United States Office Of Policy EPA 233-R-00-001
Environmental Protection And Reinvention March 2000
Agency (2131)
Status Of The State
Small Business Stationary
Source Technical And
Environmental Compliance
Assistance Program (SBTCP)
Report To Congress
For The Period
January To December 1998
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ACKNOWLEDGMENTS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
grateful for the support of the dedicated staff of the State Small Business Stationary
Source Technical and Environmental Compliance Assistance Programs (SBTCPs),
including the Small Business Ombudsmen (SBOs), Small Business Assistance Programs
(SBAPs), and the Compliance Advisory Panels (CAPs) in the preparation of this fourth
Report to Congress. All states and territories submitted timely reports to make this report
complete and comprehensive.
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENTS i
LIST OF COMMON ACRONYMS vii
EXECUTIVE SUMMARY ix
1.0 INTRODUCTION AND REPORT OVERVIEW 1-1
1.1 Rationale and Objective of the Report to Congress 1-1
1.2 Data Collection Methodology 1-1
1.3 Organization of the Report 1-3
2.0 OVERVIEW OF THE SBTCP 2-1
2.1 Small Business Ombudsman 2-1
2.2 Small Business Assistance Program 2-2
2.3 Compliance Advisory Panel 2-2
2.4 EPA's Responsibilities Under Section 507 of the CAA 2-3
2.5 Federal Small Business Assistance Program 2-3
3.0 SBTCP STATUS, BUDGETS, STAFFING AND ORGANIZATION 3-1
3.1 Operating Status 3-1
3.2 Budgets 3-3
3.3 Staffing Levels 3-9
3.4 Administrative Locations of SBO and SBAP Components 3-11
4.0 SBTCP ACTIVITIES AND SERVICES 4-1
4.1 Industry Sectors Assisted by the SBTCPs 4-1
4.2 Activities and Services 4-4
4.3 Assistance Requests 4-8
4.4 Cap Activities and Services 4-10
4.5 Financial Assistance Programs 4-11
4.6 Minimizing Duplication Through Cooperative Efforts 4-12
4.7 SBTCP Compliance with Section 507(d)(2) 4-14
5.0 PROGRAM EFFECTIVENESS 5-1
5.1 Program Goals 5-1
5.2 Program Highlights and Accomplishments 5-4
5.3 Tips and Barriers 5-6
5.4 Success Stories and Case Studies 5-8
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TABLE OF CONTENTS
(continued)
Page
6.0 COMPLIANCE ASSURANCE ISSUES 6-1
6.1 Common Compliance Problems 6-1
6.2 Compliance Problems in Particular Industry Sectors 6-2
6.3 Recommended Changes to Facilitate Small Business
Compliance with the CAA 6-5
6.4 Program Confidentiality and Conflict of Interest 6-6
6 5 Use of EPA's Small Business/Small Communities Policy 6-7
LIST OF TABLES
Table No. lille Page
3-1 Operating Status of the SBTCP Components 3-2
3-2 Start of Operations for SBTCP Functions 3-2
3-3 1998, 1997, and 1996 SBTCP Operating Budget Ranges 3-4
3-4 SBTCP Reporting Period Budget Comparisons 3-5
3-5 1998 SBO Operating Budget Ranges 3-7
3-6 1998 SBAP Operating Budget Ranges 3-8
3-7 1998 CAP Operating Budget Ranges 3-9
3-8 Staffing Levels (as FTEs) Serving the SBO & SBAP Functions 3-10
3-9 CAP Appointments 3-11
3-10 Administrative Locations of SBO and SBAP 3-11
3-11 Regulatory/Nonregulatory Locations of SBO and SBAP 3-12
4-1 Top 10 Industry Sectors Assisted 4-2
4-2 Top 10 Industry Sectors Assisted by Programs 4-2
4.3 Industry Sectors Targeted for Assistance 4-3
4.4 Outreach Activities and Businesses Reached 4-5
4-5 Notable Outreach Strategies 4-6
4-6 Information Available on Internet Home Pages 4-7
4.7 Air-only Versus Multimedia Assistance 4-8
4-8 CAA/Multimedia Assistance Reqursts 4-9
4-9 Major CAP Activities 4-10
4-10 Financial Assistance Programs 4-11
4-11 Programs That Report Cooperative Efforts for
SBTCP Functions 4-12
4-12 SBTCP Mechanisms for Avoiding Duplication 4-13
4-13 SBTCP Activities to Follow the Intent of the Paperwork
Reduction Act 4-15
4-14 SBTCP Activities to Follow the Intent of the Regulatory
Flexibility Act 4-16
4-15 SBTCP Activities to Follow the Intent of the Equal Access
to Justice Act 4-17
IV
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TABLE OF CONTENTS
(continued)
Page
5-1 Program Goals 5-2
6-1 Common Compliance Problems 6-2
6-2 Compliance Problems in Industry Sectors 6-3
6-3 Industry Sector Appearance in Compliance Categories 6-3
6-4 1998 SBTCP Recommendations for Improving Compliance 6-5
APPENDICES
A 1998 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
Below is a list of major abbreviations and acronyms that are commonly used in this report.
BACT Best Available Control Technology
CAA Clean Air Act as amended in 1990
CAP Compliance Advisory Panel
COI Conflict of Interest
EPA Environmental Protection Agency
FESOP Federally Enforceable State Operating Permit
FTE Full-time Equivalent
HAP Hazardous Air Pollutant
ICR Information Collection Request
MACT Maximum Achievable Control Technology
MOD Memorandum of Understanding
MSDS Material Safety Data Sheet
NESHAP National Emission Standard for Hazardous Air Pollutants
NOV Notice of Violation
OECA Office of Enforcement and Compliance Assurance
OMB Office of Management and Budget
P2 Pollution Prevention
PERC Perchloroethylene
PTE Potential to Emit
RACT Reasonably Available Control Technology
RCRA Resource Conservation and Recovery Act
RMP Risk Management Plan
SBA Small Business Administration
SBAP Small Business Assistance Program
SBDC Small Business Development Center
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SBO Small Business Ombudsman
SBREFA Small Business Regulatory Enforcement Fairness Act
SBTCP Small Business Stationary Source Technical and Environmental Compliance
Assistance Program
SIC Standard Industrial Classification
SIP State Implementation Plan
UST Underground Storage Tank
VOC Volatile Organic Compound
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman (SBO)
is pleased to submit this fourth 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 31,1998.
This report is being submitted in accordance with Section 507(d), Monitoring, of the Clean
Air Act, as amended in 1990 (CAA), which directs EPA to provide Congress with periodic
reports on the status of the SBTCPs. This oversight responsibility has been delegated by
the EPA Administrator to EPA's Small Business Ombudsman (SBO). The Report also
includes a general report on the EPA SBO's actions to monitor the SBTCPs.
This report addresses two of the EPA SBO's key oversight responsibilities:
Render advisory opinions on the overall effectiveness of the SBTCPs, difficulties
encountered, and degree and severity of enforcement [507(d)(1)].
• Make periodic reports to Congress on compliance of the SBTCPs with the
Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to
Justice Act [507(d)(2)].
The SBTCPs are designed to assist small businesses in complying with the requirements
of the CAA through state-operated programs. Each SBTCP is required to include three
components or functions: an SBO, a Small Business Assistance Program (SBAP), and a
Compliance Advisory Panel (CAP).
During this fourth year of monitoring the SBTCPs, over 1,000,000 small businesses have
been directly reached (as tallied by assistance efforts to specific industry sectors). This is
significantly higher than the 78,500 reported in 1997; a comparison, however, is not valid
due to the differing reporting formats between 1997 and 1998. In 1997, the number of
businesses assisted was counted by industry sector general and on-site assists only; other
types of assistance were not counted by industry sector. In 1998, the number of
businesses assisted was tallied both by industry sector and eight separate types of
assistance. The latter format more fully captures the true picture of businesses assisted
by the programs.
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SBTCP staff members continue to fill an important role as facilitator or mediator between
small business owners/operators and regulatory agencies, enhancing communication to
promote understanding and sensitivity on both sides. Based on the information reported,
improvements in compliance occur because businesses have someone to turn to for
assistance and advice, and to act as an effective liaison with regulatory agencies.
SBTCP yearly operational growth has stabilized over the past several years. As of the end
of 1998, 51 SBOs (96 percent), all 53 SBAPs (100 percent), and 43 CAPs (81 percent)
were operational. The SBO function is staffed with 2 or fewer full time equivalents (FTEs)
in 83 percent of the programs, and the SBAP function has 4 or fewer FTEs in 72 percent
of programs; these figures rose slightly from the last two years. Fifty-seven percent of
programs (compared to 58 percent last year) report that at least the required 7 members
have been appointed to their CAPs.
Budgets for the SBTCPs have a wide range from $16,000 to over $2,000,000 for 1998.
95 percent of SBOs (42 of 44) with their own budgets operate their programs with less than
$200,000. Similarly, of the 42 SBAPs with their own budgets, 86 percent are allotted less
than $400,000. As programs mature and the cost of establishing programs stabilize, more
programs are projecting fairly consistent budgets for the next reporting period (41 this year
versus 39 last year). The number of programs projecting budget increases has held steady
at six this year.
Ninety-one percent of SBTCPs provided specific information oh the types of industry
sectors and number of facilities that their programs assisted. Seventy-two industry sectors
received assistance in 1998 (the number of industry sectors has been standardized). The
top ten industry sectors receiving assistance by SBTCPs in 1998 were:
1. Cross Sector
2. Other (not classified)*
3. Organizations/Associations
4. Auto/Body Maintenance, Repair, Refinishing*
5. Government*
6. Printing/Graphic Arts*
7. Dry Cleaning/Laundry Services*
8. Recycling
9. Agriculture/Farming/Crop Service
10. Paints and Painting/Coatings.
* Also in the top ten in 1997.
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The top ten industry sectors that received assistance from the most programs were:
1. Dry Cleaning/Laundry Services (44 programs)*
2. Auto/Body Maintenance, Refinishing, Repair (44 programs)*
3. Printing/Graphic Arts (39 programs)*
4. Furniture Manufacturing/Repair/Wood Finishing (39 programs)*
5. Metal Fabricating/Finishing (21 programs)
6. Attorney/Consultant/Engineer (35 programs)
7. Government (34 programs)
8. Organizations/Associations (34 programs)
9. Chemicals/Products (33 programs)
10. Hospitals/Medical Health Services (33 programs).
These were the same top four industry sectors in 1997.
Toll-free hotlines, on-site visits, seminars, mailings, and publications are among the wide
range of outreach mechanisms used to serve the small business community. Other state-
of-the-art outreach activities, such as Internet home pages, are seeing increased use. The
number of programs with web pages more than doubled from 13 in 1995 to 28 in 1996,
rose in 1997 to 41 and to 48 in 1998.
New for 1998, programs also noted outreach strategies they found to be particularly
effective in assisting small businesses. At least ten programs each mentioned the
following strategies: workshops (20 programs), on-site visits and direct contact (19),
manuals/literature/newsletters (12), and direct mailings (11).
From year to year, programs have stressed the value of direct contact in building trust and
confidence in the business community. Because of their nature, on-site visits and
workshops typically reach fewer businesses than "mass" outreach strategies like mailings
and publications. However, programs indicate that the quality of the contacts made
through direct interaction between business owner and technical assistance provider can
lead to improved compliance.
While the CAA called for the establishment of SBTCPs for air-related issues, a number of
states began their programs as multimedia (offering assistance with water, solid and
hazardous waste, etc. in addition to air); more have transitioned their programs to
multimedia. Forty programs indicated they have a full or partial multimedia assistance
focus. Their small business clients need and expect it. Small businesses appreciate "one
stop shopping" for their compliance and technical assistance questions, rather than
working through numerous media-based departments.
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Thirty-nine of the 43 operational CAPs provided information on a variety of their
activities. Primary CAP activities were reviewing SBO/SBAP outreach efforts,
reviewing SBTCP documents for compliance, and defining CAP responsibilities. 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 SBTCP development. The value-added activities of these
CAP members underscore the need for states still without operational CAPs to
complete the appointment/reappointment process and initiate the CAP function.
Eighty-three percent of SBOs (up from 79 percent in 1997), 91 percent of SBAPs (the
same as 1997), and 51 percent of CAPs (up from 49 percent in 1997) 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.
All programs (as compared to 98 percent last year) report actions have been taken to
minimize duplication of efforts among SBTCPs. Sharing information is a practical
approach to maximizing program efficiency while enhancing the cost-effectiveness of
funding spent on individual programs.
Section 507 directs EPA's SBO to monitor the SBTCPs' efforts to follow the intent of
the provisions of the Paperwork Reduction, Regulatory Flexibility, and Equal Access
to Justice Acts.
Ninety-one percent of programs (as compared to 89 percent last year and 58
percent in 1996) report taking specific actions associated with the Paperwork
Reduction Act, with the most common action being receiving and providing
information electronically.
Eighty-nine percent of programs (the same as last year and up from 51 percent
in 1996) report taking specific actions consistent with the intent of the
Regulatory Flexibility Act. The primary activities by programs were reviewing
SBTCP documents for compliance and ensuring that small businesses could
participate in rulemaking.
Seventy-seven percent of SBTCPs (as compared to 75 percent last year and 34
percent in 1996) reported specific actions similar to those associated with the
Equal Access to Justice Act. These include the availability of funding or
technical assistance services for citizen groups aggrieved by permit actions of
a regulatory agency, the review of SBTCP documents for compliance, and the
review of instances where state actions against small businesses appear
unjustified.
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The number of programs reporting specific actions to follow the intent of the provisions of
these Acts has been growing since 1996. The steps being taken appear to be better
targeted to the specific intent of each Act and in addressing the unique needs of small
businesses.
As a new reporting element for 1998, programs were asked to define and prioritize their
own program goals. They also were asked to discuss strategies to evaluate their goals and
the results of this measurement process. Increasing understanding of environmental
obligations and improving compliance rates were the two most frequently listed goals. For
evaluation, most programs focused on the number of businesses reached and the types
of assistance offered to measure their success. Measuring compliance improvements as
a result of SBTCP assistance has been attempted by only a few states to date.
All SBTCPs provided insight on the types of compliance issues addressed during the
course of providing technical assistance to small businesses. The two most common
compliance problems mentioned by small businesses were, "Not understanding the
regulatory requirements," and "incomplete recordkeeping." The former has been the
number one compliance problem cited for the last three years. Compliance issues have
remained consistent from year to year. Identifying key problems and gaps in
understanding by the small businesses have helped the SBTCPs to best target their
assistance efforts.
Forty SBTCPs provided recommendations for changes to facilitate small business
compliance with the CAA. Since 1995, the most frequent recommendation was flexibility
in applying regulations to small businesses (25 percent of programs this year). Another
common recommendation mentioned by 23 percent of programs was for continued and
increased funding for the SBTCPs.
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. Ninety-one percent
of programs reported no problems concerning confidentiality or with conflict of interest
issues during the course of providing services regardless of whether a confidentiality policy
is in place. Program structures range from a guarantee of confidentiality (most common)
to offering no confidentiality. Many programs have policies that protect small businesses
from penalties if violations are discovered during the course of their receiving technical
assistance.
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As the final new reporting element for 1998, programs were asked how they used EPA's
Policy on Compliance Incentives for Small Businesses or a comparable state policy for
small businesses/small communities. Very few states are making use of this policy or
developing their own. Eighteen states indicated that either the EPA or a state policy has
been adopted, but only four states indicated the policy has been put to use. Programs
likely are not yet tracking such statistics, as evidenced by the high number of programs not
answering this question.
The SBTCPs offer important one-on-one contacts, provide valuable information such as
the need to have operating permits, maintaining records, compliance options, pollution
prevention technologies and techniques, and compliance requirements. This assistance
enables small businesses to arrive at informed decisions and more effectively come into
compliance.
CONCLUSIONS AND RECOMMENDATIONS
As has been noted since 1995, SBTCPs are being run by hardworking, dedicated
staffs who operate successful programs with what they report to be often limited
budgets and resources. Small businesses are grateful for the technical assistance
and personalized attention from people they can trust. In this fourth year of
gathering information from the programs, over 1,000,000 small businesses have
been reached (as tallied by industry sector).
SBTCPs facilitate dialog between the small business community and the regulatory
community, fostering trust, and improving attitudes and awareness towards
regulatory compliance.
SBTCPs have significant expertise and are increasingly becoming multimedia as
states want to offer this type of assistance, and small businesses are requesting it.
Programs are seeking ways to expand the scope and quality of the services they
offer and the means to fund the enhanced services. To maximize their budgets and
staffing capabilities and to minimize duplication of effort, programs are encouraged
to use the resources of the federal SBO and SBAP plus those developed by other
SBTCPs.
Commonly identified compliance problems include not understanding regulatory
requirements and improper recordkeeping. Many current SBTCP activities are
designed to remedy 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.
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In conducting the Federal program, EPA has followed the requirements of the
Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts.
EPA's SBO has monitored SBTCP activities for following the intent of the provisions
of these three Acts. The number of programs reporting specific activities associated
with these Acts has significantly increased in the past several years. 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. Allocation
of adequate resources to permit on-site visits by program staff is important. On-site
visits (as tallied by industry sector) increased to over 14,600 in 1998, up from almost
6,000 in 1997, and over 3,800 in 1996.
Efficiency of information transfer (among SBTCPs and to small businesses) can be
realized through the increased use of Internet home pages. Presently, 91 percent
of programs operate a home page, up from 77 percent last year and 53 percent in
1996. Such electronic services also would be promising mechanisms to avoid
duplication of effort among programs. Programs again are encouraged to explore
the potential of the Internet for sharing information with small businesses and with
other SBTCPs.
Only 21 percent of SBTCPs reported the availability of financial assistance
programs in 1998, up from 13 percent last year. Small businesses have expressed
their need for creative financing mechanisms. Programs are encouraged to explore
the potential for sponsoring or facilitating financial assistance programs for pollution
control or pollution prevention capital expenses.
SBTCPs report that they are often underfunded and understaffed as they provide
their current level of services. Because of this, they may be challenged to expand
their function both in air-related outreach and multimedia technical assistance.
SBTCPs are encouraged to better utilize the expertise of their CAP members to
enhance improvements in their technical assistance programs. As has been noted
in the three previous Reports, several states still do not have operational CAPs. A
number of CAPs also need to address vacancies of the CAP due to expired terms.
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1.0 INTRODUCTION AND REPORT OVERVIEW
1.1 RATIONALE AND OBJECTIVE OF THE REPORT TO CONGRESS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
pleased to submit this Report to Congress describing the accomplishments and activities
of the state/territory Small Business Stationary Source Technical and Environmental
Compliance Assistance Programs (SBTCPs) during the January 1 - December 31,1998
reporting period.
This is the fourth 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 (CAA) as amended in 1990.
This report is submitted in accordance with Section 507(d), Monitoring, of the CAA, which
directs EPA to provide Congress with periodic reports on the SBTCPs. 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
SBTCPs.
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
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 applied for Information Collection Request (ICR) Approval from
the Office of Management and Budget (OMB) for the Reporting Form. The Form
subsequently was approved and was assigned OMB Number 2060-0337, expiration date
July 31,1998.
In June 1998, the EPA SBO submitted a request for ICR renewal. State program
representatives conducted a lengthy review and revision process of the Reporting Form.
Questions were streamlined, several redundant and less pertinent questions were
eliminated, and other questions were added at the request of the states. OMB approved
the renewal request, and the Form was assigned OMB Number 2060-0337, expiration date
September 30, 2001.
In December 1998, EPA's SBO distributed copies of the SBTCP Annual Reporting Form
(for the reporting period January through December 1998) to state/territory SBTCP
contacts (primarily SBOs). These contacts were requested to coordinate completion of this
Form among their SBO, SBAP, and CAP. The 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 1998 SBTCP Reporting Form is enclosed as Appendix A.
Programs were not asked to create information that they did not have; therefore, some
SBTCPs were not able to answer all questions posed. Based on the information requested
in the Reporting Form from the first year of reporting, programs were encouraged to revise
the types of statistics they track in subsequent years to simplify completing future reports.
Programs were asked to complete and submit the Form to the EPA's SBO by February 15,
1999. 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 1998 SBTCP Reports (53 programs total) to EPA's SBO.
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In addition, Arizona, California, and Kentucky have distinct air quality districts or counties
with regulatory jurisdiction within their states, which also submitted full or partial reports.
In Arizona, Maricopa County submitted a separate report. For California, the South Coast
Air Quality Management District submitted a full report For Kentucky, Jefferson County
submitted a report. For statistical purposes of this report, data from states that submitted
multiple reports have not been combined except where noted. Raw data for the separate
air quality districts are shown in the appendices. Percentages have been rounded.
According to the Federal Register of November 13,1996, Volume 61, Number 220, Pages
58284-94, EPA promulgated a direct final rule conditionally exempting the Territory of
American Samoa, the Commonwealth of the Northern Mariana Islands (CNMI), and the
Territory of Guam from the requirements of Title V of the CAA. Therefore, reports were not
received from American Samoa, CNMI, and Guam.
1.3 ORGANIZATION OF THE REPORT
As detailed below, this report is organized into six main sections, the Executive Summary,
and Appendices.
Section 1.0
Section 2.0
Section 3.0
Section 4.0
Introduction and Report Overview
Overview of the SBTCP - This section provides an overview of the
three components of the SBTCP (i.e., the SBO, the SBAP, and the
CAP) as well as EPA's responsibilities under Section 507.
SBTCP Status, Budgets, Staffing, and Organization - This section
encompasses these four categories of information about the SBTCPs.
SBTCP Activities and Services - In this section, assistance to
industry sectors and the types and levels of services provided by the
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 -- Program goals and evaluation strategies
are discussed. General information on some of the accomplishments
and highlights of the programs in 1998 are outlined. Program tips and
barriers plus success stories and case studies also are included.
Section 6.0 Compliance Assurance Issues - Information on the effectiveness
of the SBTCPs in providing compliance assistance support to state
small businesses is provided in this section. Recommendations to
facilitate compliance and confidentiality issues are discussed. Finally,
programs report on their use of EPA's Small Business/Small
Communities Policy.
Additional details on the information provided by the individual SBTCPs are included in the
various appendices to this report.
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2.0 OVERVIEW OF THE SBTCP
As part of Section 507 of the CAA, the U.S. Congress mandated that each state/territory
establish a SBTCP to assist small businesses comply with the requirements of this Act
through state-operated programs. Each SBTCP (also commonly referred to as a "Section
507 program") is required to include the following three components or functions:
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, 1998, 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 officially
submitted and/or approved are:
Hawaii - not yet submitted
Rhode Island - submitted, but not approved
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:
Reviewing and provide recommendations to EPA and state/local air pollution control
authorities regarding development and implementation of regulations impactinq
small businesses.
Assisting in dissemination of information about upcoming air regulations control
requirements, and other matters relevant to small businesses.
Referring small businesses to appropriate specialists for help with specific needs.
Conducting studies to evaluate the effects of the CAA on state and local economies,
and on small businesses generally.
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2.2 SMALL BUSINESS ASSISTANCE PROGRAM
The SBAPs provide information and assistance to small businesses on matters of:
Determining applicable requirements under the Act and permitting assistance
The rights of small businesses under the Act
Compliance methods and acceptable control technologies
Pollution prevention and accidental release prevention and detection
Audit programs.
2.3 COMPLIANCE ADVISORY PANEL
The CAPs are created at the state level and are comprised of at least seven members:
2 members who are not owners of small business stationary sources - selected by
the Governor to represent the public.
• 2 members who are owners of small business stationary sources — selected by the
lower house of the state legislature.
• 2 members who are owners of small business stationary sources - selected by the
upper house of the state legislature.
1 member from the state air pollution permit program - selected by the head of that
agency.
The responsibilities of the CAP are to:
Render advisory opinions concerning the effectiveness of the SBTCP, difficulties
encountered, and degree and severity of enforcement.
Report on the compliance of the SBTCP with the intent of 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)j.
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)].
Have the federal SBAP serve as the secretariat for the development and
dissemination of reports and advisory opinions [507(d)(4)].
Further information on the activities and accomplishments of EPA's Office of the Small
Business Ombudsman may be found in Appendix B.
2.5 FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM
EPA, through the Federal SBAP, provides technical guidance for the use of the SBTCPs
in the implementation of their programs. Information on the activities of the Federal SBAP
may be found in Appendix C.
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3.0 SBTCP STATUS, BUDGETS, STAFFING,
AND ORGANIZATION
Information on the operating status (Section 3.1), budgets (Section 3.2), staffing levels
(Section 3.3), and the administrative location of the three components of the SBTCPs
(SBOs, SBAPs, and CAPs) within their states/territories (Section 3.4) for the January -
December 1998 reporting period may be found in this chapter.
A listing of state/territory Ombudsman, SBAP, and alternate SBAP contacts is included in
Appendix D-1.
3.1 OPERATING STATUS
Importantly, by December 31, 1998, 51 SBOs (96 percent of the 53 states and U.S.
territories) and all 53 SBAPs (100 percent) had been established and were providing
assistance to small businesses. Only 43 programs reported that their CAPs were
operating; however, 45 programs reported that their CAPs had been established.
The number of established and operational SBOs increased by one to 51 since holding at
50 from 1995 to 1997. The number of established and operational SBAPs is now complete
at 53 for the first time. Two new CAPs were established in 1998, but the number of
established CAPs remains at 45; some states have amended previously reported dates.
Four CAPs became operational in 1998 (43 in 1998 versus 39 in 1997).
Operating status for each of the three components of the SBTCPs is shown in Table 3-1;
programs whose SBOs, SBAPs, and CAPs are not yet established or operational also are
identified.
3-1
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TABLE 3-1
OPERATING STATUS OF THE SBTCP COMPONENTS
SBO2
SBAP
CAP3
COMPONENTS ESTABLISHED1
# Programs
51
53
45
% Programs
96
100
85
COMPONENTS OPERATIONAL1
# Programs
51
53
43
% Programs
96
100
81
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 12/31/98, SBOs were reported not to be established or operating in Massachusetts or Vermont.
Note 3: As of 12/31/98, CAPs were reported not to be established or operating in 8 programs: California, Hawaii,
Iowa, Maryland, Massachusetts, Rhode Island, Tennessee, or the Virgin Islands. In addition, Arizona
reported that their CAP had been established, but was not yet operating. Alabama did not provide
operational data for its CAP.
Details on when the SBOs, SBAPs, and CAPs were reported to be established and
operational may be found in Appendix D-2. A summary of the start of operations for the
three SBTCP functions is shown in Table 3-2.
TABLE 3-2
START OF OPERATIONS FOR SBTCP FUNCTIONS
Pre-1990
1991
1992
1993
1994
1995
1996
1997
1998
% operational by
12/31/98
SBO
Number
11
20
10
7
2
1
Total
11
31
41
48
50
51
96%
SBAP
Number
1
1
12
16
16
5
1
1
Total
1
2
14
30
46
51
52
53
100%
CAP
Number
1
8
12
11
4
3
4
Total
1
9
21
32
36
39
43
81%
3-2
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3.2 BUDGETS
Information about the total SBTCP operating budgets may be found in Section 3.2.1, with
details on the SBO, SBAP, and CAP budgets contained in Sections 3.2.2, 3.2.3, and 3.2.4,
respectively.
3.2.1 1998 Reporting Period
As detailed in the paragraphs and tables below, the total operating budgets for the
SBTCPs varied from $16,000 (District of Columbia) to over $2,000,000 (New York) for the
1998 reporting year. 1998 operating budget ranges for the SBTCPs are shown m Table
3-3; 1997 and 1996 ranges also are shown for comparison. Details on the operating
budgets, by program, for the individual SBO, SBAP, and CAP components, including the
source of these funds, may be found in Appendix D-3.
3-3
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TABLE 3-3
1998, 1997, and 1996 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
>1,000,0002
>2,000,0003
Report submitted, no
data provided
TOTAL
1998
#
Programs
8
15
10
9
4
3
1
1
1
1
53
%
Programs1
15
28
19
17
8
6
2
2
2
2
1997
#
Programs
10
15
7
12
3
1
1
1
1
1
1
53
%
Programs1
19
28
13
23
6
2
2
2
2
2
2
1996
#
Programs
1
9
19
5
9
2
2
1
2
1
1
1
53
%
Programs1
2
17
36
9
17
4
4
2
4
2
2
2
Note 1: County budgets are not combined with state budgets, nor are they counted separately.
Note 2: Texas (1997 and 1996).
Note 3: New York (1998, 1997, and 1996).
Note 4: Hawaii (1997, 1996).
3.2.2 Comparison of Previous and Projected Budgets
A comparison of budgets from 1997, 1998, and 1999 (projected) is valuable in tracking
program growth and resource allocation. Programs were asked to indicate significant
budget changes (greater than ten percent) from year to year and to provide insight into any
major shifts (more than ten percent) in funding levels. SBTCP reporting period budget
comparisons are shown in Table 3-4.
3-4
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TABLE 3-4
SBTCP REPORTING PERIOD BUDGET COMPARISONS
1997to
1998
Reporting
Period
1998to
1999
Reporting
Period
BUDGET DECREASE
(> 10% change)
#
Programs
4
4
%
Programs
8
8
BUDGET CONSISTENT
(< 10% change)
#
Programs
38
41
%
Programs
72
77
BUDGET INCREASE
(> 10% change)
#
Programs
11
6
%
Programs
21
11
INSUFFICIENT DATA
FOR COMPARISON1
ff
Programs
0
22
%
Programs
0
4
Note 1: Not all programs provided budget amounts. In order to establish trends, combined budgets for the SBO, SBAP,
and CAP were examined. This was necessary, as some programs indicate combined budgets for two or three
facets of their programs, while other programs may have had one or two facets of their programs inactive during
the previous reporting period.
Note 2: New York, Wisconsin.
In reviewing the combined budgets for the SBO, SBAP, and CAP functions of the SBTCPs,
11 programs (21 percent) indicated a budget increase (of at least ten percent) from the
1997 to 1998 reporting periods. Six programs (11 percent) showed an increase from the
1998 to 1999 reporting periods.
As programs mature and the cost of establishing programs stabilizes, more programs are
projecting fairly consistent budgets for the next reporting period (41 this year as compared
to 39 last year). The number of programs projecting a budget increase for the subsequent
reporting period held steady at six this year.
According to responses received, projected budget increases primarily were related to the
growth and expansion of SBTCP services and staff additions. Examples of reasons given
for budget increases greater than ten percent are provided below:
Michigan's funding is based on collected air permitting fees from the state's Title V
program. In 1998, the fee structure was increased to begin supporting FY 98-99.
Both SBO and SBAP will experience an increase in funding of 26.6 percent and
28.9 percent, respectively, beginning 10/1/98. ($487,700/1998 to $627,300/1999)
In Ohio's SBAP, no new employees were hired in 1998. The 1999 projected budget
reflects an allowance for one more staff member. In addition, a significant part of
the 1998 supervisor's salary was charged to another program due to temporary
transfer. ($437,000/1998 to $539,000/1999)
Utah's EPA Partnership for Compliance Grant has introduced substantial contract
funds that have not been obligated due to the lengthy planning process. These
funds will be obligated by September 1999. ($204,000/1998 to $237,000/1999)
3-5
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Thirty-eight programs (72 percent) report steady budget levels (less than a ten percent
change) for the 1997 to 1998 reporting periods, and 41 programs (77 percent) indicate
consistent budget levels from the 1998 to 1999 (projected) reporting periods.
Four programs (8 percent) showed a decrease (more than ten percent) from the 1997 to
1998 reporting periods, and four programs (8 percent) also projected a decrease from the
1998 to 1999 periods. Budget reductions often are attributed to program reorganizations
and consolidations, expiration of grant funds, and lower projected costs to maintain a
program (versus the higher resource requirements to develop a program).
Eighty-eight percent of the programs reported either a consistent or increasing budget from
the 1998 to 1999 (projected) reporting periods.
Budgets for the 1997,1998, and 1999 (projected) reporting periods for the SBO function,
SBAP function, and CAP function may be found in Appendix D-4.
3.2.3 SBO Operating Budgets
Forty-four SBOs have their own budgets (versus having their budgets combined with other
SBTCP functions). Budgets for these SBOs are concentrated in a range below $200,000,
with 42 of 44 SBOs (95 percent) reporting budgets between $0 and $200,000. (The two
exceptions are New York's SBO, who reports a budget of $1,170,000 and Ohio's at
$208,000.) The primary source of funding for all programs is Title V fees (55 percent),
which are collected at the state/territory level. Other sources of funding include RCRA
grant funds, permit and other fees, EPA grants, and state general funds.
The range of 1998 operating budgets for the SBOs with their own budgets is shown in
Table 3-5. A comparison of SBO budgets for the past three years is not practical, as a
different number of SBOs have had their own budgets each year.
3-6
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TABLE 3-5
1998 SBO OPERATING BUDGET RANGES
(44 non-combined budgets)
Budget ($)
0 - 25.0001
25,001 - 50,000
50,001 - 75,000
75,001 - 100,000
100,001 -200,000
200,001 - 300,000
>1, 000,000
Combined budgets2
Report submitted, no data provided3
TOTAL
# Programs
12
9
8
6
7
1
1
8
1
53
% Total Programs
23
17
15
11
13
2
2
15
2
Note 1: An answer of N/A or "as needed" was counted as "zero" if SBO was administratively assigned their own budget.
Note 2: Eight SBOs have combined budgets. If a program combined the budget for two SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the budget
of the third component of the program also was tallied separately (e.g.. a program reporting a combined
SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for the SBO/CAP
budget and with SBAPs for the SBAP budget).
Note 3: Puerto Rico.
3.2.4 SBAP Operating Budgets
Forty-two SBAPs have their own budgets. SBAP budgets are spread across a wider dollar
range as compared to the SBOs with 12 of 42 programs (29 percent) between $0 and
$100,000,12 of 42 programs (29 percent) between $100,001 and $200,000, and 7 of 42
programs (17 percent) between $200,001 and $300,000. Budgets range from $8,000
(District of Columbia, which is closely followed by South Dakota at $10,000) to a high of
$1,000,000 for New York. Title V fees again are the main funding source (64 percent of
all programs); funds from EPA grants, permit and other types of fees, and general
revenues also are used to support SBAPs.
The range of 1998 operating budgets for the SBAPs with their own budgets is shown in
Table 3-6. A comparison of SBAP budgets for the past three years is not practical, as a
different number of SBAPs have had their own budgets each year.
3-7
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TABLE 3-6
1998 SBAP OPERATING BUDGET RANGES
(42 non-combined budgets)
Budget ($)
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
500,001 - 600,000
600,001 - 700,000
1.000,000
Combined budgets1
TOTAL
# Programs
2
3
5
2
12
7
5
3
1
1
1
11
53
% Total Programs
4
6
9
4
23
13
9
6
2
2
2
21
Note 1: Eleven SBAPs have combined budgets. If a program combined the budget for two SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the budget
of the third component of the program also was tallied separately (e.g., a program reporting a combined
SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for the SBO/CAP
budget and wifh SBAPs for the SBAP budget).
3.2.5 CAP Operating Budgets
Forty-one CAPs have their budgets calculated separately, ranging from $0 to a high of
$10,000 (two programs, Montana and Wyoming). Eighty-eight percent of CAPs with their
own budget operate with $5,000 or less. Title V fees are the most commonly listed funding
source for all CAPs (43 percent).
The range of 1998 CAP operating budgets is shown in Table 3-7. A comparison of CAP
budgets for the past three years is not practical, as a different number of CAPs have had
their own budgets each year.
3-8
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TABLE 3-7
1998 CAP OPERATING BUDGET RANGES
(41 non-combined budgets)
Budget ($)
O1
1 - 1 ,000
1 ,001 - 2,000
2,001 - 3,000
3,001 - 4,000
4,001 - 5,000
10,000
Combined budgets2
Report submitted, no data provided3
TOTAL
# Programs
15
5
3
7
1
8
2
9
3
53
% Total Programs
28
9
6
13
2
15
4
17
6
Note 1: CAPs reporting "N/A" or "as needed" also were counted as "0" if they administratively were assigned their own
budgets.
Note 2: Nine CAPs have combined budgets. If a program combined the budget for two SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a combined budget. However, the budget
of the third component of the program also was tallied separately (e.g., a program reporting a combined
SBO/CAP budget and a separate SBAP budget was tallied in the "combined budget category" for the SBO/CAP
budget and with SBAPs for the SBAP budget).
Note 3: Alabama, Arizona, Puerto Rico.
3.3 STAFFING LEVELS
Forty-four programs (83 percent) report operating their SBOs with two or fewer full-time
equivalents (FTEs) as shown in Table 3-8. This number has increased from 41 in 1997.
In 1998 38 programs (72 percent) operated their SBAPs with four or fewer FTEs (up from
37 programs in 1997), which include both paid and unpaid staff and may include retired
engineers. There are some notable exceptions to these staffing levels, such as Louisiana,
Indiana, and California, which report using 10,12, and 20 FTEs, respectively, to support
their SBAP function. Also, Texas reported the services of over 50 unpaid "EnviroMentors"
who assist with SBAP duties, for 84.50 FTEs supporting Texas' SBAP.
Specific details on the number of FTEs, by program, for the SBO and SBAP functions may
be found in Appendix D-5.
3-9
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TABLE 3-8
1998 STAFFING LEVELS (as FTEs1) SERVING THE SBO & SBAP FUNCTIONS
#FTEs
0 - 0.09
0.1 -1
1.1 -2
2.1 -3
3.1 -4
4.1 -5
5.1 -6
6.1 -7
7.1 -8
10
12
14.5
20
84.5
N/A3
TOTAL
# Programs
SBO
2
30
12
4
1
1
1
1
52
SBAP
3
9
11
10
5
4
2
1
3
1
1
1
1
52
Combined Staffing2
1
1
Note 1: An FTE is considered to work 40 hours/week. For example, two people working 20 hours/week would be
equivalent to one FTE.
Note 2: Florida combined its SBO and SBAP functions.
Note 3: Not applicable: SBO-Massachusetts.
Thirty programs (57 percent), compared to 31 last year, report that at least the required
seven members have been appointed to their CAPs. An overview of CAP appointments
is shown in Table 3-9. In CAPs with fewer than seven members, several programs
indicated that expired terms on their CAPs have not yet been filled or that their CAPs have
not yet been established. Program statistics of the number of CAP members in each
category (small business, state agency, general public, not yet appointed, other) may be
found in Appendix D-6.
3-10
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TABLE 3-9
CAP APPOINTMENTS
Minimum 7 members appointed
Less than 7 members appointed
Not applicable1
# Programs
30
18
5
% Programs
57
34
9
Note 1: Hawaii, Maryland, Massachusetts, Minnesota, Virgin Islands.
3.4 ADMINISTRATIVE LOCATION OF SBO AND SBAP COMPONENTS
As shown in Table 3-10, 51 programs indicated that their SBOs are located within a
state/territory-related agency, typically the environmental agency. The majority of
programs (50) report to have located their SBAPs within a state/territory-related agency,
typically the environmental agency. Three programs (Kansas, Kentucky, and
Pennsylvania) contract their SBAP function to an outside agency or organization. As
defined in Section 507, the CAPs are to be independent entities, operating outside of any
agency.
TABLE 3-10
ADMINISTRATIVE LOCATIONS OF SBO AND SBAP
Location
State-related agency
University-related (contracted)
Private contractor
Not applicable1
TOTAL
SBO
# Programs
51
2
53
% Programs
96
4
SBAP
# Programs
50
2
1
53
% Programs
94
4
2
Note 1: Massachusetts, Vermont.
As indicated in Table 3-11,22 SBOs are located in a regulatory section within their agency,
while 29 SBOs are housed in a nonregulatory section. Twenty-seven SBAPs reported their
location in a regulatory section, 24 indicated nonregulatory, and 2 programs reported
association with both regulatory and nonregulatory offices.
3-11
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TABLE 3-11
REGULATORY / NONREGULATORY LOCATIONS OF SBO AND SBAP
Regulatory
Nonregulatory
Mixed1
Not applicable/Not established2
TOTAL
SBO
# Programs1
22
29
2
53
% Programs
42
55
4
SBAP
# Programs
27
24
2
53
% Programs
51
45
4
Note 1: Massachusetts, Montana.
Note 2: Massachusetts, Vermont.
Complete information for the administrative location of each SBO, SBAP, and CAP may
be found in Appendix D-7.
3-12
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4.0 SBTCP ACTIVITIES AND SERVICES
Information regarding the activities and services of the SBTCPs is provided in this section.
Industry sectors assisted by the SBTCPs are discussed in Section 4.1. An overview of
SBTCP activities and services is provided in Section 4.2. SBTCP assistance requests are
outlined in Section 4.3. CAP activities are outlined in Section 4.4. Financial assistance
programs are described in Section 4.5 A discussion of how programs minimize duplication
through cooperative efforts may be found in Section 4.6. SBTCP efforts to comply with the
intent of the Paperwork Reduction Act, Regulatory Flexibility Act, and the Equal Access to
Justice Act are summarized in Section 4.7.
For the 1998 reporting year, information on SBTCP services to specific industry sectors
was gathered under a new format designed to make the resulting data more complete and
meaningful. Please refer to the Reporting Form in Appendix A for the questions pertaining
to program activities and services (Section 3).
4.1 INDUSTRY SECTORS ASSISTED BY THE SBTCPs
Programs were asked to report on their assistance to 72 industry sectors in eight
assistance categories. The industry sectors and assistance services into which programs
could categorize their efforts have been standardized for 1998. Not all states kept
information as to industry sectors assisted or total assists provided. Notes on data
calculation are included with the various data tables in the appendices.
All 53 SBTCPs (100 percent) provided information on the types of industry sectors and
number of facilities that their programs assisted in 1998; data from county and air district
programs were included with their state's activities.
The top ten industry sectors receiving SBTCP assistance (by number of assists) in 1998
are shown in Table 4-1.
4-1
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TABLE 4-1
TOP 10 INDUSTRY SECTORS ASSISTED
Industry Sector
Cross Sector
Other (not classified)*
Organizations/Associations
Auto/Body Maintenance, Repair, Refinishing*
Government*
Printing/Graphic Arts*
Dry Cleaning/Laundry Services*
Recycling
Agriculture/Farming/Crop Services
Paints & Painting/Coatings
# Assists
1,105.387
436,145
159,846
38,454
22,615
20,337
15,310
13,480
8,643
8,243
Note *: Also in the top 10 in 1997.
The top 10 industry sectors that received assistance from the most programs are shown
in Table 4-2.
TABLE 4-2
TOP 10 INDUSTRY SECTORS ASSISTED BY PROGRAMS
Industry Sector
Dry Cleaning/Laundry Services*
Auto/Body Maintenance, Refinishing, Repair*
Printing/Graphic Arts*
Furniture Manufacturing/Repair/Wood Finishing*
Metal Fabricating/Finishing
Attorney/Consultant/Engineer
Government
Organizations/Associations
Chemicals/Products
Hospitals/Medical Health Services
# Programs
44
44
39
39
37
35
34
34
33
33
Note *: These industry sectors held the same rankings as in 1997.
4-2
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A list of businesses reached by industry sector may be found in Appendix E-1. This same
list also has been reordered by the number of states providing assistance (Appendix E-2).
A summary of individual program responses may be found in Appendix E-3.
New for the 1998 reporting year, programs were asked if they targeted any specific industry
sectors for assistance. Forty-seven programs (89 percent) indicated they focused on
certain high priority industries. Of the 38 industries mentioned, the following sectors were
targeted by at least five programs, as shown in Table 4-3.
TABLE 4-3
INDUSTRY SECTORS TARGETED FOR ASSISTANCE
Industry Sector
Dry Cleaning/Laundry Services
Printing/Graphic Arts
Auto/Body Maintenance, Refinishing, Repair
Manufacturing (various)
112(r) Affected
Metal Fabricating/Finishing
Wood Finishing
Paints & Painting/Coatings
# Programs
22
22
18
7
6
5
5
5
4.1.1 Total Businesses Assisted
As tallied by industry sector, SBTCPs reported they assisted 1,002,446 businesses in
1998. This is significantly higher than the 78,565 reported for 1997; however, a
comparison may not be valid due to the differing reporting formats between 1997 and
1998. In 1997, the number of businesses assisted was counted by industry sector general
and on-site assists only; other types of assistance were not counted by industry sector.
In 1998, the number of businesses assisted was tallied both by industry sector and eight
separate types of assistance. The latter format more fully captures the true picture of
businesses assisted by the programs. Also, many programs have improved their
recordkeeping strategies, resulting in higher quality and more comprehensive data.
When studying the data, several points should be considered. In general, "total
businesses reached," as reported by each Section 507 program, is used as the "official"
4-3
-------
count for this report. Seventeen programs tried not to double count the number of
businesses assisted within a given industry sector. Seven programs did not keep data by
industry sector, and only "total businesses reached" was given. Four programs tracked the
types of services they offered or the industry sectors they assisted, but did not compile
data. One program elected to exclude over 950,000 publications in their "total businesses
reached" tally; these publications are reflected in the sector totals, but not in the overall
number of businesses reached.
A tally of "total businesses reached," as reported by each program, may be found in
Appendix E-4.
4.2 SBTCP ACTIVITIES AND SERVICES
An overview of activities and services provided by the SBTCPs is discussed in this section.
For 1998, programs were asked to provide information about their services separately from
the types of assistance requests they received.
4.2.1 Outreach Activities and Businesses Reached
The number of programs offering specific outreach services plus an aggregate of the
number of businesses reached through these services in 1998 is presented in Table 4-4.
These outreach activities and services are designed to introduce small business people
to the available assistance services and to identify common problems and issues to be
addressed on a more specific basis.
For 1998, programs reported their outreach statistics for their SBO, SBAP, and CAP
combined. Information was requested by the type of assistance (e.g., hotline, on-site visit,
etc.) and by industry sector served. With this reporting year, the types of outreach
activities and industry sectors on which programs could report were standardized.
4-4
-------
TABLE 4-4
OUTREACH ACTIVITIES AND BUSINESSES REACHED
(by number of programs offering)
ACTIVITY
Hotline
On-site visits
Seminars/Workshops
Mailings
Publications
Other
Teleconferences
Home page2
# Programs
51
51
49
44
43
32
24
22
% Programs
96
96
92
83
81
60
45
42
Total Businesses
Reached1
53,000
14,646
36,050
254,121
1,491,709
75,709
954
136,694
Note 1: Total businesses reached" is tallied using industry sector assistance data. Some programs tried not to double
count. For example, if one printer called a hotline 5 times, one program may count this as 5, while another
program may count as 1. Therefore, "total businesses reached by industry sector will not equal total
businesses reached by type of assistance.
Note 2: 48 programs reported having web sites under the question directly addressing this issue.
The most common outreach activities, offered by over 90 percent of programs, were:
Hotline
• On-site visits.
• Seminars/workshops.
Such activities remain as some of the most common services offered by the programs from
year to year.
Detailed information, by program, about the number of occurrences and the number of
businesses reached by each reported activity is presented in Appendix E-5.
4.2.2 New Publications
As noted above, more businesses were reached through publications than through any
other method. Forty-three programs reported outreach to 1,491,709 business through
publications. Programs were asked to provide a list of new documents they prepared in
1998, which may be found in Appendix E-6.
4-5
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Examples of the types of publications produced include:
Fact sheets
Manuals
Assistance request forms
Emission calculation worksheets
Brochures
Resource guides and directories
Drycleaners' calendar
Training workbooks and checklists
Permit guides
Newsletters
Posters
Annual reports
Technical papers
Generic compliance plans.
4.2.3 Notable Outreach Strategies
Also new for 1998, programs were asked to note outreach strategies they found to be
particularly effective in assisting small businesses. Of the 24 strategies noted by the 47
programs (89 percent) that answered this question, the following received mention by at
least 10 programs, as shown in Table 4-5.
TABLE 4-5
NOTABLE OUTREACH STRATEGIES
Outreach Strategy
Workshops
On-site visits/direct contact
Manuals/literature/newsletter
Direct mailings
# Programs
20
19
12
11
From year to year, programs have stressed the value of direct contact - primarily via on-
site visits, but also through workshops — in building trust and confidence in the business
community. Because of their nature, on-site visits and workshops typically reach fewer
businesses than "mass" outreach strategies like mailings and publications. However,
programs indicate that the quality of the contacts made through direct interaction between
business owner and technical assistance provider can lead to improved compliance.
Effective outreach strategies as noted by each program may be found in Appendix E-7.
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4.2.4 Internet Web Pages
Of particular note is the ever-growing number of programs that are using Internet web
pages to disseminate technical assistance information. (Programs are no longer reporting
use of electronic bulletin board services. In 1997, only six bulletin boards were operating
in conjunction with a program's home page.) Forty-eight programs (91 percent) currently
operate home pages, up from 41 in 1997 and 28 in 1996.
The types of information available on these home pages are listed in Table 4-6; detailed
information on the home pages, including web site address, usage, and comments
received, may be found in Appendix E-8.
TABLE 4-6
INFORMATION AVAILABLE ON INTERNET HOME PAGES
Type of Information
Program description
Contact listings
Links
Permitting information
Permit forms
Regulations
Pollution prevention information
Guidance documents/fact sheets
Multimedia
List of publications
Calendar of events .
Policies
Emissions inventory
CAP information
Other
# Programs
46
45
40
40
37
35
35
34
31
27
26
26
15
15
13
% Programs
87
85
75
75
70
66
66
64
58
51
49
49
28
28
25
* Programs without web sites: District of Columbia, Hawaii, New Hampshire, Puerto Rico, and Virgin Islands.
A number of programs provided information on comments they have received about their
web sites. A sampling of responses is shown below.
4-7
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• Alaska reports their program has not received very many feedback responses via
the Internet. One person indicated he had a hard time finding information on the
web pates. SBAP is working with the Governor's Small Business Council to provide
easier web site access to the broad range of small business services offered in
Alaska.
• California's web site has a contact button. The program receives praise for its web
site, particularly for the meta tags that enhance finding information using search
words. Their search engine hit percentage is 90 percent.
• Kansas indicated their feedback has been exclusively positive and extremely
complementary. They often get OSHA questions, which they refer to appropriate
agencies.
• In Texas, feedback includes technical questions about compliance issues for
various industries, available publications, and how to participate in the EnviroMentor
program.
• Web site users in Washington want to complete registration and application forms
electronically.
Internet home pages are efficient mechanisms for SBTCPs to disseminate information to
small businesses, as evidenced by the increasing use of electronic media over the last
three years. Because the Internet is practical for information transfer from the federal SBO
and SBAP, between programs, and to the small business community, increased access
to the Internet and expanded web page content should continue to be pursued.
4.3 ASSISTANCE REQUESTS
4.3.1 Air-only Versus Multimedia Assistance
Section 507 of the CAA calls for the establishment of technical assistance programs for air-
related issues. However, a number of states began their programs as multimedia (offering
assistance with water, solid waste, hazardous waste, etc. in addition to air) and more have
since transitioned their programs to multimedia assistance, as shown in Table 4-7.
TABLE 4-7
AIR-ONLY VERSUS MULTIMEDIA ASSISTANCE
Assistance Focus
Multimedia
Air-only
Mixed
# Programs
38
13
2*
%Programs
72
25
4
Hawaii's and West Virginia's SBOs offer multimedia assistance. Their SBAPs offer air-only assistance.
4-8
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More and more programs are offering multimedia assistance, because their small business
clients need it and expect it. Small businesses appreciate "one stop shopping" for their
compliance and technical assistance questions, rather than working through numerous
media-based departments.
Each program's assistance focus is shown in Appendix D-1.
4.3.2 Types of Assistance
With this consideration, as a new element for the 1998 reporting year, SBTCPs were asked
for data on the type of assistance requested (e.g., regulatory information, permitting,
record keeping, etc.). Programs could indicate the number of CAA-related requests and
the number of multimedia requests for assistance.
Forty-one programs (77 percent) provided data on CAA/multimedia assistance requests.
These data are summarized in Table 4-8. Individual program responses may be found in
Appendix E-9.
TABLE 4-8
CAA/MULTIMEDIA ASSISTANCE REQUESTS
Type of Assistance Requested
Compliance/Regulatory Information
Monitoring
Recordkeeping
Financial/Funding Information
Permitting
General CAA Information
Add to Mailing List
P2 Assistance
Other
TOTAL REPORTED REQUESTS*
CAA Requests
14,197
1,570
2,376
702
8,217
4,258
1,308
1,663
2,680
35,703
Multimedia
Requests
7,275
137
397
573
911
542
79
1,253
4,027
17,013
Total Requests
21,472
1,707
2,773
1,275
9,128
4,800
1,387
2,916
6,707
56,220
Note *: Total requests are as reported by the programs. Numbers will not add up, since some programs merely
indicated they provided a certain type of assistance, but did not provide data. Some did not nave data by
assistance type, but did provide totals.
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Requests for compliance/regulatory information far outnumbered any other type of
assistance request at 21,472. Permitting information received 9,128 requests followed by
"other" types of information at 6,707.
Businesses made over twice as many CAA-related requests for information than they did
for multimedia — 35,703 as compared to 17,013. CAA assistance outnumbered multimedia
assistance in every assistance category except for "other."
Such data are not surprising, since the SBTCPs were established to provide CAA
assistance. Since 40 programs (75 percent) indicate they provide full or partial multimedia
assistance, multimedia requests are expected to rise in the coming years.
4.4 CAP ACTIVITIES AND SERVICES
Forty-three CAPs indicated they were operational during the 1998 reporting period, 39 of
which reported activities. The primary CAP activities were review of SBO/SBAP outreach
efforts (33 CAPs) and review of SBTCP documents for compliance (28 CAPs). This was
followed by defining CAP responsibilities (reported by 25 CAPs). These were the same
prime activities as 1997.
Major activities of the CAPs during the 1998 reporting period are shown in Table 4-9. A
program summary of CAP activities may be found in Appendix E-10.
TABLE 4-9
MAJOR CAP ACTIVITIES
Activity
Review of SBTCP outreach efforts
Review of SBO/SBAP documents
Define CAP responsibilities
Review/comment on new/proposed regulations, policies, etc.
Attend training seminars, conferences, etc.
Appoint staff/elect officers
Meet with small businesses/trade associations
Review/comment on state legislative actions
Other
# Programs
33
28
25
20
18
15
15
15
7
% Programs
62
53
47
38
34
28
28
28
13
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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 continue to
effectively and efficiently define the role of the CAP and fully maximize the skills of CAP
members in assisting small businesses. The value added activities of these CAPs
underscore the need for states still without operational CAPs to complete the
appointment/reappointment process and initiate the CAP function.
4.5 FINANCIAL ASSISTANCE PROGRAMS
Information about financial assistance programs offered to small businesses to address
environmental compliance needs (e.g., capital expenses associated with pollution
prevention or control equipment) is provided in Table 4-10.
TABLE 4-10
FINANCIAL ASSISTANCE PROGRAMS
States/territories offering grants/loans
Grants/loans offered
States/territories planning grants/loans
#
11
161
2
Note 1: Some states/territories offer more than one financial assistance program.
Eleven states/territories (21 percent) offered 16 financial assistance programs during the
1998 reporting period. Two SBTCPs have plans to offer financial assistance programs to
small businesses in the near future. This is up from 8 financial assistance programs
offered by 6 states in 1996 and ten grants/loans offered by seven states in 1997. Detailed
information about these financial assistance programs is provided in Appendix E-11.
Creative financing mechanisms fulfill a need conveyed to programs by small businesses;
offering financial assistance was a common recommendation made for improving
compliance by SBTCPs themselves. The number of states/territories that offer some type
of small business financial assistance program continues to rise, albeit slowly. Programs
are encouraged to explore funding opportunities for small businesses within their state or
territory.
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4.6 MINIMIZING DUPLICATION THROUGH COOPERATIVE EFFORTS
Programs reported on the extent to which they utilized existing state/territorial agencies and
departments, organizations, and other resources to maximize efficiency and minimize
redundancy, as discussed in Section 4.1.1. Programs also provided information on their
strategies to exchange information and resources with other SBTCPs, which is
summarized in Section 4.4.2.
4.4.1 Cooperative Efforts
Information provided in this section is vital to understanding how some programs with
limited budgets and resources are functioning. Generally, programs report that 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 cooperatively
manage resources is shown in Table 4-11. Descriptions of programs' cooperative efforts
may be found in Appendix E-12.
TABLE 4-11
PROGRAMS THAT REPORT COOPERATIVE EFFORTS
FOR SBTCP FUNCTIONS
SBO
SBAP
CAP
# Programs
44
48
27
% Programs
83
91
51
Forty-four programs (83 percent) report some level of cooperative effort to enhance the
SBO function. The SBO often coordinates information development and dissemination,
training, and workshops/seminars with such entities as other state agencies, Chambers of
Commerce, trade associations, non-profits, universities, public utilities, and Small Business
Development Centers. The overall concerns of small businesses are being taken into
account, as many SBOs provide multimedia information, coordinate outreach with non-air
programs, or intervene on behalf of a small business with other agencies. Some SBOs
also serve in other roles within the state environmental agency.
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Forty-eight programs (91 percent) indicate some level of cooperative effort by the SBAP
function in order to maximize their programs' effectiveness. Strategies and sources of
assistance are quite similar to those used by the SBOs.
Twenty-seven CAPs (51 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.
The number of programs reporting cooperative efforts has remained fairly consistent from
year to year.
4.6.2 Minimizing Duplication of Efforts Among SBTCPs
All programs (100 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
programs employ to avoid duplication of effort are presented in Table 4-12; program details
for this topic are found in Appendix E-13.
TABLE 4-12
SBTCP MECHANISMS FOR AVOIDING DUPLICATION
Mechanism
Communication/networking within SBTCP & state agency
Meetings, conference calls, other contacts with SBOs/SBAPs
within EPA region
Review of EPA documents, contacts with EPA
Information gathering from electronic sources
Review of documents from other public, private, or university
sources
Networking through state/regional air groups (e.g., WESTAR)
Subscribe to SBO or government ombudsman listserve
Other
# Programs
51
51
50
48
47
43
26
12
% Programs
96
96
94
91
89
81
49
23
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The most common techniques(in 96 percent of programs) to avoid duplication of effort was
communication and networking with SBTCP and state agency personnel via phone, mailing
lists, etc. and contact with other programs within the same EPA region through conference
calls and other means.
Gathering information from electronic sources, including Internet use for information
transfer, continues to be one of the most promising mechanisms for avoiding duplication
of effort among programs. Use of this method increased slightly in 1998 as reported by
48 programs, up from 46 in 1997 and 18 in 1996. This parallels the rise in the number of
web pages available, as previously noted. Posting information from the federal SBO and
SBAP, other private and university sources, and state programs facilitate efficient use of
resources and would encompass all of the mechanisms to avoid duplication. Additionally,
26 programs reported subscribing to applicable listserves, a surprising decrease of four
from the 30 in 1997. (A listserve is a program that allows users to mass-distribute
electronic mail messages. 1997 was the first year this reporting category was solicited.)
4.7 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 Office
continues its outreach actions toward assisting the SBTCPs in this effort.
Key EPA SBO outreach activities under the CAA Section 507(b) pursuant to these statutes
include:
Conducted educational activities at the EPA SBO Regional Liaison Conference,
Washington, DC, August 1998.
Provided information on statutes at the 1998 National/State SBO/SBAP Conference
in Scottsdale, AZ.
Responded to telephone hotline inquiries in regard to the three statutes.
r
Distributed copies of the three statutes by request to state contacts.
Provided states with copies of the 1996 Small Business Regulatory Enforcement
Fairness Act (SBREFA), which strengthens and amends the Regulatory Fairness
Act, and SBREFA Implementation Guidance documents.
Offered information on the three statutes on the small business environmental home
page.
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4.7.1 SBTCP Activities Associated with the Paperwork Reduction Act
Forty-eight programs (91 percent) reported specific activities associated with the intent of
the provisions of the Paperwork Reduction Act, up from 47 programs in 1997 and 32
programs in 1996. This Act was designed to minimize the burden and maximize the
practical utility and public benefit associated with the collection of information by or for a
federal agency.
The two most common actions taken to follow the intent of the provisions of this act were
receiving/providing information electronically (75 percent of programs) and reviewing
SBTCP documents for compliance (74 percent). Overall, all activity categories are showing
increases as SBTCPs continue to take significant steps 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 4-13 and are detailed, by program, in Appendix E-14.
TABLE 4-1 3
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE PAPERWORK REDUCTION ACT
Activity
Receiving/providing information electronically
Routine review of SBTCP documents for compliance
General permits for certain types of industries
Routine review of SBTCP information collection activities
Simplified/consolidated permits or forms
Eliminating unnecessary permits by increasing exemptions
Other
# Programs
40
39
34
33
33
29
5
% Programs
75
74
64
62
62
55
9
4.7.2 SBTCP Activities Associated with the Regulatory Flexibility Act
Forty-seven programs (89 percent) reported activities to follow the intent of the provisions
of the Regulatory Flexibility Act during 1998, the same as in 1997 and an increase from 27
programs in 1996. The Regulatory Flexibility Act requires that when a number of
regulations will have a significant economic impact on a substantial number of small
4-15
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entities, "a regulatory analysis must be performed to explore options for minimizing those
impacts." Those actions most often implemented are prioritized in Table 4-14.
TABLE 4-14
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE REGULATORY FLEXIBILITY ACT
Activity
Ensure that small businesses can participate in rulemaking
Routine review of SBTCP documents for compliance
Periodic rule review for
impact on small business
Amnesty program
Other
# Programs
39
39
28
21
8
% Programs
74
74
53
40
15
SBTCPs have played a major role in ensuring awareness of the effects of regulatory
requirements on small businesses as well as promoting environmental compliance in the
small business community. SBTCP personnel have made significant strides in promoting
the effects of legislation/regulations on small businesses to regulatory agencies through
their role as mediators between these two groups. The two primary activities reported by
programs in following the intent of the Regulatory Flexibility Act was ensuring that small
businesses can participate in rulemaking and reviewing SBTCP documents for compliance
(each reported by 39 programs). SBTCPs continue to be effective advocates of the small
business perspective and have helped negotiate flexible application of regulatory
requirements that provided great benefits to small businesses. Actions taken by SBTCPs
in response to the Regulatory Flexibility Act, by program, may be found in Appendix E-15.
4.7.3 SBTCP Activities Associated with the Equal Access to Justice Act
Forty-one programs (77 percent) reported specific activities to follow the intent of the
provisions of the Equal Access to Justice Act, up from 40 programs in 1997 and 18
programs in 1996. The purpose of this Act is to provide certain parties who prevail over
the Federal government with covered litigation in an award of attorneys' fees and other
expenses under appropriate circumstances. Specific actions include reviewing SBTCP
documents for compliance (the most common activity, conducted by 33 programs), and
reviewing instances where state actions against small businesses appear unjustified (22
programs).
4-16
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SBTCP actions to follow the intent of the provisions of the Equal Access to Justice Act are
shown in Table 4-15 and detailed, by program, in Appendix E-16.
TABLE 4-15
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE EQUAL ACCESS TO JUSTICE ACT
Activity
Routine review of SBTCP documents for compliance
Review instances where state actions against small
businesses appear unjustified
Providing funding/technical assistance for groups aggrieved
by regulatory actions
Other
# Programs
33
22
17
3
% Programs
62
42
32
6
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5.0 PROGRAM EFFECTIVENESS
Internal and external assessments of SBTCP program effectiveness are reviewed in this
section. Program goals and evaluation strategies are discussed in Section 5.1. Program
highlights and accomplishments are found in Section 5.2. In Section 5.3, SBTCPs offer
tips and barriers in operating their programs. Success stories and case studies are
included in Section 5.4. A discussion of "comments received on SBTCPs" and "concerns
or inquiries received and resolution strategies employed" are no longer included in this
section; these issues have been incorporated into other questions posed to the programs.
5.1 PROGRAM GOALS
At each national SBO/SBAP conference since 1995, SBTCP representatives have
discussed strategies to measure the success of compliance assistance programs. With
the revision of the SBTCP Reporting Form for 1998, SBTCPs were asked to define and
prioritize their own program goals. They also were asked to discuss strategies to evaluate
their goals and the results of this measurement process.
Programs are at different stages of development and have varying resources. Self-defined
goals allow each program to strive for success and measure its achievements within its
means.
Performance measurement tools can take a variety of forms from simple to sophisticated.
• Methods of tracking number of attendees at events.
• Types of numerical data collected for activities and methods of collection.
• Surveys to measure customer satisfaction after attending an event or receiving
assistance.
• Surveys to determine quality of service provided or request suggestions for
improvement.
• Detailed program analysis or evaluation.
• Statistical analysis of return on investment in program.
SBTCPs were asked to indicate goals for their programs, ranking them in terms of priority.
Their responses are summarized in Table 5-1.
5-1
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TABLE 5-1
PROGRAM GOALS
Goal
Increase understanding of environmental obligations
Improve compliance rates
Provide site specific compliance assistance
Increase understanding of permitting
Increase understanding of CAA
Other
Encourage self-auditing
# Programs
Declaring Goal
(regardless of rank)
45
42
30
25
17
14
13
# Programs
Declaring This
As #1 Goal
29
15
1
1
1
3
1
Increasing understanding of environmental obligations (45 programs, 85 percent) and
improving compliance rates (42 programs, 79 percent) were the two most frequently listed
goals, regardless of priority ranking. These two goals also garnered the most number one
priority rankings, with 29 and 15 programs, respectively, declaring these to be their main
goals.
5.1.1 Goal Evaluation
Importantly, programs then were asked how they evaluated whether their stated were
being met. Programs were encouraged to base their assessments on quantifiable terms,
where possible. Some programs, still in the developing stage, would need to rely on
qualitative strategies to report their goal progress.
SBTCPs reported a variety of strategies to evaluate their program goals. These included:
• Various customer feedback mechanisms (customer satisfaction/value of service).
• Questionnaires/satisfaction surveys.
• Tallies of hotline calls, on-site visits, workshops, etc.
Publications developed and distributed.
• Improvements in compliance rates.
Most programs focused on the number of businesses reached and types of assistance
offered to measure their success.
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Finally, programs were asked to describe the results of their measurement process. Many
SBTCPs discussed data and client feedback related to various outreach efforts. For
example:
• Montana's SBO/SBAP met its goals to provide extensive on-site assistance to the
vehicle service, automobile refmishing, dry cleaning, and chrome plating sectors.
Other goals were to establish a low-interest loan program and to add multimedia
services; these goals were met in 1998. SBO/SBAP provided multimedia P2
assistance to each of the businesses identified by EPA's Sector Initiative and
extended loans to over 20 service stations, four auto body shops, two heating/air
conditioning projects and two small manufacturers to purchase energy efficient and
P2 equipment.
• New York's ombudsman hotline received over 700 calls, a 45 percent increase over
1997. The ombudsman handled 71 cases in 1998, also an increase of 45 percent
over 1997. The SBAP conducted 17 audits and provided site-specific assistance
to these businesses. They responded to over 1,300 hotline calls ranging from
routine program information to very specific technical assistance. They provided
permitting assistance, completing 14 state facility permits and 52 minor facility
registrations. SBAP also helped 71 businesses reply to a mass mailing from the
state regulatory agency, which brought them into compliance with the permitting
regulation and prevented them from being classified as significant violators in the
future.
• Wyoming's Outreach Office notes the following successes in meeting their goals:
Provided information on environmental statutes and regulations in over
20,000 newsletters to small businesses in the state.
Offered compliance assistance and P2 initiative support to over 500 small
businesses in one-on-one site visits.
Encouraged self-auditing through both policy formulation (compliance
incentive rule advocated by the CAP and adopted by the Department) and
education via newsletter, handout information at public displays and
presentations, and in one-on-one site visits totaling thousands of individual
contacts.
Increased the public's understanding of permitting requirements and CAA
through publications, presentations, and site visits totaling thousands of
individual contacts.
Hard data linking these accomplishments to improved compliance are not currently
available. The program, however, believes its efforts are bearing fruit in many of the
businesses contacted. Wyoming is committed to working not just with the regulated
community, but also with the numerous small businesses that do not require
permits; the latter, in combination, can have significant impacts on the environment.
Arizona, Florida, and Texas measured improvements in compliance resulting from their
technical assistance efforts.
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• In Arizona, on-site visit evaluations, including changes in compliance, are conducted
during a follow-up visit 60 days after the facility receives its report. Over 70 percent
of violations detected during the initial visit had been corrected by the time of the
follow-up visit. Issues not corrected usually are complex or require significant
capital expenses.
• Florida's dry cleaner workshops were used to create PERC awareness. PERC
reductions were achieved, but compliance with recordkeeping and reporting
remained low. Dry cleaner calendars were created that enabled businesses to
easily enter data on their calendars. They could tear off and send in the information
sheet each month to meet compliance requirements.
In 1996, the average compliance rate for recordkeeping was 12 percent. In 1998,
recordkeeping and reporting increased to 73 percent. From 1996 to 1998, a 61
percent increase in compliance was achieved directly due to calendar distribution.
• Texas measures compliance before and after assistance is provided through
questionnaires, and customer assistance surveys for hotline calls, site visits, and
workshops. For 1998, SBAP met its program goals of 90 percent compliance for
most industries. Additional outreach will be conducted for industries whose
compliance rates were below 90 percent. The measurement system was
successful, as it showed the industries for which outreach was successful, the types
of outreach that were effective, and where further outreach is needed.
Individual program goals and their priority rankings, goal evaluation strategies, and results
of this measurement process may be found in Appendix F-1.
5.2 PROGRAM HIGHLIGHTS AND ACCOMPLISHMENTS
Forty-one SBTCPs (77 percent) reported on important accomplishments, awards, and
recognitions for their work with the small business community.
The SBTCPs continue to facilitate communication and improve trust between the
regulatory agencies and small businesses. Many programs have forged strong
partnerships with such groups as trade associations, small business development centers,
and small business associations to broaden outreach efforts to the small business
community. Many states also have developed industry-specific initiatives that include
compliance manuals, workshops, and on-site visits.
In this section, key accomplishments are highlighted based on the frequency in which they
were mentioned. An overview of program accomplishments and highlights for 1998 are
provided in Appendix F-2.
5-4
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1. Forging partnerships with other organizations and agencies was mentioned by 21
programs (40 percent) as being a significant accomplishment.
California's Air Resources Board initiated a facilitated workshop in
cooperation with the California Trade and Commerce Agency to improve
small business access to financial resources.
Illinois implemented a pilot project combining the resources of the SBAP,
IEPA Office of P2, SBDCs, Procurement Technical Assistance Center, and
Manufacturing Extension Center. Companies can receive free P2
assessments from a graduate student intern.
Minnesota's SBAP coordinated with external service providers to develop an
environmental guide for small businesses. The free guide includes
comprehensive multimedia information on all environmental regulations with
which small businesses need to comply.
• Nebraska is developing an ever increasing network of partners and peer
exchange businesses. Large businesses and consulting firms are taking a
more proactive role in working with small businesses to expand the
assistance outreach.
2. Seventeen programs (32 percent) reported work on multimedia projects or moving
their whole assistance program to multimedia leadership. This is up from nine
programs in 1997.
In June 1998, Connecticut's SBAP was moved into the Commissioner's
Office to coordinate multimedia compliance assistance efforts. While the
Office is still dealing predominantly with small business activities, other
activities and responsibilities also have been included.
Mississippi's program has made the move to multimedia, and it is working
well. Customers expect staff to have knowledge in all areas. Through these
multimedia efforts, customers have one point of contact to get a variety of
questions answered.
In Pennsylvania, as of December 1,1998, the technical assistance program
known as AIRHELP expanded to include solid waste, hazardous waste, P2,
energy, efficiency, and environmental management systems as well as air
quality.. The new program is called ENVIROHELP.
Virginia's SBAP has been relocated into a new division within DEQ - the
Pollution Prevention and Compliance Assistance Division. One result of this
move is the increased opportunity to provide multimedia assistance with the
hopeful addition of resources.
3. Fourteen programs (26 percent) were pleased with the publication of various
documents.
Florida developed a dry cleaners' compliance assistance calendar.
Indiana published a vehicle maintenance compliance manual that includes
environmental, OSHA, and fire and building services regulations.
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Maryland prepared the Business Guide to Environmental Permits and
Approvals, which lists information for all permits, approvals, and licenses
issued by the Department. This document is very useful to businesses and
is available on the MDE web site.
New Jersey's SBAP worked in conjunction with EPA, trade/business groups,
and chemical manufacturers on the NJ Chemical Industry Project, which
developed compliance assistance materials for medium and small
businesses both as hard copy and on line.
4. Improved synergy between the regulatory agency and small business was noted by
13 programs (25 percent).
In Hawaii, a statewide dry cleaning technical assistance program was
designed and established with the concurrence and support of industry.
Michigan's SBAP trained more than 1,800 business, industry, regulatory, and
consulting personnel during 1998 at 18 workshops held statewide. SBAP
also provided a number of presentations to business, industry, and
government personnel, attracting a listening audience of 1,274 at 15
engagements. The technical assistance provided or customer service
displayed is reflected in nine letters of appreciation from industry or other
state government agencies commending SBAP staff on the excellent level
of technical assistance that was provided.
New Hampshire's program continues to be well received by the small
business community. An ever increasing majority of referrals for technical
assistance are through conversations between business owners. This is
primarily due to the conscious attempt by program staff to break down the
barriers of mistrust that often exist between business owners and regulatory
agencies.
One of North Carolina's primary accomplishments in 1998 was to strengthen
links with the Department of Commerce and local economic developers and
to improve our multimedia response capability. The SBO works with all
permitting agencies and business representatives to facilitate a new
company's understanding of environmental requirements.
Other accomplishments mentioned less frequently include permitting and compliance
assistance, pollution prevention initiatives, and sponsoring or making presentations.
5.3 TIPS AND BARRIERS
At the request of the SBTCPs, a new section was added to the Reporting Form for sharing
tips or barriers first developed or recognized by a program. Thirty programs (57 percent)
shared their suggestions. The three most commonly suggested tips, of the many that were
offered, were:
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1. Maximize communication with other agencies (9 programs/17 percent).
Louisiana suggests cooperation with the surveillance section as key to
assisting small businesses with notices of violations.
Ohio encourages a working relationship with the state's inspectors and
permit processors, since they are the only state environmental agency
people that a business is likely to deal with directly. Have the SBAP staff
visit district inspectors and go on inspections with them.
2. Forge partnerships (7 programs/13 percent).
• Kansas is trying to work with trade associations and local programs more
effectively by piggybacking on existing programs or events. For example,
Kansas provided a workshop in conjunction with the national screenprinters'
teleconference to provide additional state-specific information and to answer
questions.
Washington's state agencies cooperated in a series of "fugitive dust control
for construction sites" seminars given for industry.
3. Provide a sector-specific message (4 programs/8 percent).
• Iowa has found that generic guidance materials, workshops/seminars, etc.
are not very effective for "typical" small businesses. Targeted and detailed
specific information is better received and is more useful.
• New Hampshire recommends developing state- and sector-specific
compliance/ best management practices manuals as an optimum way to
foster compliance. The manuals must be as narrowly focused as possible,
as small business owners do not have time to determine if something is
applicable or not.
Less frequently mentioned tips include:
Maintain and update web site.
• Adopt Rules of Customer Service.
Schedule evening workshops for the convenience of small businesses.
• Promote CAP appointments and reappointments.
SBTCPs also were asked to identify barriers to their work. The three most commonly
mentioned were:
1. CAP appointments (4 programs/8 percent).
CAP appointments in Florida are legislatively mandated, but do not establish
a service term. This creates a difficult situation when CAP members do not
participate yet want to "stay on" the CAP.
5-7
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North Carolina reports significant problems in getting timely appointments of
CAP members. The specific problems for minority and majority legislative
appointments, the turnover in executive staff, and appointments to a purely
advisory body have created problems. A mandated advisory body with
broad-based membership - not necessarily through the appointment
process - may be a better solution.
2. Lack of resources and staff training (3 programs/6 percent).
The District of Columbia's program will be better run when there is a
dedicated full-time person who can develop and implement a plan for the
program. For the program to achieve its goals, the three program
components must be in place and operational, which is not the case for DC.
Virginia has found that resource constraints have hampered their program's
ability to provide on-site compliance assessments, which are seen as a most
essential element of providing credible compliance assistance.
3. Lack of authority to go multimedia (3 programs/6 percent).
Oregon's program needs to be multimedia to be more effective. DEQ's
current organization prevents this from happening. The SBTCP is exploring
the possibility of a multimedia technical assistance program. Funding seems
to be one of the biggest barriers.
Rhode Island reports that one major barrier to its program is the state's
Operating Permits Commission. This Commission was created by the
state's Office of Air Resources to solicit funding for salaries that are paid out
of the Operating Permits Program. Since the SBAP is funded by Operating
Permit Fees, the members of this commission prefer that the SBAP only
perform air assistance. Since the SBAP is an assistance program, it
responds to the needs of small businesses on ail media issues. The SBAP
feels it is impractical not to respond to other small business environmental
needs.
A complete list of each program's tips and barriers may be found in Appendix F-3.
5.4 SUCCESS STORIES AND CASE STUDIES
Another new addition in the 1998 Reporting Form is the request for success stories and
case studies. These can serve as strong examples of a program's effectiveness and
provide insight and inspiration to other small businesses and SBTCPs. Twenty-eight
programs (53 percent) shared their success stories or case studies.
Several success stories are included below. Success stories and case studies from all
programs may be found in Appendix F-4.
5-8
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In Hawaii, a farmer seeking to obtain an agriculture burning permit to dispose of
waste that he "inherited" on land recently leased from the State of Hawaii sought
assistance from the SBO. The SBO negotiated a waiver of lease rent with the state
land agency for the farmer, which was equivalent to the cost of collection, transport,
and disposal of non-agricultural waste (e.g., plastic nursery pots, treated lumber,
tires, and wrecked autos) from the previous tenants. The farmer was not required
to segregate non-combustible items from his burn pile. The farmer did not incur
waste disposal costs for that which he was not responsible. The state land agency
treated a new lessee fairly and ensured that waste was appropriately cleared from
its land, without incurring new costs. The air program demonstrated flexibility in its
administration of the agricultural burning permit.
In Louisiana, a cultured marble manufacturer, an employee-owned company of 18
people, contacted the Louisiana SBAP after receiving an EPA mailing about
obtaining an air quality permit for styrene emissions. The SBAP engineer met with
the company president to determine what needed to be done. "The cost savings
to the company were considerable, because we didn't have to hire a consultant to
do the work," said the president. He also said he feels more at ease knowing that
the company avoided enforcement actions by obtaining the correct air permit.
The Massachusetts auto body project generated simplified regulatory information
by using the "good faith" rationale for penalty mitigation. Working with a trade
association, Massachusetts SBAP produced the manual, "Crash Course," which
constitutes an agreement between the federal and state environmental enforcement
agencies defining what an inspector will look for when visiting an auto body facility.
Information is offered to help an auto body shop owner/operator know what to do
to comply with basic requirements. Included are a simple version of the rules,
pollution prevention tips, strategies to protect worker health, and documentation
tools so that the shop can show an inspector how key activities occur. The shop
can benefit from this demonstration of good faith if any penalties are assessed.
Using the "good faith" policy allows regulatory simplification without any regulatory
promulgation.
The Montana SBO/SBAP created the Small Business and Tribal Energy and
Environmental Loan Program to provide low-interest loans to small businesses and
tribal entities to purchase energy efficient and pollution prevention equipment. The
loan program kept over a dozen small, rural service stations from going out of
business as a result of the underground storage tank regulations.
A trailer manufacturing company in Nebraska switched to a new type of plasma
cutter, which allowed them to cut aluminum more quickly and accurately. However,
the aluminum oxide waste from the cutter was very fine, and when mixed with water,
became unstable. Faced with possible hazardous waste disposal expenses, the
company called the NE SBAP.
Upon visiting the trailer company, the SBAP determined that the company would
generate over 55 gallons of aluminum oxide powder daily. Through a network of
scrap dealers and other companies that cut aluminum, the SBAP found a company
in Illinois that would take all the aluminum oxide that the trailer company could
produce. The trailer manufacturer now is considering adding a second plasma
cutter to increase production.
5-9
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The New York Small Business Environmental Ombudsman (SBEO) negotiated a
policy with the NY Department of Environmental Conservation in which dry cleaners
could voluntarily come forward to the DEC and sign consent orders to come into
compliance with the vapor barrier requirement of the new dry cleaning regulation.
Many dry cleaners had missed a deadline to build a vapor barrier enclosure around
their dry cleaning equipment due to a variety of reason. The DEC allowed dry
cleaners operating third generation machines who had missed their deadline, and
who had a signed contract with a vapor barrier installer, to voluntarily comply by
signing consent orders with a suspended penalty. Over 300 dry cleaners took
advantage of the consent order option.
In Ohio, a one-person company that makes lead castings was inspected by District
Office staff, who maintained the company was a "secondary lead smelter,"
determined large potential emissions based on smelting emission factors, and
deemed the company in violation for not having an air permit. The SBAP visited the
company and learned the operation was not secondary lead smelting, but was
exempt from permitting due to low emissions that were calculated using the
appropriate non-smelting emission factors. The SBAP, on behalf of the company,
successfully argued this point to the District Office and Prosecutor's Office; the
charge of failure to obtain a permit was dropped.
In Texas, Lancaster Furniture focused on reducing their volatile organic compounds
(VOC) emissions with the help of TNRCC. The company invested $8,000 for more
efficient high-volume, low-pressure spray guns and related equipment and trained
employees in their proper use. VOC emissions dropped from just under 25 tons in
1996 to 16 tons in 1998, while annual expenditures on paints and coatings fell from
$69,000 to $35,000.
5-10
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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. Compliance
issues in particular industry sectors are identified in Section 6.2. Recommendations to
facilitate compliance are outlined in Section 6.3. Program confidentiality issues are
outlined in Section 6.4. Finally, in Section 6.5, information is provided on the use of EPA's
Small Business/Small Communities Policy. The section on improvements in regulatory
understanding and compliance does not appear this year, as this information has been
captured in other sections when the Reporting Form was revised.
6.1 COMMON COMPLIANCE PROBLEMS
All SBTCPs provided insight on the types of compliance issues addressed during the
course of providing technical assistance to small businesses. Common compliance
problems, listed by decreasing occurrence for 1998, are shown in Table 6-1 and are
compared with responses from 1997 and 1996; responses for 1998 are detailed, by
program, in Appendix G-1.
6-1
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(TABLE 6-1
COMMON COMPLIANCE PROBLEMS
Compliance Problem
Not understanding regulatory
requirements
Incomplete recordkeeping
Fear of arbitrary regulatory
enforcement/regulatory agency
Uncertain how to determine
emission inventories/lack of
technical expertise
Uncertain how to complete
forms/complicated paperwork
Operating without a permit
Uncertain of permitting requirements
Improper storage/disposal of
hazardous waste
Financing for pollution control
requirements
Operating outside NSPS or MACT
Failure to use or finding proper
equipment/technology To comply
with applicable standards
Other
1998
#
Programs
51
48
46
45
42
42
42
25
24
22
18
5
%
Programs
96
91
87
85
79
79
79
47
45
42
34
9
1997
#
Programs
49
42
42
45
44
39
37
29
31
23
12
5
%
Programs
92
81
81
85
83
74
70
55
58
43
23
9
1996
#
Programs
28
16
6
12
10
26
14
7
10
10
6
Not
reported
%
Programs
53
30
11
23
19
49
26
13
19
19
11
Not
reported
Compliance issues have remained consistent from year to year. Identifying key problems
and gaps in understanding by the small businesses have helped the SBTCPs to best target
their assistance efforts.
6.2 COMPLIANCE PROBLEMS IN PARTICULAR INDUSTRY SECTORS
In addition, as a new element for 1998, programs were asked to indicate if certain
compliance problems were prevalent in any particular industry sector. Nineteen programs
(36 percent) indicated at least one industry sector. Their responses are summarized in
Table 6-2 and shown in full in Appendix G-1.
6-2
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TABLE 6-2
COMPLIANCE PROBLEMS IN INDUSTRY SECTORS
Compliance Problem
(# industry sectors mentioned)
Not understanding regulatory requirements (8)
Operating without a permit (10)
Incomplete recordkeeping (9)
Uncertain of permitting requirements (3)
Uncertain how to determine emission inventories (3)
Uncertain how to complete forms (4)
Lack of financing (4)
Operating outside NSPS/MACT (3)
Improper storage of hazardous waste (3)
Fear of regulatory agency (6)
Failure to use proper equipment (3)
Industry Sector Specified
(# programs indicating this sector)
Dry cleaners (3)
Auto maintenance shops (3)
Gas stations (1)
Small/medium businesses (1)
Metal finishers (1 )
Dehydrators (1 )
Daines (1)
Surface coalers (1)
Paint booths (1)
Auto degreaser (1 )
Dry cleaners (1)
Aquaculture (1 )
Surface coaters (1)
Toxics use (1 )
New York City sources with city-only permit (1)
Small businesses (1)
Metal finishers (1)
Auto(1)
Dry cleaners (10)
Paint booths (1)
Small/medium businesses (1)
Foundries (1 )
Surface coaters (1)
Auto body (1)
Dairies (f)
Printers (1)
Metal finishers (1)
Aquaculture (1 )
Dairies (1)
Metal finishers (1)
Auto body (1 )
Surface coaters (1)
Dry cleaners (1)
Dry cleaners (2)
Venicle maintenance (1)
Small/medium businesses (1)
Surface coaters (1)
Gas stations (1)
Auto body (1)
Sand blasters (1)
Surface coaters (1)
Dry cleaners (3)
Plating (1)
Furniture manufacturing (1)
Vehicle maintenance (1)
Manufacturing (1)
Metal finishing (1)
Dry cleaners (2)
Venicle maintenance (2)
Metal finishing (2)
Small businesses (1)
Printers (1 )
Surface coaters (1)
Gas stations (1)
Degreasers (I )
Surface coaters (1)
6-3
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Of the 11 categories of compliance problems, the number of categories in which a
particular industry sector appears is shown in Table 6-3.
TABLE 6-3
INDUSTRY SECTOR APPEARANCE IN COMPLIANCE CATEGORIES
Industry Sector
Surface coaters
Dry cleaners
Metal finishers
Auto maintenance shops
Small/medium businesses
Gas stations
Auto body shops
Dairies
Paint booths
Auto degreaser
Aquaculture
3rinters
Dehydrators
Toxics use
New York City sources
Sundries
Sandblasters
rurniture manufacturers
Manufacturing
# of Compliance Problem Categories
8
7
7
5
5
3
3
3
2
2
2
2
1
1
1
1
1
1
1
Surface coaters appear in eight compliance problem categories. Dry cleaners and metal
finishers closely follow, each appearing in seven categories. Interestingly, printers have
received a strong level of technical assistance from many of the Section 507 programs in
the past several years; this sector appears in only two compliance problem categories,
implying that technical assistance efforts are working.
6-4
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6.3 RECOMMENDED CHANGES TO FACILITATE SMALL BUSINESS COMPLIANCE
WITH THE CAA
Recommendations made by SBTCPs for changes, at the state or federal level, to help
small businesses comply with the CAA are summarized in Table 6-4. SBTCP staff
members are uniquely qualified to make such recommendations, since they address
current CAA compliance problems encountered by small business and attempt to provide
effective solutions. Specific program responses may be found in Appendix G-2.
TABLE 6-4
1998 SBTCP RECOMMENDATIONS FOR IMPROVING COMPLIANCE
Recommendation
Allow flexibility/simplification in applying regulations to small
businesses
Increased funding/continued adequate funding for SBTCPs
Simplify paperwork/reporting requirements
Multimedia assistance
Regulations written in plain English
Grants/loans for small businesses
Generic outreach and training materials
Expand/facilitate effective communication between state and federal
agencies
Clean and simple audit privileges/voluntary disclosure policies
Develop a national public relations/advertising program
Develop compliance incentives
# Programs
13
12
9
8
6
6
5
5
4
3
2
% Programs
25
23
17
15
11
11
9
9
8
6
4
Forty programs (75 percent) provided at least one recommendation for changes to improve
small business compliance with the CAA. While priority of responses for 1997 parallel
those of 1996, 1998 saw a few subtle shifts with the exception of the number one
recommendation.
Allowing flexibility and simplification in applying regulations to small businesses was
mentioned by 13 programs (25 percent) as being the prime recommendation for improving
compliance. Another common recommendation, mentioned by 12 programs, was for
continued and increased funding for the state SBTCPs (ranked third last year and second
6-5
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this year). As previously noted, a number of states operate with limited budgets and staffs.
The personalized approach to technical and compliance assistance has been shown to be
effective in reaching the small business community, and 23 percent of state programs
believe that adequate financial resources are vital to continued and expanding high quality
service.
The third most common recommendation stressed by 9 programs (17 percent) called for
simplifying paperwork and reporting requirements, a suggestions that mirrors the top
recommendation. Simplifying paperwork was ranked in a tie for sixth last year, and moves
to third this year.
6.4 PROGRAM CONFIDENTIALITY AND CONFLICT OF INTEREST
In early 1995, EPA's SBO worked with the SBTCPs and EPA's Office of Enforcement and
Compliance Assurance to reach an agreement regarding the confidentiality of assistance
provided to businesses via the SBTCP.
Programs were asked how they avoid conflicts of interest (COI) and maintain
confidentiality, particularly in those cases where the SBO or SBAP is located within the
regulatory agency.
Forty-eight programs (91 percent) reported no problems with COI or confidentiality issues
regardless of whether a confidentiality policy is in place. One program (Alabama) did not
respond to the question, two programs indicated the question was not applicable (Maryland
and South Dakota), one program has not yet addressed this issue (Puerto Rico), and one
program indicated that COI is unavoidable (District of Columbia).
Responses to this question have remained consistent from year to year. SBTCPs
consistently report that, for the most part, COI and confidentiality are non-issues in
operating their programs.
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
6-6
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if violations are discovered during the course of their receiving technical assistance.
Program responses to the issue of COI and confidentiality may be found in Appendix G-3.
The following example responses reflect the range of COI issues and resolutions (from
having an established confidentiality policy to having no such policy).
• In Arizona, existing policies, strong support from the Director of ADEQ, and good
working relationships with the programs have done a great deal to maintain our
credibility as a source of assistance that can be used without risk of exposure.
Arizona's program does not advertise confidentiality. Before they conduct a site
visit, they inform the business that the resulting report will not be confidential.
Enforcement personnel have better things to do than comb through files for
businesses that are already taking steps to voluntarily come into compliance.
• The District of Columbia's SBAP is solely staffed by a permit engineer/inspector
who can recommend or carry out an enforcement action. In this situation, conflict
of interest in unavoidable.
Indiana's Compliance and Technical Assistance Program (the SBAP), which is part
of IDEM (the regulatory agency), operates under strict confidentiality as mandated
by state statute. The statute prohibits program staff from revealing confidential
information to personnel in the agency or to the public unless the client specifically
waives confidentiality, or if there is a clear and immediate danger to public health
or the environment. Working effectivejy within EDEM's regulatory offices is
sometimes difficult, because the strict confidentiality policy can hinder
communication or coordination of efforts.
The program in Iowa is funded by the Iowa Air Quality Bureau. Contract terms
stipulate disclosure of the program's client information to the AQB if such
information is requested. Unless specifically requested (very rarely), no client
information is volunteered to the regulatory agency. Program clients are told that
"confidentiality" does not exist with the SBAP.
• Utah uses the EPA's policy as a model for compliance incentives for small business,
which was issued May 20,1996..
6.5 USE OF EPA'S SMALL BUSINESS/SMALL COMMUNITIES POLICY
As the final new reporting element for 1998, programs were asked if they used EPA's
Policy on Compliance Incentives for Small Businesses (Small Business Policy) or a
comparable state policy for small businesses/small communities. EPA's Small Business
Policy, signed May 20,1996, provides incentives to small businesses to participate in on-
site compliance assistance programs and to conduct environmental audits. Under this
policy, EPA will eliminate civil penalties provided the small business satisfies certain
criteria.
6-7
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Very few states are making use of EPA's policy or developing their own, as shown in Table
6-5.
TABLE 6-5
SMALL BUSINESS/SMALL COMMUNITY POLICY USE
Policy Use
Uses EPA policy
Developed state policy
Uses both EPA and state policy
NA/NR/Not used/None
Small Business Policy Act
# / % programs
5 / 9%
11/21%
2/4%
35 / 66%
Small Community Policy Act
# / % programs
0
2/4%
0
51 / 96%
For both small businesses and small communities, SBTCPs then were asked to list:
• The number of small entities qualifying under the policy.
The number of small entities attempting to use the policy; still under consideration.
The number of small entities attempting to use the policy, but not qualifying.
• Total dollar amount of penalties reduced.
Program responses are summarized in Table 6-6 and are shown in full in Appendix G-4.
All references to small entities are for small businesses; programs did not report any use
of the Small Communities Policy.
TABLE 6-6
SMALL BUSINESS POLICY ACTIVITIES
Policy Activities
Small businesses qualifying under the policy
Small businesses attempting to use policy; still
under consideration
Small businesses attempting to use policy, but
not qualified
Total $ amount penalties reduced
Programs Using Policy
# of entities
ME-1
MT-7
TN-12
WY - several
ME-0
MT-0
SC-1
TN-12
ME-0
MT-1
NY-1
TN-1
ME - unknown
# Programs Indicating
NA/NR/None/Not used
49
49
49
52
6-8
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While the Small Business/Small Entity Policy seemingly has had little use, programs likely
are not yet tracking such statistics, as evidenced by the high number of programs not
answering this question.
6-9
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APPENDIX A
1998 ANNUAL REPORTING FORM
-------
STATE SMALL BUSINESS STATIONARY SOURCE
TECHNICAL AND ENVIRONMENTAL COMPLIANCE
ASSISTANCE PROGRAM (SBTCP)
ANNUAL REPORTING FORM
FOR THE PERIOD 1/1/98 TO 12/31/98
OMB NO.: 2060-0337
EXPIRATION DATE: 9/30/01
*** Completed forms are due by February 15,1999 ***
Enclosed is a blank copy of the Annual Reporting Form for the State Small Business Stationary Source Technical and
Environmental Compliance Assistance Program (SBTCP) under the Clean Air Act (CAA) as amended in 1990. This
Form covers information from January through December 1998 and requests information on each of the three
components of the SBTCP:
Small Business Ombudsman (SBO)
• Small Business Assistance Program (SBAP)
Compliance Advisory Panel (CAP)
As you complete this Form, please remember that we are collecting objective information on each SBTCP. This report
is not an evaluation of your program. For your convenience, we provided electronic copies of the Form in WordPerfect
(SBTCP.WPD) and Microsoft Word (SBTCP.DOC).
INSTRUCTIONS FOR COMPLETING THIS FORM
1. Please complete the electronic version of the Form. If you need additional space for your answers, enlarge the
boxes provided for your responses. Do not answer questions by referring to attached documents or a previous
SBTCP report.
2. You should already collect the information requested on this Form. However, if a question asks for data you
do not have, please provide a brief explanation of why it is not available. For future reports, you may need to
revise the statistics that you track.
3. Once you have completed the Form, please return the disk and a completed hardcopy of the Form in the
enclosed, pre-addressed mailer. If this mailer is missing or if you wish to use your own envelope, please return
the disk and hardcopy to:
Ms. Karen V. Brown
Small Business Ombudsman
ATTN: SBTCP Annual Report
U.S. Environmental Protection Agency (2131)
401 M Street, SW
Waterside Mall, Room 3423
Washington, D.C. 20460
4. If you use your own mailer, please include on the mailer the words, "Electronic Media Enclosed."
WHAT IF I HAVE QUESTIONS?
If you have any comments or questions for how to improve this Form, please call the U.S. EPA Small Business
Ombudsman (EPA SBO) at the numbers listed below. You can reach the SBO Monday through Friday from 8:30 a.m.
to 5:00 p.m. (EST). After these hours, you can leave a message on the answering machine, which is connected to the
toll-free 800 number.
(202) 260-0490 (Telephone)
(800) 368-5888 (Toll-free Hotline)
(202) 401-2302 (Facsimile)
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WHY IS EPA REQUESTING THIS FORM?
As part of the CAA, the U.S. Congress required that each state and territory establish a Small Business Stationary Source
Technical and Environmental Compliance Assistance Program (SBTCP) to help small businesses comply with this Act.
As part of its reporting requirements to Congress, EPA includes information about the SBTCP programs using
information you provide on this Form. EPA has given the responsibility for this report to its SBO, who uses this Form
as a standard information collection tool.
SUGGESTIONS FOR COMPLETING THIS FORM
• Gathering information for this report is definitely a team effort! Enlist the help of key contacts from the SBO,
the SBAP, and the CAP, and ask them to complete applicable sections.
• One person should take responsibility to complete and submit this Form (most likely the SBO).
• Refer to last year's Report to Congress and the information you provided on your Reporting Form last year when
completing this year's Reporting Form.
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SECTION 1
SOURCE OF THE INFORMATION
This section is designed to collect standardized information about the SBTCPs completing this Form, and whom to
contact if we have questions.
1.1 Name of state, territory, or local agency for which this report is being submitted.
1.2 Who should be contacted (primary and alternate contacts) if there are any questions
regarding the information contained in this Form?
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, and also a telephone extension if appropriate.
Name
Title
Relationship to SBTCP
Organization
Address
Address
City, State, Zip
Telephone Number
Facsimile Number
E-mail
Hotline (national? state?
toll free?)
Internet home page
PRIMARY CONTACT
ALTERNATE CONTACT
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SECTION 2
STATUS, BUDGETS, STAFFING, ORGANIZATION
This section is designed to collect four types of standardized information about your state's SBTCP: Status, Budgets,
Staffing Levels, and Organization. The information you provided in last year's report will be helpful in answering the
questions in this section.
STATUS
2.1 When was your SBTCP established?
Please note that in Question 2.2, we are asking when each component of your SBTCP was began to operate
(provide services), which may be different.
SBTCP Component
SBO
SBAP
CAP
Month and Year of Establishment
2.2 When did the SBTCP begin to provide operations (month and year)?
To be consistent, for the SBO, indicate the effective date of appointment; for the SBAP, indicate the date it
began providing assistance to small businesses; and for the CAP, indicate the date of the first meeting — even
if not all members of the CAP were appointed by the time of the first meeting.
SBTCP Component
SBO
SBAP
CAP
Month and Year Operations Began
BUDGETS
2.3 Please provide summary information on the funding for each component of your
SBTCP (for the period January through December 1998). Please indicate the source
of funding.
For example, sources of funding might include: Title V fees, specific appropriation ofstate funds, the
operating budgets of existing programs, or some combination of sources.
These budgets should include direct salaries, fringe benefits, materials & supplies, etc.
To keep it simple, please round your budgets to the nearest $100.
If budgets are combined for 2 or for all components of your program, please indicate.
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SBO
SBAP
CAP
TOTAL
1998 BUDGET ($)
SOURCE OF FUNDING (please describe)
2.4
What was your SBTCP's budget in 1997? What is the expected SBTCP budget during
the next reporting period (January through December 1999)?
As with the previous question, please round all numbers to the nearest $100. If these programs did not exist
(or were not active) in 1998, please indicate. Also, please indicate if any program budgets are combined.
SBO
SBAP
CAP
TOTAL
1997 BUDGET ($)
1999 PROJECTED BUDGET ($)
2.5 Briefly describe any significant changes of more than 10% in the level of funding
between the 1997,1998, and 1999 annual budget periods.
For example, a previous period may have seen a high level of fines that were credited to the SBTCP program,
perhaps Title V revenues were lower than projected, or state appropriations may have been reduced or
eliminated.
STAFFING
With these questions, we want to know how many people support each component of your SBTCP.
2.6 How many people, measured as full-time equivalents (FTEs), support the SBO?
Please complete this question for the staffing levels that are current as of December 1998. An FTE is
considered to work 40 hours/week. For example, 2 people working 20 hours/week would be equivalent to 1
FTE. It is possible that the SBO has other responsibilities and does not perform this function on a full time
basis. For example, if they perform this function approximately 20 hours/week (or 50% of their time), this
would be equivalent to an 0.5 FTE.
SBO Function
SBO
Other staff
TOTAL STAFF
Number of FTEs
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2.7 How many people, measured as full-time equivalents (FTEs), support the SBAP? How
many of these people are paid or serve as unpaid volunteers? How many of these
people are retired engineers?
Please complete this question for the staffing levels that are current as of December 1998. Use the same
definition for an FTE as discussed in Question 2.6. We want to know if the programs use unpaid volunteers
as well as "retired engineer"programs (or their equivalent) to support the SBAPs.
SBAP Staff
Paid
Unpaid Volunteers
TOTAL STAFF
Number of FTEs (including retired
engineers, paid or unpaid)
Retired Engineers
Paid
Unpaid Volunteers
TOTAL RETIRED
ENGINEERS
Number of FTEs
2.8 How many people are currently serving on your CAP?
Please indicate how many people have been appointed to your CAP as of December 1998. Please indicate
each CAP member's affiliation (i.e., small business, state regulatory agency, general public, etc.)
If appropriate, indicate the number of people who have not been appointed to your CAP as of December 1998.
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
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ORGANIZATION
2.9 Please briefly describe where each component of your SBTCP is located/organized.
Please indicate if the component is located in a regulatory agency, another agency, a university, etc. For
example, in some programs, the SBAP is in 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). Please indicate if the administrative location is regulatory or nonregulatory.
Generally, the CAP is independent and is located outside of all agencies, with each individual appointed as
defined in Section 507. If your SBAP is contracted to an outside organization, please complete Question 2.11.
SBTCP
COMPONENT
SBO
SBAP
CAP
BRIEF DESCRIPTION OF ADMINISTRATIVE
LOCATION
REGULATORY OR
NONREGULATORY
9
2.10 Has management of all or part of the SBAP been contracted to an outside organization?
If YES, please complete Question 2.11.
2.11 What is the outside organization that is operating your SBAP?
SBAP Contractor
Address
City, State, Zip
Telephone Number
Facsimile Number
Project Manager (or
principal point of contact)
1998 Budget
Term of Contract
Portion of Program Under
Contract
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2.12 Does your program offer air-only assistance, or has your program moved into
multimedia assistance?
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SECTION 3
SERVICES PROVIDED/ACTIVITIES CONDUCTED
3.1 Briefly describe the assistance services of your SBO and SBAP. What is the number of
eligible facilities, by industry sector, that your program assisted in 1998?
We are interested in compiling statistics on the types of assistances and number of businesses reached, by
industry sector, through a variety of assistance services by the SBO and SBAP combined.
To help you in completing this question, the following tables are provided.
• In Table A, please list the number of each type of service offered and the number of businesses
reached, by industry sector, through various outreach activities. If you only know the total businesses
reached per industry sector, please indicate this number in the "total" column in the right side of the
table. If you only have information on the total number of businesses reached by various types of
outreach activities, please indicate this in the "total" row at the bottom of the table.
If multiple industry sectors were reached by a particular outreach activity (for example, a permitting
training program that was relevant to any industry sector), please place this information in the "cross
sector" category.
If you only track whether these activities occurred (and not the specific number of occurrences),
please simply "check" the appropriate column.
The number(s) next to each industry sector is its 2-digit (major group) or 3-digit (industry group) SIC
code.
• In Table B, please indicate the total number of each type of assistance requests you receive by CAA
requests and multimedia requests.
Please note that the options for the types of services have been limited. Please classify the services you offer
into one of these categories. If no category is suitable, you can use the "Other" category. You do not need to
define what you have placed in the "Other" category. The Report to Congress will reflect only these
categories.
NOTE: An eligible facility is defined as a stationary source that:
Is owned and operated by a person that employs 100 or fewer individuals.
Is a small business concern as defined by the Small Business Act.
Is not a major stationary source.
Does not emit 50 tons or more per year of any regulated pollutant.
Emits less that 75 tons per year of all regulated pollutants.
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Please indicate number of each type of service offered and the number of businesses reached for each relevant industry sector (#
services/#businesses reached).
Industry Sector (SIC)
Example Industry (xx)
Aerospace (37)
Agriculture/Farming/
Crop Service (01, 07)
Airports/Air
Transportation (45)
Analytical/Medical
Instruments (3 8)
Asbestos/Remediation
(17,32)
Asphalt (295)
Attorney/Consultant/
Engineer (8 1,87)
Auto/Motor Vehicle
Dealers & Equipment
(55,501)
Auto/Body
Maintenance.Repair,
Refmishing (75)
Bakeries (546)
Boat Manufacturing
(373)
Boilers (34, 50)
Business Services (73)
Chemicals/Products
(28)
Hotline
1/10
Onsite
Visit
7/7
Seminars/
Workshops
3/200
TABLE
Publications
4/500
A
Home Page
1/200
Teleconference
3/100
Mailings
2/50
Other
TOTAL
BUSINESSES ,
REACHED
1,067
10
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TABLE A
Industry Sector (SIC)
Communications (48)
Concrete/Aggregate
(32)
Construction/
Contractor
(15, 16, 17)
Cotton Gins (072)
Crushed Stone
Products/Sand &
Gravel (14)
Dairy/Feedlots/
Livestock (02)
Degreasers
Dry Cleaners/Laundry
Services (721)
Electronics/Electric
Equipment/Repair
Electroplating/Chrome
Plating (347)
Engines & Turbines
(351)
Food/Beverage
Products & Processing
(20,514)
Foundry/Smelter,
Forging, Casting (33)
Furniture Manufacture/
Repair/Wood Finishing
(25, 764)
Hotline
Onsite
Visit
Seminars/
Workshops
Publications
Home Page
Teleconference
Mailings
Other
TOTAL
BUSINESSES
REACHED
11
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TABLE A
Industry Sector (SIC)
Gasoline Distribution
(wholesale/retail) (5 17,
554)
Government (9 1,95)
Grains/Grain Elevators
(011,422)
Hospitals/Medical
Health Services (80)
Hotels/Motels (70)
Incinerators
Landfills/Landfill Gas
(495)
Leather/Fur (3 1,237)
Machine Shop (359)
Machine/Equipment
Manufacturing &
Repair (35)
Manufacturing, Misc.
Metal Fabrication/
Finishing (34)
Mining (Metal & Coal)
(10,12)
Organizations/
Associations (86)
Paints &
Painting/Coatings
(172,285)
Paper Manufacturing
& Products (26)
Hotline
Onsite
Visit
Seminars/
Workshops
Publications
Home Page
Teleconference
Mailings
Other
TOTAL
BUSINESSES
REACHED
12
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TABLE A
Industry Sector (SIC)
Personal Services (72)
Petroleum Products,
Storage, Pipelines (29,
46)
Pharmaceuticals (283)
Plastic Manufacturing/
Products (308)
P!umbing/HVAC(171)
Printing/Graphic Arts
(27)
Private Citizen
Real Estate (65)
Recreation Services
(79)
Recycling (509)
Repair, Misc. (76)
Research & Testing
Facilities/Laboratories
(873)
Restaurants (581
Retail/Wholesale Trade
(50,51,59)
Rubber Manufacturing/
Products (30)
Sawmil Is/Loggi n g/
Wood Products (24)
Schools (82)
Hotline
Onsite
Visit
Seminars/
Workshops
Publications
Home Page
Teleconference
Mailings
Other
TOTAL
BUSINESSES
REACHED
13
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TABLE A
Industry Sector (SIC)
Stone/Clay/Glass (32)
Textiles & Apparel
(22, 23)
Transit (Passenger)
(41)
Transportation
Equipment (37)
Transportation
Services (42, 44, 47)
Utilities (49)
Veterinarians (074)
Waste/Waste Hauling
(495)
Wastewater Treatment
(495)
Cross Sector
Other
TOTAL
Hotline
Onslte
Visit
Seminars/
Workshops
Publications
Home Page
Teleconference
Mailings
Other
TOTAL
BUSINESSES
REACHED
IKIII.._I.I ._ ^^^__^M_Bp
14
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Please indicate the total number of assistance requests your program receives by Clean Air Act
requests and multimedia requests.
TABLED
TYPE OF ASSISTANCE REQUESTED
Compliance/Regulatory Information
Monitoring
Recordkeeping
Financial/Funding Information
Permitting
General CAA Information
Add to General Mailing List
P2 Assistance
Other
TOTAL
TOTAL # OF REQUESTS
CAA Requests
Non-air/Multimedia
Requests
3.2 Please list any high-priority industry sectors that your program targeted for assistance
during this reporting period.
3.3 Briefly describe any outreach methods that were particularly effective for your
program and why (e.g., number of businesses reached, cost effectiveness, improvements
in compliance).
15
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3.4 Please provide a list of new documents that were prepared and distributed by your
program during this reporting period. List industry sector, if applicable.
3.5 If your SBTCP services include an electronic bulletin board or Internet home page,
please list the information that is accessible.
Information Available Through
the Bulletin Board or Home Page
Program description
Contact listings
Copies of regulations
Permitting information
Permit forms
Emission inventory
Policies
Guidance documents, fact sheets, etc.
Information on P2 options
Multimedia
List of available publications
CAP information
Calendar of events
Links to related sites
Other (please list)
Please check appropriate boxes
Do you ask for feedback on your web site or bulletin board? If so, what are your most
common comments?
16
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How many times was your electronic bulletin board or home page accessed during the
1998 reporting period)?
COMPLIANCE ADVISORY PANEL
3.6 What were the major activities of the CAP during this reporting period?
Major CAP Activities
Review of documents for readability and/or content
Appointment/hiring of staff and/or election of officers
Review/advisement on SBO/SBAP outreach activities
Review/comment on new/proposed regulations
Review/comment on state legislative actions
Defining CAP responsibilities
Attendance by CAP members at training sessions
Meeting with small businesses/associations
Other (please list)
Please check appropriate boxes
OTHER SERVICES/CONDUCT OF ACTIVITIES
3.7 Does your program have or is your program planning a grant or loan program to assist
small businesses comply with the CAA?
If YES, please indicate the date (month/year) such a grant or loan program became/will
become available and the funding levels for each.
DATE
AVAILABLE
GRANTOR
LOAN?
NAME OF PROGRAM
FUNDING LEVEL
17
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3.8 Briefly describe the types of cooperative efforts that each component of the SBTCP has
in place. How are you partnering with others?
This question is critical to understanding how some programs, with limited budgets and resources (typically
with the SBAP and SBO components) function. For example, what types of cooperative efforts are in place
with personnel from other departments, agencies, or organizations?
SBTCP
COMPONENT
SBO
SBAP
CAP
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
3.9 How does your program avoid duplication of efforts with SBTCPs in other states or
territories?
We want to find out to what extent programs share or exchange information with SBTCPs in other states and
territories. For example, did other programs develop factsheets or information packets that your SBTCP used
(with minimal editing)?
Strategy to Avoid Duplication of Efforts
Communication/networking within own SBTCP and state agency
personnel via phone, e-mail, mailing lists, etc.
Meetings, conference calls, and other contacts with SBO/SBAP
personnel within EPA region
Networking through state or regional air group meetings (such as
WEST AR- Western States Air Resources)
Review of EPA documents/contacts with EPA
Review of documents from other public, private, and/or university
sources
Information gathering from electronic sources
Subscribe to SBO listserve or government ombudsman listserve
Other (please list)
Please check appropriate boxes
18
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3.10 Please indicate what actions were initiated by your SBTCP/CAP to follow the intent of
the provisions of the Paperwork Reduction Act, the Regulatory Flexibility Act, and the
Equal Access to Justice Act.
The CAP is responsible for critiqueing how well the SBTCP follows the intent of the provisions of these three
federal acts. To make it easy to complete this question, various possibilities for each Act are listed in the tables
below. Please add additional items as appropriate.
PAPERWORK REDUCTION ACT
Routine review of information collection activities conducted by
SBAP to ensure the information request is not duplicative or
unnecessarily burdensome
Routine review of SBTCP documents for compliance
Receiving/providing information electronically
Simplified/consolidated permits or forms
Eliminating unnecessary permits by increasing exemptions for
insignificant actions
General permits for certain types of industries
Other (please list)
Please check appropriate boxes
REGULATORY FLEXIBILITY ACT
Ensure that small businesses are allowed to participate in
rulemakings that have an effect on them
Ensure that all existing rules periodically are reviewed to
determine their impact on small businesses and changed as
necessary
Routine review of SBTCP documents for compliance
Amnesty program
Other (please list)
Please check appropriate boxes
EQUAL ACCESS TO JUSTICE ACT
Routine compliance review of SBTCP documents
Review of instances where state actions
appear unjustified
Pro bono legal services
Funding/technical assistance for groups
actions
against small businesses
aggrieved by regulatory
Other (please list)
Please check appropriate boxes
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SECTION 4
PROGRAM EFFECTIVENESS
These questions are designed to collect information about program goals, measurement of effectiveness, and results.
4.1 What are your program's goals?
Please indicate up to 3 choices, but number in terms of priority.
RANK
PROGRAM GOAL
To increase the regulated community's understanding of their environmental obligations.
To increase the regulated community's understanding of the permitting process.
To increase the regulated community's understanding of the CAA.
To provide site-specific compliance assistance.
To encourage self-auditing.
To improve the compliance rates of the regulated community.
Other (please explain).
4.2 How are you evaluating whether your above-stated goals are or are not being met?
For example, you may use questionnaires, statistics on the number of businesses helped in a certain manner,
the number of new permits issued, etc. Ideally, your goals and assessment strategies will be stated in
quantifiable terms (e.g.. The SBTCP will target 2 business sectors through mailings, seminars, and on-site
assistance to increase their rate of permit filings by 50%.). Your program may still be at the stage where your
goals are of a more general nature (e.g., The SBTCP will provide services to small businesses through a
hotline, on-site visits, seminars, etc.).
20
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4.3 What are the results of this measurement process?
Did your SBTCP meet its program goals? Did the measurement system work? What statistics or comments
did your SB TCP gather to indicate that your goals have or have not been met?
4.4 Please feel free to include any information about your program that you would like to
highlight (i.e., significant accomplishments, awards, recognitions, move to multimedia,
etc.).
21
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4.5 Please share any tips/hints/barriers first developed or recognized by your program (e.g.,
Tips: Performance based reporting ideas, Hints: Ways to optimize program delivery,
Barriers: Legislative mandate for appointing CAP and potential conflict with reporting
process).
4.6 Success stories/case studies are strong examples of a program's effectiveness. Please
share any success stories/case studies, including type of business(es) helped, existing
problems, outreach methods used, improvements in compliance, etc.
22
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SECTION 5
COMPLIANCE ASSISTANCE
5.1 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 Maximum Achievable Control Technology (MACT)
or New Source Performance Standards (NSPS), or unpermitted emissions. Please indicate if certain problems
are prevalent in any particular industry sector. A number of possible answers are listed below. Please check
all those appropriate.
Common Compliance Problems
Not understanding regulatory requirements
Operating without a permit
Incomplete recordkeeping
Uncertain of permitting requirements/need for multiple permits
Uncertain how to determine emission inventories/general lack of
technical experience
Uncertain how to complete forms/complicated paperwork
Lack of financing for pollution control equipment/technologies
Operating outside NSPS or MACT
Improper storage/disposal of hazardous waste
Fear of regulatory agency/arbitrary regulatory enforcement
Failure to use or find the right equipment to comply with
applicable standards
Other (please list)
Any specific
industry
sector?
Please check
appropriate boxes
Please list any specific regulations, monitoring, or recordkeeping requirements that are
particular problems.
Please add any additional comments you have regarding common compliance problems.
23
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5.2 What changes would you recommend, at either the state or federal level, to assist small
businesses to comply with the CAA?
Please list any suggestions you have. We intend to compile the list of recommendations and highlight these
in the report to Congress.
5.3 Briefly describe how the SBTCP avoids internal or external conflicts of interest (COI)
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 want to know how programs avoid COI and maintain confidentiality —particularly in
those cases where the SBAP is in the regulatory agency.
5.4 Has your program used EPA's Policy on Compliance Incentives for Small Businesses
(Small Business Policy) or a comparable state policy for small businesses/small
communities? If so, please provide narrative details on your activities in the boxes
below, and then complete the table for the period January through December 1998.
SMALL BUSINESS POLICY ACTIVITIES
SMALL COMMUNITY POLICY ACTIVITIES
24
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Small
Business
Policy
Small
Communities
Policy
# Small Entities
Qualifying Under
the Policy
# Small Entities
Attempting to Use
Policy, Still Under
Consideration
# Small Entities
Attempting to Use
Policy, But Not
Qualifying
Total $ Amount of
Penalties Reduced
This is the end of the 1998 SBTCP Annual Reporting Form. Thank you, and all contributors,
for the completeness and accuracy of your Report A copy of the EPA 1998 Report to Congress
will be provided upon its submittal.
25
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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 (2131)
WATERSIDE MALL, ROOM 3424
WASHINGTON, DC 20460
800-368-5888
202-260-0490 (in DC area)
202-401-2302 (fax)
The Office of the Small Business Ombudsman serves as an effective conduit for small
businesses to access EPA and facilitates communications between the small business
community and the Agency. The Office reviews and resolves disputes with EPA and works with
EPA personnel to increase their understanding of small businesses in the development and
enforcement of environmental regulations.
The SBO's primary customer group is the nation's small business community. Significant
secondary customer groups include state and EPA regional small business ombudsmen and
national trade associations serving small businesses.
In response to the identified needs of the Office's target customer groups, the SBO has
undertaken a variety of major outreach efforts including:
• Serving as liaison between small businesses and the EPA to promote understanding of
Agency policy and small business needs and concerns.
• Staffing a small business hotline that provides regulatory and technical assistance
information.
• Maintaining and distributing an extensive collection of informational and technical
literature developed by the various EPA program offices.
• Making personal appearances as a speaker or panelist at small business-related
meetings.
• Interfacing on an on-going basis with over 70 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 450 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 business1 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.
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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 29 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
202-260-0490 (in DC area)
Callers request information on a variety of topics including:
• Clean Air Act regulations
• Underground storage tank notification
• Small quantity generator requirements
• Effluent standard guidelines
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• Used oil
• Asbestos compliance
• Waste minimization/pollution prevention
• Pesticide registration fees.
Increases in the number of direct-dial calls and hotline calls (from 4,000 calls per year in the
early 1980s to the current level of 1,000 -1,500 calls per month) and the associated distribution
of technical and informational literature, growth in requests for personal appearances at
conferences and workshops, and an expansion in participation in policy-making activities are
evidence of the customer groups' confidence in the integrity and proactive stance of the SBO.
REGULATORY TRACKING AND ANALYSIS
The SBO performs a careful review of all proposed regulatory actions published in the biannual
regulatory agenda to make a prima facia determination of small business impact. From the
agenda, certain proposed regulations are selected that appear to have the potential for adverse
impact on small businesses. In 1998, the SBO reviewed and/or monitored over 100 regulatory
actions with some significant degree of intensity. In all instances, the SBO endeavored to
minimize the requirements (especially reporting and record keeping) on small businesses.
Equally significant is the level of voluntary compliance with EPA regulations by the small
business community as a result of the rapport established between the Ombudsman and trade
associations during the developmental phase of the regulations.
MAJOR INITIATIVES IN 1998
The SBO's efforts to assist the small business community continue at a high level. Key
accomplishments and activities for 1998 (some of which are on-going) include:
• Hosted fifth National Small Business Ombudsman and Technical Assistance Program
Conference in Scottsdale, AZ, which was attended by 47 states, 2 territories, and the
District of Columbia (185 participants). Set plans and issued a grant to the state of
Florida's Environmental Protection Agency to coordinate a sixth conference in April 1999
in Tampa, FL.
• Developed external stakeholder guidance and acted as a principal participant in the
Agency's Eighth Regulatory Tiering (prioritizing) Process.
• Coordinated individual meetings and follow-up meetings among major small business
trade associations and the EPA Deputy Administrat9r, Assistant Administrators, and
Agency Small Business Program Office representatives to discuss small business
initiatives and issues. These meetings were held on April 17, June 17, September 18,
and November 24, 1998.
• Worked in cooperation with the University of Tennessee's Industrial Services Center and
the EPA Office of Air Quality Planning and Standards on a satellite teleconference on
National Volatile Organic Emissions Standards for Consumer Products.
Finalized EPA's 1997 Small Business Ombudsman Report to Congress under Section
507 of the 1990 Clean Air Act Amendments.
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Received three-year ICR approval for state Section 507 reporting for years 1998-2000
from the Office of Management and Budget.
Cooperatively managing the Small Business Regulatory Enforcement Fairness Act of
1996 Small Business Entity Outreach Sub-group to implement Act requirements.
Conducted Small Business Liaison Conference for EPA Regional Small Business
Representatives in August 1998.
Developed an EPA Small Business Ombudsman Internet home page at
www.epa.gov/sbo.
Conducted a state Compliance Advisory Panel Training and Networking Meeting in
Scottsdale, AZ on March 29,1998.
Developed a State Multimedia Resource Guide for Small Business Assistance Programs.
Developed the Environmental Management Assistance Guide for Small Laboratories.
Developing a Compliance Advisory Panel (CAP) Guidance Manual to assist state CAPs
with their Clean Air Act responsibilities.
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APPENDIX C
FEDERAL SMALL BUSINESS
ASSISTANCE PROGRAM
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APPENDIX C
ERA'S FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM
The EPA provides technical guidance for the use of the states/territories in the implementation of
their programs. The Federal Small Business Technical Assistance Program (Federal SBAP) is
coordinated by the Information Transfer Group (ITG) of the Office of Air Quality Planning and
Standards (OAQPS). Other EPA programs participating in activities to assist the states include the
Office of Compliance, the Chemical Emergency Preparedness and Prevention Office, and the
Pollution Prevention Division.
ELECTRONIC ACCESS
The Federal SBAP is actively involved in expanding the use of electronic media as a tool for access
to EPA information by small businesses, state SBAPs, and the general public.
• The SBAP home page on the World Wide Web, part of the Technology Transfer Network
(TTN), provides access to EPA small business assistance information and materials. Links
to other small business-related sites also are provided. The SBAP home page address is
www.epa.gov/ttn/sbap. In 1998, users retrieved over 1,500,000 files from the TTN.
The SBAP home page serves as a communication link for state SBAPs and includes a list
of state and EPA small business program contacts. The home page also provides a forum
to share information and outreach materials developed specifically for small businesses.
• The Office of Air and Radiation, Policy and Guidance home page, also part of the
Technology Transfer Network, contains proposed and final rules; background, guidance,
and plain-English fact sheets; and implementation strategy updates and schedules.
PLAIN ENGLISH GUIDANCE MATERIALS
The Federal SBAP prepares materials for use by the states to explain new EPA CAA rules in plain
English. These include detailed guidebooks with options for compliance, including pollution
prevention; sample reporting and recordkeeping forms; and example calculations. These are
distributed to state SBAPs as well as directly to small businesses; both hard copy and electronic
formats are provided to allow for state-specific customization and reproduction as needed.
Halogenated Solvent Cleaning (completed May 1995).
Chromium Electroplating and Anodizing (completed May 1995).
Wood Furniture (completed September 1997).
Work has started on guidance for Potential-To-Emit (PTE) to assist businesses with PTE
calculations. This document will be available in early 1999.
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SATELLITE SEMINARS
The Federal SBAP is working with EPA's Small Business Ombudsman (SBO) and OAQPS's
Education and Outreach Group to present a series of satellite downlink seminars to educate small
businesses on new EPA air regulations. These seminars include:
Perc Drycleaners (May 1994) had 3,000 participants at 197 sites in 48 states, one Canadian
site, and two in Mexico.
Halogenated Solvent Cleaning/Degreasing (May 1995) had 1,300 participants at 101 sites
in 45 states, one site in Canada, and two in Mexico.
Chromium Electroplating (November 1995) had 2,000 participants at 140 sites in 43 states.
Green and Profitable Printing (May 1996) was presented in cooperation with EPA's Office
of Compliance through the Printer's National Environmental Assistance Center.
Wood Furniture Manufacturing (September 1996) had approximately 1,900 participants at
140 sites in 34 states.
• Consumer Products (October 1998) had approximately 600 participants at 100 sites in 40
states. This project included a post-broadcast help-site on the Internet, and distribution of
broadcast video tapes upon request.
ANNUAL CONFERENCE
From 1993 to 1997, EPA held an annual SBO/SBAP Conference, which was co-sponsored by
OAQPS's Federal SBAP and the EPA SBO. In 1998, responsibility for the annual conference was
moved to an individual State program; funding was provided by EPA in the form of a grant. The host
State was assisted in conference planning by a committee of State program representatives. The
1998 meeting was hosted by the Maricopa County Small Business Environmental Assistance
Program, and held in Scottsdale, Arizona, with 185 attendees from 50 states and territories, and
seven local agencies. The purpose of this meeting was to:
Facilitate communication among the state programs.
Facilitate implementation and operation of small business assistance programs.
Interpret regulatory and policy developments affecting small businesses.
OTHER PARTNERSHIP ACTIVITIES
The Federal SBAP is working with staff from EPA's Office of Policy, Office of Compliance, and
Pollution Prevention Division to determine a strategy to encourage all of the various small business
assistance providers (i.e., SBAPs, Small Business Development Centers, pollution prevention
programs, Manufacturing Extension Programs, etc.) to coordinate efforts within their state. This
would provide small businesses with easier access to comprehensive business and environmental
assistance.
-------
APPENDIX D
SBTCP STATUS, BUDGETS, STAFFING
AND ORGANIZATION
-------
TABLE D-1
STATE SMALL BUSINESS ASSISTANCE PROGRAMS
KEY CONTACT LISTING
DECEMBER 15, 1999
Under State column, (A) denotes an "air only" assistance program, (M) denotes a multimedia assistance program.
STATE
OMBUDSMAN
SBAP
OTHER SBAP
ALABAMA
(M)
Blake Roper, Ombudsman
Office of Education & Outreach
Alabama Department of Environmental
Management
P. 0. Box 301463
Montgomery, AL 36130-1463
334-394-4355
334-271-7950 (F)
800-533-2336 (national)
rbr@adem.state.al.us
www.adem.state.al.us
Mike Sherman
Air Division
Alabama Department of Environmental
Management
P.O. 60X301463
Montgomery, AL 36130-1463
334-271-7873
334-279-3044 (F)
800-533-2336 (national)
mhs@adem.state.al.us
ALASKA
(M)
Tom Chappie
Small Business Assistance
ADEC
555 Cordova Street
Anchorage, AK 99501
907-269-7686
907-269-7687 (F)
800-510-2332 (state)
tchapp!e@envircon.state.ak.us
www.state.ak.us/local/akpages/ENV.
CONSERV/dsps/compasst/caoJiome.htm
ARIZONA
(M)
Dual role SBO and SBAP
Gregory Workman
AZ DEQ - Compliance Assistance
3033 N. Central Avenue
Phoenix, AZ 85012
602-207-4337
602-207-4872 (F)
800-234-5677 (state)
workman.gregory@ev.state.az.us
www.adeq.state.az.us
Cathy Chaberski
AZDEQ
3033 N. Central Avenue
Phoenix, AZ 85012
602-207-2233
602-207-4872 (F)
800-234-5677 (state)
chaberski,catherine@ev.state.az.us
www.adeQ.state.az.us
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
ARIZONA -
Maricopa County
(A)
Richard Polito
Maricopa County SBEAP
1001 N. Central, Suite 500
Phoenix, AZ 85004
602-506-5102
602-506-6669 (F)
rpolito@mail.maricopa.gov
www.maricopa.gov/sbeap
Maureen Lynch or JaeChang
Maricopa County SBEAP
1001 N! Central, Suite 500
Phoenix, AZ 85004
602-506-5150 or 5149
602-506-6669 (F)
mlynch@mail.maricopa.gov or
jchang@iriail.maricopa.gov
www.maricopa.gov/sbeap
ARKANSAS
(M)
Joe Bob Garner
Department of Environmental Quality
P.O. Box 8913
8001 National Drive
Little Rock, AR 72219-8913
501-682-0866
501-682-0880 (F)
888-233-0326 (national)
garner@adeq.state.ar.us
www.state.ar.us
Kevin Pierson
Department of Environmental Quality
P.O. Box 8913
8001 National Drive
Little Rock, AR 72219-8913
501-682-0819
501-682-0880 (F)
888-233-0326 (national)
pierson@adeq.state.ar.us
www.staTe.ar.us
CALIFORNIA
(M)
Kathleen Tschogl
Office of the Ombudsman
California EPA
Air Resources Board
2020 L Street
Sacramento, CA 95814
916-323-6791
916-323-2393 (F)
800-arb-hlp2 (state)
ktschogl@arb.ca.gov
Ombudsman@arD.ca.gov
www.arb.ca.gov
Peter Venturini
California EPA
Air Resources Board
Stationary Source
2020 L Street
P.O. Box2815
Sacramento, CA 95814
916-445-0650
916-327-7212 (F)
800-272-4572 (state)
pventuri@arb.ca.gov
Jon Pederson
California EPA
CARB-Office of Sm. Business Ombudsman
2020 L Street
P.O. Box 2815
Sacramento, CA 95814
916-322-2825
916-323-2393 (F)
jpederso@arb.ca.gov
CALIFORNIA -
South Coast
(A; M by referral)
La Ronda Bowen, Public Advisor
South Coast Air Management District
Small Business Assistance Office
21865 E. Copley Drive
Diamond Bar, CA 91765
909-396-3235
909-396-3638 (F)
800-388-2121 (state)
800-CUT-SMOG (state)
lbowen@aqmd.gov
www.aamd.gov
Larry Kolczak.Community Relations Manager
South Coast Air Management District
Small Business Assistance Office
21865 E. Copley Drive
Diamond Bar, CA 91765
909-396-3215
909-395-3335 {F)
800-388-2121 (state)
800-CUT-SMOG (state)
lkolczak@aqmd.gov
www.aamd.gov
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
COLORADO
Cathy Heald
CDPHE
OCS-INF-A1
4300 Cherry Creek Drive, South
Denver, CO 80246-1530
303-692-2034
303-691-1979 (F)
800-886-7689 (state)
cathy.heald@siate.co.us
Nick Melliadis
CDPHE
APCD/55/B-1
4300 Cherry Creek Drive, South
Denver, CO 80246-1530
303-692-3175
303-782-5493(F)
nick.melliadis@state.co.us
CONNECTICUT
(M)
Tracy Babbidge, Ombudsman
Small Business Assistance Program
Department of Environmental Protection
79 Elm Street
Hartford, CT 06106-5127
860-424-3382
860-424-4063 (F)
800-760-7036 (state)
tracy.babbidge@po.state.ct.us
http://dep.state.ct.us
DELAWARE
(A)
George Petitgout
Small Business Ombudsman
Delaware DNREC
P.O. Box 1401
Dover, DE 19903
302-739-6400
302-739-6242 (F)
gpetitgout@dnrec.state.de.us
www.dnrec.state.de.us
George Petitgout
Dual Role as SBAP Director
Bob Barrish
Delaware DNREC
715 Grantham Lane
New Castle, DE 19720
302-323-4542
302-323-4561 (F)
bbarrish@state.de.us
www.dnrec.state.de.us
DISTRICT OF
COLUMBIA
(A)
Sandra Handon
Small Business Ombudsman
DC Department of Health/EHA/AQD
51 N Street NE, 5th Floor
Washington, DC 20002-3323
202-535-1722
202- 535-2881 (F)
shandon@mail.environ.state.dc.us
N. Olivia Achuko
DC Department of Health/EHA/AQD
51 N Street NE, 5th Floor
Washington, DC 20002-3323
202-535-2997
202- 535-2881 (F)
noa@mail.environ.state.dc.us
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
FLORIDA
(M)
Elsa Bishop
SBAP Program Administrator &
Ombudsman
FL Department of Environmental Protection
2600 Blair Stone Road, MS 5500
Tallahassee, FL 32399-2400
850-414-8399
850-922-6979 (F)
800-722-7457 (state)
elsa.bishop@dep.state.fl.us
www.dep.stale.fl.us/air/outreach/sbap/
sbapl .htm
Bruce Thomas
Small Business Assistance Program
FL DEP
2600 Blair Stone Road, MS-5500
Tallahassee. FL 32399-2400
850-921-7744
850-922-6979 (F)
800-722-7457 (state)
thomas_bx@dep.state.fl.us
Shanisha Reese
Small Business Assistance Program
FL DEP
2600 Blair Stone Road, MS-5500
Tallahassee, FL 32399-2400
850-921-9584
850-922-6979 (F)
800-722-7457 (state)
reese_s@dep.state.fl.us
GEORGIA
(M)
Marvin M. Lowry
GA SBAP
4244 International Parkway, Suite 120
Atlanta, GA 30354
404-362-2656
404-363-7100 (F)
888-373-5947 (state)
marvinjowry@mail.dnr.state.ga.us
www.gasmallbiz.org
Anita Dorsey-Word
GASBAP
4244 International Parkway, Suite 120
Atlanta, GA 30354
404-362-4842
404-363-7100 (F)
adword@mail.dnr.state.ga.us
888-373^5947 (state)
www.gasmallbiz.org
HAWAII
(A-SBAP; M-SBO)
Anthony China
HI Department of Health
Compliance Assistance Office
919 Ala Moana Boulevard, Suite 219
Honolulu, HI 96814
808-586-4527
808-586-7236 (F)
tiching@mail.health.state.hi.us
Robert Tam
HI Department of Health
Clean Air Branch
919 Ala Moana Boulevard, Suite 203
Honolulu, HI 96814
808-586-4205
808-586-4359 (F)
rtam@eha.health.state.hi.us
Willie Nagamine
HI Department of Health
Clean Air Branch
P.O. Box 3378
Honolulu, HI 96801
808-586-4200
808-586-4359 (F)
IDAHO
(M)
John Bernardo (Acting)
Division of Environmental Quality
1410 North Hilton
Boise, ID 83706
208-373-0114
208-373-0342 (F)
jbernard@deq.state.id.us
www2.state.id.us/deq
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
ILLINOIS
(A)
Donald Squires
Illinois EPA/DAPC
Small Business Ombudsman
1021 N. Grand Avenue East, 2nd Floor
P.O. Box19276
Springfield, IL 62794-9276
217-785-1625
217-785-8346 (F)
888-372-1996 (state)
epa8139@epa.state.il.us
www.epa.state.il.us
Mark Enstrom
Illinois Department of Commerce
and Community Affairs
620 East Adams Street, 3rd Floor
Springfield, IL 62701
217-524-0169
217-785-6328 (F)
800-252-3998 (state)
menstrom@commerce.state.il.us
www.commerce.state.il.us
INDIANA
(M)
Erika Seydel Cheney
IDEM - OB&LR
100 N. Senate
P.O. Box 6015
Indianapolis, IN 46206-6015
317-232-8598
317-232-6647 (F)
800-451-6027 (press 0, request x 2-8598)
eseyael@dem.state.in.us
www.state.in.us/idem/ctap
Cheri Storms
IDEM - CTAP
100 N. Senate Avenue
P.O. Box 6015
Indianapolis. IN 46206-6015
317-233-1041
317-233-5627 (F)
800-451-6027 (press 0, request x 3-1041)
(state)
cstorms@dem.state.in.us
www.state.in.us/idem/ctap
Paula Smith
IDEM - CTAP
100 N. Senate Avenue
P.O. Box 6015
Indianapolis, IN 46206-6015
317-232-8172
317-233-5627 (F)
800-451-6027 (press 0, request x 2-8172)
(state)
psmitn@dem.state.in.us
www.state.in.us/idem/ctap
IOWA
(M)
Linda King
IA Department of Development
Small Business Liaison for Air Quality
200 E. Grand Avenue
Des Moines, IA 50309
515-242-47^1
515-242-4749 (F)
800-351-4668 (national)
linda.king@ided. state, ia.us
www.stafe.ia.us/sbro
John Konefes
IA Waste Reduction Center
University of Northern Iowa
1005 Technology Parkway
Cedar Falls, IA 50613-6951
319-273-8905
319-268-3733 (F)
800-422-3109 (state)
konefes@uni.edu
www.iwrc.org
Scott Vander Hart
Iowa Department of Natural Resources
Air Quality Bureau
7900 Hickman Road
Urbandale, IA 50322
515-281-6061
515-242-5094 (F)
svander@max.state.ia.us
KANSAS
(M)
Janet Neff
Environmental Ombudsman
Planning & Prevention Section
KS DH&E
Forbes Field, Building 283
Topeka, KS 66620
785-296-0669
785-291-3266 (F)
800-357-6087 (national)
jneff@kdhe.state.ks.us
www.sbeap.niar.twsu.edu
www.kdhe.state.ks.us
Frank Orzulak, Director
Division of Continuing Education
University of Kansas
1515 St. Andrews Drive
Lawrence, KS 66047-1625
785-864-3978
785-864-5827 (F)
800-578-8898 (national)
forzulak@falcon.cc.ukans.edu
www.sbeap.niar.twsu.edu
Jean Waters
Small Business Assistance Program
Pollution Prevention Institute
Kansas State University
133 Ward Hall
Manhattan, KS 66506-2508
785-532-4698
785-532-6952 (F)
800-578-8898 (national)
jeansw@ksu.edu
www.sbeap.niar.twsu.edu
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
KENTUCKY
(A)
Rose Marie Wilmoth
Air Quality Representative for Small
Business
Commissioner's Office
Department for Environmental Protection
14 Reilly Road, Ash Building
Frankfort, KY 40601
502-564-2150, x128
502-564-4245 (F)
800-926-8111 (national)
wilmoth@nrdep.nr.state.ky.us
www.nr.state.ky.us/nrepc/aep/smbizair/
index.htm
Gregory C. Copley, Director
Kentucky Business Environmental Assistance
Program
UK Center for Entrepreneurship
Gatton College of Business and Economics,
Room 227
Lexington, KY 40506-0034
606-257-1131
606-323-1907 (F)
800-562-2327 (national)
kbeap@pop.uky.edu
http://gaiton.gws.uky.edu/KentuckyBusiness/
kbeap/kbeap.htm
Susan Weaver
Division for Air Quality
KY DNR&EP
803 Schenkel Lane
Frankfort, KY 40601
502-573-3382
502-573-3787 (F)
Susan.Weaver@mail.state.ky.us
http://www.state.ky.us/agencies/nrepc/dep/
daq/daqhome.html
KENTUCKY -
Jefferson County
(A)
Cara S. Waddell
Small Business Air Pollution Ombudsman
Department of Planning & Environmental
Management
810 Barrett Avenue, Room 637
Louisville, KY 40204
502-574-5164
502-574-8188 (F)
LOUISIANA
(M)
Jim Friloux, Small Business Ombudsman
LDEQ
P.O. Box 82263
Baton Rouge, LA 70884
225-765-0735
225-765-0746 (F)
800-259-2890 (state)
jim_f@deq.state.la.us
www.oeq.state.la.us/oarp/sbap/sbap.htm
Dick Lehr
LDEQ
P.O. Box 82135
Baton Rouge, LA 70884-2135
225-765-272$
225-765-0921 (F)
800-259-2890 (state)
richard_l@deq.state.la.us
www.deq.state.la.us/oarp/sbap/sbap.htm
Beth Altazan-Dixon
LDEQ
P.O. Box82135
Baton Rouge, LA 70884-2135
225-765-2456
225-765-0921 (F)
800-259-2890 (state)
beth_a@deq.state.la.us
www.deq.state.la.us/oarp/sbap/sbap. htm
MAINE
(M)
Ron Dyer
Maine DEP
Office of Innovation and Assistance
Station 17
State House
Augusta, ME 04333
207-287-4152
207-287-2814 (F)
800-789-9802 (state)
ron.e.dyer@state.me.us
www.state.me.us/dep
Brian Kavanah
Maine DEP
Office of Innovation and Assistance
Station 17
State House
Augusta, ME 04333
207-287-6188
207-287-2814 (F)
800-789-9802 (state)
brian.w.kavanan@state.me.us
www.state.me.usTaep
Jim Brooks
Maine DEP
Bureau of Air Quality
Station 17
State House
Augusta, ME 04333
207-287-2437
207-287-7641 (F)
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
MARYLAND
(M)
John Mitchell
MD Department of the Environment
Office of Community Assistance
2500 Broening Highway
Baltimore, MD 21224
410-631-3772
410-631-4477 (R
800-633-6101, x3003 (state)
jmitchell@mde.state.md.us
www.mde.state.md.us
Andrew Gosden
MD Department of the Environment
Environmental Permits Service Center
2500 Broening Highway
Baltimore. MD 21224
410-631-4158
410-631-4477 (F)
800-633-6101 X4158 (state)
www.mde.state.md.us
Susan Battle
Environmental Permits Service Center
MD Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
410-631-3772
410-631-4477 (F)
800-633-6101 (state)
sbattle@mde.state.md.us
www.mde.state.md.us
MASSACHUSETTS
(M)
Rick Reibstein
MA Office of Technical Assistance for Toxics
Use Reduction
100 Cambridge Street, Room 2109
Boston, MA 02202
617-727-3260x688
617-727-3827 (F)
rick.reibstein@state.ma.us
www.magnet.state.ma.us/ota
MICHIGAN
(A)
Dana Lee Cole
Ml Jobs Commission
Victor Center, 4th Floor
201 N. Washington
Lansing, Ml 48913
517-241-3518
517-241-3689(F)
www.michigan.org
Dave Fiedler
Clean Air Assistance Program
MDEQ Environmental Assistance Division
P.O. Box 30457
Lansing, Ml 48909
517-373-0607
517-335-4729 (F)
800-662-9278 (national)
fiedlerd@state.mi.us
www.deq.state.mi.us/ead/eosect/caap
MINNESOTA
(M)
Charlie Kennedy
MPCA/PPRF/SBO
520 Lafayette Road North
St. Paul.lvIN 55155-4194
651-297-8615
651-297-8676 (F)
800-985-4247 (state)
charlie.kennedy@pca.state.mn.us
www.pca.state.mn.us/programs/
sbomb D.html
Troy Johnson
MPCA/MDRF/SBAP
520 Lafayette Road North
St. Paul, MN 55155
651-296-7767
651-282-6247 (F)
800-657-3938 (state)
troy.johnson@pca.state.mn.us
www.pca.state.mn.us/programs/sbap_p.html
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
MISSISSIPPI
(M)
Jesse Thompson, Jr.
Small Business Ombudsman
MSDEQ
2380 Hwy. 80 West
P.O. Box 20305
Jackson, MS 39289
601-961-5167
601-961-5541 (F)
800-725-6112 (national)
Jesse Thompson@deq.state.ms.us
www.deq.state.ms.us
Randy Wolfe
Small Business Technical Assistance Dir.
MSDEQ
2380 Hwy. 80 West
P.O. Box 20305
Jackson, MS 39289
601-961-5166
601-961-5541 (F)
800-725-6112 (national)
Randy Wolfe@deq.state.ms.us
www.deq.state.ms.us
Cathy Johnson / Operations Management
Analyst/SBAP
MSDEQ
2380 Hwy. 80 West
P.O. Box 20305
Jackson, MS 39289
601-961-5676
601-961-5541 (F)
800-725-6112 (national)
Cathy_Johnson@deq. state, ms. us
MISSOURI
(M)
Angle Heffner
State of Missouri
Office of the Governor
State Capitol
Jefferson City, MO 65102
573-751-3222
573-526-5808 (F)
800-361-4827 (national)
@mail.gov.state.mo.us
Byron Shaw, Jr.
DNRTe • • -
echnical Assistance Program
Jefferson State Office Building
1659 E. Elm Street
P.O. Box 176
Jefferson City, MO 65102
573-526-6627
573-526-5808 (F)
800-361-4827 (national)
nrshawb@mail.dnr.state.mo.us
www.dnr.state.mo.us/deq/tap/hometap.htm
MONTANA
(M)
Karen Ekstrom
Department of Environmental Quality
Business & Community Assistance
1520 E. 6th Avenue
P.O. Box 200901
Helena, MT 59620-0901
406-444-2960
406-444-6836 (F)
800-433-8773 (state)
kekstrom@mt.gov
www.deq.state.mt.us
Warren Norton
Department of Environmental Quality
Air Quality Division
1520 E. 6th Avenue
P.O. Box 200901
Helena, MT 59620-0901
406-444-5281
406-444-1499 (F)
800-433-8773 (state)
wnorton@mt.gov
www.deq.state.mt.us
Mark Lambrecht
Department of Environmental Quality
Mar. Bus. and Community Assistance
1520 E. 6th Avenue
P.O. Box 200901
Helena, MT 59620-0901
406-444-2960
406-444-6836 (F)
800-433-8773 (state)
malambracht@mt.gov
www.deq.state.mt.us
NEBRASKA
(M)
Dan Eddinger
Public Advocate
NE Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68503
402-471-3413
402-471-2909 (F)
877-253-2603 (state)
deq178@deq.state.ne.us
de2141T@navix.net
www.dea.state.ne.us
Dan Eddinger
Dual Role as Ombudsman and SBAP
Principal
8
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
NEVADA
(M)
Marcia Manley
Small Business Ombudsman
NV Division of Environmental Protection
333 West Nye Lane
Carson City, NV 89706-0851
702-687-4670, x3162
702-687-5856 (F)
mmanley@ndep.carson-city.nv.us
www.state.nv.us/ndep/sba/sba01.htm
Janet Goodman
Technical Assistance Coordinator/SBAP
NV Division of Environmental Protection
333 West Nye Lane
Carson City, NV 897060851
702-687-4670, x3164
702-687-5856 (F)
jgoodman@ndep.carson-city.nv.us
www.state.nv.us/ndep/sba/sba01.htm
Kevin Dick
UNR/NV SBDC
Business Environmental Program
College of Business Administration-032
Reno, NV 89505-9975
702-784-1717
702-784-4237 (F)
NEW HAMPSHIRE
(M)
Rudolph Cartier
Dual Role as Ombudsman and SBAP
Principal
Rudolph Cartier
Air Resources Division
Department of Environmental Services
6 Hazen Drive
Concord, NH 03301-2033
603-271-1379
603-271-1381 (F)
800-837-0656 (state)
r_cartier@des.state.nh.us
NEW JERSEY Lauren Moore
(M) Office of Business Advocacy
NJ Commerce Commission
20 West State Street
P.O. Box 839
Trenton, NJ 08625-0839
609-292-3863
609-777-4097 (F)
800-643-6090 (national)
ceamoor@cpmmerce.state.nj.us
www.state.nj.us/commerce/caasbo.htm
Chuck McCarty
SBAP
NJDEP
401 East State Street, 3rd Floor
P.O. Box 423
Trenton, NJ 08625-0423
609-292-3600
609-777-1330 (F)
877-753-1151
cmccarty@dep.state.nj.us
www.state.nj.us/dep/aqm/sbap.htm
Jeanne Mroczko
Pollution Prevention-Permit Coordinator
SBAP
NJDEP
P.O. Box 423
Trenton, NJ 08625-0423
609-292-3600
609-777-1330 (F)
NEW MEXICO
(A)
Robert Horwitz
NM ED/AQB
Harold Runnels Building
P.O. Box26110
Santa Fe, NM 87502
505-827-9685
505-827-0045 (F)
800-810-7227 (national)
www.nmenv.state.nm.us
Cecilia Williams
NM ED/AQB
Harold Runnels Building
P.O. Box26110
Santa Fe, NM 87502
505-827-0042
505-827-0045 (F)
800-810-/227 (national)
cecilia williams@nmenv.state.nm.us
www.rirhenv.staie.nm.us
John Liberature
City of Albuquerque
EHD/APCD
P.O. Box 1293
Albuquerque, NM 87103
505-768-1964
505-768-2617 (F)
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
NEW YORK
(A)
Tria Case
Director, Environmental Business Services
NYS Empire State Development
633 3rd Avenue, 32nd Floor
New York, NY 10017
212-803-2280
212-803-2309 (F)
800-782-8369 (national)
tcase@empire.state.ny.us
www.empire .state, ny.us/sbeo/
Marian J. Mudar, Ph.D.
Environmental Program Manager
NYS Environmental Faciliites Corporation
50 Wolf Road
Albany, NY 12205
518-457-9135
518-457-8681 (F)
800-780-7227 (state)
mudar@nysefc.org
www.nysefc.org
Patrick Lentile
Bureau of Technical Support
NYS Dept. of Environmental Conservation
Division of Air Resources
50 Wolf Road, Room 110
Albany, NY 12233
518-457-7450
518-457-0794 (F)
pxlentli@gw.dec.state.ny.us
NORTH CAROLINA
(M)
Edythe McKinney
Office of the Small Business Ombudsman
Department of Environment, Health, and
Natural Resources
2728 Capital Boulevard
P.O. Box 29583
Raleigh, NC 27626
919-733-0823
919-715-7468 (F)
800-829-4841 (national)
edythe mckinney@p2pays.org
www.pZpays.org
Karen Davis
Office of the Small Business Ombudsman
Department of Environment, Health, and
Natural Resources
2728 Capital Boulevard
P.O. Box 29583
Raleigh, NC 27604
919-733-1267
919-715-6794 (F)
800-829-4841 (national)
NORTH DAKOTA
(M)
Jeff Burgess
North Dakota Department of Health
P.O. Box 5520
1200 Missouri Avenue
Bismark, ND 58506
701-328-5153
701-328-5200 (F)
800-755-1625 (state)
jburgess@state.nd.us
www.heaifti.state.nd.us
Tom Bachman
North Dakota Department of Health
Division of Environmental Engineering
P.O. Box 5520
1200 Missouri Avenue
Bismark, ND 58506
701-328-5188
701-328-5200 (F)
800-755-1625 (state)
tbachman@state.nd.us
www.healtrTstate.nd.us
Dana Mount
North Dakota Department of Health
Division of Environmental Engineering
P.O. Box 5520
1200 Missouri Avenue
Bismark, ND 58506
701-328-5188
701-328-5200 (F)
800-755-1625 (state)
dmount@state.nd.us
www.health.state.nd.us
OHIO
(A)
Mark Shanahan
Clean Air Resource Center
50 West Broad Street, Suite 1901
Columbus, OH 4321^-5985
614-728-3540
614-752-9188 (F)
800-225-5051 (state)
mark.shanahan@aqda.state.oh.us
www.state.oh.us/carc/
Rick Carleski
Ohio EPA/DAPC
Lazarus Government Center
P.O. Box1049
Columbus, OH 43216
614-728-1742
614-644-3681 (F)
614-644-4830 (state)
rcarlesk@epa.state.oh.us
www.epa.ohio.gov/dapc/sba/sbaintro
Bob Hodanbosi
Ohio EPA/DAPC
Lazarus Government Center
P.O. Box 1049
Columbus, OH 43216
614-644-2270
614-644-3681 (F)
10
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
OKLAHOMA
(M)
Steve Thompspn
Deputy Executive Director
OK Department of Environmental Quality
P.O. Box 1677
Oklahoma City, OK 73101-1677
405-702-7100
405-702-7101 (F)
Steve.Thompson@deqmail.state.ok.us
www.deq.state.ok.us
Alwin Ning
Customer Services Division
OK Department of Environmental Quality
P.O. Box1677
Oklahoma City, OK 73101-1677
405-702-6100
405-702-1317 (F)
800-869-1400 (national)
alwin.ning@deqmail.state.ok.us
Kyle Arthur
Customer Services Division
OK Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-702-9116
405-702-9101 (F)
800-869-1400 (national)
kyle.arthur@deqmail.state.ok.us
www.deq.state.ok.us
OREGON
(A)
Paul Burnet
ORDEQ
811 SW 6th Avenue
Portland, OR 97204-1390
503-229-5776
503-229-6945 (F)
800-452-4011 (state)
burnet.paul@deq.state.or.us
www.deq.state.or.us
Jill Inahara
ORDEQ
Air Quality Division
811 SW 6th Avenue
Portland, OR 97204
503-229-6147
503-229-5675 (F)
800-452-4011 (state)
inahara.jill@deq.state.or.us
www.deq.state.or.us
PENNSYLVANIA
(M)
Greg Czarnecki
Office of P2 & Compliance Assistance
PADEP
RCSOB, 15th Floor
P.O. Box 8772
Harrisburg, PA 17105
717-772-8951
717-783-2703 (F)
Czarnecki.Gregory@dep.state.pa.us
www.dep.state.pa.us
Scott Kepner
Bureau of Air Quality
PADEP
P.O. Box 8468
Harrisburg, PA 17105-8468
717-787-T663
717-772-2303 (F)
Kepner.Scott@dep.state.pa.us
www.dep.state.pa.us
Cecily Beall
PRCEnvironmental Management, Inc.
1800 JFK Boulevard, 6th Floor
Philadelphia, PA 19103
215-656-8709
215-972-0484 (F)
800-722-4743 (national)
beallc@prcemi.com
PUERTO RICO Tomas DeLeon
(A) Adminjstratpr, Commercial Development
Administration
P.O. Box 4275
San Juan, PR 00902
787-724-1451
787-722-8477 (F)
Maria Rivera
PREQB -Air Quality Area
Ponce De Leon 431
Hato Rey Pr.
P.O. Box 11488
Santurce, PR 00910
787-767-8025, x296
787-756-5906 (F)
icaaire@prtc.net
Alejandro Franco
Puerto Rico SBAP
P.O. Box 9024275
San Juan, PR 00902-4275
787-721-3290
11
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
RHODE ISLAND
(M)
Roger Greene
Rl DEM, Director's Office
235 Promenade Street, Suite 425
Providence, Rl 02908
401-222-2771 x2402
401-222-6802 (F)
800-932-1000 (state)
rgreen@doa.state.ri.us
www.state.ri.us/dem
Pam Annarummo
Rl DEM, Office of Technical & Customer
Assistance
235 Promenade Street, Suite 250
Providence, Rl 02908
401-222-6822, X7204
401-222-3810 (F)
annarump@doa.state.ri.us
www.state.n. us/dem
Joe Antonio
Rl Department of Environmental
Management
Technical/Customer Assistance
235 Promenade Street
Providence, Rl 02908
401-222-6822, X4410
401-277-3810 (FJ
800-253-2674 (state)
jantonio@doa.state.ri.us
www.staie.ri.us/dem
SOUTH CAROLINA
(M)
Phyllis T. Copeland, SBO
SC Department of Health & Environmental
Control
2600 Bull Street
Columbia, SC 29201
803-898-3997
803-898-3939 (F)
800-819-9001 (national)
copelapt@columb30.dhec.state.sc.us
www.sfate.se.us/eqc/admin/html/sbap.html
Rose Stancil
SBAP Technical Engineer Assistant
SC Department of Health & Environmental
Control
2600 Bull Street
Columbia, SC 29201
803-898-3981
803-898-3939 (F)
800-819-9001 (national)
stancirr@columb30.dhec.state.sc.us
www.staTe.se.us/eqc/admin/html/sbap.html
Willie Morgan, PE
Permitting uaison
SC Department of Health & Environmental
Control
2600 Bull Street
Columbia, SC 29201
803-898-3957
803-898-3939 (F)
800-819-9001 (national)
morganwj@columb30.ahec.state.sc.us
www.state.sc.us/eqc/admin/html/sbap.html
SOUTH DAKOTA
(M)
Joe D. Nadenicek
Small Business Ombudsman
SD Department of Environment & Natural
Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501
605-773-3836
605-773-6035 (F)
800-GET-DENR (7 state access in area)
joe.nadenicek@state.sd.us
www.state.sd.us
Brian Gustafson
SD Department of Environment & Natural
Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501
605-773-7171
605-773-5286 (F)
800-GET-DENR (7 state access in area)
brian.gustafson@state.sd.us
www.state.sd.us
TENNESSEE
(M)
Ernest Blankenship
TN Department of Environment &
Conservation
L&C Annex, 8th Floor
401 Church Street
Nashville, TN 37243
615-532-6262
615-532-8007 (F)
800-734-3619 (national)
eblankenship@mail.state.tn.us
www.state.tn.us/environment
Linda Sadler
Small Business Assistance Program
L&C Annex, 8th Floor
401 Church Street
Nashville, TN 37243
615-532-8012
615-532-8007 (F)
800-734-3619 (national)
lsadler@mail.state.tn.us
www.state.tn.us/environment
12
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
TEXAS
(M)
Israel Anderson
Small Business Ombudsman/Advocate
TNRCC(MailCode112)
P.O. Box 13087
Austin, TX 78711-3087
512-239-5319
512-239-3165 (F)
800-447-2827 (national)
ianderso@tnrcc.state.tx.us
Tamra-Shae Oatman, Manager
TNRCC (Mail Code 106)
P.O. Box 13087
Austin, TX 78711-3087
512-239-1066
512-239-1065 (F)
800-447-2827 (national)
toatman@tnrcc.state.tx.us
www.tnrcc.state.tx.us/exec/small business
Bridget Bohac
TNFTCC (Mail Code 106)
P.O. Box13087
Austin, TX 78711-3087
512-239-1066
512-239-1065 (F)
800-447-2827 (national)
bbohac@tnrcc.state.tx.us
www.tnrcc.state.tx.us/exec/small business
UTAH
(M)
Stephanie Bernkopf
UT Department of Environmental Quality
Office of Planning & Public Affairs
168 North 1950 West
Salt Lake City, UT 84114-4810
801-536-4479
801-536-0061 (F)
800-458-0145
sbernkop@deq.state.ut.us
www.deq.state.ut.us/eqoas/bus_home.htm
Ron Reece, Environmental Engineer
UT Department of Environmental Quality
Division of Air Quality
150 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114
801-536-4091
801-536-4099 (F)
800-270-4440 (national)
rreece@deq.state.ut.us
www.deq.state.ut.us/eqair/permits/
sbap3.htm
VERMONT
(M)
Judy Mirro
VT DEC Environmental Assistance Division
Laundry Building
103 South Main Street
Waterbury, VT 05671
802-241-3745
802-241-3273 (F)
800-974-9559 (state)
judym@dec.anr.state.vt.us
www.anr.state.vt.us/dec/ead/eadhome.htm
Kevin Bracey (not specific to small business
assistance)
VT Air Pollution Control Division
Building 3 South
103 South Main Street
Waterbury, VT 05671
802-241-3841
802-241-2590 (F)
kevinb@qtm.anr.state.vt.us
www.anr.state.vt.us/dec/air/default.htm
VIRGINIA
(M)
John Daniel, Jr., Director, Air Program
Coordination
VA Department of Environmental Quality
P.O. Box 10009
629 E. Main Street
Richmond, VA 23240
804-698-4311
804-698-4510 (F)
800-592-5482 (state)
jmdaniel@deq.state.va.us
www.deq.state.va.us/osba/smallbiz
Richard Rasmussen
Manager, Small Business Assistance
Program
VA Department of Environmental Quality
P.O. Box 10009
629 E. Main Street
Richmond, VA 23240
804-698-4394
804-698-4510 (F)
800-592-5482 (state)
rgrasmusse@deq.state.va.us
www.dea.staTe.va.us/osba/smallbiz
13
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
VIRGIN ISLANDS
(A)
Marylyn A. Stapleton
VI Department of Planning & Natural
Resources
Division of Environmental Protection
Wheatley Shopping Center II
Charlotte Amalie, St. Thomas, VI 00802
340-777-4577, x228
340-774-5416 (F)
Marylyn A. Stapleton
Dual role SBO/SBAP
Jasmine A. Blyden
VI Department of Planning & Natural
Resources
Division of Environmental Protection
Wheatley Shopping Center II
Charlotte Amalie, St. Thomas, VI 00802
340-777-4577
340-774-5416 (F)
WASHINGTON
(A)
Leighton Pratt
WA Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia.WA 98504-7600
360-407-7018
360-407-6802 (F)
Ipra461 @ecy. wa.gov
www.wa.gov/ecology
Bernard Brady
WA Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia. WA 98504-7600
360-407-6803
360-407-6802 (F)
bbra461 @ecy. wa .go v
www.wa.gov/ecology
WEST VIRGINIA
(M-SBO; A-SBAP)
Kenneth Shaw
WV Division of Environmental Protection
Office of Air Quality
1558 Washington Street, E
Charleston, WV 25311
304-558-4022 x235
304-558-3287 (F)
800-982-2474 (state)
kshaw@mail.dep.state.wv.us
www.dep.state.wv.us/oaq
Fred Durham
WV Division of Environmental Protection
Office of Air Quality
1558 Washington Street, E
Charleston, WV 25311
304-558-1217
304-558-1222 (F)
800-982-2474 (state)
fdurham@mait.dep.state.wv.us
www.dep.state.wv.us/oag
WISCONSIN
(A)
Hampton Rothwell
Wl Department of Commerce
201 W. Washington Avenue
P.O. Box 7970
Madison, Wl 53703
608-267-0313
608-267-0436 (F)
800-435-7287 (national)
hrothwell@commerce.state.wi.us
www.commerce.state.wi.us
Pam Christenson
Technical Assistance Director
Department of Commerce
Wl SBAP, 6th Floor
201 West Washington Avenue
Madison, Wl 53703
608-267-9214
608-267-0436 (F)
800-435-7287 (national)
pchristenson@commerce.state.wi.us
Cliff Fleener
Wl Department of Commerce
201 W. Washington Avenue
P.O. Box 7970
Madison, Wl 53703
608-264-6153
608-267-0436 (F)
800-435-7274 (national)
cfleener@commerce.state.wi.us
www.commerce.state.wi.us
14
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
WYOMING
(M)
Dan Clark
WY Department of Environmental Quality
Small Business Ombudsman
Herschler Building 4-W
122 W. 25th Street
Cheyenne, WY 82002
307-777-7388
307-777-3610(F)
dclark@missc.state.wy.us
http://deq.state.wy.us
Charles Raffelson
WY Department of Environmental Quality
Technical Assistance Program Coordinator
Herschler Building 4-W
122 W. 25th Street
Cheyenne, WY 82002
307-777-7347
307-777-3610 (F)
craffe@missc.state.wy.us
http://aeq.state.wy.us
Tina Jenkins
Environmental Program Principal, Rule
Making and Air Toxics
Department of Environmental Quality
Sheridan Field Office
1043Coffeen Ave, SteD
307-672-6457
307-674-6050 (F)
cjenki@missc.state.wy.us
http://deq.state.wy.us
15
-------
TABLE D-2
DATES OF ESTABLISHMENT AND COMMENCEMENT OF SBTCP OPERATIONS
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
MONTH & YEAR OF ESTABLISHMENT
SBO
5/93
6/95
1/93
N/R
11/93
10/92
6/89*
12/97
4/93
12/95
12/94
11/92
2/92
7/98
10/93
5/92
3/93
10/94
7/93
6/92 (part time)
2/95 (full time)
SBAP
7/94
6/95
1/93
1/95
11/93
before 1990
6/89*
7/92
4/93
12/95
12/93
11/92
11/92
7/98
4/94
9/92
1/95
10/92
7/93
7/94
CAP
7/97
6/95
1/93
N/R
6/95
N/E
2/98*
7/92
12/94
4/98
2/96
1/95
5/93
N/E
5/94
9/98
7/95
N/E
7/93
10/94
MONTH & YEAR OPERATIONS BEGAN
SBO
5/93
6/95
1/93
N/R
11/93
4/95
6/89*
12/97
4/93
12/95
9/95
11/92
7/92
7/98
10/93
5/92
3/93
10/94
11/93
6/92 (part time)
2/95 (full time)
SBAP
7/94
6/95
3/94
1/95
11/93
before 1990
6/89*
9/92
4/93
12/95
1/94
11/92
7/93
7/98
4/94
11/94
3/94
10/92
3/94
10/94
CAP
N/R
11/95
N/O
N/R
6/95
N/O
2/98*
4/94
12/94
4/98
2/98
1/95
11/94
N/O
5/94
9/98
7/95
N/O
12/93
3/95
N/A
N/O
Not applicable
Not operational
N/E
N/R
Not established
No response
-------
TABLE D-2
(Continued)
STATE OR
TERRITORY
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
MONTH & YEAR OF ESTABLISHMENT
SBO
8/95
11/92
10/93
4/94
N/E
10/95
4/92
7/93
8/92
12/93
11/92
1/95
11/94
3/93
10/92
4/92
1/93
4/92
10/94
6/94
SBAP
11/95
11/92
10/93
4/94
11/92*
9/94
4/92
7/93
8/92
12/93
11/92
1/95
1/93
11/92
10/92
4/92
8/93
4/92
10/94
6/94
CAP
See state resp,
10/93
10/93
N/E
N/E
9/94
4/92
7/93
8/92
1/94
7/93
12/95
11/95
12/95
10/94
7/94
11/94
5/92
10/94
6/96
MONTH & YEAR OPERATIONS BEGAN
SBO
8/95
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
1/93
1/93
4/92
12/94
10/94
SBAP
11/95
11/92
4/94
4/94
11/92*
9/94
8/93
7/93
5/94
12/93
11/92
1/95
1/93
11/92
1/93
4/92
8/93
4/92
4/95
10/94
CAP
See state resp.
10/93
4/94
N/O
N/O
9/94
9/93
7/93
4/98
3/94
7/93
1/95
3/96
1/97-
11/95
8/97
11/94
6/93
1/96
6/96
N/A
N/O
Not applicable
Not operational
N/E
N/R
Not established
No response
-------
TABLE D-2
(Continued)
STATE OR
TERRITORY
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MONTH & YEAR OF ESTABLISHMENT
SBO
8/91
11/92
10/97
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
8/91
11/92
11/94
11/96*
8/93
11/92
1/93
1/92
1/94
12/96
3/93
1/93
Summer 93
11/93
4/92
3/92
CAP
1/94
11/92
1/96
N/E
8/94
4/94
N/E
11/92
1/94
8/97
11/95
N/E
Summer 93
1/95
4/92
3/92
MONTH & YEAR OPERATIONS BEGAN
SBO
1/92
5/93
10/97
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
11/91
1/94
11/94
11/95
8/93
11/92
11/93
1/92
1/93
12/96
7/93
1/93
Summer 93
5/94
12/92
11/93
CAP
11/94
4/93
3/96
N/O
8/94
4/94
N/O
11/92
6/95
10/97
11/95
N/O
Summer 93
3/95
8/94
5/95
'Notes:
South Coast, CA SBO function, SBAP, and CAP (local government and small business committee) are combined.
-------
TABLE D-2
(Continued)
MA SBAP establishment: OTA established 1/90 to provide technical assistance in pollution prevention for all media (predecessor office
operating in the 1980s had nominal focus on hazardous waste), Since 11/92, MA SIP designated OTA as lead for SBAP in coordination
with other services at DEP.
SBAP operations: In 11/92, OTA was assigned to serve as the designated office under CAA. Since 1/90, OTA has provided multimedia
technical assistance to all toxics-using businesses, including small businesses. Since 1987, the Office of Safe Waste Management
provided similar assistance, focusing on waste, but covering air issues to some extent because of source reduction approach.
Rl Up until this time, the Department's existing Pollution Prevention Program staff had been responding to industry inquiries.
-------
TABLE D-3
1998 SBTCP BUDGET INFORMATION AND FUNDING SOURCES
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa
County
Arkansas
California
South
Coast
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
1998 BUDGET ($}
SBO
175,000
SBAP
165,000
CAP
N/R
118.100
175,000
N/R
64,500
200,000
133,350
264,500
340,000
N/R
N/R
2,500
0
1,310,000
60,000
250,000
0
325.000
80,000
5,000
8,000
3,000
222,400
50.000
125.000
5.000
TOTAL
340,000
118,100
175,000
133,350
331,500
540,000
1,310,000
310,000
325,000
80,000
16,000
222,400
180.000
SOURCE OF FUNDING
SBO
Title V fees;
air.water, &
RCRA grant
funds
SBAP
Title V fees, air
permit fees
CAP
N/R
All funds come from the AK Clean Air Protection Fund that
was established to fund AK's Title V program.
Air quality permit fees
N/R
Permit fees &
overhead
State budget act
Permit fees
Permit fees &
miscellaneous
grants
State budget act
N/R
Permit fees
N/A
Emissions fees, permit fees, annual operating fees,
subvention funds.
N/A
CDPHE Air
Pollution Control
Division, stationary
sources
(permitting &
annual emission
fees)
N/A
State fund that supports programs related to CAA
implementation, vehicle registration fees, Title V fees.
Title V fees
Air grant, Title V
fees
Air grant, Title V
fees
Title V fees
Title V fees, EPA grants
Title V fees I Title V fees
Title V fees
N/A
Not applicable
N/R
No response
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Hawaii
Idaho
Illinois
Indiana
Iowa*
Kansas
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
Massachusetts
1998 BUDGET ($)
SBO
100,000
66,950
75,000
150,000
81,200
125,000
123,200
40,000
0
40,000
3,500
N/A
SBAP
60,000
30,900
350,000
700,000
397,000
429,443
270,400
85,000
400,000
114,000
61,000
360,000*
CAP
N/A
0
500
3,000
0
No budget-
only travel
allowance
Inc. in SBO
budget
See state
resp.
0
As needed
N/A
N/A
TOTAL
160,000
97,850
425,000
853,000
478,200
554,443
393,600
125,000
400,000
154,000
64,500
360,000
SOURCE OF FUNDING
SBO
Title V fees
(special fund)
Title V fees
GRF
Special fund,
perm it fees,
general
revenues
Title V fees
Air fee funds,
pollution
prevention funds
Title V fees
EPA 105 grants
general funds
Funded by other
programs
General fund
MDE indirect
funds
N/A
SBAP
Title V fees
(special fund)
Title V fees, air
base grant
Title V fees
Special fund,
permit fees,
general revenues
Title V fees
Air fee funds,
hazardous waste
fee funds,
nonpoint source
funds, remediation
fee funds-
multimedia
program
Title V fees
EPA 105 grant&
general funds
N/R
Title V fees, fees
from Toxics Use
Reduction program
MDE indirect funds
Toxic Use
Reduction Act fees
CAP
N/A
N/A
Title V fees
Legislature
N/A
Air fee funds
Title V fees
N/R
N/A
Fees from Toxics
Use Reduction
Program
N/A
N/A
N/A Not applicable
N/R No response
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
1998 BUDGET ($)
SBO
71,300
75,000
150,000
52,000
91,595
0
92,272
25,000
80,000
10,000
1,170,000
SBAP
416,400
225,000
150,000
440,000
38,405
105,000
168,812
CAP
0
1,000
5,000
10.000
1,000
0
2,600
75,000
70,000
205,000
1,000,000
322,000
30,000
208,000
30,000
1,500
<1,000
4,000
3,000
1,000
229,000
TOTAL
487,700
300,000
305,000
502,000
131,000
105,000
263,684
100,000
151,500
216,000
2,174,000
325,000
61,000
437,000
SOURCE OF FUNDING
SBO
State & county
fees, restricted
funds
Air fees, 105
grant
Title V fees
Title V & other
fees
Air permit fees
SBO/SBAP
same person
Indirect cost
pool
Emission fees
Operating permit
fees
Title V fees,
other state funds
NY State Clean
Air fund
supported by
Title V fees
SBAP
State & county
fees, restricted
funds
Air fees, 105 grant,
SBREFA215grant
Title V fees
Title V fees,
general revenue,
federal grant
Air permit fees
Title V fees
Indirect cost pool.
federal grant (PPL)
Emission fees
Operating permit
fees
Title V fees,
grants, other state
funds
NY State Clean Air
fund supported by
Title V fees
Title V fees
Title V fees
Title V fees,
parent agent
subsidv
Title V fees
CAP
Unfunded
Air fees, 105
grant
Title V fees
Title V fees
Air permit fees
N/R
Air Quality
Management
Fund (permit
fees)
N/A
Operating permit
fees
Title V fees, other
state funds
NY State Clean
Air fund
supported by Title
V fees
Title V fees
Title V fees
Title V fees, CAP budget included in
SBAP budget
N/A
Not applicable
N/R
No response
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
1998 BUDGET ($)
SBO
14,000
35,000
90,000
N/R
49,000
40,000
25,000
SBAP
CAP
147,992
97,800
560,000
220,100
115,000
78,000
10,000
201,900
2,300
5,000
N/R
0
1,500
5,000
N/A
987,140*
54,000
0
10,000
150,000
40,000
50,000
30,000
148,000
60,000
285,000
150,000
200,000
140,000
117,000
2,000
5,000
5,000
N/A
5,000
5,000*
3,000
TOTAL
162,000
135,100
655,000
220,100
164,000
119,500
40,000
201,900
987,140
204,000
65,000
300,000
300,000
245,000
195,000
150,000
SOURCE OF FUNDING
SBO
Agency indirect
costs
Title V fees
Title V fees
N/R
State general
fund
Title V fees
Title V fees
SBAP
CAP
Title V fees, EPA leadership grant; CAP
budget included w/SBAP
Title V fees
Title V fees
Title V funds fully
assigned by EQB
Air Program
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
N/R
N/A
Title V fees
Title V fees
Not operational
1 51 grant funds
Title V fees,
EPA Partnership
for Compliance
grant
N/R
General funds
Title V fees
Title V fees
Title V fees,
agency penalties
General purpose
revenue
Title V fees
State of VT
general fund
Permit fees,
federal trust
Title V fees
Title V fees
Title V fees,
agency penalties
Program revenue
(permit fees)
Title V fees
State of VT
general fund
Permit fees
N/R
Title V fees
Agency penalties
Program revenue
(permit fees)
N/A
Not applicable
N/R
No response
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Wyoming
1998 BUDGET ($)
SBO
25,000
SBAP
75,000
CAP
10,000
TOTAL
110,000
ll
SOURCE OF FUNDING
SBO
Title V fees
SBAP
Title V fees
CAP
Title V fees
•Notes:
IA Budget for FY99 (7/98-6/99).
MA
TX
WV
OTA assists companies (large and small) with multimedia P2 improvements. Best estimate is $360,000 of OTA's budget is devoted to SBAP activities.
Toxics Use Reduction Act fees support the activities of the Office of Technical Assistance. These fees are from large quantity toxics users, which must
file under the act. No CAA funding used.
Combined budget for SBO, SBAP, and CAP, and is for FY98.
Expense reimbursement only. Actual yearly expenses <$ 1,000.
N/A
Not applicable
N/R
No response
-------
TABLE D-4
COMPARISON OF 1997, 1998, AND 1999 BUDGETS
and
DESCRIPTIONS OF SIGNIFICANT FUNDING CHANGES
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa County
Arkansas*
California
South Coast'
Colorado*
Connecticut*
Delaware
District of
Columbia*
Florida*
Georgia
Hawaii
Idaho
Illinois'
Indiana
Iowa*
Kansas*
Kentucky
Jefferson Cty
Louisiana
Maine*
Maryland
Massachusetts'
BUDGET FOR 1997 REPORTING PERIOD ($>
SBO
165.000
SBAP
165,000
CAP
N/R
118,100
165,000
N/R
78,210
200,000
122,000
233,068
340,000
N/R
N/R
1,564
0
1,210,000
90,000
120,000
0
325,000
80,000
5,000
8,000
0
151,200
65,000
N/A
65,000
70,000
150,000
81,000
125,000
112,800
40,000
0
40,000
3,500
- N44_.
115.000
N/A
30.000
325,000
700,000
362,000
340,000
262,500
85,000
400 000
75,000
61,000
360.000
10,000
N/A
0
0
3,000
0
0
2,000
SeeKY
0
As needed
0
N/A .
TOTAL
330,000
118,100
165.000
122,000
312.842
540,000
1,210.000
210,000
325,000
80,000
13.000
151,200
190,000
0
95,000
395,000
853,000
443,000
465,000
377.300
125,000
400,000
115,000
64,500
360.000
BUDGET FOR 1998 REPORTING PERIOD (S)
SBO
175,000
SBAP
165,000
CAP
N/R
118,100
175.000
N/R
64,500
200,000
133,500
264,500
340,000
N/R
N/R
2,500
0
1,310,000
60,000
250,000
0
325,000
80,000
5,000
8,000
3,000
222,400
50.000
100,000
66,950
75,000
150,000
81 ,200
125.000
123,200
40,000
0
40,000
3,500
N/A_
125,000
60,000
30,900
350,000
700.000
397.000
429,443
270.400
85,000
400,000
114.000
61,000
360.000
5,000
N/A
0
500
3,000
0
0
Inc. w/SBO
SeeKY
0
As needed
N/A
MA_
TOTAL
340,000
118,100
175,000
133,500
331,500
540,000
1,310,000
310,000
325,000
80,000
16,000
222,400
180.000
160,000
97,850
425,000
853,000
478,200
554.443
393,600
125,000
400,000
154,000
64,500
360 000
BUDGET FOR 1999 REPORTING PERIOD ($)
SBO
180,000
SBAP
181.500
CAP
N/R
118,100
185,000
N/R
70,950
200,000
141.300
277,725
340,000
N/R
N/R
2,625
N/A
850,000
60,000
250,000
0
325,000
80,000
0
8,000
2,000
110,600
50,000
100,000
66,950
75,000
1 50,000
81,400
125,000
129,400
40,000
0
40,000
3,500
N/A
135,000
85.000
30.900
375,000
700,000
361 ,000
430,000
278,500
85,000
400,000
114,000
61,000
360.000
10,000
10,000
0
2.000
3.000
N/A
N/R
Inc.
w/SBO
SeeKY
0
As needed
0
N/A
TOTAL
361,500
118,100
185,000
141,300
351,300
540,000
850.000
310,000
325,000
80,000
10,000
110,600
195,000
195,000
97,850
452,000
853,000
442,000
555.000
407.900
125,000
400,000
154,000
64,500
360.000
N/A
Not applicable
N/R
No response
-------
TABLE D-4
(Continued)
'mtSSt
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 Island1
South Carolina
South Dakota
Tennessee*
Texas
Utah-
Vermont
Viroinia"
BUDOET FOR 1097 REPORTING PERIOD ($)
SBO
65,000
70,000
1 50,000
50,000
91.595
N/R
77,103
25,000
80.000
10,000
1,170.000
SBAP
420,000
250,000
150,000
345,000
38.405
105.000
164.612
CAP
0
1,000
5.000
10,000
1,000
N/R
2,423
75,000
70,000
205.000
1,000,000
307.000
30.000
135.000
10,000
33.300
35.000
N/R
49,000
35,000
25,000
30.000
235,000
1,500
< 1.000
N/A
5,000
1,000
No Sep.
budget
142 300
90.800
535.000
244,805
110,000
85,000
10,000
900,000
1,296.849
43,000
0
10.000
203,000
60,000
175.000
2.200
5,000
N/R
0
1,500
5.000
0
2,000
0
5.000
TOTAL
485,000
320.000
305.000
395,000
131,000
105.000
244,336
100,000
151,500
216,000
2,170,000
312,000
61,000
370.000
152,300
126,300
575,000
244,805
159,000
121,500
40,000
900,000
1,296,849
248,000
60,000
190.000
BUDGET FOR 1998 REPORTING PERIOD ($)
SBO
71,300
75,000
150,000
52,000
91,595
0
92,272
25,000
80,000
10,000
1.170.000
SBAP
416,400
225,000
150,000
440,000
38.405
105.000
168,812
CAP
0
1.000
5.000
10,000
1,000
0
2,600
75,000
70,000
205.000
1.000,000
322.000
30,000
208,000
14,000
35,000
90,000
N/R
49,000
40,000
25,000
30,000
229.000
1,500
< 1.000
4,000
3,000
1.000
No sep.
budget
147,992
97,800
560,000
220,100
115,000
78,000
10.000
201,900
987,140
54,000
0
10.000
148,000
60.000
285.000
2.300
5.000
N/R
0
1,500
5,000
0
2,000
5.000
5.000
TOTAL
487.700
300.000
305,000
502,000
131,000
105.000
263.684
100.000
151,500
216.000
2,174,000
325,000
61,000
437,000
162,000
135,100
655,000
220,100
164,000
119,500
40,000
201,900
937,140
204,000
65,000
300.000
BUDGET FOR 1999 REPORTING PERIOD ($)
SBO
90.300
75.000
179,500
55,000
91,595
N/R
79.645
25.000
80.000
10.000
Poss. 50% cut
SBAP
537.000
225.000
179.500
458.000
38,405
105,000
90,424
CAP
0
1.000
5,000
10,000
1,000
N/R
2,600
75,000
85,000
215,000
1 .000,000
325,000
30.000
204.000
14,300
36,800
95,000
N/R
50,700
42,000
25,000
30,000
335,000
1.500
1,500
N/R
3,000
1,000
No sep.
budget
145,200
102,600
570,000
244,805
119,000
83,500
10,000
201,900
913,751
105,000
0
10000
130,000
60,000
250 000
2.500
5,000
N/R
0
1,500
5,000
0
2,000
5,000
5000
TOTAL
627,300
300,000
364,000
523,000
131,000
105,000
172,669
100,000
166,500
226,500
Unknown
328.000
61,000
539,000
159,500
141,900
670,000
244,805
169,000
127,000
40,000
201.900
913,751
237,000
65,000
265 000
N/A
Not applicable
N/R
No response
-------
TABLE D-4
(Continued)
STATE OR
TERRITORY
Virgin Islands
Washington
West Virginia*
Wisconsin
Wyoming
BUDGET FOR 1997 REPORTING PERIOD (»)
SDO
55,000
40,000
60,000
30,000
25.000
SBAP
55,000
200,000
140,000
117,000
75,000
CAP
0
5,000
5,000
3,000
10,000
TOTAL
110,000
245,000
205,000
150,000
110,000
BUDGET FOR 1998 REPORTING PERIOD ($)
SBO
150,000
40,000
50,000
30,000
25,000
SBAP
150,000
200,000
140,000
117,000
75,000
CAP
N/A
5,000
5,000
3,000
10,000
TOTAL
300,000
245,000
195,000
150,000
110,000
BUDGET FOR 1999 REPORTING PERIOD ($)
SBO
150,000
40,000
30,000
N/R
25,000
SBAP
150,000
200,000
140,000
N/R
75,000
CAP
5,000
5,000
5.000
N/R
10,000
TOTAL
305,000
245,000
195,000
N/R
110,000
*Notes, including explanations of significant changes (more than 10%) in funding levels among the 1997,1998, and 1999 budget periods:
AR Small business assistance functions separated from Ombudsman and consolidated with Customer Service Division.
South Coast, CA 1997 budget for FY1997-98,1998 budget for FY1998-99,1999 budget for 1999-00.
CO Effective October 1998, the SBAP increased staff by one full time employee.
CT Resources have been reallocated to provide program support and expansion on specific program initiatives, such as the grant project for
metal finishing or outreach on Title V. While thelevel of funding has remained constant, existing available resources have been shifted
within the Bureau of Air Management to provide additional program support as necessary.
DC The Ombudsman position has been vacant since May 1998.
FL Reductions in state funding (via Title V fees) are due to departure of more senior staff and replacement with lower classifications. FL had 2
grants this year: Small Business Ombudsman/Small Business Assistance Program Conference and Printers' Training/Workshop "Printers
Protecting the Environment."
IL SBAP difference in amounts results from difference of approved budget and actual expenses.
IA In 1997,1A received an additional $15,000 to conduct a needs assessment study of 112R-affected sources in Iowa. In 1998, IA received
an additional $50,000 to conduct a series of hands-on workshops on development of Risk Management Plans for 112R-affected sources in
IA. FY 1999 projected budget reflects only the core program funding (an increase over 1998). Additional project funding may be added
later. All budgets for fiscal year.
KS CAP has no budget - travel allowance only. The technical assistance program, which began as an air-only program, was expanded in
1998 with money from waste, water, and remediation funding. In reality, the program haspeen multimedia for several years, but after this
year the funding reflected the actual work accomplished. KS expects to continue the multimedia technical assistance approach and has
full support of media bureaus within KDHE.
N/A
Not applicable
N/R
No response
-------
TABLE D-4
(Continued)
ME Additional staff person added to SBTAP.
MA Level of funding has remained stable, except that program no longer has dedicated full time staff person to serve as liaison for SBAP
function.
Ml Funding is based on collected air permitting fees from the state's Title V program. In 1998, the fee structure was increased to begin
supporting FY 1998-99. Both SBO and SBAP will experience an increase in funding of 26.6% and 28.9% respectively beginning 10/1/98.
MN MN had a P2 demonstration grant expire during 1998, resulting in a slight budget downfall.
NV 1997 budget information reflects actual expenditures, which included position vacancies; the SBAP technical assistance position was not
filled until 1997, and the SBO position was vacant for 6 months in 1997 due to transfer of staff. The decrease in the 1999 SBAP budget
reflects the expiration of the EPA Leadership Grant, which was subcontracted to the University of Nevada-Reno, SBDC.
NJ In 1999, the SBAP will receive the US EPA Region II grant for $15,000 to set up an "800" hotline number, conduct 4 sector workshops, and
develop/distribute appropriate materials.
NY Title V revenues were lower than expected.
OH SBAP: No new employees were hired in 1998; the 1999 projected budget reflects an allowance for one additional staff member. In
addition, a significant part of 1998 supervisor's salary was charged to another program due to temporary transfer.
SBO: In 1998, SBO added a full time employee and expanded program outreach.
PA SBO was in office for only a portion of 1997, thereby explaining the low figure for 1997.
Rl Increase due to hiring of a full time Principal Environmental Planner (4/97).
TN Multimedia organizational opportunities and structural realignment caused reduction in Title V fee collection.
UT SBO: The EPA Partnership for Compliance Grant has introduced substantial amount of contract funds that have not been obligated due to
the length of the planning process. These funds will be obligated by September 1999.
SBAP: Program has reduced staff from 3 to 2.
VA The differences in funding from 1997 (FY98) to 1998 (FY99) are from a budget increase for salaries and benefits due to a realignment
within the Office of Small Business Assistance, which allocated 2 additional FTEs to the office. The difference between 1998 and
projected 1999 (FYOO) takes into account the conversion of the EPA Internet position to FTE status within the SBAP after the end of the
EPA Leadership Grant ends (3/31/99) and the depletion of grant funds.
WV SBAP budget has fluctuated due to personnel changes. SBO budget has decreased because the SBO has semi-retired and is working
approximately 20 hours per week.
N/A Not applicable N/R No response
-------
TABLE D-5
STAFFING INFORMATION
A summary of the number of full time equivalents (FTEs) that support the SBO function and SBAP function is shown in Table D-5.
With respect to the SBAP, the number of paid and unpaid staff is shown separately. The utilization of retired engineers to serve the
SBAP also is indicated.
STATE OR TERRITORY
Alabama
Alaska
Arizona
Maricopa County
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
SBO FUNCTION (# FTEs)
SBO
3.00
1.00
0.25
N/A
1.00
4.00
4.00
1.00
2.00
1.00
0.10
0.50
0.50
1.00
1.00
1.00
2.00
OTHER
STAFF
0
0.25
N/A
0
2.00
0.50
0
0
0.30
0
2.00
0
1.00
0
0
0.25
TOTAL
SBO
STAFF
3.00
1.25
0.25
N/A
1.00
6.00
4.50
1.00
2.00
1.30
0.10
2.50
0.50
2.00
1.00
1.00
2.25
SBAP FUNCTION (# FTEs)
PAID
2.00*
1.50
2.25
2.75
3.50
20.00
3.00
3.00
0
0
0.30
*
2.50
1.75
0*
5.00
12.00
UNPAID
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ARETIRED
ENGINEERS
0
0
0
0
1.0
0
0
0
0
0
0
0
0.50
0
0
0
0
TOTAL SBAP
STAFF
2.00
1.50
2.25
2.75
3.50
20.00
3.00
3.00
0
0
0.30
*
2.50
1.75
0
5.00
12.00
N/A
Not applicable
N/R
No response
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
Iowa
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
SBO FUNCTION (# FTEs)
SBO
1.00
1.00
1.50
1.00
0.25
1.00
0.05
N/A
1.00
1.00
2.00
1.00
1.00
1.00
1.00
0.25
1.00
0.50
6.00
OTHER
STAFF
0
0.50
0
0
0
0
0
N/A
0
0
0
0
0.50
0
0
0
0.50
0
2.00
TOTAL
SBO
STAFF
1.00
1.50
1.50
1.00
0.25
1.00
0.05
N/A
1.00
1.00
2.00
1.00
1.50
1.00
1.00
0.25
1.50
0.50
8.00
SBAP FUNCTION (# FTEs)
PAID
5.00
5.50
4.00
2.00
10.00
2.00
1.00
8.00
7.50
3.00
5.50
7.65
1.00
1.00
1.00
1.25
1.00
4.50
7.00
UNPAID
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ARETIRED
ENGINEERS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTAL SBAP
STAFF
5.00
5.50
4.00
2.00
10.00
2.00
1.00
8.00
7.50
3.00
5.50
7.65
1.00
1.00
1.00
1.25
1.00
4.50
7.00
N/A
Not applicable
N/R
No response
-------
TABLE D-5
(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
Virgin Islands
Washington
West Virginia
Wisconsin
SBO FUNCTION (# FTEs)
SBO
• 1.50
0.50
0.40
0.10
0.15
1.00
1.00
1.00
1.00
0.50
2.00
14.50
0.50
0
0.10
1.00
0.50
0.50
0.50
OTHER
STAFF
0
0
1.60
0
0.20
1.50
0
0
0
0
0
0
0
0
0.90
0
0
0.20
2.00
TOTAL
SBO
STAFF
1.50
0.50
2.00
0.10
0.35
2.50
1.00
1.00
1.00
0.50
2.00
14.50
0.50
0
1.00
1.00
0.50
0.70
2.50
SBAP FUNCTION (# FTEs)
PAID
2.50
2.00
4.00
3.30
1.00
3.50
2.00
2.50
2.00
0.14
2.00
14.50
2.50
1.10
4.20
3.00
2.50
1.30
2.50
UNPAID
0
0
0
0
0
0
0
0
0
0
0
70.00
0
0
0.50
0
0
0
0
ARETIRED
ENGINEERS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTAL SBAP
STAFF
2.50
2.00
4.00
3.30
1.00
3.50
2.00
2.50
2.00
0.14
2.00
84.50
2.50
1.10
4.70
3.00
2.50
1.30
2.50
N/A
Not applicable
N/R
No response
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
Wyoming
SBO FUNCTION (# FTEs)
SBO
0.50
OTHER
STAFF
0
TOTAL
SBO
STAFF
0.50
SBAP FUNCTION (# FTEs)
PAID
1.00
UNPAID
0
ARETIRED
ENGINEERS
0
TOTAL SBAP
STAFF
1.00
*Notes:
A The number of retired engineers serving as paid or unpaid SBAP FTEs is included these columns. Use of retired engineers (paid or
unpaid) is documented in the "Retired Engineers" column.
AL 10% of a staff of 20.
FL SBO/SBAP administrator functions are combined.
ID No dedicated FTEs, however, approximately 10 FTEs assist as needed.
N/A
Not applicable
N/R
No response
-------
TABLE D-6
CAP COMPOSITION
STATE OR TERRITORY
Alabama
Alaska
Arizona
Maricopa County
Arkansas
California
South Coast*
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
4
2
4
N/A
4
1
4
3
4
5
4
4
3
N/A
2
4
1
STATE
REGULATORY
EMPLOYEE
1
1
1
1
3
2
1
1
2
1
1
1
1
GENERAL
PUBLIC
2
2
2
2
4
2
4
1
2
2
3
2
NOT YET
APPOINTED
2*
6
1
1
7
1
1*
3
OTHER
4
1*
1
1
N/A Not applicable N/E Not established N/R No response
-------
TABLE D-6
(Continued)
STATE OR TERRITORY
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
2
4
SeeKY
4
4
N/A
N/A*
2
N/A*
2
2
6
4
4
4
4
6
STATE
REGULATORY
EMPLOYEE
1
1
2
2
1
1
1
1
1
1
1
1
1
1
GENERAL
PUBLIC
2
2
2
2
2
2
2
2
2
2
1
2
NOT YET
APPOINTED
4*
2*
2
2
5*
6*
OTHER
2
8
2
1*
N/A Not applicable N/E Not established N/R No response
-------
TABLE D-6
(Continued)
STATE OR TERRITORY
North Dakota
Ohio
Oklahoma
Oreqon
Pennsylvania
Puerto Rico
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
4
4
4
2
4
2
4
4
3
4
5
4
N/A
2
4
4
4
STATE
REGULATORY
EMPLOYEE
1
1
2
2
1
1
1
1
1
1
1
1
2
1
GENERAL
PUBLIC
2
1
2
3
2
*•»
o
2
2
1
2
1
2
1
2
2
2
NOT YET
APPOINTED
1
1
1
1
7
7
3
OTHER
1
2
2
1
1
2
N/A Not applicable N/E Not established N/R No response
-------
TABLE D-6
(Continued)
•Notes:
AK Reappointments in progress for 2 CAP members.
South Coast, CA Membership of Local Government and Small Business Committee.
CO 1 small business owner is now a small business consultant.
IN 7 appointed, 1 resigned.
KS Currently awaiting new appointments.
KY Legislation was enacted by the 1998 General Assembly adding 2 small business representatives. They are to be appointed by the Executive Branch to
the Panel increasing the total number of small business representatives to 6. Appointments pending.
MA Although CAP is not formally established, the Secretary of the Environment has met regularly with leaders of the business community (large and small)
to discuss environmental progress and problems.
MN The CAP currently is dormant pending reassignment by a newly elected administration.
NE SBO as a non-voting member.
NM To be reappointed.
NC Inactive CAP. Getting timely appointments has been a problem- NC will be getting an advisory body in 1999.
N/A Not applicable N/E Not established N/R No response
-------
TABLE D-7
ADMINISTRATIVE LOCATION OF SBTCP COMPONENTS
For SBO and SBAP functions, (R) denotes location is a regulatory agency; (N) denotes a non-regulatory agency or a non-
enforcement division. CAPs are considered to be independent entities, located outside any agency, even though they may indicate
that they receive administrative assistance from a regulatory or nonregulatory agency.
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa
County
Arkansas
California
South
Coast
Colorado
BRIEF DESCRIPTION OF LOCATION
SBO
AL Department of Environmental
Management, Office of Education &
Outreach (N)
AK Department of Environmental
Conservation, Statewide Public
Service Division, Compliance
Assistance Office (N)
AZ Department of Environmental
Quality, Compliance Assistance
Section (N)
N/R
Director's Office (R)
Air Resources Board (ARB), Office
of the Ombudsman (part of ARB,
Office of the Chairman) (R)
SBAP
AL Department of Environmental
Management, Air Division (R)
AK Department of Environmental
Conservation, Statewide Public Service
Division, Compliance Assistance Office
(N)
AZ Department of Environmental
Quality, Compliance Assistance Section
(N)
Environmental Services Department (R)
Customer Service Division (R)
Throughout ARB, including the Office of
the Ombudsman, Office of the
Chairman, and local Air Pollution Control
Districts (R)
CAP
Independent
Private, uncompensated individuals
from small business and the general
public appointed by the legislature
and the Governor. One member is
an employee of the Department.
Located outside the Agency, but
managed by AZ Department of
Environmental Quality, Compliance
Assistance Section
N/R
Customer Service Division
ARB, Office of the Chairman
The South Coast Air Quality Management District is a regional (Los Angeles, Orange, and portions of Riverside and San
Bernardino Counties) single media (air only) regulatory agency. The ombudsman function and outreach function are co-
located in the Public Advisor's Office of the District. (R)
CO Department of Public Health
and Environment (CDPHE), Office
of Customer Service (R)
CDPHE, Air Pollution Control Division,
Regulatory and Compliance Support Unit
(R)
Independent; located outside
regulatory agencies. Members
appointed as defined in Section 507.
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
BRIEF DESCRIPTION OF LOCATION
SBO
CT Department of Environmental
Protection (R)
DNREC Secretary's Office (N)
State regulatory agency (R)
Department of Environmental
Protection, Division of Air
Resources and Management,
Office of Air Programs
Communications and Outreach (N)
EPD/Air Protection Branch/
Planning & Support Program (N)
Department of Health, Director's
Office (N)
Division of Environmental Quality;
Planning and Support Services;
Prevention, Planning, and Outreach
Bureau (N)
IL Environmental Protection Agency
(R)
IN Department of Environmental
Management, Office of Business
Relations and Legislative Affairs
(N)
SBAP
CT Department of Environmental
Protection (R)
DNREC Secretary's Office (N)
State regulatory agency (R)
Department of Environmental Protection,
Division of Air Resources and
Management, Office of Air Programs
Communications and Outreach (N)
EPD/Air Protection Branch/Planning &
Support Program (N)
Department of Health, Clean Air Branch
(R)
Division of Environmental Quality, Air
and Hazardous Waste Division (R)
IL Department of Commerce and
Community Affairs, Small Business
Development Center (N)
IN Department of Environmental
Management, Office of Pollution
Prevention and Technical Assistance (N)
CAP
CT Department of Environmental
Protection
Independent
Business owners & private citizens
Independent
One CAP member is the program
manager of the Compliance
Permitting Program within the Air
Protection Branch. The rest of the
CAP is located outside of all
agencies with each individual
appointed as defined in Section 507.
Not yet established
Outside of all agencies, appointed as
defined in Section 507
IL Department of Commerce and
Community Affairs
Independent
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
Iowa
Kansas
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
BRIEF DESCRIPTION OF LOCATION
SBO
IA Department of Economic
Development (N)
KS Department of Health and
Environment, Planning &
Prevention Section (N)
Office of the Commissioner,
Department for Environmental
Protection, Natural Resources and
Environmental Protection Cabinet
(R)
Department of Planning and
Environmental Management (N)
Department of Environmental
Quality (R)
Department of Environmental
Protection (R)
Department of the Environment,
Environmental Permits Service
Center (R)
Not established
Ml Jobs Commission, Business
Ombudsman's Office (N)
Pollution Control Agency, Policy
and Planning Division (N)
Department of Environmental
Quality, Environmental Resource
Center (R)
SBAP
IA Air Emissions Assistance Program
(IAEAP), IA Waste Reduction Center
(IWRC), University of Northern Iowa (N)
Contracted* to University of KS, KS
State University, and Wichita State
University (N)
University of Kentucky* (N)
Air Pollution Control District, Department
of Planning and Environmental
Management (R)
Department of Environmental Quality (R)
Department of Environmental Protection
(R)
Department of the Environment,
Environmental Permits Service Center
(R)
OTA (N) and DEP (R)*
Department of Environmental Quality,
Environmental Assistance Division (R)
Pollution Control Agency, Metro District
(N)
Department of Environmental Quality,
Environmental Resource Center (R)
CAP
Pending legislators' appointment
Independent
Panel members appointed by
Executive Order of the Governor
SeeKY
Independent
Outside Department as defined by
Section 507
N/A
Not established
N/A
Independent
Department of Environmental
Quality, Environmental Resource
Center
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
Missouri
Montana
Nebraska
Nevada
NV Bureau
of Air
Quality
Washoe
Cty Air
Quality
Program
Clark Cty
Air Quality
Program
BEP-UNR
New Hampshire
New Jersey
BRIEF DESCRIPTION OF LOCATION
SBO
Governor's Office (N)
Department of Environmental
Quality, Pollution Prevention
Bureau (N)
Public Advocate (N)
Division of Environmental
Protection, Office of the
Administrator (R)
SBAP
Department of Natural Resources,
Division of Environmental Quality
Technical Assistance Program (R)
Department of Environmental Quality,
Air and Waste Management Bureau and
Pollution Prevention Bureau (N&R)
Public Advocate (N)
Division of Environmental Protection,
Office of the Administrator (R)
CAP
Administratively associated with
MDNR, supported by the Technical
Assistance Program.
Department of Environmental
Quality, Pollution Prevention Bureau
Public Advocate
Independent
Division of Environmental Protection, Bureau of Air Quality (BAQ). The NDEP is the primary state regulatory agency for
environmental issues, and the BAQ has oversight of air issues statewide with the exception of stationary sources located
in Washoe and Clark Counties. (R)
Washoe County District Health Department, Air Quality Management Divisions; 401 Ryland Street, Suite #331; Reno, NV
89502-0027. This is the county regulatory agency for air quality issues. (R)
Clark County Health District, Air Pollution Control Division; 625 Shadow Lane; Las Vegas, NV 89106. This is the county
regulatory agency for air quality issues. (R)
NV Small Business Development Center, Business Environmental Program (BEP), University of Nevada Reno (UNR),
c/o UNR College of Business Administration, 1664 N. Virginia Street, Reno, NV 89503. BEP was under contract with
NDEP BAQ to provide outreach materials, workshops, and assistance regarding air quality issues (contract expired
8/98). (N)
NH Department of Environmental
Services, Office of the
Commissioner (R)
Department of Commerce and
Economic Growth Commission (N)
NH Department of Environmental
Services, Air Resources Division (R)
Department of Environmental Protection
(R)
Independent with administrative
support from SBAP and DES Air
Resources Division
Department of Environmental
Protection
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
BRIEF DESCRIPTION OF LOCATION
SBO
Environment Department (R)
NY State Empire State
Development (N)
Department of Environment and
Natural Resources, Division of
Pollution Prevention and
Environmental Assistance (N)
Department of Health,
Environmental Health Section
Chiefs Office (N)
OH Air Quality Development
Authority (N)
Department of Environmental
Quality, Executive Director's Office
(N)
Department of Environmental
Quality, Director's Office (R)
Department of Environmental
Protection, Office of Pollution
Prevention and Compliance
Assistance (N)
Commercial Development
Administration (N)
Department of Environmental
Management, Office of the Director
(N)
SBAP
Environment Department, Air Quality
Bureau, Control Strategy Section (R)
NY State Environmental Facilities
Corporation, Technical Advisory
Services Division (N)
Department of Environment and Natural
Resources, Division of Pollution
Prevention and Environmental
Assistance (N)
Department of Health, Environmental
Health Section (air, water, waste) (R)
OH Environmental Protection Agency,
Division of Air Pollution Control (R)
Department of Environmental Quality,
Customer Services Division (N)
Department of Environmental Quality,
Air Quality Division (R)
Contracted* (N)
Environmental Quality Board, Air Quality
Area (R)
Department of Environmental
Management, Office of Technical and
Customer Assistance; University of Rl,
Center for Pollution Prevention (N)
CAP
Independent and located outside the
agency
Department of Environmental
Conservation, Division of Air
Resources, Bureau of Technical
Services
Department of Environment and
Natural Resources, Division of
Pollution Prevention and
Environmental Assistance
Independent and located outside all
agencies
Independent
Department of Environmental
Quality, Customer Services Division
Outside agency and liaison to SBAP,
SBO, small businesses
Independent
Not in full operation
Will be located outside state
agencies with individuals appointed
as per Section 507
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
BRIEF DESCRIPTION OF LOCATION
SBO
<
Department of Health and
Environmental Control,
Environmental Quality Control
Administration (N)
Supervised by DENR Secretary (R)
Bureau of Environment,
Department of Environment &
Conservation (R)
Natural Resource Conservation
Commission, Small Business
Assistance Program (N)
Department of Environmental
Quality, Office of Planning and
Public Affairs (R)
N/A
Department of Environmental
Quality, Air Programs Coordination
(R)
Department of Planning and
Natural Resources (R)
Department of Ecology, Air Quality
Program (R)
Division of Environmental
Protection (R)
SBAP
Department of Health and Environmental
Control, Environmental Quality Control
Administration (N)
DENR Air Program (R)
Division of Community Assistance,
Department of Environment &
Conservation (N)
Natural Resource Conservation
Commission, Small Business Assistance
Program (N)
Department of Environmental Quality,
Division of Air Quality, Operating Permits
Section (R)
ANR/Department of Environmental
Conservation, Environmental Assistance
Division (N)
Department of Environmental Quality,
Division of Pollution Prevention and
Compliance Assistance (N)
Department of Planning and Natural
Resources (R)
Department of Ecology, Air Quality
Program (R)
Division of Environmental Protection,
Office of Air Quality (R)
CAP
Department of Health and
Environmental Control,
Environmental Quality Control
Administration
Independent
Not yet appointed
Natural Resource Conservation
Commission, Small Business
Assistance Program
Department of Environmental
Quality, Division of Air Quality
ANR/Department of Environmental
Conservation, Environmental
Assistance Division
Appointed as per Section 507
Not yet named
Independent
Located outside all agencies,
appointed pursuant to Section 507
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
STATE OR
TERRITORY
Wisconsin
Wyoming
BRIEF DESCRIPTION OF LOCATION
SBO
Department of Commerce,
Business Development Assistance
Center, Division of Marketing
Advocacy and Technology
Development (N)
Department of Environmental
Quality, Office of Outreach,
Administrative Division (N)
SBAP
Department of Commerce, Business
Development Assistance Center,
Division of Marketing Advocacy and
Technology Development (N)
Department of Environmental Quality,
Office of Outreach, Administrative
Division (N)
CAP
Outside of state agencies, including
small business owners and other
state agencies
Independent citizens panel
appointed by legislature, Governor,
and Department located outside any
state agency
*Notes
MA
OTA functions as the technical assistance arm of the state's SBAP. DEP provides regulatory compliance information through assistance
centers. OTA and DEP cooperate on sector-based and outreach projects.
N/A Not applicable
N/R No response
-------
TABLE D-7
(Continued)
Three states have contracted the management of the SBAP to an outside entity. Information on SBAP contractors is provided below.
STATE
CONTRACTOR
TERMS
Kansas
Mr. Frank M. Orzulak
University of Kansas
Division of Continuing Education
1515 St. Andrews Drive
Lawrence, KS 66047
785-864-9196
785-864-5074 fax
1998 budget: $449,423 total for UK and KSU
Term of contract: July 1 -July 1 annual renewal
Provides newsletter, resource center.
Ms. Jean Waters
Kansas State University
Pollution Prevention Institute
133 Ward Hall
Manhattan, KS 66056
785-532-6501 and 800-578-8898
785-532-6952 fax
1998 budget: $449,423 total for UK and KSU
Term of contract: July 1 -July 1 annual renewal
Provides on sites, answers questions, develops manuals &
other materials.
Kentucky
Mr. Gregory C. Copley, Director
Kentucky Business Environmental Assistance Program
227 Gatton College of Business & Economics
University of Kentucky
Lexington, KY 40506-0034
606-257-1131
606-323-1907 fax
1998 budget: $262,500
Term of contract: Annual
Responsible for technical/compliance assistance. 1
Pennsylvania
Ms. Cecily Beall
Tetra Tech EM, Inc.
1800 JFK Boulevard, 6th Floor
Philadelphia, PA 19103
215-656-8709
215-972-0484 fax
1998 budget: $560,000
Term of contract: 2 years
Responsible for technical assistance.
8
-------
APPENDIX E
SBTCP ACTIVITIES AND SERVICES
-------
TABLE E-1
SBTCP ASSISTANCE
TOTAL STATES PROyiDING ASST. / TOTAL, BUSINESSES REACHED _____
1
TOTAL STATES i TOTAL BUSINESSES
INDUSTRY (SIC) } PROVIDING ASST. j REACHED
{ :
Cross Sector f 24 1105387
Other ! 29 436145
Organizations/Associations (86) £ 34, 159846
Aiito/Body Maintenance, Repair, Refinishing (75J 44; 38454
Government (91, 95) *~ 34 22615
Printing/Graphic Arts (27) 39 j 20337
Dry Cleaners/Laundry Services (721) I 44: 15310
Recycling (509) | 22[ 13480
Agriculture/Farming/Crop Service (01, 07) 31 8643
Paints & Painting/Coatings (172. 285} I 32r 8243
Construction/Corrtractor (15, 16, 17) I 31 ! 7105
Attorney/Consultant/Engineer J81, 87)
Auto/Motor Vehicle Dealers & Equipment (55, 501)
Wastewater Treatment (495)
Furniture Manufacture/Repair/Wood Finishing J25. 764)
Manufacturing, Misc.
Metal Fabricating/Finishing (34)
Private Citizen J
Boilers (34. 50) J
Plumbing/HVAC(171)
Gasoline Distribution (wholesale/retail) (517, 554)
Degreasers
Airports/Air Transportation (45)
Asbestos/Remediation (17, 32)
Restaurants (581]_
Electroplating/Chrome Rating (347)
Utilities (49)
Hospitals/Medical Health Services (80)
Schools (82)
Concrete/Aggregate (32)
Chemicals/Products (28)
Crushed Stone Products/Sand & Gravel (14)
Sawmills/Logging/Wood Products (24)
Petroleum Products, Storage, Pipelines (29, 46)
Boat Manufacturing (373)
Incinerators
Machine Shop (359)
Machine/Equipment Manufacturing & Repair (35)
Food/Beverage Products & Processing (20, 514)
Aerospace (37)
Miningjmetal & coal) (JO, 121
Foundry/Smelter, Forging, Casting (33)
Retail/Wholesale Trade (50, 51, 59)
Bakeries (546)
Research & Testing Facilities/Laboratories (873)
Repair, Misc. (76)
Engines & Turbines (351)
Business Services (73)
Plastic Manufacturing/Products (308)
Waste/Waste Hauling (495)
Transportation Equipment (37)
Real Estate (65) •
Asphalt (295)
Stone/Clay/Glass (32)
Electronics/Electric Equipment/Repair (36, 7_62J__
Textiles & Apparel (22, 23)
Grains/Grain Elevators (011, 422)
Transportation Services (42. 44. 47)
Robber Manufacturing/Products (30)
Landfills/Landfill Gas (495)
Paper Manufacturing/Products (26)
Analytical/Medical Instruments (38)
Veterinarians (074)
Personal Services (72)
Hotels/Motels (70)
Communications (48)
Pharmaceuticals (283)
Transit (passenqer) (41)
Dairy/Feedtots/LivestocK (02)
Recreation Services (79)
Cotton Gins (072)
Leather/Fur (31, 237)
351 6563
29! 4586
22! 4400
39 3984
29 3107
37! 3040
25
23
13
27
25
17
19
13
31
25
33
27
27
33
26
30
28
20
19
15
24
25
16
14
24
19
13
19
14
10
15
23
19
15
18
27
14
25
14
12
17
15
20
18
15
10
2999
2823
2715
2435
2164
2091
1988
1627
1603
1408
1373
1352
1259
1249
1235
1133
1101
939
901
849
829
822
664
652
579
551
543
533
489
370
364
323
317
298
270
199
198
165
157
154
151
139
128
124
105
104
141 83
9
11
9
5
14
11
4
10
72
57
55
33
r 32
31
16
16
-------
TABLE E-2
SBTCP ASSISTANCE
TOTAL STATES PROVIDING ASST. / TOTAL BUSINESSES REACHED
J- - - —
1 TOTAL STATES TOTAL BUSINESSES
INDUSTRY (SIC) PROVIDING ASST. REACHED
Auto/Body Maintenance, Repair, Refinishing£75^ 44 38454
Dry Cleaners/Laundry Services (721) 44 15310
Furniture Manufacture/Repair/Wood Finishing (25, 764) 39 3984
Printing/Graphic Arts (27^ 39 20337
Metal Fabricating/Finishing (34) : 37 3040
Attomey/Consultanf Engineer (81 , 87) j 35 6563
Government (9 1,95) 34 22615
Organizations/Associations (86) 34 159846
Chemicals/Products (28) 33 1249
Hospitals/Medical Hearth Services (80)
Paints & Painting/Coatings (172, 285)
33 1373
32 8243
Agriculture/Farming/Crop Service (01, 07) 31 8643
Construction/Contractor (15. 16, 17) 31 7105
Electroplating/Chrome Plating (347) 31 1603
Sawmills/Logging/Wood Products (24) 30 1133
Auto/Motor Vehicle Dealers & Equipment (55, 501) ! 29 4586
Manufacturing, Misc.
Other
Petroleum Products, Storage. Pipelines (29, 46)
Asphalt (295)
Concrete/Aggregate (32)
Gasoline Distribution (wholesale/retail) (51 7, 554)
Schools (82)
Crushed Stone Products/Sand & Gravel (14)
Degreasers
Electronics/Electric Equipment/Repair (36, 762)
Food/Beverage Products & Processing (20, 514)
'rivate Citizen
Utilities (49)
Foundry/Smelter, Forging, Casting (33)
Machine/Equipment Manufacturing & Repair (35)
Cross Sector
toilers (34, 50)
Plastic Manufacturing/Products (308)
Recycling (509)
Wastewater Treatment (495)
Boat Manufacturing (373)
Landfills/Landfill Gas (495)
Asbestos/Remediation (17, 32)
Incinerators
Research & Testing Facilities/Laboratories (873)
Retail/Wholesale Trade (50, 51, 59)
Waste/Waste Hauling (495)
Paper Manufacturing/Products (26)
Real Estate (65)
Airports/Air Transportation (45)
Transportation Services (42, 44, 47)
Aerospace (37)
Analytical/Medical Instruments (38)
Business Services (73)
Machine Shop (359)
Rubber Manufacturing/Products (30)
Transportation Equipment (37)
Dairy/Feedlots/Livestock (02)
Mining (metal & coal) (10. 12)
Personal Services (72)
Repair, Misc. (76)
Stone/Clay/Glass (32)
Textiles & Apparel (22, 23)
Bakeries (546)
Plumbing/HVAC(171)
Restaurants (581)
Grains/Grain Elevators (011. 422)
Communications (48)
Recreation Services (79)
Engines & Turbines (351)
Leather/Fur (31, 237)
Veterinarians (074)
Hotels/Motels (70)
Pharmaceuticals (283)
Transit (passenger) (41 )
Cotton Gins (072)
29 3107
29, 436145
28: 1101
27. 199
27 1259
27 ] 2435
27j 1352
26! 1235
25; 2164
25; 165
25 822
25 2999
25; 1408
24 579
24 829
24 1105387
23 2823
23 1 323
22 13480
22 4400
20 939
20 128
19' 1988
19 901
19 533
19! 551
19 317
181 124
18 270
17 2091
17 151
161 664
15| 105
15 364
15 849
15, 139
*~ 151 298
14 32
14 652
14] 83
14 i 489
141 198
14J 157
13 543
13 2715
13 1627
12 154
11 57
11 31
10! 370
10]^ 16
10; 104
9j 72
9 55
5i 33
4! 16
-------
TABLE E-3
HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE
N/R
The Compliance Assistance Office (which includes the SBAP) responds to public requests for assistance. Our clients,
our work. Sectors that CAO is focusing on in FY99 include auto service, contractors, and oil field service.
in part, prioritize
N/R
Printers, auto body, dry cleaners, construction.
Foundry and die casting compliance assistance program conducted jointly with EPA Region 6.
Dry cleaners.
Clean Air Ambassador Program involved a cross section of all types of industries. Focused on automotive repair and
solvent users.
other high
Restaurants, hospitals, chrome platers.
Automotive.
Dry cleaners.
Dry cleaners, utility boilers.
Printers (developed workshops and workbook), dry cleaners (distributed compliance calendars for 1999).
Dry cleaners, printers, automotive repair shops, manufacturers of consumer products.
Dry cleaners (trade association/business advocacy outreach).
Auto body shops, printers, dry cleaners.
Dry cleaners, printers, metal finishers, medical waste incinerators, degreasers.
Perc dry cleaners, vehicle maintenance shops, collision repair/auto refinishers, fiberglass reinforced product manufacturers
(due to chanqe in calculating emission factors), printers, hospitals, schools, Toxics Release Inventory reporters.
N/A Not applicable N/R No response
-------
TABLE E-3
(Continued)
PROGRAM
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE
SBO - All manufacturers including foundries, furniture manufacturers, lumber mills, metal finishers, newspapers, printers, textile
mills, and wood finishers.
SBAP - Agri-businesses (mass mailing in connection with development of the Handbook of Environmental Regulations for Small
Businesses - SBREFA grant). Main focus on 1997 state permitting amnesty list of 167 various types of businesses.
Underground storage tanks; non-point source pollution; anhydrous ammonia, propane and chlorine users affected by 112(r);
dry cleaners; feedlot dust; and environmental management systems.
Wood finishers, printers, and metal fabricators. All industry sectors that will be required to submit risk management plans
were targeted for assistance through special mailings and a series of seminars held November 1998.
N/R
Dry cleaners, wood finishers, architectural coating manufacturers.
Dry cleaners, facilities subject to CAA Section 1 12(r) (e.g., propane, chlorine, ammonia, etc.).
N/R
Solvent users were contacted and offered free software developed by the office to assist in calculating VOC emissions.
Auto body shops were offered a series of workshops and a plain-language guide to regulations containing an agreement between the
enforcement agencies (brokered by OTA) on what an inspector would consider a "good faith" effort to comply with the rules or employ
pollution prevention to be responsible.
Schools continued to be offered special assistance with chemical use and indoor air issues.
Departments of Public Works were offered a series of workshops on compliance and pollution prevention.
Dry cleaners were reached through a cooperative project with trade associations. Dry cleaners were included in a self-certification
system, the Environmental Results Program.
Printers also were included in the Environmental Results Program.
Surface coaters.
Non-metallic mineral processors at taconite facilities; vendors, suppliers, and contractors who supply or use aqueous-based
coatings within the wood finishing industry; vapor degreasers.
Sources affected bv 112(r).
N/A Not applicable N/R No response
-------
TABLE E-3
(Continued)
PROGRAM
Missouri
Montana
Nebraska
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
HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE
Printers (P2 compliance guides were compiled for screen, lithographic, and flexographic printers.)
Dry cleaners, automobile repair, automobile refinlshers.
None.
Industries having sand and gravel operations or processes that generate fugitive dust, including road construction, gravel pits,
mines, and state departments of transportation.
Automotive repair and refinishing, wood furniture refinishing.
Dry cleaners, printers, schools, chemical manufacturers.
Asphalt plants, rock crushers, dry cleaners, automotive repair, printers, concrete batch plants.
Dry cleaners, halogenated solvent degreasers, boilers/combustion sources, sources with PTEs above major thresholds that
need to cap actual emissions under Title V limits.
Metal electroplaters, printers.
Anhydrous ammonia dealers.
Dry cleaners. (Five region-specific mass mailings were sent to dry cleaners that had not yet filed for permit applications. The mailings
listed the SBAP as a source of help. This resulted in the SBAP visiting 57 dry cleaners to help them with permit applications.)
Wood furniture manufacturers, metal recyclers/reclaimers, consumer products manufacturers, printers.
Automotive repair, autobody repair, chrome electroplaters, printers.
None.
Dry cleaners - perc.
Auto body, screen printers.
Printers, consumer product manufacturers.
N/R
Companies potentially affected by CAA 112(r) regulations.
Dry cleaners, auto body and auto service facilities, metal finishers, RCRA waste recordkeeping, printers, chemical coaters.
N/A Not applicable N/R No response
-------
TABLE E-3
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE
Wood furniture manufacturers.
Vehicle service.
Targeted assistance this year was through the utilization of downlink telecasts for consumer products manufacturers and screen
printers. Also targeted for outreach in 1999, but with development beginning this reporting year, are sources affected by 112(r),
specifically propane dealers and users, and cold storage ammonia warehouses.
Auto body and repair shops.
Department of Ecology: Hospitals.
OAPCA: Asbestos, printers, spray coating operations, gas stations.
NWAPA: Agriculture burning.
SCAPCA: Surface coating operations, screen and lithographic printers.
Due to personnel changes in WV OAQ's SBAP and SBO programs in 1998, an emphasis was placed on training. Therefore, outreach
efforts were limited, and resources were concentrated on responding to requests for technical assistance.
Efforts targeted around current and emerging environmental regulations and their enforcement efforts rather than singling out an
industry sector. The latest two initiatives, minor source permits and 112(r), have hit a wide range of businesses from several sectors.
Agriculture production and agriculture chemical applicators, auto service and auto body repair facilities, contractors, dry
cleaners, fiberglass and molded plastic manufacturing operations, medical facilities and laboratories with medical waste
incinerators, printers, wood furniture manufacturers, wood finishing operations, and oil field service companies.
N/A Not applicable N/R No response
-------
TABLE E-4
SBTCP ASSISTANCE
TOTAL BUSINESSES REACHED*
TOTAL BUSINESSES
PROGRAM 7 i 1 JtEACHED
Alabama 1 1374
Alaska 462
Arizona 27338
Maricopa County. AZ 8583
Arkansas 1556
California -••-• - 11416
South Coast. CA ~ ] 2894
Colorado i NA
Connecticut
5439
Delaware [ 221
District of Columbia I NA^
Florida " "" 2575' ~"
Georgia j
44821
Hawaii j 175
Idaho ! 994
Illinois j 8895
• •- 1 ;• -
- ,
:
• • --- — 1
i
i i
j
.. . ._.. _
-•--/--}=--
....
; ~1
i
| i : j
i
Indiana I 10596 _\_ \ ,
Iowa
Kansas
Kentucky
Jefferson County, KY
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
4227
13675
j
325817
571
17554
969!
181
12026!
13978
19453!
15447; i
11237
1302
5984
Nevada j 4171
New Hampshire 8924! j
New Jersey 33184;
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
1615
20635
i
418401 i
NA
7405
2521
815
1185
Puerto Rico 108
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgnina
Virgin Islands
Washington
West Virginia
2343
416391
NA '
4340J
40694
3228
2066
144576
18849
22445
113
!
Wisconsin 19908J |
Wyoming 10082
TOTAL 1002446
! j_
! 1
i
i
i
i
| 1
\ I
I
I - -- -
i
!
]
i
1
i
I
I
i i
!
NOTE* "Total businesses reached" as reported by the states is used as the "official" count for this report. i
Seven programs did not keep data by industry sector, and only "total businesses reached" was given. (AR; ID; Jefferson Cty., KY; MN; NH; NC; Wl)
Four states kept information on I
OH chose not to count over 950,
ie types of services thej
000 publications in their
i offered or the industry sectors they assisted, but did not compile data. (CO, DC, ND, SD)
"total businesses reached" tally. The publications are reflected in the sector totals,
but not in the overall number of businesses reached for this program. i
-------
TABLE E-5
SBTCP ASSISTANCE
TOTAL BUSINESSES REACHED BY ASSISSTANCE TYPE
||
1 L ~" 1 " "" I" "~ " l"~ ": ~ ~
-'- - -
Many states tried not to double count total businesses reached when collecting their data. Therefore, data cannot be summed across to find total businesses reached for each state. ;
4 programs indicated the types of assistance they provided, but did not include data.
PROGRAM
Alabama
Alaska
Arizona
Maricopa County, AZ
Arkansas
California
South Coast, CA
Colorado
Connecticut
Delaware
District of Columbia
Florida j
Georgia
Hawaii _,
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson County. KY
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
HOTLINE
1234
363
1277
0
ON-SITE VISITS
0
5
21
124
520 156
7741 j 2011
SEMINARS/
WORKSHOPS
140
0
40
232
PUBLICATIONS
0
0
26000
6850
T ••"T""
HOMEPAGE
0
0
I
f -
TELECONFERENCE MAILINGS
0 0
o| 61
000
x 0: 609
60! 0; 220 0 600
116| 385J 0 5 703
1981 148 8j 292~"~ 6i 0; 0
x x
230
0
x
245
550
27
990
446
2766
0
453
737
240
60
114
x
2500
1582
1797
5000
2966
389
208
873
747
935
17
2026
1500
0
1314
884
55
71
0
0
30
5
2
0
155
114
19
72
40
1023
60
18
94
64
126
2768
55
93
43
490
32
2
0
17
40
x
148
30
u XL x
1550' 855
150
0
0
829
34
2
1511
764
608
1873
155
0
0
0
0
2330
25768
2
0
18
6739
400
3673
323000
200
23
0 0; X
61 6; 2329
0
0
0
0
0
0
1962
1544
0
3188j
800
0; 0
o| o
Ot 2330
, OTHER
!
33
0
768
0
463
' 465
0
420
0
j_ 0
0 14043J 3601
12 95
o
0 0| 0
41 1 4517
67 1 5361
400
0
0 2300 1 805
21 251
4 869
0 10 0
126081 0 2572
571 1 Oj 0 316
o| o
1753,
2315
222
450
1549
120
3401
1091
320
1682
256
1221
1300
x
532
32
2200
7790
8869
450
6613
450
0
893
6000
1000
1245
9000
20000
x
997104
160
I 8500
' 180
77
1286
0
0| Oj Oi 163
1200 Oj 8090
1 40
1475 | Oj 6! 0
Xj 0: 8418| 21
0
24
0
0
10
0
1218
0
687
2000
0
882
x
6; 3208
30 0
0 1079
12 374
5000
0
16
1946
81 1 240! 493
75 1750
50 28199
0| 97
20: 29350
xj 12000
x x
Ol 4038
22i ' 1580
0
95
0
680
5000
0
199
6
-------
TABLE E-5
SBTCP ASSISTANCE
TOTAL BUSINESSES REACHED BY ASSISTANCE TYPE
II I _1 l l
III!;
Many states tried not to double count total businesses reached when collecting their data. Therefore, data cannot be summed across to find total businesses reached for each state.
4 programs indicated the types of assistance they provided, but did not include data.
PROGRAM
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgnina
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
TOTAL
HOTLINE
90
1172
75
50
X
X
284
1863
1
145
695
0
4491
64
753
605
53000
ON-SITE VISITS
9
0
29
92
17
X
34
177
9
20
16
16
5454
44
31
^ 567
14646
SEMINARS/
WORKSHOPS
89
0
4
640
285
X
630
1391
210
135
2630
5
2159
2
2004
979
36050
I
. _.. i i ,
I 1 "~ t'
PUBLICATIONS
0
0
0
350
0
X
i_
HOMEPAGE TELECONFERENCE MAILINGS
I [
0
0
0
0
Oj 626
! 0] 0
0 0
0! 469
6 104 121
XT 0: X
3274! 0 90! 4118
2083 2200; 0 35651
2317J 0^ 15 588
1500 Oi 5- 24
20472 1 100000
22| 0
808
0
1523
1050
1491709
6676
0
0
X
136694
1071 20082
2j 18804
0_[ 2813
OTHER
0
6
t 0
1208
41206
0
400
0
109
504
574
0
44
ol eT o
150 I 14440
125 21000
954 254121
i
1007
0
75709
i
j
i
i
i
- - •
! "t
I ~t
I •! -
' "
-------
TABLE E-6
NEW DOCUMENTS PREPARED AND DISTRIBUTED BY SBTCPs IN 1998
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
Florida
1998 SBTCP DOCUMENTS
• General Inspection Fact Sheet
UIC Fact Sheet
• Habits of Highly Effective Alaskan Businesses
• Alaska Materials Exchange
N/R
• Assistance Request Form - faxed to business & they fax back with pertinent information and what they need
• Compliance Incentive Package - documents explaining the program
• Auto body start up documents - cover sheet, rule (portion), and sample letter; used with CIP and thereafter
VOC Calculation Help Sheet
• Sample permit applications - industry-specific samples for 5 industries or processes
• The Clean Team - brochure on Mentor-Protege Program
• Financing the Clean Team - describes the revolving loan fund established by the Department
• The Green Award: Recognizing Exceptional Environmental Solutions - awards program brochure (Santa Barbara County)
• Business Environmental Resource Center - brochure (Sacramento County)
• 1998 Pollution Prevention Week - brochure (Sacramento County)
• Business Assistance Program: A Partnership for Clean Air - brochure (Bay Area Air Quality Management District)
• Business Assistance Resource Guides
• Building and Safety Plan - check questionnaire
• AQMD Business Assistance Cards - now publicly available at city permitting centers
N/R
N/R
• Several dry cleaning documents
N/R
• Crematory Fact Sheet
1999 Dry Cleaners' Calendar
• Developed workbook for printers' trainina workshops to be held in 1999
N/A Not applicable N/R No response
-------
TABLE E-6
(Continued)
STATE OR
TERRITORY
Georgia
Hawaii
Idaho
Illinois
1 998 SBTCP DOCUMENTS
Surface Coalers' Permit Guide
1999 Dry Cleaner Compliance Calendar
SBAP Brochure
112(r) Risk Management Brochure
Lithographic Printers' Permit Guide
National Emission Standards for the Printing and Publishing Industry:
CAO Fact Sheet
Dry Cleaners' Focus Group Records and Frequently Asked Questions
None
Small Business Environmental Assistance Bulletin - Summer, Autumn
Greater Chicago Directory of Environmental Resources
Clean Fuel Fleets Program - fact sheet
Guidelines for Determining Businesses Potential to Emit Air Pollution
Revisions to the IL Cold Cleaning Regulations - fact sheet
Revisions to the IL Wood Furniture Coatings Regulations - fact sheet
How Do I Manage My Hazardous Waste? - fact sheet
Do I Have Special Waste? - fact sheet
Storm Water - Keep it Clean - fact sheet
Watch Your Perc - fact sheet
Good Cents Tios for PERC Drv Cleaners - poster
Summary
1998
• fact sheet
N/A Not applicable N/R No response
-------
TABLE E-6
(Continued)
STATE OR
TERRITORY
1998 SBTCP DOCUMENTS
Indiana
Dry Cleaning
5-Star Environmental Recognition Program Application
Solvent Mileage - poster
Brochure for customers
Map of 5-Star program participants
Compliance Manual - updated
Vehicle Maintenance
• Compliance Manual for Indiana's Vehicle Maintenance Shops
• 5-Star Environmental Recognition Program application
• Brochures - workshops, compliance manual, 5-Star environmental recognition program, availability of on-site assistance
HVAC/Plumbing
• Mercury Thermostat Reduction & Recycling Program - 2 brochures explaining the program
• Mercury Thermostat Reduction & Recycling Program - brochure for HVAC customers explaining the program and
encouraging customers to act cooperatively
Fiberglass Reinforced Products
Environmental Information for Fiber Reinforced Product Manufacturers - brochure
Wood Furniture
• Certified Product Data Sheet Question and Answer Document - brochure
• Wood Furniture NESHAP Question and Answer Document - brochure
• What a Typical NESHAP Inspection Will Involve - brochure
Collision Repair/Auto Refinishing
• Collision Repair/Auto Refinishing manual - draft chapters developed and routed for review and comment
• Brochure announcing the availability of on-site assistance
Toxics Release Inventory
• Annual Report - this is the first annual report to be done in this topic in Indiana
Mercury Brochure
Mercury Awareness Program - brochure identifying mercury-containing products commonly found in homes and
businesses .
N/A Not applicable N/R No response
-------
TABLE E-6
(Continued)
STATE OR
TERRITORY
1998 SBTCP DOCUMENTS
Iowa
SBO
SBAP
Agri-business survey - all agricultural sectors covered
Asbestos information survey - asbestos contractors and building owners
Cost-effectiveness survey - cross sectional
Benchmarking study to compare Iowa's air quality stringency with that of other states - cross sectional
112(r) needs assessment study of affected sources in Iowa
Resource Guide 1998 - finalized electronic version of guide covering all SBO/SBAP programs nationwide
Program for Enhanced Environmental Recordkeeping (PEER) - developing a computerized program, primarily for the
manufacturing sector; will be expanded later
Kansas
SBO
SBAP
Policies, Procedures, and Guidance Documents Update for 1997
Policies, Procedures, and Guidance Documents Update for 1998 (submitted early 1999). This annually updated document
contains all of the internal documents developed by the Division of Environment during 1997 for the enforcement of
environmental regulations and is available to the public.
Division of Environment - descriptive brochure
Pollution Prevention poster, bookmarks, and assessment for the general public
Here's What You Need to Know About RMP
Ammonia Handlers, Is Your RMP Ready?
Chlorine Handlers, Is Your RMP Ready?
Propane Handlers, Is Your RMP Ready?
Propane Marketers and EPA's Accident Prevention and Preparedness Rule
Hospitals Prescribe P2 Measures for the Environment
N/A Not applicable N/R No response
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TABLE E-6
(Continued)
STATE OR
TERRITORY
Kentucky
Jefferson Cty
Louisiana
1998 SBTCP DOCUMENTS
Air Quality Representative for Small Business
• Kentucky Small Businesses Volunteer Success Stories About the Kentucky Business Environmental Assistance Program -
brochure
• Program description - updated brochure
• National Small Business Assistance Centers - January 1998 column written and distributed to 1 1 state newsletters with
circulation of 45,600 per mailing
• National Metal Finishing Resource Center- March 1998 column distributed as above
• Small Business Air Quality Stewardship Award Established - June 1998 column distributed as above
• DAQ Field Operations Branch Sees All Across State - August 1998 column distributed as above
• Three Kentucky Small Businesses First Recipients of Small Business Air Quality Stewardship Awards - October 1998
column distributed as above
Wells Ready Mix, Inc. and Pikeville Ready Mix Among First Recipients of Small Business Air Quality Stewardship Awards -
column written for Kentucky Ready-Mixed Concrete Association Newsletter with circulation of 100
• Presentation of Governor's Certificate of Recognition to Jon Trout by "Bo" Hoe, Incoming Chairman - January 1998 photo
published in Land, Air & Water, a publication of the Kentucky Natural Resources and Environmental Protection Cabinet
with circulation of 13,000
Guest speaker Art Williams, Director, Jefferson County Air Pollution Control District - January 1998 photo published as
above
• Small Businesses Volunteer Success Stories - March 1998 story and photo published as above
• Small Business Stationary Source Environmental Stewardship Award Established - March 1998 story with logo published
as above
• Small Business Panel Discusses New Laws - June 1998 story and photo published as above
Small Business Program Has New Web Site - June 1998 story and logo published as above
• Three Kentucky Small Businesses First Recipients of Small Business Air Quality Stewardship Awards - December 1 998
story and photos published as above
KY Business Environmental Assistance Program
• Newsletter
• Air Quality Regulations That May Affect Your Small Business - booklet
112(r) Handbook
N/R
Published and distributed over 5,000 newsletters, brochures, technical papers, and annual report:
SBAP Quarterly Newsletters
Are You in the Dry Cleaning Business? - brochure
What All Wood Finishers Need to Know - brochure
Surface Coating Business in Louisiana - technical paper
1998 Annual Report
N/A Not applicable N/R No response
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TABLE E-6
(Continued)
STATE OR
TERRITORY
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
1 998 SBTCP DOCUMENTS
. Dry cleaner fact sheets - simplifying regulations with model forms for recordkeeping
Environmental Compliance, A Quick and Easy Guide for Small Businesses - multimedia publication
N/R
Auto Body CRASH COURSE and companion TOOLBOX
Materials for DPWs
Surface Coating of Metal Parts - fact sheet for the fabricated metals industry
Continuous Emission and Continuous Opacity Monitoring - fact sheet for general industry
Michigan Permit to Install: Guidebook for Determining Applicability - general industry
Understanding the Asbestos NESHAP - fact sheet for building demolition/renovators
What is an Air Contaminant? - general industry and public
Michigan Air Use Permit Technical Manual (Update) - general industry and air quality consultants
Regulatory Guidebook for Michigan's Lithographic Printing Industry - cooperative effort of SBAP and units in the Ml
Department of Environmental Quality's Environmental Assistance Division
. Michigan Air Emission System (MAERS) Workbook - general industry
• List of aqueous-based wood-finish manufacturers
N/A
• Preventing Pollution in the Vehicle Maintenance Industry
• Preventing Pollution at Rock Quarries
• Preventing Pollution in Collision Repair
• Preventing Pollution During Vehicle Salvage
• Preventing Pollution in Lithographic Printing
Preventing Pollution in Flexographic Printing
« Preventing Pollution in Screen Printing
Section 1 12(r) Risk Management Plan Newsletter and Guidance Document - distributed to propane dealers, farm
cooperatives, and small communities
• Medical and Infectious Waste Incineration MACT Standard - fact sheet
• Consumer Products MACT Standard - fact sheet
• Architectural Coatings MACT Standard - fact sheet
• Automobile Refinishing Coatings MACT Standard - fact sheet
Draft sorav coatinq requlation for Montana
N/A Not applicable N/R No response
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TABLE E-6
(Continued)
STATE OR
TERRITORY
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
1998 SBTCP DOCUMENTS
• Consultant Directory - provides names, addresses, points of contact, and types of services that consultant and engineering
companies can perform for small businesses. Over 200 companies have provided information for publication in the
directory.- A matrix is provided for quick reference, and an index allows for separation between disciplines. The directory is
divided into areas of interest for easily selecting the type of company that a small business may need.
No new documents were prepared. Several existing documents were updated.
• Small Business Guide to the Internet (assist small businesses in obtaining environmental compliance data from
Internet)
Wood Finishing Manual (in conjunction with NEWMOA and NHDES P2 Program)
Environmental, Health, & Safety Checklist for Auto Repair Shops (in conjunction with NEWMOA)
the
None
• Draft Regulations for Rock Crushers & Asphalt Plants - fact sheet
• Draft Regulations for Concrete Batch Plants - fact sheet
• Enabling Language for General Construction Permits - fact sheet
• Public Notification for Air Quality Permitting - fact sheet
• General Construction Permit - for oil and gas compressor stations
• 10 fact sheets describing compliance options for halogenated solvent degreasers, based on the NESHAP
1 fact sheet describing capping options for sources with PTEs above major thresholds
• 10 generic compliance plans for New York State dry cleaners (by equipment type and facility location)
2 issues of Clean Air News (technical newsletter)
Developed database and distributed lists of environmental consultants by geographic area as well as expertise
• Do You Need A Risk Management Plan? - workshop/training brochure on 1 1 2(r) and SARA Title III training
• Brochure (in progress) to help clients determine if they are subject to the chemical accidental release program
None
SBO
1 997 Annual Report of the Ohio Air Quality Development Authority
• Air Focu$ - quarterly newsletter
Clean Air Resource Center - updated fact sheet
SBAP
Extensive reorganization of SBAP web page - included links to download permit application forms, Compliance
Centers, CAGE/SAGE programs, P2 sites, and other state SBAPs
Metal Recvcler/Reclaimer - fact sheet on air and hazardous waste requlations
Assistance
N/A Not applicable N/R No response
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TABLE E-6
(Continued)
STATE OR
TERRITORY
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
1998 SBTCP DOCUMENTS
. Business Assistance Program - brochure announcing program
« General Permits in Pennsylvania: Faster and Easier Permitting
N/R
Air Pollution - auto body fact sheet
Hazardous Waste - auto body fact sheet
Water Pollution - auto body fact sheet
Pollution Prevention - auto body fact sheet
OSHA - auto body fact sheet
• Consumer Products Manual
N/R
• 1 1 2(r) Tennessee Workshop Manual
1 1 2(r) general gverview brochure
• 1 1 2(r) chemical listing brochure
• 1 1 2(r) slide presentation
• Clean Air Act Overview Workshop Manual
• 11 2(r) Workshop Announcement - brochure.
• Clean Air Act Workshop Announcement - brochure
• Consumer Products Workshop Announcement - brochure
• Printing Teleconference Announcement - brochure
Metal Finishers Guide
• Auto Repair Guide
Site Visit Card
• Do You Need A Permit? - card produced under contract
• Storm Water Frequently Asked Questions - brochure
• New Clean Air Regulations & Your Utah Business
• Pollution Prevention for Wood Furniture Manufacturers
• Vehicle Service & Repair Technician's Guide to Vermont's Environmental Regulations - Summer 1998 manual
• Internet Training Guide
• Proaram and Internet Web Sites - fact sheets
N/A Not applicable N/R No response
8
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TABLE E-6
(Continued)
STATE OR
TERRITORY
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
1998 SBTCP DOCUMENTS
• Exterminating & Pest Control
• Medical Laboratories
• Quality Assurance Laboratories
• Janitorial Services
OAPCA
• Spray Coating Operations: An Informational Summary of Regulatory Guidelines for Thurston County, Washington
SCAPCA
Things Your Business Should Know About Reducing Air Pollution
• Fiberglass and Composite Manufacturing
Controlling Dust in Spokane County
• Update - newsletter
• Various compliance information sheets and posters
• Multimedia Assistance - draft brochure
Small Business Guide to OAQ Permitting - expected to be finalized in 1999
• Maximum Theoretical Emissions Calculations - fact sheet
11 2(r)- fact sheet
• Numerous revisions of existing publications
• Auto Service/Auto Body Shop Multimedia Checklist
• Contractor Multimedia Checklist
• Dry Cleaner Multimedia Checklist
• Medical Facility Multimedia Checklist
• Printer Multimedia Checklist
Small Mining Operations Multimedia Checklist
• Oil Field Service and Wellhead Multimedia Checklist
« Hazardous Waste Disposal - non-regulatory brochure
• Septic Systems - non-regulatory brochure
• Wellhead Protection - non-regulatory brochure
• Household Hazardous Waste and Paint Disposal - non-regulatory brochure
• Proper Management of Farm Wastes - non-regulatory brochure
N/A Not applicable N/R No response
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TABLE E-7
NOTABLE OUTREACH METHODS
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
NOTABLE OUTREACH METHODS
N/R
Site visits are the most cost effective form of outreach. Direct and customized service are offered. Measurement of the results also
became easier, since a direct relationship with a business has been established. Last year, Alaska's auto service sector initiative
achieved a 96% compliance correction rate. A 98% compliance correction rate was achieved as a result of our work to help 50 small
businesses improve hazardous waste management practices. These same businesses also considered 101 options for pollution
prevention.
N/R
Direct mailings from Environmental Services Director - these letters introduced the Compliance Incentive Program (CIP), a limited-
time amnesty program. The letter had more impact on businesses, because it was from the Director and mentioned possible
enforcement action. The time limit appears to have encouraged businesses to call more quickly. Businesses were found using the
Internet yellow pages.
Workshops have proven to be the most effective method of communication and recruiting clients. Mailings represent a low
percentage of return, but also are effective.
Permit renewal inspections.
Building and Safety Department Program - One-on-one direct contact was made with the agencies in each city in South Coast's
jurisdiction. Target is to contact all 172 cities to inform them of permitting requirements by the end of this fiscal year. Effectiveness of
the efforts is being measured by the increase in the number of permit clearance letters issued as a result of the program.
Last quarter of 1998: SBAP team initiated a 25 per month per member (3x25=75/month) site visit program. A portion of their targeted
sources consisted of various businesses that were due to renew their Air Pollution Emission Notices (APEN),
Initiated and conducted industry-specific workshops.
Intensive outreach, and focused and hands-on training yielded high number of permit applications submitted and a high degree of
accuracy of submissions.
Face-to-face on-site meetings.
SBAP is a permit engineer. When she gets any permit question, she uses the opportunity to inform the sources about some
requlations that may apply to that specific source category, (direct communication)
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
NOTABLE OUTREACH METHODS
Florida
2,130 dry cleaner calendars distributed state-wide improved compliance with recordkeeping requirements. (130 businesses were
designated as a project group for this data. An additional 2,000 calendars were distributed, yielding 2,130 total calendars distributed.)
Improvements in compliance from 1996-1998:
Broward County: 20%/1996 to 98%/1998.
Orange County: 10%/1996 to 50%/1998.
Central District: 6%/1996 to 71%/1998.
Average compliance improvement was 61%.
Georgia
Calendar for dry cleaners to use for recordkeeping. Will survey dry cleaners in 1999 to gauge effectiveness of calendar. Florida
uses a similar calendar, and has reported record keeping compliance rates increased from 10% to 95%.
Hawaii
All dry cleaners in the state (62), whether regulated or not, were reached with a mailing. They all received compliance information and
record of the focus group meeting, which had been attended by 16 drycleaners from around the state. Two of the three dry cleaners
on Kauai attended the technical assistance workshop in Lihue; the remaining dry cleaner had already received compliance assistance
information.
Focus group sessions also were established for 13 trade associations and 31 small business advocacy groups. Both of these focus
groups contributed to the development of a skeletal framework for the SBO.
Idaho
Almost all outreach was conducted over the phone or via e-mail. Beginning in January 1999, the SBO will begin conducting regular
site visits.
Illinois
SBAP is partnering with the IL Office of Pollution Prevention and the Small Business Development Network to provide graduate
students to do P2 assessments of SBDC clients. The program was tried in Summer 1998 on a limited basis, and SBAP is pursuing a
longer term pilot (Feb-June 1999). Resources were maximized by combining IEPA P2 resources with those of the SBAP,
Procurement, Small Business Development, and Manufacturing Extension Centers.
Small Business Environmental Assistance Bulletin - Summer, Autumn 1998. The bulletin has proven to be an excellent tool to
inform clients of new documents and program projects. Calls to the helpline have increased as a result of the quarterly bulletin.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
Indiana
Iowa
NOTABLE OUTREACH METHODS
Dry cleaners: Regional compliance workshops were well received by the 77 dry cleaners in attendance. The majority of workshop
evaluations were positive. No hard data that what we are doing improves compliance for IN dry cleaners, but compliance workshops
and on-site visits are getting dry cleaners closer to full compliance, as some dry cleaners have fewer violations than those that are not
visited or those that do not attend compliance workshops. On-site assistance was provided to those who requested a site visit. On-
site assistance is particularly valuable to this industry, as this is sometimes the only type of assistance that truly helps small business
owners understand the rules plus helps to build a good working relationship between the business owners and the SBAP.
Vehicle Maintenance: Compliance assistance workshops were held throughout the state. Workshop evaluations were consistently
positive. SBAP staff also provided on-site assistance to shops upon request. Shops were very appreciative of this service.
Wood Furniture: Three workshops on the wood furniture NESHAP were held before the December 7 compliance deadline. The
workshops were aimed at the environmental managers of wood furniture industries. Comments provided indicated the training was
helpful, especially in providing information on new requirements, what inspectors expect, types of fines, etc. Reminder cards were
sent four times this year to the 47 wood furniture manufacturers subject to the NESHAP. Due dates for initial and semiannual
compliance reports, information to include in reports, and where to find sample reports, were included on the card. Comments on the
effectiveness of these cards were very positive.
Fiberglass Reinforced Products: CTAP created and mailed approximately 211 brochures on "Environmental Information for Fiber
Reinforced Product Manufacturers." Also mailed a pollution prevention final report to many manufacturers.
Collision Repair/Auto Refinishing: On-site visits and one-on-one discussions.
Web Site: CTAP web pages were hit 6,591 times in 1998. In January 1998, CTAP had 8 pages; by December 1998, 42 web pages
were up and running, covering subjects such as CTAP confidentiality, dry cleaners, mercury, vehicle maintenance, wood furniture, and
fiberglass. Most often visited are the mercury pages, the dry cleaner 5-star recognition program database search, and the vehicle
maintenance and dry cleaner compliance assistance manuals.
TRI Workshops: Toxics Release Inventory workshops were held in five separate locations throughout IN. The workshops reached
more than 250 businesses that either are required to report or need assistance to determine if they are required to report. These
workshops, along with more than 200 phone calls to assist reporters. Have significantly increased the quality and accuracy of reporting.
IN's SBAP is working with the newly added TRI industries, including electric utilitues, for the next reporting year. Of the TRI releases
reported in IN, 95% of these releases are to air.
Mercury Awareness Program: All 92 IN counties offered free mercury collections to IN households during October 1998. More that
2,000 pounds of mercury were collected and kept from IN lakes, rivers, streams, landfills, and incinerators.
SBAP did not conduct any special targeted outreach. We have a backlog of over 200 requests for site visits. Following are examples
of how clients were referred: state DNR and EPA (infrequently) inspectors, trade associations and business groups, client referrals,
SBO referrals referrals from other IWRC oroarams.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
NOTABLE OUTREACH METHODS
Kansas
KDHE Division of Environment provides an annual environmental conference. The ombudsman coordinates this conference, which
focuses on compliance, new technologies, and pollution prevention. The conference has grown from about 150 participants to 350 in
1998. A conference evaluation is given to attendees and continues to provide almost exclusively positive remarks. A focus of the
conference each year is the availability of free assistance. After the conference each fall, a marked increase in numbers of calls is
noted, as well as an increase in requests to be placed on mailing lists for the Kansas Environmental News and the Kansas AIRLines
newsletter. Additionally, for the last two years, seminars on Environmental Management Systems have been offered by the SBEAP,
which has stimulated interested in EMS. The target audience is businesses and community representatives, although a majority of
attendees are from medium to small businesses.
Second, the ombudsman has developed, with the cooperation of numerous other agencies, a Small Business Assistance Group.
The SBAG is comprised of the SBA, SBDC, KS Department of Commerce and Housing, KS Department of Revenue, Human
Resources, Aging, Secretary of State, and many other state and federal agencies. This group presented two seminars in different
locations in the state for people thinking of starting a new business. The seminars were in the evening, and representatives, including
the SBAP and the Division of Environment staff, explained requirements, services, and other important information to those starting a
new business. Over 140 people attended the seminars, which were very well received. The goal of the seminars is to provide good
information before a business is started in order to avoid problems in the future. The cooperative effort of the state/federal agencies
has been outstanding, and two more seminars are planned for 1999.
Technical assistance is working more with trade associations to promote programs. This provides "buy in"and reduces promotional
and organizational costs. This year, we spoke to 60 people from the KS Fertilizer and Chemical Association and KS Farmers Service
on RMP requirements under 112(r). The same subject was covered with 80 attendees from the KS Propane Marketers Association at
their annual meeting. We also met with members of KS Water Environment Association and the KS Chapter of the American
Wastewater Association on chlorine RMP. We presented compliance requirements to the Korean Dry Cleaners Association in Kansas
City. We collaborated with a vendor to present a workshop on feedlot dust and lagoon management. We also worked with ink
suppliers to sponsor the Screen Printers teleconference in two locations and worked with MO SBAP technical assistance on the
downlink for the Kansas City site. Through the KS State University Extension radio station, which covers the entire state, we provided
a 35 minute radio show on underground storage tanks.
The Division of Environment made several general and specific program presentations at local, state, and regional meetings,
including: Kansas City Chapter of the Society for Turbidation and Lubrication Engineers, City of Wichita Pretreatment Workshop, KS
Water Environment Association Industrial Pretreatment Workshop and Operator Training, KS Health and Safety Conference, KS
Association of Sanitarians and the KSU Research and Extension Annual Conference, and the Association of Metropolitan Sewerage
Agencies.
Kentucky
A cost effective method of outreach for KY has been the column written six times per year by the Air Quality Representative for Small
Business. The column is distributed to 11 statewide trade associations and business promotion newsletters with a circulation of 45,600
per mailing.
The Division for Air Quality's regulatory notification program that provides information on KBEAP to businesses that are possibly
affected by new rules also is effective.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
NOTABLE OUTREACH METHODS
N/R
Several SBAP engineers attended and were guest speakers at 43 meetings, conferences, and seminars with 1,694 attendees.
Manned informational booths at two conferences with over 400 attendees. Interviewed by a radio station in north LA. Participated in
public relations activities (e.g., high school/college career days, etc.).
Simplified regulatory documents and forms combined with a site visit to all dry cleaners. SBTAP was able to visit all dry cleaners
in the state in a short time.
N/R
Software offer to solvent users generated a lot of site visits, and the software was well appreciated. It seems to help companies to
control VOCs as well as track them.
The autobody project (workshops and plain language guide to regulations) generated a lot of site visits and has helped many
shops begin to grapple with environmental responsibilities.
The schools project (chemical use/indoor air pollution) has generated much information that is useful in publicizing this issue.
The Department of Public Works project has generated a high degree of interest and attention in addressing environmental
problems from such facilities without the administrative costs of enforcement first.
Asbestos NESHAP Workshop: SBAP presented four statewide workshops on the notification, recordkeeping, and reporting
requirements of the asbestos NESHAP. Planning for the agenda items and speakers required partnering with multiple state agencies
and industry associations to find ways of marketing this workshop to a varied audience. The SBAP was able to convince its state
consumer regulatory agency to offer continuing education credits for workshop attendance to those participants needing to maintain
some level of statewide certification. The SBAP attracted an overwhelming number of participants (527 at all four workshops), many of
whom were fulfilling the education requirement for their state certification. We believe that by offering the continuing education credits,
we were able to better market this workshop and reach a wider and varied audience with this tangible benefit.
Produced and distributed video tape for wood finishing industry. Newsletter. Training programs.
One-on-one workshops were extremely effective in communicating regulations. Television talk shows and news interviews were
very effective in reaching a large number of sources.
Direct mailings seem to be the most effective methods of contact. Attendance at workshops is always much greater when direct
mailings are done. On-site visits seem to be effective in helping facilities achieve compliance. Involvement of associations is very
inriDortant to reach the maximum number of facilities within industry sectors.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
NOTABLE OUTREACH METHODS
Site visits -- excellent way to reach businesses to explain regulatory compliance and pollution prevention options.
Workshops -- advertising for workshops focusing on regulatory compliance and pollution prevention also were successful.
Loan Program - proved to be successful in raising awareness about regulations, particularly underground storage tank standards.
Enabled over 20 small, rural, service stations to stay in business.
Working with trade associations and professional groups has brought trust and feedback to the state program.
Organizations like NICE (Nebraska Industrial Counsel on the Environment) have allowed the SBAP to provide information and discuss
issues with some of the leaders on both large and small businesses. These types of organizations are a cross section of all types of
sectors and have developed some very good partnerships.
Developing generic fact sheets and other outreach materials in cooperation with county air quality programs and sharing
costs as allowable makes outreach more cost effective. In some instances, the SBAP had the resources to develop outreach
materials and the county agencies had funds for mailing.
Our Automotive Industry Environmental Compliance Manual continues to be extremely well received. We have distributed over
1,000 copies to date and will be reformatting and reprinting this manual in 1999. Improvements in compliance rates have been
identified anecdotally, and we will be conducting a sampling survey in 1999.
Our newsletter is sent to 3,000 small businesses, consultants, town officials, and others with very positive results.
On-site assistance continues to be the most effective outreach.
The regulated community, as well as consultant and engineering firms, were targeted for mailings of state-sponsored air audit courses.
This targeted mailing to service providers is intended to increase compliance within the regulated community.
Fact sheet/template for Public Notification for Air Quality Permitting. Discuss with business representatives and public.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
NOTABLE OUTREACH METHODS
New York
Postcards -- The program began a new system of disseminating information to businesses regarding important regulatory changes or
deadlines. The SBEO developed postcards with simple, single messages on them as a means of reminding businesses of upcoming
deadlines or informing them of regulatory changes. Postcards are less expensive than letters to mail, and the simple messages caught
the attention of business owners. Once the business owner contacted the SBEO, they were given the full spectrum of assistance,
beyond the one issue described in the postcard that prompted the phone call. After initial compliance assistance was given, many
callers were referred to the SBAP program for technical assistance.
Trade Publications - In conjunction with the postcards, the program developed advertisements with the same simple, single message
as the postcards. The SBEO logo and 1-800 phone number also were printed on the advertisements. The ads were placed in trade
magazines and membership newsletters and served both to reinforce the message to business owners who had already seen the
message once in the mail, and to reach industry consultants, vendors, equipment manufacturers, etc. who may have been missed in
the mailing.
Together, the post cards and the advertisements generated a large increase in phone calls to the ombudsman hotline. For example,
over 90% of the dry cleaners who called the SBEO hotline after this campaign began indicated that they had heard of the service
through a postcard or recent advertisement.
North Carolina
112(r) Workshops -- This year, we did a joint training effort with the Division of Air Quality for all sources, particularly those affected by
112(r). Outreach efforts included brochures, workshops for industry and staff, and the web site. The web site and mailings
contained general information on requirements, guidance on how to determine if these requirements applied, and what program
particularly was appropriate for their facility. The.total number of contacts was approximately 6,000. Many of those received or will
receive three different informational mailings. Overall compliance improvement cannot yet be judged, since the deadline is not until
June 21, 1999. This effort will continue in 1999.
North Dakota
Informational mailings have been the most utilized outreach method. Individual contact is not practical, because there are so many
sources that are potentially affected by the rules.
Ohio
SBAP continues to keep in close correspondence with the inspectors and permit writers located at five OH EPA field offices and
seven local air agencies. This has caused an increase in the number of companies referred to the SBAP by the districts and has
increased SBAP credibility. On several occasions, this also has allowed the SBAP to help companies peacefully resolve violations
found during inspections and to avoid enforcement action.
SBO has found it very productive to provide program materials to all state legislators and their staff members and to educate
them about the program's potential benefits for constituents. This frequently results in a reference to the program in member's
newsletters and presentations; this also has resulted in a couple of district meetings with small businesses. In addition, SBO had
received a number of requests for assistance as a result of a business owner hearing about the program from his/her representative.
N/A Not applicable N/R No response
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TABLE E-7
(Continued)
PROGRAM
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
NOTABLE OUTREACH METHODS
The wood furniture manufacturers workshop on the NESHAP was particularly effective. We partnered with a local coatings
manufacturer, and they hosted the workshop. The representative from the coatings company that worked with us is a member of our
CAP.
The workshops for chromium electroplaters were very successful, because this industry group was easy to identify.
SBO served as a trainer in a series of training sessions delivered by the PA Department of Community and Economic Development
to small business service providers. The training introduced more than 500 service providers to the SBAP and resulted in an increased
awareness of departmental programs, pollution prevention, and the small business technical assistance program.
Since the program is not in full operation, usually referrals for assistance come from other programs inside EQB.
On-slte assistance for autobody shops. Satellite downlink conference for screen printers.
Newsletter articles were very effective. Calls for assistance usually increased immediately after the release of an article.
N/R
CAA overview workshops were repeated for the fourth year and attendance remained good. Over 250 businesses attended the
workshops.
In-house staff conducted 112(r) training. Over 250 businesses attended the workshops. Requests have been made for industry-
specific 1 12(r) workshops.
On-slte, one-on-one assistance to small employers was effective.
N/A Not applicable N/R No response
8
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TABLE E-7
(Continued)
PROGRAM
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
NOTABLE OUTREACH METHODS
Site Visit Program - Site visits were conducted for 177 small businesses in 1998. Surveys taken after the site visit found small
businesses had made significant changes based on the consultant's recommendations. Site visits also spurred more small businesses
to recycle and use environmentally friendly solvents, reduce waste, and cut disposal costs.
EnviroMentor Program - This program matches volunteer environmental professionals with small businesses that need compliance
assistance. EnviroMentors provide free, on-site, confidential assistance, including identifying areas of noncompliance, suggesting
ways to cut costs, and assisting with permit applications. In 1998, eight businesses were reached for a total of 120 hours volunteered.
Volunteers have saved small business owners over $7,050 through voluntary assistance. In 50% of the matches, volunteers assisted
businesses with hazardous waste management. Other areas of assistance included above ground storage tanks, stormwater permits,
Voluntary Cleanup Program, and exemption from air permitting.
Workshops - SBAP gave 35 workshops in 1998 on topics including metal finishing, auto body and auto service, chemical coating,
printing, dry cleaning, and RCRA waste recordkeeping. Attendance at all workshops totaled over 1 ,391 people.
Notification -- SBAP performed 22 notifications on rules in 1998, reaching 22,749 customers. Following are the number of
notifications/businesses reached for the higher-profile industries. Auto body/auto service: 2/11,508. Metal finishing: 2/1,139.
Foundries: 2/255. Increases in compliance are measured via hotline calls.
Hotline - 1,865 hotline call from all industry groups were received in 1998.
N/R
Workbooks mailed out for the vehicle service industry and followed with nine regional workshops, which had over 135 attendees.
Received many follow up calls for on-site assistance or for more information about specific regulations.
Continuing development of the SBAP web site (www.deq.state.va.us/osba/smallbiz.html) has been successful in providing compliance
and pollution prevention information. We averaged approximately 300 hits per month in 1998. The EPA Leadership Grant provided
the opportunity to create this site; the grant will end in March 1999, but the site will continue with dedicated staff to provide assistance.
Since the inception of the SBAP and with the addition of the Internet, we have reached or have the capability to reach in excess of
100,000 businesses.
Direct compliance assistance outreach continues to provide the most effective vehicle for delivery of information and compliance
assistance. Direct activity can take the form of workshops, on-site visits, direct communication, phone, and one-on-one
meetings. We highly recommend interacting with trade associations as an absolutely necessary component to effective outreach.
Mailings and correspondence total was 9,213 brochures, 30 manual information packets, 5 seminars, and 10 permit and
compliance assistance.
SCAPCA: Pre-visit survey sent to 100 printers.
N/A Not applicable N/R No response
-------
TABLE E-7
(Continued)
PROGRAM
West Virginia
Wisconsin
Wyoming
NOTABLE OUTREACH METHODS
Attending expos involving small businesses and distributing SBAP information.
Workshops targeted to specific regulations, such as minor source permits, have been especially effective.
The Department, through its Office of Outreach (SBAP, SBO, P2 Coordinator, and Emergency Response Coordinator), publishes a
newsletter tri-annually, which includes multimedia compliance information to our targeted business and government community, plus
points of contact for additional information on the full range of environmental topics. Each issue of the newsletter is mailed/distributed
to about 7,500 businesses and government entities and has consistently generated return calls.
The staff from the Office of Outreach regularly travels throughout the state doing one-on-one site visits with small businesses in our
targeted business categories. Our handout literature, business sector check sheets, and newsletter articles open doors to businesses
that otherwise would be apprehensive talking to DEQ regulatory personnel. These one-on-one contacts routinely provide new
opportunities for compliance assistance and P2 initiatives. The Office has conducted over 500 one-on-one site visits this calendar
year.
N/A Not applicable N/R No response
10
-------
TABLE E-8
SBTCP WEB PAGES
In the first table, web page addresses, usage statistics, and comments/feedback from users are listed. In the second table, types of
information accessible through each program's web site are shown.
Program
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
Web Page Address
www.adem.state.al.us
www.state.ak.us/local/akpages/ENV.CONSERV/d
sps/compasst/cao home.htm
www.adeq.state.az.us
www.maricopa.gov/sbeap
www.state.ar.us
www.arb.ca.gov
www.aqmd.gov
www.cdphe.state.co.us/ic/sbomain1.html
http://dep.state.ct.us
www dnrec state de us
Usage During
Report Period
N/R
No counter at
this time
N/R
25,024
N/A
2,543,656;
>50B bytes
transferred
N/A
Not known
N/A
N/R
Comments Received
N/R
Our clients can provide feedback by using our standard feedback form.
We supply clients with this form when we work with them. We have been
receiving feedback for the post several years. Responses indicate that our
clients value our services, and we maintain high ratings for service
delivery, professionalism, and results. We have incorporated additional
opportunities to provide feedback on our developing web site. We have
not received very many feedback responses via the Internet. We have
received anecdotal reports that clients like our web site. One person
indicated that he had a hard time finding information on our web pages.
SBAP is working with the Governor's Small Business Council to provide
easier web site access to the broad range of small business services
offered in AK.
N/R
Since our home page includes other Department programs - water, food
inspections, etc. - we get a huge variety of questions, which range from
requests about food inspection to flood plain maps to animal waste.
N/A
The web site has a contact button. We receive praise for our web site,
particularly for the meta tags that enhance finding information using search
words. We now have a search engine hit percentage of 90%.
All comments on the home page are routed through the District's media
office. Feedback specific to the small business portion of the home page
is not readily available at this time. Comments on the web site overall
have been positive. A major redesign of the AQMD web page is planned
for 1999.
Comments not solicited.
The most common request is to include more information on our web site.
N/R
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
Program
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana*
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michiaan
Web Page Address
None
www.dep.state.fl.us/air/outreach/sbap/sbap1.htm
www.gasmallbiz.org
None
www2.state.id.us/deq
www.epa.state.il.us
www.commerce.state.il.us
www.state.in.us/idem/ctap
www.state.ia.us/sbro
www.iwrc.org
www.sbeap.niar.twsu.edu
www.kdhe.state.ks.us
www.state.ky.us/agencies/nrepc/dep/smbizair
http://gatton.gws.uky.edu/KentuckyBusiness/
kbeap/kbeap.htm
None
www.deq.state.la.us/oarp/sbap/sbap.htm
www.state .me.us/dep
www.mde.state.md.us
www.magnet.state.ma.us/ota
www.michigan.org
www.deq.state.mi. us/ead/eosect/caao
Usage During
Report Period
N/R
1,360
81 (from 11/4-
12/31/98)
N/R
N/A
1,962
1,650
SBO +3,000
SBAP -14,000
4,925
KBEAP 800
N/R
12,608
N/A
N/A
1,200
1.911
Comments Received
N/R
We do not have a "chat room," but people can e-mail to any listed staff
member. We do not typically get any e-mails derived from the web site.
We currently are not asking for feedback or comments on the web site.
Immediately after the new site was established, we requested comments
from other states, Region IV small business contacts, and our CAP.
N/R
We asked for feedback until November. We stopped as we didn't have a
full time web master who could handle or distribute incoming requests,
suggestions, comments, etc.
N/A
We do not ask for comments.
SBO - We ask for comments, none received.
SBAP - We ask for comments. IWRC site recorded 1 ,163 user sessions
per month. Average time spent per user is 17.5 minutes. On average, 22
different counties accessed IWRC web site per month.
Our feedback has been exclusively positive and extremely complimentary.
We often get OSHA questions, which we refer to appropriate agencies.
Air Quality Representative for Small Business does not. Feedback is
requested by KBEAP. None has been received to date.
N/R
None.
We are not soliciting feedback at this time on the home page.
Do not ask for feedback.
No significant comments received.
Feedback is not actively solicited, but the SBAP receives it anvwav.
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
Program
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New
Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Web Page Address
www.pca.state.mn.us/prog rams/sbomb_p. html
www.deq.state.ms.us
www.dnr.state.mo. us/deq/tap/hometap. htm
www.deq.state.mt.us
www.deq.state.ne.us
www.state.nv.us/ndep/sba/sba01.htm
pending
www.state.nj.us/commerce/caasbo.htm
www.state.nj.us/dep/aqm/sbap.htm
www.nmenv.state.nm.us
www.empire.state.ny.us/sbeo/
www.nysefc.org
www.p2pays.org
www. health .state . nd. us
www.state.oh.us/carc/
www.epa.ohio.gov/dapc/sba/sbaintro
www.dea.state.ok.us
Usage During
Report Period
Unknown
Not tracked
3,000
N/A
11,000+
N/A
N/A
SBO 650
SBAP1.218
-4,000
687
(9/1-12/31/98)
-2,000
Unknown
SBO 1,441 hits
from 882
sources
(6 mo.)
SBAP not
tracked
N/A
Comments Received
N/R
N/A
We do not ask for feedback on our web site; however, we do receive
phone calls from those who have visited our site. A couple of the
comments received are: We need to have more of our publications
downloadable. Requests have been made for permit forms and
applications on the site for downloading.
N/A
N/R
Web site will be implemented in early 1999. No comments available.
Not yet completed.
None.
N/R
N/R
We have received a number of questions, which most often are for
information on financial assistance and how to start a business. Most of
our traffic comes through the Department of Pollution Prevention links.
We will be revising the web site and tracking the hits we get to better
respond.
We ask for comments.
SBO - 5-10 businesses have stated they learned about the Clean Air
Resource Center on the web site.
SBAP - No comments have been received, although a handful of
industries reported learning of us through the web.
Yes, we do ask for comments, but have not received any thus far.
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
Program
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Web Page Address
www.deq.state.or.us
www.dep.state.pa.us
None
www.state.ri.us/dem
www.state.sc.us/eqc/admin/html/sbap.html
www.state.sd.us
www.state.tn.us/environment
www.tnrcc.state.tx.us/exec/small business
www.deq.state.ut.us/eqoas/bus home.htm
www.deq.state.ut.us/eqair/perrrifts/sbap3.htm
www.anr.state.vt.us/dec/ead/eadhome.htm
www.deq.state.va.us/osba/smallbiz
None
www.wa.gov/ecology
www.dep.state.wv.us/oaq
www.commerce.state.wi.us
http://deq.state.wy.us
Usage During
Report Period
N/R
6,810+
N/R
N/A
931
5,200
N/A
-2,200
N/A
N/A
3,616
N/R
Several
thousand
N/A
17,040
N/A
Comments Received
N/R
Do not ask for comments.
N/R
Do not ask for comments.
Feedback is requested. No comments received.
Yes! Usually receive questions on radon, feed lots, odors, etc. We also
get requests from students.
Feedback not requested. The number of hits is included with Division
total, and separation of information is not available.
We do request comments. These include technical questions about
compliance issues for various industries, available publications, and how
to participate in the EnviroMentor program.
We do ask for comments, but there has been none.
N/A
We have not received enough on-line feedback to classify comments.
N/R
Want to be able to complete registration and application forms
electronically.
We haven't received any specific feedback on the web site, but have
received positive feedback on the overall SBAP program.
General feedback is not available for our section of the Wl Department of
Commerce web site.
No formal feedback mechanism for our web page is in place at this time.
However, we do get comments from individuals who access the site. Most
ask for additionafinformation or points of contact. A small number ask for
assistance in downloading documents or finding related links.
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
INFORMATION ON SBTCP WEB PAGES
AL
AK
AZ
Mari
copa
AR
CA
S.
Cst.
CO
CT
DE
DC
FL*
GA
HI
ID
IL
IN
IA
KS
KY
INFORMATION AVAILABLE
Program
Description
X
X
X
X
X
X
X
X
X
X
N/A
X
X
N/A
X
X
X
X
X
Air rep.
KBEAP
Contact
Listings
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
t£3k
Regulations
X
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
Permit
Info
X
X
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
Permit
Forms
X
X
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
Emissions
Inventory
X
X
X
X
X
X
X
Policies
X
X
X
X
X
X
w x
X
X
X
Guidance
Documents/
Fact Sheets
X
X
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
P2 Info
X
X
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
Multimedia
X
X
X
X
X
X
X
X
X
X
X
List of
Publications
X
X
X
X
X
X
X
X
X
X
X
X
KBEAP
CAP
Info
X
X
X
X
X
Air rep.
Calendar
of Events
X
X
X
X
X
X
X
X
X
X
X
KBEAP
Links
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
^ffi-
Other*
X
X
X
X
X
X
X
Air rep.
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
Jeff.
Cty
LA
ME
MO
MA
Ml
MN
MS
MO
MT
NE
NV
NH*
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
INFORMATION AVAILABLE
Program
Description
N/A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
N/R
X
N/R
Contact
Listings
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Regulations
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Permit
Info
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Permit
Forms
X
X
X
X
X
X
X
X
X
X
x
X
X
X
X
Emissions
Inventory
X
X
X
x
X
X
Policies
x
X
X
x
x
x
x
x
X
X
x
Guidance
Documents/
Fact Sheets
X
X
X
X
X
x
X
x
x
X
x
X
x
X
x
X
P2 Info
X
x
X
X
X
X
x
x
X
x
X
X
X
X
X
Multimedia
X
X
X
X
X
X
x
X
X
x
X
X
X
x
List of
Publications
x
x
X
X
X
X
x
x
x
x
CAP
info
X
X
x
x
Calendar
of Events
X
x
X
x
X
X
x
x
x
Links
X
X
X
X
X
X
X
X
x
x
x
Other*
X
X
X
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
INFORMATION AVAILABLE
Program
Description
X
X
X
X
X
X
X
N/R
X
X
X
X
Contact
Listings
X
X
X
X
X
X
X
X
X
X
X
Regulations
X
X
X
X
X
X
X
X
X
Permit
Info
X
X
X
X
X
X
X
X
X
X
Permit
Forms
X
X
X
X
X
X
X
X
X
X
Emissions
Inventory
X
X
X
X
Policies
X
X
X
X
X
X
X
Guidance
Documents/
Fact Sheets
X
X
X
X
X
X
P2 Info
X
X
X
X
X
X
X
Multimedia
X
X
X
X
X
X
X
X
List of
Publications
X
X
X
X
X
CAP
Info
X
X
X
X
X
Calendar
of Events
X
X
X
X
X
X
X
Links
X
X
X
X
X
X
X
X
X
X
Other*
X
X
•Notes & Other
Maricopa County, AZ Pollution advisories, education, workshops/public hearings, enforcement, other Department programs.
South Coast, CA Business assistance, compliance education classes, clean air technologies.
FL
IL
IN
IA
KS
KY
MA
Ml
MN
Regulations, permitting information, permit forms, and emissions inventory are available on the Division page, not on the SBAP page. Guidance documents are found on the Division page; fact sheets on the
SBAP page. P2 information and multimedia information are available on the FDEP page. Other -- some on-line or downloading documents.
News and announcements, bulletin.
Regulations, permitting information, permit forms, policies, and calendar of events on IDEM & Office of Air Management sites. Emissions inventory on Office of Air Management site. Other - IN 5-Star
Environmental Recognition Program for Dry Cleaners and Vehicle Maintenance Shops (application and information).
Other - What's New?
Vendor lists, copies of newsletter, electronic downloading of documents, on-line order forms for printed documents, electronic question submission.
Other - Small Business Air Quality Stewardship Award information.
Other - Case studies. Regulations, permitting information, permit forms, and policies provided via links.
Other - Training opportunities.
Other - Environmental Improvement Loan Program.
N/A Not applicable N/R No response
-------
TABLE E-8
(Continued)
NH Planned. Web site not yet completed.
NY Information found on SBAP web site. Other - back issues of newsletter, detailed compliance information by industry type (to be on web site by Spring 1999).
OH Other - mailbox for questions.
SD Other -- training.
WA Other - newsletters.
N/A Not applicable N/R No response 8
-------
TABLE E-9
CLEAN AIR ACT AND NON-AIR/MULTIMEDIA ASSISTANCE REQUESTS
BY TYPE OF ASSISTANCE REQUESTED
CAA = Clean Air Act Requests
M = Non-air/Multimedia Requests
State
AL
AK
A2
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
Compliance/
Regulatory
Information
CAA
15
91
62
100+
210
5700
524
410
M
170
10
256
25
490
200
0
41
Not tracked
25
12
20
0
Not tracked
200
12
114
15
8
20
Monitoring
CAA
3
0
0
10
0
700
582
11
0
10
0
2
50
M
0
0
20
0
0
75
0
0
0
0
0
0
0
Recordkeeping
CAA
0
0
5
15
0
1700
0*
130
0
8
30
0
0
M
64
0
0
0
0
50
0
18
0
0
0
0
0
Financial/
Funding
Information
CAA
1
0
0
6
70
75
42
13
0
0
12
0
0
M
12
0
26
15
163
25
0
4
0
0
0
0
0
Permitting
CAA
25
148
25
600+
84
950
588
340
50
10
57
5
803
M
149
0
115
0
196
75
0
11
15
0
2
5
0
General CAA
Information
CAA
5
39
38
3
0
250
30
26
20
4
220
10
0
M
0
0
248
0
0
25
0
0
0
0
0
0
0
Add to
Mailing List
CAA
0
0
0
5
0
75
0
0
0
8
25
619
0
M
0
0
0
0
0
25
0
0
0
0
0
0
0
P2
Assistance
CAA
2
0
4
25
82
650
0
0
0
0
5
2
0
M
30
5
22
10
261
50
0
2
0
0
1
0
2
Other
CAA
0
115
91
0
0
200
599
31
0
0
105
0
0
M
0
0
365
50
0
75
0
0
0
0
0
0
0
Total
Requests
CAA
51
393
225
764+
446
10300
2365
961
95
52
654
650
967
M
425
15
1052
100
1110
600
0
76
35
0
18
13
22
-------
TABLE E-9
(Continued)
State
IL
IN
IA
KS
KY
JeffCty.
LA
ME
MD
MA
Ml*
MN
MS
MO
MT
NE
NV
NH
NJ
Compliance/
Regulatory
Information
CAA
218
M
0
Not tracked
120
84
600
72
N/A
0
18
100+
285
213
30
772
75
30
0
77
300
0
0
0
200+
0
78
0
1039
50
14
Not tracked
X
X
Not tracked
Monitoring
CAA
41
0
1
100
0
0
0
0
0
0
15
0
0
0
M
0
0
0
25
0
0
0
0
0
0
0
9
0
0
Recordkeeplng
CAA
29
0
0
300
35
0
0
0
0
10
15
2
12
8
X
M
0
0
2
50
0
0
0
0
0
0
0
266
7
4
X
Financial/
Funding
Information
CAA
90
100
0
50
0
0
0
0
0
21
15
3
15
0
M
0
0
10
10
0
0
0
0
0
21
0
85
85
2
Permitting
CAA
155
0
3
400
168
0
200
0
236
692
210
1131
25
6
X
M
0
0
2
25
0
0
24
0
0
62
0
61
0
2
X
General CAA
Information
CAA
79
20
107
650
0
34
12
0
837
140
300
804
10
130
X
M
0
0
137
0
0
0
0
0
0
47
0
0
0
0
Add to
Mailing List
CAA
46
0
8
100
0
0
0
0
0
5
5
0
0
8
X
M
0
0
25
0
0
0
0
0
0
0
0
0
0
2
X
P2
Assistance
CAA
160
0
17
75
0
0
0
200+
0
42
10
0
25
4
X
M
0
0
20
10
0
0
0
400+
0
0
0
295
30
4
X
Other
CAA
0
800
22
100
0
0
0
0
0
99
5
55
15
0
X
M
0
300
38
0
0
146
0
0
0
0
0
2452
20
38
X
Total
Requests
CAA
818
1040
242
2375
275
34
230
300+
1400
1222
605
2767
177
186
M
0
300
285
420
0
146
24
600+
90
208
0
4207
192
56
Not tracked
935 for both
-------
TABLE E-9
(Continued)
State
NM
NY
NC*
ND
OH*
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT*
VA
VI
Compliance/
Regulatory
Information
CAA
38
919
1220
20%
264
81
X
24
32
X
94
0
109
0
248
5
M
0
0
1730
0
133
4
X
17
174
X
4
1681
10
104
21
0
Monitoring
CAA
15
0
0
2%
0
1
X
0
0
X
0
0
5
0
2
0
M
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Recordkeeplng
CAA
0
0
X
2%
3
1
X
0
0
X
0
0
20
0
1
5
M
0
0
0
0
0
0
0
0
0
0
0
18
1
0
Financial/
Funding
Information
CAA
0
202
0
2%/
40%
0
8
X
0
0
11
0
0
0
11
2
M
0
0
0
0
0
0
X
0
0 -
0
30
5
2
9
0
Permitting
CAA
32
365
X
60%
480
5
X
14
12
X
7
0
100
0
87
50
M
0
0
X
0
0
0
X
8
121
0
0
5
11
0
0
General CAA
Information
CAA
4
23
0
1%
2
4
X
0
11
X
0
0
60
0
40
75
M
0
0
0
0
0
0
0
72
0
0
10
0
3
0
Add to
Mailing List
CAA
0
74
0
2%
2
3
X
8
0
15
0
10
0
5
250
M
0
0
0
0
0
0
2
0
0
0
0
0
1
0
P2
Assistance
CAA
0
260
X
1%
0
31
X
0
20
12
0
10
0
3
2
M
3
0
X
0
0
0
X
0
39
7
0
0
30
14
0
Other
CAA
0
133
0
0
0
0
10
17
0
0
0
0
217
0
M
0
50
0
10%
0
0
12
121
0
298
0
0
32
0
Total
Requests
CAA
89
1976
1220+
100
100%
751
134
828
56
92
150
139
0
314
0
614
389
M
3
50
1730
+
400
133
4
175
39
527
250
11
2009
25
165
81
0
-------
TABLE E-9
(Continued)
State
WA
WV
Wl
WY
Total
Grand
Total
Compliance/
Regulatory
Information
CAA
559
55
302
155
14197
M
0
16
0
368
7275
21742
Monitoring
CAA
0
6
4
12
1570
M
0
0
0
8
137
1707
Recordkeeplng
CAA
0
6
19
22
2376
M
0
0
0
37
397
2773
Financial/
Funding
Information
CAA
0
10
22
4
702
M
0
50
3
16
573
1275
Permitting
CAA
0
36
102
16
8217
M
0
12
0
10
911
9128
General CAA
Information
CAA
0
0
226
45
4258
M
0
0
0
0
542
4800
Add to
Mailing List
CAA
0
0
17
20
1308
M
0
0
0
24
79
1387
P2
Assistance
CAA
0
0
2
20
1663
M
0
0
0
18
1253
2916
Other
CAA
0
0
50
16
2680
M
0
0
6
24
4027
6707
Total
Requests
CAA
559
113
744
310
39107
M
0
78
9
495
17113
56220
Notes:
South Coast
Ml
NC
OH
Figures for Recordkeeping included in Compliance/Regulatory.
Breakout categories reflect customer assistance provided by SBAP only, while totals reflect activity by both SBO and SBAP.
Compliance/Regulatory figures are an estimate of percentages by hotline, on-site, and some workshop. Recordkeeping requests come in frequently; no estimate of
figures. Permitting questions occur in 90% of site visits, and about 70% of hotline calls are permit related. For P2 assistance, we work jointly with P2 for training
and newsletter; training and newsletters are multimedia.
Individual requests are not separated into these categories, so no exact data are available. However, the total requests can be separated into approximate
percentages by type based on practical experience and judgement. SBO estimates the issue of financing comes up in 40% of its calls. This is directly related to
SBO's function to provide financing assistance.
VT
Air included in multimedia requests.
-------
TABLE E-10
MAJOR CAP ACTIVITIES
State
AL
AK
AZ
Maricopa
Cty
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
Review of
documents
for
readability
and/or
content
N/R
X
N/A
N/A
N/R
X
X
X
X
N/R
N/R
N/R
X
X
Appointment/
hiring of
staff/ election
of officers
X
X
X
X
X
Review of
SBO/SBAP
outreach
efforts
X
X
X
X
X
X
X
X
X
X
X
Review/
comment on
proposed/
new
regulations
X
X
X
X
X
X
X
Review/
comment on
state legislative
actions
X
X
X
X
Definition of
CAP
responsibilities
X
X
X
X
X
X
X
X
X
X
Attendance by
CAP members
at training
sessions, etc.
X
X
X
X
X
X
Meeting with
small
businesses/
asstnaSffons
X
X
X
Other*
X
X
N/A Not applicable N/O Not operational N/R No response
-------
TABLE E-10
(Continued)
State
Jeff. Cty
LA
ME
MO
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
Review of
documents
for
readability
and/or
content
N/R
X
X
N/R
N/A
N/A*
N/A*
X
X
X
X
X
X
X
N/A
X
X
X
X
Appointment/
hiring of
staff/ election
of officers
X
X
X
X
X
Review of
SBO/SBAP
outreach
efforts
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review/
comment on
proposed/
new
regulations
X
X
X
X
X
X
X
X
X
Review/
comment on
state legislative
actions
X
X
X
X
X
X
X
X
Definition of
CAP
responsibilities
X
X
X
X
X
X
X
X
X
X
X
Attendance by
CAP members
at training
sessions, etc.
X
X
X
X
X
Meeting with
small
businesses/
asstTdfteons
X
X
X
X
X
X
X
X
X
Other*
N/A Not applicable N/0 Not operational N/R No response
-------
TABLE E-10
(Continued)
State
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
Review of
documents
for
readability
and/or
content
X
N/O
N/O
X
X
X
X
N/O
X
X
X
Appointment/
hiring of
staff/ election
of officers
X
X
X
X
X
Review of
SBO/SBAP
outreach
efforts
X
X
X
X
X
X
X
X
X
Review/
comment on
proposed/
new
regulations
X
X
X
X
X
Review/
comment on
state legislative
actions
X
x
X
X
X
Definition of
CAP
responsibilities
X
X
X
X
X
Attendance by
CAP members
at training
sessions, etc.
X
X*
X
X
X
X
X
Meeting with
small
businesses/
asstfolftaons
X
X
X
X
Other*
X
X
X
X
X
N/A Not applicable N/O Not operational N/R No response
-------
TABLE E-10
(Continued)
'Notes and Other:
FL Other - Annual state CAP meeting.
KY Other - Awarding first Small Business Air Quality Stewardship Awards.
Ml Michigan's CAP did not meet in 1998.
MN The CAP currently is dormant pending re-assignment by a newly elected administration.
PA Other - For the first time, a meeting was coordinated with a site visit.
PR state representative only assigned member. Other - State representative, CAP member helped outline SBAP program.
SD CAP did not meet in 1998.
UT Other - Lieutenant Governor's Small Business Advisory Council.
WY Other - Promoted Voluntary Disclosure Rule/Confidentiality Policy.
-------
TABLE E-11
FINANCIAL ASSISTANCE PROGRAMS TO HELP SMALL BUSINESSES
COMPLY WITH CAA REQUIREMENTS
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
DATE AVAILABLE
None
None
None
None
1998
1972
1995
1991
None
1994
None
None
None*
None
None
None
None
None
None
None
NAME OF GRANT/LOAN
Small Business Revolving Loan Program
CA Pollution Control Financing Authority
Innovative Clean Air Technologies
Air Quality Assistance Fund (loan)*
Financial Assistance for Vapor Recovery (loan)
X
FUNDING LEVEL
$2 million
$6.8 billion in bond sales, with projects
ranging from $10,000 to $500,000.
$1 million/year
No new guarantys in 1998.
$1 million revolving
-------
TABLE E-11
(Continued)
PROGRAM
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey*
New Mexico
New York
North Carolina
DATE AVAILABLE
None
N/R
None
None
To be determined
None
None
7/97
None
None
10/98
None
None
None
None
None
9/97
11/96
9/99
None
NAME OF GRANT/LOAN
To be determined (loan)
Small Business Environmental Improvement Loan
Program
Small Business and Tribal Energy and Environmental
Loan Program
Empire State Development Linked Deposit Program
(interest buy-down loan)
Environmental Bond Act (grant)
Environmental Protection Agency Pollution Prevention
Incentives for States (grant)
FUNDING LEVEL
To be determined
$750,000 revolving
$660,000
N/R
$30 million
$285,000
-------
TABLE E-11
(Continued)
PROGRAM
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
Wvnminn
DATE AVAILABLE
None
7/97
1/95
None
None
2/99
None
None
N/R
Planned
None
None
10/95
None
7/1/99
None
None
Mid 98
None
Nonp
NAME OF GRANT/LOAN
Small Business Assistance Fund (grant)
Ohio Air Quality Development Authority Assisted
Financing (loan)
Pollution Prevention/Energy Efficiency (loan)
V
Partnership for Compliance (grant)
Small Business Environmental Compliance
Assistance Fund (loan)
WV Small Business Environmental Loan
FUNDING LEVEL
$180,000
Market demand
$2,000,000
$180,000
$625,000 initially
$450,000 general + $500,000 UST
-------
TABLE E-11
(Continued)
'Notes:
South Coast, CA
The District recently released an RFP seeking a financial assistance consultant or organization to redesign its management of
the Air Quality Assistance Fund, a loan guaranty program. The contract will be awarded on or about March 19,1999.
FL Proposed legislation last session, but it did not pass.
NJ Inventory of existing funding opportunities planned for 1999.
-------
TABLE E-12
COOPERATIVE EFFORTS
Descriptions of how each component of the SBTCP has developed cooperative efforts among existing personnel resources are
provided in Table E-11.
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
Organizationally allied with P2 program unit and
Section 319 Nonpoint Source unit to allow sharing
of resources and personnel.
Works with the Department of Commerce, SBDC,
MEP, and University to reach more small
businesses. Participates in regional and national
P2 Roundtables. Participates in Governor's
Council on Small Business Assistance Programs to
eliminate possible duplication of efforts and to
have better coordination and referrals between
agencies.
Information referral network with Small Business
Association, AZ Department of Commerce, and
various small business industry trade associations.
Also work with Maricopa County SBEAP and
ADEQ internal program staff to help reach their
target audience.
N/R
Applied research on composting as a remediation
method with School of Engineering, University of
AR and AR Science and Technology Authority.
SBAP
N/R
Works with the Air Program to ensure that efforts
are not duplicated. Works with local businesses to
review information that affects them. Works with
local associations and other agencies, such as
Department of Community and Regional Affairs,
Division of Energy, and the Alaska village Electric
Co-op.
Same as SBO.
Working with Community colleges related to dust
control courses - we had several classes in 1998.
Also meeting with Arizona State University to
discuss construction/dust issues and how to work
together. Planning a coatings/solvents workshop in
partnership with the community colleges and the AZ
Department of Environmental Quality (tentatively
Spring or Summer 1999).
The AZ Strategic Alliance is a government and
industry partnership founded to promote
environmental leadership. The Green Building
Group is a subcommittee of AZ Strategic Alliance.
This committee focuses on environmental issues
(waste, recycling, energy) related to construction.
Small Business Providers is a group made up of
various organizations dedicated to assisting small
businesses. Members represent SBA, associations,
chambers, and ADEQ.
Engineering services through the AR Center for
Technology Transfer, University of AR at
FayettevilTe, and the AR Science and Technology
Authoritv.
CAP
N/R
SBO/SBAP uses the CAP to review fact
sheets, newsletters, and other Departmental
information. CAP members are from all parts
of the state. Their names and contact
information has been distributed in different
ways to allow businesses and concerned
citizens to contact CAP members directly
regarding Department activities.
N/R
N/R
N/R
N/A Not applicable N/R No response
-------
TABLEE-12
(Continued)
STATE OR
TERRITORY
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
Outreach efforts are coordinated with other public
agencies, trade associations, chambers of
commerce, local government agencies, etc.
Outreach Ideas and materials are shared with other
SBAPs, AWMA, and statewide CA Air Pollution
Control Officer's Association.
SCAQMD staff is assigned to assist one day per
week at Cal/EPA permit assistance centers.
Outreach efforts are coordinated with other public
agencies, trade associations, chambers of
commerce, local government representatives, and
agency staff. Outreach ideas and materials are
shared with other SBAPs, AWMA, and statewide
CA Air Pollution Control Officer's Association.
Public Advisor participates with other states in
activities coordinated through US EPA's SBO.
Works with the CO Revolving Loan Program so
that SBO has a small business loan resource.
Work with SBA and its various loan resources for
the same reason. Meets periodically with the local
county environmental agencies and Chamber of
Commerce groups. Partnering with the SBDCs to
deliver compliance workshops. Referral
exchanges with the OSHA consultation service.
Partnering with our Environmental Customer
Assistance Center to address multimedia
environmental compliance.
SBAP
A number of local districts assist one day per week
at Cal/EPA permit assistance centers. District staff
provide counter-top displays in city and local
government, business assistance, and permit
services areas to refer customers to the districts.
Districts larger than 250,000 people assign a single
point of contact to assist businesses.
SCAQMD staff is assigned to assist one day per
week at Cal/EPA permit assistance centers. AQMD
provides counter-top displays in city and local
government, business assistance, and permit
service areas to refer customers to AWMD's toll free
line.
Periodically meets with the local county
environmental agencies regarding compliance
assistance outreach. Works closely with industry
trade associations to provide better compliance
assistance. Works with EPA Region 8 to create and
distribute outreach materials for small business.
CT's SBO and SBAP are merged and collectively the program leverages technical staff from within the
Department to provide compliance assistance. The SBO position is designated out of the Office of the
Commissioner to enhance the multimedia capabilities of the SBAP. Additional resources are leveraged
through partnerships with trade associations, quasi-public agencies, other state agencies, public utilities,
local chambers of commerce, and programs established at CT universities. The SBAP has established
effective partnerships with trade associations and vendors representing the auto body industry, the metal
finishing industry, and the gasoline industry.
Attempts to partner with anyone who can be of
assistance at the state or federal level.
N/R
SBO has a dual role as SBAP.
To reach more businesses, the inspectors distribute
brochures when they go out on inspection. The
SBAP name and number are stamped so that if they
have any questions after the inspection, they can
call for confidential advice.
CAP
Under construction.
The Local Government & Small Business
Committee involved the State Air Resources
Board (CARB) and US EPA Ombudsman in
decisions such as compliance assistance,
SBREFA, and BACT/LAER issues.
Meets with SBAP quarterly and also
participates on quarterly conference calls.
Attends national CAP training with CAP
members at large.
CT's CAP consists of ten members. Other
interested individuals attend meetings
regularly and serve as non-voting members.
The CAP has helped to establish relationships
with the small business community and has
helped to publicize the availability of the
N/R
N/R
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBAP
In FL, SBO/SBAP functions are combined. We have partnered with our permitting staff, district staff, and
local program staff to enhance from within the agency. We have partnered with the Small Business
Development Centers and the FL Manufacturing Technology Centers to enhance assistance and
availability.
SBO has a gentleman's agreement with the
Hazardous Waste Program on providing
multimedia technical assistance to dry cleaners.
Small Business and Trade Association Advocacy
Focus Groups, dry cleaning technical assistance
workshops.
Working with the different regulatory divisions
(including air and hazardous waste) within the
agency has produced a high level of cooperation.
Also, have worked with the small business
administration and small business development
centers, particularly TECHelp. Monthly meetings
with air staff, who represent the SBAP portion of
the program.
SBO has access to 1 ,200 employees of the IEPA
for their expertise.
N/R
Working with and submitting newsletter articles to
associations of targeted industries, IA Department
of Natural Resources, Center for Industrial
Research and Services, and IA Manufacturing
Technology Center.
N/R
Dry cleaning technical assistance workshops, ad
hoc Clean Air Branch rulemaking advisory
committee.
Monthly meetings with the SBO.
Being a part of the IL Small Business Development
Center Network, we have access to small
businesses through 53 centers across the state. In
addition, we have established working relationships
with mariy business groups including NFIB, Printing
Industry of IL, State Fabncare Association, State
Chamber of Commerce, Manufacturers Association,
Automotive Wholesalers, and local economic
development organizations. We work very closely
with the Waste Management Research Center,
IEPA Bureau of Air and Office of Pollution
Prevention.
SBAP maintains regular contact with other offices
within IDEM. SBAP borrows information from and
shares information with other states' SBAP
programs.
IAEAP uses part time and full time student
assistants and interns from the University of
Northern Iowa to help with client assistance and
other program activities. As needed, staff from
IWRC (in addition to the 5.0 FTE for IAEAP) are
used from time to time.
CAP
We have partnered with specific trade
associations to enhance relationships with
specific industries (e.g., as part of a six
member partnership, we developed materials
for a series of statewide workshops for the
printing industry).
N/R
N/A
N/R
N/R
SBAP submits annual confidentiality reports to
the CAP. SBAP provides CAP with regular
updates as to our initiatives, including
providing the CAP with a copy of this SBTCP
report. CAP provides Quarterly guidance as to
areas on which the SBAP should focus.
N/R
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
Kansas
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBO has organized a group of state/federal agency
staff who work with businesses to facilitate better
referrals and understanding of available services.
SBO works extensively with regulatory bureaus
and university technical assistance programs.
Air Quality Representative for Small Business
(AQRSB) writes a column for distribution 6 times
per year and responds to requests for technical
assistance. Division for Air Quality (DAQ) has
designated several people to assist AQRSB in
completing requests and drafting columns for state
newsletters. AQRSB worked with KBEAP, DAQ,
and other state business associations to promote
and present 1 12(r) seminars across the state in
November 1998.
N/R
N/A
SBO works closely with SBTAP and other business
providers, such as the ME Department of
Economic and Community Development, ME
Chamber and Business Alliance, ME Small
Business Development Centers, Manufacturing
Extension Partnership, ME Metal Products
Association, ME Wood Products Association, and
other business groups to maximize Its
effectiveness.
N/R
SBAP
Technical assistance program works with MAMTC,
PETE, and other P2/technical assistance programs
to facilitate coordination and cooperation. SBAP is
working with local county department programs,
such as the P2 Alliance in Wichita, KS.
Joint outreach efforts with KY Pollution Prevention
Center, KY Small Business Development Centers,
and the Division for Air Quality. Joint visits /P2,
economic development, and other assistance
providers.
N/R
SCORE, Air Toxics Permit Section.Vade
associations, technical program support.
SBTAP works with staff from the Department's
Office of Innovation and Assistance and other
bureaus to assist in some function of the program.
The SBTAP also works with the SBO and other
business service providers such as the ME
Department of Economic and Community
Development, ME Chamber and Business Alliance,
ME Small Business Development Centers,
Manufacturing Extension Partnership. ME Metal
Products Association, ME Wood Products
Association, and other business groups to maximize
its effectiveness.
SBAP works with the other administrations to reach
small businesses. ARMA has two engineers who
provide permitting services to small businesses.
SBAP works closely with the P2 program on
outreach activities. Input from other administrations
is used to determine sectors to taraet for assistance.
CAP
CAP works with the SBO and SBAP through
meetings and telephone contacts.
CAP members have assisted the AQRSB and
KBEAP in working with organizations that the
members represent. A legislative member
created a team that included a legislative
analyst, the AQRSB, and a Cabinet attorney to
draft legislation to add more small business
owners to the Panel. The economic
development representative scheduled a
presentation by the KBEAP to field office
representatives from the Panel member's
agency.
N/R
Trade associations, environmental leadership.
The CAP is a joint panel comprised of 16
members. Functions of SBTAP oversight
were merged with an existing panel charged
with overseeing the Toxics use Reduction
Program. >
N/R
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBAP
CAP
Massachusetts
N/R
OTA works with the enforcement agencies to ensure
that its compliance advice is accurate, to provide
general information about trends we see in the field,
to assist in incorporating P2 into enforcement, to
include regulatory updates in our public events, and
to coordinate outreach. OTA co-sponsors its events
with appropriate trade associations and
environmental agencies. For example, auto body
Crash Course was a joint project of a trade
association, individual shop owners, and four
agencies. The DPW project was conducted with
EPA. OTA has assisted in the formation of a
multiagency task force on Environmental, Health,
and Safety issues in schools. The enforcing
agencies refer violators to OTA. OTA and
Manufacturing Partnership refer to each other. OTA
and Central Mass Manufacturing Partnership have
formed a Business Environmental Network.
N/R
Michigan
SBO works closely with the company referrals
made by the staff of the Ml Jobs Commission, who
are assigned to make initial contacts with the
state's business and industry for purpose of
economic development expansion and retention.
SBAP has developed a pattern of working closely
and seeking consultation from not only the
regulatory air quality agency, but also other
multimedia divisions and units of the regulatory
agency, business and industry associations, SBAP
counterparts in EPA Region v, as well as 9ther state
agencies when developing and implementing its
outreach efforts (e.g., statewide workshops and fact
sheet/guidebook development).
Works closely with the SBO and SBAP.
Minnesota
SBO is an active member on the MN Ombudsman
Roundtable, a peer networking group consisting of
all MN State Ombudsman Offices. SBO also
coordinates with SBDCs and other financial
assistance providers to market the Small Business
Environmental Improvement Loan Program.
SBAP partners with the MN Technical Assistance
Program to promote P2 activities, the SBDCs to
coordinate environmental compliance service
delivery, the MN Emergency Response-Commission
to coordinate RMP and 112(r) technical assistance,
Worksafe MN to promote worker safety, and internal
agency groups to represent small business
concerns during agency activities including
rulemaking andpermitting.
CAP currently is dormant pending
reassignment by a newly elected
administration.
Mississippi
Cooperates with regulatory programs, P2, trade
associations, and public organizations.
Same as SBO.
Same as SBO.
Missouri
Greg Johnston was Just appointed as the new
ombudsman. SBAP has met with him to brief him
of his responsibilities and the SBAP program in
general. The SBAP supplies technical assistance,
as needed, to the SBO.
SBAP works closely with the CAP, supplying
information as required to the CAP. SBAP works
with the department's regulatory programs to obtain
expertise in specific areas when needed. SBAP
also partners with the Small Business Development
Centers and other assistance providers to reach
MO's businesses.
CAP is supported by the SBAP and is looking
at ways to assist businesses by hearing their
problems and making recommendations to the
regulatory agencies and by giving the SBAP
direction as to the best methods To assist
businesses.
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
Montana
Nebraska
Nevada
Washoe Co.
AQMP
Clark Co. AQP
New Hampshire
New Jersey
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBO/SBAP buy down interest rates offered by the
MT Department of Commerce's Microbusiness
Finance Program's loan program. SBO/SBAP
approves all prospective projects and provides
technical assistance to 13 loan officers around MT.
The SBO and SBAP person are the same person.
Cooperative effort is not an issue.
SBO utilizes BAQ and other agency files to obtain
information regarding issues that the ombudsman
is investigating. SBO interviews staff with
knowledge of a facility, as well as facility personnel,
to establish a complete picture of an issue to
determine solutions. SBO interfaces with various
business organizations by attending monthly
meetings and networking with business
professionals.
SBAP
SBO/SBAP work with the MT State University
Pollution Prevention Program on several
cooperative projects, including Peaks to Prairies P2
Information Center, ECOSTAR Environmental
Awards Program (with US Small Business
Administration), STAR Program (spray coating
technique training), and the Pollution Prevention
Partnership (with MT industries).
N/R
SBAP utilizes the expertise of NDEP staff in various
environmental programs for technical information.
SBAP works closely with the SBDC to provide
information and technical assistance to the business
community and to coordinate dissemination of
outreach materials and workshops. SBAP works
closely with the county air pollution control programs
for hands-on education of the various sources,
identification of industry needs, and outreach
activities. The NDEP Bureau of Air Quality provides
direct assistance to businesses regarding permitting
and compliance. Workshops are conducted as
changes in federal and state regulations warrant.
CAP
N/R
N/R
CAP utilizes the information SBO and SBAP
collect to determine needs within business
community and identify methods to support
and assist small businesses. CAP members
network with representatives from their
individual areas of business and bring
concerns before the SBO and SBAP. Issues
are identified and recommendations to the
agency are made.
Air Quality permitting and enforcement staff provide assistance for small business in completing permits, monitoring, and compliance. Staff work cooperatively
with the SBO regarding program development and mutual outreach activities. Staff work closely with local business development centers and often meet with
prospective NV businesses to identify environmental permits for the business should it locate within the county.
Air Quality program staff utilize direct mailings to affected businesses, Internet postings, workshops, public speaking, and various outreach materials such as
brochures and information packets. Permitting and enforcement personnel assist small businesses to comply with permitting, monitoring, and operation.
Assistance also is given for P2 when appropriate.
Administrative support from Air Resources
Division. Continue working relationship with other
advocates for energy, environmental, legislative,
and business issues.
Interagency agreement between NJ Commerce
and NJ DEP for administration of the SBO
responsibilities through NJ Commerce.
On-going relationship with DES Pollution Prevention
Program and other compliance assurance groups
within and outside the DES organization. Continue
to develop cooperative ventures with trade
associations, the university system, and other
technical assistance providers.
SBAP acts as staff to the CAP. SBAP coordinates
with Air Permit, Air Planning, and P2 within DEP.
Coordinates with the NJ Institute of Technology's
Technical Assistance Program for P2. SBAP and
SBO work with business and trade associations and
the Small Business Development Centers.
Administrative assistance from Air Resource
Division.
CAP met with seven trade associations as part
of their regular meetings. The trade
associations were invited to offer their
concerns with state and federal regulations
and areas in need of improvement;
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBAP
CAP
New Mexico
SBO provides advocacy and referral services upon
request by the SBAP, the CAP, or clients. These
services have included small and large group
meeting facilitation (regulated entities,
environmental groups, citizen groups, etc.), public
input and informational meetings, and interventions
on an individual level. Technical assistance, once
determined, then is provided by various programs
within the Environmental Department, including the
SBAP.
Other agencies, such as Economic Development,
Small Business Development Centers, Chambers of
Commerce, and local environmental field offices,
help with SBAP outreach. SBAP also networks with
other bureaus to develop multimedia environmental
management tools, workshops, and presentations
for the printing, automotive, and manufacturing
industries. An example of our networking is the P2
effort with the New Mexico Green Zia Program.
Legal assistance to the CAP is being provided
by the NM Assistant Attorney General s Office.
CAP member reviewed draft template of rock
crusher/asphalt regulations.
New York
SBEO routinely cosponsors workshops and
conferences with the SBAP, the DEC, and trade
associations. SBEO also routinely works with the
New York City Department of Environmental
Protection's Environmental Economic
Development Assistance Unit (EEDAU) (9 reach
out and assist businesses in New York City. In
1998, under a grant from the US EPA, the SBEO
partnered with the SBAP, EEDAU, the Empire
State Development Corporation, Environmental
Business Association, and the dry cleaning trade
associations to produce a P2 program aimed at
exploring the alternatives to perchloroethylene dry
cleaning equipment.
SBAP cosponsors technical workshops with other
providers of technical assistance, including local
agencies, trade groups and associations, and DEC'S
Pollution Prevention Unit to leverage outreach to
industry sectors and to avoid duplication of effort. In
addition, the SBAP utilizes DEC s technical staff to
review technical fact sheets and artic'es for the
SBAP's technical newsletter. SBAP also regularly
invites equipment vendors and representatives from
companies that develop technologies to provide in-
house technical workshops for staff. SBAP always
invites DEC'S technical staff and other
representatives of state agencies to these
workshops so they might share the learning
experience.
N/R
North Carolina
NC Air Quality Division and the Division of
Pollution Prevention and Environmental Assistance
(DPPEA) have provided technical support and
helped jointly to develop workshops for specific
business sectors. The air, water, and hazardous
waste regulatory programs and DPPEA have
assigned a senior permit writer to the
Ombudsman's Office to staff the Environmental
Permit Center, a multimedia permit center.
The Ombudsman also is a participant on the
Governor's Small Business Council. This involves
Cabinet level participation from most state
agencies and includes small business
representatives. The Council is chaired by the Lt.
Governor and staffed by the Small Business
Technology and Development Center. The Council
recently won a national award for its efforts to
communicate to small businesses.
N/R
N/R
North Dakota
The ombudsman makes referrals to the SBDCs in
the state, and they reciprocate.
SBAP works with trade associations, other state
agencies, and pther organizations to get information
to affected businesses.
N/R
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
GHTATC rtD
oTATc OR
TERRITORY
Ohio
Okfahoma
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
The SBO, located in a nonregulatory agency,
works closely with the SBAP and "piggybacks" on
its efforts, including those described under SBAP.
SBO has reached out to various trade associations
including the Printing Industry of OH, the
Automotive Services Association of OH, the state's
330 local Chambers of Commerce, the OH Bakers
Association, the OH Bar Association, and the OH
Bankers Association. During 1998, we contacted
each of OH's SBDCs and have met with many of
them.
Work together to represent small business issues,
particularly with respect to rulemaking and rule
reform within the agency among the regulatory
divisions.
SBAP
SBAP is located in the OEPA Division of Air
Pollution Control headquarters, allowing direct
access to permitting, inspection, enforcement, and
policy development questions. This has helped to
resolve many site-specific permitting issues. To stay
informed, the SBAP also has joinedseveral
workgroups within the Air Pollution Division, which
develop Agency permitting policies and coordinate
NESHAP, 1 12(r). and non-Title V fee system
outreach and enforcement activities.
SBAP has used OEPA's Public Interest Center to
promote the SBAP through agency newsletters and
to develop fact sheet layout and graphics.
SBAP uses five district offices and nine local air
agencies to help distribute SBAP literature and to
refer companies to the SBAP. SBAP also has direct
e-mail access to district office staff through a LAN
network. SBAP has invested much time and effort
building positive relationships with the district offices
and has noticed an increase in the number of
companies they refer to the SBAP, many after
routine inspections or complaint investigations.
SBAP has established mutual referrals with the
OSHA on-site consultation programs offered
through the OH Bureau of Employment Services
and the OH Bureau of Workers Compensation to
help businesses bridge the gap between OSHA and
EPA concerns.
OEPA has established a pilot program for
multimedia small business assistance, which covers
the 10-county Central OH District and is funded
through a special appropriations bill. SBAP has
coordinated several multimedia site visits with this
program and regularly refers non-air questions to
them. They, in Turn, refer air questions to us. This
program also has developed a newsletter to which
the SBAP is a regular contributor for air articles (4
during 1998). They have formed an advisory group
modeled after the CAP and regularly attend CAP
meetings. This initial two-year program received
additional funding to operate in 1999, but future
funding is uncertain at this time.
SBAP is the lead group providing assistance to and
representing the small businesses in OK. They work
closely with the other components listed here.
CAP
N/R
CAP has become quite active in evaluating
new and existing state air rules and their
impact on small "businesses in OK. They work
closelv with the SBAP staff to accomolisn this.
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
N/R
SBO draws upon the expertise and assistance of
all PA DEP's regional and central office staff.
Commercial Development Administration Regional
Managers were instructed on the S8TCP basics for
referral to SBAP.
SBO is funded entirely from state revenues not
associated with CAA.
SBO provides multimedia assistance using
resources in other program areas. Program is
involved in Environmental Network Partnership,
which includes representatives from other
providers, such as SBDCs, Center for Waste
Minimization, Center for Environmental Policy at
the University of SC, MEP-sponsored programs,
etc. Also involved in a new Environmental, Health
& Safety Association that includes OSHA
representatives.
SBO is multimedia and works with all programs
within the deoartment.
SBAP
BAP brochures were mailed to all chambers of
commerce, economic development departments,
planning departments, and many trade associations
in OR. Calls have been received from people
receiving these brochures, and speaking
engagements were arranged.
Joint projects with the OR Economic Development
Department have been fairly successful.
BAP has been working with the DEQ's Divisions of
Hazardous and Solid Waste, Water Quality, and
Pollution Prevention Team.
BAP also is working with the Portland Pollution
Prevention Outreach Team, consisting of local
environmental regulatory agencies. This team is
working on a green stick project for the automotive
industry.
SBAP has received cooperation from trade
associations and district libraries in delivering its
services. SBAP is a member if the PA
Environmental Assistance Network, which allows it
to draw on the expertise of all of the consortium
members.
Inside the state environmental regulatory agency,
referrals are made to SBTAP to assist businesses
on environmental requirements.
SBAP (2 FTEs) integrated into Department's existing
P2 program housed in the Office of Technical &
Customer Assistance. 0.5 FTE (University of Rl
research associate) providing technical support to
FTEs.
Program has regular access to technical staff in
Bureau of Air Quality to assist on permitting issues.
Air Quality also provides computer dispersion
modeling at no charge to eligible small businesses.
There is good cooperation between programs.
CAP
CAP worked with the SBDCs at the community
colleges to sponsor generic P2 workshops.
This effort was not successful, and the CAP is
continuing to work with the SBDCs to improve
this outreach.
PA DEP provides administrative support to the
CAP, whose meetings are held at the
department's central office building.
N/R
N/A
SBO serves as secretariat to CAP.
N/R
N/A Not applicable N/R No response
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBAP
CAP
Tennessee
SBO has access to other needed departmental
resources to assist SBAP function when deeded
necessary.
Reorganization of program allows access to county
and municipal technical assistance agencies, a
training facility, and inclusion of program information
in educational material dissemination.
Partnerships have been developed with the state
energy office, TVA, and SBDCs.
P2
Not opera ting.
Partnership that could assist in reducing th
regulatory burden for small businesses.
Texas
Small Business Advisory Committees (5 committees with 96 members) serve as a link between the SBAP
and the small businesses in their area.
The EnviroMentor Program provides free on-site environmental compliance assistance to small businesses.
Work with trade associations to sponsor workshops and distribute literature to small businesses.
Work with TX Manufacturing Assistance Centers to deliver on-site assistance to small businesses and to
ensure that whatever service provider a small business contacts, they get the appropriate help. Developed
directory of service providers to small business.
Work with SBDCs to develop videos, sponsor workshops, and conduct on-site visits for small businesses.
Diverse membership from around the state,
includjng contacts with several primary trade
associations.
Utah
SBO and SBAP meet about every other week.
They send e-mail with questions and have
developed a cooperative working relationship.
SBO and SBAP meet with the Small Business
Work Group to coordinate multimedia in the
Department.
SBAP works with the Department's P2 Program.
SBAP refers companies to Water Quality and
Solid/Hazardous Waste.
SBO/SBAP and CAP meet about every other
month. Information is faxed and.e-mailed as
necessary.
Vermont
N/A
Partnering with Central VT Solid Waste District.
Working with VT Environmental Assistance
Partnership, which includes VT Smal] Business
Development Center, VT Manufacturing Extension
Center, VT Economic Development Center, and
SBAP. Sitting on 9ur Department's internal
Inspection, Compliance and Enforcement Team to
help incorporate SBAP into regulatory programs.
Referrals of business with problems made by our
regulatory programs. Working with EPA on
initiatives.
Attending all meetings. Discussing up-coming
projects and getting feedback, etc.
N/A Not applicable N/R No response
10
-------
TABLE E-12
(Continued)
STATE OR
TERRITORY
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
Utilization of national air program contacts, where
appropriate.
SBAP
On behalf of the SBO and the CAP, the SBAP
actively tries to utilize the contacts and credibility of
the following organizations: VA Small Business
Development Center Network, VA Manufacturing
Technology Center, the A.L. Philpott Manufacturing
Extension Partnership, and VA Chamber of
Commerce.
SBAP actively solicits input and partnerships with
individual trade organizations to assist in getting
information into the hands of their constituents.
Organizations include Mid-Atlantic Cleaners and
Launderers Association, Greater Washington
Korean Dry Cleaner Association, VA chapter of the
National Federation of Independent Businesses, VA
Propane Gas Association, VA Chamber of
Commerce, etc.
Dual role SBO/SBTAP.
N/R
SBO works closely with SBAP personnel to
evaluate technical aspects of small business
issues. DEP personnel outside the air office are
available for consultation. Resources outside the
agency are consulted on specialty projects,
generally at no cost or exchanged for in-kind
services.
Numerous public and private sector experts are
called upon as needed to provide assistance to the
SBO. Experts from the areas of development
finance, permit assistance, law, and environmental
compliance/safety have provided suggestions and
guidance.
Combined effort between Ecology and seven local
air quality authorities. Cooperative efforts among
various Ecology departments (i.e., media).
SBAP works with other air quality staff, when
necessary, to evaluate permit and Title V
applicability for small businesses. A significant
number of clients are referred to the SBAP through
agency enforcement activities. Other DEP staff,
especially P2 Services, are available to help
coordinate assistance to small businesses. SBAP
also is coordinating its efforts with other outside
assistance groups, including academic and SBDC
efforts. Trade organizations and OSHA contacts
provide additional assistance.
Periodically, DNR personnel provide technical
review of publications and partner is the
development of seminars and workshops. These
individuals review documents for completeness and
accuracy, help formulate outreach strategy, and
suggest work plans. SBAP members also provide
guidance to and receive guidance from P2 and Solid
& Hazardous Waste Education Center personnel on
outreach and publications. SBAP staff consult with
trade associations and other private and public
sector professionals as appropriate.
CAP
CAP has held one trade association
roundtable for issue identification and program
marketing and plans on conducting similar
events in the future.
Not yet named.
N/R
All members serve on a volunteer basis.
Personnel from SBAP coordinate meeting
locations, develop agenda topics and organize
the bi-monthly CAP meetings. Other
individuals from the Wl DNR, EPA Region V,
Wl Department of Commerce, and the
University if Wl Solid & Hazardous Waste
Education Center advise the CAP on an as
needed basis.
N/A Not applicable N/R No response
11
-------
TABLEE-12
(Continued)
STATE OR
TERRITORY
BRIEF DESCRIPTION OF COOPERATIVE EFFORTS
SBO
SBAP
CAP
Wyoming
Since the formation of the Outreach Office in July
1997, cooperation between the SBO and the
regulatory programs of our Department has
continued to evolve. Responses to inquiries and
coordination between the Office and regulatory
programs in the Air, Land, Water, Solid and
Hazardous Waste, Abandoned Mine Land
Reclamation, and Industrial Siting Divisions now
are solicited and published routinely in our
newsletter. Technical assistance Is provided
regularly by the regulatory staff in response to
questions generated during outreach visits.
Additional coordination also is occurring with our
counterparts in other states and on the national
level through established SBO/SBAP channels.
SBAP continued as the secretariat for the CAP,
providing administrative and logistical support. On
numerous occasions, the SBAP developed NSR
permit applications for signature by small
businesses and coordinated this activity with the Air
Quality Division. Working with other DEQ Divisions,
the SBAP coordinated the development of the
Office's environmental checklists for the medical
industry, wood manufacturers, and printers. Also,
the SBAP coordinated EPA's 112(r) training
activities through the WY Emergency Management
Agency and the SERC. SBAP provided MWI
presentations to the WY Hospital Association and
coordinated CAP issues with NFIB. As site
coordinator for the APDLN and other educational
broadcasts, the SBAP coordinates satellite training
sessions and workshops for regulatory personnel
and the public. As a member or the planning
committee and technical subcommittee for trie
National SBO/SBAP conference, the SBAP provides
moderators and speakers for the upcoming
concurrent sessions. SBAP provided input to
WESTAR, EPA, and other SBAPs regarding WY's
activities and issues.
Through its advisory capacity, the CAP
recommended to the Department the adoption
of its multimedia "Small Business Voluntary
Disclosure and Incentive Rule" and a
Confidentiality Policy for the office staff. CAP
ensured that its activities were forwarded to
the NFIB. Also, the CAP concurred with the
SBO/SBAP communications activities with
EPA, other SBAPs, trade associations, and
economic assistance organizations.
N/A Not applicable N/R No response
12
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TABLE E-13
SUMMARY: SBAP MECHANISMS FOR AVOIDING DUPLICATION AMONG SBTCPs
Program
AL
AK
AZ
Maricopa
Cty
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
Communication/
networking within
SBTCP & state
agency personnel
via phone, mailing
lists, etc.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Meetings,
conference calls
and other contacts
withSBAP/SBO
personnel within
EPA region
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Networking
through state/
regional air group
meetings such as
WESTAR (Western
States Air
Resources)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
EPA
documents/
contact with
EPA
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
documents from
other public,
private, or
university
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Information
gathering
from
electronic
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subscribe to
SBO or govt.
Ombudsman
listserve
X
X
X
X
X
X
X
X
Other*
X
X
X
X
X
X
N/A Not applicable N/R No response
-------
TABLE E-13
(Continued)
Program
KS
KY
Jeff. Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
Communication/
networking within
SBTCP & state
agency personnel
via phone, mailing
lists, etc.
X
X
N/R
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Meetings,
conference calls
and other contacts
with SBAP/SBO
personnel within
EPA region
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Networking
through state/
regional air group
meetings such as
WESTAR (Western
States Air
Resources)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
EPA
documents/
contact with
EPA
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
documents from
other public,
private, or
university
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Information
gathering
from
electronic
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subscribe to
SBO or govt.
Ombudsman
listserve
X
X
X
X
X
X
X
X
X
X
X
X
X
Other*
X
X
X
X
N/A Not applicable N/R No response
-------
TABLEE-13
(Continued)
Program
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
Communication/
networking within
SBTCP & state
agency personnel .
via phone, mailing
lists, etc.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Meetings,
conference calls
and other contacts
with SBAP/SBO
personnel within
EPA region
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Networking
through state/
regional air group
meetings such as
WESTAR (Western
States Air
Resources)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
EPA
documents/
contact with
EPA
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Review of
documents from
other public,
private, or
university
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Information
gathering
from
electronic
sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subscribe to
SBO or govt.
Ombudsman
listserve
X
X
X
X
X
Other*
X
X
X
N/A Not applicable N/R No response
-------
TABLE E-13
(Continued)
*0ther
AK Developing service delivery plan with AK SBDC.
South Coast, CA Subscribe to Printing Industry & Pollution Prevention listserve.
CT Participate in the development of a coordinated network of environmental assistance providers.
ID Subscribe to non-SBO Hstservers.
IL Greater Chicago P2 Project of state, county, city, and business groups.
IN Networking with specific industry or chemical groups, such as the Region V Mercury Workgroup.
KS Participation in National P2 Roundtable and the Region VII P2 Roundtable.
KY Serve as Team Leader of a national work group on performance measurements.
MN Attend regional and national conferences.
NC NC SBO is part of a Small Business Partnership Group, which includes SBDCs, universities, and other assistance providers. The purpose of this group
is to coordinate activities and avoid duplication.
ND Subscribe to several other states' newsletters.
Rl SBAP annual New England meeting.
VA Use of the SBO/SBAP National Steering Committee. P2 Roundtable.
N/A Not applicable N/R No response
-------
TABLE E-14
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE PAPERWORK REDUCTION ACT
Program
AL
AK
AZ
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
Routine review
of SBTCP
information
collection
activities
N/R
X
X
X
N/R
X
X
X
N/A
X
Routine
review of
SBTCP
documents
for
compliance
X
X
X
X
X
X
X
X
Receiving /
providing
information
electronically
X
X
X
X
X
X
X
X
X
X
X
X
Simplified /
consolidated
permits and/or
forms
X
X
X
X
X
X
X
X
X
X
X
Eliminating
unnecessary
permits by
increasing
exemptions
X
X
X
X
X
X
X
General
permits for
certain types
of industries
X
X
X
X
X
X
X
X
X
X
Other
(See below)
X
X
X
N/A Not applicable N/R No response
-------
TABLE E-14
(Continued)
Program
IA
KS
KY
Jefferson
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
Routine review
ofSBTCP
information
collection
activities
X
X
X
N/R
X
N/A
X
X
X
X
X
X
X
X
Routine
review of
SBTCP
documents
for
compliance
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Receiving /
providing
information
electronically
X
X
X
X
X
X
X
X
X
X
X
X
X
Simplified /
consolidated
permits and/or
forms
X
X
X
X*
X
X
X
X
X
X
Eliminating
unnecessary
permits by
increasing
exemptions
X
X
X
X
X
X
X
X
X
X
X
X
General
permits for
certain types
of industries
X
X
X
X
X
X
X
X
X
X
X
Other
(See below)
X
N/A Not applicable N/R No response
-------
TABLE E-14
(Continued)
Program
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
Routine review
ofSBTCP
information
collection
activities
X
X
X
X
N/R
X
X
X
X
X
X
X
X
Routine
review of
SBTCP
documents
for
compliance
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Receiving /
providing
information
electronically
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Simplified /
consolidated
permits and/or
forms
X
X
X
X
X
X
X
X
X
X
X
X
X
Eliminating
unnecessary
permits by
increasing
exemptions
X
X
X
X
X
X
X
X
X
General
permits for
certain types
of industries
X
X
X
X
X
X
X
X
X
X
X
X
Other
(See below)
X
N/A Not applicable N/R No response
-------
TABLE E-14
(Continued)
Program
wv
Wl
WY
Routine review
ofSBTCP
information
collection
activities
X
X
Routine
review of
SBTCP
documents
for
compliance
X
X
Receiving /
providing
information
electronically
X
X
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
Other
(See below)
"Other Actions and Notes:
DC Electronic filing of permits.
FL General permits for dry cleaners. Other - Review materials during annual state CAP meeting. Our CAP is, at present, somewhat
dysfunctional. We are trying to revitalize it.
MA Autobody Crash Course is a regulatory simplification and clarification. P2 worksheet for DEP's ERP program. Currently working on
clarification of rules for schools.
MN Continued efforts to reduce recordkeeping requirements.
TX Concise, easy to read summary documents.
N/A Not applicable N/R No response
-------
TABLE E-15
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE REGULATORY FLEXIBILITY ACT
Program
AL
AK
AZ
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
Ensure that small
businesses can
participate in
rulemaking
N/R
X
X
X
X
X
X
X
N/R
X
X
X
X
N/A
X
X
Periodic rule review for
impact on small
businesses
X
X
X
X
X
X
X
X
Routine review of
SBTCP documents for
compliance
X
X
X
X
X
X
X
X
X
X
X
Amnesty program
X
X
X
X
X
X
Other
(See below)
X
X
N/A Not applicable N/R No response
-------
TABLEE-15
(Continued)
Program
KY
JeffCty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND
Ensure that small
businesses can
participate in
rulemaking
X
N/R
X
X
N/R
X
N/A
X
X
X
X
X
X
X
X
X
X
X
Periodic rule review for
impact on small
businesses
X
X
X
X
X
X
X
X
X
X
X
Routine review of
SBTCP documents for
compliance
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Amnesty program
X
X
X
X
X
X
X
X*
X
X
Other
(See below)
X
X
N/A Not applicable N/R No response
-------
TABLEE-15
(Continued)
Program
OH
OK
OR
PA
PR
R!
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
Ensure that small
businesses can
participate in
rulemaking
X
X
X
N/R
X
X
X
X
X
X
X
X
X
X
Periodic rule review for
impact on small
businesses
X
X
X
X
X
X
X
X
X
X
Routine review of
SBTCP documents for
compliance
X
X
X
X
X
X
X
X
X
X
X
X
X
Amnesty program
X
X
X
X
X
X
X
Other
(See below)
X
X
X
X
-------
TABLEE-15
(Continued)
'Other Actions and Notes:
IN Advisory groups for specific industries.
KS Audit policy.
MO DNR has its own enforcement policy.
NH Federal amnesty program in place, state program in progress.
TN Department policy modeled after the national SBAP policy.
VT SBCAP itself -- only significant impacting violations are forwarded to regulatory programs for possible enforcement. None forwarded to date.
WY Self audit legislation.
-------
TABLEE-16
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE EQUAL ACCESS TO JUSTICE ACT
Program
AL
AK
AZ
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
Routine review of
SBTCP
documents for
compliance
N/R
X
N/R
X
X
N/R
N/R
X
X
X
X
N/A
X
Review instances
where state actions
against small
businesses appear
unjustified
X
X
X
X
X
X
Pro bono legal
services
Funding/technical
assistance for groups
aggrieved by
regulatory actions
X
X
X
X
X
Other
(See below)
X
N/A Not applicable N/R No response
-------
TABLE E-16
(Continued)
Program
!A
KS
KY
Jeff Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
Routine review of
SBTCP
documents for
compliance
X
X
N/R
X
X
N/R
N/R
N/A
X
X
X
X
X
X
X
N/R
N/R
Review instances
where state actions
against small
businesses appear
unjustified
X
x
X
X
X
X
X
X
Pro bono legal
services
Funding/technical
assistance for groups
aggrieved by
regulatory actions
X
X
X
X
X
X
Other
(See below)
N/A Not applicable N/R No response
-------
TABLE E-16
(Continued)
Program
NY
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
X
X
N/R
X
X
X
X
X
X
None
X
X
X
Review instances
where state actions
against small
businesses appear
unjustified
X
X
X
X
X
X
X
Pro bono legal
services
Funding/technical
assistance for groups
aggrieved by
regulatory actions
X
X
X
X
X
X
Other
(See below)
X
N/A Not applicable N/R No response
-------
TABLEE-16
(Continued)
Program
WV
Wl
J/VY
Routine review of
SBTCP
documents for
compliance
X
X
JsJ/R
Review instances
where state actions
against small
businesses appear
unjustified
X
Pro bono legal
services
Funding/technical
assistance for groups
aggrieved by
regulatory actions
X
Other
(See below)
X
"Other Actions and Notes:
ND The Department media programs, including the SBAP, are aware of what equal access to justice and environmental justice concerns are;
however, the Department is not aware of any problems in North Dakota.
Wl Provide information on the act to interested parties.
N/A Not applicable N/R No response
-------
APPENDIX F
PROGRAM EFFECTIVENESS
-------
TABLE F-1
SBTCP PROGRAM GOALS AND MEASUREMENT STRATEGIES
SBTCPs were asked to indicate up to 3 program goals, numbering them in terms of priority. These goals are ranked by the programs
in the following table.
Program
AL
AK
AZ
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
Increase
regulated
community's
understanding
of environmental
obligations
1
2
1
2
4
1
1
3
1
1
SBO1
2
Increase
regulated
community's
understanding
of permitting
2
3
3
3
2
SBO3
Increase
regulated
community's
understanding
ofCAA
4
2
3
Provide site-
specific
compliance
assistance
5
3
3
2
1
2
2
3
SBO2
SBAP1
1
Encourage
self -auditing
6
3
3
SBAP2
Improve
compliance
rates of
regulated
community
3
1
2
1
1
2
1
3
3
1
2
2
SBAP3
Other
(See below)
1&2
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
Program
IL
IN
IA
KS
KY
Jefferson
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
Increase
regulated
community's
understanding
of environmental
obligations
1
1
X
2
X
2
1
1
2
1
2
1
1
Increase
regulated
community's
understanding
of permitting
X
KBEAP 2
4
3
3
3
2
Increase
regulated
community's
understanding
ofCAA
2
X
3
AQR1
KBEAP 3
6
3
5
Provide site-
specific
compliance
assistance
2
X
KBEAP 1
X
3
2
2
2
2
2
3
Encourage
self-auditing
5
3
4
4
Improve
compliance
rates of
regulated
community
3
3
X
1
AQR3
X
1
2
3
1
1
2
1
1
6
6
Other
(See below)
AQR2
3
1
3
3
5
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
Program
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
Increase
regulated
community's
understanding
of environmental
obligations
1
1
1
2
1
1
1a
1
1
1
2
1
2
1
1
3
3
Increase
regulated
community's
understanding
of permitting
2
3
1b
3
6
2
2
4
Increase
regulated
community's
understanding
ofCAA
7
3
3
2
1
6
Provide site-
specific
compliance
assistance
3
2a
2
3
3
3
1
3
1
Encourage
self-auditing
3
3
5
5
Improve
compliance
rates of
regulated
community
2
3
1
2
2
3
4
2
1
3
2
2
Other
(See below)
2
2b
2
3
1
2
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
Program
VA
VI
WA
WV
Wl
WY
Increase
regulated
community's
understanding
of environmental
obligations
1
3
Ecology 1
OAPCA 1
NWAPA 3
SCAPCA 2
2
1
Increase
regulated
community's
understanding
of permitting
3
Ecology 2
OAPCA 2
3
3
2
Increase
regulated
community's
understanding
ofCAA
3
Provide site-
specific
compliance
assistance
2
Ecology 3
OAPCA 3
NWAPA 2
SCAPCA 3
2
Encourage
self -auditing
1
Improve
compliance
rates of
regulated
community
2
NWAPA 1
SCAPCA 1
1
1
Other
(See below)
*Other Actions and Notes:
CA #1 - Increase the regulated community's participation in development of permitting and C9mpliance programs.
#2 -- Increase the regulated community's satisfaction with air quality permitting and compliance programs.
KY Air Quality Representative #2 goal to increase participation of small business stationary sources in the development of the air program.
ME To encourage businesses to implement pollution prevention techniques and to help them save money.
MA To promote reduction in the use of toxic materials.
MN To move towards full multimedia assistance.
MT To provide financial/technical pollution prevention assistance.
NV To increase regulatory staff's understanding of small business concerns and needs.
NM To redirect efforts to make the permitting process easier for the regulated community.
OH To provide financing assistance to small businesses to help reduce the economic impact of compliance.
N/A Not applicable N/R No response 4
-------
TABLE F-1
(Continued)
OR To reduce environmental impacts by providing practical, cost-effective methods for small businesses.
PA To increase the use of pollution prevention and the adoption of strategic environmental management.
PR To get a full start on the SBAP by 1999.
Rl To create and provide plain English materials regarding state and federal regulations specific to industry sectors.
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
SBTCPs were asked how they plan to evaluate whether the above-stated goals are being met as well as the results of this
measurement process.
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
AL
Tracking phone calls on the hotline and making note of
the number of calls we receive as a result of recent
speaking engagements involving a regulated group.
We get a good feel for the most important issues facing the regulated community,
and we gel feedback on the effectiveness of our outreach efforts when regulated
individuals call soon after a speaking engagement. Repeat callers also are a good
indicator of the effectiveness of our efforts and trust from the regulated community.
AK
1. Client satisfaction - using feedback forms.
2. Output measures - technical assistance database
tracks numbers of calls, outreach, etc.
3. Compliance improvements - "to do" lists are provided
to clients at the end of site visits. Clients sign and return
form stating corrections have been made. Staff conduct
additional follow up visits at 10% of sites visited.
4. Overall impact - one-page outcome forms are sent to
clients receiving site visits at the end of the fiscal year.
We request additional information on compliance
improvements and other beneficial outcomes resulting
from the site visit.
5. Anecdotal case studies - testimonials or other
accounts of cost savings, safety and health benefits,
efficiency improvements, etc.
Currently, SBAP is using technical assistance database to
track the number and types of assistance given to small
busjnesses. January 1999 is the first time many small
businesses had to send in reports to the air quality
program. SBAP will work with the air quality program to
track the number of small businesses that are out of
compliance and SBAP efforts to achieve compliance
corrections.
We have previously described some of our outcomes and results. With respect to
the SBAP portion of CAO; we have a very good understanding of what businesses
are requesting based on the database. We have seen the number of permit
assistance requests go down. We have seen the number of non-enforcement
related compliance assistance go up. This was expected, as businesses moved
from trying to get permits to trying to comply with the permits. Of note, in FY98 the
SBAP was able to provide technical assistance to help 33 facilities avoid the
need for a permit.
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
PROGRAM
AZ
Maricopa
Cty
AR
STRATEGIES TO EVALUATE GOALS
On-site visit evaluations are accomplished by conducting
a follow-up visit 60 days after the facility receives our
report. At the time of the follow-up, we measure the
change in compliance.
Outreach goals to improve understanding of
environmental issues are evaluated based on number of
presentations and number of attendees, along with a
survey of the presentation.
Another goal of the program is to respond quickly and
without transferring people within the department, if
possible. This goal is tracked through our client log.
Our data shows we are assisting more sites every year.
We plan to target at least 2 new industries starting with
wood furniture manufacturing. We will provide industry-
specific information and have the Air Quality Division
Manager sign the letter.
We will conduct at least one seminar this year targeting
coatings/solvents.
No evaluation has been attempted. Number of small
business firms needing assistance exceeds resources of
aqencv.
RESULTS OF MEASUREMENT PROCESS
On-site visits have proven to be very effective, with over 70% of all violations
detected being corrected by the time of the follow-up visit. Issues not
corrected by that time are usually more complex or require significant capital
expenditures.
Outreach through presentations has been very effective for our program. Just
having our name and face in front of a variety of people helps encourage them to
call and seek help more readily. By developing a few template presentations and
then modifying for a specific audience, we are able to tailor a presentation for a
specific audience while not spending a great deal of time. We have received high
marks for these efforts.
By receiving more referrals and assistance requests, we know we are meeting our
goals. We also send every site we help (significantly) an evaluation. Almost every
evaluation comes back as "excellent service." We track sites by date and
alphabetically, rather than by industry or type of assistance. Many businesses say
they were unaware they needed a permit, and many are grateful for on-site visits
and assistance with the application. We try to explain technical terms in a non-
technical way, both verbally and in writing.
N/A
N/A Not applicable N/R No response
-------
TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
CA
#1 - Increase the regulated community's participation in
development of permitting and compliance programs.
ARB's Office of the Ombudsman tracks each regulatory
item and works with ARB divisions to help identify key
stakeholder constituencies. It assists staff with outreach
efforts to notify stakeholders of regulatory development
workshops and board hearings. If reviews staff outreach
for regulatory items and reports to the ARB board during
hearings on the sufficiency of the outreach process.
Outreach efforts are measured and reported as a
performance measure per ARB's strategic plan.
Stakeholder satisfaction with the outreach process is
measured using a survey. The survey results are
reported as a performance measure per ARB's strategic
plan.
#2 - Increase the regulated community's satisfaction with
air quality permitting and compliance programs.
ARB holds peripdic stakeholder forums to hear
stakeholders' views about ARB's programs, including
permitting and compliance. Stakeholders told us in 1996
the key elements of an effective air quality management
program that were important to them. These included
sound science, simplified regulatory processes, improved
public education efforts, involvjng stakeholders in program
development and implementation efforts, and pursuing
emission reductions proportionate to emission
contributions.
These key themes were in large part incorporated into
ARB's strategic plan. One performance measure in the
plan is to measure stakeholder satisfaction with programs.
In 1998, the ARB Ombudsman's Office developed a "How
Are We Doing?" survey as a follow-up to the 1996 forums.
We hope to administer the survey in 1999 and report the
results as a program performance measure per ARB's
strategic plan.
#1 - The ARB Office of the Ombudsman measures the number of stakeholder
workshops, meetings, and conferences held annually on a fiscal year basis (July 1-
June 30). For FY 97/98, there were 264 meetings on 14 regulatory items
(about 19 meetings per regulatory item). This compares to 24 meetings per item
for 10 regulatory topics for the year before.
Since November 1998, the ARB Office of the Ombudsman has been measuring
stakeholder satisfaction with the regulatory outreach process using a survey. The
first partial cycle of results will not be completed until July 1999; however,
preliminary results from eight regulatory items indicate very favorable satisfaction
with stakeholder involvement processes. Average satisfaction in six process
areas, including the overall regulatory development process, ranged between
3.0 and 3.5 on a scale of 1 to 4, with 1 being poor and 4 being excellent.
#2 - We hope to administer the program satisfaction survey in 1999 and report the
results as a program performance measure.
South
Coast
Every year, a work plan with (when appropriate)
quantifiable goals is developed in coordination with the
budget. The work plan includes federal, state, and local
agency programs that need to be implemented by the
SBAP. Assessment of on-going business consultation
goals is handled through the statistics generated by our
automated client tracking system. This system allows the
program to track the success of outreach to business
sectors and cooperative local governments.
The technical consultation program met its goals for the year. The measurement
system (described to the left) still needs some enhancements to more accurately
measure certain program work. This year, we are modifying the tracking system to
account for special projects associated with rule-specific outreach. The SBTCP
kept careful records of all advice given to clients, types of assistance provided
(e.g., rule interpretations, permit application assistance, compliance reviews,
financial assistance), types of industries assisted, geographic areas, and relative
staff productivity. Hotline calls to SBAP are a good indicator of current and
emerging small business concerns.
N/A Not applicable N/R No response
8
-------
TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
CO
Initiated a customer feedback loop via a "customer
service survey" program. A survey is mailed to every site
visit conducted. The results are tracked in a database.
Conduct industry-specific workshops and obtain workshop
evaluation forms.
Feedback from department's enforcement group.
General - The survey process has been instrumental, as we have received specific
recommendations for improvement. However, the return rate needs to increase.
The workshops have allowed interface with individual small business owners to
resolve specific compliance issues.
Specific data - We needed to establish specific measurement programs/systems
and will do so in 1999.
CT
We are evaluating program effectiveness through the use
of questionnaires and surveys. We also have developed
outcome-based measures of performance as part of
targeted initiatives. Outcome measures have included
numbers of facilities submitting permit applications as a
result of outreach, increases in compliance with specific
requirements, and increases in compliance rates.
SBAP has pursued measurement efforts very narrowly for specific, well-defined
compliance objectives. For specific compliance assistance efforts, SBAP has met
programmatic goals. However, we continue to see an expansion of the regulatory
universe that cannot be addressed through current resources.
DE
SBAP is working with business sectors that will be
immediately impacted once DE takes delegation of certain
programs identified by our Engineering and Compliance
branch. SBAP works to provide compliance assistance
information to these sectors prior to our state taking
delegation of a program. One way to evaluate the
effectiveness of our SBAP is to hopefully realize a
reduction in enforcement actions taken in these delegated
sectors and to evaluate the quality of recordkeeping
requirements by the businesses.
We feel as though an increase in small business callers
seeking assistance is a sign that our program is having a
positive effect. We are working hard to improve
communications between our regulatory programs and
the small business community and to increase the level of
trust and confidence on both sides.
We track the number of phone calls and the number of requests for assistance.
Each year, we see an increase in requests for assistance. In addition, we have
more than one request for assistance from the same business, which indicates a
level of confidence in our program within the business community.
DC
The frequency of calls received from small businesses is
an indication that the information is getting around. Once
you talk to the caller, you will be able to determine how
jriuch he/she knows or understands about the regulations.
With the limited resources that the program has, this is the only feasible way of
measuring the program's goal.
N/A Not applicable N/R No response
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
FL
#7 - Increase understanding.
Manage 800 line for regulatory and technical assistance
inquiries. Conduct training and associated pre- and post-
training surveys. Target one significant smalt business
industry per year (currently printers).
#2 - Improve compliance.
Training increases awareness, and thus, compliance
rates. Developed and distributed dry cleaners compliance
assistance calendar.
#3 - Encourage self audits.
Developed self audit road maps for printers to be
distributed during 1999 training workshops.
SBAP met many goals in 1998. Statistical data for small businesses showed which
types of businesses and how many businesses of each industry type were
reached. Hopefully, this will enable future relationships with these businesses.
The measurement system worked, but with a variety of people collecting data, a
more uniform recording plan has been implemented for 1999. Statistical data are
as follows:
Initially, outreach workshops were used to create PERC awareness. Reductions in
PERC were achieved proving the success of the workshops. However, compliance
with recordkeeping and reporting remained low. To remedy this situation, dry
cleaner calendars were created that enabled businesses to easily enter data on
their calendars and then tear off information each month to send in and meet
compliance requirements. In 1996, there was a 12% average compliance rate in
recordkeeping. In 1998, recordkeeping and reporting increased to an average of
73% for the year. Therefore, from 1996-1998, a 61% increase in compliance
was achieved due directly to calendar distribution.
Responded to 245 regulatory and technical assistance requests (via 800 line,
letters, e-mails, etcj. __^
N/A Not applicable N/R No response
10
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
GA
SBAP prepared measurable objectives to help us achieve
our 1998 goals. Those objectives were grouped under
Education and Technical Assistance.
Education - Publish a quarterly newsletter. Develop a
working relationship with 4 trade associations that results
in the preparation of educational materials for distribution.
Sponsor an exhibit at one trade association exposition.
Make 8 informational presentations to professionai and
civic associations. Establish and maintain a web page for
small business owners to use for distributing relevant
information in a timely manner. Establish a repository of
P2 and SBAP resources. Ensure that each staff member
attends at least one training course or small business
assistance conference, in order to provide effective staff
development and training in current methodologies and
practice. Establish a combined database of small
businesses by SIC code.
Technical Assistance - Establish a toll free telephone
assistance line. Prioritize small business technical
assistance needs by industrial classification and prepare
two technical information assistance brochures. Make 12
site assessment visits. Assist 12 businesses with
permitting. Respond to 300 technical assistance requests
via telephone within 24 hpurs and complete any required
on-site follow-up at the client's convenience. Establish a
liaison with at least one other state agency and work
cooperatively on a joint consumer assistance project to
foster better interagency cooperation.
SBAP far exceeded our program goals for 1998. We gathered comments from the
businesses assisted via a customer survey form. We identified measurable
objectives that allowed us to readily determine that our goals had been met.
HI
SBO - The number of public speaking engagements with
busjness advocacy, trade associations, andsmall
business permittee groups. The number of publications
and answers to questions raised by individual regulated
businesses disseminated. The number of compliance
cases undertaken and closed.
SBAP - The number of services/assistance provided to
small businesses.
SBO - Established the Compliance Assistance Office, conducted outreach,
increased services to target client group, and closed 21 compliance assistance
requests/cases.
SBO has received positive feedback and subsequent calls for assistance.
ID
Performance measurements are under development. The
goals are for the future and do not necessarily represent
the past. As pf now, we are keeping track of the number
of calls, meetings, site visits, etc.
Discovering that more people were using the SBTCP than was previously thought.
N/A Not applicable N/R No response
11
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
IL
SBO - Client satisfaction survey to asphalt plants, chrome
platers, rock crushers in Spring 1998.
SBAP - Tracks the number of calls to the helpline, nature
of the questions, kinds of information sent, workshops
held and number of attendees, and articles printed in
trade magazines. We do a monthly report of program
activities as well as the Annual Report to Karen Brown. In
addition, we note any partnership activities.
The SBAP currently sends surveys to all clients after they
receive assistance to gauge program performance. We
have experienced a high approval rating with 94% of
clients returning the survey and stating they were very
satisfied with services they were provided.
We have tracked all surveys sent to clients for rating. To date, the SBAP has a
94.44% approval rating.
IN
Dry Cleaners - Noting dry cleaners that come into
compliance following an initial site visit.
Wood Furniture - Increase the wood NESHAP reports
filed on time by sending reminders and making
information available to this sector in a variety of ways.
Vehicle Maintenance - Workshop evaluation forms are
distributed at each workshop.
HVAC - Approximately 15% of the industry is participating
in the Thermostat Reduction and Recycling Program.
General - Number of referrals from past clients. Receipt
of "thanks" and appreciation, either verbally or written.
Follow-up calls or visits show improved compliance rates.
Evaluation sheets from workshops. Evaluation from our
Environmental Performance Partnership Agreement goals
and our Measure of Success Goals.
The Indiana SBTCP met our program goals. Our measurement system of
"numbers reached and assisted worked as defined in the Environmental
Performance Partnership Agreement with EPA and our own Agency's Measures of
Success.
We worked cooperatively with our target industries; provided comprehensive
compliance manuals, workshops, and on-site assistance; and kicked-off several
new 5-star recognition programs. All of our workshop evaluations have provided
consistent, positive feedback, and companies continue to request more technical
help, both on the phone and in person.
N/A Not applicable N/R No response
12
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
IA
Our evaluation system focuses on our services. We do
not have a system to track and relate client evaluation to
specific program goals.
We send an evaluation form to every on-site visit client or
detail assistance (defined as any assistance involving
more than one hour of staff time) client. They rate the
quality and usefulness of assistance. Completed and
returned evaluation forms are entered into a database,
which can generate a number of reports based on the
client evaluations.
Also, we develop case studies of cjients we have worked
with whenever we feel it is aDDrooriate.
Returned evaluation forms show that over 95% of respondents found the
services "excellent" and "very helpful" and would recommend our services to
other businesses.
Evaluation feedback is only one part of the measurement for meeting program
goals. Among other indicators, increased client referrals, repeat visit requests from
past clients, and a steady backlog of site visit requests (over 200) show us the
confidence of the small business community we nave earned.
N/A Not applicable N/R No response
13
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
KS
Following all on-site assessments, workshops, and
conferences, evaluation forms are sent to participating
businesses. Six months later, those businesses receiving
on-site assistance receive another evaluation to
determine if advice provided has been implemented by
the business. In addition, numbers and comments
provided by businesses are recorded. Evaluations are
provided after every workshop, which relates to our
second ranked goal regarding the "regulated community's
understanding of their environmental obligations." and to
determine the quality of the workshop. Almost all
workshop evaluations show extremely positive results.
The program continues to grow as services are known throughout the state. We
receive many positive comments and letters of thanks for our services.
Evaluations following on-site assessments show improvements in most
businesses. Relationships between the technical assistance program and the
regulatory agency continue to improve with regulators referring many businesses
for SBAP services.
Plans for 1999 include a detailed survey of businesses through cooperation of the
SBAP and SBO.
1998 survey results:
• Did you implement recommendation (made by SBAP)? Yes-48; No-
25; Planned-10
• Did you originally contact the SBAP for help with a compliance
related question? Yes-16; No-5
• Were these compliance concerns resolved as a result of PPI
assistance? Yes-15
• Was the delivery of the written report timely? Yes-15
• What sections of the written report were most helpful? executive
summary-10; waste reduction opportunitles-1; regulatory contacts-5;
vendor contacts-5; MSDS-3; case studies-2; other (main body of
report)-1
• How would you rate the content of the report (1-10 with 10 best)? 10-
3; 9-2; 8-6; 7-3
• How would you rate the length of the report? 10-3; 9-4; 8-5; 7-1; 6-2
• Was the report easy to read? 10-6; 9-5; 8-3
• Was the information provided in the written report what you asked
for/needed? Yes-14
• Was the report, In combination with information provided during the
site visit enough to implement the recommendations? Yes-14; No-1
(needed cost analysis)
• Approximately how many total person hours did you and your staff
spend with SBAP staff conducting the site visit and
reviewing/Implementing report recommendations? Answers varied
from 2 to 40 hours.
• What dollar value would you place on the service provided? $200-
$5,000
• Would you recommend our services to another company? Yes-21
N/A Not applicable N/R No response
14
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TABLE F-1
(Continued)
PROGRAM
KY
Jefferson
Ctv
STRATEGIES TO EVALUATE GOALS
The AQRSB developed 3 questionnaires during 1998 to
assist in evaluating 3 services - technical assistance to
§hone callers, the column that has been in distribution for
years, and the work of the DEP in staffing and
responding to the CAP.
SBAP evaluates its efforts to provide compliance
assistance and educational information to small
businesses through evaluation cards; requests for
"success stories" prepared by the Ombudsman; meetings
and discussions with businesses and industry
organizations; and working with the regulatory agency,
CAP, and other stakeholders.
N/R
RESULTS OF MEASUREMENT PROCESS
Responses to questionnaire on assistance to telephone callers indicated a high
level of satisfaction, using a scale of 1-4 with 1 representing poor service and
4 representing excellent service. The average was 3.9. This composite rating
indicates some success in increasing understanding of the CAA of 1990.
A survey was sent to the newsletters that receive the AQRSB column. 4 out of 12
newsletters responded. As a result of these surveys, more information is available
on how the column is being used and valuable suggestions were received on how
to improve it, some of which have been incorporated. The results of these surveys
were valuable in assessing how useful a tool the column is in reaching the
regulated community.
A survey was developed and sent to CAP members to help the DEP evaluate its
assistance to the Panel. A second mailing of the survey is scheduled for 2/99 due
to the low initial response.
Through the cooperation of the regulatory agency, the ombudsman, other partners,
and stakeholder requests for SBAP assistance increased dramatically
(approaching 50%) in the last 6 months of 1998. Client evaluation cards indicate
a nigh level of customer satisfaction. A growing partnership network indicates the
program is effective in delivering quality assistance and information.
KBEAP provided 71 businesses with compliance and technical assistance in 1998.
Each company was sent an evaluation card. KBEAP received 19 cards for a 27%
return rate.
Customer satisfaction KBEAP program services:
• Knowledge of air quality Issues: A-18; B-1
• Courteous ness: A-19
• Timeliness in responding to your request: A-16; B-3
• Grade KBEAP's overall performance: A-19
Value of KBEAP services:
• Did KBEAP services save your company money? Yes-1 8; No-1
• Is there a need for similar services in water and waste management
programs? Yes-1 0; No-9
• Did your experience with KBEAP result in your company decreasing
emissions? Yes-7; No-11; N/A-1
• Will you contact KBEAP if additional air quality assistance is
needed? Yes-1 9
N/A Not applicable N/R No response
15
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
LA
We send an evaluation form to every small business we
assist. We have two levels of assistance: contacts and
assists. Contacts are advice given by phone and
seminars. Assists are extensive engineering assistance,
such as emission inventories, permit applications, and on-
site audits. We maintain a database of these activities
and compare with previous time periods.
The returned evaluation forms were favorable in every case. We have increased
the number of contacts and assists each year since 1992.
ME
Customer comment card sent out with all written
information:
1. Did you receive regulatory information you were
previously unaware of?
2. Did you receive technical information on your process
or service?
3. Will the information help you achieve regulatory
compliance?
4. Will the information help you reduce pollution?
5. Will the information help you reduce costs?
Those who responded indicated the following:
1. Yes-69%; No-17%; N/A-14%
2. Yes-52%; No-24%; N/A-24%
3. Yes-65%; No-7%; N/A-28%
4. Yes-48%; No-21%; N/A-31%
5. Yes-31%; No-38%; N/A-31%
MD
N/R
N/R
MA
On-site visits: We included a survey of our service with
on-site visjts during 1998. This survey asked for a very
critical review, focusing on problems and improvements.
The results were very complimentary. We stopped
surveying, because although it was valuable to know our
services were greeted positively, the survey was not
providing us with the information we needed -- it was not
addressing the shortcomings.
Sometimes we have the data to measure the company's
waste and use. We assess their P2 opportunities ana
compliance. We provide the recommendations and
follow-up to see if they have addressed their compliance
issues and implemented the P2 opportunities.
Sector projects: We incorporate measurements into some
of our outreach projects. The dry cleaners project
produced data that we are examining. The Printers
Project (pre-1998) used Environmental Business Practice
Indicators and produced before and after information.
Our medical facilities project utilized a conference
attendee survey and a follow-up survey.
Outreach projects: We examine the number of on-site
visits or requests for help that they generate.
Measurement of waste/use ratios shows dramatic improvement by companies
visited by OTA.
Best estimate from follow-up program shows high rate of implementation
(approximately 60%) of P2 suggestions and higher rate (approximately 80%)
of addressing identified compliance issues.
Sector results for printers showed excellent results (pre-98); dry cleaners not
tabulated. Before and after results may not be usable.
Outreach for autobody and municipal departments of public works generating
significant number of on-site visits and phone assistance. Substantial numbers of
manuals requested by local officials for distribution.
N/A Not applicable N/R No response
16
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
Ml
SBO - Evaluates its services from the feedback received
by econpmic development staff that visit statewide
companies. Results of measurement process not
applicable.
SBAP - Targeted the following objectives (based on
individual staff work plan objectives) for completion during
FY97/98 (October 1997-September 1998):
New workshops - 6
New guidance documents - 9
Publication revisions - 7
Responses to requests for technical assistance -1,000
On-site visits -15
Permitting assistance meetings - 20
Articles for newsletters, etc. - 8
Partnership opportunities -16
Presentations - 24
SBAP - Evaluates quality of its services and effectiveness by reviewing its
projected and actual program objectives and the level of technical assistance
provided on a monthly and annual basis. Some SBAP measurement tools include
the review and summary of overall responses from customer surveys that
accompany all new and revisited SBAP guidance publications, responses from
evaluation forms returned after each SBAP workshop, and appreciation letters
submitted by satisfied customers. A summary of these reports is shown below:
New workshops = 8 completed (objective met 100%; exceeded by 33%)
Workshop evaluations 1-5 (5 = excellent)
• Handling Asbestos (4 sites) = 4.0 average
Surface Coating of Metal Parts (2 sites) = 4.3
Managing Chemical Risk (RMP) (1 site) = 3.8
• Ml Air Emission Reporting System Peer Review (1 site) = 4.1
Percent attendees anticipating future action or compliance based on workshop
activity (as reported by attendees)
Handling Asbestos = 48.5%
Surface Coating of Metal Parts = 62%
Managing Chemical Risk (RMP) = 70%
New guidance documents = 5 completed (objective met 55%; 4 final/1 draft)
Document evaluations 1-5 (5 = excellent)
Permit to Install Guidebook for Determining Applicability = 4.5
Surface Coating of Metal Parts Fact Sheet = draft
Continuous Emission and Continuous Opacity M9nitpring Fact Sheet - not
measured, created for the air quality regulatory division
Understanding the Asbestos NESHAP Fact Sheet = 4.0
• What is an Air Contaminant? Fact Sheet = 4.2
Publication revisions = 3 completed (objective met 43%)
Ml Air Use Permit Technical Manual - not a measured SBAP publication
Air Pollution Control "101" Fact Sheet = 4.7
• Renewable Operating Permit Program: Guidebook for Completing Forms
= 4.3
Requests for technical assistance = 1,358 completed (objective met 100%;
exceeded by 36%)
On-site visits = 26 completed (objective met 100%; exceeded by 73%)
Permitting assistance meetings = 52 completed (objective met 100%;
exceeded by 60%)
Articles for newsletters, etc. = 8 completed (objective met 100%)
Partnership opportunities = 9 completed (objective met 56%)
Presentations = 18 completed (objective met 75%)
N/A Not applicable N/R No response
17
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
MN
Goal #1 - Compliance rates based on follow-up
enforcement initiatives by MPCA's regulatory programs
(e.g., NESHAP compliance rates among degreasers,
platers, and wood finishers).
Goal #2 - Same as above. Also, follow-up surveys have
indicated a 95% satisfaction rating for program site visits.
Goal #3 - Will attempt to use similar methods as above.
Results of the MPCA's NESHAP enforcement initiative involving degreasers,
platers, and wood finishers indicated a 98% compliance rate among businesses
inspected. This high compliance rate has been linked to SBAP's compliance
assistance efforts within these sectors. In this respect, we feel that the SBAP is
reaching its goals in terms of getting the regulated community into compliance.
The program continues to receive very positive responses from the small business
community as a result of its on-site compliance assistance. The program may
conduct additional surveys in the future to learn if the site visits can be further
tailored to meet the needs of the small business community.
MS
N/R
N/A
MO
We sent out an evaluation survey to every fifth facility
helped.
Our on-site assessment team performs a follow-up on
each facility they visit to see if the recommendations have
been followed.
We are continuing to write industry-specific
P2/compliance guides and other technical bulletins.
The surveys indicate that facilities have received the assistance and information
they needed to attain compliance.
Follow-up on the on-site assessments indicates that most violations are being
corrected and the P2 recommendations are being followed.
MT
SBO/SBAP keeps statistics on the number of site visits it
conducts each year and records the number of
participants at workshops and meetings. Records are
kept about recipients or mailings and of callers on the toll-
free hotline.
SBO/SBAP did meet its goals to provide extensive on-site assistance to the vehicle
service, automobile refinishing, dry cleaning, and chrome plating sectors. Other
goals were to establish a low-interest loan program and to add multimedia
services. All of these goals were accomplished in 1998. SBO/SBAP provided
multimedia P2 assistance to each of the businesses identified by EPA's Sector
Initiative and extended loans to over 20 service stations, 4 auto body shops, 2
heating/air conditioning projects, and 2 small manufacturers to purchase energy
efficient and P2 equipment.
NE
NE has one person that handles the SBAP, the
ombudsman activities, the one-stpp permit assistance
program, and the small business information library. This
includes site visits, phone calls, compliance tracking,
public meetings, association meetings, and all reporting
requirements. The Public Advocate will continue to
provide these services to the businesses, industry, and
the public in NE.
The program is a success in NE. Tracking is provided on a month by month report
that covers all activities of the Public Advocate.
NV
Survey forms are circulated following each seminar or
workshop to evaluate outreach efforts.
Tracking sheets are maintained for each SBAP contact,
logging name, business, assistance needed, etc. These
forms indicate an increasing number of referrals from
regulatory staff, which indicates their greater
understanding of small business needs and concerns.
Gpals for 1998 are not necessarily reflected in the choices shown above. SBAP is
fairly new and much of the staff's time and program resources have been focused
in program development and networking with the business community. The
number of contacts has increased each quarter and this is a good indication that
the regulated community has an increased awareness of their environmental
obligations. Additionally, the number of requests for on-site compliance assistance
has increased.
N/A Not applicable N/R No response
18
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
NH
Measuring effectiveness of activities up to this point has
been fairly general (i.e., number of manuals requested
and sent, quantity of newsletters sent, and number of on-
site visits conducted). Many on-site visits are the direct
result of referrals from enforcement personnel, so these
visits usually result in quantifiable compliance assurance
due to follow-up activities by the enforcement personnel.
One quantitative measure we are using is the percentage
of identified businesses in an industry sector we are
reaching through various activities. Two primary sectors
we are concentrating on are the automotive repair and
refinishing industry and the printing industry.
We routinely send out short, self-mailing questionnaires to
businesses that receive specific compliance information,
such as industry-specific guidance manuals.
Unfortunately, the return rate is usually very low (i.e., less
than 25%).
At this time, it is not possible to make any sweeping statements on the
effectiveness of the measurement process.
We are confident that the activities are successful based on the conversations with
those businesses we have worked directly with as well as through the information
provided on returned surveys. In addition, for the sectors where we have has the
opportunity to somewhat accurately identify the number of existing sources in the
state, we have been able to determine the sector penetration rate for activities such
as mailings.
What we have not been able to accurately determine is the increased compliance
rate and environmental improvements businesses have undertaken on their own
after receiving non-on-site assistance (such as newsletter articles, etc.). We
continue to evaluate ways to collect, compile, and present these data to provide
"hard" measurement information.
NJ
Recordkeeping on the number and type of businesses
assisted through the program.
Use of surveys with Environmental Air Compliance for
Small Business Audit/Training seminars.
Use of surveys at workshops done in conjunction with
EPA Region II, dry cleaners association, etc.
Use of telephone loas.
N/A
N/A Not applicable N/R No response
19
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
NM
Early in the year, when 2 of our staff were transferred, we
took the time to re-evaluate our overall SBAP goals. Our
program had been a very labor-intensive, one-on-one,
client-based effort that was time demanding of our staff,
which only allowed limited outreach activities. We
decided to redirect our efforts to make the permitting
process easier for small businesses, to reach more
businesses, and to reach whole sectors whenever
possible.
Several activities were initiated with the end goal of
making the permitting process easier for small businesses
and shortening the time it takes to get a permit. We
began by developing regulatory enabling language,
authorizing the Air Quality Bureau to write general permits
for categories of similar sources with an easier application
process and a 30-day turnaround. We held public and
similar source information meetings to make certain our
approach was on target with the needs. We then wrote
drafts of general permit regulations for rock crushers,
asphalt plants, and concrete batch plants. We went to
public hearings on a general permit for oil and gas
compressor stations.
We made major revisions to our construction permit
regulation, 20 NMAC 2.72. These revisions created an
exemption list and streamlined permit revision procedures
that were intended, in part, to assist small businesses by
eliminating certain activities, thereby making it easier and
quicker to get a construction permit for those who qualify.
We also dedicated significant staff time to writing a Plain
English Manual for Construction Permit Applications to
make it easier for the small business person to
understand and apply for a construction permit or Notice
of Intent. The manual will be made available to all small
businesses in NM when complete.
We believe we met our new, redirected program goals. The feedback from the
public/sector meetings and public hearing indicate we are going in the right
direction for our small business clients in paving the way for an easier, more
understandable permitting process.
For one-on-one clients, we currently are operating as a clearinghouse for
regulations and permitting contacts.
N/A Not applicable N/R No response
20
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
NY
The program primarily uses statistics on the response
rates to mailings and the numbers of hotline calls,
Ombudsman cases, mailings, permits completed, and on-
site audits that occur each year.
SBAP tracks the numbers of hotline calls, audits conducted, permits and
registrations completed, and attendance at wprkshops. SBAP has surveyed all
program contacts via our newsletter, Clean Air News, for their feedback on the
content and frequency of the newsletter. Responses were favorable, indicating
reader satisfaction.
SBAP conducted 17 audits this year and provided site-specific assistance to these
businesses. We responded tp over 1,300 SBAP hotline calls with requests that
ranged from routine program information to very specific technical assistance. We
provided permitting assistance, completing 14 state facility permits and 52 minor
facility registrations. SBAP also helped 71 businesses reply to a mass mailing
from the state regulatory agency, DEC, which brought them into compliance with
the permitting regulation and prevented them from being classified as significant
violators in the future.
SBEO tracks the number of hotline calls and the number of ombudsman cases
completed each year. There were over 700 calls to the ombudsman hotline in
1998 representing a 45% increase over 1997. The ombudsman handled 71
cases in 1998, which also represents about a 45% increase over 1997.
SBEO also tracks the response rate to seminar mailings in terms of number of
attendees at the seminars. Generally, a participant response rate of 10% of the
number of mailings sent i
well above
produced by SBEO in 1998 had participant response to mailing rates '
this benchmark. The Combustion Boiler workshop had a 66% response rate,
the PPIS seminar had a 47% response rate, the statewide dry cleaning
seminar had a 15% response rate, and the Spanish dry cleaning seminar had
a 45% response rate.
There were 5 Regujatory Alert postcards sent in 1998. The number of hotline calls
from these sectors increased dramatically after the mailings were sent. Over 90%
of the businesses that contacted the hotline from these targeted sectors indicated
that they heard of the SBEO through the postcard mailing.
NC
We have not had a good way to measure this in the past.
This is a priority this year, and we plan to develop surveys
and change our strategy to target particular cpmpliance
problems. We will be improving our communication and
dialogue with trade associations and regulatory agencies
to identify areas of need and address those areas.
Documenting increased understanding vs. improving
compliance is easier, since the regulatory agencies
determine compliance. Meshing our voluntary,
confidential approach with the regulatory program has
some obstacles that must be overcome.
We do have some results of measurement through numbers reached in the 112r
training. A large number of potential industries were contacted or exposed to
training. (This also included staff training.) We will have some follow-up as plans
are submitted. This will allow us to go a step further in measurement. We have
been tracking one-on-one contacts, out not necessarily by SIC code and have not
been successful in directly relating our efforts to program goals.
N/A Not applicable N/R No response
21
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
ND
One indicator of our effectiveness is the compliance
status of small businesses. Since there appears to be a
high level of compliance among small businesses, it
would appear our assistance efforts have been successful
in achieving our goals.
No statistics have been compiled. Qualitatively, the vast majority of small
businesses are in compliance.
OH
Goal 1a - The distinction between 1a and 1b is a direct
outgrowth of the different functions of the SBO and SBAP
in OH. Due to the high quality of technical assistance
provided through SBAP, SBO has chosen to focus more
on general education about the degree to which
environmental regulation has an impact on small
busjnesses. In a very real sense, SBO hopes to get small
businesses to ask the question, "Do I need a permit?"
SBAP then can help provide the answer.
Goals 1b and 2a - On-site assistance concentrates on
determining a company's need for state permits. Each air
pollution source at a company may be exempt or may
require a Permit to Install, Permit to Operate, or both.
During site visits, data are collected, including the number
and type of sources, whether each source is
permitied/unperrnitted/exempt, and if SBAP assisted with
a permit application. This data are analyzed to present a
true picture of how much the small business currently
knows about their permitting obligations and how many
would be found in violation for not having permits.
Through on-site assistance, the company is made aware
of their permitting needs, often for the first time. In the
future, SBAP will attempt to track the processing time of
the permit applications that received SBAP assistance to
see how much processing time is reduced.
Goal 2b - The most straightforward indicator is the
number of projects financed or receiving grants. Because
that number remains low (about 10), SBO commissioned
a series of focus groups to help identify barriers to
reaching the small business constituency. Results of
those groups currently are under review.
Goal 3 - This was not evaluated in 1998.
W evaluate
ay to go,
Goal 1 a - SBO has not undertaken the extensive surveying necessary to
progress. Initial results from the focus groups indicate we have a long w „_.
But there is no surprise in that. Within certain sectors (e.g., printing or aggregates),
we have anecdotal evidence through trade associations that members exhibit a
higher awareness of environmental regulations and available sources of help. We
are beginning to see a slight improvement in the response of dry cleaners as a
result of two recent loans to dry cleaners; both cleaners are still in business and
convinced their colleagues that working with a government program is not the
death knell for the business.
Goals 1b and 2a - In visiting 149 companies in 1998, the SBAP assisted with 234
permit applications, indicating the need for businesses to understand their
permitting obligations is great. 100% of companies receivina on-site assistance
were made aware of their permitting requirements. Only 12% of cpmpanies were
exempt from all permitting requirements, and only 18% of companies needing
permits had any kind of existing permit. SBAP hopes that its findings can help the
OH EPA create more permit exemptions for small sources.
OK
We evaluate these goals through our FOCUS document.
This agreement with EPA Region VI replaces our old
program goals. FOCUS outlines the individual tasks for
each staff member in terms of specific tasks to
accomplish our Agency goals. Individual employee
performance evaluations measure whether these goals
were accomplished or not.
We believe our program is meeting the goals defined in our FOCUS document.
N/A Not applicable N/R No response
22
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TABLE F-1
(Continued)
PROGRAM
OR
PA
PR
Rl
SC
SD
TN
STRATEGIES TO EVALUATE GOALS
BAP goals are more general. We do not have a good
system for evaluating the effectiveness of the program.
We hope that the work of the EPA SBO/SBAP will
develop a method that we can use. Technical assistance
currently is tracked by the number of calls, TA on-site
visits, mailings, etc., but we do not track reductions in air
pollution or improvements to the environment,
Measurement tools are being developed.
N/R
SBTCP will target the autobody industry for in-classroom
training along with workshops on practicing P2 in the
shop.
Completed surveys returned to our office give us an
indication as to whom is still in business. Also, returned
(unopened) mailings indicate who has gone out of
business.
A simple head count is another way we keep track of how
many industrial representatives attend specific
workshops.
We are continuously reviewing requests for assistance to
determine how many small businesses are seeking help
before an actual complaint has been filed with the
regulatory agency. Our goal is to reduce the number of
small businesses that end up in the enforcement process.
Track the number of sources that were inspected and in
compliance. The performance measure is based on the
percentage of sources in compliance with their air quality
permits.
Subjective determination that SBAP has provided all
necessary information and opportunities to affected small
employers to ensure their understanding of employer
obligations. Services include on-site visits upon request,
workshops, satellite teleconference downlinking and
sponsorship, and understandable documents provided to
employers.
RESULTS OF MEASUREMENT PROCESS
Some of the program goals are being met, as far as educating the regulated
community about their environmental obligations. This is indicated by the technical
assistance tracking method, originally developed for the AK DEC. This
measurement system does not work as well as desired. An improved
measurement system needs to be developed, but limited resources have
prevented this from happening. Attendance (or lack of) at P2 classes sponsored
by the SBDCs indicate that our goals are not being met. There also are fewer on-
site technical assistance visits being requested than is desirable.
N/R
N/R
People respond well to teleconferences and on-site assistance when the
assistance is provided by professionals who are familiar with specific industry
problems. These professionals also should have experienced a trial and error
approach to solving problems and know of success stories in working with the
nonregulatory branch of state and federal environmental agencies.
Measuring the achievement of our program goal is a continuous process. The
objective is to minimize the number of small businesses that end up in the
enforcement process.
Just initiated the performance measure, so it is too early to tell if the measurement
system works.
We met program goals. We believe in the "customer service" concept but not in
intrusive governmental involvement or oversight.
N/A Not applicable N/R No response
23
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
TX
Measurement (compliance surveys) of industries'
compliance before and after assistance is achieved
through questionnaires and customer-service surveys for
all hotline calls, site visits, and workshops. Future
measurement goals include tracking the number of small
businesses taking advantage of Supplemental
Environmental Projects (towards which small businesses
may apply a portion of the penalty owed under an
enforcement order, which benefit the environment in the
community where the violation occurred), and the number
of small businesses issued default orders (issued to
entities that do not respond to Notices of violation).
SBAP met its program goals of 90% year-end compliance for most industries,
but fell short for others. Additional outreach will be conducted for industries in
which compliance rates were below 90%, and specifically targeted to the media for
which it is needed. The measurement system was successful as it showed us the
industries for which outreach was successful, what types of outreach were
successful, and where further outreach is needed.
(Results of measurement process are very extensive. Please see notes section
below.)*
UT
SBTCP provides services to small businesses through a
hotline, on-site visits, seminars, etc.
We do not have a measurement process in place to measure the goals of the
program.
VT
Follow-up phone calls and site visits whenever possible to
record improvements made.
Increased number of Hazardous Notification forms filed
with regulatory division.
Increase in permits issued, which are attributable to
SBCAP's assistance.
Increased number of on-site requests.
Increased number of hotline requests.
In general, comparing 1997 numbers to 1998 numbers
across the board,
VT met its program goals.
Hotline calls:
1997-75
1998-146
51% increase in use
On-site visits:
1997-9
1998-18
50% increase in requests
N/A Not applicable N/R No response
24
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
VA
For this program year, the evaluation of the above goals
was done on a general provision of assistance basis.
This year wouldencompass general compliance
assistance and concentrate on the final development of
the program's web site, including the development of
training materials in preparation Tor delivery of training to
VA's small businesses. The targeting of specific industry
sectors was confined to the begmnjngs of the
development of concept, partnerships, and materials to
provide outreach to sources affected by the provisions of
112(r), specifically propane dealers and users. Other
outreach for specific rules, guidance, or P2 activity would
be developed as opportunities presented themselves.
Indeed, three opportunities arose in the form of downlink
telecasts: "WasteWise," "Clean Air Compliance for
Consumer Products," and "Using Screen Printing
Technologies for Business and Environmental Success."
Each of the above goals relies on the dissemination of
information of regufatory and permitting requirements to
potentially affected sources. Assistance provided to a
single client, a single permit, a single untangling of
confusing regulations, or productive interfaces with a
trade group can provide results not necessarily captured
by the parameters of the numbers found in the charts.
VA met its program goals. The ability to empirically measure the results of
compliance assistance or P2 activity is unfortunately just as difficult as it is to
define the total parameters of P2 and compliance assistance. Compliance
assistance, as a very "soft sided" activity, does not always produce results that are
immediate, definitive, or discernible.
VI
We are presently putting together a self-audit sheet. With
a new Environmental Specialist on board, our site-specific
compliance is in progress, and we are sending out fact
sheets to the community by way of our schoolchildren.
Our goals are being met. Calls from clients are positive.
WA
By responses from sources. By availability of SBAP
services. By development of SBAP materials. By
comparing ratio of notice of violation to enforcement
inspections.
Ratio is decreasing.
WV
Applications received by the Agency in which assistance
was provided by the SBAP are periodically followed up in
conjunction with apprising the applicant of the progress of
same. Because of resource limitations, evaluations for
1998 were more qualitative than in 1997.
Given the workload of WV OAQ's Permitting Section, this effort has not been as
successful as we would like. However, an increase of permitting staff, coupled with
an effort to streamline the state's minor source construction regulation, should
result in better progress in this area. General permits also are more user-friendly
and can be processed more quickly than typical construction permits. Our Coal
General Permit issued 9 registrations over an 8 month period. Typical individual
permits would have taken 3-4 months each.
N/A Not applicable N/R No response
25
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
Wl
Wl SBAP initiatives are built around new or emerging
environmental regulations that have a significant impact
on small businesses. Efforts based around regulations
that have specific deadlines, such as minor source
permits and 112(r) requirements, have been especially
successful. Success is measured by the number of
attendees at these targeted workshops and the number of
calls and publications provided. Seminar evaluation
forms also are used to evaluate the quality of each event.
Additionally, a bi-yearly customer satisfaction survey is
conducted on a representative sample of our total client
base.
Our program has met its goal of providing assistance to small businesses affected
by the CAA. Total number of businesses reached via all outreach efforts exceeded
5,000.
Bi-annual survey results of clients for 1998:
90% of customers surveyed would recommend the small business clean air
assistance program to others.
91% of customers surveyed said they have a better understanding of the air
quality regulations that apply the their business.
41% of respondents report they have been able to reduce the amount of
emissions they generate as a result of receiving assistance from the
SBCAAP.
80% of individuals attending our breakfast seminars on air permitting have a
"much better understanding" of the permitting requirements.
N/A Not applicable N/R No response
26
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TABLE F-1
(Continued)
PROGRAM
STRATEGIES TO EVALUATE GOALS
RESULTS OF MEASUREMENT PROCESS
WY
We conducted a mail-in survey to assess our
performance for 1998. The response was quite light (less
than 3%), even though we provided a self-addressed,
stamped return envelope. However, the responses
received indicate good value in our newsletter and
appreciation for the one-on-one site visits we conduct.
Translating that feedback into actual improvements in
environmental compliance is not possible with the limited
data currently available.
While fairly new and still in the growing stage, our Outreach Office has made great
strides in serving the small businesses in WY. Through a variety of publications,
displays at public events, presentations to various groups, and one-on-one site
visits, we have penetrated a large portion of the small business community in the
state. Notable successes include:
Provided information on environmental statutes and regulations in
over 20,000 newsletters to small businesses in the state (goal 1).
• Offered compliance assistance and P2 initiative support to over 500
small businesses in one-on-one site visits (goal 2).
• Encouraged self-auditing through both policy formulation
(compliance incentive rule advocated by the CAP and adopted by the
Department) and education via newsletter, handout information at
public displays and presentations, and in one-on-one site visits
totaling literally thousands of individual contacts (goal 2).
• Increased the public's understanding of permitting requirements and
CAA through publications, presentations, and site visits totaling
thousands of individual contacts (goals 1 and 2).
Hard data linking these accomplishments to improve compliance (goal 3) is not
currently available. However, we believe our efforts are bearing fruit in many of the
businesses we have contacted. We also are committed to working not just with the
regu|ated community, but also with the numerous small businesses that do not
require permits, but that in combination can have a significant impact pf our
environment. A special focus for those businesses is the use of P2 initiatives,
which can benefit both the environmental performance and their business' bottom
line.
Additional data gathering and statistical analyses will be planned for 1999 to
improve our ability to assess the positive impacts of our outreach efforts.
N/A Not applicable N/R No response
27
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TABLE F-1
(Continued)
*Notes
Texas
Site Visit Program - Site visits were conducted for 177 small businesses in 1998. Baseline and year-end compliance figures, compliance
increases, ana number of site visits for specific industries were as follows:
Industry
Auto Repair air
waste
Dry Cleaners air
waste
Auto Body air
waste
Foundries air
waste
Other air
Industries waste
All Industries air
waste
Baseline Compliance %
91.2
68.2
78.0
83.0
92.4
74.7
94.4
65.4
69.7
66.0
78.4
70.1
Year-end Compliance %
95.7
94.4
96.1
98.2
96.8
93.8
100.0
80.0
85.4
88.3
90.0
90.0
Compliance Increase %
4.6
26.3
18.1
15.2
4.4
19.0
5.6
14.6
15.8
22.3
11.6
19.9
# of Visits
48
36
See auto repair
7
46
177
Surveys taken after the site visits found small businesses had made significant changes based on the consultant's recommendations. Site visits
also spurred more small businesses to recycle and use environmentally friendly solvents and in turn reduce waste and cut disposal costs.
N/A Not applicable N/R No response
28
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TABLE F-1
(Continued)
Hotline - Baseline and year-end compliance figures, compliance increases, and number of calls for specific industries were as follows:
Industry
Auto Body air
waste
Metal Finishers air
waste
Other air
Industries waste
All Industries air
waste
Baseline Compliance %
61.3
59.7
35.0
69.7
51.9
47.6
55.2
52.3
Year-end Compliance %
90.7
97.4
50.0
96.6
87.4
88.0
82.6
90.4
Compliance Increase %
29.4
37.7
15.0
26.9
35.5
40.5
27.4
38.1
# of Calls Received
361
166
130
1,865
N/A Not applicable N/R No response
29
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TABLE F-1
(Continued)
Workshops - SBAP gave 35 workshops in 1998 on topics including metal finishing, auto body and auto service, chemical coaters, printers, dry
cleaners, and RCRA waste recordkeeping. Attendance at all workshops totaled over 1,391 people. Baseline and year-end compliance figures,
compliance increases number of workshops offered, and workshop attendance for specific industries were as follows:
Industry
Auto Repair air
waste
Dry Cleaners air
waste
Auto Body air
waste
Printers air
waste
Metal Finishers air
waste
All Industries air
waste
Baseline Compliance %
72.0
73.4
56.0
70.8
72.9
78.6
25.9
48.6
41.2
78.9
65.0
73.3
Year-end Compliance %
85.2
90.2
87.2
87.8
94.4
90.7
55.6
71.4
57.1
87.0
83.5
88.2
Compliance Increase %
13.2
16.8
31.1
17.0
21.5
12.1
29.6
22.8
16.0
8.1
18.5
14.9
# Offered
12
4
See auto
repair
2
2
35
Attendance
287
74
38
28
1,391
N/A Not applicable N/R No response
30
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TABLE F-2
SIGNIFICANT PROGRAM ACCOMPLISHMENTS, AWARDS, AND RECOGNITIONS
PROGRAM
Alabama
Alaska
Arizona
Maricopa County
Arkansas
ACCOMPLISHMENTS
N/R
SBAP mailed postcard reminders to small businesses that have a general permit or pre-approved limit (PAL) in early January 1998. By using
postcards instead of formal letters, the SBAP was able to save staff time, postage, and Department materials. This format was very successful
in informing the small businesses affected by the air quality laws to maintain compliance and avoid costly enforcement actions. Selected
feedback includes:
• Timely reporting - A Juneau dry cleaner called and received assistance after getting the postcard. He was very thankful for the
reminder. He stated that there were so many forms and reports due (sales tax, quarterly taxes) and that he had forgotten to add the
air reporting requirements to his list of forms that must be filled out. He also wanted to have a reminder sent in July for the next
report. This is a typical response by permit holders to the postcard reminder that was sent out.
• Cost reductions - A few facilities were delinquent in responding to requests to update their general permit applications. Through the
postcard, those facilities were given a hand-written reminder that their air permit application was still incomplete. This allowed them to
avoid the cost associated with potential enforcement measures. The SBAP was able to get 5 facilities to complete their applications
and receive their air general permit.
• Communication - Some of PAL holders needed both assistance in filling out the form as well as getting the reports completed. SBAP
worked closely with the Air Quality Maintenance Compliance Assurance Section to ensure that PAL holders returned their reports on
time.
N/R
The Compliance Incentive or time-limited (90 days) amnesty program was a success. We received over 275 calls and visited over 20 sites.
Of those, 12 obtained an air quality permit. This "leveled the playing field" and also generated revenue.
A team of several individuals from MCESD revamped our home page for easier navigation and a cleaner look.
Direct mailings and using the Internet to find sources have been very helpful.
Approximately 232 attended the dust course in 1998, and we anticipate 100-130 participants in 1999.
We continue to receive referrals from inspectors and permit reviewers to assist businesses in completing their air quality application.
The small business program is performing some excellent work on a one-on-one basis. Extensive use is being made of retired engineers
from the business sector. Technology transfer grant funds through the AR Science and Technology Authority are being used to provide
more in-depth engineering support. Maximum project level is $5,000 with Science and Technology Authority providing $3,750 and the
business client providing $1 ,250. The revolving loan fund is primarily being used to comply with underground storage tank regulations. The
loan fund is limited to $10,000 and $15.000 loans with an interest rate atonlv80% of the published national "crime" lendina rate.
N/A Not applicable N/R No response
-------
TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
California
SBO maintains a customer assistance hotline (1-8000-ARB-HLP2) and e-mail helpline (helpline@arb.ca.gov) for those who need information
about the ARB's programs and services referral help with the environmental regulatory process. SBO responded to over 1,000 helpline calls
and over 1,000 e-mail inquiries in 1998.
ARB initiated a facilitated workshop with the CA Trade and Commerce Agency to improve small business access to financial resources to
help achieve compliance with environmental regulations and P2 activities. Participants included 50 individuals from small business, private
and governmental financial lenders, and financial and environmental assistance providers. They agreed to move forward on the development
of a private/public working group to determine how to implement the recommendations of the workshop participants.
SBO initiated, coordinates, and supports the CAPCOA/ARB Business Assistance Committee. In 1998, the Committee provided an ongoing
opportunity for representatives of business assistance programs to partner with the business community to assess needs, exchange ideas, and
strengthen business assistance programs. Committee activities include developing and maintaining a business assistance clearinghouse,
marketing business assistance programs and providers, promoting communications among various business assistance organizations and the
business community, and encouraging involvement of the business community in developing and implementing business assistance programs.
SBO participates with US EPA and state SBOs/SBAPs to foster communication among states and EPA to improve business assistance
programs. The Office represents CA in the SBO/SBAP Steering Committee and participates in planning the annual conference.
SBO participates in Cal/EPA's Ombudsman Forums, which provide stakeholders with legislative, regulatory, and program updates, and are
especially useful to businesses seeking information on permitting and compliance with air quality requirements.
SBO tracks each regulatory workshop and assesses the sufficiency of the outreach efforts. The Office tracked over 40 regulatory items in
1998 that involved over 800 workshops, meetings, and conference calls. Key items included the modification of the LEV/ZEV regulation,
adoption of jet ski and personal watercraft regulations, Board consideration of the City of Los Angeles' appeal of the Owens Valley PM10 Plan,
and the identification of particulate emissions from diesel-fueled engines as a toxic air contaminant.
SBO evaluates survey results and presents them to division staff for use in improving the regulatory process. The Office also incorporates
survey results into a performance measure in ARB's strategic plan.
SBO worked with ARB staff and CA Air Pollution Control Officers Association management to develop the December 1998 report,
"Stakeholder Visions for the Future of California Air Quality Management," which describes the results of strategic planning forums held
in 1996 and 1997.
Strategic planning visioning forum was held in February 1998 to get feedback from industry, environmental groups, and local air districts on
lessons learned and future challenges to CA's air program. The SBO developed a "How Are We Doing?" survey for administration to a
broad cross-section of stakeholders.
SBO developed an outreach binder, "California's Clean Air Successes and Future Challenges," which documents the historical success of
CA's air quality programs, in order to earn continued public support for future efforts.
N/A Not applicable N/R No response
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TABLE F-2
(Continued)
PROGRAM
South Coast, CA
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
ACCOMPLISHMENTS
The automated business client tracking system will be used as a prototype in other customer assistance programs. Other SBAPs have
expressed interest in designing a system similar to ours for tracking.
We have had a tremendous response from the local building and safety department from our outreach on permitting clearances. Because
of their frequent staff turnover and lack of awareness of our air quality permit requirements, we need to constantly reinforce these relationships.
SBO program has partnered with the Office of Customer Service's Environmental Customer Assistance Center to assist businesses with
all aspects of compliance.
SBAP is working to create program effectiveness tracking methods in 1999.
In June 1998, SBAP was moved into the Commissioner's Office to coordinate multimedia compliance assistance efforts. While the Office
still dealing predominantly with small business activities, other activities and responsibilities also have been included.
is
N/R
N/R
Developed dry cleaners' compliance assistance calendar.
• In 1998, we received the Director's commitment to provide multimedia assistance to small businesses.
• SBAP published 4 newsletters during 1998. The Small Business Advocate has a circulation of 13,000.
• SBAP updated the Program's brochure (last update 1994).
• SBAP published articles in The Georgia Outreach, Management Update, and Shared Services.
• Developed an informal mechanism for the regional office and enforcement programs to refer small businesses to us for
assistance.
• SBAP revamped our web page and placed it in a more prominent location.
• Governor's appointees to the CAP were sworn-in at the state capital in August.
SBAP, CAP, and SBO met 4 times in 1 998.
For the first time, SBO, SBAP coordinator, and a CAP member attended the annual SBO/SBAP conference.
SBAP coordinator represented the Region IV states at the 4th annual Small Business Liaison Conference in Washington, DC.
SBAP presented information on the SBAP, CAA, and P2 to the Air Branch's new employees during their orientation.
SBAP staff attended the Region IV conference in Biloxi, MS.
Dry cleaning technical assistance program (statewide) was designed and established with the concurrence and support of industry.
During 1998, greater emphasis was placed on business assistance - small business assistance in particular. Agency support has grown
tremendously.
N/A Not applicable N/R No response
-------
TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Illinois
Clean Tech 98 Parts Cleaning Expo.
Town Hall meetings.
Rotary Club meeting - general information about compliance.
We have continued to try to maximize resources by establishing and building partnerships with both the regulators and business
community. We have worked on steering committees for the Great Printers Project, Greater Chicago P2 Project, and IL Gold Star
Dry Cleaner Project.
We implemented a pilot project combining resources of SBAP, IEPA Office of P2, SBDCs, Procurement Technical Assistance
Center, and Manufacturing Extension Center. Companies can receive P2 assessments free of charge from a graduate student intern.
Greater Chicago P2 Project includes local, state, and federal assistance and regulatory programs plus some business organizations.
In a cooperative effort, SBAP developed a directory of programs that may be able to assist companies in the Chicago area. We
continue to use private industry as an effective marketing tool and partner in assistance efforts.
We are attempting to find financial resources to provide multimedia assistance.
Indiana
Wood Furniture - Currently involved in the development of a multimedia pilot project for this industry. Wood furniture is one of IN's first
industries to receive multimedia inspections. Several other industry sector multimedia projects are in the works including metal finishing,
Pharmaceuticals, and electric utilities.
Vehicle Maintenance - Developed a compliance manual that includes environmental, OSHA, and fire and building services regulations.
Conducted 8 workshops throughout the state and made presentations at several trade association meetings.
Mercury & Steel Mills -- In a cooperative effort between US EPA, IDEM, and the steel mills, 3 northern IN steel mills are identifying areas
where mercury is located and establishing programs to get mercury out of the steel mills in the next year.
Mercury Awareness Program » In October 1998, IDEM and the IN Regional Household Hazardous Waste Task Force offered free recycling
of household mercury in every IN county. More than 2,100 pounds of mercury were collected, preventing mercury from reaching IN's air,
rivers, lakes, or streams.
N/A Not applicable N/R No response
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Iowa
We had a multimedia program in place even before the air program started. The IWRC multimedia program and the IAEAP (SBAP)
complement each other, provide clients with "one stop shopping" services, and makes what we have to offer very attractive. In the past year,
we were and are involved with the following projects, in addition to the core program services:
Updated the 1998 Resource Guide (funded by US EPA) and made it available on-line with search capabilities (www.iwrc.org). The
Guide was mailed to all SBO/SBAP programs.
Received SBREFA grant to develop an environmental regulatory handbook for agricultural businesses covering both state and
federal regulations. This is a work in progress.
• Completed an IDNR-funded project to find how many and what type of businesses may be affected by 112(r) in IA. Our study
determined that 112(r) would potentially impact about 4,000 businesses in IA; EPA estimated the number to be about 1,800. This
study and resulting database are being used to provide additional 112(r) assistance.
• Developed industry-specific spreadsheet-based emission estimation programs to generate emission inventories and estimates
for permit applications. Input data are collected from small businesses using a 2-4 page industry-specific questionnaire. The IAEAP
has developed programs for small manufacturing operations, dry cleaning facilities, printers, and grain handling facilities. These
programs are continuously updated.
N/A Not applicable N/R No response
-------
TABLE F-2
(Continued)
PROGRAM
Kansas
Kentucky
Jefferson County
Louisiana
Maine
ACCOMPLISHMENTS
In 1998, KDHE officially expanded the technical assistance program to multimedia by funding the program. In the past, although the program
really was multimedia, funds were provided primarily by air fees. This year, the P2 program and the SBEAP program were officially combined
with one contract and multiple sources of funding through KDHE. We feel that this reorganization has benefitted businesses, since it is less
confusing to them.
Examples of comments include:
The services offered by the Pollution Institute (SBAP) are essential to small industries in rural Kansas. Without the assistance of
these types of programs, it would be extremely difficult for a business of our size to stay in compliance with federal law and KDHE
regulations. Your diligence in helping us function within these laws and regulations is very much appreciated.
• Excellent cooperation.
• This is a great program. [Tim and Sherry] helped us face problems that we wouldn't have tackled alone. Because of them we are
more focused on environmental issues - without being fined!
• Thanks [this is] very helpful.
• Both [Tim and Jean] were very helpful and very professional. I enjoyed working with both! I would not hesitate to call if or when I
need further assistance.
• The help that we received has been excellent. This Pollution Prevention Institute [SBAP] is priceless for small companies like ours.
• I don't think the report could have been done any better. [Jean and Sherry] did an excellent job of inspection and recommendations.
Anything that they weren't sure of, they found out about and they were able to work as a go-between for us and KDHE, making it
possible to get some straight answers from KDHE.
• Great job. Thanks for the help.
• This is a great program. Keep up the good work.
• Excellent resource material made available, and [Tim] was very helpful.
During 1998, the SBSSCAP gave its first annual Small Business Air Quality Stewardship Awards, which were presented by Lt. Gov.
Stephen Henry, MD, at a luncheon at the Lt. Gov's Mansion. The award program has generated good will and publicity for all participants.
SBAP director is routinely invited to share his experience and insights on compliance assistance, partnering efforts, and educational programs
at state and national meetings. In 1998, these events included SBO/SBAP conferences, National P2 Roundtable meetings, Association of
Small Business Development Centers annual conference, Air and Waste Management Association meeting, KY SBDC directors' meeting,
Chamber of Commerce environmental activities, and others.
N/R
One of our engineers was awarded the LDEQ Customer Service Award in December 1998.
We went to the LA Universities' Marine Consortium (LUMCON) in Cocodrie, LA for a 3-day strategic planning session to prepare for re-
engineering and multimedia.
The ME SBTAP is fully multimedia.
N/A Not applicable N/R No response
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Maryland
The P2 program made arrangements for the Mobile Outreach for Pollution Prevention (MOPP) from the IA Waste Reduction Resource
Center to visit two locations in Baltimore. The MOPP is a customized motorhome containing P2 information and demonstrations for the
automotive service industries. Auto body shops and repair facilities in Baltimore City, Baltimore County, and Anne Arundel County were invited
to attend the demonstrations. EPA also attended the demonstrations.
MDE promotes the Businesses for the Bay program, a voluntary P2 program that provides recognition for businesses and other
organizations that implement P2 programs. Businesses for the Bay also has a mentoring program with more than 70 individuals from various
industries offering free P2 assistance. This program won two national awards in 1998, one from the National P2 Roundtable and one from the
National Environmental Education and Training Foundation.
MDE developed and published the Business Guide to Environmental Permits and Approvals, which lists information for all permits,
approvals, and licenses issued by the Department. This document is very useful to businesses and is available on the MDE web site.
Massachusetts
Increasing interaction with enforcement agencies has improved the referral process. OTA increasingly involved in post-enforcement
actions, which helps incorporate P2 into enforcement. Enforcement agencies are taking more advantage of OTA's services, which are
available to them as well as to industry. As long as we maintain our image of service provider to industry, there is no bar to working with the
enforcement agency.
Michigan
SBO - none.
SBAP - Trained more than 1,800 business, industry, regulatory, and consulting personnel during 1998 at 18 workshops held statewide.
SBAP also provided a number of presentations to business, industry, and government personnel in 1998, attracting a listening audience of
over 1,274 at 15 engagements. The technical service provided or customer service displayed is reflected in 9 letters of appreciation that were
written by either industry or other state government agencies commending SBAP staff on the excellent level of technical assistance
(information and service) that was provided.
N/A Not applicable N/R No response
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Minnesota
The Small Business Environmental Improvement Loan Program has made more than 25 loans that collectively amount to over $890,000.
These loans have helped the businesses make significant environmental improvements in their operations while giving money back to the loan
program through principal and interest payments. The program has had zero defaults, allowing the revolving fund to grow and offer loans to
other businesses.
SBAP successfully coordinated with other external service delivery providers to develop an environmental guide for small businesses. The
free guide includes comprehensive multimedia information on all environmental regulations with which all small businesses need to comply.
SBAP successfully created, maintains, and distributes the "Small Business Enterprise," a quarterly newsletter for the small business
community. This newsletter has been well received and has been an effective tool for communicating information to businesses and for
marketing the program.
SBAP produced and distributed a video tape on the use of aqueous finishes for the wood finishing industry.
SBO and SBAP were part of an agency-wide reorganization from a traditional media-based structure to a multimedia/geographic-based
organizational structure. The reorganization also includes a sector-based approach. SBO and SBAP have been assigned to work in the
regular facilities sector and have been given the opportunity to expand the program into a multimedia format.
Mississippi
Our program has made the move to multimedia, and it is working well. Customers expect us to have knowledge in all areas. By our
multimedia efforts, customers have one point of contact to get a variety of questions answered.
Missouri
The P2/Compliance Guides have been well received by industry. The guides are written in an easy-to-understand format providing the
information necessary for the facility to comply with regulations, but also providing P2 opportunities and ideas.
The On-site Assessment Team is visiting many facilities across the state, and their services have been well received. Facilities visited
receive a comprehensive, yet easy to understand report illustrating the areas that need improvement and the areas where they are in
compliance. The report also includes P2 tips and opportunities.
The regulatory programs have commented that when a facility submits an application for a permit or other required documentation that the
Technical Assistance Program has helped them to complete, the application or document takes much less time to review and process.
Montana
SBO/SBAP created the Small Business and Tribal Energy and Environmental Loan Program in 1998 and has extended over two dozen
loans to service stations, auto body shops, and small manufacturers for the purchase of energy efficient and P2 equipment.
SBO/SBAP expanded by one full time employee and now offers multimedia assistance to small businesses.
Mark Lambrecht, SBO/SBAP Manager, was awarded the 1998 MT Governor's Award for Excellence for his role in resolving a dispute
between a small business and its neighbors and for creating the loan program.
N/A Not applicable N/R No response
8
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TABLE F-2
(Continued)
PROGRAM
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
ACCOMPLISHMENTS
SBAP progress is seen in the development of an ever increasing network of partners and peer exchange businesses. Large businesses
and consulting firms are taking a more proactive role in working with small businesses to expand the assistance outreach. The NE DEQ
created a new division' to'better serve its customers. The Customer and Technical Assistance Division includes the Pollution Prevention
Coordinator, Community Right-to-Know person, SBAP, NE Mandates Management Initiative, and the Grants and Planning Unit.
SBAP has been multimedia since inception. Administration's position was that staff should provide such assistance for all types of
environmental programs and issues. SBAP staff were instrumental in web site development and getting the site online.
The Program continues to be well received by the small business community. An ever increasing majority of referrals for technical assistance
are through conversations between business owners. This is primarily due to the conscious attempt by Program staff to break down the
barriers of mistrust that often exist between business owners and regulatory agencies.
Through public and private partnerships, we are making great strides in getting business owners to realize that environmental compliance
does not necessarily mean economic costs. An example of this "new" attitude was evident during a recent on-site visit conducted by the
Program where the business owner noted that he was informed by a DES inspector that acetone storage containers needed to be covered at
all times unless product was being added or removed. The business owner told me that by conforming to this regulation, he had reduced his
acetone purchases by over 50%.
SBAP serves on EPA's National ChemAlliance advisory board.
SBAP worked in conjunction with EPA, trade/business groups, and chemical manufacturers on the NJ Chemical Industry Project, which
developed compliance assistance materials for medium and small businesses both in hard copy and online (through a new web site).
N/R
N/A Not applicable N/R No response
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
New York
Considering its small staff size, SBAP provided a significant volume of technical assistance to small businesses in New York State. SBAP
provided off-site assistance via the hotline to over 100 small businesses and their support groups per month, conducted 17 air audits and
completed 66 state facility permits and registrations.
SBEO handled about twice as much volume as it did in 1997 with the same staffing level. SBEO provided hotline assistance to an average of
60 small businesses per month and completed an average of 6 ombudsman cases per month.
SBAP generated significant volume of technical outreach materials in 1998 that are well received by businesses: 10 fact sheets describing
compliance options for halogenated solvent degreasers, one fact sheet for capping operations for sources with PTEs above major thresholds,
10 generic compliance plans for New York State dry cleaners (by equipment type and facility location), and two issues of the program
newsletter, Clean Air News, mailed to over 4,000 per edition. SBAP also developed a database of environmental consultants by geographic
area and by expertise. A survey of companies audited is planned.
Together, the SBEO and SBAP reached about 5,000 more small businesses than it did in 1997 (a 25% increase) and provided direct
assistance via the hotline and on-slte audits to about 400 more small businesses than in 1997 (a 20% increase).
SBEO received an Award of Excellence from the New York State Library Association for the production of the Environmental Audit Guide for
Small Business.
SBAP and SBEO continue to receive letters and comments of appreciation from small businesses.
North Carolina
One of the primary accomplishments this year was to strengthen our links with the Department of Commerce and local economic developers
and to improve our multimedia response capability. As an appointed Departmental Permit Team Coordinator, I worked with all permitting
agencies and business representatives to facilitate a new company's understanding of environmental requirements. While the business
assisted was not a small business, the contacts, knowledge of requirements and processes are very transferable to small businesses. Also
served on a number of work groups to develop better communication and coordination on permitting and other environmental requirements.
The results will be a department-wide customer service center, which will be located with this office.
Our cooperative venture with air quality to develop training for potentially affected sources of 112(r) was an important accomplishment
toward better liaison with our air quality regional staff and to introduce our services to a number of unpermitted sources.
North Dakota
Nothing outstanding to mention.
Ohio
SBAP played a significant role in implementing OH EPA's non-Title V fee system. The SBAP was part of a hotline pool designed to help
companies estimate their emissions and complete their fee reports.
SBAP supervisor was temporarily reassigned as the Manager of the Mobile Sources Section from October 1997 to August 1998 and an SBAP
specialist left for other employment in July 1998. SBAP effectively operated with only three people throughout 1998 and without a supervisor
for ten months.
N/A Not applicable N/R No response
10
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TABLE F-2
(Continued)
PROGRAM
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
ACCOMPLISHMENTS
We believ.e we have continued to pioneer the simplification of rules for small businesses. In particular, the SBAP staff has worked with the
air quality division staff to ensure that any new rules passed or the revision of existing rules is done in a manner that is not overly burdensome
to the small business community and accurately reflects what is best for them and for our agency.
None.
As of December 1 , 1 998, the technical assistance program known at AIRHELP expanded to include solid waste, hazardous waste, P2, energy
efficiency, and environmental management systems as well as air quality. The new program is called ENVIROHELP.
Legislation was passed creating the Small Business Pollution Prevention Assistance Account, which is a revolving loan fund that will
finance P2 and energy efficiency projects.
SBO has taken a more active role on the SBTCP. A cooperation agreement between Environmental Quality Board and Commercial
Development Administration was signed in December. The agreement will combine funds to operate the SBAP and SBO, increasing the
participation of Commercial Development Administration and its contacts in the small business community to raise awareness of environmental
regulations. The results of this agreement will be seen during the next reporting period.
Participated in an international technology transfer workshop by hosting a delegation of environmental experts from China. The group
(through translators) learned about the regulatory process to control and prevent air and water pollution in Rl, and nonregulatory assistance
programs to help industry comply with environmental regulations.
URI professor Eugene Park (Center for Pollution Prevention) received EPA Region I's Environmental Merit Award for his P2 work with
various manufacturing industries in Rl. Industries that Dr. Park has worked with include seafood processing, electroplating, and nickel plating.
N/R
N/R
Satellite teleconference downlinking: consumer products, printers.
Division of Community Assistance multimedia support.
Workshop manuals.
SBO support of EPA's RTP education and outreach group.
112(r) workshops.
Site Visit Program - To provide better service to small businesses and to leverage our resources to gain the maximum effort for our dollar, TX
SBAP initiated the Site Visit Program. We are able to provide free, confidential site visits to small businesses by contracting with a private
environmental consultant. Site visits were requested bv over 177 small businesses in FY98.
N/A Not applicable N/R No response
11
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Texas (cont.)
Surveys taken after the site visits found small businesses had made significant changes based on the consultant's recommendations. The
program's overall result was a significant increase in compliance. Baseline compliance with air regulations for all industries averaged 78.4%
and air regulations averaged 70.1%. Year-end compliance with air regulations increased by 11.6% to 90%, and compliance with waste
regulations increased by 19.9% to 90%. For example, waste regulation compliance among automotive repair facilities increased by 26%, while
compliance by autobody shops increased by 19%. Site visits also spurred more small businesses to recycle and use environmentally friendly
solvents and in turn reduce waste and cut disposal costs.
EnvlroMentor Program - Matches volunteer environmental professionals with small businesses that need compliance assistance.
EnviroMentors provide free, on-site, confidential assistance including identifying areas of noncompliance, suggesting ways to cut costs, and
assisting with permit applications. In 1998, 8 businesses were reached with 120 hours volunteered. Volunteers saved small business owners
over $7,050 through voluntary assistance. In 50% of the matches, volunteers assisted businesses with hazardous waste management. Other
areas of assistance included above ground storage tanks, stormwater permits, Voluntary Cleanup Program, and exemption from air permitting.
Star Program - A grant from the TX Natural Resource Conservation Commission kicked off the state's first training course in the Spray
Techniques Analysis Research (STAR) program. Developed by the IA Waste Reduction Center, STAR teaches participants how to use spray
painting equipment in an environmentally friendly manner. STAR students learn an efficient method that reduces the amount of spray paint
going into the air instead of on the vehicle, which also reduces VOC emissions that contribute to ground level ozone. Students learn how to
reduce pollution, cut costs for the disposal of hazardous paint wastes, and gain a new skill that strengthens their employment opportunities.
TNRCC won a second place award from the National P2 Roundtable's 1998 Most Valuable Pollution Prevention Program.
Foundry Initiative - A new SBAP outreach effort, the foundry initiative, was created to inform foundry operators about environmental laws. In
FY97 and 98, SBAP staff conducted workshops and site visits, and developed a self-audit checklist for foundry operators. These efforts
resulted in compliance increase for foundries: air compliance shot up from 52% to 93% while waste compliance rose from 68% to 75%. Key to
the initiative was promoting the reuse of foundry sand for the TX Department of Transportation road and highway projects. Collaboration
among the TNRCC, EPA, TXDOT, foundry associations, and the TX Manufacturing Association Center made the initiative a success.
Consolidation of Compliance Assistance Offices - Help for small business should be enhanced following the new merger of three
assistance programs at TRNCC. The SBAP has merged with the Regulatory Assistance section (local government assistance and education
and outreach programs) and the Office of Pollution Prevention and Recycling. The merger creating the new Office of Small Business and
Environmental Assistance, which will be completed by September 1, is a result of a review of the agency's business processes conducted in
October 1997 by TechLaw, a consulting firm.
The new division will not only continue to offer free, confidential technical assistance and services to small businesses, it also will enhance P2
and education efforts and remain independent of TNRCC's enforcement program. Small businesses are ensured a voice in the rulemaking
process through the Rule Review Committee, Small Business Advisory Groups, and the CAP. The new division will continue to seek small
business input in the design of agency guidance documents, reporting forms, and applications through the Statewide Plain Language
Committee. Twenty of the positions in the new division will be moved to regional offices around the state, increasing Texans' access to
TNRCC staff and services.
N/A Not applicable N/R No response
12
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TABLE F-2
(Continued)
PROGRAM
ACCOMPLISHMENTS
Texas (cont.)
Small Business Enforcement Tracking Report - The first tracking report was completed in September 1998. The report's purpose is to
identify common environmental trends and problems experienced by small businesses. A summary of data collected from FY96 to FY98
identified enforcement issues for small businesses and included the following:
Most enforcement orders are issued to small businesses.
• The percentage of enforcement orders issued to small businesses increased.
The average penalty for small businesses increased.
• The number of default orders (enforcement orders that companies do not respond to) increased from 5 in FY96 to 68 in FY98.
• 91% of default orders issued in FY98 were to small businesses.
The report also notes that small businesses have participated in fewer Supplemental Environmental Program (SEP) options than large
businesses. SEPs are an alternative method of paying penalties through community projects.
The Office of Small Business and Environmental Assistance (SBEA) will use the tracking report to improve outreach, help small businesses
achieve compliance, and meet its goal of minimizing enforcement issues in the small business community. SBEA has made the following
recommendations: revise the automatic enforcement referral criteria, allow a one-year inspection exemption to small businesses that
participate in the SBEA site visit program, promote SEPs, rewrite the TNRCC enforcement letters for clarity, and get other TNRCC programs to
begin tracking small businesses and their specific types of violations. SBEA is drafting an enforcement process fact sheet that will be attached
to the Notice of Violation and Notice of Enforcement letters and will be distributed by inspectors during visits. The fact sheet will explain the
enforcement process and the actions required by a business that is under enforcement. With a better understanding of the enforcement
process, the business has a greater chance of reaching compliance.
Grant Received to Conduct Site Visits for Border-area Small Businesses - TNRCC received a $50,000 grant from US EPA to offer site
visits through August 1999 in border communities from El Paso to the Lower Rio Grande Valley. This grant will fund approximately 33 site
visits including an initial visit and a follow-up visit.
Metal Finishers Common Sense Initiative, now the Strategic Goals Program - An SBAP staff member participated in the initiative, which
involved quarterly meetings between EPA, POTWs, and the metal finishing industry about how all parties can work together to reduce pollution
and improve the industry's compliance status. The meetings provided a beneficial forum for networking with other compliance
assistance/enforcement staff to share outreach information.
SBREFA Grant - SBAP received this grant to work with Southwest Texas State University (SWT) to develop a stormwater regulatory fact sheet
and an initiative for the chemical preparation industry. SWT researched stormwater rules and compiled a draft fact sheet. SBAP further
developed and completed the fact sheet and had the final version published for distribution to small businesses to assist them in complying
with applicable stormwater regulations. For the chemical preparation industry project, SWT researched databases and compiled a list of
chemical preparation facilities in TX. SWT surveyed these businesses on their basic environmental regulatory knowledge and needs and
produced a final report. Survey results reflected business size and identified compliance issues. These results were presented to SBAP staff.
SWT developed a draft chemical preparation facility fact sheet, which SBAP may enhance and finalize in the future.
N/A Not applicable N/R No response
13
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TABLE F-2
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
ACCOMPLISHMENTS
N/R
No awards, recognitions...
SBAP has been relocated into a new division within DEQ - The Pollution Prevention and Compliance Assistance Division. One result of this
move is the increased opportunity to provide multimedia assistance with the hopeful addition of resources.
SBAP continues to be very proud of EPA's Leadership Grant to explore and provide compliance assistance and P2 information through the
Internet and the development of our web site. Development is almost complete, and we are looking forward to training the small businesses
and continuing to provide this resource. Please visit us at www.dep.state.va.us/osba/smallbiz.html.
We are recommending to the DPNR Commissioner that our program should go multimedia.
Web pages have been well received.
New employee, who provides technical assistance, completed CARB 100 series training class and successfully completed ISO 14000
Lead Auditor course and corresponding examination.
The creation of a Coal Handling/Preparation General Permit has simplified and streamlined permitting for this industry sector.
N/R
A highlight of our outreach efforts this year was the production and broadcasting of a positive P2 advertisement highlighting our Department's
goal to reduce pollution in our state. The package was contracted to a local firm, produced using photography from WY, and used an excellent
western theme musical background. The advertisement was broadcast via radio and television across the state. The project was funded
through a federal P2 grant and generated numerous positive comments.
N/A Not applicable N/R No response
14
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TABLE F-3
TIPS AND BARRIERS RECOGNIZED BY THE PROGRAMS
PROGRAM
Alabama
Alaska
Arizona
Maricopa County
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
TIPS/BARRIERS
N/R
None to
report at this time. The program is running smoothly.
N/R
Tips
•
•
•
Barriers
•
Direct mailings signed by Director (regulatory body) are more effective than letters from SBEAP.
Specific time limits and deadlines are better than saying "as soon as possible."
Faxes work better than calling if reminding sites to submit their permit application.
Disputes within department related to de minimus status determinations and what SBEAP can do for sites related to that issue.
Regulators would like sites to submit applications, then tell the sites they are exempt. This is costly and time consuming if they are
clearly exempt. SBEAP staff does not tell sites they are exempt, rather, educates them on the rules and thresholds.
N/R
Tips
•
Tips
•
•
Continually update the organization's web site so that information is readily accessible and current. In 1998, we achieved a 90%
rate via search engines by thoughtful use of meta tags. This means that out of the 2,5 million hits on our web site in 1 998 - a
remarkable number - approximately 90% of the requests found some information related to their inquiry.
hit
The automated business client tracking system will be used as a prototype for other customer assistance programs. Other SBAPs
have expressed interest in designing a system similar to ours for tracking work.
We have had a tremendous response from the local building and safety department from our outreach on permitting clearances.
Because of their frequent staff turnover and lack of awareness of our air quality permit requirements, we need to constantly reinforce
these relationships.
N/R
Tips
•
We continue to succeed in delivering a multimedia message to sector-specific small business categories. We have contracted
our outreach efforts on new regulatory requirements, but use these opportunities to provide small businesses with a refresher on other
regulatory areas that affect them.
N/R
Barriers
•
The program will be better run when there is a dedicated full time person who can develop and implement a plan for the program. For
the oroaram to achieve its qoals, the three oraqram components must be in place and operational, which is not the case for DC.
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
TIPS/BARRIERS
Florida
Barriers
GAP appointments are legislatively mandated, but do not establish a service term. This creates a difficult situation when CAP
members do not participate yet want to "stay on" the CAP. We are trying to resolve this issue at present.
Georgia
Tips
In 1998, SBAP adopted the rules of Customer Service, prepared by US EPA, after tweaking them to meet our needs. We assigned
activities to a specific person and listed backups for each activity. We did this when we prepared our annual work plan. This allowed
the program to run more effectively while the Agency was undergoing major changes.
Hawaii
Barriers
Existing advisory groups speak against a formally appointed CAP. Too few people have the time or inclination to serve on yet
another advisory group.
CAP requirement raises questions as to the legitimacy of their specialized ad hoc advisory groups (e.g., Barbers Point/CIP Air
Quality Advisory Task Force).
Unanswered questions as to the authority of the CAP where multimedia (non-air) issues are raised.
Idaho
N/A
Illinois
Tips
Our program is located in the economic development agency for IL. We have found it essential to meet regularly with IEPA
Bureau of Air to be effectively incorporated into the delivery system at the agency. Maximized communication has been the key to
any successes.
Outreach followed by an aggressive enforcement schedule helps to maximize the calls for assistance. Businesses need an
incentive to reprioritize their compliance responsibilities.
Private partnerships serve as the most effective marketing tool for SBAP program activities.
Indiana
Tips
Barriers
SBAP has been able to improve the environment and assist businesses more broadly than some SBAP programs due to our
multimedia focus. Being able to expand beyond air issues allows small businesses to see the larger picture and stay in contact with
all program areas.
CAP provides only limited guidance and does not have a full panel.
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
Iowa
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
TIPS/BARRIERS
Tips
Effective assistance to small businesses needs to be more than "why, where, and what to do." Details of "how to" should be an
integral part.
• Generic guidance materials, workshops/seminars are not very effective for "typical" small businesses. Targeted and detailed
specific information is better received and is more useful.
Barriers
• Provide an incentive for legislators to appoint CAP members.
• Resources. Adequate staff training.
Tips
• We are trying to work with trade associations and local programs more effectively by piggybacking on existing programs or events.
We provided a workshop in conjunction with the national screenprinters teleconference to provide additional state-specific information
and answer questions.
N/R
N/R
Tips
Small business owners prefer evening meetings and seminars because it detracts less from their daily routines.
We use "contacts" and "assists" to maintain a record of our activities.
We mail performance evaluation forms to clients.
• Technical assistance sites are found in major cities across the state.
• We use laptop computers to perform paperwork at site visits.
• We use spreadsheets to determine VOC content of paints.
• A database helps us maintain complete records and prepare reports of our activities.
• Cooperation with the surveillance section is key to assisting small businesses with NOVs.
• Serve "King Cake" at all meetings during Mardi Gras season.
Tips
• Since our SBTAP only has two staff, it is very important to use the skills and expertise of staff from other programs and
organizations to assist in delivering services.
N/R
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
TIPS/BARRIERS
Massachusetts
Tips
Barriers
OTA developed software to assist companies in tracking VOCs and chemical use. Office mailed notice of availability to industry
with mail-back postcard to obtain free disk. Programs also available on the web site.
OTA identified a regulatory barrier to zero discharge system, promoted resolution through Common Sense Initiative. CSI council
adopted resolution for EPA to address this problem.
Michigan
Tips
SBO and SBAP should work very closely with the air quality regulatory program PRIOR to initiating any outreach. For example,
the Ml SBAP has worked closely with its air quality regulatory agency, along with business and industry, to address various air quality
compliance issues prior to workshop implementation. This process was most especially useful when SBAP conducted its emission
reporting workshops in November 1998 where a new electronic reporting system was being instituted. By holding a "peer review"
training session prior to implementation of the actual statewide business and industry workshops, the SBAP was able to modify its
presentation materials to reflect the comments and suggestions of business, industry, and regulatory personnel to make the workshop
presentations as clear, concise, and smooth-flowing as possible.
Minnesota
Tips
Barriers
Maintain a hotline and always have it answered.
Use a standardized newsletter to convey information and market the program.
Market the program through the use of trinkets. Refrigerator magnets have been a big hit.
Provide free sector-specific spreadsheets to businesses for recordkeeping or determining other compliance issues.
Make networking with other service delivery providers a priority.
Provide on-site assistance.
Develop sector-specific workbooks, videos, training, etc.
Funding (always).
A lack of state or federal statutory authority to move towards multimedia assistance.
Rules that don't make sense.
Opposing philosophies on the benefits on non-regulatory assistance.
Inconsistent enforcement methods.
Mississippi
N/R
Missouri
Tips
Our on-site team is implementing a procedure of performing follow-up by tracking each facility visited. Follow-up will be done by
either contacting the facilities, recording calls for additional help by the facilities, or reviewing written responses by the facilities in
regard to the assessment report.
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
TIPS/BARRIERS
Tips
• Ensure a strict eligibility criteria when creating a loan program to create fairness in reviewing proposals. However, don't make
them so restrictive that businesses lose interest.
Barriers
• Location of SBO/SBAP within a regulatory/nonregulatory agency creates problems with some, because they do not trust
government.
N/R
None at this time.
Tips
• Developing state- and sector-specific compliance/best management practices manuals is an optimum way to foster compliance.
The manuals must be as narrowly focused as possible for use by small business owners, as they do not have time to determine if
something is applicable or not.
Actual small business owners need to be consulted during the manual development stages to determine if the information is
appropriate and is written in a manner consistent with the "lingo" understood by the reader.
Barriers
• A major problem we identified in providing outreach and assistance to small businesses is the lack of accurate information on who
and where they are. We have minimized this problem by using computer-based data sources (such as ProCD's Phone Select
Program) and developing a close working relationship with local code enforcement personnel.
Tips
SBO/SBAP have worked with trade/business groups to sponsor/cosponsor events to ensure their members' participation and
provide greater outreach without cost to the SBO/SBAP.
to
N/R
N/R
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
North Carolina
North Dakota
Ohio
Oklahoma
TIPS/BARRIERS
Tips
• The Department established a Permit Information Center, which is attached to our office. The Center was originally staffed with
senior permit writers who were on loan for a six month rotation period. While program divisions were not thrilled about giving up staff,
they benefitted from the cross media training and received a picture of the larger regulatory puzzle. This was very valuable to the
SBAP and SBO in developing user friendly guidance materials and providing an immediately available resource to provide multimedia
technical assistance.
Barriers
• We have had significant problems getting timely appointments of CAP members. The specific requirements for minority and
majority legislative appointments, the turnover in executive staff, and appointments to a purely advisory body have created problems.
1 believe a better solution may be to mandate an advisory body with broad-based membership, but not necessarily through the
appointment process.
No suggestions.
Tips
• An SBAP should have a working relationship with the state's inspectors and permit processors, since they are the only "EPA"
people a business is likely to deal with directly. Have the SBAP staff visit district inspectors and go on inspections with them. In OH,
the SBAP site visits are made to resemble an actual inspection so the company can learn what to expect.
• Have the SBAP produce a useful tool (source-specific permit exemption, emission calculation spreadsheet, etc.) for permit
writers or inspectors to use.
Barriers
Getting the legislature to appoint new CAP members to vacant positions is very slow and tiresome.
• Constant reminders of how negative an image of government is held by many small businesses.
Tips
• Our program has benefitted from being housed in the Customer Service Division within the Agency. This has allowed us, through the
years, to develop relationships and in-roads with key staff members and decision makers within the regulatory division. This
was a very unique approach to environmental regulatory agency organization, that is, to have a group that includes the SBAP that is
dedicated to providing nonregulatory technical and regulatory assistance to business and industry in the state. This gives us
autonomv from the reaulatorv arouos. but still allows us to network internally.
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
TIPS/BARRIERS
Tips
• We have found that generic P2 classes offered through the SBDCs are not effective. Since businesses are doing well right now,
they do not appear to be interested in extra curricular training. The hazardous waste division has been very successful in getting
people to attend their training classes. Without regulatory requirements for P2, people are not interested.
Barriers
• The program needs to be multimedia to be more effective. DEQ's current organization prevents this from happening. We currently
are exploring the possibility of a multimedia technical assistance program. Funding seems to be one of the biggest barriers.
N/R
N/R
Barriers
• One major barrier to our program is Rl's Operating Permits Commission. This Commission, the only one of its kind in Region 1,
was put together by our Department's Office of Air Resources as a way to solicit funding for FTEs that are paid out of the Operating
Permits Program. Since the SBAP is funded by Operating Permit Fees, the members of this Commission prefer that the SBAP
perform only air assistance. Since the SBAP is an assistance program, it responds to the needs of small businesses on all media
issues. Further, it is impractical for the SBAP to not respond to other environmental needs of small businesses. Certainly, the SBAP
would be failing in its mission as an assistance program if it was impeded from performing the assistance duties mandated in CAA
Section 507.
N/R
N/R
Tips
• We have structured and modified TN's program to meet our perceived needs to effectively use resources while not engaging small
employers unnecessarily.
N/A Not applicable N/R No response
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TABLE F-3
(Continued)
PROGRAM
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
TIPS/BARRIERS
Tips
• Send regular postcard regulatory updates to industries identified as affected or in need of compliance assistance. Examples of
regulatory updates SBAP mailed in 1998 include SBAP's newsletter, The Advocate, a quarterly publication containing regulatory
updates of concern to small businesses; and metal finisher and foundry postcards.
• Send notice of proposed new regulations or rule amendments and regulatory guidance documents to affected business and
trade associations for input/review. Examples of notices/documents SBAP mailed in 1998 include proposed revisions to concrete
batch plant standard exemption, changes to emission inventory reporting, proposed NESHAP for coating of plastic parts, risk
reduction rule, stormwater fact sheet, special waste frequently-asked question sheet, TX Pollutant Discharge Elimination System
(TPDES) frequently-asked question sheet, spray booth air flow calculation frequently-asked question sheet, draft EPA guidance
document on potential to emit, Proposition 2 brochure, article on EPA's general permit for confined animal feeding operations (CAFO),
TNRCC's Wastewater Permits Section TPDES web pages, EnviroMentor program summary, enforcement process summary, and
SBAP web page changes.
N/R
Tips
• Develop and keep a rapport with the regulatory program staff. This has resulted in a lot of regulatory program referrals of small
businesses needing assistance. Regular division updates are given (by SBCAP) to keep the regulators and general staff informed.
Barriers
• Resource constraints can hamper our ability to provide on-site compliance assessments - what we see as a most essential element
of providing credible compliance assistance.
N/R
Tips
• OAPCA's Spray Coating Manual is a valuable multimedia compliance information tool.
• All state agencies cooperated in a series of fugitive dust control for construction sites seminars given to industry.
None in 1998.
N/R
N/A Not applicable N/R No response
8
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TABLE F-3
(Continued)
PROGRAM
TIPS/BARRIERS
Wyoming
Tips
One of the keys to success with our CAP was personal SBAP attention in identifying potential CAP members and encouraging
the appointing officials to consider them for appointment. By doing that advance ground work and then following up with the
appointing officials, we were able to complete our CAP appointments/re-appointments and maintain a strong team that is making
great strides in dealing with the issues before them. Sending one of our new members to the CAP training in Scottsdale, AZ early in
the year was another key to this success.
The SBO is working to improve coordination between the Office and the regulatory staff in our Department. Considerable
progress has been made. In 1999, we will improve our coordination and cooperation with all program personnel in the Department to
optimize the services we provide to the businesses that operate in those sectors.
N/A Not applicable N/R No response
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TABLE F-4
SUCCESS STORIES AND CASE STUDIES
PROGRAM
Alabama
Alaska
Arizona
Maricopa County
Arkansas
SUCCESS STORIES AND CASE STUDIES
N/R
CAO was the subject of an independent study done by the University of AK. The study was designed to determine how small and medium
sized firms viewed various state assistance programs and how to improve services to smaller businesses. One interesting factor that came out
of the focus groups was that the companies that had dealt directly with the CAO/SBAP were happy with the service received. They stated that
they would call again if they had a question and would recommend other companies to do the same.
N/R
Using the Internet's Yellow Pages for direct mailings has been successful. The information includes zip codes, telephone and fax numbers,
and is more up-to-date. We can also segment by city and within industries for a manageable workload. Brought many new sites into
compliance.
Newest idea: Only send the application pages that apply to the business. The current application is a "catch all" for all industries and is 10
double sided pages. When businesses receive the application, they are overwhelmed and confused. In most cases, most would receive 3
pages under the new plan. This would prompt them to complete the application more quickly as well as saving the Department postage and
paper.
Success story (edited letter dated 2/24/99 from Delores M. Bryson; Safety, Health, Environmental, Training, & Waste Coordinator; Imperial
Lithography & Dryography; Phoenix, AZ to Richard Polito):
/ am the Safety, Health, Environmental Training, & Waste Coordinator at Imperial. April 24, 1996, EPA Region 9 came in and did a 7 hour
audit. And after having been laid off only a few days before this, 1 returned to Imperial as a consultant, per Imperial's request. And with your
help, 1 was able to meet all of the demands of EPA Region 9. You started me on the right path in 1996. 1 still have your letters and the notes 1
took when you were helping me regarding what, how, who, and all the other ideas you had. Therefore, 1 wanted to say Thank You!
Beginning in 1996, Imperial has reduced waste disposal by 10.9 tons or 21,800 pounds and VOC emissions from 39 tons (78,000 pounds)
down to 2.9 tons (5, 761 pounds). Imperial did not have to pay a VOC emission fee for 1998.
Judy Anthony, EPA VOC Emissions Audit Department, called me last Thursday, February 18, 1999, to give me "An Atta Girl," because my
yearly report was perfect the first time and because the VOCs were extremely low. Judy wanted to know, "how did you do that?" First, all
alcohol usage stopped April 16, 1998; second, the highest VOC-emitting ink is 2.69 pounds/gallon; and third, solvents are down from 6. 79 to
.20 pounds/gallon. 1 was enlightened; this is a record for a large commercial printing company equivalent to Imperial in the state of Arizona.
Two years later after the first 1996 critical situation, with your help and focused in the correct direction, Imperial surpassed all governing
agencies' expectations. 1 wanted you to understand, all your time and efforts have been and are helping many businesses and is very
appreciated.
N/R
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georaia
SUCCESS STORIES AND CASE STUDIES
For ARB's Ombudsman's Office, the case began with a call from the Executive Director of a business association in CA indicating a local
District was about to close a rendering plant after issuing a number of Notices of Violation. The hot weather, among other adverse conditions,
was resulting in the deaths of a number of large animals. The carcasses were piling up and creating an odor problem, because the rendering
plant was not accepting carcasses.
The following people became involved as the Ombudsman's Office facilitated discussion and resolution of a major growing health and air
pollution problem: the local Air District, the CA Department of Food and Agriculture, residents around the rendering plant, the ARB Chairman,
the Secretary of Cal/EPA, an assemblyman, the animal hauler, the CA Department of Health Services Director, the communicable diseases
officer, local landfill operators, local health and environmental officers, and CA's Integrated Waste Management Board.
The matter was resolved in two days by securing landfill permits and reaching agreement between the local District and the rendering plant for
correcting the Notices of Violation. Thus, through good efforts, the ARB Ombudsman's Office helped various stakeholders to engage in
constructive dialogue to resolve a multimedia problem in an expedited manner.
1 . Individual courtesy phone calls to companies whose permits were about to expire, without the possibility of reinstatement, resulted in over
3,600 permits being reinstated and companies returning to compliance. The agency increased its revenue, and the companies avoided
potential costs associated with applying for new permits or receiving penalties.
2. SBAP staff attended the annual National Autobody Congress and Exhibition where they informed manufacturers about compliance
problems and new regulations affecting manufacturing customers, thereby extending the resources of SBAP.
SBO and SBAP teamed up on behalf of a small business sand and gravel mining operation. The company ran into problems with enforcement
via a routine air inspection, which resulted in a NOV and subsequent fines. SBAP worked one-on-one with the owner to address the
compliance deficiencies (i.e., completing the APEN/permit/control plan paperwork). The SBO represented the owner through the Compliance
Order hearing and was able to negotiate the penalties to a minimum. The result of our team effort was the company quickly came into
compliance and was able to continue to operate without any real hardships.
N/R
N/R
N/R
1 . Mailed over 2,000 calendars to dry cleaning/laundry service businesses.
2. Developed and mailed a fact sheet for degreaser industry sector.
N/A
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
Hawaii
Idaho
Illinois
Indiana
SUCCESS STORIES AND CASE STUDIES
Multi-agency and Media Issue Resolution - A farmer seeking to obtain and utilize an agricultural burning permit to dispose of various waste
items that he " inherited" on land recently leased from the State of Hawaii sought assistance from the SBO. The SBO negotiated a waiver of
lease rent with the state land agency on behalf of the farmer, which was equivalent to the cost of appropriate collection, transportation, and
disposal of the non-agricultural waste (e.g., plastic nursery pots, treated lumber, tires, and wrecked autos) associated with the previous tenant.
The SBO sought and received clarification from the air program with regards to the farmer's agricultural burning permit. The farmer was not
required to segregate non-combustible items from his burn pile (e.g., unpainted concrete spoils and bricks) prior to burn. The farmer did not
incur waste disposal costs for that which he was not responsible. The state land agency treated a new lessee fairly and ensured that waste
was appropriately cleared from its land inventory, without incurring new costs. The air program demonstrated flexibility in its administration of
the agricultural burning permit.
Clarity and Compliance - A new dry cleaning establishment was unaware of appropriate protocols associated with the disposal of spent
perchloroethylene (PERC). Within three working days, the SBO facilitated the issuance of an EPA ID number for the dry cleaner. The SBO
also ensured that the dry cleaner received compliance information and submitted a covered source general permit application with the air
program.
N/A
Assisted a small fiberglass company (1 1 employees) to expand operations by facilitating its state air permit through the regulatory agency and
assisting with completing the permit applications.
IN's SBAP (CTAP) helps businesses each and every day to not only come into compliance, but to go above and beyond. Several industry
sectors have received assistance through one of CTAP's integrated education programs. These programs include the development of a
compliance manual that not only provides the rules/regulations for the environmental requirements, but also covers OSHA, DOT, and
Department of Fire & Building Services' rules. In addition to compliance manuals, the integrated education program also includes workshops,
on-site assistance, and a 5-Star environmental recognition program. The industries CTAP has successfully worked with include dry cleaners,
vehicle maintenance, fiberqlass, wood finishers, child care, and auto refinishers.
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
SUCCESS STORIES AND CASE STUDIES
Iowa
Company D is an Iowa facility that produces toy models.
In February 1996, Iowa Department of Natural Resources (IDNR) visited Company D, cited violations with permitting requirements, and
Company D was asked to attain compliance within 60 days. Company D initially contacted a consultant and received estimates in the range of
$15,000-20,000 to complete the required permit applications.
In June 1996, Company D requested assistance from the Iowa Waste Reduction Center (IWRC) in determining air permitting regulatory
requirements. Company D was referred to the IWRC by the IDNR. Following a review of company operations and air emission sources, the
IWRC determined that Company D needed "existing" air quality construction permits for five spray booths, two drying ovens, one paint stripping
hood, four aluminum melting furnaces, and one burn-off oven.
After completing the initial air emission review, the IWRC assisted Company D in completing construction permit applications for the existing
sources. Company D saved at least $15,000 on completing the 13 required permit applications. These applications subsequently were
approved by the IDNR, and construction permits were issued for the 13 sources.
IWRC and Company D identified a concern about the approved permits. Particulate matter (TSP) stack testing and opacity testing were
required for each of the five spray booths and the single burn-off oven. TSP testing for six stacks would cost approximately $12,000, while
opacity testing for the sources was estimated at $1,800. IWRC worked with Company D to respond to IDNR's requirements and propose an
alternative stack testing regime. IWRC proposed to conduct one TSP stack test, eliminate opacity testing, and do additional stack testing only
if the first test result showed allowable standards had been exceeded. The IDNR agreed with this regime with a visit and a written response.
The TSP stack test was conducted on April 29, 1997. The data indicated the booth had passed the stack test.
IWRC also assisted Company D in developing an emission inventory and documenting their "non-major" status. Currently, Company D is in
compliance with state and federal air emission regulations. Company D saved $27.000 by working with IWRC and IDNR.
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
SUCCESS STORIES AND CASE STUDIES
1 . A small Kansas company needed to obtain their air permit, which was complicated, since part of their process resulted in HAP emissions.
The Kansas SBAP assisted the company by calculating their potential and actual emissions and helping them complete their paperwork. The
ombudsman "hurried along" the process after their application had been delayed within the regulatory agency (due to the resignation of an
engineer).
2. In another instance, we had a concern about the continuous release initiative from EPA Region VII. In this case, the technical assistance
program helped companies see that if they found records of the xylene isomers used in their paint, they could prove that their actual emissions
of p-xylene were below the thresholds. EPA still fined them $2,200, but that was better than the $1 1 ,000 originally levied.
3. For Kansas dry cleaners, the technical assistance program staff is making site-specific compliance record organizers (notebooks). We will
continue this service over the next year with additional workshops planned. Local vendors and local programs (in specific counties) will be
assisting with workshop endeavors.
1 . The KY program published "Kentucky Small Businesses Volunteer Success Stones about the Kentucky Business Environmental Assistance
Program" in February 1998. Copies were mailed to each SBO and SBAP in the country. The report was widely distributed in-state and was
well received. The AQRSB has started working on a second pamphlet of new success stories.
2. The biggest success story for 1998 was the effort the Division for Air Quality made to notify businesses possibly subjected to new
regulations of the KBEAP. This effort, coupled with increased networking and partnering, resulted in a dramatic increase in assistance
requests.
3. Another highlight of the year was the cooperative effort between KBEAP, the Division for Air Quality, the Air Quality Representative, the KY
State Chamber, various local chambers of commerce, and the Associated Industries of KY to provide Risk Management Plan seminars.
N/R
1 . A cultured marble manufacturer, which is an employee-owned company of 18 people, contacted the LA SBAP as a result of receiving an
EPA informational mailing concerning obtaining an air quality permit for styrene emissions. The SBAP engineer met with the company
president to determine what needed to be done. "The cost savings to the company were considerable, because we didn't have to hire a
consultant to do the work," said the president. He further stated that he feels more at ease knowing that the company avoided enforcement
actions by obtaining an air permit to operate.
2. The owner of a packaging company contacted an SBAP engineer about needing a permit for newer, larger, automated equipment. This
business employs 15 people and has been growing and expanding through the years. The SBAP continues to work with this company in
search of recyclable uses for its wood waste.
N/R
N/R
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
SUCCESS STORIES AND CASE STUDIES
The Massachusetts auto body project generated simplified regulatory information by using the "good faith" rationale for penalty mitigation.
Enforcement policies include setting penalties according to a number of factors, including whether a violator has shown good faith. But what is
good faith?
Working with a trade association, Massachusetts SBAP produced the manual, "Crash Course," which constitutes an agreement between the
federal and state environmental enforcement agencies defining what an inspector will look for when he/she visits an auto body facility. (The
manual also was mailed to all local boards of health.) In plain terms, information is offered to help an auto body shop owner/operator know
what to do to comply with basic requirements. Included are a clear and simple version of the rules, pollution prevention tips, strategies to
protect worker health, and documentation tools so that the shop can show an inspector how key activities are taking place. If an inspector
finds violations, the shop can benefit from this demonstration of good faith if any penalties are assessed.
This program has been well received by shops. Using the "good faith" policy allows regulatory simplification without any regulatory
promulgation.
N/A
The loan program has been very successful, particularly within the dry cleaning industry. Many of these businesses have reduced their solvent
use by as much as 90% by upgrading their equipment with a loan from the program. The loan program also helped a wood finisher make the
move from solvent-based coatings to an aqueous-based line of wood products.
N/R
An air conditioning manufacturing facility that had been visited by our on-site assessment team received a hazardous waste inspection by the
department's regional office. Only a couple of minor violations were found. The facility was grateful for the on-site team's assessment, as it
kept them from receiving other violations.
1 . The SBO/SBAP settled a dispute between an auto body shop and several of its neighbors, who had complained about odors and dust from
the shop's spray coating operations. The SBO/SBAP was able to convince the shop owner to install a ventilation/filtration/dispersion system to
control air pollution from the spray booth. The SBO/SBAP provided technical assistance on system design as well.
2. The SBO/SBAP created the Small Business and Tribal Energy and Environmental Loan Program to provide low-interest loans to small
businesses and tribal entities to purchase energy efficient and P2 equipment. The loan program was able to keep over a dozen small, rural
service stations from aoina out of business as a result of the underaround storaae tank reaulations.
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
SUCCESS STORIES AND CASE STUDIES
A trailer manufacturing company switched to a new type of plasma cutter, which allowed them to cut aluminum more quickly and accurately. A
problem arose, since the waste from the cutter was very fine, and when mixed with water, became unstable. The trailer company now had a
disposal problem and nowhere to recycle the waste product (aluminum oxide). Faced with possible hazardous waste disposal expenses, the
company environmental manager called the NE SBAP for assistance.
The SBAP visited the trailer company to see the waste and determine the amount that was being created. The company was more than willing
to cooperate! The SBAP determined that the company would generate over 55 gallons of aluminum oxide powder each day.
Through a network of scrap dealers and other companies that cut aluminum, the SBAP found a company in Illinois that would take all the
aluminum oxide that the trailer company could produce. The trailer manufacturer now is considering adding a second plasma cutter to
increase production.
The Clark County Air Quality Program has had substantial compliance improvements by 1) requiring construction management to attend "dust
school" for violations of fugitive dust, and 2) imposing increased fines for each subsequent violation for fugitive dust emissions. Signage
requirements on construction sites note the phone number to call to report blowing dust, etc.
N/R
CAP developed its own mission statement. CAP invited 7 trade association representatives to some of its meetings so that these associations
could present issues affecting their members. Based on this input, CAP developed a matrix to prioritize and identify cross-cutting issues. The
CAP plans to bring this information to the attention of the Governor, Legislature, and NJDEP.
N/R
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
SUCCESS STORIES AND CASE STUDIES
New York
SBAP
1. In 1998,' SBAP prepared 52 Minor Facility Registrations and 14 State Facility Permits for small businesses, which brought each source into
compliance with New York State's air emissions permitting regulations, Part 201. The SBAP also helped 71 businesses reply to a mass
mailing in December by the state's regulatory agency, the Department of Environmental Conservation (DEC) that required permitted sources to
indicate either their need for a Title V permit or their desire to cap their emissions under major thresholds. These were sources whole potential
emissions exceeded major thresholds, but whose actual emissions may have been much less. By helping these businesses indicate an
appropriate response to DEC, the SBAP brought them into compliance with the permitting regulation and prevented them from being classified
as Significant Violators in the future.
2. In addition, the SBAP responded to 166 calls-from environmental consultants and attorneys, who typically were seeking regulatory and
permitting information. If the results of each of those calls were to help even one business obtain the necessary permit or registration, then the
SBAP helped bring at least 303 businesses into compliance with state permitting regulations, either directly or indirectly [based on adding the
number of permits and registrations the SBAP completed (66), the number of businesses the SBAP helped respond to the DEC capping letter
(71), and the number of businesses that might have received a permit or registration from a consultant who called the SBAP (166)].
3. The SBAP developed a condensed version of the perc dry cleaning NESHAP initial notification form for third and fourth generation
machines. The form was distributed at 11 workshops for dry cleaners statewide (attended by nearly 700 dry cleaners) and in response to
hotline calls from dry cleaners. The SBAP's version took a 6-page form that addressed all generations of equipment and condensed it to a 2-
page form for third and fourth generation equipment only (the most common types of machines after the state's phase-out of older equipment).
Many cleaners couldn't recall if they had submitted the form, others had submitted it, but their facility was not on the DEC'S list of facilities that
had submitted forms, and still others needed to submit a new form for the new equipment they had purchased as a result of the state's
regulation. Dry cleaners submitted these forms to DEC central office, their DEC regional office, and EPA's regional office in New York City. At
this writing, more than 200 of these streamlined forms have been sent to the DEC regional office in New York City alone, bringing these
facilities into compliance with that part of the NESHAP. More forms will be submitted as facilities make additional equipment changes.
SBEO
1. The SBEO negotiated a policy with the DEC in which the dry cleaners could voluntarily sign consent orders to come into compliance with
the vapor barrier requirement of the new dry cleaning regulation - Part 232. The SBEO recognized that many dry cleaners throughout the state
had missed a deadline to build a vapor barrier enclosure around their dry cleaning equipment due to reasons that were beyond their control
(e.g., lack of available contractors, lack of available approved materials, confusion and misinformation about the requirement). The DEC
agreed to let dry cleaners operating third generation machines that had missed the deadline, and who had a signed contract with a vapor
barrier installer, to voluntarily comply by signing consent orders with a suspended penalty. The SBEO, in coordination with the DEC and trade
associations, did extensive outreach on the policy. Over 300 dry cleaners took advantage of the consent order option.
2. The SBEO coordinated an outreach effort with the DEC to increase the understanding and compliance of permitting requirements. The
DEC conducted a mass mailing to inform permittee sources of their new permitting requirements. The SBEO mailing warned businesses not to
ignore the DEC letter and offered free and confidential assistance. These mailings generated many hotline calls to both the SBEO and SBAP
and resulted in many more permit assistance requests from small businesses to the SBAP (as described above).
N/A Not applicable N/R No response
8
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TABLE F-4
(Continued)
PROGRAM
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
SUCCESS STORIES AND CASE STUDIES
A metal coating company called with questions about 1 12(r) and the changing requirements for propane. On a site visit, our engineer
observed a number of problems with waste management and potential safety issues. The plant representatives indicated they were being
trained, but management didn't really pay much attention to their needs. We talked with management and gave them some specific
recommendations on how to address their problems, which were immediately implemented.
No strong, unique examples.
1 . A small, one-person company that makes lead castings was inspected by District Office staff because of a complaint. The District Office
maintained the company was a "secondary lead smelter," determined large potential emissions based on smelting emission factors, and
deemed the company in violation for not having an air permit. The company was being prosecuted by the County Prosecutor for criminal
violations of open burning and failure to obtain an air permit. Upon referral from the District, the SBAP visited the company and learned the
operation was not secondary lead smelting, but was in fact exempt from permitting due to low emissions that were calculated using the
appropriate non-smelting emission factors. The SBAP, on behalf of the company, successfully argued this point to the District Office and
Prosecutor's Office, and the charge of failure to obtain a permit was dropped.
2. Two years ago, SBO provided funding to the Printing Industry of Ohio for its ENVIROPRINT OHIO project. Printing Industry of Ohio
produced an environmental operations manual for printers and conducted a series of workshops on its use. The industry responded favorably
and the trade association reports a significant shift in attitude among its members about the state regulatory agency and about alternate
technology. For this project, the Printing Industry of Ohio was awarded the OH Alliance for the Environment's "Business Environmental
Educator of the Year" prize.
We continue to have great success with our site visits. We, as a program, prefer to meet with the individuals face-to-face, take a tour of their
facilities, see their processes, and provide assistance from this vantage point. We believe this has allowed us to refine our methods of
assistance and also better relate to the business owners.
We also have continued to have outstanding success with our involvement in new rule proposal and revisions. We, as SBAP staff, are now
asked to be on committees and workgroups within the Agency (particularly in the Air Quality Division) to help represent small business
perspectives. In fact, we have become a source that is relied upon to provide a complete, holistic approach to regulating business in OK.
None.
N/R
N/R
Our Lieutenant Governor has sponsored a monthly series of "Small Business Town Meetings" to help small businesses with a variety of issues
including "Marketing Your Small Business" and "Working with State Government to Enhance Your Small Business." These meetings, held at
various locales throughout the state, have been well attended and have generated lively, but fruitful discussions among the small business
community. The SBAP always has sent a representative to these meetings and occasionally has been asked to make presentations regarding
the program's nonregutatory services available to small businesses. SBAP's coordination of assistance activities with industry is a common
occurrence at these meetinas.
N/A Not applicable N/R No response
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TABLE F-4
(Continued)
PROGRAM
South Carolina
South Dakota
Tennessee
SUCCESS STORIES AND CASE STUDIES
N/R
N/R
1 . TN was the first state in the region to develop and conduct 1 12(r) workshops for small businesses.
2. A small wood operation that wanted to expand its business ran into compliance problems associated with the expansion and continued to
have visible emission complaints. The TN SBAP helped to pair the wood operation with a major source that would accept wood waste. The
wood operation was able to acquire funding to purchase equipment to property size the wood waste so that it would be suitable for the major
source's use. Compliance and emission complaints were resolved.
3. A small business in a metropolitan area was referred to the agency for air permit violations. An inspection revealed compliance issues for
several media. Our staff explained the consequences of the violations to the company and worked with them on possible solutions. The
company now wants to be environmentally responsible.
4. Use of electronic media assisted a company with a oermit aoolication violation to be in compliance in a matter of davs.
N/A Not applicable N/R No response
10
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TABLE F-4
(Continued)
PROGRAM
SUCCESS STORIES AND CASE STUDIES
Texas
1. The Site Visit Program is a key SBAP outreach effort that offers free technical assistance to small businesses through private consultants.
The program focuses on opportunities for companies to reduce both the amount of pollution they create and the costs associated with proper
waste handling. These site visits are free of charge, and all results are kept confidential. Begun in October 1997, site visits were requested by
over 177 small businesses. Common problems discovered during site visits included failure to make a hazardous waste determination
(49.72%), properly label waste containers (31.64%), keep monthly records of hazardous waste generation (28.25%), and register for air permit
exemptions (20.32%);
Surveys taken after the site visits found small businesses had made significant changes based on the consultants' recommendations. The
program's overall result was a significant increase in compliance. Baseline compliance with air regulations averaged 78.4%, and waste
regulations averaged 70.1% for all industries. Year-end compliance with air regulations increased by 11.6% to 90%, and compliance with
waste regulations increased by 19.9% to 90%. Site visits also spurred more small businesses to recycle and use environmentally friendly
solvents, which reduced waste and cut disposal costs.
2. A grant from the Texas Natural Resource Conservation Commission (TNRCC) kicked off the state's first training course in the Spray
Techniques Analysis and Research (STAR) program. Developed by the Iowa Waste Reduction Center, STAR teaches participants how to use
spray painting equipment in an environmentally friendly manner. STAR students learn an efficient method that reduces the amount of spray
paint going into the air instead of onto the vehicle, which also reduces VOC emissions that contribute to ground level ozone, a major air
pollutant. STAR has some other bright outcomes: students learn how to reduce pollution, cut costs for the disposal of hazardous paint wastes,
and gain a new skill that strengthens their employment opportunities. As a result of this program and several others, TNRCC won a second
place award from the National Pollution Prevention Roundtable's 1998 Most Valuable Pollution Prevention Program.
3. A new SBAP outreach effort, the foundry initiative, was created to inform foundry operators about environmental laws. In FY97 and FY98,
SBAP staff conducted workshops and site visits, and developed a self-audit checklist for foundry operators. These efforts resulted in
compliance increases for foundries: air compliance shot up from 52% to 93%, while waste compliance was up from 68% to 75%. Key to the
initiative was promoting the reuse of foundry sand for the TX Department of Transportation (TXDOT) road and highway projects. Collaboration
among TNRCC, EPA, TXDOT, foundry associations, and the TX Manufacturing Association Center made the initiative a success.
4. Lancaster Furniture is proof positive that environmental investments can produce significant economic returns. This company slashed its
paint and coating expenses 50 percent and cut regulatory reporting tasks to almost nil after implementing new technology that reduces air
pollution while increasing painting efficiency. These changes were made based on SBAP recommendations during a site visit in 1998.
At Lancaster Furniture, the focus was on volatile organic compounds (VOCs). These pollutants evaporate into the air from such substances as
paint, thinners, and solvents. VOCs contribute to ground-level ozone, the major threat to air quality in southeast Texas. Following TNRCC
recommendations, the company invested $8,000 to purchase more efficient high-volume, low-pressure spray guns and related equipment and
train employees in their proper use. VOC emissions dropped from just under 25 tons in 1996 to 16 tons in 1998, while annual expenditures on
oaints and coatinqs plummeted from $69.000 to $35,000.
N/A Not applicable N/R No response
11
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TABLE F-4
(Continued)
PROGRAM
Texas (cont.)
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
SUCCESS STORIES AND CASE STUDIES
The VOC reductions help ensure a healthier environment for the 65 employees who work at Lancaster Furniture as well as for the community
at large. The cost savings in materials mean the company has been able to avoid raising prices, a further boost for its competitive standing.
The VOC reductions also put the company well under the 25 ton threshold that triggers permitting requirements, allowing company staff to
concentrate on the business of making furniture.
Lancaster credits the TNRCC program with raising overall awareness of environmental costs and issues in running a business. Lancaster
realized that it could save disposal fees and make a healthier work environment by replacing certain products with less hazardous alternatives
and recycling others. Now, for example, the company uses sponges instead of rags in initial stages of staining, allowing employees to
recapture a considerable amount of stain that otherwise would have been tossed out on used rags. Stain recycling also has reduced the
volume of rags hauled away for disposal at a cost of $300 per barrel.
N/R
Currently working documenting success stories.
SBAP hosted a roundtable meeting with selected trade associations to inform them of the program's compliance assistance web site
development activity. We asked for suggestions on how to improve the site and sought to understand the reach of the Internet within their
organizations. The meeting was very successful, providing partnerships upon which we can build both electronically through the Internet, and
in general, through joint outreach.
N/R
N/R
SBO and SBAP were successful in the passage of state legislation for a "Small Business Environmental Loan Program." Loans can range
from $5,000 to $150,000 with a 10 year payback at an APR of half the federal prime, but not less than 4.5%. The size of the small business
cannot exceed 50 full time employees. Also, there is a provision to refinance loan balances where a small business has already obtained a
commercial loan and. completed a project.
N/R
N/A Not applicable N/R No response
12
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TABLE F-4
(Continued)
PROGRAM
SUCCESS STORIES AND CASE STUDIES
Wyoming
1. Disposing of certain waste is a problem for many WY small businesses. During one-on-one site visits to small businesses that generate
waste tires, we often hear concerns over this waste stream. Many landfills now are charging for accepting waste tires; the only tire shredder in
the state charges for picking up tires and, at this time, is still putting shredded tires in a local landfill.
Our office is looking for secondary uses for waste tires. Initial efforts have led to reuse of tires for retaining walls, livestock shelters, hay barn
enclosures, and some minor farmstead construction projects. Follow-on activities include uses for shredded tire material depending on the
economics of supply, transportation costs, and markets for the finished products.
2. Many small businesses in Wyoming have problems disposing of waste wood from milling and wood manufacturing operations. The
relatively small quantities of this waste stream that are generated at widely dispersed operating locations and the sparse rail transportation
service in the state combine to limit the feasibility of reprocessing much of this material for reuse. The low population density throughout the
state also limits marketing opportunities for reprocessed wood materials. As a result of these factors, much of this valuable waste stream is
being burned or sent to landfills.
The SBAP office has begun looking for secondary uses for waste wood. Initial efforts include helping to set up a municipal composting
program at a sawmill to provide an alternative to burning wood waste. The local community will enjoy improved air quality, extended life of their
landfill, and production of overburden material for closing off sections of the landfill as they are completed. Follow-on efforts include alternative
uses ranging from pelletized fuel to composite construction material manufacturing.
N/A Not applicable N/R No response
13
-------
APPENDIX G
COMPLIANCE ASSURANCE ISSUES
-------
TABLE G-1
COMMON COMPLIANCE PROBLEMS
SBTCPs were asked to note common compliance issues addressed in the course of providing technical assistance, Programs also were
asked to indicate if certain problems were prevalent in any particular industry sector.
Program
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Not
understanding
regulatory
requirements
X
X
X
X
X
X
(gas stations)
X
X
X
X
X
(dry cleaners)
X
X
Operating
w/out
permit
X
X
X
X
(paint
booths)
X
X
X
X
(auto
degreaser)
X
(dry
cleaners)
X
Incomplete
records
X
X
X
X
X
(paint
booths)
X
X
X
X
(dry
cleaners)
X
(dry
cleaners)
X
(dry
cleaners)
Uncertain of
permitting
requirements/
need multiple
permits
X
X
X
X
X
X
X
X
X
Uncertain
how to
determine
emission
Inventories/
lack of tech
expertise
X
X
X
X
(auto body)
X
X
X
X
X
X
Uncertain
how to
complete
forms/
complicated
paperwork
X
X
X
X
X
X
X
X
X
Lack of
financing
for
equipment
X
X
(small retail
gas)
X
X
X
X
Operating
outside
NSPS or
MACT
X
X
X
X
X
Improper
storage/
disposal of
hazardous
waste
X
X
X
X
Fear of
regulatory
agency/
arbitrary
regulatory
enforcement
X
X
X
X
X
X
X
X
X
X
X
Failure to
use right
equipment
to comply
w/standards
X
X
X
X
(gas stations)
Other*
N/R
No response
-------
TABLE G-1
(Continued)
Program
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Not
understanding
regulatory
requirements
X
X
X
X
(dry cleaners)
X
X
(sm/ med
business)
X
X
X
X
X
X
X
X
Operating
w/out
permit
X
X
X
X
X
X
X
X
X
X
X
X
Incomplete
records
X
X
X
X
(dry
cleaners)
X
X
(sm/med
business)
X
X
X
X
X
X
X
X
X
Uncertain of
permitting
requirements/
need multiple
permits
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Uncertain
how to
determine
emission
Inventories/
lack of tech
expertise
X
X
X
X
X
X
X
X
X
X
X
X
X
Uncertain
how to
complete
forms/
complicated
paperwork
X
X
X
X
(vehicle
maint.)
X
X
(sm/med
business)
X
X
X
X
X
X
X
X
X
Lack of
financing
for
equipment
X
X
•
X
X
X
X
Operating
outside
NSPS or
MACT
X
(dry
cleaners,
platers,
furniture
mfg)
X
X
X
X
X
X
X
Improper
storage/
disposal of
hazardous
waste
X
X
X
(vehicle
maint.)
X
(manuf)
X
X
X
X
X
X
Fear of
regulatory
agency/
arbitrary
regulatory
enforcement
X
X
X
X
(dry cleaners,
vehicle
maint)
X
X
(sm
business)
X
X
X
X
X
X
X
X
x •
Failure to
use right
equipment
to comply
w/standards
X
X
X
X
X
(degreasers)
Other*
X
X
(sm
business)
X
N/R
No response
-------
TABLE G-1
(Continued)
Program
Montana
Nebraska
Nevada
New
Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
Not
understanding
regulatory
requirements
X
X
(dehydrators)
X
X
X
X
X
X
X
X
X
X
X
(auto maint
shops)
X
X
Operating
w/out
permit
X
X
X
(toxics use)
X
X
X
(NY City
sources
w/city but
no state
permit)
X
X
X
X
X
X
(sm
business)
X
X
Incomplete
records
X
(dry
cleaners)
X
X
X
X
X
(dry
cleaners)
X
X
X
X
X
X
(dry
cleaners)
X
X
Uncertain of
permitting
requirements/
need multiple
permits
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Uncertain
how to
determine
emission
Inventories/
lack of tech
expertise
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Uncertain
how to
complete
forms/
complicated
paperwork
X
X
X
X
X
X
X
X
(dry cleaners)
X
X
X
X
Lack of
financing
for
equipment
X
(auto body,
service)
X
X
X
X
X
X
Operating
outside
NSPS or
MACT
X
X
X
X
(dry
cleaners)
Improper
storage/
disposal of
hazardous
waste
X
X
X
X
X
X
X
Fear of
regulatory
agency/
arbitrary
regulatory
enforcement
X
X
X
X
X
X
X
X
X
X
X
X
Failure to
use right
equipment
to comply
w/standards
X
X
X
X
X
Other*
N/R
No response
-------
TABLE G-1
(Continued)
Program
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Not
understanding
regulatory
requirements
X
X
X
(auto
body/repair, dry
cleaners,
dairies, metal
finishers.
surface coaters)
X
X
X
X
(auto body
repair)
X
X
X
X
Operating
w/out
permit
X
X
(aqua
culture,
metal
finishers,
surface
coaters)
X
X
X
X
X
X
X
(auto)
Incomplete
records
X
X
X
(auto
body/repair,
dry
cleaners,
dairies,
printers,
foundries,
metal
finishers,
surface
coaters)
X
X
X
X
X
(dry
cleaners)
X
X
(dry
cleaners)
X
Uncertain of
permitting
requirements/
need multiple
permits
X
X
(aquaculture,
dairies, metal
finishers)
X
X
X
X
X
Uncertain
how to
determine
emission
Inventories/
lack of tech
expertise
X
X
X
(surface
coaters)
X
X
X
X
(dry cleaners)
X
X
X
X
Uncertain
how to
complete
forms/
complicated
paperwork
X
X
(dry cleaners,
surface
coaters)
X
X
X
X
X
X
X
Lack of
financing
for
equipment
X
X
(sandblast,
surface
coaters)
X
X
X
X
Operating
outside
NSPS or
MACT
X
(dry
cleaners)
X
X
X
X
X
Improper
storage/
disposal of
hazardous
waste
X
(metal
finishers)
X
X
X
Fear of
regulatory
agency/
arbitrary
regulatory
enforcement
X
X
(printers, dry
cleaners,
auto service,
metal
finishers,
surface
coaters)
X
X
X
X
X
X
X
X
Failure to
use right
equipment
to comply
w/standards
X
X
(surface
coaters)
X
X
Other*
(dry
cleaners,
printers)
X
N/R
No response
-------
TABLE G-1
(Continued)
•Other
IL UST's major problem with December deadline. Many are forced to close due to lack of financing to upgrade tanks.
KS Wait for someone to come tell them what to do.
MA Lack of funds for implementing pollution prevention.
TX Hazardous waste determination, keeping monthly hazardous waste records.
VI Lack of a hazardous waste notification form filed with the Department.
NfR No response
-------
TABLE G-1
(Continued)
PROGRAM RESPONSES
Programs were asked for any specific regulations, monitoring, or recordkeeping requirements that were particular problems. Programs also were invited to provide
general comments regarding common compliance issues addressed during the course of providing technical assistance. Individual program responses are listed below.
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
Florida
COMPLIANCE ISSUES
Compliance with industrial storm water permits by auto salvage operations. These facilities have a very negative public image and are often
controversial, because they need to locate in areas with no zoning laws. The industrial storm water permit is usually the only permit they need to
operate.
Rolling 12 month totals. AK's yearly certification of compliance with permit conditions.
Most NESHAPs that apply to small businesses have overly complicated reporting, recordkeeping, and operational requirements (chrome and wood
to name a couple). Simplified small business rules should be considered in many cases, or simple operational or process changes that can get
them out of requirements altogether.
As regulations are revised, sources aren't aware of changes that may affect them with the rule revision. Many sources still claim they never knew
they needed a permit.
N/R
Since the local air districts issue permits, this (compliance) is largely inapplicable at our state level. Our workshops with those we regulate prior to
rule adoption are well attended and have excellent participation. EPA recordkeeping requirements are onerous for small business rules written to
meet EPA approval criteria are difficult to understand.
Daily recordkeeping concerns for very small users continues to be a problem. New Source Review. EPA's policy of treating relocation as a new
facility.
MACT regulations are resulting in financial hardships due to the cost to comply. Specifically, the dry cleaner MACT occasionally affects a business
in this manner.
Common problem: The small business owner faces many different and complex regulations with multiple federal, state, and local agencies (i.e.,
EPA, OSHA, DOT, etc.).
N/R
Regulations are far too complicated and complex. They far exceed the capabilities of the regulated community to understand why the need to
comply and how to comply as efficiently and economically as possible.
Dry cleaning facilities are required to record different activities at the shop, such as amount of PERC purchased and maintenance dates. This
requirement mostly is ignored by the plant manager.
None at present.
N/R No response
-------
TABLE G-1
(Continued)
PROGRAM
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
COMPLIANCE ISSUES
The Enforcement Program inspected the PERC dry cleaners several times during 1998. Most of the dry cleaners inspected were noncompliant for
recordkeeping.
We feel the biggest problem is the lack of awareness of the programs that provide compliance assistance. We also feel that the Permitting and
Enforcement Programs are remiss in not referring small businesses for assistance. If compliance assistance is a priority to Carol Browner, ECOS,
and STAAPA-ALAPCO, 507 programs would have the resources available to improve compliance.
N/R
N/A
Although we are an air-focused program, we continually receive calls for assistance regarding USTs and contamination of private property. There
seems to be a problem for companies wishing to upgrade or remove tanks in securing financing to get the work completed.
There seems to be a lack of access to capital for most small companies. Those who need to make modifications often have difficulty in financing
projects.
Dry cleaners: weekly temperature readings, 12-month rolling total of PERC purchases.
Wood furniture: NESHAP recordkeeping requirements.
Fiberglass reinforced plastics: Lack of emission factors for open mold industry.
Synthetic minor sources doing a Federally Enforceable State Operating Permit (FESOP) are required to keep a set of complex and confusing
records to document compliance.
X
Most small businesses want to do the right thing if they know what it is and are shown how to do it.
There are problems with training and emergency preparedness under RCRA, recordkeeping under all NESHAPs, and compliance reporting that is
triggered by the facility under the NESHAPs. Again, the businesses are more likely to fill something out and send it back, rather than remembering
to generate a report of their own. Small businesses really need multimedia, site-specific compliance assistance. They really need someone to
come in and tell them what to do. We don't think we can afford to do that for everyone, but that would be effective. A more realistic suggestion
would be to simplify recordkeeping so that they can actually be in compliance. Another suggestion, although difficult to implement, is to integrate
inspections so that when a company is visited by a regulator, that person could answer all the environmental questions. If a business is expected
to understand all of the regulations, it seems reasonable to expect the same from the inspector.
N/R
N/R
N/A
Common compliance problems across all businesses include hazardous waste violations due to a lack of understanding of regulatory
reauirements.
N/R
No response
-------
TABLE G-1
(Continued)
PROGRAM
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New
Hampshire
New Jersey
New Mexico
COMPLIANCE ISSUES
N/R
MACTs. RACTs. Permitting exemptions. Potential to Emit.
CAA requirements are not well understood. We see a lot of noncompliance in the field. There is a dearth of plain language explanation, and the
rules are very complex. There is a lot of noncompliance with groundwater discharge requirements, particularly with unsewered areas and vehicle
washing. Routine hazardous waste violations persist.
Hard and decorative chromium plating NESHAP. Asbestos NESHAP. Surface coating for metal parts (state rule), especially the recordkeeping
requirements.
Monthly rolling sums, emission inventory and fees, HAP tracking, RMP, some Form R.
Lack of funding, difficulties getting multimedia assistance (too many rules, too many different sources of information), confusing or meaningless
regulations.
N/R
N/R
N/R
RCRA paperwork. Continuous release reporting under CERCLA.
None at this time.
In general, maintaining adequate records for determining applicability of regulations (such as MACT or toxics rules) is a problem. Also, the inability
to understand regulations as written continues to create frustration for those companies that want to be "in compliance" but can't determine what "in
compliance" is!
Most compliance problems can be resolved through the development and issuance of General Permits or plain language, industry-specific
guidance documents (including self-certification workbooks).
The fact that a recordkeeping violation may receive the same weight of penalty as an actual air violation.
N/R
N/R
No response
8
-------
TABLE G-1
(Continued)
PROGRAM
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
COMPLIANCE ISSUES
Dry cleaners in New York State are subject not only to the federal NESHAP, but to a significantly more burdensome state regulation. Compliance
with the environmentally substantive, equipment-based elements of the NESHAP appears to be less difficult to achieve than compliance with the
recordkeeping requirements of the NESHAP. However, the NESHAP's requirements, coupled with the complex state requirements for dry
cleaners, make it difficult to achieve total compliance. Additionally, New York dry cleaners have to respond to phased state deadlines for
equipment replacement and vapor barrier installation. For businesses that typically have fewer than 10 employees, only a couple of who may
actually operate the dry cleaning machine, the combined federal and state regulatory requirements are difficult to understand and comply with.
Recordkeeping is a serious problem for small businesses. Permits routinely have monthly or annual reporting. Small businesses need to have this
element of their permit emphasized. Standard reporting forms need to be developed, and regulatory agencies need to realize there are costs
associated with recordkeeping. For small businesses, these costs are significant.
Small business is still overwhelmed by the complexity of environmental regulations. They do not know if they need a permit or how to avoid a
permit. For the most part, they are not able to keep up with changes that may affect them. Determining points of emissions, calculating emissions,
and applying multiple sets of requirements to their business still makes it very difficult for the small business to comply with regulations.
Wood furniture manufacturing MACT presented some difficulties for affected businesses.
Companies have had problems with state regulations (e.g., permit requirements), not federal regulations. Not having the required state permits is
the most common violation found at small businesses. Despite 3 years of periodic mass mailings, many dry cleaners still have not filed for the
required state permits. An inspection may be the only thing that will prompt most companies to file the appropriate paperwork.
The largest problem appears to be operating without an air quality permit.
The BAP currently is working with the hazardous waste division on outreach to dry cleaners. This effort should improve compliance with monitoring
and recordkeeping requirements.
DEQ is concerned about the possibility of the area source deferral ending. If this happens, many small businesses will have the potential to emit at
major source thresholds. If that is the case, the BAP would no longer be able to help small businesses, because they would no longer qualify for
the program as major sources. We have been in communication with Ginger Gotliffe/EPA about this issue.
Annual inventory report, plan approval and permit applications, EPA's MACT notification.
MACT requirements for drv cleaners (recordkeeoinq, control equipment). Lack of other aqencv requirements.
N/R
No response
-------
TABLE G-1
(Continued)
PROGRAM
COMPLIANCE ISSUES
Rhode Island
RMPs could become another paperwork headache for small businesses. RMPs may be viewed by industry as duplicative, and they may sense
that such plans piggyback on information already required of them by their local fire department under MSDS regulations. Whether or not this new
requirement will become burdensome to small businesses remains to be seen.
Another issue that could become a problem, particularly for the auto repair industry, is the requirement of EPA's Auto Emission Inspection
Program. Presently, there are 900 inspection stations in Rl. The program is to be combined with the safety inspection program. Because of the
expense of emissions inspection equipment, only about 300 garages are expected to get this equipment, thus limiting the number of inspection
stations. Anxiety about this program was expresses by repair facilities at a public hearing held last year. Repair facilities fear the loss of business
and potential shutdown of garages that don't have the emissions inspection equipment. The new law is expected to take effect June 1999. Time
will tell if this new law has a negative effect on these facilities.
Instead of industry receiving separate visits by different media inspectors, a single visit by an inspector cross-trained to recognize air, water, and
hazardous waste issues of a specific industry will do much to improve compliance by industry.
South Carolina
N/R
South Dakota
Recordkeeping requirements in certain MACT standards.
Tennessee
Identifying companies affected by a particular regulation. A regulation could affect a process that includes several SICs.
Small companies often don't have good environmental management practices in place.
Texas
Problems/assistance needs identified from hotline calls and site visits included: outreach to dairy, aquaculture, and die caster industries; hazardous
waste determinations; waste container labeling requirements; waste recordkeeping; registration for air permit standard exemption.
Common problems discovered during site visits included the failure to: make a hazardous waste determination (49.72%), properly label waste
containers (31.64%), keep monthly records of hazardous waste generation (28.25%), register for air permit exemptions (20.32%).
Comments received from hotline calls and site visits stressed the need to ensure small business input into the rulemaking process from the CAP,
Small Business Advisory Committees, Review Committees, trade associations, and small business owners. Input is important to increase small
businesses' knowledge and awareness of new regulations and amendments to existing regulations, as well as to ensure that regulations are in
plain language and are not unduly burdensome for small businesses. These actions will help ensure that compliance problems for small
businesses are reduced.
The greatest compliance problem our office saw during this reporting period was determining which wastes are hazardous and documenting waste
determinations. Site visit findings showed a 50% occurrence for this problem. Other problems identified and their frequencies of occurrences
included: failure to properly label waste containers (32%), failure to keep records of monthly hazardous waste generation (28%), failure to obtain air
authorization (32%), and failure to keep records to show compliance with air authorization (32%).
To address the waste-related problems, we held a series of RCRA waste recordkeeping workshops and stressed recordkeeping in our printed
guidance booklets.
N/R
No response
10
-------
TABLE G-1
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
COMPLIANCE ISSUES
N/R
N/R
MACT regulations continue to be highly confusing. Compliance through pollution prevention is a disincentive to small businesses
trap of "once in always in." Even if all pollution is eliminated, a business will still have to prove compliance.
N/R
Monitoring and recordkeeping for dry cleaners, asbestos remediation, construction fugitive dust, outdoor burning.
No unusual problems.
112(r)RMPs.
because of the
A number of small businesses have problems with keeping records of the materials used in their operations and in tracking accumulation and
disposal of hazardous wastes and used oil.
While considerable progress is being made to reach out to small businesses across the state, there are still remnants of the previous anxiety about
dealing with our Department. The program will continue our outreach efforts through all the current channels. In time, we hope to break down
those barriers to to optimize our effectiveness in providing compliance assistance and P2 initiatives for WY businesses.
N/R
No response
11
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TABLE G-2
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
Small businesses generally are dependent on consultants to help them complete permit applications and provide technical information needed to
get them through the. permit process. Because of the cost of this service, many small businesses may avoid getting permits until an inspector
walks in the door and starts the regulatory process to force them to get a permit. If a more cost effective way of getting this service could be
developed, there would likely be less non-compliance due to failure to obtain a permit.
None at this time.
Provide funding for all SBAPs to expand/enhance their program to multimedia. Many businesses can actually do more harm to the environment if
their assistance provider only looks at CAA requirements and not the potential impact that operational or process changes may have on water
quality or land.
More public service announcements.
N/R
Given the diversity in size and programs in CA and its air districts, small businesses highly value a flexible, non-prescriptive implementation
approach to the CAA. Supplement the prescriptive approach (i.e., rule-making and evidence) with an equivalency approach that allows states the
option of fashioning an equal method of securing the federally required air pollution reduction.
EPA should provide resources identifying the common compliance problems nationwide that have technology-based solutions and then help
develop and promote those technologies. This would advance P2.
Recognize that state and local jurisdictions often have developed regulatory programs suited to their local conditions and make equivalency much
more easily achievable.
Continued national effort with the President's initiative to write regulations in PLAIN English.
Requiring EPA regulatory writers to work together on related programs to eliminate redundant requirements and unnecessary reporting, and to look
for opportunities for streamlining. One example would be Emergency Response/Community Right to Know and the Accidental Release Program
under CAA.
Make the regulations less complicated and easier with which to comply. Explain the benefits of compliance and be more straightforward and less
bureaucratic in attempting to achieve higher levels of compliance in the small business sectors. Have a high degree of visibility within the small
business community and work to develop relations built on trust and respect rather than fear and intimidation.
N/R
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
Provide specific mandate for funding to conduct outreach/awareness campaigns to increase program visibility.
GA thinks that all 507 programs need to be multimedia. We also think that Karen Brown's office should do a public service announcement about
the 507 programs. The PSA should run in every state with the local SBO/SBAP number listed at the bottom of the screen. This would make
businesses aware of the program and would ultimately increase compliance.
Develop a uniform minimum general permit (covered/non-covered) fee. Regulated small business emission levels sometimes do not correlate with
posted minimum permit fees. Establishing uniform minimum permit fee levels might provide financial relief for industries such as dry cleaning.
Be consistent. Provide support to state programs. Don't spend any more money on federal SBTCP. The money is needed in the states.
When regulations will have a definite impact on small businesses (UST deadline 98), the US EPA should work with SBA to set aside money in
existing loan programs to be targeted to these sectors. In addition, US EPA should turn to SBA to identify environmental lenders in each state.
Often a lack of knowledge of environmental issues by the lender prevents financing of projects. Environmental projects are a scary unknown that
raise red flags of liability for lenders.
Simplify permitting applications and other paperwork for small entities so a consultant or engineer is not required. Allow common indicators (e.g.,
number of gallons of paint used, size of spray area, type of spray equipment) so Mom and Pops don't need to do calculations just to submit and
find out they're exempt. Have the more complicated forms as a "turn around" from the agency once a simple letter/form is submitted that indicates
a need for further details.
Provide incentives (reduced recordkeeping, etc.) for suppliers of equipment or raw materials to provide all purchasers with permitting information.
For instance, with each spray gun sold, a notice stating, "use of this equipment may indicate a need for an air construction or operating permit.
The contact in your area is ," with the state or local air management aqency contact or SBAP contact listed.
Provide more assistance to industries on hazardous waste regulations. Make guidance, nonrule policies, databases, permit applications, etc. more
easily available and let the regulated facilities know this information is available.
Consider repealing the requirement for area sources to get a permit in 2000.
Clear and simple audit privilege or voluntary disclosure policies.
N/R
Adopt de minimus activity levels for all small businesses subject to NESHAPs by limiting potential emissions to area source limits and excluding
them from Title V permitting.
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Jefferson
Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
N/R
Conduct a national public relations program to let small businesses know that there is safe help available to them. Most small businesses want to
comply with the law but fear the bureaucracies and will remain invisible until they are contacted. A national public relations program would let small
businesses know that it's ok to contact the agency.
Consider raising the threshold for 1 12(r) from 10,000 pounds of propane for combined tanks to 10,000 pounds in a single tank. Numerous small
businesses will be subject to this rule due to co-location of three 1,000 gallon tanks, which will bring them above the threshold. The regulatory
burden of this threshold does not seem justified by the relatively small risk these facilities pose.
N/R
Under something like the Common Sense Initiative or NACEPT, define the sectors in terms of air pollution categories, such as small business VOC
emitters. (Include employers with up to 500 employees.) With these groups, review what is required and what the goals of the current system are,
and brainstorm simpler ways to get there. Use the multi-stakeholder approach to maintain a balance. Set the goal as reinventing rules, so that
they make sense, are easy to understand, and provide not only better protection, but also better information. Build not only right-to-know into the
system, but also provide extra benefits for those facilities that provide use information demonstrating that they use materials accounting, and even
greater benefits for facilities that provide information showing either that they are doing prevention plans or are achieving prevention. For these
performing facilities and for facilities that agree to provide direct access to their monitoring, provide reduced inspection priorities, reduced fees,
simplified authorization, and other benefits. Conduct pilots of these alternative regulatory approaches with measurements of environmental
outcomes, including costs to facilities and agencies.
EPA should work more closely with the SBAPs on national compliance incentives. EPA should include the SBAP early in the process of
establishing goals and criteria for compliance and enforcement and should actively solicit the feedback of the SBAPs on all compliance initiatives.
Provide grants or low interest loans (under the administration of the SBTCPs only) for small and medium-sized businesses for modification of
current facility processes and control equipment to reduce air emissions.
Provide more grant monies to state SBTCPs to develop and use innovative ways to distribute environmental 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 might allow a SBTCP to work with federal and state government, as well as business, industry, and statewide educational institutions to
coordinate and package environmental compliance and P2 information that is specific to industry sectors. The information might be introduced to
students at the secondary or post-secondary level so that by the time the student enters the workforce, he/she will bring timely, relevant and useful
knowledge and experience to specific industry or businesses.
Develop or support federal legislation that would mandate all SBOs/SBAPs to be multimedia in format!!!! Offer amnesty programs.
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Mississippi
Missouri
Montana
Nebraska
Nevada
New
Hampshire
New Jersey
New Mexico
New York
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
Be proactive in providing information in the applicability and implications of the regulations.
N/R
Coordinate the efforts of EPA SBO/SBAP with OECA to prevent OECA from conducting compliance assurance activities without first notifying the
EPA SBO or the state SBOs. This has disturbed the trusting relationships SBO/SBAPs have built with businesses in several states.
N/R
No recommendations at this time.
Encourage/require that the SBTCP be multimedia and ensure funding is available for effective operation. In addition, clear guidance, tools, and
funding need to be provided to allow the programs to measure effectiveness without interfering with the provision of useful assistance.
The SBTCP should, by federal mandate, be the lead programs for providing environmentally related assistance.
EPA must increase its marketing and publicity campaign for both the federal SBO/SBAP and state SBOs/SBAPs. Specifically, the regulated
community needs to be informed of the compliance assistance services available through the state and federal SBOs/SBAPs. In addition, funding
levels for more staff at the state level would greatly increase program effectiveness and outreach.
N/R
Congress has taken a step in the right direction to help small businesses by requiring Section 507 programs in each state. In conjunction with EPA
enforcement initiatives, Congress also should encourage, perhaps via incentives, a coordinated strategy between the regulatory enforcers and
implementation/compliance assistance units so that small businesses are given fair notice and opportunity to comply: notification followed by
compliance assistance/education followed by enforcement. Presently, there is much tension between the compliance assistance and enforcement
groups, since each is perceived to represent mutually exclusive compliance strategies. However, most people in compliance assistance
acknowledge that enforcement is necessary after sufficient notification and assistance. These groups need to be working closer toward the
common goal of environmental health via environmental compliance.
In developing regulations that affect small business sectors, regulators need to take the needs of small businesses into account in developing ways
to achieve regulatory goals. For example, the dry cleaners, like most small businesses, have a difficult time with recordkeeping. Maybe there is
another way to determine compliance with the avoidance of leaks.. .maybe tracking PERC usage? Currently, developing regulations is done in
reverse: the regs are written and then small business impact is analyzed. In the case of EPA regulations, the small business impacts are taken
into account based on the limited input available from small businesses and the regulations are revised between proposal and final ruling.
However, at the state level, the regulatory impact analysis for small businesses is cursory and frequently underestimated.
SBREFA is the federal requlation that looks out for small business. Perhaps the states should be required to adopt SBREFA.
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
New York
(cont)
North Carolina
North Dakota
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
Streamline recordkeeping for small businesses and eliminate burdensome recordkeeping. Duplicative or trivial recordkeeping and reporting do not
serve any purpose. They do not encourage or improve compliance. Some examples: Why should a halogenated solvent cleaning NESHAP
source submit a report on exceedances twice a year whether or not they had any exceedances? How does a recordkeeping log from a dry cleaner
indicating that they checked their equipment for leaks prove that they actually looked for leaks? Such excessive paperwork only creates extra work
for the small business and takes away precious time that they could otherwise use to perform pollution prevention measures.
The SBEO/SBAP should take an active role in commenting on proposed federal regulations/control strategies that impact small businesses.
Although EPA's goal to have small businesses participate in the rule making process (SBREFA) is laudable, very few small businesses have either
the time or expertise to comment on proposed rules or control strategies. The SBEOs and SBAPs have the technical, legal, and economic
backgrounds to comment in a manner that could reduce the impact of a regulation on small businesses, while still implementing control strategies
that protect the environment.
The federal legislation that creates SBTCPs should also mandate minimum program staffing and funding, based on the number of affected sources
in each state. This would prevent state legislatures from gutting the funding for a program as a result of political or other pressures, or failing to
establish meaningful programs in the first place. Compliance assistance to regulated small businesses shouldn't be subject to political whims or
pressure from lobbyists for large businesses who feel their Title V fees shouldn't go toward helping other sources comply. There currently is
pressure by larger businesses and their representatives to reduce or prevent the use of Title V fees for helping small, non-Title V -affected sources.
Congress should examine providing funds for 507 programs from monies other than Title V fees.
The New York State Department of Environmental Conservation should institute the draft Voluntary Compliance policy as soon as possible.
Modify EPA policy of "once in, always in." This will allow major MACT sources to voluntarily reduce emissions below major thresholds to become
small "nonmajor" sources and receive benefits of less emissions, less recordkeeping, less reporting.
Support and expand initiatives for multimedia environmental assistance. Small business does not understand why 4-5 agencies have different
requirements and inspectors for one chemical or process. We must make it easier for business to understand the requirements. Once they
understand what they need to do, why, and how, compliance will improve.
EPA and state regulatory agencies need to be more receptive to allowing small business to do training, community environmental involvement, and
other educational efforts in lieu of fines for notice of violation. Certainly, first time offenders should be offered assistance in resolving their problem
or making sure it does not happen again, rather than fines.
Write reputations in lanquaqe more understandable to small business.
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Ohio
Oklahoma
Oregon
Pennsylvania
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
US EPA should finally decide that dry cleaners, chrome platers, or degreasers do not EVER need Title V permits. In most states, the number of
dry cleaners alone greatly exceeds the number of presently identified Title V facilities. Decide now - don't defer the issue for another five years.
Both state and federal regulatory agencies must continue to attempt to translate environmental requirements into language and forms that can be
understood by the small business person. This means simple language, clear charts and tables, and examples that have been tested in the field
with real business people.
Better cooperation between the Regions and the states.
The greatest obstacles to assisting small businesses in complying with the CAA are the lack of financial and staffing resources. Many SBAPs are
functioning at a 1.0 FTE level. More educational training, financial, and support assistance are needed. Also, achieving compliance through
educational programs emphasizing pollution prevention should be given a higher priority at both the federal and state levels.
Financial
• Allocate $5 million to SBAPs.
Develop a national policy that allows small businesses to invest in P2 technologies.
Institute a revolving fund to finance small businesses willing to invest in MACT and BACT.
Fund small business R&D projects with emphasis on P2.
Regulatory
• Adopt realistic potential to emit criteria for small businesses.
Adopt simple, less costly emission testing procedures for very small area NESHAP businesses.
SBAP Support Projects
Develop an easy-to-use national technical assistance tracking and reporting database.
• Develop a national small business mentorship program.
• Develop a national cross-media P2 green sticker recognition program.
Develop a national simplified ISO 14000 plan for small businesses.
Education
Develop a national educational program at state small business development centers.
• Use OR SBAP-SBDC P2 cross-media training as model for national program.
• Employ state SBDCs to disseminate specialized training.
Training
• Offer 1-2 hour teleconferences for all area source NESHAP regulations.
• Develop 30-minute training videos with workbooks for small business sectors.
• Offer teleconferences on cross-media P2 and environmental auditing.
• Offer a national training teleconference for environmental consultants serving small businesses.
N/R
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
N/R
As EPA makes industry-specific regulatory changes, it would be helpful for federal or state officials to hold workshops (or informational sessions)
for industries so that they can be made aware of what's required of them to comply with the new changes. The workshops would be held once a
regulation is set to become law and in a manner that would allow the affected industry a reasonable timetable to comply. It also would be helpful to
have industry associations participate in this process by being available to assist their members in making any transitions necessary to comply with
the new or amended regulation.
N/R
EPA should increase their efforts in helping states identify sources or categories of sources that will be affected by a MACT standard.
EPA should discontinue the policy of "once in, always in." It does nothing but hamper efforts to get facilities to reduce toxic emissions.
Too many organizations and layers of government offering help to the employers. Congress should recognize and fund state Section 507 (CAA)
groups to interact with small business administration efforts to serve employer needs.
At the federal level, include small business review and input in rulemaking process. Streamline permitting process. Include a "de minimus"
concept for all media. Expand available exemptions. Write exemptions for small businesses into all rules; use a stairstep approach where controls
increase as business size and production increase. Write rules in plain language. Make compliance conditions, such as recordkeeping and
reporting, easier by using common business terms (e.g., gallons used vs pounds/hour, or gallons generated for hazardous waste). Make all
SBAP assistance at the state and federal level multimedia and reinforce it with funds for the program. Increase availability of low-cost loans.
Environmental assessment training opportunities -- Industry-specific training sessions that provide a step-by-step approach to conducting on-site
environmental assessments (including P2 assessments) would be of great benefit to SBAP staff.
N/R
At the federal level, we would recommend that the Small Business Enforcement and Self-audit Policies be reviewed and changed to provide
consistency of application and interpretation by all EPA Regional Offices. The small businesses do not now see these policies as affording any
degree of safety that might encourage them to utilize them as they make repairs to any compliance deficiencies they may have. Many businesses
will not come forward and identity themselves if there are potential penalties involved. Because the application of the policies is on a case decision
basis, differences in application may be inconsistent from region to region or even within a region, again providing uncertainty about the use of the
policies. Once the policies are uniformly accepted, understood, and implemented by the regional offices, the EPA should embark on a heavy
marketing campaign to promote them as non-enforcement incentives. Marketing was lacking the first time around.
Resolution of compliance problems caused by new regulations or existing requirements must provide adequate time for small businesses to
incorporate potential resource expenditures, both financial and human, that the company may require.
N/R
No response
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TABLE G-2
(Continued)
PROGRAM
Virginia (cont.)
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
More comprehensive economic impact analysis of regulations affecting small businesses. Is the gain in emission reduction worth the price that will
have to be paid?
Provide adequate funding by EPA to promote and provide for program expansion into multimedia (water, waste, and small community assistance).
Have the Small Business Administration create a revolving loan fund to assist small businesses to finance their compliance activities.
One standard form for on-site visits and recordkeeping. Continued training for SBO/SBAP.
Clearer language in regulations.
Enact federal legislation that requires the states to promulgate an effective "self audit" program for small businesses.
The state of WV and the federal government, if necessary, would enact legislation that authorizes the SBO to function as a multimedia
ombudsman.
Federal legislation should be enacted that allows SBREFA to apply to federal programs that have been delegated to the states.
Find a new way to measure success. Regulatory agencies should look for positive measures of pollution reduction/elimination instead of dollars
collected in fines or number of enforcement actions.
Provide targeted grant funding to help small businesses that want to implement P2 or other compliance-related programs, but can't afford the up-
front costs.
N/R
No response
8
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TABLE G-3
CONFLICT OF INTEREST/CONFIDENTIALITY ISSUES
The SBTCPs provided information as to how their programs address internal or external conflicts of interest (COI) or perception that
their programs may not be confidential.
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of Columbia
COI ISSUES AND RESOLUTIONS
N/R
SBAP is located in the Compliance Assistance Office (CAO) of the Division of Statewide Public Service (SPS). The CAO is located
in a non-regulatory and non-enforcement office within the Department. Under AK law, CAO staff providing on-site assistance do not
have enforcement authority. In addition, the Division has developed reporting relationships with EPA and other divisions that do not
require facility names to be identified. CAO only shares the nature of compliance concerns identified.
Existing policies, strong support from the Director of the ADEQ, and good working relationships with the programs have done a great
deal to maintain our credibility as a source of assistance that can be used without risk of exposure.
Our program does not advertise confidentiality. In fact, before we conduct a site visit, we inform the business that our report is not
confidential. The simple fact is that our enforcement personnel and NGOs have better things to do than comb our files for people
who are already taking steps to come into compliance voluntarily.
Confidentiality has not been a problem to date. We take the position of educating the site on their regulatory obligations and the
possibility of enforcement action if they fail to comply with applicable regulations. We, however, do not "turn them over" if they don't
follow through by submitting their application or paperwork.
Confidentiality has never been considered a problem. Where small business can avoid a relationship with the regulatory agency, a
relationship will be avoided.
The Ombudsman's Office is part of the Air Resources Board Chairman's Office, and no COI or confidentiality issues have arisen yet.
Businesses constantly ask for reassurance. We now have a reputation for maintaining confidentiality and by word-of-mouth and
trade association referrals, customers are open to our services. Our Local Government and Small Business Committee is reviewing
this issue in 1999.
To date and since the SBO program's beginning (12/1/97), the SBO has had no COI regarding confidentiality. The same goes for
our SBAP.
Connecticut does not offer confidentiality.
Not a problem.
The SBAP is a permit engineer as well as an inspector who can recommend or carry out an enforcement action. In this situation,
the conflict of interest is unavoidable.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
COI ISSUES AND RESOLUTIONS
We do not require that an inquirer identify him/herself. We do not disclose compliance issues to the enforcement section.
The SBAP avoids the discussion of confidential material with enforcement personnel unless enforcement makes a referral. When
discussions are unavoidable, the business names are not used; or, circumstances are presented and assurances are secured
before any sensitive materials are discussed.
Separate SBO/SBAP mailing lists and intake files. Confidentiality offered to all SBO callers/contacts and maintained where
requested. Secured and locked SBO files.
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.
We are located separately from the regulatory agency. We do not share client information with the IEPA unless the client is
comfortable with this and we are facilitating their discussion.
If a Freedom of Information Act request was made, we would only have to give numbers and not names of companies assisted.
IN's Compliance and Technical Assistance Program (IN's SBAP), which is part of IDEM (the regulatory agency), operates under
strict confidentiality as mandated by state statute (1C 13-28-3-4). The statute prohibits program staff from revealing confidential
information to personnel in the agency or to the public unless the client specifically waives confidentiality, or if there is a clear and
immediate danger to public health or the environment.
A non-rule policy document (published in the December 1996 Indiana Register) and written confidentiality procedures add
explanations and details on how we implement the statute. The written procedures are changed, as needed, to reflect new
information or new situations that have arisen. During 1998, the procedures were updated twice.
The physical location of CTAP is in a separate building than the rest of IDEM, and access to the office is limited. Only the main
reception area, conference room, and mail room are public areas in which anyone is allowed. Other areas are either escort-required
(private offices, kitchen, main aisle) or access prohibited (individual cubes, side aisles, and staff meeting areas). Accessibility is
indicated by posted signs and colored tape on the floor and doorways.
Working effectively within IDEM's regulatory offices is sometimes difficult, because our strict confidentiality policy can hinder
communication or coordination of efforts.
The IAEAP is funded by the IA Air Quality Bureau (AQB) of the IA DNR. Contract terms stipulate disclosure of the IAEAP client
information to the AQB if such information is requested. Unless specifically requested (very rarely), no client information is
volunteered to the requlatorv aqencv. The IAEAP clients are informed that "confidentiality" does not exist with the SBAP.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
COI ISSUES AND RESOLUTIONS
Confidentiality has not been an issue with the KS program. KDHE's contract with the universities indicates that business names will
be confidential. Reports indicate businesses by SIC code, county, and type of question (in general) only. The ombudsman
maintains confidentiality by agreement of the regulatory bureau directors who understand the importance of confidentiality. In some
instances, it is difficult to resolve a conflict when the name of the business is to remain confidential. In these cases, we discuss
options with businesses and explain these difficulties. Most of the time, businesses are interested in resolving their problems and
will waive confidentiality to expedite resolution.
Compliance issues where confidentiality is impossible (e.g., permit application submission) are resolved by the Division for Air
Quality recognizing the TAP'S assistance is a good faith effort to comply, thereby waiving or reducing civil penalties. This is
explained to the business during the application completion process. Other issues (e.g., compliance issues with standards or
control requirements) are handled confidentially through compliance agreements between the small business and the TAP.
An amnesty program is in place to encourage honest and prompt self-reporting.
We have had no problems regarding confidentiality with state enforcement. Regional EPA inspectors come into the state,
unannounced, and levy heavy fines on small businesses we have been working with, which results in the perception that our
program is not confidential.
SBTAP has adopted the Small Business Compliance Incentives Policy based on EPA guidance.
N/A
OTA is outside of the regulatory agency and has a statutory mandate for confidentiality.
External conflicts of interest
Confidentiality has not been an issue with the current services provided by the SBTCP. The SBAP is developing guidance
publications, presenting 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 is in the process of developing a policy that explains how the program will respond when it becomes aware of a violation
by a facility seeking assistance. The policy also will explain that information contained in the SBTCP files or databases will not be
snared with the regulatory agency (Ml Air Quality Division). Presently, Mi's SBTCP cannot claim that this information is "confidential"
unless a facility invokes a provision in Mi's recently enacted "Environmental Audit Privilege and Immunity" law, which designates the
terms of confidentiality between a facility and the regulatory agency in a "confidentiality agreement."
Internal conflicts of interest
The SBTCP works closely with the regulatory agency (Ml 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 CAA. Mi'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
avoidina internal conflicts of interest.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
COI ISSUES AND RESOLUTIONS
SBAP has a signed memorandum of understanding (MOU) with the MPCA's enforcement programs. This MOU has been well
respected by the enforcement programs, thus enabling the SBAP to provide consistent confidential compliance assistance to small
businesses. The small business community is aware of the successful history of the MOU, and is comfortable with the relationship it
has created between the SBAP and the MPCA's programs.
The SBO, while not covered under the MOU, is able to operate confidentially and independently due to statutory language in the
enabling legislation. This condition also has been well respected by the MPCA's enforcement programs, which has created trust in
the SBO within the small business community.
The SBO and SBAP are regarded by DEQ as independent, confidential, and non-regulatory. Regulatory programs are regarding
these programs as confidential to small businesses.
On-site assistance is provided by an outside organization as authorized in EPA's Enforcement Response Policy for SBAP's option 2.
Therefore, no written correspondence on the compliance status of a small business is maintained by the SBO or SBAP.
The regulatory programs and TAP have an understanding that regulatory programs cannot look at TAP'S records unless a facility is
under enforcement. If TAP finds a violation that is not an immediate threat to human health or the environment, recommendations
are made to get the facility into compliance, but no report is turned over to the regulatory programs. If a violation that is an
immediate threat to human health or the environment is encountered, the facility is notified that TAP must report this to the
appropriate regulatory program. Facilities that come to TAP for assistance are favorably looked upon when it is discovered they
need a permit and TAP assists them with attaining compliance.
MT's SBO/SBAP follow the EPA's Compliance Incentives for Small Business Policy when dealing with its clientele.
Not a problem in NE.
None defined.
The SBTAP's policy continues to offer businesses the option of remaining anonymous or taking advantage of the Compliance
Incentives Policy. We continue to encourage businesses to use the Compliance Incentives Policy and have found the majority of
businesses we deal with are indeed taking advantage of the Policy. We still work cooperatively with our state-level enforcement
personnel to ensure those businesses that voluntarily approach the SBTAP are not subject to punitive enforcement actions if they
agree to comply within a set time frame.
As a general rule, the NH SBTAP discourages businesses from remaining "confidential," as they are not "protected" in the event
they are subject to a random compliance inspection.
SBAP has an agreement with NJDEP Enforcement that SBAP information is confidential. SBAP publicizes this in all collateral
marketina material as well as at meetinas. seminars, and verballv on the telephone.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
New Mexico
NM SBAP does not offer confidentiality. However, any information that is observed by or revealed to the SBAP and claimed as a
trade secret by the small business will be treated by the Environment Department to the extent allowable under State law. The
procedure for identifying trade secrets to the Environment Department is described in NMED's Public Records and Inspection
Policy.
New York
Confidentiality is key to the success of assistance programs designed to help businesses comply with environmental requirements.
Recognizing this, New York State has designed its 507 programs to have the SBAP and the SBEO each located in non-regulatory
state agencies. Further New York State assured the confidentiality of the small businesses working with the program by passing
legislation that maintains under state law the confidentiality of their identity, location, and other plant information and protects this
information from access under the Freedom of Information Law.
In this way, companies can be frank in describing their problems without fear of reprisals or penalties. However, confidentiality is not
a shield against enforcement that is conducted independently by the regulatory agency, but is in place to encourage more
companies to discuss their problems so they may achieve compliance.
North Carolina
Generally, the Department's policy of confidentiality for the Office of the Small Business Ombudsman has worked well. There have
been several cases where we were helping a client submit an air quality application or do an assessment and identified unpermitted
equipment. Air Quality sent a notice of violation or took enforcement action against the client soon after issuing the permit. This
sends a signal that if you are trying to do the right thing and take initiative, you will still be punished. The Department has attempted
to strengthen its enforcement program and some have interpreted giving a fine for everything as part of that policy. We need to
better publicize that the self-confessor oolicv rewards voluntary efforts.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
North Dakota
The environmental programs of the Department's Environmental Health Section have traditionally been compliance assistance
oriented, with enforcement reserved for recalcitrant violations or where damage to health 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
noticeably changed, but there has been more outreach activity.
We don't know whether small businesses are reluctant to request assistance or confide in the SBO, since the ombudsman is
housed in and employed by the Department of Health. Besides serving as the SBO, the ombudsman has other duties that support
the administrative functioning (e.g., petroleum product quality testing program; coordinating emergency response, quality assurance,
P2, and various staff training needs) of the Environmental Health Section. The SBO's assistance regarding enforcement matters
has not been requested to date. The SBO has requested the Department's Chief of the Environmental Health Section to refer cases
to the SBO when a small business expresses dissatisfaction or frustration in their dealings with the Department. This is an area that
should receive continued monitoring and evaluation.
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 as not disclosed to or sought to be disclosed from the SBAP. Information disclosed by
small businesses to SBAP staff would not be turned over to the compliance program staff for enforcement purposes; however, a
plan for correcting any violations would be developed. When needed, the SBAP will provide compliance assistance.
In the opinion of the SBO and SBAP, confidentiality (disclosure of violations to enforcement staff) has really been a non-issue in ND.
Ohio
SBAP is physically separated from OEPA enforcement staff (different floors) and is not located at a district office where enforcement
begins. SBAP files are kept in a separate area, and SBAP databases are accessible by SBAP only.
SBAP has not experienced any problems with keeping information confidential. In some cases where the customer was referred by
a district office because of violations, the SBAP has not spoken directly with the district to resolve the problem. This was done only
with the prior approval of the company.
In 1998, SBAP received a public records request under OH's Public Records Law from counsel representing a company that was in
enforcement. (The company requested SBAP assistance after the District Office found violations, and the SBAP had repeatedly
worked with the company for nearly two years to correct the problems.) Presumably, the company was attempting to claim the
SBAP's recommendations as "official EPA findings" to invalidate the District Office violations. SBAP consulted OEPA legal staff,
who determined that SBAP information was exempt from the Public Records Law. No SBAP files were given to either the company
or enforcement staff.
The SBO is located in a nonregulatory agency and provides a gateway to assistance not connected to OEPA. State statute
establishing the program (SBO and SBAP) explicitly makes almost all information gathered by the program confidential (emissions
data are excluded) and excludes use of any information in state enforcement actions.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
COI ISSUES AND RESOLUTIONS
The SBAP being housed in the nonregulatory Customer Service Division in our agency has allowed us to effectively develop trust
with many businesses. Our group is supported very strongly by our Agency management and, as a result, we are provided with the
tools we need to provide quality confidential assistance.
Information disclosed and minor violations discovered during on-site small business technical assistance visits are protected by
state statute except when there is reasonable cause to believe there is clear and immediate danger to public health or safety of the
environment. In accordance with state statute and the confidentiality option set forth in EPA's Office of Enforcement and
Compliance Enforcement Policy, OR SBAP has adopted a written confidentiality policy. In summary, this policy allows the SBAP to:
• Function independently of the enforcement section.
• Restrict access to information and files of small businesses receiving technical assistance.
• Keep businesses' names and locations in a separate, confidential file.
• Perform follow-up consultations to assure resolution of violations discovered during on-site visits.
This policy has prevented conflicts inside and outside the agency. To the contrary, it allows additional flexibility to bring small
businesses into environmental compliance. For example, it allows the SBAP to assist a small business that faces enforcement
through other channels by allowing staff to assist with P2, permit applications, and penalty mitigation via supplemental
environmental projects. In such cases, OR's confidentiality policy is congruous with EPA's Policy on Compliance Incentives for
Small Businesses.
The technical assistance program is operated by an outside contractor that keeps all of its clients confidential, thereby eliminating
any potential conflict of interest.
This matter hasn't been addressed yet.
Rl DEM has been operating a non-regulatory technical assistance program since 1987. Since that time, we have worked with
hundreds of companies and have gained the trust of many more. Conflicts of interest are avoided through close coordination with
the regulatory Office of Air Resources. Coordination with our state's Economic Development Corporation also has been helpful in
stressing our Office's pledge to work with industry on a confidential basis.
Upper management has supported the SBAP in part by informing the regulatory program areas of the services provided and
encouraging the areas to use the SBAP as much as possible.
N/A
The regulated community accepts and respects the benefits of our program being confidential. The only differences of opinion that
developed involved the use of company lists. We remained firm and were not challenged on anv decisions.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
Texas
Utah
Vermont
Virginia
Virgin Islands
Washinaton
COI ISSUES AND RESOLUTIONS
TX's confidentiality policy states: All contact with the Small Business Assistance Program is confidential, and the enforcement
division of the TNRCC cannot seek information regarding these contacts.
This policy has allowed us to work with our enforcement offices on a number of projects, such as the Metal Finishing and Auto
Body/Auto Repair Initiatives, and still maintain the confidentiality of the businesses that contact us.
Many businesses like our confidentiality policy and have commented that it gives them confidence and trust to call us. Usually, once
a business uses our services, they will contact us again if necessary. Because we have a high satisfaction rate, we have a large
number of repeat callers. However, even with the existence of the confidentiality policy, some small businesses are still hesitant to
contact our office because they view us a regulators and do not realize that our office is independent from enforcement.
We use the EPA's policy as a model for compliance incentives for small business, which was issued May 20, 1996.
We started with an internal policy on confidentiality, signed by the Commissioner of Environmental Conservation and have had no
problems. In order for a regulator to access my files, they literally have to jump through hoops. As time goes on and businesses
see that this trust is not breached, their trust in the system grows.
Confidentiality, as indicated in last year's report, is still not a major problem. This issue will take on more importance when the
SBAP is able to provide voluntary site assessments as a part of normal program operations. The ability to deliver a quality product
to the customer is only as good as the credibility of the provider. The ability to correct the deficiencies and non-compliance
situations through the 507 Enforcement Policy provides a non-confrontational means for a business to achieve compliance. A
business will respond when it feels it controls financial business decisions. Compliance through the 507 Enforcement Policy can be
put into the category of a smart business decision. In this regard, the DEQ has at its disposal EPA's Section 507 Enforcement
Policy.
Within DEQ, the SBO/SBAP continues to maintain an excellent working relationship with the Enforcement and Compliance Office,
which also helps to ensure an understanding of the needs on both sides of compliance enforcement issues. We both recognize that
compliance is the ultimate goal, and compliance assistance can become, and is, a means to that end.
We have separated the various sections of DPNR.
This has never been a problem.
N/A Not applicable N/R No response
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TABLE G-3
(Continued)
STATE OR
TERRITORY
COI ISSUES AND RESOLUTIONS
West Virginia
SBAP operates separately and independently from the enforcement group of the agency. Also, the SBAP currently is housed in a
separate physical location. To better help small businesses, enforcement refers some violators to the SBAP for technical assistance
to facilitate compliance. The 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, the 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 state (or federal) inspectors
during this period. Such independent discovery may occur through routine inspection activity or complaint investigation.
The PEP director has given strong assurances that the confidentiality of all assistance programs shall be respected.
Wisconsin
Wl SBAP/SBO is a cooperative effort between the Wl Department of Natural Resources (DNR) and the non-regulatory component
of the Wl Department of Commerce (Commerce). The primary responsibility for interacting with businesses rests with Commerce
staff. A memorandum of understanding has been established between Commerce and DNR that allows businesses to speak to
Commerce staff on a confidential basis. As a rule, we ask customers if they do not want to be identified if we have to discuss their
situation with a DNR representative.
Wyoming
This issue of confidentiality has been addressed in a draft policy that allows the Office of Outreach to hold in confidence contacts
and conversations. This confidentiality does not offer protection from discovery, but rather is a personal commitment not to divulge
information to others. In the event that the Outreach staff appear as witnesses in any legal action, any oral communication or
contacts may be disclosed. The Outreach staff must report through proper channels serious problems noted, including public health
risks, safety problems, or criminal activity. Contacts with the Office of Outreach involving or requiring the documentation of
problems encountered may be referred to Department regulatory staff. Office documentation developed through customer
interaction is not confidential and will be available to the public.
N/A Not applicable N/R No response
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TABLE G-4
EPA's POLICY ON COMPLIANCE INCENTIVES FOR SMALL BUSINESSES/SMALL COMMUNITIES
SBTCPs were asked if their program used EPA's Policy on Compliance Incentives for Small Businesses or a comparable state policy
for small businesses/small communities. Individual program responses are shown below.
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Arkansas
California
South Coast
Colorado
Connecticut
Delaware
District of
Columbia
SMALL BUSINESS POLICY ACTIVITIES
N/R
When facilities request on-site compliance assistance, they are also
agreeing to implement any compliance "to do" action items identified
during the site visit. Facilities are provided with an initial 90-day
correction period with an opportunity for extending this time frame. An
extension request needs to be communicated in writing. The terms
are negotiated depending on the circumstances. Extension terms are
similar to the EPA 507 policy.
ADEQ has adopted the Enforcement Waiver Policy (Small Business).
which waives penalties if business meets similar criteria as in EPA
policy. ADEQ policy does not address economic benefit. No
business has applied for the policy as of this time.
N/A
AR developed a "voluntary compliance" policy based on national
policies. Works well. Did not impact regulatory enforcement program
as first feared.
N/R
Staff goes to the company and identifies whether they need a permit.
Provides technical assistance as needed, helps submit forms, and
follows-up. To date, all small businesses have come into compliance
that have received this help.
None. Some programs initiating in 1999 may fit in this category.
CT developed sector-specific policies tailored to specific compliance
goals. Enforcement policies were developed specifically for auto body
refinishing and gas stations.
DE has a Penalty Mitigation Policy that has seen limited use by
business and industry during 1998. Its use is not limited to small
business. In fact, businesses with more than 100 employees have
been the largest users of the policy.
N/R
SMALL COMMUNITY POLICY ACTIVITIES
N/R
The Division of Statewide Public Service is developing a small
community compliance assistance program that includes
compliance incentives that generally are consistent with EPA's
approach. This program currently is in the design and pilot-test
phase.
N/R
N/A
N/R
N/R
N/A
N/R
N/R
N/R
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
PROGRAM
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
SMALL BUSINESS POLICY ACTIVITIES
This policy was not in place in 1998, but will be considered in 1999.
GA has not used EPA's Policy on Compliance Incentives for Small
Businesses or Small Communities.
SBO disseminated details of EPA/DOH compliance
incentive/enforcement policy to all focus groups, technical assistance,
and individual contacts.
None
N/R
N/A
We have not used the EPA policy with any of our clients yet. We
have a state amnesty policy applicable only to state construction
permit requirements. The IAEAP and IDNR formulated that policy in
1 997 and set a deadline of July 1 , 1997 for sign up. At that time, 167
businesses signed up, and we are still working with businesses on
that list.
Since then, we have a more general amnesty policy in place. In the
last two years, approximately 50 businesses have taken advantage of
this policy. We are in the process of implementing a newly approved
self-audit state law that will supersede the previous amnesty policies.
N/R
N/A
N/R
The policy is available, but we have not had an occasion to use it.
17 companies have used the policy since its adoption in 1995. One
wood products company used the policy in 1998 due to hazardous
waste violations discovered during an on-site assessment.
N/A
SMALL COMMUNITY POLICY ACTIVITIES
There is a Small Community coordinator position in the office of
the Secretary; however, it is not part of the SBO/SBAP office.
N/R
N/R
None
N/R
N/R
N/R
N/R
N/A
N/R
N/R
N/R
N/A
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
PROGRAM
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
SMALL BUSINESS POLICY ACTIVITIES
EPA's policy requires self-reporting and has not seen much use.
Businesses are reluctant to self-report. DEP's policy does not require
self-reporting, but it is only applicable to businesses with 10
employees or less.
Our autobody "Crash Course" promoted the use of existing good faith
penalty mitigation policies. The advantages are: no self-reporting is
required, it is applicable to any size facility, and no amnesty is
promised. Thus, the enforcement agency retains discretion to set
penalties when justified by economic benefit, seriousness of harm, or
any other consideration.
Ml SBAP is in the early stages of using both the Ml and EPA
enforcement policies by working with companies that have both state
and federal violations.
N/R
N/A
Not used.
The MT SBO/SBAP have used the policy in granting certain
protections from enforcement action to small businesses that work
with the program to achieve compliance. Businesses appreciate the
guarantee of protection along with the free technical assistance
offered by the program.
None.
None requested.
We utilize the Compliance Incentives Policy as a guiding rule for
program operation. We strongly encourage businesses to take
advantage of the policy, as it affords "protection" against punitive
actions and rewards proactive activities. We continue to develop a
more formalized approach to its use (i.e., a written request to take
advantage of the policy and an MOU between the program and state
Enforcement Section).
N/A
N/R
SMALL COMMUNITY POLICY ACTIVITIES
No information available.
N/A
N/R
N/A
Not used.
Have not had an opportunity to use the small community policy.
N/R
None requested.
N/R
N/A
N/R
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
PROGRAM
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
SMALL BUSINESS POLICY ACTIVITIES
The SBEO tried to bring one client into compliance using EPA's Small
Business Policy. The business was a major source with uncontrolled
emissions that wanted to undertake a P2 project that would make his
facility a minor source within 1 year. When approached with the case,
the EPA did not believe that the source would be accepted into the
policy, because having uncontrolled emissions in the past, it would be
considered a significant violator, and therefore, not eligible. The EPA
also warned that the source could not be protected from enforcement
by New York State, which does not have a voluntary compliance
policy. As a result, the business has not yet come forward to the
regulatory authorities, and the business has not yet undertaken its P2
project. Conversations are still taking place with EPA and New York
State officials to find a solution to this case.
NC has a confidentiality policy, but does not apply EPA small
business policy requirements. That specifically relates to reducing
penalties.
None.
None.
We have an internal agency policy similar to EPA's that allows us to
waive civil penalties for those facilities that come forward. This policy
may be invoked by a business under certain circumstances only.
None.
N/R
N/R
None.
N/R
None.
TN developed a self-policing and voluntary correction policy. This
policy was developed using the SAP compliance incentives for small
businesses. The provision allows a company to correct a compliance
problem provided certain conditions are met.
SMALL COMMUNITY POLICY ACTIVITIES
N/R
N/A
N/R
N/R
N/R
None.
N/R
N/R
None.
N/R
N/R
N/R
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
PROGRAM
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
SMALL BUSINESS POLICY ACTIVITIES
OCE does not have any policies exclusively for small businesses.
However, the majority of enforcement actions initiated in the regional
offices that are informally resolved involve small businesses. Informal
resolution means that the violations were resolved between the
inspector and the entity without the case going through the formal
enforcement process and without the assessment of a penalty. Based
on data obtained from the Enforcement Division's annual report for
FY98, 51,795 enforcement actions involving small businesses were
informally resolved.
N/R
None.
None in this reporting year.
N/R
N/R
None at this time.
The flexibility already built in to the Wl DNR's stepped enforcement
policy makes existing federal compliance incentives redundant. Our
DNR has chosen not to implement this policy.
The Department has its "Small Business Voluntary Disclosure and
Compliance Incentive Rule" in place, which mirrors the EPA policy
and is applicable to multimedia. The basics of this Rule have been
published in our newsletter and in handout material provided to
businesses during on-site visits and in public displays and
presentations. The Rule has generated limited interest in the small
business community and led to a handful of positive responses this
year.
SMALL COMMUNITY POLICY ACTIVITIES
N/A. Agency's Local Government Assistance Program handles
compliance assistance for small communities.
N/R
N/R
None.
N/R
N/R
N/R
N/A
The Department has not developed a formal policy for small
communities. However, it is policy of the Department not to seek
penalties when municipalities work to come into compliance.
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
Program
AL
AK
AZ
Maricopa
AR
CA
South
Coast
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
Small Business Policy / Small Communities Policy
# Small Entities
Qualifying Under the
Policy
N/R
N/R
N/R
N/R
No reporting data
maintained.
N/R
156/
N/R
Not used
N/R
N/R
N/A
N/R
N/R
N/R
N/R
N/R
# Small Entities Attempting
to Use Policy, Still Under
Consideration
None
# Small Entities Attempting
to Use Policy, But Not
Qualifying
None
Total $ Amount of Penalties
Reduced
None
N/A Not applicable N/R No response
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TABLE G-4
(Continued)
Program
IA
KS
KY
Jeff Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
Small Business Policy / Small Communities Policy
# Small Entities
Qualifying Under the
Policy
N/R
N/R
N/R
N/R
N/A
1/
N/R
Info not available
N/A
N/R
N/R
N/R
71
N/R
N/R
Not tracked/NA
N/R
N/R
# Small Entities Attempting
to Use Policy, Still Under
Consideration
07
O/
# Small Entities Attempting
to Use Policy, But Not
Qualifying
O/
1/
1/
Total $ Amount of Penalties
Reduced
unknown/
N/A
N/A Not applicable N/R No response
-------
TABLE G-4
(Continued)
Program
NC
ND
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wt
Small Business Policy / Small Communities Policy
# Small Entities
Qualifying Under the
Policy
N/R
N/R
N/A
Do not track information
N/R
N/R
N/R
N/R
N/R
12/
Not tracked
N/R
N/R
N/R
N/R
N/R
N/R
N/A
# Small Entitles Attempting
to Use Policy, Still Under
Consideration
1/
12/
# Small Entities Attempting
to Use Policy, But Not
Qualifying
1/
Total $ Amount of Penalties
Reduced
N/A Not applicable N/R No response
8
-------
TABLE G-4
(Continued)
Program
WY
Small Business Policy / Small Communities Policy
# Small Entities
Qualifying Under the
Policy
Several sought help under
this rule, but none actually
required penalty relief /
# Small Entities Attempting
to Use Policy, Still Under
Consideration
# Small Entities Attempting
to Use Policy, But Not
Qualifying
Total $ Amount of Penalties
Reduced
N/A Not applicable N/R No response
------- |