, help business owners overcome misconceptions and
difficulties attributed to environmental rules and regulations.
A noted improvement is the effect one successful site visit has on other members of a particular business sector. For example, timely and
accurate assistance provided to one print shop, without the feared follow-up enforcement visit so many owners anticipate, generated
several calls for assistance within the following weeks. This is an effective public relations tool among small business owners.
The trust and respect developed between the business owner and staff person help foster a frank and open dialogue. In turn, the business
owner is more prone to contact the department when he/she has a problem, because they no longer fear retribution. Instead, they know
the department will help them find workable solutions to their environmental concerns.
Arkansas
The regulatory agency is being perceived as less enforcement-oriented and more helpful.
California
The many publications (with CA's Annual Report) and their wide distribution has greatly increased awareness of regulatory requirements
and who to contact to get help. Accordingly, the number of contacts has increased significantly. Our education efforts have resulted in
significant improvements in self-compliance.
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TABLE G-2
(Continued)
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
In the industries with active trade organizations, the level of awareness has greatly improved, along with the level of voluntary compliance
These industries include dry cleaners, auto body shops, and printers.
More sources are willing to seek information and assistance from a regulatory agency. More small businesses involved and informed about
the regulatory developments.
No response.
Better understanding of what the priorities are in preventing pollution in their work place and how to avoid compliance actions.
No response.
This is an area that we have not tracked.
No response.
We did not gather information for this question.
Small businesses are much more likely to call if they even have a remote idea that they may be doing something wrong or need a permit
they don't have. Their apprehension regarding environmental regulation and pursuing assistance has been drastically reduced by continual
interaction between our program and small business.
Trust level between Agency and businesses has improved significantly. Communication between Agency and businesses have improved
significantly. Businesses are more willing to contact Agency personnel for guidance and for clarification on specific issues. Businesses
expresses willingness to comply with regulations as long as they understand what is required of them. Compliance among businesses have
improved. Businesses expressed appreciation for Agency outreach and education efforts.
For companies that use targeted processes, such as spray painting, it has been significant. Nearly all autobody shops in the state are now
aware that permits are required and about 500 have been introduced to the state permit-by-rule option. This has resulted in about 500 less
permit applications that need to be processed. An improvement in compliance exists as a direct result of on-site activities because clients
are provided with assistance until they are in compliance or until they choose to remail out of compliance.
Although difficult to quantify, SBO outreach efforts to a broad spectrum audience - local community leaders, statewide associations,
individuals, and professionals -- have resulted in increased awareness of the IAEAP and the resources available to small businesses. SBO
has provided important one-on-one contacts that have provided valuable information to those who were previously unaware of their
compliance requirements under CAAA.
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TABLE G-2
(Continued)
Kansas
Businesses are often fearful of regulatory agencies. When assistance is offered by university staff (through the technical assistance
contract), free of charge, businesses are grateful for the help. The technical assistance component sends follow-up surveys on six month
schedules to note if changes have been made. In most cases, recommended improvements were made.
Most businesses want to comply with environmental regulations. They may be afraid to ask questions, but when a nonthreatening
assistance program is available, they are most anxious to take advantage of the services.
SBO receives many calls asking about needed changes and how to get information without fear of enforcement actions. Through the
technical assistance program, improvements are made and businesses come into compliance voluntarily.
Kentucky
The program has resulted in submission of better quality permit applications and regulatory information to the Division for Air Quality. This
has led to a shorter review time, improving the relationship between the Division and small businesses. The information provided to small
businesses by the SBAP staff has increased awareness of the Division's role in environmental regulation. Through meetings, presentations,
and her monthly column, the SBO is building a good working relationship with state trade associations. The monthly column is published in
9 state trade association newsletters with a circulation of 15,000.
Louisiana
Improvement in "paperwork" compliance. Better hazardous waste disposal. Changes to low solvent paints. Recycling/reusing solvents.
Proposed sandblasting rules were put aside, however, permits using criteria and shipbuilders still want to discuss. Many new contacts
come to us from referrals.
Maine
There is a definite rise in compliance among the industry sectors we have targeted. Until the businesses were notified by the SBTAP, the
vast majority had no idea they were even regulated. After initial notification, hundreds of businesses call on the "800" number to ask
questions. When we are done with the conversation, the businesses understand the rule. Several on-site visits have led to quantifiable
reductions in the use of chlorinated solvents.
Maryland
There is a definite increase in awareness of federal compliance requirements in targeted industry sectors. We get calls for specific
questions from businesses that heard about the requirements from another business that attended a seminar. It is impossible to document
improvement in compliance without the resources to perform site audits before and after outreach projects.
Massachusetts
Making a correlation between those companies that received on-site visits and the increased degree of environmental understanding is
easy. Now that we have some staff resources, this information will be tracked. It is not as easy to get the same level of confidence from
companies with whom the only contact is a workshop or phone conversation. We are looking for improved tracking mechanisms to put in
place this year to show a significant improvement in 1996.
Michigan
The Environmental Assistance Division (EAD), which houses the Ml Clean Air Assistance Program (CAAP), also has an Environmental
Assistance Center (EAC). EAC provides a single point of access for inquiries related to environmental issues. The availability of EAC to the
CAAP, the development of guidance publications, and the delivery of workshops by the CAAP has resulted in a better working relationship
between EAD, the regulatory agency (Ml Air Quality Division), and the regulated community. For example, there is more professionalism
and respect by all, and this relationship has helped to eliminate such government stereotypes as the "typical, uncaring, bureaucratic" or a
preconceived stereotype of industry as having a "lack of concern for (the state's) natural resources."
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Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New
Hampshire
New Jersey
Many businesses calling the program for help. Awareness that assistance is available and is being used and appreciated Many stating
that they now have awareness and general understanding of environmental responsibility. Many have now applied for permits. Many are
now in compliance with NESHAPs and reports are coming in on time. From understanding the regulations due to SBAP assistance, many
small businesses are changing processes, equipment, and materials to get out of permitting and/or NESHAPs.
No statistics available at this time.
We have some anecdotal information in the form of individuals thanking us for the assistance provided. Sometimes this comes in the form
of a "thank you" letter written directly to us or to others in the department with whom they are dealing. Other forms have come verbally
from the individuals telling us how much they appreciated our assistance or when they refer other businesses to us. We currently are
working on a method to track these activities, however, we presently do not have our database structured to include this information.
The most notable improvements in compliance have been a result in on-site visits. Many of the businesses visited by the SBAP were not
aware of regulations or pollution prevention opportunities and were eager to be given a chance to comply without the threat of
enforcement action.
Seminars and publications have proven to be less valuable than site visits. SBAP found it more difficult to establish relationships with small
businesses through these tools than with direct personal contact. This is especially important in a state where many small business owners
are independent-minded and distrustful of government.
The toll-free hotline is a tool that has worked very well for SBAP. Much of the initial contact between the SBAP and small business owners
is initiated at this level. SBAP often makes telephone contact several times with a small business before it is invited to make a site visit.
A stronger understanding of the need to control emissions, development of better bookkeeping methods, and more willing to allow P2
opportunities to be discussed.
N/A
Businesses have been very supportive of the non-regulatory nature of the program. The ability to talk to someone who has a full
understanding of regulations and can assist in compliance is constantly mentioned. Once explained, regulatory requirements are usually
complied with in a reasonable time frame. The animosity created through enforcement is eliminated, which has improved communication
dramatically.
No response.
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(Continued)
New Mexico
Bernalillo Cty.
Small businesses have a better understanding of the air quality regulations that apply to them, and the technical support provided by the
SBAP has improved the attitude of some business persons about complying with the regulations. Pollution prevention information has
helped small business reduce pollution and save money. As a result of our assistance, six businesses were able to identify potential
pollution problems in other media and seek help. SBAP also gave presentations to the employees of small business, and their improved
understanding of regulations and how P2 reduces their personal exposure to air toxics resulted in positive behavioral changes.
The regulated business community that has contact with the SBAP has a much better understanding of the air issues affecting businesses
and therefore more interest in the regulations that affect them. There has been an increase in the registration/permitting of existing
sources within Albuquerque/Bernalillo County.
New York
SBTCP notifies and explains to small businesses the requirements. For example, (1) need to have operating permits (businesses previously
without permits are applying for permits); (2) need to maintain records to verify the facility's compliance status; (3) explains available
compliance options such as capping, reformulation, control equipment, and P2 -- businesses making informed choices; (4) need to maintain
updated information because of ever-changing requirements; (5) serves as advocate of small business interest - businesses being helped
through government maze and serves as voice of businesses in rulemaking, etc.
Word-of-mouth recommendations - business-to-business that SBTCP is a source of information that is knowledgeable, approachable, able
to cut through maze of bureaucracy, and trustworthy.
SBTCP helps small businesses understand what the requirements are and how they apply to their operations/facilities and what methods or
alternatives are available to achieve voluntary compliance. Companies understand that they must look at their facility holistically to work
toward achieving compliance.
SBTCP plays an important role in helping regulator to understand the value and needs for compliance assistance in conjunction with an
enforcement element rather than solely an enforcement/penalties approach to achieving compliance. SBTCP serves to enlighten the
regulatory group's negative way of thinking about businesses, that not all businesses are "bad guys wanting to pull something over on
them." Contrary to the expectations of many regulators, SBTCP's experience is that most businesses are willing to voluntarily comply with
requirements so long as they are aware what the requirements are, how the requirements apply to them, and receive compliance
assistance.
North Carolina
Improvements in understanding has resulted from small businesses learning what is required and how to complete forms. The confidential
policy of this office has encouraged businesses to ask if they need a permit or what requirements apply. As businesses find out what is
expected of them, their compliance increases. Record keeping still is a great burden for small businesses. Simplifying the requirements and
simple explanation of the requirements is the biggest boost to compliance.
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(Continued)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
It is difficult to assess environmental improvement or compliance improvement that may have resulted from the SBO or SBAP assistance
However, any assistance provided surely make it easier for business to comply, and that was the primary intent of Congress in mandating
the states to establish SBTCPs.
With regard to dry cleaners, the state has a 95% success rate in receiving initial reports from regulated sources. This success rate can be
directly attributed to the SBAP.
From the perspective of SBO, the most important advance is an increase in the number of businesses willing to ask for help. Although the
number is still small, it is building a clear track record for the program.
SBAP experience has been exceedingly positive in relation to its on-site visits. The opportunity for a business to have "an inspector's eyes"
visit the plant or shop without fear of penalty has resulted in businesses acting quickly to resolve any problems there may be.
It is important to stress that businesses are asking for help because they want to be in compliance with environmental regulations, but have
been afraid to look closely for fear of what they might find. This fear is very rarely based upon actual personal bad experiences with the
regulating agency; more often, it is based on "industry legend" stories about what happened to a similar operation. The businesses visited
to date are pleasantly surprised that they have stumbled upon a government program that can be of immediate and direct benefit to them.
We have not formally tracked this. However, from the feedback that we have received on various fronts, there has been a change in the
perception of our Agency's willingness to provide assistance as a means to achieving compliance - and that it works!
There is a greater awareness of costs associated with discharging pollutants to the environment in some industrial sectors. Several small
businesses have replaced solvent cleaning (e.g., vapor degreasers) with aqueous cleaning systems. There is a growing awareness of
liabilities associated with improper waste management and costs associated with less efficient technologies. A dry cleaning business
converted to a citrus cleaning technology. Another converted from perc cleaning to a new dry-to-dry machine that uses Exxon-2000
cleaning solvent. Several wood surface coaters have converted to water-based coatings. Powder coating systems are becoming more
prevalent to avoid MACT, GACT, and worker safety regulations.
No response.
Distrust in SBAP because of the link we have with the regulatory office.
Overall outreach, communication, and availability of SBO and technical assistance services are having a positive impact on behavior and
environmental compliance.
Reduced fear and suspicion of outreach efforts. Increased compliance by previously unpermitted sources.
The department's technical assistance activities have helped small businesses understand and comply with new federal requirements.
10
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(Continued)
Tennessee Program assistance has resulted in 75 + % regulatory response compliance rate for new MACT standard-impacted companies. Program
evaluations indicated workshop participants had a greater understanding of regulations. Businesses have expressed interests in ensuring
compliance in all areas of their businesses that may impact the environment.
Texas
Compliance visits resulted in the following increase in complying with regulations.
• Spray booths: 3% increase (from 90% to 93%)
• Gun cleaners: 6% increase (from 82% to 88%)
• HVLP guns: 5% increase (from 92% to 97%)
• Prep areas: 14% increase (from 73% to 87%)
• Low VOC solvents and paints: 32% increase (from 36% to 68%)
• Stack: 31 % increase (from 62% to 93%)
Compliance was measured at the beginning of the site visit using checklists, and compliance again was measured after the visit.
SBAP reached 1,792 dry cleaners. Of this, 95%, or 1,697 sent their registration forms to EPA.
TNRCC received 831 Standard Exemption 124 registration forms.
Utah
Businesses are often responsive once they believe they are safe and supported. The addition of VAP on-site evaluations has added a new
level of interest and responsiveness. It seems that if a business has a positive experience with such a service, they are more eager to
provide encouragement for other businesses. The VAP services have been a valuable extension of SBAP service, where initial participation
in VAP services was through SBAP referrals. Obviously on-site support provides a great deal of awareness and understanding of the
reasoning and methods for regulatory compliance. Businesses are also becoming increasingly interested in P2 opportunities - especially the
benefits of reduced emissions, costs, and regulatory requirements.
The Amnesty Program provided a great "window of opportunity" for many businesses. Additionally, many businesses discovered that,
although they did not require permits at current operating levels, future modifications may require the need for a permit and that they might
incorporate P2 techniques in existing processes to avoid greater regulatory costs in the future.
The establishment of the Small Business Advisory Committee was a major highlight in providing a forum for exploring opportunities to
improve relations and create a positive influence in the business community. The Committee's energy and enthusiasm has been most
refreshing and insightful and has built a stronger foundation for trust between government and industry.
Vermont
No response.
1 1
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Virginia
There is definitely a relationship of compliance assistance activity to the awareness of the regulated or newly regulated community. We
saw with the dry cleaners in 1994 that their acceptance of responsibility to comply with regulation was a direct result of their
understanding of the requirements, the costs, the benefits of compliance, and the fact there was a willing party (SBAP) to provide
infirmation and assistance. The initial results of the June 18, 1994 deadline for initial notification reports was met by 73% of the state s
dry cleaners. Cooperation between the state and interested trade associations was a great benefit in ensuring wide coverage approaching
200 facilities. The outgrowth of the workshop activity yielded months in which telephone assistance approached 100 calls per month for a
short period.
A large part of the success of any outreach assistance are the materials used and delivery of the message, which have to be geared to the
audience. With the dry cleaners, EPA's efforts with language was a great help. Development of very basic grade level materials also
helped make the job easier. Finally, the necessity to reach understanding and parity between the compliance/enforcement activities and
the SBAP is crucial to assuring the small business that the end result is compliance and improvement of the environment.
Regulations geared toward a less defined universe such as the halogenated solvent MACT are less likely to achieve the same results.
Identification of the source universe becomes a major problem, and communication becomes difficult because of physical resources of the
SBAP to provide coverage to a potential universe in the 1,000s. However, any success breeds success and more activity. Thus, the
credibility of the SBAP and the ability to use the 507 Enforcement Policy is critical to the continuing success of the compliance assistance
activity.
Virgin Islands
No response.
Washington
Better understanding of regulations and multi-media interactions.
communication between sources and agency.
Improvement in P2 oriented management practices. More open
West Virginia
Region III inspection of dry cleaners in WV has detected no significant deficiencies in complying with MACT requirements. WV chrome
electroplaters achieved a high compliance level for initial notification to Region III. The overwhelming majority of businesses we have
worked with are cooperative and seem willing to address air quality issues, but need guidance on requirements and practical methods of
compliance. However, because of the many other business demands, companies often need more than a one-time assistance effort.
Follow-up and routine reminders help ensure that the business actually accomplished the objectives. This level of monitoring is time-
intensive, but should be continued until the specific goal is achieved or it becomes clear that the business is not sincere in complying with
requirements.
Wisconsin
As a result of Wl's SBO and SBAP technical assistance activities, we have seen more businesses submit initial notifications to DNR than
we would have expected without our outreach efforts. The level of understanding by individual businesses seems to be increasing. We
have seen an increase in the number of calls for assistance over the last year. Inquiries are getting more focused. Rather than just
knowing whether a regulation affects them, businesses want to know how to comply. Small business is better informed by our program,
because outreach efforts are reaching them, and our materials and presentations are clear and understandable.
12
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(Continued)
Wyoming No objective information or data are available to evaluate any improvements made in compliance by small businesses, although a number of
businesses have orally expressed their appreciation for the assistance provided by SBAP However, communication is being established
between the SBAP and various businesses that can only lead to an improvement in compliance. Small businesses are under a heavy burden
of federal and state requirements, and a knowledgeable SBAP can make appropriate referrals while improving the relationship.
13
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TABLE G 3
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
RECOMMENDATION
Program
AZ
AR
IA
KY
MN
NE
NH
NY
NC
ND
SC
Institute Multi-Media Pollution Control Efforts
Adopt an industry-specific multi-media approach to regulation and compliance assistance.
Regulate business by industry sector, not media ("one-stop shopping") and not by revising individual acts (i.e., CAA,
CWA, SDWA).
Mandate with appropriate funding true multi-media compliance assistance programs.
Consolidate all environmental reporting and recordkeeping into a single form with an electronic format, due annually and
available to all agencies.
Expanding the focus of small business assistance to all media is necessary.
Pass federal legislation to broaden the role of the SBO to encompass all forms of pollution.
Funding should be made available to provide multi-media assistance to small businesses.
Many small businesses (especially industry or sector groups) would benefit from a multi-media industry-specific assistance
and compliance initiatives (assistance, inspections, reports, fees, P2, etc.).
Make the SBAPs multi-media.
Should work to have programs multi-media through legislation with appropriate funding mechanisms.
appreciate "full service" for environmental compliance assistance.
Make outreach and assistance multi-media. More than air regulations need to be addressed by small
need help complying with all environmental regulations.
Environmental information and assistance should be multi-media. Small businesses find it difficult to
need to deal with multiple agencies.
Most businesses
businesses, and they
understand why they
Allow states to use their funding in multi-media pollution control assistance and not restrict use of funding to solely air
pollution control assistance.
Multi-media efforts would allow compliance assistance with overlapping regulations.
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(Continued)
RECOMMENDATION
UT
Many small businesses that seek SBTCP assistance request multi-media support and assistance. Utah's SBAP receives
numerous requests to establish a "one-stop" regulatory assistance center.
VT
The existing Air Pollution Control Division adequately addresses small business needs regarding air pollution issues.
Vermont needs one office where small business owners/operators can call for assistance with all types of pollution
problems. This office could serve as a "one-stop" information warehouse. Problems deemed unsolvable at this level
could be directed to the appropriate division in the Department of Environmental Conservation.
Wl
SBTCPs should have multi-media authority, not just for the CAA, but for CWA, RCRA, and CERCLA as well. Many small
businesses have remediation and other types of problems for which they need assistance.
DC
MD
NE
Increase / Ensure Adequate Funding for All Small Business Assistance Programs
Increased funding.
IA Ensure continued adequate funding for small business technical assistance programs.
Funding of the SBO needs to be guaranteed.
LA The problem of financial assistance for the Small Business Assistance Group needs to be addressed
Fund the appointment by EPA of a full-time technical director responsible to the state technical groups, since small
businesses emit over half of the air pollutants in the U.S.
Give more resources to the federal SBAP instead of the SBO.
MA No federal or state funds have been received for SBAP operations, although this funding was established in the 11/92 SIP
revisions.
At the federal level, it would it would be helpful to have a memo specifically dealing with funding SBAP activities
circulated to the regions and states. It should indicate unequivocally the source of SBAP funding and perhaps link it to
other operational funds provided to states for implementation of Title V activities.
Provide federal funds to allow a local EPA representative in each state.
NH
Increase direct funding to state programs for increased on-site assistance efforts.
Maintain funding for national MACT satellite conferences for new MACT standards.
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(Continued)
RECOMMENDATION
OH
State programs could benefit from federal funds to support this federally mandated activity. It is particularly problematic
that the mandated revenue source (Title V permit fees) are paid by businesses that are excluded from receiving
assistance.
EPA assistance for the SBO and other technical assistance has been excellent to date. However, it is clear that lack of
adequate funding for this effort has placed restraints on EPA's ability to provide timely and adequate assistance to 50 +
state programs.
Increase grant funding to undertake R & D and the development of technical resources.
TN
Provide a meaningful direct appropriation to the EPA Small Business Ombudsman to be shared with state SBTCPs for
outreach activities and education on behalf of small business voluntary compliance initiatives.
Wl
Provide more funding for the EPA Ombudsman's Office. The staff is too small to participate in a multi-media approach.
This could also be fully delegated to the states, thereby reducing the need for more funding.
Utilize the Internet and Other Electronic Resources for Information Exchange
CO
DC
NM
NY
OR
Encourage EPA to add additional information on the internet.
Electronic media.
Create and maintain a home page on the internet by the Small
electronically share documents such as newsletters, brochures
Business Ombudsmen's Office so that states can
, and other publications.
SBTCP should make information available on the internet.
Work with state SBAP's to develop an easy-to-use electronic technical assistance tracking database.
Expand National Advertising to Increase Program Exposure
IL
Expanded national media advertising campaigns produced at the federal level.
IA
The federal level needs to expand its national media efforts/campaign.
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(Continued)
RECOMMENDATION
Provide / Facilitate Acquisition of Generic Outreach and Training Materials
CA
Provide free downlink locations for participating in training.
IA
NV
Develop campaigns at the federal level in several media that can be used by state SBOs.
Ml Provide grant money to state SBTCPs to develop and utilize innovative ways to distribute program content and services to
various industry sectors, a type of "back door" approach to outreach and education for the small business workforce. For
example, a federal or state grant would allow a SBTCP to work with federal and state government, business and industry,
and statewide educational institutions to coordinate and package environmental compliance and pollution prevention
information that is specific to industry sectors. The information could be introduced to students at the secondary or post-
secondary level so that by the time he/she enters the workforce, he/she will bring timely, relevant, and useful
knowledge/experience to specific industry and business.
Expand the services of the national clearinghouse for SBAP information and activities.
NY
Rl
Industry sector guidebooks on environmental compliance should be made available.
OR The EPA-sponsored national teleconferences through the University of Tennessee were a cost effective means of
information transfer. Similar training related to other industry sectors (printing, furniture coating,) is needed.
Develop 30-minute training videos.
Offer a national teleconference on small business cross-media pollution prevention.
Offer a national teleconference on small business environmental auditing for SBAPs, CAPs, environmental consultants,
and small business.
Develop a small business environmental cost accounting course.
Additional outreach and training materials, for example, industry-specific fact sheets.
WA EPA can best be of assistance to SBTCPs by providing generic outreach and training materials, e.g., funding MACT-
related video conferences and related manuals. SBAP and local agencies are best suited to coordinating distribution of
outreach tailored to emphasize state/local concerns and integrate with other media issues (i.e. hazardous waste and water
quality). _^___
Wl Provide case studies illustrating an actual achievement of compliance for minimal cost via pollution prevention and waste
minimization efforts.
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RECOMMENDATION
Establish Mechanisms to Finance Environmental Compliance Equipment
IN
MT
NM
Establish a compliance assistance grants program similar to that of the pollution prevention grants program.
Ml Provide grants or low interest loans (under the administration of the SBTCPs only) for small and medium-sized businesses
for access to design engineers for modifications of current facility processes and control equipment to reduce air
emissions.
MN Seek more financial assistance funding and/or tax incentives/exemptions for small businesses who are making process or
equipment changes that will demonstrate environmental improvement.
MS A federal grant program for small businesses to purchase control equipment or services in complying with the CAAA
would be a great asset for small business.
Provide federal funds to state SBAPs to start revolving loan programs for small business environmental problems.
NV Establish a revolving loan program similar to the program started in the 1980s for small wastewater treatment plants
(State Revolving Fund-SRF).
National loan program for small businesses to help purchase new pollution control or pollution prevention equipment.
NY
OR
Provide a mechanism for small businesses to finance environmental compliance equipment.
OH Additional federal financing assistance would be important, either in the form of funds available for loan and grant
programs or in the form of tax incentives targeted at small business Clean Air Act compliance (tax credits, earmarked
deductions, or tax exempt financing).
Institute a national revolving fund to finance small business compliance and technology conversion projects.
UT
The creation of low interest revolving loan programs would greatly enhance CAAA compliance and SBTCP services.
VA
DC
Creation of a revolving loan fund by the SBA for small business compliance assistance.
Expand / Facilitate Effective Communication Between State and Federal Agencies
Effective cooperation.
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TABLE G 3
(Continued)
LA
CA
KS
RECOMMENDATION
IA Continue and expand communication between states and federal agencies that address specific CAAA compliance
obligations.
Improve/initiate technical guidance and communication from the technical arm of EPA, not just the Ombudsmen's office.
TX Develop formal process for input from SBAPs on proposed EPA policies/rules. Also provide an opportunity to gather
information from network of small businesses throughout the U.S.
UT The small business services and exchange of state information and federal regulatory updates are crucial for providing
effective services and timely information and support. Information packets provided by the national SBO office,peer
exchanges, conferences, workshops, and phone contacts are vital to provide local assistance. These efforts are cost
effective in avoiding duplication and research time and should be continued and expanded.
WA A major effort by the state Ombudsman to communicate with EPA's Office of Enforcement and Compliance Assurance in
support of the proposed Automotive Service and Repair Compliance Center to be located in Kansas City has been
"rebuffed." It would appear that EPA efforts will, in fact, be duplicating local/state activities and causing confusion for
automotive small business owners.
Allow Flexibility in Rules Applying to Small Business
Explore ways under Title V implementation to minimize burdens on small business.
CO Remove the "once in, always, in" requirement in the MACT program. (Note: A source can move in and out of Title V,
but unless it gets out of the MACT in time, it will always be subject.)
Federal requirements should reflect whether or not a state has any nonattainment areas.
ME Shift the emphasis of CAAA from pollution regulation to pollution prevention.
Focus assistance efforts on getting businesses out of the regulatory loop by reducing their emission levels below
regulatory thresholds.
MD Reduce the requirements/inflexibility of the CAAA so that states can more easily prove that they require equivalent
environmental protection and so exempt their small businesses from duplicate or more prescriptive efforts.
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TABLE G-3
(Continued)
RECOMMENDATION
MN Simplify regulations for small business -- "one size fits all" does not work in this case.
More simply defined levels of "insignificant activities" and "exemption" status are required.
Set industry sector/size goals and phase them in over a period of time. Small businesses often lack the financial ability to
make major changes quickly.
NE Eliminate the "potential to emit" calculations ,and allow small businesses to use actual emission data from the source to
be regulated.
Provide a bottom line of actual emissions at which a source does not have to provide a report.
NH
Increase use of general permits and standard exemptions for small sources.
NY State and federal governments should be more flexible with regulatory requirements as they are applied to small business
sources. This would reduce the regulatory burden yet result in no impact on environmental or human health. For
example, the VOC RACT requirements in New York State have no applicability threshold for sources located in the NY
metropolitan area, but control options included in the regulations were developed based on control options available to
major facilities. The CTGs evaluated major sources when the control options were established, and these control
strategies were never intended for minor sources.
Examine streamlining procedures for variances.
NC Change the definition of potential to emit to reflect a reasonable number based on a factor of 2 or 3 times actual
emission.
Modify the EPA enforcement policy to allow small major sources to reduce emissions below major thresholds to become
"small non-major" sources.
Simplify requirements and reduce the paperwork. It is still difficult for a small business to be certain that all applicable
requirements are met.
Raise the permit threshold above the 5 tons per year exemption level presently in use in North Carolina. Ten tons per
year seems reasonable since this is the threshold used for a HAP.
ND Allow states flexibility in administering rules and policies they adopt which are intended to assist small business (e.g.
different versions of amnesty that result in compliance).
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(Continued)
RECOMMENDATION
OH There continues to be an inherent conflict in EPA's policy of forcing states to choose between offering confidentiality and
offering flexibility on enforcement action. Although the current position represents a step forward for EPA, it would be
more productive to allow states to develop their own "mix" of tools required to carry out the job.
OK Eliminate potential to emit as a defining criteria for applicability to Part 63 NESHAPs. Base it upon actual emissions.
Do not require Sec. 11 2 sources, regardless of size, to obtain a Title V permit.
SC Do not require small businesses to obtain a Title V permit if subject only to new MACT standards and are not otherwise a
major source.
Allow small businesses to calculate emissions based on actual and not potential if adequate control equipment or devices
are in place.
Continue to require notification for modifications to processes, but not for new construction permits if changes do not
exceed permitted emission limits (Plant-wide Applicability Limits), a major source otherwise.
Allow more exemptions to the P.E. certification requirements for construction applications.
SD
The federal government should give states as much flexibility as possible to help small businesses comply with the CAAA.
Wl The EPA's enforcement policy should not lead from command and control-driven regulations, but should provide for
economically-driven enforcement with flexibility to allow the regulated community to solve their own problems using
innovative and cost-effective approaches. Permitting should be based solely on performance and the specific
environmental discharge standards that the facility must meet.
Avoid Duplication of Effort in Compliance Assistance Activities
ID Instead of creating compliance centers throughout the U.S., channel that money to state programs where it can be used
by everyone. These compliance centers are a duplication of effort, waste of increasingly limited resources, and an
irresponsible action on the part of the EPA.
IA Assess the need to establish national compliance assistance centers based on the existence of a clearly defined client
base that cannot reasonably access equivalent services elsewhere. Optimize spending by funding existing programs
instead of creating new ones.
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(Continued)
Wl
RECOMMENDATION
ND Ensure that the proposed federal compliance assistance centers do not duplicate the efforts of the state SBTCPs. If the
centers are established, one role of the center that may be helpful to states would be to serve as a clearinghouse for
documents.
WA The SBAP and related activities should be coordinated at the federal level to avoid internal duplication of effort and
competition for funds. A specific focus of this coordination effort should be the four Compliance Office technical centers.
Ensure that federal programs do not duplicate efforts at the state level.
OECA Compliance Incentive Policy
MA Additional guidance is needed to enable implementation of the OCEA Compliance Incentive Policy. In some cases, getting
the state to implement the policy would be facilitated by clear, step-by-step guidance on state implementation.s, getting
the state to implement the policy would be facilitated by clear, step-by-step guidance on state implementation.
Wl The EPA Interim Policy on Compliance Incentives for Small Business is an "inferior policy." It lacks immunity from
penalties for those who audit, remedy violations, and report voluntarily. It also creates uncertainty and obstruction
regarding voluntary corporate disclosure of violations. Further, this policy will increase the liability of those who perform
environmental audits, voluntarily report violations, and provide timely remedies. A congressional fix may be necessary in
the spirit of meaningful self-regulation.
Other
AR Small business assistance must become a component of all regulatory activities - not some separate and competing
activity.
Pollution prevention must be integrated with small business assistance.
CO Transfer resources now being used for Federal Assistance Centers to Federal SBO/SBAP programs.
Allow state SBAPs/SBOs to operate with unconditional confidentiality in regards to discovered violations (except for
imminent public endangerment).
FL The Ombudsman would like federal regulations requiring the state to enact legislation providing confidentiality in all SBAP
transactions.
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TABLE G-3
(Continued)
KS
NH
RECOMMENDATION
IN Get the rules out to affected businesses by means other than the Federal and State Registers. Utilize newsletters, trade
associations, etc.
Offer compliance assistance on a confidential basis.
The requirement for a CAP should be the state's option.
MN Regulation development needs to include more small businesses and involve people from across the country.
Rule writers at EPA should personally visit more small businesses.
Write rules in real "plain English."
Re-evaluate recordkeeping/reporting requirements, keeping them simple. Avoid collecting data that does not demonstrate
compliance.
MT Provide federal funding to state SBAPs for regional technical training. It would be advantageous for SBAPs to help
sponsor regional training sessions where staff would receive detailed, industry-specific training on MACT issues. The
sessions should involve hands-on training on industrial processes, pollution prevention, and control equipment.
Allow of increased recycling of used auto refrigerant and catalytic converters without excessive reprocessing.
NM
Increase regional participation in MACT development.
NY Regulatory agencies at the state and federal level should institute informational outreach to environmental consultants.
Numerous consultants are contacting SBTCP for information about regulatory requirements because they have difficulty
accessing the regulators. SBTCPs could arrange to provide consultant services to small businesses at a reduced rate.
Direct assistance is provided small business by the SBTCP and consultants. Therefore, the states should develop a
mechanism to provide accurate and timely advice to their clients. This should result in a higher rate of compliance.
The state and federal government should develop formalized training for those providing permitting assistance.
State and federal regulatory agencies should provide outreach to those affected by their requirements (not just SBTCP).
OH Larger quantities of EPA brochures on new MACT standards and EPA-developed software for calculating source emissions
would be helpful.
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TABLE G-3
(Continued)
RECOMMENDATION
OR
PA
PR
TN
TX
UT
VA
The greatest obstacle to meeting all the requirements of the Clean Air Act is the lack of resources. The state SBAPs
training, financial, and support assistance.
Work with state SBAPs to institute a national small business mentor program.
Work with state SBAPs to develop a national green sticker program (e.g. simplified ISO project).
need
Maintain a high level of enforcement against companies that wilfully violate regulations. Otherwise, companies will
continue to avoid detection or refrain from complying with the regulations.
Provide guidelines and recommendations for each state to assist Puerto Rico in developing its program.
Maintain the SBAP requirement in Section 507 of the Act.
Modify the present statutory provisions by elevating the EPA Small Business Ombudsman to the Office of the
Administrator.
Abolish "continuous emission monitoring" provisions that would be better left to state regulatory authorities.
Ensure a sufficient time frame from publication of a new rule and the compliance date(s).
Concerted effort to ensure that grants for small business assistance are coordinated with state SBAP/SBO to provide
maximum leverage of resources.
for
Training sessions that provide a step-by-step approach to conducting on-site evaluations, along with
sample forms, pollution prevention materials, industry-specific information, and mock site visits would be of great benefit
in increasing effectiveness of reviews, as well as providing a training program for volunteer site evaluators.
Continued coordination with P2 programs and services would be mst helpful, along with providing additional support
research and information of services and improved team efforts.
in
Increase training and networking opportunities with CAP peers and integrate training sessions with SBO/SBAPs to allow
for greater understanding of services and improved team efforts.
More comprehensive impact analysis of regulations affecting small businesses. Is the gain in emission reduction worth
the price which will have to be paid?
11
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TABLE G-3
(Continued)
RECOMMENDATION
wv
There should be a mechanism to reduce the minimum composition for small state programs. While it is desirable to have
a variety of interests represented, it is inefficient to oversee the activities of three people with a seven-person panel. We
suggest consideration of a five-member panel for small states, perhaps reducing duplication of members representing the
same constituency (e.g. one member representing the general public rather than two, and three members representing
small business rather than four).
Wl
EPA should insist that all other regions became equally active in order to maintain a uniform CAP policy throughout the
U.S.
EPA should recognize, by a policy statement(s), that industry is basically in environmental compliance without a large
number of recalcitrants. Industry owners are responsible adults with an acquired (over the years) environmental
consciousness supported by a well-established irreversible public environmental ethic.
To be fully effective, CAP staff need training in negotiated rule making and conflict resolution. Abbreviated training could
be arranged through existing seminars at Harvard and M.I.T.
The Wisconsin Small Business Environmental Council strongly supports the formation of a national (non-profit) Small
Business Assistance Coalition/Trade Association.
No recommendations reported: AL, AK, CT, DE, GA, HI, MO, NJ, WY.
12
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TABLE G-4
CONFLICT OF INTEREST/CONFIDENTIALITY ISSUES
In Table G-4, the SBTCPs describe how their programs address internal or external conflicts of interest (COD or perception
that this program may not be confidential. (Comments edited for space.)
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Final Cty.
Maricopa
Cty.
Pima Cty. &
Tucson
Arkansas
California
Colorado
COI ISSUES AND RESOLUTIONS
To maintain confidentiality, businesses can work through Ombudsman's office, which is placed under the Director of the AL
Department of Environmental Management and not under any regulatory divisions. When SBO staff receive a call for
information and goes to the regulatory divisions for answers, it is understood that the source of these questions is to be kept
confidential unless there is an imminent threat to public health or the environment.
Small Business Air Program is located in the Compliance Assistance Section of the Statewide Public Services Division. The
section is a non-enforcement unit without authority for taking enforcement actions. The section was specifically set up to
provide assistance to businesses and pollution prevention services without enforcement authority. Alaska has a strong open
records law, and as such, the documents and information contained in the SBAP are open to the public and to other sections
of the department. However, there are no efforts on the part of the SBAP to notify enforcement entities in the department of
issues arriving from SBAP actions, with exception of those involving immediate threats to public health or the environment.
SBAP moved out of Air Quality regulatory program and housed under Director's Office of Customer Service and External
Affairs (separate physical buildings in close proximity). Agency policies developed regarding Confidentiality of Information
and the relationship between SBAP and Compliance & Enforcement activities within the Agency.
To the extent that our assistance activities have revealed non-compliance, we have initiated vigorous enforcement action
where the non-compliance has caused a meaningful risk to human health. In other cases, we have simply exercised
enforcement discretion. (In all candor, we have encountered NO revelations of non-compliance that could be characterized as
creating a meaningful endangerment of human health.)
Although Maricopa County SBEAP is housed in the same department as enforcement and compliance groups, there have been
no instances where confidentiality or a conflict of interest have been brought into question. We remain very sensitive to that
perception, and have increased communication between the SBEAP and enforcement groups so we can be aware of any
planned or pending action against a company prior to providing assistance. A formal confidentiality policy is currently being
developed and should be in place in the first quarter of 1996.
Business Assistance personnel are forbidden by the director to inform other department personnel of situations, practices,
equipment, etc. at a particular facility that could lead to enforcement action unless the observed practice poses an imminent
and immediate threat to public health or the environment. Department personnel respect this confidentiality. The regulated
community is apprised of this policy, but only place confidence in it after dealing one-on-one with Business Assistance staff.
Bottom line: Over time, business persons benefit from the assistance program and communicate to others that they were not
burned by the department. Grass roots marketing and sincere staff are what make the program work in Pima County.
Confidentiality has not posed a problem in AR. The SBAP has used multi-media inspection teams from the regulatory
divisions to achieve voluntary compliance. SBAP has been able to offer permit extensions and waivers to small businesses to
allow reasonable periods for achieving compliance.
Ombudsman's office is part of the Air Resources Board Chairman's Office and no COI or confidentiality issues have arisen
yet.
CO doesn't have a formal policy on how to handle the issue of confidentiality.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
COI ISSUES AND RESOLUTIONS
CT's program does not offer confidentiality and probably never will. The State has liberal Freedom of Information Act that
provides for only a few limited exceptions to the general policy of disclosing governmental documents. CT's program works
closely with other service providers, some of which do offer confidentiality. In situations where confidentiality is an issue,
the SBTCP refers clients to programs within the state that do offer confidentiality. These organizations include CT
Department of Economic Development (CTDED) and CT Technical Assistance Program (ConnTAP). Until recently, the Air
Bureau funded two staff positions at the CTDED to offer small businesses a confidentiality option. The CTDED positions
were funded under an Memorandum of Understanding, which has expired.
The SBTCP is working to establish a policy/protocol with the Air Bureau's Enforcement Division to provide some level of
predictability for small businesses seeking assistance. This policy/protocol likely will take the form of a Compliance
Assistance Agreement that provides for delivery of technical assistance as part of the Air Bureau's Enforcement Response
Policy.
CT's Regulations of Connecticut State Agencies (RSCA) provide for confidentiality exceptions for company trade secrets.
Not a problem to date. Program is structured to assure confidentiality to those requesting assistance from SBO/SBAP
Technical questions are referred to regulatory and engineering personnel by SBO, who is not compelled to reveal the source
of the inquiry.
Abide by 1995 Memorandum of Agreement delineating confidentiality policy by EPA's Assistant Administrator.
Program is organizationally isolated from the regulatory section within the Division of Air Resource Management.
SBAP avoids discussion and review of confidential materials with compliance and enforcement personnel. In discussions,
business names are not used, or circumstances are presented and assurances are secured before any sensitive materials are
discussed.
No response.
This hasn't been a big problem for us (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 that we can't.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
Illinois
The Illinois EPA (IEPA) requested that the SBAP be housed in the Department of Commerce and Community Affairs (DCCA),
which is the economic development agency for the state and was created in 1979. The SBAP is part of the Small Business
Division within DCCA. This Division also includes the Small Business Development Center Network, which includes 53
Centers throughout IL that provide free counseling and business assistance.
Having the SBAP at DCCA, a non-regulatory and small business assistance agency, removes the "fear factor" for small firms
looking for assistance and information by not having to talk with the regulatory agency. SBAP staff rely on the IEPA for
correct and timely information that can be communicated to small businesses.
Although the SBAP does not provide on-site assessments, small businesses can obtain needed assistance. The Illinois
Hazardous Waste Research and Information Center (part of the IL Department of Natural Resources, a non-regulatory agency)
provides free assistance as needed. The SBAP created an Environmental Services Directory and Guide to Hiring an
Environmental Consultant that small businesses may use to get on-site assistance. These two factors also allow for avoiding
conflicts of interest and confidentiality for program clients.
Indiana
Most of the CTAP program, including all of the SBTAP, has been relocated to a separate building away from the rest of the
regulatory programs within the Agency. The physical separation of the SBTAP minimizes the perception that our program is
not confidential.
Senate Enrolled Act 417 requires that information and documents of the CTAP/SBTAP be kept confidential. A policy has
been drafted to carry out the confidential provision of the Act. The policy includes detail procedure that staff should follow
to ensure that confidentiality is not breached.
Iowa
The Iowa Air Emissions Assistance Program (IAEAP) is located within the Iowa Waste Reduction Center (IWRC) at the
University of Northern Iowa. The IWRC is not part, and operates independently, of the Iowa Department of Natural
Resources (DNR). However, the IAEAP is funded by Title V fees through the DNR Air Quality Bureau (AQB). Contract terms
require disclosures of the IAEAP client list to the DNR-AQB. The quarterly disclosure identifies client names and addresses,
but does not include facility-specific information. The IAEAP informs clients that confidentiality does not exist.
The IAEAP considers the disclosure list to be insignificant for two reasons: the vast majority of IAEAP clients must submit
permit applications to DNR, which do contain detailed facility information; and to encourage voluntary compliance, the DNR
does not target small businesses that are receiving assistance from the IAEAP
This system encourages small businesses to work with the IAEAP The disclosure list provides a measure of insulation from
DNR enforcement for actively working toward compliance with the IAEAP.
Kansas
SBAP is under contract, which states that specific information regarding businesses (such as name, specialty, specific nature
of inquiry or other trade information) will not be reported to the regulatory agency; only numbers by type (SIC codes) are
reported. The Ombudsman (Public Advocate) has the approval by the division director and bureau directors to keep
information confidential. Confidentiality has not been an issue.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
Kentucky
KY SBTCP is based on independence from the regulatory program. SBO located in the Cabinet Secretary's Office. SBAP is
offered through Center for Business Development outside state government. CAP members are appointed by Executive Order
of the Governor. Legal issues concerning KY SBTCP have been reviewed extensively twice and discussed at two CAP
meetings. Confidentiality is not an issue for the JCAPCD because the District approved a pilot amnesty program for small
businesses on November 15, 1995. The pilot amnesty will be effective through the 1996 calendar year
Louisiana
The following policy is published on the electronic bulletin board: "The Small Business Assistance Program (SBAP) personnel
will not voluntarily reveal any environmental information received from a small business to any regulatory agency, except: 1)
a criminal act has been committed, 2) the violation is a serious hazard to life or the environment, or 3) the company is a
repeat violator."
Maine
The Department has adopted a "Small Business Compliance Incentives Policy" based on EPA's guidance dated June 1995.
Maryland
The SBAP conducted on-site assistance at only 10 businesses, and do not advertise this service. Therefore, since the
program is not discovering instances of non-compliance, this has not been a major issue. The SBAP ;has an enforcement
policy agreement with the Air and Radiation Management Administration. If businesses voluntarily come forth to get late
permits through the SBAP, no fines are issued. However, if they are found in non-compliance by enforcement, the SBAP
cannot help. No conflicts have arisen.
Massachusetts
With the passage of the Toxics Use Reduction (TUB) Act in 1989, OTA was created with a legislative guarantee of
confidentiality to client companies. The only exception would be in the case of imminent threat to human health or the
environment. In 6 years of operation, OTS has not been required to report a single company. The confidentiality of our
clients has been demonstrated and after a slow beginning, the business community has come to accept this as valid.
The OCEA Compliance Incentive Policy would be an ideal opportunity for us to expand our repertoire of credible alternatives
for clients. If we were able to utilize the Policy, we could then offer either confidentiality or the compliance window/penalty
mitigation option. Companies could choose between the options according to their best interests.
Conversations with the Acting Director, Chemical, Commercial, and Municipal Services Division of OECA indicated that no
legislative enactment was required for the state to adopt the Policy. Since it was a policy rather than a regulation, it could be
supported perhaps by an MOU between the Department of Environmental Protection (DEP) and OTA. Despite numerous
attempts to get a supporting policy, we have not been able to achieve implementation of this policy. Efforts to implement
this policy will continue.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
COI ISSUES AND RESOLUTIONS
External COI: Confidentiality is not an issue because the current services provided by the SBTCP are proactive. The SBAP is
eluding the confidentiality issue by developing guidance publications, workshops, and conducting phone consultations. At
present, these activities do not warrant the collection of sensitive data. Additionally, the SBAP does not perform on-site
audits, so facility-specific information is not collected.
The SBTCP will soon be developing a policy that explains how the program will respond when it becomes aware of a violation
by a facility seeking assistance. The policy will also explain that information contained in the SBTCP files or databases will
not be shared with the regulatory agency (Michigan Air Quality Division). At present, Michigan's SBTCP cannot claim that
this information is "confidential" because state law (Michigan Freedom of Information Act) prohibits this claim.
Internal COI: The SBTCP works closely with the regulatory agency, the Michigan Air Quality Division, as it develops and
executes all of its program objectives. SBAP staff are included in and advised of all policy developments regarding state
implementation of the Clean Air Act. Michigan's SBAP acts as an education, outreach, and marketing arm for the state's air
quality program and that role has assisted the SBAP in avoiding internal COI.
MOD between SBCAP and Air Quality Division Enforcement Program signed April 6, 1995.
The Technical Assistance audits are handled outside DEQ by MISSTAP at Mississippi State University, allowing the SBTCP to
use Option 2 of EPA's Enforcement Response Policy. The Ombudsman Office has been established within the DEQ with
independence and confidentiality presented to and acknowledged by the Director and the Commission on Environmental
Quality. We feel small businesses will trust this division of MSU to conduct the audits in a confidential manner.
Technical Assistance Program (TAP) does not share their files with any regulatory programs within the Division of
Environmental Quality. When TAP requests information about a facility or type of process from a technical expert within a
regulatory program, no information is provided that would allow the regulatory program to identify the facility in need of
assistance.
No issues have developed at this time.
MT SBAP has been granted explicit authority from the MT Department of Environmental Quality to offer small businesses
amnesty from enforcement measures provided that they make reasonable progress towards compliance with environmental
regulations and are not presenting an immediate danger to public health, safety, and welfare. The issue of confidentiality
soon will be detailed in a formal policy by the Department of Environmental Quality.
This is not an issue within the Nebraska Department of Environmental Quality mainly because the SBO, SBAP, Public
Advocate, and Technical Assistance are all located in the Management Services section of DEQ and not under any Regulatory
program. The SBO, Public Advocate, and Director of SBAP is one person. Coordination and confidentiality are not problems.
Currently, there is no confidentiality or amnesty-type programs at NDEP and specifically at SBTCP However, NDEP is
working toward some resolution of this issue and should have it resolved by the next reporting cycle.
Informal directive from DES Commissioner and Air Resources Director which implements OECA Policy. State law allows
"audit privilege" for third party audits, which includes SBAP activities. Compliance assistance is a strong part of DES
activities and is encouraged.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
New Jersey
New Mexico (except
Bernalillo County)
Bernalillo County
New York
North Carolina
COI ISSUES AND RESOLUTIONS
No response.
The SBAP offers an amnesty policy to qualifying small businesses in New Mexico. An agreement has been set up in the
Environmental Department between the Air Pollution Control Bureau (APCB), which has enforcement responsibilities, and the
Air Quality Bureau (AQB). SBAP provides qualifying small businesses relief from enforcement activities while the small
business is making good faith efforts to meet air quality requirements. The SBAP will continue the amnesty status as long as
the small business continues to work towards compliance with federal and state air quality regulations. A small business will
not be eligible for amnesty for violations for which they were cited by the APCB before contacting the SBAP The SBAP does
not offer confidentiality.
Expect development of an MOU and Amnesty program with Regulatory Section of Air Pollution Control Division in 1996.
Currently, the SBAP provides a listing of small businesses receiving assistance to the Compliance Section that efforts are
being made to comply with regulations. These businesses are those that have requested assistance through referral,
outreach, or other city /state agencies.
The SBO and SBAP are located in non-regulatory agencies. Also, there is state legislation mandating confidentiality for both
entities. The information is not subject to the Freedom of Information Law.
November 1993 the Department of Environment, Health, and Natural Resources issued a Confidential Policy for the Offices of
Waste Reduction and Small Business Ombudsman. Since the entire SBAP and SBO are in the Office of the Small Business
Ombudsman, the policy applies to all operations of the SBTCP. The policy states that the regulatory Divisions will not seek
to obtain information about compliance of any individual or company from the two assistance offices. Further it states that
the OWR and SBO will maintain confidentiality of information to the maximum extent allowed by law.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
North Dakota
Ohio
Oklahoma
COI ISSUES AND RESOLUTIONS
There are advantages and disadvantages to the organizational structure of the SBAP and SBO. As structured, the SBAP and
SBO may not appear to be free of conflict of interest. Although the SBAPO staff are part of the permit section, which is
separate from the compliance section, it is difficult to know whether small businesses may be reluctant to request assistance
from the SBAP, since the SBAP staff are part of the air pollution control regulatory program. Also it is unknown whether
small businesses are reluctant to request assistance or confide in the SBO, since the Ombudsman is housed within and
employed by the Department of Health.
The environmental programs of the Department's Environmental Health Section have traditionally been assistance and
compliance oriented, with enforcement reserved for recalcitrant violators or where damage to health and/or the environment
has occurred. Even prior to the establishment of the SBAP and SBO, the Department's emphasis has been on educating and
assisting the regulated community to achieve compliance. With the establishment of the SBAP and SBO, the fundamental
approach to compliance hasn't changed noticeably. However, with the establishment of the SBAP and SBO, there has been
more outreach activity advertising the Department's assistance-oriented philosophy.
With respect to confidentiality, dialogue between the SBO and SBAP has resulted in the understanding that small businesses
may reveal certain information to the SBO that may be treated confidential and not disclosed to, or sought to be disclosed
from, the SBAP. Information disclosed by small businesses directly to SBAP staff is not turned over to the compliance
program staff for enforcement purpose; however, it is expected that a plan for correcting any violations will be developed.
When needed, compliance assistance will be provided from the SBAP
It is the SBAP's and SBO's position that confidentiality (disclosure of violations to enforcement staff) is really a non-issue in
North Dakota.
Ohio General Assembly passed implementation legislation for the Small Business Assistance Program. These amendments to
the Ohio Revised Code included a strict confidentiality protection as well as a provision that prohibits use of information
gathered by SBAP in any OEPA enforcement action. Confidentiality has been emphasized and set in policy through a
"Memorandum of Understanding" distributed by OEPA Division of Air Pollution Control to all OEPA and local air agency staff.
The MOU specifies the confidentiality policy and instructs personnel to take it into account. SBAP cannot and does not
report violations to enforcement personnel. The MOU follows USEPA's August 14, 1994 memo from S. Herman using the
confidentiality option.
SBAP is located in the DEQ's Customer Service Division, which is a non-regulatory part of the regulatory agency.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
COI ISSUES AND RESOLUTIONS
Information disclosed and minor violations discovered from on-site small business technical assistance visits is protected by
state statute except when there is reasonable cause to believe there is a clear and immediate danger to public health and
safety or to the environment. In accordance with state statute and the confidentiality option set forth in EPA's Office of
Enforcement and Compliance policy, SBAP adopted a Confidentiality Policy. In summary, the Policy requires the SBAP:
• to function independent of enforcement section
• to restrict access to information and files of small businesses receiving assistance
• to keep business names and locations in a separate confidential file
• to perform follow-up consultations to assure resolutions of violations discovered during on-site visits.
This policy has not caused any conflicts of interest inside or outside the agency. To the contrary, it allows additional
flexibility to bring small businesses into environmental compliance. For example, it allows SBAP to assist a small business
that faces enforcement action through other channels by allowing staff to assist with P2, applying for permits, and mitigating
penalties via supplemental environmental projects (SEPs). In such cases OR's SBAP Confidentiality Policy is compatible with
EPA's "Interim Policy on Compliance Incentives for Small Businesses."
Many services of the PA SBAP have been contracted to a private company. The terms of this contract prohibit the
contractor from providing client names and addresses to the regulatory agency. The contractor primarily seeks contracts
with government agencies, and therefore does not normally have small business clients outside of the SBAP contract. This
arrangement, to date, has avoided any problems with conflict of interest, and has provided a solution to the confidentiality
issue.
We have a group of qualified consulting engineers which will provide the necessary assistance at lower cost when needed by
small business. The source will make the necessary payments. Any assistance provided directly by EQB will be paid by Title
V.
Rl DEM has been operating a non-regulatory P2 technical assistance program since 1987. Since that time, we have worked
with more than 200 companies and have gained the trust of many more. As the Rl SBAP develops, and prior to on-site
compliance assistance, SBAP staff will enter into a memorandum of understanding with OEM's regulatory Division of Air
Resources.
The SBTCP is located in Environmental Quality Control Administration within the regulatory agency. This separation from the
Bureau of Air Quality has allowed us to offer confidentiality. We have encountered no problems with this arrangement.
South Dakota has a good working relationship with businesses. Individuals that write permits also conduct the inspection or
facility audits. The goal of the department is to make sure all sources are in compliance with both state and federal
requirements. As of yet, there have been no issues concerning COI.
Program is housed in non-regulatory division of department. Files are not shared. Company names are not provided to
regulators unless company okay. Regulatory agency respects confidential nature of program.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Texas
Utah
Vermont
Virginia
Virgin Islands
CO! ISSUES AND RESOLUTIONS
In 1993, SBAP developed a Confidentiality Policy for small businesses that was adopted by the TNRCC Commission. SBAP
operates under a multi-media TNRCC policy that provides for confidentiality from enforcement program of the agency. We
work closely with the TNRCC Executive Office, Enforcement and Field Operations to ensure that all are aware of the
Confidentiality Policy. The Enforcement Division now refers small businesses to our office for confidential assistance. Most
printed materials developed by SBAP contain statements regarding confidentiality of information shared with SBAP The
confidentiality policy that started with the Air Program has been expanded to all media that TNRCC regulates.
Utah's SBO Office was originally established at the Department level. During the transition in hiring the new Ombudsman
and the Voluntary Assistance Program (VAP) Coordinator [both confidential positions (VAP adheres to the state legislature's
"Self Audit" confidentiality rule, which passed during the 1995 session)), the Division Director determined that a closer
working relationship with the SBAP would be needed to ensure effective development of the on-site review program. The
SBO Office was moved under the Division Director's Office during this "incubation" phase to establish solid VAP services and
to allow for greater internal coordination.
The move was presented to the Small Business Advisory Committee (SBAC) with no objection. A comment was made that
basically "government wears the same hat at any level." However, a Committee member strongly encouraged that
appropriate internal safeguards be taken to ensure confidentiality. Such provisions have been taken to ensure a confidential
workspace.
SBAP continues to operate under the "don't ask, don't tell" philosophy within the Division's Permit Section. A Division-wide
confidentiality policy has been in the development stages through the Division's internal Small Business Coordinating
Committee (SBCC) and should be completed spring 1996.
Confidentiality issues have been a topic of discussion in the formulation of a Department-wide "multi-media" Small Business
Assistance Program. The present plan is to offer on-site assistance with non-regulatory compliance specialists. The
compliance specialists will sign an agreement not to provide information on compliance assistance visits to regulatory
inspectors.
DEO has adopted EPA's Section 507 Enforcement Policy and is in the process of reviewing a MOD that would ensure
confidentiality for the SBAP and the P2 Program from direct review by the enforcement division.
The issue of confidentiality has not yet been a major problem, but will take on more importance as the SBAP moves further
into voluntary complimentary compliance audits. The ability to deliver a quality product to the customer is only as good as
the credibility of the provider. The ability to correct deficiencies and non-compliance situations through the 507 Enforcement
Policy provides a non-confrontational means to achieve compliance assistance and deliver a quality product. Also, it is
worthy of note that Virginia's legislature passed both voluntary remediation and voluntary environmental assessment
legislation last year, which provides an additional degree of relief to the business community.
No response.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
Washington
Revised Code of Washington, Chapter 70.94.034: "The department (of Ecology) shall establish a technical assistance unit
within its air quality program, consistent with the federal Clean Air Act,...No representative of...the technical assistance
unit...may have enforcement authority...Consultation(s)...shall not be regarded as an inspection or investigation...No
enforcement action shall be taken...for violations...unless and until the facility owner or operator has been provided
reasonable time to correct (any) violation." Violations that pose immediate threats to public health and the environment may
result in immediate enforcement action.
SBAP staff are obligated to report personally-detected violations (i.e., from on-site visits) to agency enforcement staff.
Reporting is discretionary in the case of suspected violations or those suggested by the source with the exception of those
posing "imminent threat."
West Virginia
SBAP operates separately and independently from the enforcement group of the agency. SBAP currently housed in a
separate physical location. To better help small businesses, enforcement refers some violators to SBAP for technical
assistance to facilitate compliance. SBO also intervenes in specific enforcement actions to ensure that small businesses are
fairly treated. SBAP does not refer any cases to enforcement, except in the case of imminent danger. However, to ensure
that compliance is eventually achieved, SBAP will make on-site assessment files available to enforcement after an eighteen
month grace period. The business is not shielded from enforcement actions related to violations independently discovered by
inspectors during this period. Such independent discovery may occur through routine inspection activity or complaint
investigation.
Wisconsin
The SBTCP responsibilities are split between the Wl DNR and the Wl DOD. As a result, the majority of contact that the
SBTCP has with the public is handled by non-regulatory DOD personnel. Our program has a confidentiality policy that gives
a. business confidentiality when they speak with a DOD representative. If they speak with a DNR representative, they have a
90-day grace period to correct the deficiency. Our confidentiality policy does not provide immunity for businesses that are
undergoing an inspection.
Wyoming
By Wyoming law, all emission and pollution information must be available to the public. The only information that can be
kept confidential is that relating to trade secrets. The department maintains that its statutory authority and commitment to
resolve violations of the Environmental Quality Act through conference and conciliation whenever possible assures small
businesses that they will not be subject to enforcement and penalties for violations discovered in the course of receiving
technical assistance. The CAP does not feel that this assurance is adequate and currently seeks to have the department
provide that assurance by adopting a policy and promulgating it into rules department-wide that any small business seeking
compliance assistance will not be penalized for disclosure of violations providing a good faith effort is made to correct them
in a timely manner. This issue has not yet been resolved.
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