United States Policy, Planning, EPA 233-R-97-001
Environmental Protection And Evaluation December 1997
Agency (2131)
c/EPA Status Of The State
Small Business Stationary
Source Technical And
Environmental Compliance
Assistance Program (SBTCP)
Report To Congress
For The Period
January To December 1996
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REPORT TO CONGRESS
STATUS OF THE STATE SMALL BUSINESS
STATIONARY SOURCE TECHNICAL AND ENVIRONMENTAL
COMPLIANCE ASSISTANCE PROGRAM (SBTCP)
FOR THE REPORTING PERIOD
JANUARY - DECEMBER 1996
PRESENTED BY:
KAREN V. BROWN
SMALL BUSINESS OMBUDSMAN
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC
DECEMBER 1997
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ACKNOWLEDGEMENTS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
grateful for the support of the dedicated staff of the State Small Business Stationary
Source Technical and Environmental Compliance Assistance Programs (SBTCP),
including the Small Business Ombudsmen (SBOs), Small Business Assistance
Programs (SBAPs), and the Compliance Advisory Panels (CAPs) in the preparation of
this second Annual Report to Congress. All states and territories submitted timely
reports to make this report complete and comprehensive.
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TABLE OF CONTENTS
Page
ACKNOWLEDGEMENTS i
LIST OF COMMON ACRONYMS iv
EXECUTIVE SUMMARY v
1.0 INTRODUCTION AND REPORT OVERVIEW 1-1
1.1 Rationale and Objective of the Report to Congress 1-1
1.2 Data Collection Methodology 1-1
1.3 Organization of the Report 1-3
2.0 OVERVIEW OF THE SBTCP 2-1
2.1 Small Business Ombudsman 2-1
2.2 Small Business Assistance Program 2-2
2.3 Compliance Advisory Panel 2-2
2.4 EPA's Responsibilities Under Section 507 of the CAA 2-3
2.5 Federal Small Business Assistance Program 2-3
3.0 SBTCP STATUS, BUDGETS, STAFFING AND ORGANIZATION 3-1
3.1 Operating Status 3-1
3.2 Budgets 3-2
3.3 Staffing Levels 3-8
3.4 Administrative Locations of SBO and SBAP Components 3-10
4.0 SBTCP ACTIVITIES AND SERVICES 4-1
4.1 Industry Sectors Assisted by the SBTCPs 4-1
4.2 Principal SBO, SBAP, and CAP Activities and Services 4-3
4.3 SBTCP Financial Assistance Programs 4-10
4.4 Leveraging of Resources and Minimizing Duplication of Efforts . 4-11
4.5 SBTCP Compliance with Section 507(d)(2) 4-13
5.0 PROGRAM EFFECTIVENESS 5-1
5.1 Comments Received by SBO or CAP on SBTCP 5-1
5.2 Complaints Received by SBO or CAP and Resolution Strategies . . 5-1
5.3 Program Highlights and Accomplishments 5-3
6.0 COMPLIANCE ASSURANCE ISSUES 6-1
6.1 Common Compliance Problems 6-1
6.2 improvements in Regulatory Understanding and Compliance .... 6-2
6.3 Recommended Changes to Facilitate Small Business
Compliance with the CAA 6-5
6.4 Program Confidentiality 6-7
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TABLE OF CONTENTS
(Continued)
LIST OF TABLES
Table No. TJUfi Eaflfi
3-1 Operating Status of the SBTCP Components 3-1
3-2 Start of Operations for SBTCP Functions 3-2
3-3 1996 SBTCP Operating Budget Ranges 3-3
3-4 1996 SBO Operating Budget Ranges 3-4
3-5 1996 SBAP Operating Budget Ranges 3-5
3-6 1996 CAP Operating Budget Ranges 3-6
3-7 SBTCP Reporting Period Budget Comparisons 3-7
3-8 Staffing Levels (as FTEs) Serving the SBO & SBAP Functions ... 3-9
3-9 CAP Appointments , 3-10
3-10 Administrative Locations of SBO and SBAP 3-11
4-1 SBO Outreach Activities 4-4
4-2 SBAP Outreach Activities . . 4-5
4-3 Information Available on SBAP BBS and WWW Pages 4-6
4-4 Major CAP Activities 4-7
4-5 Frequency of Meetings Among SBOs, SBAPs, and CAPs 4-9
4-6 Financial Assistance Programs 4-10
4-7 Programs That Report Leveraging of Resources for
SBTCP Functions 4-11
4-8 SBTCP Mechanisms for Avoiding Duplication 4-12
4-9 SBTCP Activities to Follow the Intent of the Paperwork
Reduction Act 4-15
4-10 SBTCP Activities to Follow the Intent of the Regulatory
Flexibility Act 4-15
4-11 SBTCP Activities to Follow the Intent of the Equal Access
to Justice Act 4-16
6-1 Common Compliance Problems 6-1
6-2 Improvements in Regulatory Understanding 6-3
6-3 SBTCP Recommendations for Improving Compliance 6-6
APPENDICES
A 1996 SBTCP Reporting Form
B Federal Small Business Ombudsman
C Federal Small Business Assistance Program
D SBTCP Status, Budgets, Staffing, and Organization
E SBTCP Activities and Services
F Program Effectiveness
G Compliance Assurance Issues
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LIST OF COMMON ACRONYMS
Provided below is a list of the major abbreviations and acronyms which are commonly
used in this report.
CAA Clean Air Act as amended in 1990
CAP Compliance Advisory Panel
COI Conflict of Interest
EPA Environmental Protection Agency
FTE Full-time Equivalent
ICR Information Collection Request
OECA Office of Enforcement and Compliance Assurance
OMB Office of Management and Budget
SBAP Small Business Assistance Program
SBO Small Business Ombudsman
SBTCP Small Business Stationary Source Technical and Environmental
Compliance Assistance Program
SIC Standard Industrial Classification
SIP State Implementation Plan
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman
(SBO) is pleased to submit this second Annual Report to Congress describing the
activities and accomplishments of the state Small Business Stationary Source
Technical and Environmental Compliance Assistance Programs (SBTCPs) during the
reporting period, January 1 - December 31, 1996.
This report is being submitted in accordance with Section 507(d), Monitoring, of the
Clean Air Act, as amended in 1990 (CAA), which directs EPA to provide Congress
with periodic reports on the status of the SBTCPs. This oversight responsibility has
been delegated by the EPA Administrator to EPA's Small Business Ombudsman (SBO).
The Report also includes a general report on the SBO's actions to monitor the
SBTCPs.
This report addresses two of the EPA SBO's key oversight responsibilities:
• Render advisory opinions on the overall effectiveness of the SBTCPs,
difficulties encountered, and degree and severity of enforcement [507(d)(1)].
• 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: an SBO, a Small Business Assistance Program (SBAP),
and a Compliance Advisory Panel (CAP).
During the second year of monitoring the SBTCPs, over 73,000 small businesses have
been directly reached, and over 3,800 on-site consultations have been conducted (as
tallied by industry sector assists). SBTCP staff members continue to fill an important
role as facilitator or mediator between small business owners/operators and regulatory
agencies, enhancing communication to promote understanding and sensitivity on both
sides. Based on the information reported, improvements in compliance occur because
businesses have someone to turn to for assistance and advice, and to act as an
effective liaison with regulatory agencies.
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SBTCP yearly operational growth has been continuous since 1990. As of the end of
1996, 50 SBOs (94 percent), 52 SBAPs (98 percent), and 36 CAPs (68 percent) are
operational. The SBTCPs are staffed with two or fewer full time equivalents (FTEs)
in 77 percent of the SBO functions and 4 or fewer FTEs in 70 percent of the SBAP
functions. These figures are the same as last year. 58 percent of programs (up from
49 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 $0 to over $2,000,000 for 1996.
98 percent of SBOs (36 of 37) with their own budgets operate their programs with
less than $200,000. For all 53 programs, 19 percent of SBOs operate with budgets
of between $0 and $25,000; 11 percent operate with budgets of between $25,001
and $50,000; 13 percent operate with budgets of between $50,001 and $75,000;
and 11 percent operate with budgets of between $75,001 and $100,000.
Similarly, of the 37 SBAPs with their own budgets, 86 percent are allotted less than
$400,000. For all 53 programs, 4 percent operate with budgets of between $0 and
$25,000; 4 percent operate with budgets of between $25,001 and $50,000; 11
percent operate with budgets of between $50,001 and $75,000; and 11 percent
operate with budgets of between $75,001 and $100,000. As programs mature and
the cost of establishing programs stabilize, more programs are projecting fairly
consistent budgets for the next reporting period (35 this year versus 25 last year).
The number of programs projecting budget increases has declined from 15 last year
to 11 this year.
89 percent of SBTCPs provided specific information on the types of industry sectors
and number of facilities that their programs assisted. 121 industry sectors received
assistance in 1996. The top ten industry sectors receiving assistance (general and
on-site) by SBTCPs in 1996 were:
Other (not classified)
Auto Body Maintenance/Refinishing/Repair
Dry Cleaners/Laundry Services
Wood Products/Furniture/Finishing
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Casting
Attorney/Consultant/Engineer
Manufacturing
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• Gasoline Distribution (Wholesale/Retail)
• Boilers.
On-site visits were characterized as being highly effective in providing the
individualized attention often required to assist a facility in achieving compliance. The
top ten industry sectors that received on-site assistance were:
Auto Body Maintenance/Refinishing/Repair
Dry Cleaning/Laundry Services
Other (not classified)
Wood Products/Furniture/Refinishing
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Casting
Construction/Contractors
Gasoline Distribution (Wholesale/Retail)
Manufacturing
Plastic Manufacturing/Products.
The top ten industry sectors that received assistance from the most programs were:
Dry Cleaning/Laundry Services (37 programs)
Auto Body Maintenance/Refinishing/Repair (36 programs)
Printing/Graphic Arts (32 programs)
Metal Fabrication/Finishing/Forging/Casting (27 programs)
Wood Products/Furniture/Finishing (25 programs)
Attorney/Consultant/Engineer (17 programs)
Gasoline Distribution (Wholesale/Retail) (16 programs)
Other (not classified) (16 programs)
Chrome Plating (15 programs)
Construction/Contractors (14 programs).
Toll-free hotlines, fact sheets, brochures, seminars, and meetings are among the wide
range of outreach mechanisms used to serve the small business community. Other
state-of-the-art outreach activities, such as Internet home pages, are seeing increased
use. The number of programs with web pages has more than doubled from 13 in
1995 to 28 in 1996.
87 percent of SBOs (up from 66 percent in 1995), 87 percent of SBAPs (up from 81
percent in 1995), and 38 percent of CAPs (down from 40 percent in 1995) report
some sharing of resources within their state/territory. Generally, programs recognize
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the efficiency and value of coordinating their efforts with each other and also with
environmental agency departments, state agencies, and other organizations.
92 percent of programs (as compared to 83 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.
• 58 percent of programs (as compared to 42 percent last year) report taking
specific actions associated with paperwork reduction, with the most common
action being CAP review of SBTCP documents.
• 51 percent of programs (up from 42 percent) report taking specific actions
consistent with the intent of the Regulatory Flexibility Act. The primary
activity by programs was the review and comment on new air regulations to
evaluate their impact on small businesses.
• 34 percent of SBTCPs (as compared to 30 percent last year) reported specific
actions similar to those associated with the Equal Access to Justice Act.
These include the establishment of pro bono legal services, the availability of
funding for technical assistance services for citizen groups aggrieved by permit
actions of a regulatory agency, and the review of SBTCP documents for
compliance.
The number of programs reporting specific actions to follow the intent of the
provisions of these Acts grew in 1996. 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.
70 percent of SBTCPs report that small businesses provided comments on the
assistance programs and that feedback was overwhelmingly positive. Common
themes were similar to those in 1995. Small businesses appreciated the availability
of a non-regulatory approach for certain problems and the personalized guidance
through the many regulatory processes leading to compliance.
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51 percent of programs provided examples of complaints received and resolution
strategies employed. Resolution of issues between the small business and regulatory
communities comprises a significant portion of the SBTCPs1 activities, which included:
• Developing plain language explanations of regulatory requirements.
• Providing one-on-one guidance through the paperwork process.
• Facilitating communication about regulatory flexibility and compliance
assistance issues between small business and regulatory agencies.
96 percent of the SBTCPs (up from 85 percent in 1995) provided insight on the types
of compliance issues addressed during the course of providing technical assistance
to small businesses. Two of the three most common compliance problems mentioned
by small businesses were, "Not understanding the regulatory requirements," and
"Operating without a permit," the same issues most commonly addressed last year.
Programs reported, "More open communication between sources and agencies," and
"Increased compliance," as a result of program outreach efforts.
Generally, small businesses want to comply with environmental regulations; however,
they may be afraid to ask for help. When a non-threatening assistance program, such
as the SBTCP, is available, small businesses are eager to take advantage of the
services, as this help increases chances of survival and profitability.
45 SBTCPs provided recommendations for changes to facilitate small business
compliance with the CAA. Once again, the most frequent recommendation was
flexibility in applying regulations to small businesses (42 percent of programs).
In addition to inquiries regarding air issues, many programs are being contacted about
multimedia problems as well. 26 percent of programs suggested expanding
assistance to cover multimedia programs (i.e., air, water, solid waste).
Programs were asked to describe how their SBTCP avoids internal or external
conflicts of interest or the perception that their program may not be confidential. 77
percent of programs reported no problems concerning confidentiality or with conflict
of interest issues during the course of providing services; 9 programs indicated that
no confidentiality program or guarantee of confidentiality is in place. Program
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structures range from a guarantee of confidentiality (most common) to offering no
confidentiality. Many programs have policies that protect small businesses from
penalties if violations are discovered during the course of their receiving technical
assistance.
The SBTCPs offer important one-on-one contacts, provide valuable information such
as the need to have operating permits, maintaining records, compliance options,
pollution prevention technologies and techniques, and compliance requirements. This
assistance enables small businesses to arrive at informed decisions and more
effectively come into compliance.
CONCLUSIONS AND RECOMMENDATIONS
As was noted in the 1995 report, SBTCPs are being run by hardworking,
dedicated staffs who operate successful programs with often limited budgets
and resources. Small businesses are grateful for the technical assistance and
personalized attention from people they can trust. In this second year of
gathering information from the programs, over 73,000 small businesses have
been reached, and over 3,800 on-site consultations have been performed (as
tallied by industry sector).
SBTCPs facilitate dialog between the small business community and the
regulatory community, fostering trust and improved attitudes towards
regulatory compliance.
Programs 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.
Commonly identified compliance problems include not understanding regulatory
requirements and operating without a permit, the same as in 1995. SBTCPs
suggested reasons for these problems may be the overwhelming volume of
regulations, businesses' fear of talking to regulators, and the amount of
paperwork required to come into compliance. Many current SBTCP activities
have remedied such problems. The concerns regarding these problems
underscore the critical role of the SBTCP in providing vital technical assistance
and promoting compliance by establishing trust and greater understanding.
Programs are to be commended for their accomplishments in continuing to
promote compliance. Highlights include more open communication between
sources and agencies and greater understanding/awareness of regulations by
small businesses. Award programs and loan programs have proved to be
effective in providing incentives, both for small businesses and the programs
themselves. Programs should consider developing award and loan programs
as incentives for their small business customers.
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• In conducting the Federal program, EPA has followed the requirements of the
Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts.
EPA's SBO has monitored SBTCP's activities for following the intent of the
provisions of these Acts. The careful review of SBTCP documents and the
development of simplified forms and permits are among the positive actions
implemented to fulfill the intent of the Acts.
• Program activities primarily emphasize mechanisms to reach larger audiences
(e.g., mailings, hotlines). However, one-on-one assistance has been reported
as the most effective method in bringing small businesses into compliance, and
programs are encouraged to increase their emphasis on personalized
assistance. It is important that adequate resources are allocated to permit on-
site visits by their staff. On-site visits (as tallied by industry sector) almost
doubled from over 2,000 last year to over 3,800 this year.
• With the strong small business technical assistance infrastructure in place
through the SBTCPs, programs should explore their potential to expand into
multimedia assistance. A number of programs already offer multimedia
assistance and industry-specific permitting, which can ease the regulatory
burden on small businesses and promote compliance.
• Efficiency of information transfer (among SBTCPs and to small businesses) can
be realized through the increased use of Internet home pages (and to a lesser
extent electronic bulletin boards, which have become less common).
Presently, 53 percent of programs operate some type of electronic information
transfer, up from 25 percent last year; 6 additional programs indicated plans
to implement home pages in 1997. 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 or
bulletin board services for sharing information with small businesses and with
other SBTCPs.
• Programs are encouraged to explore the potential for sponsoring or facilitating
financial assistance programs for pollution control or pollution prevention
capital expenses. (Only 11 percent of SBTCPs reported the availability of
financial assistance programs in 1996, down from 19 percent last year.) Small
businesses have expressed their need for creative financing mechanisms,
which was recommended by 25 percent of SBTCPs as a method for enhancing
compliance.
• SBTCPs are often underfunded and understaffed as they provide their current
level of services. Because of this, they are likely to be challenged to expand
their function both in air-related outreach and multimedia technical assistance.
SBTCPs are encouraged to better utilize the expertise of their CAP members to
enhance improvements in their technical assistance programs. Several states
still do not have operational CAPs. A number of CAPs also need to address
vacancies of the CAP due to expired terms.
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1.0 INTRODUCTION AND REPORT OVERVIEW
1.1 RATIONALE AND OBJECTIVE OF THE REPORT TO CONGRESS
The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is
pleased to submit this Report to Congress describing the accomplishments and
activities of the state/territory Small Business Stationary Source Technical and
Environmental Compliance Assistance Programs (SBTCP) during the January 1, -
December 31, 1996 reporting period.
This report represents the second Annual Report to Congress on this important
program designed to help the small business community understand and cost-
effectively comply with the requirements of the Clean Air Act Amendments (CAA) as
amended in 1990.
This report is being submitted in accordance with Section 507(d), Monitoring, of the
CAA, which directs the EPA to provide Congress with an Annual Report on the
SBTCP. This oversight and reporting responsibility has been delegated by the EPA
Administrator to the EPA Small Business Ombudsman (SBO).
This report is intended to address two of the EPA SBO's responsibilities with respect
to the SBTCP.
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)J.
1.2 DATA COLLECTION METHODOLOGY
Information to assess the SBTCPs was collected through a relatively simple,
standardized Annual Reporting Form, which is designed to streamline the reporting
process.
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During the fall of 1994, EPA's SBO, with assistance from SBTCP personnel,
developed the criteria for a standardized Reporting Form. A draft Form was
distributed to the state programs for review in November 1994, and the Form was
further refined during the National SBO/SBAP Conference in January 1995. Programs
also were asked to comment on EPA's Office of Enforcement and Compliance
Assurance's (OECA's) sample questions regarding compliance assessment.
In March 1995, EPA's SBO submitted a "Request for Information Collection Request
(ICR) Approval" to the Office of Management and Budget (OMB) for the Annual
Reporting Form. The Form subsequently was approved and was assigned OMB
Number 2060-0337, expiration date 7/31/98.
In December 1996, EPA's SBO distributed copies of the SBTCP Annual Reporting
Form (for the reporting period January through December 1995) to state/territory
SBTCP contacts (primarily SBOs). These contacts were requested to coordinate
completion of this Form among their SBO, SBAP, and CAP. The Annual Reporting
Form was provided in hard copy and on computer disk for ease of completion and to
reduce the reporting burden. A copy of the 1996 SBTCP Reporting Form is enclosed
as Appendix A.
Programs were not asked to create information that they did not have; therefore,
some SBTCPs were not able to answer all questions posed. Based on the information
requested in the Reporting Form from the first year of reporting, programs were
encouraged to revise the types of statistics they track for subsequent years for
simplicity in completing future reports.
Programs were asked to provide the information requested in the Annual Reporting
Form and submit the Form to the EPA's SBO by February 15, 1997. The information
provided in the Forms was compiled and analyzed to produce this report. The 50
states, plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands,
submitted SBTCP Annual Reports (53 programs total) to EPA's SBO.
In addition, Arizona, California, and Kentucky have distinct'air quality districts or
counties with regulatory jurisdiction within their states, which also submitted full or
partial reports. In Arizona, Maricopa County, and Pima County submitted separate
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reports. For California, the South Coast Air Quality Management District submitted
a full report; partial reports or informational letters were submitted by Bay Area Air
Quality Management District, Kern County Air Pollution Control District, Placer County
Air Pollution Control District, San Joaquin Valley Unified Air Pollution Control District,
San Luis Obispo County Air Pollution Control District, and Santa Barbara County Air
Pollution Control District. For Kentucky, Jefferson County submitted a report. For
statistical purposes of this report, data from states that submitted multiple reports
have 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 Introduction and Report Overview
Section 2.0 Overview of the SBTCP -- This section provides an overview of
the three components of the SBTCP (i.e., the SBO, the SBAP, and
the CAP) as well as EPA's responsibilities under Section 507.
Section 3.0 SBTCP Status, Budgets, Staffing, and Organization - This section
encompasses these four categories of information about the
SBTCPs.
Section 4.0 SBTCP Activities and Services - In this section, types and levels
of services provided by the three components of the states'
SBTCPs are discussed including efforts to comply with the
Paperwork Reduction, Regulatory Flexibility, and Equal Access to
Justice Acts. Financial assistance program information also is
included.
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Section 5.0 Program Effectiveness - A discussion of program effectiveness
based on comments received by the SBO or CAP, as well as
resolution strategies for any negative comments are provided.
General information on some of the accomplishments and
highlights of the programs in 1996 also are outlined.
Section 6.0 Compliance Assurance - Information on the effectiveness of the
three components of the SBTCPs in providing compliance
assistance support to state small businesses is provided in this
section.
Additional details on the information provided by the individual SBTCPs are included
in the various appendices to this report.
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2.0 OVERVIEW OF THE SBTCP
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:
• 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, 1996, 50 of
53 states/territories (94 percent) had received approval from EPA for their SIPs
implementing Section 507 of the CAA. States/territories whose SIPs have not yet
been submitted/approved are:
• Hawaii -- not yet submitted
• Rhode Island ~ submitted, but not yet 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:
• Review and provide recommendations to EPA and state/local air pollution
control authorities regarding development and implementation of regulations
impacting small businesses.
• Assist in dissemination of information about upcoming air regulations, control
requirements, and other matters relevant to small businesses.
• Refer small businesses to appropriate specialists for help with specific needs.
• Conduct 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 Paperwork Reduction Act, the
Regulatory Flexibility Act, and the Equal Access to Justice Act.
• Submit periodic reports to EPA's SBO.
• Review information for small business stationary sources to ensure it is
understandable to the layperson.
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2.4 EPA's RESPONSIBILITIES UNDER SECTION 507 OF THE CAA
Section 507(d), Monitoring, directs the EPA to monitor the SBTCPs and to provide a
report to Congress. This responsibility has been delegated to EPA's SBO, whose
oversight duties are to:
• Render advisory opinions on the overall effectiveness of the SBTCP, difficulties
encountered, and degree and severity of enforcement [507(d)(1}].
• Make periodic reports to Congress on the compliance of the Paperwork
Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice
Act [507(d)(2)l.
• Review information issued by the SBTCPs to ensure that it is understandable
to the layperson [507(d)(3)l.
• 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
This section presents information on the operating status (Section 3.1), budgets
(Section 3.2), staffing levels (Section 3.3), and the administrative location of the three
components of the SBTCPs (SBOs, SBAPs, and CAPs) within their states/territories
(Section 3.4) for the January - December 1996 reporting period.
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, 1996, 50 SBOs (94 percent of the 53 states and U.S.
territories) and 52 SBAPs (98 percent) had been established and were providing
assistance to small businesses. Only 36 programs reported that their CAPs were
operating; however, 41 programs reported that the CAPs had been established.
The number of established and operational SBO functions remained at 50, the same
as 1995. The number of established SBAPs was up from 50 in 1995 to 52 in 1996;
the number of operating SBAPs has risen from 49 in 1995 to 52 in 1996. One more
CAP was established in 1996 (41, up from 40 in 1995), and 4 additional CAPs
became operational (36 in 1996 versus 32 in 1995).
Operating status for each of the three components of the SBTCPs is shown in Table
3-1 and also identifies those programs whose SBOs, SBAPs, and CAPs are not yet
established or operational.
TABLE 3-1
OPERATING STATUS OF THE SBTCP COMPONENTS
SBO2
SBAP3
CAP*
COMPONENTS ESTABLISHED1
f Programs
50
52
41
% Programs
94
98
77
COMPONENTS OPERATIONAL1
# Programs
50
52
36
% Programs
94
98
68
3-1
-------
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 12/31/96, SBOs were reported not to be established or operating in Hawaii,
Massachusetts or Vermont.
Note 3: As of 12/31/96, an SBAP was reported not to be established or operating in Hawaii.
Note 4: As of 12/31/96, CAPs were reported not to be established or operating in 12 programs:
Alabama, California, Delaware, Hawaii, Illinois, Iowa, Maryland, Massachusetts, New York,
Rhode Island, Vermont, or the U.S. Virgin Islands. In addition, 5 other states reported that
their CAPs had been established, but not yet operating: Arizona, District of Columbia,
Missouri, New Jersey, and Tennessee.
Details on actual dates (month/year) when the SBOs, SBAPs, and CAPs were reported
to be established and operational may be found in Appendix D-2. A summary of the
start of operations for the three SBTCP functions is shown in Table 3-2.
TABLE 3-2
START OF OPERATIONS FOR SBTCP FUNCTIONS
Pre-1990
1991
1992
1993
1994
1995
1996
% operational by
12/31/96
SBO
Number
12
20
10
8
Total
12
32
42
50
94%
SBAP
Number
1
1
11
17
16
5
1
Total
1
2
13
30
46
51
52
98%
CAP
Number
1
8
12
10
5
Total
1
9
21
31
36
68%
3.2 BUDGETS
3.2.1 1996 Reporting Period
As detailed in the paragraphs and tables below, the total operating budgets for the
SBTCPs varied from $0 to over $2,000,000 for the 1996 reporting year. These
3-2
-------
extremes include $0 for Vermont, whose SBO/CAP have not yet begun operations,
to New York, reporting a total operating budget of $2,170,000
1996 operating budget ranges for the SBTCPs are shown in Table 3-3. Details on the
operating budgets, by program, for the individual SBO, SBAP, and CAP components,
including the source of these funds, may be found in Appendix D-3.
TABLE 3-3
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
> 1,000,000*
> 2.000,000*
Report submitted, no data provided4
TOTAL
f Programs
1
9
19
5
9
2
2
1
0
2
0
1
1
1
53
% Programs1
2
17
36
97
17
4
4
2
0
4
0
2
2
2
Note 1: County budgets are not combined with state budgets, nor are they counted separately.
Note 2: Texas
Note 3: New York
Note 4: Hawaii
The balance of this section provides summary details on the operating budgets for the
SBOs, SBAPs, and the CAPs.
3-3
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3.2.2 SBO Operating Budgets
37 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 36 of 37 SBOs (97 percent) reporting budgets between $0 and
$200,000. (The one exception is New York's SBO, who reports a budget of
$1,170,000.) The primary source of funding for all programs is Title V fees (58
percent), which are collected at the state/territory level. Other sources of funding
include EPA 105 Grant funds (provided for in Section 105 of the CAA, these funds
flow to the states through EPA regional offices), non-Title V air fees, and state permit
fees.
The range' of 1996 operating budgets for the SBOs with their own budgets is shown
in Table 3-4.
TABLE 3-4
1996 SBO OPERATING BUDGET RANGES
(37 non-combined budgets)
Budget (*)
0 - 25,000
25,001 - 50,000
50,001 - 75,000
75,001 - 100,000
100,001 - 200,000
> 1,000,000
Combined budgets1
Report submitted, no data provided2
TOTAL
f Programs
10
6
7
6
7
1 .
11
5
53
% Total Programs
19
11
13
11
13
2
21
9
Motel:
Note 2:
11 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). 11 SBOs have combined budgets.
Hawaii, Louisiana, Massachusetts, Vermont, Virgin Islands.
3-4
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3.2.3 SBAP Operating Budgets
37 SBAPs have their own budgets. SBAP budgets are spread across a wider dollar
range as compared to the SBOs with 16 of 37 programs (43 percent) between $0 and
$100,000, 5 of 37 programs (14 percent) between $100,001 and $200,000, and 6
of 37 programs (16 percent between $200,001 and $300,000. Title V fees again are
the main funding source (66 percent of all programs); funds from EPA 105 Grants,
non-Title V fees, indirect funds, and permit fees are also used to support SBAPs.
The range of 1996 operating budgets for the SBAPs with their own budgets is shown
in Table 3-5.
TABLE 3-5
1996 SBAP OPERATING BUDGET RANGES
(37 non-combined budgets)
Budget (*)
0 - 25,000
25,001 - 50,000
50,001 - 75,000
75,001 - 100,000
100,001 - 200,000
200,001 - 300.000
300,001 - 400,000
400,001 - 500,000
600,001 - 700,000
900,001 - 1,000,000
Combined budgets1
Report submitted, no data provided2
TOTAL
f Programs
2
2
6
6
5
6
5
3
1
1
12
4
53
% Total Programs
4
4
11
11
9
11
9
6
2
2
23
8
Note 1:
Note 2:
12 SBAPs have combined budgets. If a program combined the budget for two SBTCP
functions (i.e., SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a
combined budget. However, the budget of the third component of the program also was
tallied separately (e.g., a program reporting a combined SBO/CAP budget and a separate
SBAP budget was tallied in the 'combined budget category" for the SBO/CAP budget and
with SBAPs for the SBAP budget). 10 SBAPs have combined budgets.
Alabama, Hawaii, Nebraska, Vermont.
3-5
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3.2.4 CAP Operating Budgets
32 CAPs have their own budgets. CAP funding ranges from $0 (25 percent of
programs with their own budgets) to a high of $12,000 (one program, Missouri). 88
percent of CAPs with their own budget operate with a budget of $5,000 or less. Title
V fees are the most commonly listed funding source for all CAPs (45 percent).
The range of 1996 CAP operating budgets is shown in Table 3-6.
TABLE 3-6
1996 CAP OPERATING BUDGET RANGES
{32 tton*combiMd budgets)
Budget (*)
0
1 -1.000
1,001 -2,000
2,001 - 3,000
3,001 - 4,000
4,001 - 5,000
9,001 - 10,000
11.001 -12,000
Combined budgets1
Report submitted, no data provided2
TOTAL
f Programs
8
4
3
4
1
8
3
1
10
11
53
% Total Programs
15
8
6
8
2
15
6
2
19
21
100
Note 1:
Note 2:
10 CAPs have combined budgets. If a program combined the budget for two SBTCP
functions (i.e., SBO/SBAP, SBO/CAP, or SBAP/CAP), they were counted as having a
combined budget. However, the budget of the third component of the program also was
tallied separately (e.g., a program reporting a combined SBO/CAP budget and a separate
SBAP budget was tallied in the "combined budget category" for the SBO/CAP budget and
with SBAPs for the SBAP budget). 8 CAPs have combined budgets.
Alabama, District of Columbia, Hawaii, Iowa, Kansas, Maine, Maryland, Massachusetts,
Nebraska, New York, Virgin Islands.
3-6
-------
3.2.5 Comparison of Previous and Projected Budgets
A comparison of budgets from 1995, 1996, and 1997 (projected) is valuable in
tracking program growth and resource allocation. Programs were asked to indicate
significant budget changes (greater than 10 percent) from year to year and to provide
insight into any major shifts (more than 10 percent) in funding levels. SBTCP
reporting period budget comparisons are shown in Table 3-7.
TABLE 3-7
SBTCP REPORTING PERIOD BUDGET COMPARISONS
1995 to
1996
Reporting
Period
1996 to
1997
Reporting
Period
BUDGET DECREASE
(> 10% chang«)
t
Programs
7
2
%
Programs
13
4
BUDGET CONSISTENT
« 10% cnang*)
*
Programs
30
36
%
Programs
57
68
BUDGET INCREASE
(> 10% changa)
*
Programs
14
11
%
Programs
26
21
INSUFFICIENT DATA
FOR COMPARISON1
*
Programs
21
43
%
Programs
4
8
Note 1: Not all programs provided budget amounts. 4 progra-ns may have had an established
SBTCP during the previous reporting period or were unable to project their budgets for the
next reporting period. In order to establish trends, combined budgets for the SBO, SBAP,
and CAP were examined. This was necessary, as some programs indicate combined
budgets for two or three facets of their programs, while other programs may have had one
or two facets of their programs inactive during the previous reporting period.
Note 2: Hawaii, Louisiana
Note 3: Hawaii, Louisiana, Massachusetts, Missouri
In reviewing the combined budgets for the SBO, SBAP, and CAP functions of the
SBTCPs, 14 programs (26 percent) indicate a budget increase (of at least 10 percent)
from the 1995 to 1996 reporting periods. 11 programs (21 percent) show an
increase from the 1996 to 1997 reporting periods.
As programs mature and the cost of establishing programs stabilizes, more programs
are projecting fairly consistent budgets for the next reporting period (35 this year as
compared to 25 last year). The number of programs projecting a budget increase for
the subsequent reporting period has declined from 15 last year to 11 this year.
3-7
-------
According to responses received, budget increases primarily were related to the
growth and expansion of SBTCP services and staff additions. Examples of reasons
given for budget increases greater than 10 percent are provided below:
• In Illinois, the budget has grown as program staffing increased to 5 FTE. The
funding source was Title V permit fees, and outreach activities have increased.
($330,000/1996, $485,000/1997)
• Ohio's SBAP hired one additional FTE in June 1996, and new budgets reflect
one additional staff member. Both SBO and SBAP operated at lower than
expected levels due to lower than expected revenues from Title V fees.
($498,000/1996, $625,000/1997)
• West Virginia's SBO has significantly increased participation in trade shows
and professional organizational events. This has raised travel and display
costs. SBAP substantially increased on-site visits and compliance audits. Staff
participated in more multimedia training workshops. An increase is projected
in 1997 due to dedicating more resources for developing general permits.
($160,000/1996, $215,000/1997)
30 programs (57 percent) report steady budget levels (less than a 10 percent change)
for the 1995 to 1996 reporting periods, and 35 programs (66 percent) indicate
consistent budget levels from the 1996 to 1997 reporting periods.
7 programs (13 percent) showed a decrease (more than 10 percent) from the 1995
to 1996 reporting periods, and only 2 programs (4 percent) project a decrease from
the 1996 to 1997 periods. Budget reductions are often attributed to program
reorganizations and consolidations and lower projected costs to maintain a program
(versus the higher resource requirements to develop a program).
87 percent of the programs reported either a consistent or increasing budget from the
1996 to 1997 reporting periods.
Budgets for the 1995, 1996, and 1997 reporting periods for the SBO function, SBAP
function, and CAP function may be found in Appendix D-4.
3.3 STAFFING LEVELS
41 programs (77 percent) report operating their SBOs with 2 or fewer full-time
equivalents (FTEs) as shown in Table 3-8.
3-8
-------
37 programs (70 percent) operate their SBAPs with 4 or fewer FTEs, which include
both paid and unpaid staff and may include retired engineers. There are some notable
exceptions to these staffing levels, such as Louisiana, Indiana, and California, which
report using 11, 12, and 20 FTEs, respectively, to support their SBAP function.
Specific details on the number of FTEs, by program, for the SBO and SBAP functions
may be found in Appendix D-5.
: • • ' TABLE 3-8
STAFFING LEVELS in flit') SERVING THE SBO & SBAP FUNCTIONS
*FTEs
0
0.1 -1
1.1 -2
2.1 -3
3.1-4
4.1 -5
5.1 -6
6.1-7
7.1 -8
9.1 -10
10.1 -11
11.1 -12
19.1 -20
TOTAL*
SBO
f Programs
1
28
12
4
1
1
1
1
49
% Programs
2
53
23
8
2
2
2
2
SBAP
# Programs
0
14
10
9
4
5
2
2
1
1
1
1
1
51
% Programs
0
26
19
17
8
9
4
4
2
2
2
2
2
Note 1: An FTE is considered to work 40 hours/week. For example, 2 people working 20
hours/week would be equivalent to 1 FTE.
Note 2: 2 states (Florida and Texas) combined their SBO and SBAP functions and report 4 and 19.5
FTEs, respectively. Massachusetts and Puerto Rico did not provide information on their
SBOs.
58 percent of programs (up from 49 percent last year) report that at least the required
7 members have been appointed to their CAPs. An overview of CAP appointments
3-9
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is shown in Table 3-9. Program statistics of the number of CAP members in each
category (small business, state agency, general public, not yet appointed, other) may
be found in Appendix D-6.
TABLE 3-9
CAP APPOINTMENTS
Minimum 7 members appointed
Less than 7 members appointed1
No response2
Not established*
f Programs
31
20
1
1
% Programs
58
38
2
2
Note 1: A number of states indicated that expired terms on their CAPs have not been filled.
Note 2: California
Note 3: Hawaii
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 (not necessarily a
regulatory section). (Two programs whose SBO functions are not operational
indicated the intended location for this function. Ohio's program reports their SBO
is housed in an independent, non-regulatory, financing agency.) The majority of
programs (50) report to have located their SBAPs within a state/territory-related
agency, typically the environmental agency.
As defined in Section 507, the CAPs are to be independent entities, operating outside
of any agency. In addition to this independent status, 15 programs also indicated
that administrative support is provided to the CAPs by some facet of their state
environmental agency or SBO/SBAP.
3-10
-------
TABLE 3-10
ADMINISTRATIVE LOCATIONS OF SBO AND SBAP
Location
State-related agency
University-related (contracted)
Private contractor
Independent
Not established
TOTAL
SBO
# Programs1
51
1
1
53
% Programs
96
2
2
100
SBAP
# Programs1
50
2
1
53
% Programs
94
4
2
100
Note 1: Numbers are higher than those reported in Table 3-1. Programs without established SBOs
or SBAPs indicated where those functions are intended to be located once established.
Complete information for the administrative location of each SBO, SBAP, and CAP
may be found in Appendix D-7.
3-11
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4.0 SBTCP ACTIVITIES AND SERVICES
Information regarding the services and activities of the three components of the
SBTCPs is provided in this section. Industry sectors assisted by the SBTCPs are
discussed in Section 4.1. An overview of SBO, SBAP, and CAP activities and
services is provided in Section 4.2. SBTCP financial assistance services are outlined
in Section 4.3. A discussion of how programs leverage resources and minimize
duplication of efforts may be found in Section 4.4. SBTCP efforts to comply with the
Paperwork Reduction Act, Regulatory Flexibility Act, and the Equal Access to Justice
Act are summarized in Section 4.5.
4.1 INDUSTRY SECTORS ASSISTED BY THE SBTCPs
47 SBTCPs (89 percent) (county and air district programs were not counted
separately) provided specific information on the types of industry sectors and number
of facilities that their programs assisted in 1996. Small businesses in 121 industry
sectors were identified as having been assisted by SBTCPs. Certain industry sectors,
such as dry cleaning and vehicle maintenance and repair, received larger numbers of
assists, as these sectors are strongly impacted by the CAA. Programs also may have
targeted certain industry sectors for assistance based on their anticipated impact by
the CAA and the number of small businesses in that industry sector.
The top ten industry sectors receiving assistance (general and on-site) by SBTCPs in
1996 were:
Other (not classified)
Auto Body Maintenance/Refinishing/Repair
Dry Cleaners/Laundry Services
Wood Products/Furniture/Finishing
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Casting
Attorney/Consultant/Engineer
Manufacturing
Gasoline Distribution (Wholesale/Retail)
Boilers.
4-1
-------
The top ten industry sectors that received on-site assistance were:
Auto Body Maintenance/Refinishing/Repair
Other (not classified)
Dry Cleaning/Laundry Services
Wood Products/Furniture/Refinishing
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Casting
Construction/Contractors
Gasoline Distribution (Wholesale/Retail)
Manufacturing
Plastic Manufacturing/Products.
The top ten industry sectors that received assistance from the most programs were:
Dry Cleaning/Laundry Services (37 programs)
Auto Body Maintenance/Refinishing/Repair (36 programs)
Printing/Graphic Arts (32 programs)
Metal Fabrication/Finishing/Forging/Casting (27 programs)
Wood Products/Furniture/Finishing (25 programs)
Attorney/Consultant/Engineer (17 programs)
Gasoline Distribution (Wholesale/Retail) (16 programs)
Other (not classified) (16 programs)
Chrome Plating (15 programs)
Construction/Contractors (14 programs).
Industry sectors that received the most overall types of assistance generally received
the greatest number of on-site visits. In comments provided by the SBTCPs, the
majority indicated that the most notable improvements in compliance were the result
of on-site visits.
A list of the industry sectors receiving assistance (by number of programs) may be
found in Appendix E-1. This same list also has been reordered by total number of
assistance efforts (Appendix E-2) and by on-site assistance efforts (Appendix E-3).
Individual program responses by number of general, on-site, and total assists are
shown in Appendix E-4. The fifteen most active programs, With over 1,000
assistance efforts (as tallied by specific industry sectors) were:
• California
• Colorado
• Connecticut
4-2
-------
Indiana
Iowa
Massachusetts
Missouri
Oklahoma
Pennsylvania
Tennessee
Texas
Utah
Virgin Islands
Washington
Wisconsin.
4.2 PRINCIPAL SBO, SBAP, AND CAP ACTIVITIES AND SERVICES
An overview of activities and services provided by the three SBTCP functions is
discussed in this section.
4.2.1 SBO Activities and Services
Outreach services offered by the SBOs during the 1996 reporting period are
summarized in Table 4-1. Outreach activities offer a means of informing the small
business community about the technical assistance services available from SBOs and
providing technical information to small businesses.
The three most common SBO activities (by the number of SBOs offering such
services) were meetings, speaking engagements, and distribution of brochures/flyers.
37 SBOs (70 percent) have telephone hotlines.
4-3
-------
TABLE 4-1
SBO OUTREACH ACTIVITIES
ACTIVITY
Meetings
Speaking engagements
Brochures/flyers
Training sessions
Personal assistance (including toll-free hotlines)
Information booths
On-site visits
Newsletters
Media coverage
Other2
f Programs1
40
36
30
28
10
6
6
5
5
16
% Programs
75
68
57
53
19
11
77
9
9
30
Note 1: Does not include county or regional activities.
Note 2: SBO activities classified as "other" included:
Fact sheets
Fax back service
Tracking legislation
Focus groups/task forces
Permit and regulatory guidance documents
Teleconferences
Site visits
Visit to another CAP for training.
Detailed information, by program, about the number of occurrences and the number
of people reached by each reported SBO activity is presented in Appendix E-5.
Details of the SBOs toll-free hotlines are shown in Appendix E-6.
4.2.2 SBAP Activities and Services
An aggregate of the outreach services offered by the SBAPs during the 1996
reporting period is presented in Table 4-2. These outreach services/activities are
designed to introduce the available assistance services to small businesses, provide
general information, and identify common problems and issues to be addressed on a
more specific basis.
The four most common outreach services offered by at least 80 percent of SBTCPs
were:
4-4
-------
Seminars, workshops and meetings
General assistance (including assistance provided via telephone hotlines)
Distribution of printed materials such as factsheets
On-site consultations.
These were the four most common services in 1995 as well.
TABLE 4-2
SBAP OUTREACH ACTIVITIES
ACTIVITY
Seminars, workshops, meetings, etc.
General assistance (including telephone hotlines)
Fact sheets, manuals, etc.
On-site consultations
Telephone hotlines
Bulletin board services/World-Wide Web page
Permit and compliance assistance
Teleconferences
Newsletters
Pollution prevention assistance
Other1
f Programs
49
49
44
44
42
31
12
9
9
5
15
% Programs
92
92
83
83
79
58
23
17
17
9
28
Note 1: SBAP services classified as "other" included the following:
Meetings with regulatory permit assistance centers
Surveys
Fax back and on line service
Media interviews
Targeted letters and mass mailings
Referrals
EPA initiative meetings
Customer meetings
Special projects
Visit to another CAP
Loan program
Resource centers
Enforcement negotiations
Notifications
Trade shows
Amnesty programs.
Detailed information, by program, about the number of occurrences and the number
of people reached by each SBAP during the 1996 reporting period is shown in
Appendix E-7. 42 SBAPs (79 percent) offered telephone hotline services for their
4-5
-------
customers (both toll free and non-toll free). SBAP telephone hotline information is
listed in Appendix E-8.
Of particular note is the number of SBAPs that are using Bulletin Board Services
(BBSs) and World Wide Web (WWW) home pages to disseminate technical assistance
information. 28 programs are currently using BBSs or home pages, up from 13 last
year. (County/regional air district programs operating their own home pages are
counted as one with the state.) An additional 6 states indicated they plan on
launching home pages in 1997.
The types of information available via these BBSs or home pages are listed in Table
4-3; detailed information on the BBSs and home pages, by program, may be found
in Appendix E-9.
TABLE 4-3
INFORMATION AVAILABLE ON SBAP BBS Al
Type of Information
Regulations
Pollution prevention
Factsheets
Application forms
Calendar of events
Guidance documents
Program description/information
Contact listings
Policies
Permit information
Emission inventory/information/spreadsheets/calculations
Other1
W WWW PAGES
# Programs
25
23
13
11
10
9
9
8
8
5
4
18
% Programs
(of 31)
81
74
42
35
32
29
29
26
26
16
13
58
Motel:
: "Other" information available from SBAP bulletin boards includes:
Multimedia information
Newsletters
Free downloadable software
List of publications
Links to relevant sites
4-6
-------
Downloadable technical information
Public notices/rulemakings
CAP meetings
Environmental education.
BBSs (which are becoming less common) and 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 year. Because the Internet and
BBSs are also efficient ways to transfer information from the federal SBO and SBAP,
between SBAPs, and to the small business community, increased access to the
<*
Internet should continue to be pursued by SBAPs.
4.2.3 CAP Activities and Services
36 CAPs were operational during the 1996 reporting period, 34 of which reported
activities. The primary CAP activity, as reported by 20 CAPs, was to suggest
effective outreach activities. This was closely followed by review of SBTCP
documents and review of SBO/SBAP outreach activity efforts (each reported by 1 9
CAPs).
Major activities of the CAPs during the 1 996 reporting period are summarized in Table
4-4. A program summary of CAP activities may be found in Appendix E-10.
TABLE 4-4
MA JOB CAP ACTIVITIES
Activity
Suggest effective outreach activities
Review SBTCP documents
Review of SBO/SBAP outreach efforts
Appoint staff/elect officers
Define CAP responsibilities
Review/comment on new regulations, policies, etc.
Suggest effective outreach activities
Attend training seminars, conferences, etc.
Other1
# Programs
20
19
19
12
10
10
6
5
17
% Programs
38
36
36
23
19
19
11
9
32
4-7
-------
Note 1: Less frequently-reported CAP activities classified as "other* included:
• Leveraged resources through trade associations, vendors, suppliers, and small business publications.
• CA Air Quality Rules were revised to reflect CAP length of service and structure.
• Reviewed and commented on various new programs and personnel.
• Reviewed reports on assistances to dry cleaners and upcoming state regulatory calendar.
• Met with trade associations.
• Developed legislative strategy for small business loan program.
• Helped SBO evaluate nominees for small business award program.
• Reviewed and instructed staff to prepare letter of concern on auto repair facility technician training.
• Spoke at local civic and business group meetings.
•. Sponsored workshops.
• Assisted with cross media program for cleaning contaminated dry cleaning sites.
• Collaborated to develop brochures and P2 guidance documents.
• Participated in Region X Success Methods Survey.
• Assessed current state initiatives regarding ISO 14000.
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 without operational
CAPs to complete the appointment process and initiate the CAP function.
4.2.4 SBO/SBAP/CAP Meetings
As shown in Table 4-5, SBTCPs have recognized the importance of meetings among
the three functions to ensure effective coordination of efforts and use of resources.
Two-thirds of SBOs and SBAPs have scheduled meetings at least quarterly, and
almost one-half of programs report scheduled meetings among SBOs, SBAPs, and
CAPs at least once a year.
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TABLETS
FREQUENCY OF MEETINGS AMONG $608, SBAPs, AND CAP*
(number of program* reputing such frequency}
Frequency
Daily
Weekly
Bi-weekly
Monthly
Bi-monthly
Quarterly
Bi-annuelly
Annually
Occasionally
TOTAL
SBO & SBAP
14
4
6
5
1
3
2
1
8
39
SBO & CAP
1
2
8
3
1
5
20
SBO, SBAP. & CAP
1
1
13
4
5
4
28
SBAP & CAP
1
8
4
4
3
20
Meetings between SBOs and SBAPs were the most common form of contact,
occurring in 39 programs (74 percent). A majority of these meetings (31 of 39
programs or 79 percent) were regularly scheduled, with frequencies ranging from
daily to annually. The most commonly, scheduled frequency of meeting between
SBOs and SBAPs, reported for 14 of the 39 programs (36 percent), was daily.
Meetings between SBOs and CAPs were reported for 38 percent of programs (20 of
53). The majority of these meetings, 15 of 20 (75 percent), were regularly
scheduled. The most common frequency of meetings between SBOs and CAPs was
quarterly, reported for 8 of 20 programs, or 40 percent.
28 programs (53 percent) reported meetings involving SBOs, SBAPs, and CAPs.
Most of these meetings, 24 of 28 (86 percent), were regularly scheduled, and the
common frequency was quarterly, reported for 13 of 28 programs (46 percent).
Meetings between SBAPs and CAPs were reported in 20 programs (38 percent), the
same frequency as meetings between the SBO and CAP. Of these, 17 of 20 (85
percent) were regularly scheduled, and the most common frequency was quarterly,
reported for 8 of 20 programs (40 percent).
4-9
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Detailed information, by program, about meetings between SBTCP functions, is
presented in Appendix E-11.
4.3 SBTCP FINANCIAL ASSISTANCE PROGRAMS
Information about financial assistance programs offered to small businesses to
address environmental compliance needs is provided in Table 4-6.
TABLE 4-6
FINANCIAL ASSISTANCE PROGRAMS
Programs offering grants/loans
Grants/loans offered
Programs planning grant/loan programs
*
6
81
10
Note 1:
Some SBTCPs offer more than 1 financial assistance program.
8 financial assistance programs were offered by 6 of 53 SBTCPs (11 percent) during
the 1996 reporting period. 10 SBTCPs have plans to offer financial assistance
programs to small businesses in the near future. This is down from 14 financial
assistance programs offered by 10 states in 1995. Detailed information about these
financial assistance programs is provided in Appendix E-12.
Only 11 percent of SBTCP programs offer some type of financial assistance to help
small business with capital expenses associated with pollution prevention or control
equipment. Creative financing mechanisms fulfill a need conveyed to programs by
small businesses; offering financial assistance was a common recommendation made
for improving compliance by SBTCPs themselves. The addition of grant or loan
programs planned by 10 additional states will be of great benefit to small businesses
in these states.
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4.4 LEVERAGING OF RESOURCES AND MINIMIZING DUPLICATION OF EFFORTS
Programs reported on the extent to which they leverage resources within their
state/territory, as discussed in Section 4.4.1. SBTCP strategies to exchange
information and resources with other programs is provided in Section 4.4.2.
4.4.1 Leveraging of Resources
Information provided in this section is vital to understanding how some programs with
limited budgets and resources are functioning. Generally, programs report that all
three components of their SBTCPs recognize the efficiency and value of coordinating
their efforts with each other and with other environmental agency departments, state
agencies, and organizations. A summary of the number of SBTCP functions that
leverage resources is shown in Table 4-7. Descriptions of how programs leverage
resources for their SBOs, SBAPs, and CAPs may be found in Appendix E-13.
TABLE 4-7
PROGRAMS THAT REPORT LEVERAGING OF RESOURCES
FOR SBTCP FUNCTIONS
SBO
SBAP
CAP
£ Programs
46
46
20
% Programs
87
87
38
46 programs (87 percent) indicate some level of leveraging resources for the SBO
function. The SBO often coordinates information development and dissemination,
training, and workshops/seminars with such entities as other state agencies,
Chambers of Commerce, trade associations, non-profits, public utilities, and Small
Business Development Centers. The overall concerns of small businesses are being
taken into account, as many SBOs provide 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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46 programs (87 percent) indicate some level of leveraging resources for the SBAP
function in order to maximize their programs' effectiveness. Strategies and sources
of assistance are quite similar to those used by the SBOs.
20 CAPs (38 percent) report leveraging resources within their state/territory. While
the CAPs, by design, are independent entities, many receive administrative support
and technical resources from the state/territory environmental agency, the SBO, or
the SBAP. Many CAPs also report receiving a small level of funding for travel and per
diem expenses.
4.4.2 Minimizing Duplication of Efforts Among SBTCPs
49 programs (92 percent) report some action to minimize duplication of efforts among
SBTCPs. The sharing or exchanging of information among SBTCPs is a practical
method for avoiding duplication of effort, thus increasing the overall cost-
effectiveness of individual programs. As an example, industry-specific information
developed by one program would have wide applicability to other programs involved
with similar industries. Mechanisms that SBAPs employ to avoid duplication of effort
are presented in Table 4-8; program details for this topic are found in Appendix E-14.
TABLE 4-8
. . . SBTCP MECHANISMS FOR AVOIDING DUPLICATION
Mechanism
Review of documents from other sources
Contact with other SBTCPs within EPA regions
Contacts with state and regional air groups
Communication with other SBTCPs
Gathering of information from electronic sources
Review of EPA documents and/or contact with EPA
# Programs
41
30
25
23
18
17
% Programs
77
57
47
43
34
32
The most common technique (in 77 percent of programs) employed by SBAPs to
avoid duplication of effort was review of documents from various other public,
4-12
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private, or university sources. This facilitated the exchange of ideas and allowed
programs to identify those documents that they could adapt for their own use.
The second most common method for avoiding duplication was contact with other
programs within the same EPA region through conference calls and other means.
This technique was utilized during the 1996 reporting period by 30 programs (57
percent).
Gathering information from electronic sources, including use of the Internet for
information transfer, may be the most promising mechanism for avoiding duplication
of effort among SBAPs. This method increased in use in 1996 and was reported by
18 programs, up from 8 in 1995. This parallels the rise in the number of web pages
available, as previously noted. Posting of information from the federal SBO and
SBAP, other private and university sources, and state SBAPs facilitate efficient use
of resources and would encompass all of the mechanisms currently utilized by SBAPs
for avoiding duplication.
4 programs (8 percent) reported taking no specific actions to avoid duplication of
efforts during the 1996 period.
4.5 SBTCP COMPLIANCE WITH SECTION 507(d)(2)
Section 507(d)(2) of the CAA requires EPA's SBO to periodically report to Congress
on SBTCP actions to follow the intent of the provisions of the Paperwork Reduction
Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act. EPA's SBO
has conducted a number of significant outreach actions toward assisting the SBTCPs
in this effort.
Key EPA SBO outreach activities under the CAA Section 507(b) pursuant to these
statutes include:
Conducted educational activities at the EPA SBO Regional Liaison Conference,
Arlington, VA, August 1996.
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• Provided information on statutes at the 1996 National/State SBO/SBAP
Conference.
• Responded to telephone hotline inquiries in regard to the three statutes.
• Distributed copies of the three statutes by request to state contacts.
• Provided states with copies of the 1996 Small Business Regulatory
Enforcement Fairness Act (SBREFA), which strengthens and amends the
Regulatory Fairness Act.
4.5.1 SBTCP Activities Associated with the Paperwork Reduction Act
32 programs (60 percent) reported specific activities associated with the intent of the
Paperwork Reduction Act, up from 22 programs in 1995. 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 action taken to follow the intent of the provisions of this act
were development of simplified/consolidated permits or forms and CAP review of
SBTCP documents to monitor compliance with this Act. In addition, SBTCPs are
developing general permits for particular industry sectors and providing and receiving
information electronically. Producing concise, easy-to-read documents that
summarize regulatory issues also was cited as an effective activity, since these
summaries eliminate the need for small businesses to have copies of full legislative
documentation. Overall, these actions show that many SBTCPs have continued to
take significant steps during the 1996 reporting period in following the intent of the
provisions of the Paperwork Reduction Act.
Actions taken by SBTCPs in following the intent of the provisions of the Paperwork
Reduction Act are listed in Table 4-9 and are detailed, by program, in Appendix E-15.
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TABLE 4-9
SBTCP ACTIVITIES TO FOLLOW THE INTENT OF
THE PAPERWORK REDUCTION ACT
Activity
Simplified/consolidated permits and/or forms
Routine review of documents for compliance
Receiving/providing documents electronically
Producing concise, easy-to-read summary documents
Use of general industry-specific permits
Increasing exemptions for "insignificant" activities
f Programs
12
11
11
10
9
6
% Programs
23
21
21
19
17
11
4.5.2 SBTCP Activities Associated with the Regulatory Flexibility Act
27 programs (51 percent) reported activities to follow the intent of the provisions of
the Regulatory Flexibility Act during 1996, as shown in Table 4-10. The Regulatory
Flexibility Act requires that when a number of regulations will have a significant
economic impact on a substantial number of small entities, "a regulatory analysis
must be performed to explore options for minimizing those impacts."
TABU 4-10
SBTCP ACTIVITIES TO FOUOW THE INTENT OF
THE REGULATORY FLEXIBILITY ACT
Activity
Assessing impact of new regulation, policies, etc.
Routine review of documents for compliance
Simplified/consolidated permits and/or forms
Use of general industry-specific permits
Increased exemptions for "insignificant" activities
Amnesty program
# Programs
16
11
7
6
4
2
'4 :
% Programs
30
21
13
11
8
4
SBTCPs have played a major role in ensuring awareness of the effects of regulatory
requirements on small businesses as well as promoting environmental compliance in
the small business community. SBTCP personnel made significant strides in
4-15
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promoting the effects of legislation/regulations on small businesses to regulatory
agencies through their role as mediators between these two groups. The primary
activity reported by programs in following the intent of the Regulatory Flexibility Act
(16 programs, or 30 percent) was the review and comment on new air regulations to
evaluate their impact on small businesses. 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-16.
4.5.3 SBTCP Activities Associated with the Equal Access to Justice Act
18 programs (34 percent) reported specific activities to follow the intent of the
provisions of the Equal Access to Justice Act, whose purpose is to provide certain
parties who prevail over the Federal government with covered litigation in an award
of attorneys' fees and other expenses under appropriate circumstances. Specific
actions include the routine review of SBTCP documents by CAPs (the most common
activity, conducted by 9 programs), the establishment of pro bono legal services, and
the provision of technical assistance to groups aggrieved by permit actions of a
regulatory agency.
SBTCP actions to follow the intent of the provisions of the Equal Access to Justice
Act are shown in Table 4-11 and detailed, by program, in Appendix E-17.
* TABtE4.1t
SBTCP ACTTVTTIES TO TOUOW THE INTENT OF
THE EOUAl ACCESS TO JUSTICE ACT
Activity
Routine review of
Offering pro bono
documents for compliance
legal services
Providing technical assistance for groups aggrieved by
regulatory actions
Other1
* Programs
9
1
1
9
% Programs
17
2
2
17
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5.0 PROGRAM EFFECTIVENESS
External assessments of the SBTCPs' program effectiveness are reviewed in this
section. Comments regarding the SBTCP are discussed in Section 5.1. Complaints
received by SBTCPs and resolution strategies are presented in Section 5.2. Finally,
program highlights and accomplishments are found in Section 5.3.
5.1 COMMENTS RECEIVED BY SBO OR CAP ON SBTCP
37 programs (70 percent) reported that comments were received by their SBOs or
CAPs on the SBTCP. Comments were overwhelmingly positive, generally expressing
appreciation for the availability of services and the way in which these services were
provided. A detailed list of comments received by SBOs and CAPs on their SBTCPs
is presented in Appendix F-1.
Common themes repeated by small business clients of numerous programs include:
• Appreciation for knowledgeable, responsive, non-regulatory assistance with
environmental issues.
• Expressions that SBTCP services filled an existing need in the small business
community for personalized guidance through the many regulatory processes
involved in compliance. Many small businesses cited specific SBO/SBAP staff
members for their dedicated and professional service.
5.2 COMPLAINTS RECEIVED BY SBO OR CAP AND RESOLUTION STRATEGIES
SBTCP staff members fill an important role as facilitator or mediator between small
business owners/operators and regulatory agencies, enhancing communication to
promote understanding and sensitivity on both sides. Based on information reported,
most problems seem to be resolved when businesses have someone to turn to for
non-regulatory assistance, advice, and effective liaison with regulatory agencies.
Information was requested about complaints or issues raised by small business
representatives about SBTCP services and how these issues were resolved. Lessons
learned by one program can be shared with other programs, which thereby can
benefit from these experiences.
5-1
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27 programs (51 percent) provided examples of complaints received and resolution
strategies employed. Only 1 program (2 percent) indicated that specific complaints
had not been resolved.
Major themes of the issues reported have not changed significantly from the last
reporting period.
• A need for improved communication between businesses and regulatory
agencies.
• Requests for simplified forms and procedures.
• Confusion by small business as to which regulations applied to them, how
these regulations affected their specific operations, and how they can be met
in a time- and cost-effective manner.
• The need for specialized one-on-one assistance for identifying and completing
paperwork associated with regulatory requirements and submitting it on
schedule.
• The need for flexibility in applying regulations to small businesses (e.g., the use
of general permits, amnesty programs, exemptions).
• Overwhelming number of regulations.
• Desire for financing assistance programs.
Resolution strategies similar to those noted last year were employed and usually
involved SBTCP personnel:
• Providing "plain English" explanations of regulatory requirements.
• Giving one-on-one guidance through the paper work processes.
• Facilitating communication about flexibility and compliance assistance issues
between businesses and regulatory agencies.
• Investigating, developing, or institutionalizing financial assistance programs.
• Developing confidentiality policy for those concerned with seeking assistance.
A list of specific issues addressed by SBOs and CAPs and actions taken to resolve the
concerns expressed by the complainants is presented in Appendix F-2.
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5.3 PROGRAM HIGHLIGHTS AND ACCOMPLISHMENTS
41 SBTCPs (77 percent) reported on important accomplishments, awards, and
recognitions for their work with the small business community.
The SBTCPs have facilitated dialog and improved trust between the regulatory
agencies and small businesses. Many programs have forged strong partnerships with
such groups as trade associations, small business development centers, and small
business associations to broaden outreach efforts to the small business community.
Many states also have developed industry-specific initiatives that include compliance
manuals, workshops, and on site visits.
In this section, key accomplishments are highlighted based on the frequency in which
they were mentioned. An overview of program accomplishments and highlights for
1996 are provided in Appendix F-3.
1. Forging partnerships with other organizations and agencies was mentioned by
25 (47 percent) of the programs as being a significant accomplishment.
• Georgia's SBO/SBAP joined with government, industry, and trade
organizations to sponsor 20 workshops in 1996.
• In Louisiana, the SBO and SBAP cooperated with the Louisiana State
University Forestry Laboratory and Department of Economic
Development to organize a full day wood furniture small business
exposition with the EPA teleconference as the focal point.
• The Ohio SBO's major accomplishments in 1996 centered on building
solid working relationships with the Printing Industry of Ohio, Ohio Small
Business Council, Ohio Chamber of Commerce, Ohio Bakers Association,
Ohio Cleaners Association, Ohio Cast Metals Association, Ohio Chemical
Council, National Federation of Independent Businesses Ohio,
Automobile Service Association of Ohio, Ohio Petroleum Marketers
Association, and Ohio Council of Retail Merchants.
2. Sponsorship of or making presentations at workshops and forums was
highlighted by 18 programs (34 percent).
• The District of Columbia's SBAP indicated they reach more people by
attending trade associations' annual seminars and making presentations.
SBAP made a presentation at the Korean Drycleaners Association's
annual seminar, which was attended by 700 business owners and their
employees.
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• Kansas conducted a well-received series of Air Emission Inventory and
Class II Permit Application Assistance workshops.
• Michigan's SBAP conducted 6 workshops on the state's Renewable
Operating Permit Program.
• Rhode Island's Pollution Prevention Conference and Expo attracted over
700 attendees in 1996 and provided SBO, SBAP, and CAP information
on large scale.
3. Improved synergy between the regulatory agency and small business was
noted by 17 programs (32 percent).
• In New Hampshire, presentations to three industry trade associations
that previously were reluctant to allow a "regulatory" speaker to attend
their meetings resulted in a number of requests for on site assistance.
• North Carolina noted a 100 percent increase in technical assistance,
including on-site assistance, to wood furniture companies, service
stations, dry cleaners, small boat manufacturers, metal plating
companies, and others.
• Washington state's YRCCA held a series of meetings with feedlot
operators to discuss complaints, concerns, and opinions for a dust
control abatement process. Procedures were suggested for voluntary
compliance.
4. 13 programs (25 percent) were pleased with the publication of various
documents.
• With funding from a Leadership Grant, Florida developed Environmental
Facility Survey Guidance manuals for multimedia environmental audits.
• Minnesota's SBAP participated in a workgroup to develop a compliance
guide for the wood furniture manufacturing NESHAP's work practice
standard.
• New Jersey published a Small Business Directory of Information, which
is available in hard copy or through the DEP BBS.
5. Awards and grants also have been received by individual programs that have
displayed exceptions vision and leadership. 9 programs (17 percent) reported
receiving awards or grants.
• Arkansas' program received the 1996 Distinguished Service Award from
the Arkansas Environment Federation.
• Maryland's program received recognition of appreciation at the 1996
awards dinner of the Korean Drycleaners Association of Maryland and
the Korean Drycleaner Association of Greater Washington.
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• Oklahoma received the Ecos Award for their Customer Assistance
Program.
6. 8 programs (15 percent) reported involvement in regulatory/permitting
developments and negotiations.
• Iowa noted that after two years of meetings, a revised, streamlined
version of their construction permits should go to the printer in March
1997.
• Mississippi's SBO and SBAP, in conjunction with the Air Toxics section
of the Air Division, are developing simplified versions of Air Permit
Applications for perc and petroleum dry cleaners.
• New York's SBTCP was directly involved in negotiations on rewriting the
state's general permitting regulations that produced a registration
system for minor sources that simplifies permitting with a one-page, no
calculations form; a general permit application for sources that can cap
out of Title V; and a major source Title V application.
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6.0 COMPLIANCE ASSURANCE ISSUES
EPA's Office of Enforcement and Compliance Assurance (OECA) requested
information on the effectiveness of the SBTCPs in providing compliance assistance
to small businesses. Common compliance problems are discussed in Section 6.1,
improvements in regulatory understanding and compliance are detailed in Section 6.2,
and recommendations to facilitate compliance are outlined in Section 6.3. Program
confidentiality issues are outlined in Section 6.4.
6.1 COMMON COMPLIANCE PROBLEMS
51 SBTCPs (96 percent) provided insight on the types of compliance issues addressed
during the course of providing technical assistance to small businesses.
Common compliance problems, listed by decreasing occurrence, are shown in Table
6-1 and are detailed, by program, in Appendix G-1.
TABLE 6-1
COMMON COMPLIANCE PROBLEMS
Compliance Problem
Not understanding regulatory requirements
Operating without a permit
Incomplete record keeping
Uncertain of permitting requirements
Uncertain how to determine emission inventories/lack technical
expertise
Rnancing for control requirements
Uncertain how to complete forms/complicated paperwork
Operating outside NSPS or MACT
Improper storage/disposal of hazardous waste
Fear of arbitrary regulatory enforcement/regulatory agency
Failure to use or finding proper equipment/technology to comply
with applicable standards
Multiple permitting requirements/need for multi-media permits
# Programs
28
26
16
14
12
10
10
10
7
6
6
5
% Programs
53
49
30
26
23
19
19
19
13
11
11
9
6-1
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Examples of less frequently-cited compliance concerns as identified by small
businesses and programs are shown below.
• Overwhelmed by the quantity and complexity of regulations.
• Lack of sufficient notification by or getting straight answers from the regulatory
agency.
• No manifest for special or hazardous waste.
• Uncertain as to which government agency to contact and when to contact that
agency.
• Improper labeling of storage areas.
• Noncompliance, since risk of inspection and penalty seem remote.
6.2 IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Programs reported on their observations of improvements in understanding and
awareness of regulatory requirements, behavioral changes, and environmental
improvements (if tracked) that they feel have resulted from their compliance
assistance activities.
49 programs (92 percent) provided insight as to improvements in regulatory
understanding and compliance. The most common responses, listed by number and
percentage of programs, are provided in Table 6-2 and are detailed, by program, in
Appendix G-2.
6-2
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'." TABU**
IMPROVEMENTS IN REGULATORY UNDERSTANDING
Response
More open communication between sources and agencies
Increased compliance
Greater understanding/awareness of regulations
Reduced apprehension of regulatory agencies and environmental
compliance
Improved attitude about compliance
Increased registration and permitting of existing sources
Improvements in pollution prevention practices
Promotion of compliance through on-site visits
Better record keeping
Involvement by business in regulatory development process
Businesses including compliance strategies early in their business
plans
Recycling and reuse
Better hazardous waste disposal
f Programs
30
20
18
12
12
11
10
10
4
2
1
1
1
% Programs
57
38
34
23
23
21
19
19
8
4
2
2
2
Generally, businesses want to comply with environmental regulations; however, they
may be afraid to ask for assistance. When a non-threatening assistance program,
such as the SBTCP, is available, small businesses are most anxious to take advantage
of the services. The SBTCPs have offered important one-on-one contacts, which
have provided valuable information to those who were previously unaware of their
compliance requirements. Such information included: the need to have operating
permits and how to obtain and complete them; the need to maintain records; and
information on available compliance options such as reformulation, pollution
prevention, or control equipment.
SBTCPs help small business understand how the regulations apply to their
operations/facilities and offer information on the available alternatives to achieve
voluntary compliance. Two of the top three most common compliance problems
mentioned by small businesses, "not understanding regulatory requirements", and
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"operating without a permit", were represented positively by facilities as compliments
to program effectiveness, with programs reporting "greater understanding and
awareness of the regulations," and "improved communication between sources and
agencies." This indicates that the SBTCPs are working to understand the small
business community and provide quality service where it is most needed.
10 programs reported that the most notable improvements in compliance have been
a result of on-site visits, up from 3 programs in 1995. Many of the businesses visited
by the SBAP were not aware of regulations or pollution prevention opportunities and
were eager to be given a chance to comply without the threat of enforcement action.
Two other areas attributed to improvements in regulatory understanding that showed
strong increases were increased registration and permitting of existing sources! as
reported by 11 programs, up from 5 in 1995) and improved pollution prevention
practices (doubling from 5 programs in 1995 to 10 in 1996).
Texas and Virginia reported specific improvements in compliance as a result of their
outreach efforts to specific industry sectors.
• In Texas in 1996, 1,780 businesses in the wood products industry were
contacted by SBAP to promote compliance. Because of this outreach, proper
handling of hazardous waste rose by 73 percent, completion of hazardous
waste determinations increased by 1 percent, waste related recordkeeping was
up by 43 percent, transport of hazardous wastes off site within the required
time limits improved by 77 percent, and disposal of hazardous waste at an
approved facility showed a 52 percent rise.
The SBAP also conducted site visits in the auto body industry. The average
initial Compliance rate was 72 percent. Following initial assessments, SBAP
made follow up visits to measure compliance, which was found to have
improved to 88 percent. Also, SBAP site visits saved each auto body shop an
average of $1,200 through reduced costs for materials, consulting fees, and
avoided penalties.
• In Virginia, there is a strong relationship of compliance assistance activity to
the awareness and acceptance by the existing regulated or newly regulated
community. Virginia saw with dry cleaners in 1994 that their acceptance of
responsibility to comply with regulations was a direct result of their
understanding of the requirements, the cost of compliance, the benefits of
compliance, and that there was a willing party to provide information and
assistance outside a perceived hostile environment. The June 1994 deadline
for initial notification reports was met by 73 percent of Virginia dry cleaners.
Continued cooperation between the state and interested trade associations
6-4
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ensured wide coverage of compliance assistance activities and workshops,
consistency of information, and follow up. Notification report compliance
reached approximately 84 percent in October 1996.
Virginia also provided insight that reflects the sentiment of many state programs:
• We are finding that a large part of the success of any outreach assistance is
a continued interest in and delivery of a non-regulatory assistance message to
the affected source population. This includes concise, understandable
materials; a recognition of the minimal available time for a source to participate
in outside activities beyond daily business; and the provision of options for
compliance. All these are critical to the success of a compliance assistance
effort. Results of compliance assistance activity will not necessarily yield
verifiable results immediately. Compliance assistance activity should be viewed
as a system, a support system that will yield incremental results arriving at full
compliance.
6.3 RECOMMENDED CHANGES TO FACILITATE SMALL BUSINESS COMPLIANCE
WITH THE CAA
Recommendations made by 45 SBTCPs for changes, at the state or federal level, that
would help small businesses comply with the CAA are summarized in Table 6-3.
SBTCP staff members are uniquely qualified to make such recommendations, since
they address current CAA compliance problems encountered by small business and
attempt to provide effective solutions. Specific responses, grouped by category and
listed by program, may be found in Appendix G-3.
6-5
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, • , "\\ ---
- x - TABLE 0-3
SBTCPRBCOMMBfi>ATIONSFORIMPROVINGCOMPUANCE
Recommendation
Allow flexibility/simplification in applying regulations to small
businesses
Multimedia pollution control and compliance assistance
Increased funding/continued adequate funding for SBTCPs
Mechanisms for financing pollution control equipment
Expand/facilitate effective communication between state and federal
agencies
Promote compliance assistance versus enforcement
Expand advertising to increase program exposure
Avoid duplication of effort in compliance assistance activities
Generic outreach and training materials
Use of Internet for information transfer
Develop plain language materials
f Programs
22
14
14
13
12
9
8
6
6
6
6
% Programs
42
26
26
25
23
17
15
11
11
11
11
85 percent of all of programs (45) provided at least one recommendation for changes
to improve small business compliance with the CAA. Several of these
recommendations reflect dominant themes repeated in data relating to SBO/SBAP
outreach activities, CAP activities, and comments from small businesses, methods of
avoiding duplication. Priority of responses for 1996 parallel those of 1995. Allowing
flexibility and simplification in applying regulations to small businesses was mentioned
by 22 programs (42 percent) as being the prime recommendation for improving
compliance.
Another common recommendation stressed by 26 percent of SBTCPs involves the
expansion of technical assistance into a multimedia effort, addressing small business
concerns about ground water, soil, and hazardous waste issues. Many states have
already expanded their programs to encompass multimedia assistance or are planning
to do so in response to small business requests.
The third most common recommendation, mentioned by 14 programs, was for
continued and increased funding for the state SBTCPs. As previously noted, a
6-6
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number of states operate with limited budgets and staffs. The personalized approach
to technical and compliance assistance has been shown to be effective in reaching
the small business community, and 26 percent of state programs believe that
adequate financial resources are vital to continued and expanding high quality service.
6.4 PROGRAM CONFIDENTIALITY AND CONFLICT OF INTEREST
t
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 (COD and maintain
confidentiality, particularly in those cases where the SBAP is located within the
regulatory agency.
41 programs (77 percent) report no problems with COI or confidentiality issues. 5
programs (9 percent) indicate that no confidentiality program or guarantee of
confidentiality is in place, while 3 programs (6 percent) indicated possible perception
problems with confidentiality or COI. 4 programs did not respond to the question.
Program structures range from guaranty of confidentiality (more common) to
providing no confidentiality. For example, assistance programs may be housed in
non-regulatory departments, or a program may refer a business in need of technical
assistance to such a provider that will guaranty confidentiality. Most programs
provide for confidentiality of trade secrets. Many programs have policies that protect
small businesses from penalties if violations are discovered during the course of their
receiving technical assistance. Program responses to the issue of COI may be found
in Appendix G-4.
The following example responses reflect the range of COI issues and resolutions (from
having an established confidentiality policy to having no such policy).
• In Colorado, the SBO is located in an agency independent of the air pollution
regulatory agency, so the problem has not presented itself. SBAP is located
in the air pollution regulatory agency; however, they are removed from the
6-7
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enforcement section of their department. As of yet, a problem has not
occurred.
Georgia's SBAP avoids the discussion and review of confidential materials with
compliance and enforcement personnel. When in discussions with other
programs in EPD about a small business client, business names are not used
or circumstances are presented and assurances are secured before any
sensitive materials are disclosed.
In Wyoming, the problem of COI or that SBAP does not have confidentiality has
not been resolved internally or externally. CAP recommended that
confidentiality is necessary for an effective SBAP; however, the department
has maintained that state statute prohibits confidentiality, since all received
information must be available to the general public, other than trade secrets.
CAP believes that the result of this impasse is a less than effective SBAP
where the bottom line is to provide compliance and technical assistance to the
small business community. The Department initiated the drafting of its Small
Business Voluntary Disclosure and Incentive Rule that provides penalty waivers
for small businesses that voluntarily disclose non-compliance and work with
the Department to achieve compliance.
In Utah, several concerns have been expressed regarding confidentiality issues.
An outside program that advertised confidentiality was not considered to be
confidential. After legislative review by the Utah Attorney General's office, it
was determined that although a self-audit bill exists, it did not cover on site
visits. Further, federal and state records are, in many cases, open and
available for public review.
In the District of Columbia, COI is inevitable, because the SBAP performs many
other regulatory functions. SBAP also is a permit engineer who may
recommend enforcement actions for noncompliance of her permit conditions.
SBO is not a regulator and has no appearance of conflict.
6-8
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APPENDIX A
1996 ANNUAL REPORTING FORM
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STATE SMALL BUSINESS STATIONARY SOURCE
TECHNICAL AND ENVIRONMENTAL COMPLIANCE
ASSISTANCE PROGRAM (SBTCP)
ANNUAL REPORTING FORM
FOR THE PERIOD 1/1/96 TO 12/31/96
OMB NO.: 2060-0337
EXPIRATION DATE: 7/31/98
INSTRUCTIONS FOR COMPLETING THIS FORM
Enclosed is a blank copy of the Annual Reporting Form for the State Small Business Stationary Source
Technical and Environmental Compliance Assistance Program (SBTCP). The questions are the same as
those asked last year, but they have been reordered to mirror the presentation of information in the 1995
SBTCP Report to Congress; there are now five section instead of six. To streamline the reporting, this
Form is designed to collect standardized information on each of the three components of the SBTCP, listed
below, in a single document.
• Small Business Ombudsman (SBO)
• Small Business Assistance Program (SBAP)
• Compliance Advisory Panel (CAP)
The period of time covered by this first report is January through December 1996.
For your convenience, electronic copies of the form are provided on the enclosed disk in WordPerfect
(SBTCP96.WP) and Microsoft Word (SBTCP96.DOC). Table 3-1 also is provided on disk in a spreadsheet
format in Lotus'! 23 (TABLE3-1 .WK3) and Microsoft Excel (TABLE3-1.XLS).
Please answer the questions on this Form, and return the disk and a completed hardcopy of the Reporting
Form using the enclosed, ore-addressed mailer.
If this mailer is missing, please return the disk and a completed hardcopy to:
Ms. Karen V. Brown
Small Business Ombudsman
U.S. Environmental Protection Agency (1230C)
401 M Street, SW
Washington, D.C. 20460
ATTN: SBTCP Annual Report
If you use your own mailer, please include on the mailer the words, "Electronic Media Enclosed."
Completed forms are due by February 15, 1997.
If you have any comments or questions regarding this form, please contact the U.S. EPA Small Business
Ombudsman (EPA SBO) at the numbers listed below. The SBO can be reached Monday through Friday
from 8:30 a.m. to 5:00 p.m. (EST). After these hours, messages can be left on an answering machine,
which is connected to the toll-free 800 number.
(703) 305-5938 (Telephone)
(800) 368-5888 (Toll-free Hotline)
(703) 305-6462 (Facsimile)
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WHY ARE WE REQUESTING THIS FORM?
As part of the Clean Air Act CAA as amended in 1990, the U.S. Congress included, as Section 507, the
requirement that each state establish a Small Business Stationary Source Technical and Environmental
Compliance Assistance Program (SBTCP) to assist small businesses in complying with this Act.
As part of its normal reporting requirements to Congress, EPA will also provide the Congress with a report
on the SBTCP program, including overall effectiveness, difficulties encountered, and the degree and
severity of enforcement. EPA has internally delegated responsibility for completion of this report to its
Small Business Ombudsman (EPA SBO).
The EPA SBO intends to use the information contained in this Form, as reported by the states, to prepare
the Report to Congress, including the need for such technical assistance programs and how they should
be changed, if necessary. The goal of this Form is to standardize the information reported by the state
SBTCPs.
Any suggestions or recommendations to improve this reporting format would be appreciated. Please feel
free to contact EPA's SBO to discuss any recommendations using the address and telephone numbers
listed on page 1.
SUGGESTIONS FOR COMPLETING THIS FORM
• Gathering information for this report is definitely a team effort! You may wish to provide hard
copies of this form to key contacts from the SBO, the SBAP, and the CAP, and indicate who will
be responsible for the various parts of the report. Once all information is collected, one person
should take responsibility for completing and submitting this form (most likely the SBO).
• We are looking to collect objective information on each state SBTCP. This report is not meant to
be an evaluation of any facet of your program.
• The period covered by this report is January through December 1996.
• We are seeking information you should be already collecting for you own purposes. We are not
asking you to create information you do not have. If a question asks for information you do not
have, please provide a brief explanation as to why the information is not available.
• You may wish to refer to last year's report for reference in completing this year's reporting form.
• For future reports, you are encouraged to continually gather your statistics during the reporting
period. Based on the information requested in this Form, you may need to revise the types of
statistics you track for your SBTCP for subsequent years.
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SECTION 1
SOURCE OF THE INFORMATION
This section is designed to collect standardized information about the state SBTCPs completing this Form,
and whom to contact if we should have any questions.
1.1 Name of state or territory for which this report is being submitted.
1.2 Period of time (calendar year) covered by this report.
1996
1.3 Who should be contacted (primary and alternate contacts) if there are any
questions regarding the information contained in this Form?
The most typical answer for this question will be the CAP Chairperson or the state Small Business
Ombudsman. For the question 'Relationship to SBTCP*, we would like to know the relationship
of that person to the SBTCP program (i.e., CAP Chairperson, SBO, etc.). Be sure to include the
area code for the telephone and facsimile numbers. Also include a telephone extension if
appropriate.
Name
Title
Relationship to SBTCP
Organization
Address
Address
City, State. Zip
Telephone Number
Facsimile Number
PRIMARY CONTACT
ALTERNATE CONTACT
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SECTION 2
STATUS, BUDGETS, STAFFING, ORGANIZATION
This section is designed to collect four types of standardized information about your state's SBTCP:
Status, Budgets, Staffing Levels, and Organization. The information you provided in last year's report will
be helpful in answering the questions in this section.
STATUS
2.1 When was your SBTCP established?
Please note that in Question 2.2, we are asking when each component of your SBTCP actually
began to operate (provide services!, which may be different.
SBTCP Component
SBO
SBAP
CAP
Month and Year of Establishment
2.2 When did the SBTCP begin to provide operations (month and year)?
To be consistent, for the SBO, indicate the effective date (month/year) of appointment; for the
SBAP, indicate the date (month/year) it began providing assistance to small businesses; and for
the CAP, indicate the date (month/year) of the first meeting ~ even if not alt members of the CAP
were appointed by the time of the first meeting.
SBTCP Component
SBO
SBAP
CAP
Month and Year Operations Began
BUDGETS
2.3 Please provide summary information on the funding for each component of your
state's SBTCP (for the period January through December 1996). Please indicate
the source of funding.
For example, sources of funding might include: Title V fees, specific appropriation of state funds,
the operating budgets of existing programs, or some combination.
These budgets should include direct salaries, fringe benefits, materials & supplies, etc.
To keep it simple, please round your budgets to the nearest $5,000.
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SBO
SBAP
CAP
BUDGET (*)
SOURCE OF FUNDING (please describe)
2.4 What was the SBTCP's budget in 1995? What is the expected SBTCP budget
during the next reporting period (January through December 1997)?
As with the previous question, please round all numbers to the nearest $5,000. If these programs
did not exist for were not active) in the previous reporting period, please complete this question
with such words as, "inactive * or 'did not exist."
SBO
SBAP
CAP
1995 BUDGET ($)
1997 PROJECTED BUDGET ($)
2.5 Briefly describe any significant changes (more than 10%) in the level of funding
between the 1995, 1996, and 1997 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 Vrevenues were lower than projected; or state appropriations may
have been reduced or eliminated.
STAFFING
With these questions, we are interested in knowing how many people are supporting each component of
your state's SBTCP.
2.6 How many people, measured as full-time equivalents (FTEs), support the SBO
function?
Please complete this question for the staffing levels that are current as of December 1996. An
FTEis considered to work 40 hours/week. For example, 2 people working 20 hours/week would
be equivalent to 1 FTE. It is possible that the SBO has other responsibilities and does not perform
this function on a full time basis. For example, if they perform this function approximately 20
hours/week for 50% of their time), this would be equivalent to an 0.5 FTE.
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SBO Function
SBO
Other staff (as FTEs)
Number of FTEs
2.7 How many people, measured as full-time equivalents (FTEs), support the SBAP
function?
Please complete this question for the staffing levels that are current as of December 1996. Use
the same definition for an FTEas discussed in Question 2.6.
SBAP Function
All Staff
Number of FTEs
2.8 With respect to the SBAP, how many of these people are paid or serve as (un-
paid) volunteers?
Please complete this question based on the information in Question 2.7, also reporting the results
as FTEs. The total should be the same as the total number of FTEs in Question 2.7.
SBAP Staff
Paid
Un-paid Volunteers
Number of FTEs
2.9 How many of the people identified in Question 2.7 would be considered retired
engineers?
Please complete this question based on the information in Question 2.7, also reporting the results
as FTEs. We are interested in knowing if the states are utilizing "retired engineer' programs (or
their equivalent) to support the SBAPs.
SBAP Staff
Retired Engineers
Number of FTEs
2.10 How many people are currently serving on your CAP?
Please answer this quest/on by indicating how many people have been appointed to your CAP as
of December 1996. Please indicate the affiliation of each CAP member (i.e., small business, state
regulatory agency, general public, etc.)
If appropriate, please indicate the number of people who have not been appointed to your CAP as
of December 1996.
When complete, this table should list a total of at least 7 people (including appointed and not vet
appointed).
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AFFILIATION
Owner (or representative) of small business
State regulatory agency
General public
Not yet appointed
Other (please specify)
NUMBER OF PEOPLE ON CAP
ORGANIZATION
2.11 Please briefly describe where each component of your SBTCP is
located/organized.
Please indicate if the component is located in a state regulatory agency, another state agency, a
university, etc. For example, in some states, the SBAP is located within the state regulatory
agency. If so, please list the name of the agency and the appropriate department, division, etc.
(for example: Department of Environmental Protection, Bureau of Waste Management). If your
state has subcontracted your SBAP to an outside company, please complete Question 2.13. In
the case of the SBO, for example, some states have located this component within the Department
of Commerce. Generally, the CAP is independent and is located outside of all agencies, with each
individual appointed as defined in Section 507.
SBTCP COMPONENT
SBO
SBAP
CAP
BRIEF DESCRIPTION OF ADMINISTRATIVE LOCATION
2.12 Has management of the SBAP been contracted to an outside company?
If YES, please complete Question 2.13.
YES
NO
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2.13 Who is the outside company that is operating your SBAP?
For the section, 'Budget During the Current Reporting Period", please complete for the time period
January through December 1996. Please indicate (or estimate) the budget to the nearest $5,000.
Company
Address
Address
City, State, Zip
Telephone Number
Facsimile Number
Project Manager (or
principal point of contact)
Budget During the Current
Reporting Period
Term of Contract
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SECTION 3
SERVICES PROVIDED/ACTIVITIES CONDUCTED
This section is designed to collect standardized information about the type and level of services provided
by the three components of the state's SBTCPprogram: SBO, SBAP, and CAP. As you complete this
section, please seek assistance from the SBAP (primarily) and CAP.
SMALL BUSINESS OMBUDSMAN
3.1 Does your state's SBO have a toll-free Hotline?
YES
NO
If YES, is the hotline number accessible nationally or in-state only?
National
In-state only
-1
If YES. please list this number.
3.2 Briefly describe the state SBO's outreach program.
With this question we are interested in compiling statistics on the types and number of people
reached through a variety of outreach activities by the SBO, such as meetings with trade
associations, speeches, mailings, etc. during the 1996 reporting period.
A list of activities is sufficient, however, the number of occurrences of these activities when
available is preferred (e.g., 12 speaking engagements reaching 160 people;, 3 training seminars
reaching 72 participants; preparation and distribution of 8 industry-specific brochures, 500 copies
of each.
To help you in completing this question, the following table is provided in which you can list the
number of occurrences and the number of people reached, if those statistics are available. If you
only track whether these activities occurred (and not the specific number of occurrences), please
simply indicate "YES" in the "DID THIS ACTIVITY OCCUR' column.
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OUTREACH
ACTIVITY
Meetings
Speaking
Engagements
Brochures/Ryers
Training Sessions
Others (please
specify)
DID THIS ACTIVITY
OCCUR? (YES OR NO)
f OF OCCURRENCES
DURING REPORTING
PERIOD
NUMBER OF
PEOPLE REACHED
SMALL BUSINESS ASSISTANCE PROGRAM (SBAP)
3.3 What assistance services are offered by your state's SBAP?
At a minimum, we would like to compile a list of the services offered by your state's SBAP. The
table below lists these services. Please check those boxes that apply, list additional services as
appropriate and, if possible, indicate the number of services provided, and/or individuals/businesses
reached.
ASSISTANCE SERVICE
General Assistance
On-Site Visits
Seminars, Workshops,
Meetings, etc.
Factsheets, Manuals,
Information Packets
Others (please specify)
SERVICE
PROVIDED?
(YES OR NO)
* OF SERVICES
PROVIDED DURING
THE REPORTING
PERIOD
# OF INDIVIDUALS
OR BUSINESSES
REACHED
NOTE: If available, please include a list of documents, that were prepared and distributed by your
SBTCP during the 1996 reporting period.
10
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Preferably, but only if you are maintaining such statistics, we would like to compile the number
of businesses helped/reached by the SBAP's services (e.g., general assistance via telephone,
letters, etc.; on-site consultations; seminars/workshops/meetings/etc.; distribution of
factsheets/manuals/informatfon packets/etc.) by three-digit Standard Industrial Classification (SIC)
codes.
Please complete Table 3-1, which is attached. Electronic copies of this table are
provided in both Lotus123 (TABLE3-1. WK3) and Excel (TABLE3-1.XLS) formats
for your convenience.
3.4 Does your state's SBAP have a telephone Hotline?
YES
NO
If YES. is this a toll-free number?
YES
NO
If YES, is the number accessible nationally or in-state only?
National
In-state only
Please list the number.
3.5 Does the SBAP program services include an electronic bulletin board or Internet
homepage?
If YES, what is the address of the bulletin board or homepage?
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Please list what information is accessible through this bulletin board or homepage.
To make it easy to complete this question, the table below lists some possibilities. Please add
additional items as appropriate.
Information Available Through
the Bulletin Board or Homepage
Copies of regulations
Information on P2 options
Others (please specify)
Please check all
appropriate boxes
If your SBAP has an electronic bulletin board or homepage, please indicate, if available, its level
of usage (i.e., how many times was it accessed during the 1996 reporting period)?
Was it helpful to its users?
With this question, we are asking if you have received ANY comments from the bulletin board or
homepage users. Please indicate if any component of the SBTCP is soliciting feedback from users
as to information/topics they would like to see on the bulletin board or homepage.
12
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COMPLIANCE ADVISORY PANEL
3.6 What were the major activities of the CAP during this reporting period?
For example, the CAP may have: reviewed documents for readability, assessed small business
concerns, reviewed technical assistance outreach efforts by the SBTCP, established procedures,
or appointed a chairperson.
3.7 Please indicate the number of meetings that occurred between the SBO, SBAP,
and CAP during the 1996 reporting period.
We are interested in comparing how much communication occurred between the different
components of each state SBTCP during the 1996 reporting period, and if these were regularly
scheduled or occasional meetings.
To make it easy to complete this question, the table below lists all possible combinations of
meetings between these groups. For the question of "Frequency *, please indicate if the meetings
between these groups are regularly scheduled (i.e., monthly, quarterly, or biannually), or
occasional.
MEETINGS BETWEEN
WHOM
SBO and SBAP
SBO and CAP
SBO and CAP and SBAP
SBAP and CAP
NUMBER OF
MEETINGS DURING
THE REPORTING
PERIOD
FREQUENCY
(Please indicate if monthly, quarterly,
biannually, etc.)
13
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OTHER SERVICES/CONDUCT OF ACTIVITIES
3.8 Is your state planning a grant or loan program?
Please indicate if your state has or is planning a financial assistance program to help small
businesses comply with the requirements of the CAA.
YES
NO
If YES, please indicate the date (month/year) such a grant or loan program became/will become
available for each.
If YES, please indicate the funding levels for each grant or loan program.
NAME OF GRANT OR LOAN PROGRAM
•
FUNDING LEVEL
14
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3.9 Briefly describe how each component of the SBTCP (i.e., SBO, SBAP, and CAP)
leverages existing personnel resources (within the state).
This question is critical to understanding how some states, with limited budgets and resources
(typically with the SBAP and SBO components) are functioning. For example, have personnel from
any other departments been assigned to assist with the program?
SBTCP COMPONENT
BRIEF DESCRIPTION OF HOW RESOURCES ARE LEVERAGED
SBO
SBAP
CAP
3.10 How does your state SBAP avoid duplication of efforts among other state
SBTCPs?
With this question, we are hoping to find out to what extent states are sharing/exchanging
information with other state SBTCPs. For example, what factsheets or information packets were
developed by another state and used (with minimal editing) in your state?
15
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3.11 Please briefly describe what actions were initiated by your SBTCP/CAP to follow
the intent of the provisions of the Paperwork Reduction Act, the Regulatory
Flexibility Act, and the Equal Access to Justice Act.
One of the responsibilities of the CAP is to critique the SBTCP in following the intent of the
provisions of these three federal acts.
16
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SECTION 4
PROGRAM EFFECTIVENESS
The questions in this section are designed to collect some external assessments of the SBTCP's program
effectiveness and how it is providing a useful service.
We suggest that the questions in this section be completed by either the SBO or the CAP.
4.1 What were some comments (positive or negative) received by the SBO or the CAP
on the SBTCP?
To answer this question, we are looking for comments that the SBO or CAP may have received.
Additionally, you might wish to attach copies of relevant letters, memos, etc. that your office
received.
4.2 What was the nature of the complaints received/initiated by the SBO or the CAP,
and how were they resolved?
By collecting some representative information on the type of complaints received and how they
were addressed, we believe that there may be some lessons learned that could be shared with
other state SBTCPs.
COMPLAINTS
RESOLUTION OF COMPLAINTS
17
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4.3 Please feel free to include any information about your program that you would like
to highlight (i.e., significant accomplishments, awards, recognitions, etc.)
Jo answer this question, please invite the SBO, SBAP, and the CAP to include any information they
believe is appropriate. Use as much space as necessary.
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SECTION 5
COMPLIANCE ASSURANCE
The first three questions in this section have been included at the request of EPA's Office of Enforcement
and Compliance Assurance (OECA).
5.1 What is the total number of eligible facilities identified by your program, by
industry sector, that have received assistance by your program from January
through December 1996?
NOTE: An eligible facility is defined as a stationary source that: (1) is owned and operated by a
person that employs 100 or fewer individuals; (2) is a small business concern as defined by the
Small Business Act; (3) is not a major stationary source; (4) does not emit 50 tons or more per year
of any regulated pollutant; and (5) emits less that 75 tons per year of all regulated pollutants.)
Please distinguish between general assistance and on-site assistance. What percentage is this of
the total eligible pool of facilities? Please photocopy the table on the next page if additional space
is needed.
INDUSTRY
SECTOR
Example:
Dry Cleaners
A
#OF
GENERAL
ASSISTANCE
71
B
#OF
ON-SITE
ASSISTANCE
14
C
TOTAL # OF
FACILITIES
ASSISTED
(A + B)
55
D
#OF
ELIGIBLE
FACILITIES
IN YOUR
STATE
400
E
%OF
TOTAL
ELIGIBLE
POOL OF
FACILITIES
(C/D)«100
21%
19
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INDUSTRY
SECTOR
A
*OF
GENERAL
ASSISTANCE
B
*OF
ON-SITE
ASSISTANCE
C
TOTAL # OF
FACILITIES
ASSISTED
(A + B)
D
#OF
ELIGIBLE
FACILITIES
IN YOUR
STATE
•
E
%OF
TOTAL
ELIGIBLE
POOL OF
FACILITIES
(C/D)*100
20
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5.2 What are the most common compliance problems identified by the facilities?
In the course of providing technical assistance, what have been the most common compliance
issues addressed? Examples of compliance problems may include incomplete reports, lack of
permits for new equipment or changes in processes, operating outside of MACT standard, or
unpermitted emissions. Please indicate if certain problems are prevalent in any particular industry
sector.
5.3 What have been the improvements in understanding and awareness of regulatory
requirements, behavioral changes, and environmental improvements (if tracked)
that have resulted from your compliance assistance activities?
From the perspective of the SBAP andSBO, what changes have you seen in businesses as a result
of your technical assistance activities? Do you see a relationship between your activities (on-site
consultations, hotline, seminars, publications, etc.) and improvements in compliance? Please use
as much space as necessary.
21
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5.4 What changes would you recommend, at either the state or federal level, to assist
small businesses to comply with the CAA?
Please list any suggestions you have. We intend to compile the list of recommendations and
highlight these in the report to Congress.
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5.5 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 are interested in knowing how the states are avoiding COI and maintaining
confidentiality - particularly in those cases where the SBAP is located within the regulatory
agency.
This is the end of the 1996 SBTCP Annual Reporting Form. Thank you, and all
contributors, for the completeness and accuracy of your state's Report. A copy of the
EPA 1996 Report to Congress will be provided upon its submittal.
23
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APPENDIX B
FEDERAL SMALL BUSINESS OMBUDSMAN
-------
APPENDIX B
OFFICE OF THE EPA SMALL BUSINESS OMBUDSMAN
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE SMALL BUSINESS OMBUDSMAN
401 M STREET, SW (1230-C)
WASHINGTON, DC 20460
800-368-5888
703-305-5938 (in DC area)
703-305-6462 (fax)
The Office of the Small Business Ombudsman serves as an effective conduit for small
businesses to access EPA and facilitates communications between the small business
community and the Agency. The Office reviews and resolves disputes with EPA and works
with EPA personnel to increase their understanding of small businesses in the development
and enforcement of environmental regulations.
The SBO's primary customer group is the nation's small business community. Significant
secondary customer groups include state and EPA regional small business ombudsmen and
national trade associations serving small businesses.
In response to the identified needs of the Office's target customer groups, the SBO has
undertaken a variety of major outreach efforts including:
• Serving as liaison between small businesses and the EPA to promote understanding
of Agency policy and small business needs and concerns.
• Staffing a small business hotline that provides regulatory and technical assistance
information.
• Maintaining and distributing an extensive collection of informational and technical
literature developed by the various EPA program offices.
• Making personal appearances as a speaker or panelist at small business-related
meetings.
• Interfacing on an on-going basis with over 45 key national trade associations
representing several million small businesses and with state and regional ombudsmen
who serve businesses on the local level. Also in contact with over 400 additional
national organizations that represent millions of small businesses.
• Providing guidance on the development of national policies and regulations that
impact small businesses.
The SBO actively seeks feedback on its responsiveness to small business' inquiries and ever-
evolving needs, primarily in the areas of technical assistance and advocacy. The SBO can
"package" relevant information for the most effective and efficient delivery — be it through
training seminars, fact sheets, or position papers - to its target audience.
1
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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 26 years of management service
with EPA.
Staff Assistants to the Ombudsman are James Malcolm, Chemical Engineer; Arnold B.
Medbury, P.E., Mechanical Engineer; Larry 0. Tessier, P.E., Civil Engineer; and Thomas J.
Nakley, Civil Engineer.
TOLL-FREE HOTLINE SERVICE
The Ombudsman operates a toll-free hotline for the convenience of small businesses, trade
associations, and others seeking access to the Ombudsman. A member of the
Ombudsman's staff will answer between 8:30 AM and 4:30 PM EST. Message-recording
devices for calls during non-business hours and overload periods are provided. All calls are
personally handled on a fast turn-around basis.
The toll-free hotline number is:
• 800-368-5888
703-305-5938 (in DC area)
-------
Callers request information on a variety of topics including:
Clean Air Act regulations
Underground storage tank notification
Small quantity generator requirements
Effluent standard guidelines
Used oil
Asbestos compliance
Waste minimization/pollution prevention
Pesticide registration fees
Increases in the number of direct-dial calls and hotline calls (from 4,000 calls per year in the
early 1980s to the current level of 1,100 - 1,500 calls per month) and the associated
distribution of technical and informational literature, growth in requests for personal
appearances at conferences and workshops, and an expansion in participation in policy-
making activities are evidence of the customer groups' confidence in the integrity and
proactive stance of the SBO.
REGULATORY TRACKING AND ANALYSIS
,j
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 1996, the SBO reviewed and monitored 28
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 1996
The SBO's efforts to assist the small business community continue at a high level. Key
accomplishments and activities for 1996 (some of which are on-going) include:
• Hosted third National Small Business Ombudsman and Technical Assistance Program
Conference, which was attended by 44 states and 2 territories (162 participants).
Set plans for a fourth conference in early 1997.
• Developed external stakeholder guidance and acted as a principal participant in the
Agency's Fifth Regulatory Tiering (prioritizing) Process.
• Served as principal role player in the development of a new EPA policy offering
compliance initiatives to small businesses in all media (e.g., waste, water, toxics).
-------
Coordinated individual meetings and follow-up meetings among major small business
trade associations and the EPA Administrator, Deputy Administrator, and four
Assistant Administrators to discuss small business issues.
Developed small business regulatory impact studies for several small business trade
associations.
Participated as key player in the joint Small Business Administration and Office of
Management and Budget Regulatory Reform Initiative.
Developed, in cooperation with the University of Tennessee's Industrial Services
Center and the EPA Office of Air Quality Planning and Standards, a Fourth National
Satellite Teleconference on Wood Furniture Manufacturing, which was held in Fall
1996.
Initiated formal on-site environmental auditing/assessment education and training
program at the February 1996 National Small Business Ombudsman and Technical
Assistance Conference.
Developed, in cooperation with all State and Territorial Small Business Assistance
Programs, EPA's 1995 Small Business Ombudsman Report to Congress under the
1990 Clean Air Act Amendments.
Managing Small Business Regulatory Enforcement Fairness Act of 1996 Small
Business Entity Outreach Sub-group to implement Act requirements.
Conducted meeting for State Small Business Ombudsmen and Technical Assistance
Program "Steering Committee" with Assistant Administrator, Office of Air and
Radiation on small business issues and a "show and tell" for EPA, other Federal
agencies, and small business trade associations.
-------
APPENDIX C
FEDERAL SMALL BUSINESS
ASSISTANCE PROGRAM
-------
APPENDIX C
ERA'S FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM
The EPA provides technical guidance for the use of the states/territories in the implementation
of their programs. The Federal Small Business Technical Assistance Program (Federal SBAP)
is coordinated by the Information Transfer Group (ITG) of the Office of Air Quality Planning and
Standards (OAQPS). Other EPA programs participating in activities to assist the states include
the Office of Compliance and the Pollution Prevention Division.
ELECTRONIC ACCESS
The Federal SBAP is actively involved in expanding the use of electronic media as a tool for
access to EPA information by small businesses, state SBAPs, and the general public.
• The SBAP home page on the World Wide Web, part of the Technology Transfer
Network, provides access to EPA small business assistance information and materials.
Links to other small business-related sites are also provided. The SBAP home page
address is www.epa.gov/ttn/sbap.
• 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 an
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 in hard copy and electronic format so that states could
customize the guidebooks and reproduce as many as needed.
• Halogenated Solvent Cleaning (completed May 1995).
• Chromium Electroplating and Anodizing (completed May 1995).
• Wood Furniture (expected to be completed summer 1997).
Work has started on guidance for Potential-To-Emit (PTE), including a diskette-based application
to assist businesses with PTE calculations for their particular industry.
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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 expected to be broadcast in early 1998.
ANNUAL CONFERENCE
EPA holds an annual SBO/SBAP Conference, which is co-sponsored by OAQPS's Federal SBAP
and the EPA SBO, with participation by the Office of Compliance and the Pollution Prevention
Division. The majority of conference planning and presentations are carried out by the states.
The 1996 meeting was held in San Diego, CA, with 150 attendees from 44 states and 2
territories. Several small business trade associations also participated. The purpose of this
meeting is to:
• Facilitate implementation and operation of small business assistance programs.
• Interpret regulatory and policy developments affecting small businesses.
• Share EPA activities and programs to assist state SBAPs.
OTHER PARTNERSHIP ACTIVITIES
The Federal SBAP is working with staff from EPA's Office of Compliance and Pollution
Prevention Division to determine a strategy to encourage all of the various small business
assistance providers (i.e., SBAPs, Small Business Development Centers, pollution prevention
programs, Manufacturing Extension Programs, etc.) to coordinate efforts within their state.
This would provide small businesses with easier access to comprehensive business and
environmental assistance.
-------
APPENDIX D
SBTCP STATUS, BUDGETS, STAFFING
AND ORGANIZATION
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TABLE D-1
STATE SMALL BUSINESS ASSISTANCE PROGRAMS
KEY CONTACT LISTING
December 1997
STATE
OMBUDSMAN
SBAP
OTHER SBAP
ALABAMA
Blake Roper, Ombudsman
Administrative Division
Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
334-213-4308
334-213-4399
800-533-2336 (national)
James Moore
Air Division
Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
334-271-7861
334-271-7950 (F)
800-533-2336 (national)
Mike Sherman
Air Division
Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
334-271-7861
334-271-7950 (F)
800-533-2336 (national)
ALASKA
David Wigglesworth
Small Business Advocate
AKDEC
555 Cordova Street
Anchorage, AK 99501
907-269-7582
907-269-7600 (F)
800-510-2332 (state)
Scott Lytle
Small Business Assistance
AKDEC
555 Cordove Street
Anchorage, AK 99501
907-269-7571
907-269-7600 (F)
800-510-2332 (state)
ARIZONA
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)
Mary Bezaniuk
AZ DEQ - Complinace Assistance
3033 N. Central Avenue
Phoenix, AZ 85001
602-207-4871
602-207-4872 (F)
800-234-5677 x4871 (state)
ARIZONA -
Maricopa County
Richard Polito
Maricopa County SBEAP
1001 N. Central, Suite 200
Phoenix, AZ 85004
602-506-5102
602-506-6669 (F)
ARKANSAS
Robert Graham
Department of Pollution Control & Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
501-682-0708
501-682-0707
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
CALIFORNIA
James Schoning
Small Business Ombudsman
California EPA
Air Resources Board
2020 L Street
P.O. Box 2815
Sacramento, CA 95814
916-323-6791
916-323-2393 (F)
800-272-4572 (state)
Peter Venturini
California EPA
Air Resources Board
Stationary Source
2020 L Street
P.O. Box 2815
Sacramento, CA 95814
916-445-0650
916-327-7212 (F)
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)
CALIFORNIA -
South Coast
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 (national)
Natalia Porche
SCAQMD/SBAP
21865 E. Copley Drive
Diamond Bar, CA 91765
909-396-3218
909-396-3335 (F)
800-388-2121 (national)
COLORADO
Cathy Heald
Department of Public Health & Environment
Office of Customer Service
4300 Cherry Creek Drive, South
Denver, CO 80246
303-692-2034
303-691-1979 (F)
Nick Melliadis
Air Pollution Control Division
Department of Health
4300 Cherry Creek Drive, South
Denver, CO 80246
303-692-3175
303-782-5493 (F)
800-333-7798 (national)
Doug Ryder
Air Pollution Control Division
Department of Health
4300 Cherry Creek Drive, South
Denver, CO 80246
303-692-3175
303-782-5493 (F)
800-333-7798 (national)
CONNECTICUT
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)
Glen Daraskevich
Small Business Assistance
Department of Environmental Protection
Environmental Quality Division
79 Elm Street
Hartford. CT 06106-5127
860-424-3545
860-424-4063 (F)
800-760-7036 (state)
Kirsten Cohen
Small Business Assistance
Department of Environmental Protection
79 Elm Street
Hartford, CT 06106-5127
860-424-3548
860-424-4063 (F)
800-760-7036 (state)
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHCTSBAP
DELAWARE
George Petitgout
Small Business Ombudsman
DE DNRC
P.O. Box 1401
Dover, DE 19903
302-739-6400
302-739-6242 (F)
800-789-4599 (state)
Bob Barrish
DENREC
715 Grantham Lane
Newcastle, DE 19720
302-323-4542
302-323-4561 {F)
DISTRICT OF
COLUMBIA
Carol Baker
ERA/ARMD
2100 Martin Luther King Avenue, SE
Washington, DC 20020
202-645-6093 x3082
202-645-6102 (F)
Olivia Achuko
ERA/ARMD
2100 Martin Luther King Avenue, SE
Washington, DC 20020
202-645-6093x3071
202-645-6102 (F)
FLORIDA
Elsa Bishop
Small Business Ombudsman
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-0114
904-922-6979 (F)
800-722-7457 (state)
Currently dual role as SBAP Principal and
Small Business Ombudsman
Lorraine Clark
FL SBAP - MS5505
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-1344
904-922-6979 (F)
800-722-7457 (state)
GEORGIA
Marvin Lowry
GA SBAP
4244 International Parkway, Suite 120
Atlanta, GA 30354
404-363-7014
404-363-7100 (F)
Anita Dorsey-Word
GA SBAP
4244 International Parkway, Suite 136
Atlanta, GA 30354
404-362-4842
404-363-7100 (F)
Ron Mathier
GA SBAP
4244 International Parkway, Suite 120
Atlanta, GA 30354
404-363-7016
404-363-7100 (F)
HAWAII
Robert Tam
HI Department of Health
Clean Air Branch
919 Ala Moana Boulevard
Honolulu, HI 96814
808-586-4200
808-586-4359 IF)
Willie Nagamine
HI Department of Health
Clean Air Branch
P.O. Box 3378
Honolulu, HI 96801
808-586-4200
808-586-4359 (Fl
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
IDAHO
Doug McRoberts
ID DEQ/PL&E
Statehouse Mail
1410 North Hilton
Boise, ID 83706
208-373-0497
208-373-0169 (F)
Aviiit Ray
IDDEQ/PL&E
Statehouse Mail
1410 North Hilton
Boise, ID 83706
208-373-0298
208-373-0417 (F)
ILLINOIS
Donald Squires
Illinois EPA/DAPC
Small Business Ombudsman
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
217-785-1625
217-782-9039 (F)
800-372-1996 (state)
Mark Enstrom
Illinois Department of Commerce
and Community Affairs
520 East Adams
Springfield, IL 62701
217-524-0169
217-785-6328 (F)
800-252-3998 (state)
John Kelley
Illinois EPA
J.R. Thompson Center
100 West Randolph, Suite 11 -300
Chicago, IL 60601
312-814-6026
312-814-1825 (F)
INDIANA
Maggie McShane
IDEM/OBR
100 N. Senate
P.O. Box 6015
Indianapolis, IN 46206-6015
317-232-8598
317-233-6647 (F)
800-451-6027 (state)
Cheri Storms
IDEM/OPP & TA/VOC
100N. Senate, Room 1320
P.O. Box 6015
Indianapolis, IN 46206-6015
317-233-1641
317-233-5627 (F)
IOWA
Linda King
IA Department of Development
Small Business Liaison
200 E. Grand Street
Des Moines, IA 50309
515-242-4761
515-242-4749 (F)
800-358-5510 (state)
John Konefes
IA Waste Reduction Center
University of Northern Iowa
75 Biology Research Complex
Cedar Falls, IA 50614-0185
319-273-2079
319-273-2926 (F)
800-422-3109 (state)
Chris Klemesrud
Iowa Department of Natural Resources
Air Quality Bureau
7900 Hickman Avenue, Suite 1
Urbandale.lA 50322
515-281-6318
515-242-5094 (F)
KANSAS
Janet Neff
Environmental Ombudsman
Office of Pollution Prevention
KS DH&E
Forbes Field, Building 283
Topeka, KS 66620
913-296-0669
913-291-3266 (F)
800-357-6087 (national)
Frank Orzulak, Director
Continuing Education Building
University of Kansas
Lawrence, KS 66045
913-864-3978
913-864-5827 (F)
800-578-8898 (state)
Theresa Hodges
Pollution Prevention Director
KS DH&E
Forbes Field, Building 283
Topeka, KS 66620
913-296-6603
913-291-3266 (F)
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER S8AP
KENTUCKY
Rose Marie Wilmoth
Air Quality Representative
Office of Commissioner
Department of Environmental Protection
UReillyRoad
Frankfort, KY 40601
502-564-2150, x 128
502-564-4245 (F)
800-926-8111 (national)
Gregg C. Copley, Director
Kentucky Business Environmental
Assistance Program
Gatton College of Business and Economics
University of Kentucky
Lexington, KY 40506-0034
606-257-1131
606-323-1907 (F)
800-562-2327 (national)
Monica Hale-Kehrt
Division of Air Quality
KY DNR&EP
803 Schenkel Lane
Frankfort, KY 40601
502-573-3382
502-573-3787 (F)
LOUISIANA
Jim Friloux, Small Business Ombudsman
LA DEO
P.O. Box 82263
Baton Rouge, LA 70804
504-765-0735
504-765-0746 (F)
800-259-2890 (state)
Vic Tompkins
LA Department of Environmental
Quality (Air)
7290 Bluebonnet
P.O. Box 82135
Baton Rouge, LA 70884-2135
504-765-2453
504-765-0921 (F)
800-259-2890 (state)
Liz Santa
DEQ/AQD
P.O. Box 82135
Baton Rouge, LA 70884-2135
504-765-0169
504-765-0222 (F)
800-259-2890 (state)
MAINE
Ron Dyer
Department of Environmental Protection
Office of Innovation and Assistance
Station 17
State House
Augusta, ME 04333
207-287-4152
207-287-2814 (F)
800-789-9802 (state)
Brian Kavanah
Department of Environmental Protection
Office of Innovation and Assistance
Station 17
State House
Augusta, ME 04333
207-287-6188
207-287-2814 (F)
800-789-9802 (state)
Jim Brooks
Department of Environmental Protection
Bureau of Air Quality
Station 17
State House
Augusta, ME 04333
207-287-2437
207-287-7641 (F)
MARYLAND
John Mitchell
MD Department of the Environment
Office of Community Assistance
2500 Broening Highway
Baltimore, MD 21224
410-631-3003
410-631-3936 (F)
800-633-6101, x3003 (state)
Leslie Sipes
Environmental Permits Service Center
MD Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
410-631-3165
410-631-3896 (F)
800-433-1247 (national)
MASSACHUSETTS
George Frantz
Executive Office of Environmental Affairs
Office of Technical Assistance/#2109
100 Cambridge Street
Boston, MA 02202
617-727-3260x631
617-727-3827 (F)
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHCTSftAP
MICHIGAN
Dana Cole
Ml Jobs Commission
Victor Center, 4th Floor
201 N. Washington
Lansing, Ml 48913
517-335-1847
517-335-0198 (F)
Dave Fiedler
MDEQ Environmental Assistance Division
P.O. Box 30457
Lansing, Ml 48909
517-373-0607
517-335-4729 (F)
800-662-9278 (national)
MINNESOTA
Charlie Kennedy
MPCA/OEA
520 Lafayette Road
St. Paul, MN 55155-4194
612-297-8615
612-297-8324 (F)
800-985-4247 (state)
Troy Johnson
SBAP Coordinator
Air Quality Division
MN Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
612-296-7767
612-297-7709 (F)
800-657-3938 (state)
MISSISSIPPI
Jesse Thompson
Small Business Ombudsman
MSDEQ
P.O. Box 10385
Jackson, MS 39289-0385
601-961-5171
601-961-5742 (F)
800-725-6112 (national)
MISSOURI
Brad Ketcher
State of Missouri
Office of the Governor
P.O. Box 720
Jefferson City, MO 65102
573-751-3222
573-751-1495 (F)
Bvron Shaw, Jr.
DNR Technical Assistance Program
Jefferson State Office Building
Box 176
Jeff erson City. MO 65102
573-526-5352
573-526-5808 (F)
800-361-4827 (national)
MONTANA
Mark Lambrecht
Department of Environmental Quality
Small Business Ombudsman
1520 E. 6th Avenue
Helena, MT 59620
406-444-2960
406-444-6836 (F)
800-433-8773 (national)
Adel Johnson
Department of Environmental Quality
Air Quality Division
1520 E. 6th Avenue
Helena, MT 59620
406-444-4194
406-444-5275 (F)
800-433-8773 (national)
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TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
NEBRASKA
Dan Eddinger
Public Advocate
Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-3413
402-471-2909 (F)
Dan Eddinger
Dual Role as Ombudsman and SBAP
Principal
NEVADA
Marcia Manley
Small Business Ombudsman
NV Department of Environmental
Protection
333 West Nyle Lane
Carson City, NV 89710
702-687-4670, x3162
702-687-5856 (F)
800-992-0900. x4670 (state)
David Cowperthwaite
Small Business Program Manager
NV Department of Environmental
Protection
333 West Nyle Lane
Carson City, NV 89710
702-687-4670, x3118
702-687-5856 (F)
800-992-0900, x4670 (state)
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
Rudolph Cartier
Dual Role as Ombudsman and SBAP
Principal
Rudolph Cartier
Air Resources Division
Department of Environmental Services
64 North Main Street, 2nd Floor
Concord, NH 03301-2033
603-271-1379
603-271-1381 (F)
800-837-0656 (state)
NEW JERSEY
John Serkies
Office of Business Advocacy
Department of Commerce and Economic
Development
20 West State Street
CN823
Trenton, NJ 08625-0823
609-633-7308
609-777-3106 (F)
800-643-6090 (national)
Chuck McCarty
Pollution Prevention-Permit Coordinator
SBAP
NJDEPE
P.O. Box 423
Trenton, NJ 08625-0423
609-292-3600
609-777-1330 (F)
Jeanne Mroczko
Pollution Prevention-Permit Coordinator
SBAP
NJDEPE
P.O. Box 423
Trenton, NJ 08625-0423
609-292-3600
609-777-1330 (F)
NEW MEXICO
Robert Horwitz
NM ED/AQB
Harold Runnels Building
P.O. Box 26110
Santa Fe, NM 87502
505-827-9685
505-827-0045 (F)
800-810-7227 (national)
Cecilia Williams
NM ED/AQB
Harold Runnels Building
P.O. Box 26110
Santa Fe, NM 87502
505-827-0042
505-827-0045 (F)
800-810-7227 (national)
John Libretori
City of Albuquerque
EHD/APCD
P.O. Box 1293
Albuquerque, NM 87103
505-768-1964
505-768-2617 (F)
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TABLE D-1
(Continued)
• „•
STATE
.: : OMBUDSMAN
88AP
OTHCTSBAf
NEW YORK
TriaCase
Supervisor, Division of Small Business
Environmental Ombudsman Unit
Empire State Development, 32nd Floor
633 3rd Avenue
New York, NY 10017
212-803-2282
212-803-2309 (F)
800-782-8369. x157 (national)
Marian Mudar
Environmental Program Manager
NYS Environmental Faciliites Corporation
50 Wolf Road, Room 598
Albany, NY 12205
518-457-9135
518-485-8494 (F)
800-780-7227 (state only)
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)
NORTH CAROUNA
Edyth McKinney
Office of the Small Business Ombudsman
Department of Environment Health, and
Natural Resources
P.O. Box 29583
Raleigh, NC 27626
919-733-1267
919-715-6794 (F)
800-829-4841 (national)
Fin Johnson
Office of Small Business Ombudsman
Department of Environment, Health and
Natural Resources
P.O. Box 29583
Raleigh, NC 27626
919-733-0824
919-715-6794 (F)
800-829-4841 (national)
Karen Davis
Office of the Small Business Ombudsman
Department of Environment, Health, and
Natural Resources
P.O. Box 29583
Raleigh, NC 27604
919-733-1267
919-715-6794 (F)
800-829-4841 (national)
NORTH DAKOTA
Jeff Burgess
ND SDH&CL
P.O. Box 5520
Bismark, ND 58506
701-328-5153
701-328-5200 (F)
800-755-1625 (state)
Tom Bachman
ND SDH&CL
Division of Environmental Engineering
P.O. Box 5520
Bismark, ND 58506
701-328-5188
701-328-5200 (F)
800-765-1625 (state)
Dana Mount
ND SDH&CL
Division of Environmental Engineering
P.O. Box 5520
Bismark, ND 58506
701-328-5188
701-328-5200 (F)
800-755-1626 (state)
OHIO
Mark Shanahan
Clean Air Resource Center
50 West Broad Street, Room 1901
Columbus, OH 43215-5985
614-728-3540
614-752-9188 (F)
800-225-5051 (state)
Rick Carleski
Ohio EPA
Division of Air Pollution
1600 Watermark Drive
Columbus, OH 43215
614-728-1742
614-644-3681 (F)
Bob Hodanbosi
OEPA/DAPC
PO Box 1049
1600 Watermark Drive
Columbus, OH 43215
614-644-2270
614-644-3681 (F)
OKLAHOMA
Steve Thompson
Deputy Executive Director
Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-271-8056
405-271-8425 (Fl
Alwin Ning
Small Business Program
Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-271-1400
405-271-1317 (F)
Kyle Arthur
Small Business Program
Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-271-1400
405-271-1317 (F)
8
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER $8AJ»
OREGON
Paul Burnet
ORDEQ
811 SW 6th Avenue
Portland, OR 97204-1390
503-229-5776
503-229-6945 (F)
800-452-4011 (state)
Terry Obteshka
ORDEQ
Air Quality Division
811 SW 6th Avenue
Portland, OR 97204
503-229-6147
503-229-5675 (F)
800-452-4011 (state)
PENNSYLVANIA*
Greg Czarnecki
Office of P2 & Compliance Assistance
PADEP
RCSOB, 13th Floor
P.O. Box 8772
Harrisburg, PA 17105-8468
717-772-8951
717-783-2703 (F)
Scott Kepner
Bureau of Air Quality
PADEP
P.O. Box 8468
Harrisburg, PA 17105-8468
717-787-1663
717-772-2303 (F)
Cecily Beall
PRC Environmental Management, Inc.
1800 JFK Boulevard, 6th Floor
Philadelphia, PA 19103
215-656-8709
215-972-0484 (F)
800-722-4343 (national)
PUERTO RICO
Maria Rivera
PREQB - SBAP
IIC-91, Box 9197
VegaAlta,PR 00692-9607
787-767-8025, x296
787-756-5906 (F)
RHODE ISLAND
Roger Greene
Rl Department of Environmental
Management
235 Promenade Street
Providence, Rl 02908
401-277-2771
401-277-4546 (F)
Richard Enander, Technical Asst. Mgr.
Rl Department of Environmental
Management
235 Promenade Street
Providence, Rl 02908
401-277-6822, x4411
401-277-3810(F)
800-253-2674 (state)
Richard Girasole
Rl Department of Environmental
Management
Technical/Customer Assistance
235 Promenade Street
Providence, Rl 02908
401-277-6822, x4411
401-277-3810(F)
800-253-2674 (state)
SOUTH CAROLINA
Donna H. Gulledge, SBO
SC Department of Health & Environmental
Control
2600 Bull Street
Columbia, SC 29201
803-734-5909
803-734-9196 (F)
800-819-9001 (national)
Willie Morgan
Bureau of Air Quality Control
Department of Health & Environmental
Control
2600 Bull Street
Columbia, SC 29201
803-734-5179
803-734-9196 (F)
800-819-9001 (national!
-------
TABLE D-1
(Continued)
OMBUDSMAN
SBAP
OTHEKS8AP
SOUTH DAKOTA
Joe D. Nadenicek
Small Business Ombudsman
Department of Environment & Natural
Resources
Joe Foss Building
523 East Capitof
Pierre, SD 57501
605-773-3151
605-773-6035 (F)
800-438-3367 (state)
Bryan Gustafson
Department of Environment & Natural
Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501
605-^73-3351
605-773-6035 (F)
TENNESSEE
Ernest Blankenship
TN Department of Environment &
Conservation
L&C Tower, 8th Floor
401 Church Street
Nashville, TN 37243-1551
615-532-0731
615-532-0614 (F)
Linda Sadler
Small Business Assistance Program
L&C Annex, 8th Floor
401 Church Street
Nashville, TN 37243-1551
615-532-0779
615-532-0614 (F)
800-734-3619 (national)
TEXAS
Tamra Shae-Oatman
Small Business Advocate
TX NRCC
P.O. Box 13087
Austin, TX 78711-3087
512-239-1062
512-239-1065 (F)
800-447-2827 (national)
Kerry Drake
Manager, Technical Assistance Program
TX NRCC
P.O.Box 13087
Austin, TX 78711-3087
512-239-1112
512-239-1065 (F)
800-447-2827 (national)
UTAH
Stephanie Bernkopf
UT Department or Environmental Quality
Office of the Small Business Ombudsman
168 North 1950 West
Salt Lake City, UT 84114-4810
801-536-4479
801 -536-4099 (F)
Frances Bernards
UT Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
801-536-4056
801-536-4099 (F)
800-270-4440 (state)
Ron Reece, Environmental Engineer
UT Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
801-536-4091
801-536-4099 (F)
VERMONT
Judy Mirro
VT Environmental Assistance Division
Laundry Building
103 South Main Street
Waterbury, VT 05671
802-241-3745
802-241-3273 (F)
Kevin Bracey
VT APCD/ANR
Building 3 South
103 South Main Street
Waterbury, VT 05671
802-241-3841
802-241-2590 (F)
10
-------
TABLE D-1
(Continued)
STATE
OMBUDSMAN
SBAP
OTHER SBAP
VIRGINIA
John Daniel, Air Division Director
VA Department of Environmental Quality
P.O. Box10009
Richmond, VA 23240
804-698-4311
804-698-4510 (F)
800-592-5482 (state)
Richard Rasmussen
Manager, Small Business Assistance
Program
VA Department of Environmental Quality
P.O. Box 10009
Richmond, VA 23240
804-698-4394
804-698-4510 (F)
800-592-5482 (state)
VIRGIN ISLANDS
Dual role SBO/SBAP Principal.
Marylyn A. Stapleton
VI Department of Planning & Natural
Resources
Division of Environmental Protection
8000 Nisky Center, Suite 231
Charlotte Amalie, St. Thomas, VI 00802
340-777-4577
340-7 74-5416 (F)
WASHINGTON
Leighton Pratt
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
360-407-7018
360-407-6802 (F)
Bernard Brady
WA Department of Ecology
Air Quality Program
P.O. Box 48600
Olympia, WA 98504-7600
360-407-6803
360-407-6802 (F)
Judy Schwieters
WA Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia, WA 98504-7600
360-407-6804
360-407-6802 (F)
WEST VIRGINIA
Kenneth Shaw
Small Business Ombudsman
WV Office of Air Quality
1558 Washington Street, SE
Charleston, WV 25311
304-558-1218
304-558-1222 (F)
800-982-2474 (state)
Fred Durham
WV Office of Air Quality
1558 Washington Street, SE
Charleston. WV 25311
304-558-1217
304-558-1222 (F)
800-982-2474 (state)
Joe Ciccarello
WV Development Office/SBDC
950 Kanawha Boulevard, Suite 200
Charleston, WV 25311
304-558-2960
304-558-0127 (F)
800-982-2474 (state)
WISCONSIN
Hampton Rothwell
Small Business Ombudsman
Department of Development
Wl SBAP, 9th Floor
123 West Washington Avenue
Madison, Wl 53703
608-267-0313
608-267-0436 (F)
800-435-7287 (national)
Pam Christenson
Technical Assistance Director
Department of Commerce
Wl SBAP, 9th Floor
123 West Washington Avenue
Madison, Wl 53707
608-267-9214
608-267-0436 (F)
800-435-7287 (national)
Cliff Fleener
Department of Commerce
Wl SBAP, 9th Floor
123 West Washington Avenue
Madison, Wl 53707
608-264-6153
608-267-0436 (F)
800-435-7274 (national)
11
-------
TABLE D-1
(Continued)
WYOMING
Dan Clark
Department of Environmental Quality
OA/Small Business Ombudsman
122 W. 25th Street
Cheyenne, WY 82002
307-777-7388
307-777-3773 (F)
Charles Raffdson
Department of Environmental Quality
Division of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
307-777-7391
307-777-5616 (F)
Charles Collins
Department of Environmental Quality
Division of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
307-777-7391
307-777-5616 (F)
• Notes
PA SBO position vacant in 1996. Greg Czamecki appointed in 1997.
12
-------
TABLE D-Z
DATES OF ESTABLISHMENT AND COMMENCEMENT OF SBTCP OPERATIONS
•. % ::•.''•• ,'••,' '
STATE Oft
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Pima Ctv
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
MONTH & YEAR OF ESTABLISHMENT
SBO
5/93
6/95
1/93
N/R
N/R
11/93
10/92
6/89*
7/92
4/93
12/95
12/93
11/92
2/92
N/E
10/93
5/92
3/93
10/94
11/93
SBAP
7/94
6/95
1/93
1/95
1/93
11/93
before 1990
6/89*
7/92
4/93
12/95
1/94
11/92
11/92
N/E
4/94
9/92
1/95
10/92
3/94
CAP
N/E'
6/95
1/93
N/R
N/R
6/95
N/E
N/A
7/92
12/94
N/E
12/96
1/95
5/93
N/E
5/94
N/E'
7/95
N/E
12/93
MONTH
SBO
5/93
6/95
1/93
N/R
N/R
11/93
4/95
6/89
9/92
4/93
12/95
9/95
11/92
7/92
N/O
10/93
5/92
3/93
10/94
11/93
fc YEAH OPERATIONS BEGAN
SBAP
7/94
6/95
3/94
2/95
1/93
11/93
before 1 990
6/89
9/92
4/93
12/95
1/94
11/92
7/93
N/O
4/94
11/94
3/94
10/92
3/94
CAP
N/O
11/95
N/O
N/R
N/R
6/95
N/O
N/A
4/94
12/94
N/O
N/O
1/95
11/94
N/O
5/94
N/O
7/95
N/O
12/93
-------
TABLE D-2
(Continued)
STATE OR
TERRITORY
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
MONTH & YEAR OF ESTABLISHMENT
SBO
6/92 (parttime)
2/95 (fulltime)
8/95
11/92
10/93
4/94
N/E
10/95
4/92
7/93
8/92
12/93
9/92
1/95
11/94
3/93
10/92
4/92
1/93
SBAP
7/94
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
CAP
10/94
10/94
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
N/E
11/94
MONTH ft YEAR OPERATIONS BEGAN
SBO
6/92 (parttime)
2/95 (fulltime)
8/95
11/92
11/93
4/94
N/0
10/95
6/93
7/93
5/94
12/93
9/92
3/95
11/94
3/93
9/94
1/93
1/93
SBAP
10/94
Always provided
tech. asst. for
sm. bus.
11/92
4/94
4/94
9/93*
9/94
8/93
7/93
5/94
12/93
11/92
1/95
1/93
11/92
1/93
4/92
8/93
CAP
3/95
3/95
10/93
4/94
N/0
N/0
9/94
9/93
7/93
N/0*
3/94
7/93
1/96
3/96
N/0*
11/95
N/0
11/94
-------
TABLE D-2
(Continued)
STATE Oft
TERRITORY
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
US Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MONTH & YEAR OF ESTABLISHMENT
SBO
4/92
10/94
6/94
8/91
11/92
1/95*
5/95
8/93
11/93
1/93
2/92
1/94
N/E
8/92
1/93
Fall 92
4/94
4/92
3/92
SBAP
4/92
10/94
6/94
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
5/92
10/94
6/96
1/94
11/92
1/96
N/E
8/94
4/94
1/93
11/92
1/94
N/E
11/95
N/E
Summer 93
1/95
4/92
3/92
MONTH ft YEAR OPERATIONS BEGAN
SBO
4/92
12/94
10/94
1/92
5/93
1/95*
5/95
8/93
11/93
3/93
2/92
5/94
N/0
4/93
1/93
Fall 92
12/94
11/92
5/94
SBAP
4/92
4/95
10/94
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
6/93
1/96
6/96
11/94
4/93
3/96
N/O
8/94
4/94
N/O
11/92
6/95
N/O
11/95
N/O
Summer 93
3/95
8/94
5/95
-------
TABLE D-2
(Continued)
N/E Not established
N/0 Not operational
N/R No response
•Notes:
AL Not yet fully appointed.
CA SCAQMD SBO and SBAP combined.
IL 3 members appointed to date. No CAP meeting yet held.
MA 11192 SBAP date of establishment is date of MA SIP revision.
9/93 SBAP date of commencement of operations: although 507 SBAP did not formally begin until this time, multimedia technical
assistance to small business had been occurring for some time through OTA and some outreach elements at DEP. While the structure
of the Massachusetts program does not exactly mirror Section 507 program design, services have been provided on a free and
confidential basis by OTA as part of the Commonwealth's Toxics Use Reduction program. Business leaders (large and small) are
invited to meet every month with Trudy Coxe, Secretary of Environmental Affairs, the concerns are communicated to OTA and DEP
staff for appropriate response.
MO Only 2 members have been appointed as of January 1997.
NJ Became operational 1/97 (following this reporting period).
NV Manager of SBAP was established 1/95. However, a staff person who has been designated as SBAP Coordinator was not hired until
November 1996.
PR SBO resigned 1/96. No SBO assistance provided 1996.
Rl One FTE hired to staff SBAP 11/96. Up to that point, the Department's existing Pollution Prevention Program staff had been
responding to industry inquiries.
-------
TABLE D-3
1996 SBTCP BUDGET INFORMATION AND FUNDING SOURCES
STATE OR
TERRTTORY
Alabama
Alaska
Arizona
Maricopa
County
Pima
County
Arkansas
California
SCAQMD
BUDGET W
SBO
150,000-165,000
112,700
combined
FY97 (7/96-6/97)
1 65,000 combined
N/R
N/R
80,000
200,000
887,659
SBAP
Function
performed as part
of overall
permitting
program. No
specific budget
designated.
Combined
Combined
140,000
30,000
100,000
340,000
SBO/SBAP
combined
CAP
N/R
Combined
Combined
N/R
N/R
3,500
0
N/A»
SOURCE OF FUNDING
SBO
Federal air grant
funds, Title V fees,
surface water
grant funds, state
solid waste funds.
Federal RCRA
grant funds
Interagency
receipts: Funds
provided from
combination of
state general funds
and air permitting
fees transferred to
SBTCP
Air Quality Permit
fees (combined)
N/R
N/R
EPA allocation and
Title V fees
State Budget Act
29% from
emissions fees
C$225,000), 45%
from permit fees
C$400,000), 25%
from annual
operating fees
C$220,000), 1%
from subvention
funds C$8.000)
SBAP
Title V fees/permit
fees
Same
Same
General permit
fees
Title V and general
fund
EPA allocation and
Title V fees
State Budget Act
SBO/SBAP
combined
-
CAP
N/R
Same
Same
N/R
N/R
EPA allocation
and Title V fees
State Budget Act
N/R
-------
TABLE D-3
(Continued)
,
STATE OR
TERRITORY
Colorado
Connecticut
District of
Columbia
Florida
Idaho
Illinois
Indiana
Iowa
BUDGETS)
SBO
90,000
325,000
(combined)
80.000
5,000 (salary)
Funded under
SBAP
65.000
N/R
65,000
75.000
150,000
74,500 plus
1 0,000 for special
oroiect
SBAP
120,000
Combined
8,000 (salary)
158,000
115.000
N/R
30,000
255.000
700,000
310,000
CAP
0
Combined
N/R
Funded under
SBAP
10,000
N/R
5,000
0
3,000
N/A
SOURCE OF FUNOWG
880
CO Dept. of Public
Health and
Env./CDPHE, Air
Pollution Control
Div., stationary
sources (permitting
and annual fees)
State fund that
supports Clean Air
Act-vehicle
registration fees.
Title V fees for
costs related to
Title V permitting
activities
Title V fees
Air grant
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
General
revenues/Title V
fees
Title V fees
SBAP
Same
Same
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees, 105
funding
Title V fees
General
revenues/Title V
fees/enforcement
fines
Department of
Natural Resources
CA"
0
Same
Title V fees
N/R
Title V fees
Title V fees
Title V fees
Title V fees
N/A
Legislative
Service Agency
N/A
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Kansas
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
BUDGETS)
8BO
125,000
107,000
50,000
N/R
40,000
0
N/A
100,000
(FY 95-96)
71,000(FY97)
150,000
50,000
130,000
106,000
(combined)
SBAP
340,000
250,000
80,000
400,000
75,000
61,000
51,000
470,000
(FY 95-96)
31 6,000 (FY97)
150,000
415,000
Combined w/SBO
N/R
CAP
No budget, travel
expenses only
2,000
2,000
0
As needed
(negligible)
N/A
N/A
\
0
1,000(FY97)
5,000
12,000
1,000
N/R
SOURCE OF FUNDING
SBC
Air fee funds
Title V fees
EPA 105 Grant
and general funds
Operating budget
of existing
programs
Toxic Use
Reduction Program
fees
N/A
N/A
State & county
fees, restricted
funds
Air fees, 1 05 grant
Title V fees
Title V fees and
other fees
Air Quality Permit
fees
Title V fees
SBAP
Air fee funds
Title V fees
EPA 105 Grant
and general funds
240,000 = 105
grant
160,000= self-
generated
Title V fees
Maryland
Department of the
Environment funds
Toxics Use
Reduction Act
program
State & county
fees, restricted
funds
Air fees, 1 05
grant. Leadership
grant
Title V fees
Title V fees and
general revenue
Same
Same
CAP
N/R
Title V fees
N/R
N/A
Toxic Use
Reduction
Program fees
N/A
N/A
Unfunded
Air fees, 1 05
grant
Title V fees
Title V fees
Same
N/R
-------
TABLE D-3
(Continued)
',-, ' •• i\ ' ' '>•
"'I STATIC*
TERRITORY
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
BUDGETS)
: wo
52,500*
25.000
80,000
10,000
1,170.000
324,000 (SBO &
SBAP combined)
30.000
175,000
10,000
31,756
185,000(41,000
actual)*
0
70,000
35,000
25,000
900,000 (SBO &
SBAP)
.' -... .SBAP. ,.
52,500 •
75,000
80,000
205,000
1,000,000
SBO & SBAP
combined
30.000
323,000
120,000
86,430
460,000
228,000
90,000
85,000
10,000
Combined w/SBO
CAP
3,000*
Included in SBAP
1,500
< 1,000
N/R
5,000
1.000
Combined w/SBAP
Combined w/SBAP
2,120
10,000
0
0
1,500
5,000
Combined w/SBO
SOURCE OF FUNDWG
S8O
Indirect cost pool
Emission fees
Title V fees
Title V fees, other
state funds
NY Clean Air
Fund/Title V fees
Title V fees
Title V fees
Title V fees,
OAQDA funds
Agency indirect
costs
Title V fees
Title V fees
Title V fees
State Hard-to-
dispose material
account
Title V fees
Title V fees
Title V fees
SBAP
Indirect cost pool
Emission fees
Title V fees* 105
Air Grant
Title V fees, other
state funds, grants
Same
Title V fees
Title V fees
Title V fees
Title V fees, EPA
Leadership grant
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
Title V fees
CAP
Air Quality
Management
fund*
N/R
Title V fees
Title V fees, other
state funds
N/R
Title V fees
Title V fees
Title V fees
N/A
Title V fees
Title V fees
Title V fees
N/A
Title V fees
Title V fees
Title V fees
-------
TABLE D-3
(Continued)
STATE OR
TERRITORY
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
BUDGET!*)
SBO
1,260,000
(combined and for
fiscal year)
85,000
Did not exist
10,000
N/R
40,000
55,000
15,000
25,000
SBAP
Combined
210,000
Not budgeted for
'96
180,000
55,000
225,000
100,000
117,000
75,000
CAP
Combined
5,000
Did not exist
5,000
N/R
5,000
5,000
3,000
10,000
SOURCE Of FUNDING
SBO
1,191,648 = 151
funds
68,352 = 102
grant funds
Title V fees, Utah
"Air Fair" grant,
EPA "Partnership
for Compliance"
grant
N/R
General funds
N/R
Title V fees
Title V fees &
Agency penalties
General purpose
revenue
Title V fees
SBAP
Same
Title V fees, EPA
"Partnership for
Compliance" grant
State
Federal trust,
permit fees, and
general fund
C$50,000 from
EPA Leadership
Grant)
Title V fees
200,000= Title V
fees
25,000 = SBAP
grant
Title V fees &
Agency penalties
Program revenue
(permit fees)
Title V fees
CAP
Same
Title V fees
N/R
General funds,
permit fees
N/R
Title V fees
Agency penalties
(expense
reimbursement
only; actual yearly
expenses less
than 1,000)
Program revenue
(permit fees)
Title V fees
N/R No response
N/A Not applicable
-------
TABLE D-3
(Continued)
•Notes:
CA SCAQMD Governing Board recommended the creation of a Local Government and Small Business Assistance Committee, which will not be in
effect until sometime in the 1997-98 fiscal year.
NV Funding for state program only. Clark County Health District, Air Quality Program and Washoe County Health Department, Air Quality Program do
have people in their compliance and permitting branches respectively that provide assistance to small businesses. However, these programs are
not formal ones. NDEP does not have access to information regarding expenditures from these two entities.
Air Quality Management fund is funded through air quality permit fees.
PA SBO position has been vacant since 4/96. The SBO is being relocated from the Department of Community and Economic Development to the
Department of Environmental Protection. There has not been a decrease in funding, but the funds have not been spent due to the vacancy.
EPA 106 grants are provided for in the CAAA. Section 106. Funding ii distributed to the ttatet through the EPA regional office*.
Leadership grant* (Research and Development grant* to the ttatee) flow from EPA'* Office of Retearch and Development through the Innovative Technology Control Program. Funding comea
from the President'* Environmental Technology Initiative (ETI).
-------
TABLE D-4
COMPARISON OF 1995, 1996, AND 1997 BUDGETS
and
DESCRIPTIONS OF SIGNIFICANT FUNDING CHANGES
•TATKM
fBRMICmv
Alebem*
Al**k*
Arisen*
M*ricop* County
Plm* County
ArkeneM
Celtforni*
SCAOMD
Colored*
Connecticut
D*l*w*r*
&SSJS
Florid*
Qaoroi*
Heweli
Ideho
Illinoi*
Indian*
low*
Ken***
Kentucky
Jiffenan Ctv
•MM
WO
160.000
192,000
(cocnb into j
FY98)
1 66.OOO
N/R
N/R
76.000
200.000
mo.
90.0OO
326.000
80,000
(combined!
N/R
Combined
66,000
Did not
wcM
66.000
66,000
160.000
74.600
126.000
10.000
4O.OOO
KTMftttMN
WA*-
60,000
Combined
Combined
120.0OO
90.000
90.000
140.000
S8O/S8AP
120.000
Contwnod
Combined
20.000
160.000
100.000
Did not
•xtt
30.0OO
190.000
700,000
232,600
340,000
260.OOO
BO.OOO
CAP
N/R
Combined
Combined
N/R
N/R
2.000
0
N/R
0
Combined
N/A
0
ContbtntM
7.000
Old not
exiet
6.000
N/R
3.000
N/A
Trcvel only
400
40O
TOTAL
200,000
192,600
1 66.OOO
120.000
90.000
167.000
640.000
963,383
21O.OOO
326,000
80,000
20.000
160.000
162.OOO
0
1OO.OOO
246.000
863.0OO
307,000
466,000
260.400
12O.4OO
TUJBOit -EOJI tVM MPQPRW4} MM00 181
WO
160.000-
166.000
112.700
(combined;
FY87I
1 66.OOO
N/R
N/R
BO.OOO
200.000
SftSIn
90.000
326.000
(combined)
6.000
Combined
66.000
N/R
66,000
76.000
160,000
74,600 < +
10.0OO for
•p*ti*l
project)
126,000
90.OOO
BO.OOO
WAP> 1 Off I TOTAL
' " '
Combined
Combined
140.000
30.000
100.0OO
340.000
SBO/SBAP
1 20.0OO
Combined
CofTtbtnM
8,000
168.000
116,000
N/R
30,000
266.000
700.000
310.000
340,000
260.000
BO.OOO
.
N/R
Combined
Combined
N/R
N/R
3.600
0
N/R
0
Combined
Combined
N/R
Combined
1OO.OOO
N/R
6,000
N/R
3,000
N/A
Travel only
2.OOO
2.OOO
160,000-
1 66.0OO
112,700
1 66.OOO
140,000
30.000
183.600
640.000
887,669
210.000
326,000
80,000
13,000
168.000
190.0OO
100,000
330.000
863.000
394,600
466,000
342,000
1 33.OOO
MMV
WO
166,000
116,100
(combined;
FY98)
1 66.OOO
N/R
N/R
86.OOO
200.000
WVffi
90.OOO
326,000
80,000
6,000
N/R
66.000
N/R
66.000
76.000
160.000
84,600
126.000
107.0OO
BOOOO
rfWfMTMKKfMaMWM
WAT r c*» '
..Jim flT L ^
164,000
COflmffWCt
Combined
140,000
30.000
100.000
340,000
880/SBAP
COOWVleM
120.000
Combined
Combined
8,000
171,000
116.000
N/R
30 ,OOO
400.000
70O.OOO
3 10.0OO
340,000
26O.OOO
BO.OOO
N/R
COfTmnWQ
Combined
N/R
N/R
3.000
6.000
Combined
0
Combined
Combined
6,000
N/R
10.000
N/R
6.000
10,000
3,000
N/A
Tr«v*l only
2,000
2.OOO
Ml
TOTAL
330,000
118,100
166.000
140.000
30.000
1 88.OOO
646.000
1.434,000
2 10.0OO
326.000
80,000
18,000
171.000
190.000
100.000
486.000
863.000
394,600
466,000
369.000
132.OOO
-------
TABLE D-4
(Continued)
fi£ft%
-
IMMM
Main*
Maryland
Maaaachuaatla
M,**n
Mkmaaata
MIlllMlPCl
Mieoourl
Montana
N**.*.
Nevada
N~Hamp-*o
NowJeroov
NawMaidco
Now York
North Carolina
North Dakota
Ohio
Oklahoma
Orooon
Parmaylvania
Puerto Rico
Rhod.W.nd
wm
MO
60.000
40.000
0
N/A
•0.000
(FY84-86)
84ft?
160.000
46.000
130.000
106.000
•2.600
26,000
40.OOO
10.000
1.170.OOO
320,000
Ik*
3O.OOO
1 86.OOO
10.000
30.863
1 86,000
26,000
84 B38
KTMftttMW
MM*
76.000
2OO.OOO
0»
466.000
(FY844S)
ffitf°
160.000
280.0OO
Combined
w/MO
N/R
•2.600
76,000
80.000
206.000
•26.0OO
SBOk
30.000
lae.ooo
116.000
173.676
460.000
1OO.OOO
42268
PQftyWO f9M
CA»
Noohanoa
Aar—"
N/A
N/A
0
MB.
6,000
10.000
1,000
N/R
3.0OO
Combined
w/SBAP
0
<1.0OO
N/R
6,000
0
O
Cofnunsd
w/SBAP
1.600
10.000
10.OOO
O
•Mi
TOTM.
Unknown
116.000
200.000
0
646,000
304,000
306,000
346.000
131.OOO
106.00O
108.000
100.000
120.000
216.000
2.086.000
326.000
60.000
380.OOO
126.OOO
206,138
666.0OO
1 36.OOO
1O7 1B8
WO
MO
N/R
40.000
0
N/A
1 0O.OOO
(FY86-86)
WB?
160.000
60.000
130.0OO
106.000
62.600
26.OOO
80.000
10.000
1.170.000
324.000
jSBdfc
cofnbintM)
30.000
176.000
10.000
31.766
186.000
141.000
0
7OOOO
MTfOKMMI
•H«f
400.000
76.000
61.000
61.000
47O.OOO
IFY86-86I
?rV".9?°
160.OOO
416.OOO
CamMnad
w/SBO
N/R
62.6OO
76.000
80.000
206.OOO
1 .OOO.OOO
SBO&
SBAf. ___,
combaiad
3O.OOO
323.OOO
1 2O.OOO
86.430
46O.OOO
228.00O
BO OOO
VOWIVJMIHMM
e*r
0
A* needed
N/A
N/A
0
m
6,000
12,000
1,000
urn
3.OOO
Combined
w/SBAP
1.6OO
< 1.OOO
N/R
6.0OO
1.000
N/R
Combined
w/SBAP
2.120
10.000
0
O
DIM
TOTM,
4OO.OOO
116.OOO
61.000
61.000
670.000
368.000
306.000
477.00O
131, OOO
106.000
1O8.000
100,000
161.6OO
216.000
2.170.OOO
328,000
• 1.000
488.OOO
130,000
120.306
61 1.OOO
228.0OO
ISO OOO
MflMH
MO
Unknown
40.000
0
N/A
100.000
IFY86-87I
71.000IFY88)
160.000
N/R
130.OOO
106.000
•2.600
26,000
80.000
10.000
1.170.OOO
32|jOOO HBO
30.000
226.000
10.OOO
32.660
1 9O.OOO
16.000
7E.OOO .
r*0K1M7M*<
MAP
400.000
76.000
•1.000
1
467.000
(FY86-87)
146.000
16O.OOO
N/R
CajiWnad
w/MO
N/R
•2.600
76.000
80.000
206.000
1.000.000
BL
30.000
40O.OOO
116.000
88.680
6OO.OOO
188.000
1 43.OOO
MfWttNMO
CAf
0
0
N/A
0
i^l
6.OOO
N/R
1.000
N/R
3.000
Combined
w/SBAP
1.6OO
< 1,000
N/R
6.000
1.000
N/R
Cofnbifwd
w/SBAP
2.176
1O.OOO
10.000
O
W»
TOTAL
Unknown
116.000
• 1.000
Ineurt.
667,000
218,000
306.000
N/R
131.000
106.000
108.000
1OO.OOO
161.600
216.000
2.270.000
334.000
61.000
626.OOO
126.000
123.316
700.000
223.000
218.0OO
-------
TABLE D-4
(Continued)
•TATC04I
IBrMHMV
South Cerofine
South Dekote
Tenr-"—
Texee
Utah
Vermont
Virginie*
Virgin Wend*
\rVMhinBton
WeetViraMe
Wcon*.
inrVOfnino
:»MN
M9
36.000
26.000
9OO.OOO
1.470,000
S8AP1. CAP
jujmthl— '-
cofitDinvQ,
fiecelYeer)
120.000
Did not
exirt
2O.OOO
0
4O.OOO
60.000
16.000
26.OOO
**A»
K.OOO
10.000
Combined
Coffibtntd
136,000
Did not
exist
1 66.00O
N/R
226.OOO
70.0OO
117.000
76.000
«*»
1.600
6.000
tractive
Combined
6.000
Did not
exist
6.OOO
0
6.OOO
6.OOO
3.000
1O.OOO
TOT«.
121.6OO
40.000
•OO.OOO
1,470,000
260.OOO
0
180.000
0
270.OOO
126.OOO
136.000
110,000
•uoatT TOM **M MMKTMM rmo
mo
36.00O
26.000
•OO.OOO
1.2W.OOO
(SBO. S8AP.
CAP
combined;
fiecelveer)
86.000
Did not exist
10.000
N/R
40.OOO
66.OOO
16.000
26.OOO
.**»•
•6.000
10.000
Combined
Conwined
210.000
Not
budgeted
1BO.OOO
66,000
226.OOO
1 0O.OOO
117.0OO
76.OOO
««r
1.600
6,000
Combiiiod
Cofnomod
6.000
Did not exist
6.0OO
N/R
6.000
6.0OO
3.000
10.OOO
O(*i
TOTM,
121.600
40,000
•OO.OOO
1 .260,000
300,000
0
1*6.000
66.000
270.000
1*0.000
136.000
110,000
MO
36.000
26.000
•00.000
1,037.604
116.000
Unknown
10.000
Unknown
4O.OOO
•O.OOO
16.000
26.000
ri9K1MTMera*tTHMKMO«(*)
mtf
•6.000
10,000
Conwinvd
N/R
267.600
6O.OOO
20O.OOO
06,000
20O.OOO
16O.OOO
117.000
76.OOO
CAT
1.6OO
6.000
ContbinMi
N/R
6.000
Unknown
6.000
6.000
6.000
6.000
3.000
10.OOO
TOTM
121.600
40.000
•OO.OOO
1,037,604
377,000
60,000
216.000
70.000
246.000
216.000
136.000
11 O.OOO
N/R No response
N/A Not applicable
*Notes:
MA
No separate budget existed, but actual expenditures were higher, due to more resources dedicated to the program (1.25 FTE in 1995
vs. O.SFTEin 1996).
VA 1995 budget amount of $310,000 entered in last year's report was in error. Calendar year budget amounts are based on fiscal year
budgets July 1 through June 30 for the previous year (i.e., calendar year 1995 = FY 1996 budget).
-------
TABLE D-4
(Continued)
Significant changes (more than 10%) in the level of funding between the 1995, 1996, and 1997 annual budget periods are described below.
STATE
Alabama
Alaska
Maricopa Cty
Pima Cty
Arkansas
California -
SCAQMD
Colorado
Connecticut
District of
Columbia
Georgia
Illinois
Iowa
Louisiana
DESCRIPTION OF SIGNIFICANT BUDGET CHANGES
The significant change indicated in the SBAP budget was due to a better estimation of the actual FTEs of effort expended doing
small business assistance. The 1 995 estimate was 1.0 FTE versus a 3.4 FTE estimate for the 1997 budget. The difference in the
SBO budget was due simply to staff salary increases.
SBTCP budget reduced 41 percent for FY97 due to reductions in anticipated program receipts (air permitting fees) due to delays in
receiving Title V program approval.
Increase was used to expand services, provide P2 guides, marketing, workshops, and home page enhancements to increase the
number of businesses helped.
County appropriations to the Business Assistance Program, including funds to cover assistance regarding hazardous materials and
waste generated from a landfill tipping fee, were cut.
Operate with a Leadership Grant Award, Title V fees and two professional services contracts with Henderson State University and
University of Arkansas.
Small Business Assistance Office is being loaned an office assistant (during FY 96-97). This position will be transferred to the Small
Business Office at the end of June 1 997, resulting in an increase to the 1 997-98 fiscal year budget. Also, $50,000 is being added
to the 1 997-98 budget to increase business outreach.
Effective June 30, 1 997, the Small Business Ombudsman Office will no longer be located in the Office of Regulatory Reform. Senate
Bill 96-1307 requires the function of the ombudsman to move to the Department of Public Health and Environment.
Program funding has remained constant at $325,000. 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 the level of funding has
remained constant, existing available resources have been shifted within the Bureau of Air Management to provide additional
program support as necessary.
More responsibilities have been added to SBAP that drastically reduced her involvement with SBAP activities.
The addition of a second engineer to the small business program resulted in an increase in the SBAP's budget.
The budget has grown as the program jumped to 5 FTE. The funding source became CAAA Title V permit fees, and outreach
activities have increased.
Increased funding to add staff and equipment. Additional funding to hire a consultant to conduct an educational outreach study.
Expect increased costs associated with implementation of this plan and designing a web page.
SBO-unknown, new administration. SBAP-no chanae. CAP-no chanae.
-------
TABLE D-4
(Continued)
STATE
DESCRIPTION Of SIGNIFICANT BUDGET CHANGES
Maryland
For the first half of 1995, the SBAP was funded for three engineers and a dedicated secretary. As a result of Maryland Department
of the Environment's reorganization, the program was reduced to one engineer and 15% of a secretary. Also, the scope of the
program was changed from air-only assistance to multimedia assistance. The funding was moved from the Air and Radiation
Management Administration to the indirect funds from the Office of the Secretary. The program is expected to remain the same for
1997.
Massachusetts
In the 1995 SBAP Annual Report, we listed 1.75 FTEs for the SBTCP activity; this year, we have 0.8 FTE. The reduction is based on
the need to devote resources to other specific projects, such as the Massachusetts Printers Partnership (MP2) and the Environmental
Results Project (ERP). We have attempted to include in each of these projects the essential support for small business entities.
MA Department of Environmental Protection reports that fewer than expected Title V permits were written, due in part to many
companies filing for Restricted Emission Status (FESOP program). In addition, our programs have been multimedia since inception.
As with some other states, there has been some reluctance to establish a single media program.
Minnesota
Previous numbers (fiscal 95 and 96) may have not indicated indirect budget information. Increase in fiscal 96 and 97 due to EPA
Leadership grant for 2-year wood finishing project ($170,000).
Missouri
SBAP: Funding constraints were removed, which allowed two vacancies to be filled.
Nevada
No significant changes in budgets at SBAP level. However, some additions to the budget will be made to incorporate the salary for
the newly hired Technical Assistance Coordinator.
North Carolina
During 1996, the Environmental Permit Information Center was started under the Small Business Ombudsman and funds were spent
for office space, furniture, and equipment to open this office. This start up expense will not reoccur in 1997.
Ohio
SBAP hired one additional FTE in June 1996 and new budgets reflect one additional staff member. Both SBO and SBAP operated at
lower than expected levels due to lower than expected revenues from Title V fees.
Oregon
During 1996, the SBAP was comprised of 1.35 FTE (one FTE less than 1995). The program is expected to continue with 1.35 FTE in
1997. This position was reassigned in the Air Quality Division and is involved with special educational projects. The $86,430
annual budget reduction will be partially offset by an EPA grant awarded to Region X SBAPs. Oregon's share of the $200,000
($150,000 Leadership + $50,000 105 Grant) is $25,000 for 1996 and 1997, $50,000 total. This money is funding special projects
through the Pacific Northwest Pollution Prevention Resource Center is Seattle, WA. No other staff additions and reductions of
revenue are anticipated during the 1996 and 1997 budgetary cycles.
Pennsylvania
The SBO position has been vacant since 4/96. The SBO is being relocated from the Department of Community and Economic
Development to the Department of Environmental Protection. There has not been a decrease in funding, but the funds have not been
spent due to the vacancy.
Puerto Rico
Salaries have been raised to staff since June 1996.
Rhode Island
SBO-More than 10% increase attributed to rounding budget to nearest $5,000.
SBAP-lncrease due to hiring of a full-time Environmental Planner and a Principal Environmental Planner (to be hired; 75% of total
annual budget) to coordinate SBAP functions. $53,887 also included for University of Rhode Island Center for Pollution Prevention
support work.
-------
TABLE D-4
(Continued)
STATE
DESCRIPTION OF SIGNIFICANT ftODGET CHANGES
Texas
Loss of 102 grant funds.
Utah
Voluntary Assistance Program position (courtesy inspector) transferred from SBO office to SBAP, which accounts for drop in SBO
expenses in 1996 (as well as increase to SBAP budget). Also, EPA 'Partnership for Compliance* funds of $150,000 incorporated
into budget: $10.000 for FY95; $43.500 for FY96: and $96.500 for FY97.
Vermont
In December 1996, a full-time employee was hired as the Small Business Compliance Advisory Program Engineer. This marks the
first time a full-time employee has been hired specifically to assist small businesses. The estimated budget for this position for 1997
is $50,000. This also marks the first time that money has been allocated from the state to run this program.
Virginia
There are several reasons for the decline in the budget for SBO/SBAP.
1) SBAP budget declined from FY95 through FY97 primarily due to a leveling of costs to maintain the air programs as a result of EPA
non-approval of Title V. Virginia's enabling legislation for Title V fees precluded DEQ from collecting those fees until EPA approved
the Virginia Title V program. That approval is now imminent and we should be able to begin collecting fees beginning July 1, 1997.
Once permitting resources are addressed, it may be possible to devote more resources to SBO/SBAP.
2) Concurrently, there was a reduction of $20,000 in federal 105 grant funds from FY95 to FY96, which could not be replaced by
fees.
3) FY94-96 biennium budget proved not to be an accurate reflection of the program expenses and resources. The budget was again
restructured when the agency went to a unit budget concept for FY96-98 biennium budget and adjusted at the biennium midyear to
more accurately reflect expenditures to budgeted revenues.
West Virginia
The SBO significantly has increased participation in trade shows and professional organizational events. This has raised travel and
display costs. The SBAP has substantially increased on-site visits and compliance audits. Also, have participated in more
multimedia training workshops. Projected increase in 1997 due to dedication more resources for developing general permits.
-------
TABLE D-5
STAFFING INFORMATION
A summary of the number of full time equivalents (FTEs) that support the SBO function and SBAP function are shown in Table
D-5. With respect to the SBAP, the number of paid and unpaid staff are shown separately. The utilization of retired engineers
to serve the SBAP also is indicated.
STATE OR TERRITORY
Alabama
Alaska
Arizona
Maricopa County
Pima County
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
SBO FUNCTION (NO. FTEs)
SBO
3.0
1.0
0.25
N/R
N/R
1.0
5.0
+
6.0
1.5
3.0
1.0
0.20
SBO/SBAP
combined
0.5
1.0
1.0
OTHER STAFF
N/R
0.25
N/R
N/R
N/R
5.0
3.0
+
1.0
N/R
0
0
0
N/R
0.5
1.0
N/R .
SBAP FUNCTION (NO. Flic)
ALL STAFF
3.4
1.5
2.25
3.0
1.0
6.0
20.0
2.0
2.0
1.0*
1.0
0.25
4.0
2.5
2.0
1.0
PAID
3.4
1.5
2.25
3.0
1.0
6.0
20.0
2.0
2.0
0
0
0.25
4.0
2.5
2.0
1.0
UNPAID
N/R
0
0
N/R
N/R
0
N/R
0
0
0
0
0
0
0
N/R
0
RETIRED
ENGINEERS
0
0
0
0
0
3.0
0
0
0
0
0
0
0
1.0
0
0
-------
TABLE D-5
(Continued)
STATE Oft TfRRITORY
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
SBO FUNCTION (NO. FTEtf
SBO
1.5
2.0
1.0
1.0
1.5
1.0
0.25
1.0
0.1
N/A
1.0
1.0
2.75
1.0
1.0
1.0
1.0
0.25
1.0
OTHER STAFF
0
0.25
0.5
1.0
0
0
0
0
0
N/A
0
0
N/R
0
N/R
0
0
N/R
0
SBAP FUNCTION (NO. FTEs)
ALL STAFF
5.0
12.0
5.0
3.5
3.0
2.0
11.0
1.0
1.1
0.8
5.0
3.0
6.5
8.0
1.0
1.0
1.0
0.75
1.0
PAID
5.0
0
5.0
3.5
3.0
2.0
11.0
1.0
1.1
0.8
5.0
3.0
6.5
8.0
N/A
N/A
1.0
0.75
1.0
UNPAID
0
0
0
0
N/R
0
0
0
0
N/A
0
0
N/R
0
N/A
N/R
0
0
0
RETWED
ENGINEERS
0
0
0
0
0
0
0
0
0
N/A
0
0
3.0
0
N/A
N/A
0
N/A
0
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washinoton
SBO FUNCTION (NO, FTEs)
SBO
0.5
4.0
1.5
0.5
0.5
0.1
0.15
1.0"
N/A
1.0
1.0
0.5
2.0
19.5
1.0
0
0.10
1.0
0.5
OTHER STAFF
0
1.0
0
0
1.2
0
0.20
0.75
N/R
N/R
N/R
0
0
N/R
*
0
0.90
N/R
0
SBAP FUNCTION (NO. FTEs)
ALL STAFF
4.5
7.0
2.5
0.5'
4.0
3.2
1.35
4.5
10.0
1.5
1.8
0.14
6.0*
N/R
2.5
1.2
2.5*
1.0
2.5
PAID
4.5
7.0
2.5
0.5
4.0
3.2
1.35
4.5
10.0
1.5
1.8
0.14
6.0*
19.5
2.5
1.2
2.5
1.0
2.5
UNPAID
0
0
0
0
0
N/R
0
0
0
0
0
0
0
N/R
0
0
0
0
0
RETIRED
ENGINEERS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-------
TABLE D-5
(Continued)
STATE OR TERRITORY
West Virginia
Wisconsin
Wyoming*
SBO FUNCTION (NO, FTEtf
SBO
1.0
0.5
0.5
OTHER STAFF
0.2
3.0
0
SBAPFUNCT
AU. STAFF
1.7
2.1
1.0
PAID
1.7
2.5
1.0
ION (NO. FTE»)
UNPAID
0
0
0
RCHR6D-
ENGINEERS
0
0
0
N/R No response
N/A Not applicable
•Notes:
CT
NO
PA
TN
UT
VA
The program leverages technical staff from the Engineering and Enforcement Division to provide additional staff support on specific
projects or initiatives. Leveraging additional resources is critical to the operation of the program and to ensure the delivery of quality
technical assistance.
Includes only Air Pollution staff, not other media program assistance, which is not funded by Title V fees. For the purpose of this
report, assistance activities by media programs (waste management and water pollution control) other than air have not been included
throughout the report.
Position vacant since 4/96.
Six positions filled and 6 vacant positions in budget.
Part-time temporary for newsletter production.
2.5 FTE includes 1.0 FTE for SBAP Leadership Grant; 0.3 FTE from Office of Small Business Assistance Air Toxics Section's 2
engineers providing SBAP outreach and compliance assistance for MACT; and 0.2 FTE considered as SBAP from SBAP Permit Engineer
Liaisons, who function in an ad-hoc, on-request manner in the six DEQ regional offices.
WY For SBO position, 0.5 FTE authorized, 0.2 FTE utilized.
-------
TABLE D-6
CAP STAFFING
STATE OR TERRITORY
Alabama*
Alaska
Maricopa County
Pima County*
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa* .
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
4
4
4
N/R
0
3
N/R
N/A
2
4
1
4
3
4
N/E
4
1
4
0
STATE
REGULATORY
EMPLOYEE
1
1
1
0
1
N/A
1
2
0
1
1
1
1
1
1
0
GENERAL
PUBLIC
0
2
2
0
3
N/A
2
4
0
2
3
0
2
1
0
NOT YET
APPOINTED
2
15*
2*
6
2
4
1
0
OTHER
N/A
0
1*
0
-------
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
4
4
seeKY
2
3
0
»
1
3
4
6
4
4
4
4
4
5
4 of 8
STATE
REGULATORY
EMPLOYEE
1
1
seeKY
2
2
0
N/A
1
3
1
1
1
1
1
1
1
1
1 of 8
GENERAL
PUBLIC
2
2
seeKY
0
2
0
N/A
2
2
2
2
0
2
2
2
2
2
2
3 of 8
NOT YET
APPOINTED
0
seeKY
4
T
0
7
1
1
5
0
0
0
1
0
OTHB*
2'
seeKY
2'
0
2'
N/A
r
0
-------
TABLE D-6
(Continued)
STATE OR TERRITORY
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
NUMBER OF PEOPLE ON CAP
SMALL
BUSINESS
OWNER
4
4
3
4
5
3
0
3
4
0
4
4
0
4
0
2
4
3
4
STATE
REGULATORY
EMPLOYEE
1
1
1
1
1
1
0
1
1
0
1
1
0
1
0
1
1
2
1
GENERAL
PUBLIC
2
2
2
2
3
2
0
1
2
0
2
2
0
2
0
1
2
3
2
NOT YET
APPOINTED
0
0
1
0
1
7
2*
0
7
0
0
0
0
3'
r
0
OTHER
0
0
0
1*
2"
0
0
1*
0
0
2"
-------
TABLE D-6
(Continued)
N/A Not applicable
N/E Not established
N/R No response
•Notes:
AL
Pima County, AZ
SCAQMD, CA
CO
IN
IA
KY
ME
ME
MA
Ml
NE
OR
PA
SC
UT
WA
Wl
WY
CAP staffing complete as of July 1997.
Rely upon state CAP.
The Local Government and Small Business Assistance Committee has not yet been formed and is still in the development stage.
To be appointed are 4 local government elected officials, 3 AQMD board members, 4 small business representatives, and 4
members of the general public. No CAP in place for state.
Terms expired as of 1/31/97, new appointments have not been made.
Environmental organization.
All pending Governor's appointment.
One person from Economic Development, one person from the local Air Pollution Control District.
7 = 1 small business, 1 business, 1 labor, 1 municipal government, 1 environmental, 2 public health.
2 = 1 business, 1 labor.
Although CAP is not formally established, Secretary of Environmental Affairs meets monthly with leaders of small business
community to discuss environmental progress and problems.
2 attorneys.
SBO non-voting member.
In July 1995, the CAP was expanded to 8 members. The eighth member represents Lane Regional Air Pollution Authority
(Eugene, OR area) small business interests.
Department of Community and Economic Development designee and ombudsman (vacant).
Positions not refilled after resignations.
Honorary member of Utah Pollution Prevention Association (small business, nonprofit group working to prevent and reduce
industry pollution).
Expired terms, replacements to be announced.
Assembly minority leader appointment still vacant.
Major source representatives.
-------
TABLE D-7
ADMINISTRATIVE LOCATION OF SBTCP COMPONENTS
STATE OR TERRITORY
Alabama
Alaska
Arizona
Maricopa County
Pima County
Arkansas
California
SCAQMD
BRIEF DESCRIPTION OF LOCATION
SBO
Office of Education and
Outreach in the Environmental
Regulatory Agency
AK Department of Environmental
Conservation, Compliance
Assistance Office (non-
enforcement)
AZ Department of Environmental
Quality, Compliance Assistance
Section
N/R
N/R
AR Department of Pollution
Control and Ecology (regulatory
agency)
Air Resources Board (ARB),
Office of the Ombudsman (part
of ARB, Office of the Chairman)
SBAP
Air Division of the Permitting
Agency
AK Department of Environmental
Conservation, Compliance
Assistance Office (non-
enforcement)
AZ Department of Environmental
Quality, Compliance Assistance
Section
Environmental Service (same
department as Enforcement)
Information Services Division of
Pima County Department of
Environmental Quality
AR Department of Pollution
Control and Ecology (regulatory
agency)
Throughout ARB including Office
of the Ombudsman and local Air
Pollution Control Districts
South Coast Air Quality Management District is a regional (Los
Angeles, non-desert portions of Riverside, and San Bernardo
counties), single media (air only), regulatory agency. The
ombudsman function and outreach function are co-located in the
Public Advisor's Office of the aaencv.
CAP
N/R
Private, uncompensated
individuals from small
businesses and general public
appointed by legislature and
Governor. One member is
employee of the Department (of
Environmental Conservation).
Outside Agency, but managed
by AZ Department of
Environmental Quality,
Compliance Assistance Section
N/R
N/R
AR Department of Pollution
Control and Ecology (regulatory
agency)
ARB, Office of the Chairman
N/A
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
BRIEF DESCRIPTION OF LOCATION
$80
CO Department of Regulatory
Agencies, Office of Regulatory
Reform (function will move to
CO Department of Public Health
and Environment / CDPHE,
Customer Service Center in
7/97)
CT Department of Environmental
Protection (regulatory agency)
Office of the Secretary, DE
Department of Natural
Resources and Environmental
Control
State regulatory agency
Department of Environmental
Protection, Division of Air
Resource Management, Bureau
of Air Regulation
Environmental Protection
Division, Air Protection Branch
State Department of Health,
Deputy Director of
Environmental Health
Division of Environmental
Quality, Planning and Support
Services, Performance
Manaaement Bureau
SBAP
CO Department of Public Health
& Environment / CDPHE, Air
Pollution Control Division,
Stationary Sources
CT Department of Environmental
Protection (regulatory agency)
DNREC, Division of Air and
Waste Management, Engineering
and Compliance (referred to for
technical assistance by
Ombudsman)
State regulatory agency
Department of Environmental
Protection, Division of Air
Resource Management, Bureau
of Air Regulation
Environmental Protection
Division, Air Protection Branch
State Department of Health,
Environmental Management
Division, Clean Air Branch
Division of Environmental
Quality, Air and Hazardous
Waste, Technical Services
Bureau
CAP
Independent, located outside of
agencies, individuals appointed
as defined in Section 507
CT Department of
Environmental Protection
(regulatory agency)
N/R
State regulatory agency
Independent
One CAP member is program
manager in Air Protection
Branch. Others located outside
all agencies with each individual
appointed as per Section 507.
Independent
Outside of all agencies,
appointed as defined by Section
507
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson County
Louisiana
Maine
BRIEF DESCRIPTION OF LOCATION
SBO
IL Environmental Protection
Agency
IN Department of Environmental
Affairs Management, Office of
Business Relations and
Legislative Affairs
IA Citizens' Aide/Ombudsman's
Office (a legislative office)
Department of Health and
Environment, Office of Pollution
Prevention (non-regulatory)
Office of the Secretary, Natural
Resources and Environmental
Protection Cabinet
Department of Planning and
Environmental Management,
Jefferson County
Governor's Office until October
31; Department of
Environmental Quality, Office of
the Secretary from November 1
Department of Environmental
Protection
SBAP
IL Department of Commerce and
Community Affairs, Small
Business Division
IN Department of Environmental
Management, Office of Pollution
Prevention and Technical
Assistance
IA Air Emissions Assistance
Program (IAEAP), Iowa Waste
Reduction Center (IWRC),
University of Northern Iowa
Contracted: University of Kansas
with subcontracts to Kansas
State University and Wichita
State University
Contracted: Center for
Entrepreneurship, Gatton College
of Business and Economics,
University of Kentucky
Air Pollution Control District,
Jefferson County
Department of Environmental
Quality, Air Quality Division
Department of Environmental
Protection
CAP
N/R
Independent
Pending Governor appointment
Independent
Panel members appointed by
Executive Order of Governor
See KY above
No permanent location
Outside Department (as defined
bv Section 507)
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
SBO
MD Department of the
Environment, Office of
Communication (state regulatory
agency)
Office of Technical Assistance*
Ml Jobs Commission, Business
Ombudsman's Office
MN Pollution Control Agency,
Environmental Planning and
Review Office
Department of Environmental
Quality
Governor's Office
Pollution Prevention Bureau of
Planning Division (non-regulatory
division of MT Department of
Environmental Quality)
BRIEF DESCRIPTION OF LOCATION
SBAP
MD Department of the
Environment, Environmental
Permits Service Center (state
regulatory agency)
Department of Environmental
Protection and Office of
Technical Assistance*
Ml Department of Environmental
Quality, Environmental
Assistance Division
MN Pollution Control Agency,
Air Quality Division, Manager's
Office
Department of Environmental
Quality
MO Department of Natural
Resources' Division of
Environmental Quality's
Technical Assistance Program
Pollution Prevention Bureau of
Planning Division (non-regulatory
division of MT Department of
Environmental Quality) - Small
Business Engineer located in Air
and Waste Management Bureau
of Department's Permitting and
Compliance Division
CAP
N/A
Not established
N/A
N/R
Outside
Independent and located
outside all agencies
Administered by CAP
Chairperson in Billings and
Secretary in Helena
SBO, SBAP, and CAP are directed by one person, the Public Advocate, who is located in the
Manaaement Services section of NE Department of Environmental Quality.
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Nevada
NV Bureau of Air
Quality
Washoe County Air
Clark County Air
BEP-UNR
New Hampshire
New Jersey
New Mexico
New York
BRIEF DESCRIPTION OF LOCATION
SBO
NV Division of Environmental
Protection - Office of the
Administrator
SBAP
NV Division of Environmental
Protection - Office of the
Administrator*
CAP
NV Division of Environmental
Protection (independent, SBO
and SBAP staff serve as staff
members to CAP)
NV Division of Environmental Protection, Bureau of Air Quality (Division is main state regulatory agency
for most environmental issues, and the Bureau has control over air issues with exception of most air
quality sources located in Washoe and Clark Counties.)
Washoe County District Health Department, Air Quality Management (County regulatory agency for
most air quality issues.)
Clark County Health District, Air Pollution Control Division (County regulatory agency for most air quality
issues.)
NV Small Business Development Centers (Certain outreach services have been contracted to the
"Business Environmental Program" at University of Nevada, Reno.)
NH Department of Environmental
Services, Office of the
Commissioner
NJ Department of Commerce &
Economic Development, Division
of Economic Development
NM Environmental Department,
Air Quality Bureau
NY State Empire State
Development, Division for Small
Business (non-regulatory state
agency)
NH Department of Environmental
Services, Air Resources Division
NJ Department of Environmental
Protection, Permit Coordination
and Pollution Prevention Element
NM Environmental Department,
Air Quality Bureau
NY State Environmental
Facilities Corporation, Technical
Advisory Services Division (non-
regulatory public benefit
corporation)
Independent with administrative
support from SBAP and DES Air
Resources Division
NJ Department of
Environmental Protection
Independent
NY State Department of
Environmental Conservation,
Division of Air Resources,
Bureau of Technical Support
(administrative location and
contact point of CAP)
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
BRIEF DESCRIPTION OF LOCATION
SBO
NC Department of Environment,
Health and Natural Resources,
Division of Pollution Prevention
and Environmental Assistance
ND Department of Health,
Environmental Health Section,
Chief's Office
Clean Air Resource Center, OH
Air Quality Development
Authority (independent, non-
regulatory, financing agency)
ODEQ, Executive Director's
Office
Department of Environmental
Quality, Director's Office
SBO funded by PA Department
of Environmental Protection and
utilizes local service providers,
which are funded by Department
of Community and Economic
Development
Commercial Development
Administration Executive Office
(position not reappointed)
Rl Department of Environmental
Management, Office of the
Director
SBAP
NC Department of Environment,
Health and Natural Resources,
Division of Pollution Prevention
and Environmental Assistance
ND Department of Health,
Division of Environmental
Engineering
OH Environmental Protection
Agency, Division of Air Pollution
Control
ODEQ, Customer Services
Division
Department of Environmental
Quality, Air Quality Division
Contracted: PRC Environmental
Management, Inc. SBAP has
received cooperation from trade
associations, utilities, and
district libraries in delivering
services.
Environmental Quality Board, Air
Quality Area, Planning Division
Rl Department of Environmental
Management, Office of
Technical and Customer
Assistance (1 FTE) and
University of Rhode Island,
Center for Pollution Prevention
(0.5 FTE)
CAP
Independent
Independent and located
outside all agencies
Appointed as defined in Section
507
ODEQ, Customer Services
Division
Outside agency. Liaison to
SBAP, SBO; Small Businesses.
PA DEP provides administrative
and technical support to the
committee. CAP meetings held
in Department's building.
Not in full operation - as defined
in Section 507
Outside state agencies;
individuals appointed as per
Section 507
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
US Virgin Islands
BRIEF DESCRIPTION OF LOCATION
SBO
Department of Health and
Environmental Control,
Environmental Quality Control
Administration
SBO supervised by Secretary of
the Department.
TN Department of Environment
& Conservation, Deputy
Commissioner's Office
TNRCC, SBAP
UT Department of Environmental
Quality, Executive Director's
Office
Not yet established
Department of Environmental
Quality, Air Division
Small Business Development
Aaencv, Department of Tourism
SBAP
Department of Health and
Environmental Control,
Environmental Quality Control
Administration
Individuals that work with the air
program all contribute to the
success of the SBAP.
TN Department of Environment
& Conservation, Pollution
Prevention/Environmental
Awareness Division
TNRCC, SBAP
UT Department of Environmental
Quality, Division of Air Quality,
Operating Permits Section
Department of Environmental
Conservation, Environmental
Assistance Division
Department of Environmental
Quality, Air Division
Department of Planning and
Natural Resources
CAP
Department of Health and
Environmental Control,
Environmental Quality Control
Administration
Made up of individuals across
state with a good mixture of
private individuals and small
business owners.
Not operating
TNRCC, SBAP
UT Department of
Environmental Quality, Division
of Air Quality
Not yet established
Appointed as per Section 507-
all outside appointments except
DEQ appointment
None
-------
TABLE D-7
(Continued)
STATE OR TERRITORY
Washington
West Virginia
Wisconsin
Wyoming
BRIEF DESCRIPTION OF LOCATION
SBO
SBO is agency representative to
Governor's Small Business
Improvement Council composed
of small business owners and
various state agencies
responsible for regulating the
state's businesses. SBO is
agency representative to Unified
Business Identifier (UBI) Board
composed of state and federal
regulatory agencies impacting
primarily small businesses.
WV Division of Environmental
Protection
Department of Commerce,
Bureau of Small Business and
Permit Assistance, Division of
Marketing Advocacy and
Technology Development
WY Department of
Environmental Quality,
Administration Division
SBAP
SBAP supports and is supported
by the following cooperative
relationships: (1) Technical
assistance staff for business-
related pollution
control/prevention exist in other
Ecology programs. (2) Outreach
and assistance staff in 4 of
states' 7 local air authorities.
(3) Moderate risk waste staff in
state's 39 counties.
WV Department of
Environmental Protection, Office
of Air Quality
Department of Commerce,
Bureau of Small Business and
Permit Assistance, Department
of Natural Resources
WY Department of
Environmental Quality, Air
Quality Division
: CAP
One CAP member is legislative
liaison for Air Quality Program.
All others are unpaid volunteers
(per diem travel, lodging, and
meals reimbursed). Staff
support provided by SBAP.
Outside of all agencies, as per
Section 507
Outside of all state agencies,
includes small business owners
and other state agencies
Independent citizens panel
appointed by legislature,
governor, and Department;
outside any state agency with
statewide meetings
N/A Not applicable
N/R No response
8
-------
TABLE D-7
(Continued)
"Notes
MA SBO: SBAP manager at OTA functions as SBO and receives all communications routinely directed to SBO. Secretary of Environmental
Affairs, Trudy Coxe, Executive Office of Environmental Affairs, routinely meets with business leaders to solicit input on problems and
programs.
MA SBAP: According to November 1992 SIP, program functions are divided between DEP and OTA. DEP currently is reorganizing and has
established a "business customer support unit," which deals with permits, compliance and enforcement activities related to industrial
and commercial entities. We routinely collaborate with DEP on compliance assistance programs, including Printers Partnership (MP2),
all Environmental Results Program (ERP) sectors, and special outreach projects such as one targeted for the autobody refinishing
industry currently under development. This means that all such programs impacting small business in MA receive the benefits of
SBAP-oriented planning being incorporated into DEP programs, which are then implemented by DEP staff within the state's five
regions. For example, in the MP2 program, several DEP personnel accounted for more than 2,000 person/hours, OTA/SBAP staff for
1,750. For the ERP program, DEP and OTA staff have devoted considerable time and resources in 1996 to the development and
implementation of programs affecting small business.
NV Also provides services to all industries and general public on other medias as well as air.
-------
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
CONTRACTED COMPANY
Kansas
Mr. Frank Orzulak
University of Kansas Center for Environmental Education and Training
Continuing Education Building
University of Kansas
Lawrence, KS 66045-2608
913-864-3978
913-864-5827 fax
Current budget: $340,000
Term of contract: July 1 - July 1 annual renewal
Kentucky
Mr. Gregory C. Copley, Director, Business Environmental Assistance Program
Center for Entrepreneurship
Gatton College of Business and Economics
University of Kentucky
Lexington, KY 40506-0034
606-257-1131
606-323-1907 fax
Current budget: $250,000
Term of contract: July 1, 1996 - June 30, 1997
Pennsylvania
Mr. Joseph Knox
PRC Environmental Management, Inc.
1800 John F. Kennedy Boulevard, Sixth Floor
Philadelphia, PA 19103
215-972-0444
800-722-4743
215-972-0484 fax
Current budget: $300,000
Term of contract: Rve years
10
-------
APPENDIX E
SBTCP ACTIVITIES AND SERVICES
-------
APPENDIX E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Dry Cleaners/Laundry Services
Auto/Body Maintenance/Refinishing/Rep
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Casl
Wood Products/Fumiture/Finishing
Attomey/Consultants/Engineers
Other
Gasoline Distribution (Wholesale/Retail)
Chrome Plating
Construction/Contractor
Concrete/Aggregate
Manufacturing
Petroleum/Products/Storage
Chemicals/Products
Agriculture/Farming/Crop Service
Electric Equipment/Repair
Plastic Manufacturing/Products
Schools
Organizatbns/Assoc iations
Mining and Minerals
Electroplating
Machine/Manufacturing & Repair
Food Products/Processing/Beverages
Sawmills/Logging/Wood Products
Paints and Painting
Private Citizen
Government
Cut/Crushed Stone Products/Glass
Hospitals/Medical/Health Services
Grains/Grain Elevators
Furniture Manufacture/Repair/Sales
Utilities
Foundry/Smelter
Transportation Services/Equipment
Asphalt
Recycler
Textiles
Rubber/Products
Wholesale/Retail Goods
Auto Dealers
Metals
NUMBER
OF
STATES
NUMBER OF
ASSISTANCES
GENERAL
37 8,592
36 7,846
32
27
25
17
16
16
15
14
14
14
13
12
11
10
10
10
10
10
g
9
9
9
8
8
8
8
8
7
7
7
7
7
6
6
6
6
6
5
5
2,982
2,172
4,207
1,885
23,150
1,738
286
302
196
1,791
283
222
313
353
52
158
310
59
77
180
266
205
70
610
557
198
77
169
144
79
19
30
16
98
23
52
55
537
30
ON-SITE
440
1,292
184
167
237
10
592
75
10
123
42
64
41
21
16
25
51
6
3
9
22
29
11
10
7
4
8
24
2
18
7
0
9
12
5
18
8
11
3
25
5
TOTAL
9,032
9,138
3,166
2,339
4,444
1,895
23,742
1,813
296
425
238
1,855
324
243
329
378
103
164
313
68
99
209
277
215
77
614
565
222
79
187
151
79
28
42
21
116
31
63
58
562
35
c:\sbtcp96.wk3
-------
APPENDIX E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Boat Manufacturing
Waste/Waste Hauler
Business Services
Sand & Gravel
Airports/Air Transportation
Plumbing/HVAC
BrickAlte
Landfills/Landfill Gas
Research & Testing Facilities/Laboratory
Dairy/Feedtots/Livestock
Fabricated Structural Metal
Paper Manufacturing/Products
Newspapers
Personal Services
Analytical/Medical Instruments
Leather/Fur
Repair
Motor Vehicles and Equipment
Restaurants
Machine Shop
Clothing
Veterinarians/Veterinary Incinerators
Water/Wastewater
Cotton Gins
Engines and Turbines
Bakery
Remediation
Portable Equipment
Advertising/Commun teat tons
NUMBER
OF
STATES
5
5
5
5
5
5
4
4
4
4
4
4
4
4
4
4
3
3
3
3
3
3
3
3
3
3
2
2
2
Incinerators 2
Real Estate 2
Boilers 2
Adhesives 2
Degreasers 2
Crematories 2
Aerospace 2
Jewelry Manufacturing 2
Asbestos 2
Media 2
Solvents 2
Tires 2
NUMBER OF
ASSISTANCES
GENERAL ON -SITE
6
91
321
22
35
557
7
101
24
18
1
53
14
88
16
7
3
21
379
9
3
34
31
52
13
70
99
193
7
44
17
1,029
247
46
4
30
4
27
7
26
5
25
5
4
11
2
5
6
3
2
4
10
0
1
2
3
3
2
1
35
6
0
3
1
3
4
3
0
1
1
0
1
0
0
0
2
1
2
0
0
0
2
TOTAL
31
96
325
33
37
562
13
104
26
22
11
53
15
90
19
10
5
22
414
15
3
37
32
55
17
73
99
194
8
44
18
1,029
247
46
6
31
6
27
7
26
7
c:\sbtcp96.wk3
-------
APPENDIX E-1
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF STATES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Hotels/Motels
Ethylene Oxide
Screw Machine Products/Bolts
Warehouse/Storage
Thermoset
Television/Radio
TRI
Welding Shop
Software
Wire
Title V Affected Industry
Smoking Vehicles
Self Audits
Trona Process
Tribal
Abrasive Blasting
Churches
Casino
Environmental Equipment
Emergency Generators
Cuttery/Handtools/Hardware
Environmental Quality & Housing Progra
Equipment Rental
Banks
Auto Wrecking
Apartment Houses
Environmental Programs
Race Track
Marine
Household Appliances
P2 Conference
Ordnance
Optical
Pharmaceuticals
Fiberglass
NUMBER
OF
STATES
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Glass 1
Forestry 1
Flower Shops 1
Landscaping 1
TOTALS
NUMBER OF
ASSISTANCES
GENERAL
4
3
1
10
79
1
450
0
0
0
254
9
86
5
2
344
7
1
4
2
5
40
1
4
1
3
238
1
2
6
700
0
2
6
2
0
7
2
1
66,433
ON-SITE
0
0
0
4
1
0
2
1
6
1
8
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
2
0
0
1
0
0
1
3,829
TOTAL
4
3
1
14
80
1
452
1
6
1
262
9
86
5
2
344
7
1
4
2
5
41
1
4
1
3
238
1
2
6
700
1
4
6
2
1
7
2
2
70,262
c:\sbtcp96.wk3
-------
APPENDIX E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Other
Auto/Body Maintenance/Refinishing/Rep
Dry Cleaners/Laundry Services
Wood Products/Fumiture/Finishing
Printing/Graphic Arts
Metal Fabrication/Finishing/Forging/Cast
Attorney/Consult ants/Engineers
Manufacturing
Gasoline Distribution (Wholesale/Retail)
Boilers
P2 Conference
Private Citizen
Government
Plumbing/HVAC
Auto Dealers
TRI
Construction/Contractor
Restaurants
Electric Equipment/Repair
Abrasive Blasting
Agriculture/Farming/Crop Service
Business Services
Petroleum/Products/Storage
Organizations/Associations
Chrome Plating
Food Products/Processing/Beverages
Title V Affected Industry
Adhesives
Chemicals/Products
Environmental Programs
Concrete/Aggregate
Cut/Crushed Stone Products/Glass
Sawmills/Logging/Wood Products
Machine/Manufacturing & Repair
Portable Equipment
Grains/Grain Elevators
Schools
Furniture Manufacture/Repair/Sales
Recycler
Landfills/Landfill Gas
Plastic Manufacturing/Products
NUMBER
OF
QTATFQ
o i m co
16
36
37
25
32
27
17
14
16
2
1
8
8
5
5
1
14
3
10
1
11
5
13
10
15
9
1
2
12
1
14
8
9
9
2
7
10
7
6
4
10
N
A4
GENERAL
23,150
7,846
8,592
4,207
2,982
2,172
1,885
1,791
1,738
1,029
700
610
557
557
537
450
302
379
353
344
313
321
283
310
286
266
254
247
222
238
196
198
205
180
193
169
158
144
98
101
52
UMBER OF
3SISTANCES
ON-SITE
592
1,292
440
237
184
167
10
64
75
0
0
4
8
5
25
2
123
35
25
0
16
4
41
3
10
11
8
0
21
0
42
24
10
29
1
18
6
7
18
3
51
TOTAL
23,742
9,138
9,032
4,444
3,166
2,339
1,895
1,855
1,813
1,029
700
614
565
562
562
452
425
414
378
344
329
325
324
313
296
277
262
247
243
238
238
222
215
209
194
187
164
151
116
104
103
c:\sbtcp96.wk3
-------
APPENDIX E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR NUMBER
OF
STATES
Remediation 2
Electroplating 9
Waste/Waste Hauler 5
Personal Services 4
Self Audits 1
Thermoset 1
Utilities 7
Hospitals/Medfcal/HeaJth Services 8
Paints and Painting
Bakery
Mining and Minerals
Rubber/Products
Wholesale/Retail Goods
Cotton Gins
Paper Manufacturing/Products
Degreasers
Incinerators
Transportation Services/Equipment
Environmental Quality & Housing Progra
Airports/Air Transportation
Veterinarians/Veterinary Incinerators
Metals
Sand & Gravel
Water/Wastewater
Aerospace
Textiles
Boat Manufacturing
Foundry/Smelter
Asbestos
Research & Testing Facilities/Laboratork
Solvents
Motor Vehicles and Equipment
Dairy/Feedtots/Livestock
Asphalt
AnaJytical/Medteal Instruments
Real Estate
Engines and Turbines
Machine Shop
Newspapers
Warehouse/Storage
Brick/Tile
8
3
10
6
6
3
4
2
2
7
1
5
3
5
5
3
2
6
5
7
2
4
NUMBER OF
ASSISTANCES
GENERAL
99
77
91
88
86
79
79
77
70
70
59
52
55
52
53
46
44
30
40
35
34
30
22
31
30
23
6
19
27
24
2 26
3 21
4 18
6 16
4 16
2 17
3 13
3 9
4 14
1 10
4 7
ON-SITE
0
22
5
2
0
1
0
2
7
3
9
11
3
3
0
0
0
12
1
2
3
5
11
1
1
8
25
9
0
2
0
1
4
5
3
1
4
6
1
4
6
TOTAL
99
99
96
90
86
80
79
79
77
73
68
63
58
55
53
46
44
42
41
37
37
35
33
32
31
31
31
28
27
26
26
22
22
21
19
18
17
15
15
14
13
c:\sbtcp96.wk3
-------
APPENDIX E-2
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Fabricated Structural Metal
Leather/Fur
Smoking Vehicles
Advertising/Communications
Media
Forestry
Tires
Churches
Software
Jewelry Manufacturing
Crematories
Household Appliances
Pharmaceuticals
Repair
Trona Process
Cutlery/Handtools/Hardware
Banks
Environmental Equipment
Hotels/Motels
Optical
Ethytene Oxide
Clothing
Apartment Houses
Tribal
Landscaping
Fiberglass
Emergency Generators
Marine
Flower Shops
Glass
Wire
Welding Shop
Equipment Rental
Television/Radio
Screw Machine Products/Bolts
Auto Wrecking
Ordnance
Race Track
Casino
TOTALS
NUMBER
OF
OTATCe
o i m co
4
4
1
2
2
1
2
1
1
2
2
1
1
3
1
1
1
1
2
1
2
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
N
A!
GENERAL
1
7
9
7
7
7
5
7
0
4
4
6
6
3
5
5
4
4
4
2
3
3
3
2
1
2
2
2
2
0
0
0
1
1
1
1
0
1
1
66,433
UMBER OF
DISTANCES
ON-SITE
10
3
0
1
0
0
2
0
6
2
2
0
0
2
0
0
0
0
0
2
0
0
0
0
1
0
0
0
0
1
1
1
0
0
0
0
1
0
0
3,829
TOTAL
11
10
9
8
7
7
7
7
6
6
6
6
6
5
5
5
4
4
4
4
3
3
3
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
70,262
c:\sbtcp96.wk3
-------
APPENDIX E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Auto/Body Maintenance/Refinishing/Rep
Other
Dry Cleaners/Laundry Services
Wood Products/Fumiture/Finishing
Printing/Graphic Arts
Metal Fabrfcaton/Finishing/Forging/Cas)
Construction/Contractor
Gasoline Distribution (Wholesale/Retail)
Manufacturing
Plastic Manufacturing/Products
Concrete/Aggregate
Petroleum/Products/Storage
Restaurants
Machine/Manufacturing & Repair
Electric Equipment/Repair
Auto Dealers
Boat Manufacturing
Cut/Crushed Stone Products/Glass
Electroplating
Chemicals/Products
Recycter
Grains/Grain Elevators
Agriculture/Farming/Crop Service
Transportation Services/Equipment
Rubber/Products
Sand & Gravel
Food Products/Processing/Beverages
Attomey/Consultants/Engineers
Fabricated Structural Metal
Chrome Plating
Sawmills/Logging/Wood Products
Foundry/Smelter
Mining and Minerals
Title V Affected Industry
Textiles
Government
Furniture Manufacture/Repair/Sales
Paints and Painting
Machine Shop
Brick/Tile
Software
NUMBER
OF
STATF«4
O 1 i\ 1 CO
36
16
37
25
32
27
14
16
14
10
14
13
3
9
10
5
5
8
9
12
6
7
11
7
6
5
9
17
4
15
9
7
10
1
6
8
7
8
3
4
1
NUMBER OF
ASSISTANCES
GENERAL ON-SITE
7,846 1,292
23,150 592
8,592 440
4,207 237
2,982 184
2,172 167
302 123
1,738 75
1,791 64
52 51
196 42
283 41
379 35
180 29
353 25
537 25
6 25
198 24
77 22
222 21
98 18
169 18
313 16
30 12
52 11
22 11
266 11
1,885 10
1 10
286 10
205 10
19 9
59 9
254 8
23 8
557 8
144 7
70 7
9 6
7 6
0 6
TOTAL
9,138
23,742
9,032
4,444
3,166
2,339
425
1,813
1,855
103
238
324
414
209
378
562
31
222
99
243
116
187
329
42
63
33
277
1,895
11
296
215
28
68
262
31
565
151
77
15
13
6
c:\sbtcp96.wk3
-------
APPENDIX E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Schools
Waste/Waste Hauler
Metals
Plumbing/HVAC
Asphalt
Private Citizen
Engines and Turbines
Dairy/FeedJots/Livestock
Warehouse/Storage
Business Services
Landfills/Landfill Gas
Leather/Fur
Wholesale/Retail Goods
Analytical/Medical Instruments
Bakery
Veterinarians/Veterinary Incinerators
Organizations/Associations
Cotton Gins
TRI
Repair
Optical
Personal Services
Airports/Air Transportation
Tires
Jewelry Manufacturing
Crematories
HospitaJs/Medfcal/Health Services
Research & Testing Facilities/Laboratory
Welding Shop
Real Estate
Thermoset
Portable Equipment
Wire
Water/Wastewater
Landscaping
Aerospace
Ordnance
Environmental Quality & Housing Progra
Glass
Motor Vehicles and Equipment
Newspapers
NUMBER
OF
<5TATFQ
O 1 n 1 CO
10
5
5
5
6
8
3
4
1
5
4
4
6
4
3
3
10
3
1
3
1
4
5
2
2
2
8
4
1
2
1
2
1
3
1
2
1
1
1
3
4
NUMBER
ASSISTAN
GENERAL ON-SI1
158
91
30
557
16
610
13
18
10
321
101
7
55
16
70
34
310
52
450
3
2
88
35
5
4
4
77
24
0
17
79
193
0
31
1
30
0
40
0
21
14
OF
CES
rn
6
5
5
5
5
4
4
4
4
4
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
TOTAL
164
96
35
562
21
614
17
22
14
325
104
10
58
19
73
37
313
55
452
5
4
90
37
7
6
6
79
26
1
18
80
194
1
32
2
31
1
41
1
22
15
c:\sbtcp96.wk3
-------
APPENDIX E-3
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE
RANKED IN DECREASING ORDER BY NUMBER OF ON-SITE ASSISTANCES
(DATA FROM 1996 SECTION 507 REPORT)
INDUSTRY SECTOR
Advertising/Commun icatbns
Utilities
Emergency Generators
Degreasers
Cuttery/Handtools/Hardware
Clothing
Churches
Casino
Solvents
Tribal
Trona Process
Screw Machine Products/Bolts
Boilers
Banks
Auto Wrecking
Asbestos
Apartment Houses
Television/Radio
P2 Conference
Environmental Equipment
Race Track
Hotels/Motels
Paper Manufacturing/Products
Pharmaceuticals
Media
Marine
Adhesives
Incinerators
Household Appliances
Smoking Vehicles
Self Audits
Remediation
Forestry
Flower Shops
Fiberglass
Ethytene Oxide
Equipment Rental
Environmental Programs
Abrasive Blasting
TOTALS
NUMBER
OF
STATES
2
7
1
2
1
3
1
1
2
1
2
2
1
1
2
4
1
2
1
2
2
1
1
1
2
1
1
1
2
1
1
1
NUMBER OF
ASSISTANCES
GENERAL
7
79
2
46
5
3
7
1
26
2
5
1
1,029
4
1
27
3
1
700
4
1
4
53
6
7
2
247
44
6
9
86
99
7
2
2
3
1
238
344
66,433
ON-SITE
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,829
TOTAL
8
79
2
46
5
3
7
1
26
2
5
1
1,029
4
1
27
3
1
700
4
1
4
53
6
7
2
247
44
6
9
86
99
7
2
2
3
1
238
344
70,262
c:\sbtcp96.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1M6 SECTION 507 REPORT)
STATE
_,_
AL
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
INDUSTRY SECTOR
LIvMtock and Amlmal Specialties
Agricultural Services
Oil S. Gas FMd Exploration Services
Mining & Quarrying of NonmetaHIc Mate*
General Contractors - Building Construct
General Confractors-Not Residential Hon
Soil Remediation Unto
Prapwd Ftoh or Frozen Fish/Seafood
Sawmill* & Planing Mill*
Wood Product*, NEC
Printing & Publhhtig
Newspapers, PubHehlng A Printing
Periodicals, Publishing & Printing
Fabricated Metal Products
Process Control Instruments
TrucUng & Courier Services, Except Air
Air Transportation
Airports, Flying Fields, & Airport Terminal :
Radio Broadcasting Stations
Communication/Services
Electric Services
Qes Production & attribution
Combination Electric, Qas & Other Utility !
Sewerage Systems
Hsfuss Systems
Professional & Commsrclal EqulpmenVSu
Industrial Machinery. Equipment, & Suppl
Qroeerles & Related Products
Automotive Dealers
Gasoline Service Stations
Men's & Boy's ClothlngAeeessoriee
Misc. Retail Stores, NEC
Banks, Commercial
Subdivide™ A Developers
Hotels & Lodging House Operated by Me
Dry Cleaning Plants
Business Services
Advertising. NEC
Automotive Repair Shops, General
Health Services
Legal Services
Elememtary A Secondary Schools
College*, Universities, & Professional Sch
School* A Professional Services, NEC
Social Services, NEC
Business AssocUlans
Professional Associations
Political Organizations
Member Organizations, NEC
Englnsenng Services
Management Consulting Services
Business ConsuUng Services, NEC
Private Households (Domestic Services)
Executive;, Legislative, A General Gcvt
Justice, Public Order, A Safety
Environmental Quality & Housing Progran
Admin, of Transportation
National Security A International Affairs
Government, Oty
Government, County
Government, State
Government, Federal
Non-profit Organization
Civic Organization
Lawyer
Vendor/Supplier
Recyclef
Tribal
Consultant/Engineer
Private Citizen
Media
Agriculture
QENERAL
(A)
NUMBER OF
ASSISTANCES
CM-SITE
(B)
TOTAL
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
MaricopaCt
Plma Cty, A;
Rma Cty. A;
Plma Cty, K
Plma Cty, K
Plma Cty, A:
Rma Cty, A:
Plma Cty, A;
Plma Cty, A;
Plma Cty, A:
Plma Cty, K
Plma Cty, K
Plma Cty, A:
Plma Cty, A!
Plma Cty, A:
Plma Cty, K
Plma Cty, A;
Plma Cty, A;
Plma Cty, K
Plma Cty, A!
Plma Cty, K
Plma Cty, K
Plma Cty, A;
Plma Cty, A;
Plma Cty, A;
Plma Cty, A>'
Plma Cty, A;
PlmaCty.A;
Rma Cty, A;
Rma Cty, A;
Plma Cty, A;
PlmaCty.A;
PlmaCty.A;
Plma Cty, K
Plma Cty, Ai
Rma Cty, A;
Rma Cty, K
INDUSTRY SECTOR
Aerospace Manufacturing/Repair
Automotive Rapalr/Body Shop
Chemical Manufacturing
Construction
Composites/Plastics
Dry Cleaner/Laundry
Educational Institution
Electreplater
Electronic Manufacturing
Equipment Manufacturing/Repair
Furnltura/Shu1«w»
Health Services
Metal Fabricattap/Flnishing
Mining Extraction
Paint Applicator
Printing/Publishing
Stone/Clay/Glass
Transportation Services/Equipment
UtilKin
Wood Treatment
Auto Body
Bakeries
Concrete Plants
Crematories
Cultured Marbb
Dry Cleaner
Engine Repair
Fiberglass
Foundries
Wood Products
Qas Service Stations
Laboratories
Paint Manufacturing
Electroplating Operations
PriottflQ
Sand a Gravel
Unspeclied Sources
Landscape & Horticulture Services
Mmee
Sand & Gravel
General Building Contractors
ROOMft
Special Trade Organization
Mate. Food Products
Misc. Furniture & Fixtures
Printing Trade Service*
Plastic Materials & Synthetics
Paints & Allied Products
Hoses, Belts, & Gaskets
Glass
Concrete, Gypsum, & Platter Products
Cut Stone & Stone Products
Misc. Primary Metals
Fabricated Structural Metal Products
Fabricated Metal Products, Misc.
Construction & Related Machinery
Metalworkkig Machinery
Electrical Industrial Apparatus
Electrical Component!
Jewelry, Silverware, & Plated Ware
Auto Dealers & Service Stations
Gasoline Service Stations
Restaurant*
Shoppkig Goods Stores, Misc.
Hotels & Motels
Laundry, Cleaning, & Garment Services
Equipment Rentals & Leases, Mbc.
Computer & Data Processing
Business Services, Misc.
Auto Repair Shops
Auto Services. Not Repair
Hospitals
| NUMBER OF
ASSISTANCE
GENERAL ON -SITE
(A) (B)
a 1
19 3
8 1
17 4
1 0
IB 2
25 0
2 0
5 0
1 0
3 0
3 0
8 1
B 0
1 0
8 0
4 0
1 0
8 0
3 1
12 25
2 3
2 2
3 2
2 2
6 4
e 3
3 4
2 4
10 9
2 1
1 1
1 1
2 2
17 13
2 2
8 0
1 1
1 1
1 1
1 0
1 0
0 1
1 0
0 2
0 1
4 2
1 0
2 0
0 1
1 1
0 1
1 0
0 1
1 2
1 0
0 2
0 1
1 1
1 0
1 0
1 0
0 1
0 1
1 0
1 3
1 0
1 0
1 0
4 9
0 1
1 1
s
TOTAL
(A+B)
10
22
9
21
1
21
25
2
5
1
3
3
10
6
1
9
4
1
B
4
37
4
S
4
10
9
7
6
19
3
2
2
4
30
4
8
2
2
2
1
1
1
1
2
1
B
1
2
1
2
1
1
1
3
1
2
1
2
1
1
1
1
1
1
4
1
1
1
13
1
2
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
unknown
unknown
5
10
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
«OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100A
40
20
c:\sbtcp96.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 5O7 REPORT)
STATE
Plma Cty, A:
Plma Cty, A;
Plma Cty, A:
Plma Cty, A:
AR
AR
AR
AR
CA
Kern Cty, C/
Kern Cty, C/
Placer Cty, (
Placer Cty, (
Placer Cty, (
Placer Cty, (
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
San Joaqulr
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
Santa Barba
South Coast
INDUSTRY SECTOR
Medical & Dental Laboratories
School* & Educational Services
Engineering Services
Government
Tide V Affected Industry
Solid Waste Landfill*
Metal Fabrication
Recycling
N/R
Dry Cleaners
Spray Painters
Auto flefintehlng
Dry Cleaners
Landfill Gas
Soil Remediation
Auto Refinlahlng
Gasoline Dispensing (420 facilities subjec
Dry Cleaners (provided training to 263 pei
Abrasive Blasting
Portable Equipment
Adhesive.
SeifAudto
Abrasive Blasting
Agricultural Related Business
Aggregate Plants
Asphalt Batch Plants
Automotive Refinlshlng
Can & Coll
Chrome Platers
Consultants
Cotton Gin*
Concrete Batch Plants
Dry Cleaners
Feed Protesting
Food Processing
Gasoline Dispensing Facilities
Graphic Art*
Hospitals
Metal Parts flefmlshlng
Misc.
OU Production
Government Agencies, Other
Paper Packaging (food, misc.)
Potester/Resin Operations
Portable Equipment (registration certinca*
Refineries
Small Manufacturers (misc.)
Soil Remediation Protects
Water District
Wood Coating & Woodworking
OH A Gas (onshore)
Solvents (general)
Gas Station*
Auto Body Shops
1C Engines
Dry Cleaners
Sand, Rock, & Gravel
Incinerator
Contaminated Soil
Misc. Unpermtted
General Public
Government
Consultants
Asbestos
Media
Smoking Vehicle*
All Small Businesses
,, , .
GENERAL
(A)
0
1
6
3
254
83
254
41
24 workshop!
37
1
30
570
420
330
ISO
187
86
14
84
28
7
71
5
12
182
4
30
21
IS
138
229
37
28
44
199
127
200
38
14
39
9
82
84
21
38
9
24
6
4
7
3
2
1
2
20
78
19
34
4
1
9
3737
NUMBER OF
ASSISTANCE
ON-SITE
(8)
1
0
0
1
8
1
6
1
6
27
•
0
0
0
0
0
156
0
0
0
0
2
7
3
1
2
S
2
4
1
3
339
:s
TOTAL
(A+B)
1
1
6
4
282
84
230
42
6
27
24
37
1
30
570
420
156
330
150
167
86
14
84
30
7
76
5
12
162
4
33
22
16
140
229
42
26
46
189
131
200
38
14
39
9
82
64
22
41
8
24
6
4
7
3
2
1
2
20
78
19
34
4
1
9
4076
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
unknown
unknown
unknown
unknown
362
86
1481
354
6
27
50
37
570
420
200
7,000
64
38
224
70
41
34
9
9
89
~30000
%OF
TOTAL
PI ircini P
d.lUIDI»C
FACILITIES
(A+B)*100/t
72
98
15
12
100
100
46
100
100
100
78
1
0.78
4.69
1.67
0.39
4.35
0.28
0.67
9.04
0.22
1.84
1.23
0.89
7.81
12.78
2.34
1.62
2.57
11.10
7.31
11.18
2.12
0.78
2.18
0.50
4.58
3.57
1,23
2.29
14
63
3
6
17
9
22
11
3
13.8
c:Vsbtcp96.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 19M SECTION 507 REPORT)
STATE
South COM)
South COM)
South COM)
South Co**
South Cowl
South COM)
South Cowl
South Cowl
South Cow)
South Cowl
CO
CO
CO
CO
CT
CT
CT
CT
CT
CT
DE
DE
DE
06
DC
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
GA
GA
GA
GA
GA
HI
ID
IL
IL
IL
||
IL
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
INDUSTRY SECTOR
Auto Body
Dry Cleaner*
RWtMlfWIti
WOOO rNltohOre
M*ti Rntotwr*
Electronic.
AutoMpt**
Printtnflt uGrwii
Printing, LtttoQTBphlc
Dry Cleaner*
Automotive Induitry
Prlntar* .
Metal FMihere
Gw Station*
Dry Cleaner*
Auto Body Shops
MMM FintentWB
fTrlntara
rTWilW
Mite.
Dry Cleaner*
Motor Vehicle ReflnMien
Chrome Plater*
AgricuKural Crop Producer*
Dry Cleaner*
DryClMfMn
Service) Station*
Bulk Pet/ohum Plant*
Machinery Shop*
BoatBufkftig
Auto Repair Shop*
Wood Shop*
Nursing Home*
Home Health Care
ComuKane), Environmental
Environmental Lab*
Biwlnee* Organbatton*
Chrome PtaBno
Concrete Manufacturing
AtphaRPwing
Poly Caet Fabricator*
ITiliiiaia
rnniVTV
A/C Contractor
Drydeenen
Chrome PMer*
D*gr*w»ri
Oftm^mfm
rrvn*n
Wood Furniture Manufacture™
Dry Clean era
Nore*pon*e
fT-lnfa.—
rnnwfw
Auto Body
Heating & Air Conditioning
R0fnQ*MDon nspwr
Etoctropta-ng
Metal Fabricator*
ContuKanti
Sign Shop*
Aluminum Sand Ceding
Lubricant Manufacturing
Aluminum Extructon
WeMngShop
Dry Clean en
Dry Clean era -General
NUMBER OF
ASSISTANCE
GENERAL ON-SITE
(A) (B)
834 8S
1ST 14
374 34
Ml 51
187 17
187 17
581 51
581 51
83 9
82 10
900 25
480 8
25 5
80 5
150 0
50
250 460
250 25
100 0
950 15
82 3
78 1
5 0
150 0
80 0
84 1
1
11
1
2
2
2
1
3
2
1
384 15
5 0
3 0
89 2
88 2
5
0
0
0
0
0
0
0
0
0
0
0
0
45
450
8
TOTAL
(A+B)
._._..-_
1018
201
408
812
204
204
812
812
102
102
800
458
30
85
150
50
700
275
100
565
85
79
5
150
80
65
1
1
1
1
15
1
1
1
11
1
2
2
2
1
3
2
1
379
5
3
71
70
5
-
350
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
900
600
1500
350
2000
735
1500
500
500
2500
120
78
S
N/A
150
661
15
11
1200
700
37
350
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/I
100
57
2
27
8
6
47
55
20
23
71
100
100
SO
57
33
27
6
10
13.5
100
c:\*btcp98.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE, BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
IN
IN
IN
IN
IN
IN
IN
IN
IA*
IA
IA
IA
IA
IA
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
K8
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KS
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
INDUSTRY SECTOR
Dry Cleaners- Workshops
Dry Cleanera-Me** Mall
Auto Body
Degreasers
Electroptater*
HVAC
TH (assistance by project)
Boilers (assistance by project)
Dry Cleaners
Qraln FaeHltta*
Auto Body Repair
Print*™
Manufacturing
Others
Agricultural Production & Strvlcet
Highway ft Street Construction
Food ft Kindred Products
Lumber & Wood Products Except Furnttur
Furniture/Fixtures
Printing, Publishing, ft Allied Industries
Chemicals ft Allied Product*
Rubber & Misc.
Stone, Glass, ft Clay
Prime^ Metals Industry
Fabricated Metal Products Except Machln
Industrial ft Commercial Machinery & Con
Electronics
Transportation Equipment
Railroad Transportation
Air Transportation
Electric, Gas, ft Sanitary Sewer
Wholesale Trade-Durable Soods
Personal Services
Automotive Repair
Repair, Misc.
Health Services
Educational Serhrees
Membership Organizations
Engineering, Accounting, Research, & Arc
Private Households
Others Not Classified
Flower Shops
Veterinarians
Oil/Gas Field Services
Misc. Specialty Trade
MIsc.TextHes
Misc. Apparel
Misc. Wood Products
Paperboard Containers
Paints ft Allied Products
Chemicals, Misc.
Metal Cans/Ship
General Industrial Machines
Electric Wirhg
Motor Vehicles
Consultants
Bit. Coal ft Ug, Surface
Crushed ft Broken Limestone
Food ft Kindmd Products, Misc.
Textile Finishing, Except Wool
SawmlHs ft Planing Mills
MWwork, Plywood, ft Structural
Wood Products, Misc.
Household Furniture
Paperboard Containers ft Boxes
Printing, Commercial
Paints ft Allied Products
Chemicals, Industrial Organic
Chemical, Agricultural
Chemical Products, Misc.
Petroleum Refining
| NUMBER OF
ASSISTANCE
GENERAL ON-SITE
(A) (B)
80
1090
338 384
40 0
38 0
900 0
480 2
1028 0
200 18
100 10
800 90
10 9
100 29
90 20
9
1
8
13
2 1
28 2
5
9 1
1
2
43 7
28 9
1
10 3
2 9
4
4
3
11 2
14 7
3
3
7
4
30
9
70
2
2
8
2
1
24
2
2
1
* *
1 3
2
2
2
1
1
1
1
1
2
2
:a
TOTAL
(A+B)
287
40
38
900
492
198
219
110
690
19
129
70
9
1
8
13
3
28
5
6
1
2
90
38
1
13
7
4
4
3
13
21
3
3
7
4
30
9
70
2
2
e
2
1
24
2
2
1
4
2
2
2
1
1
1
1
1
2
2
NUMBER
OF
ELIGIBLE
GklUIQbC
FACILITIES
(Q
309(4ctyar
108
81
900
900
unknown
279
1900
1200
700
2900
2000
0
0
20
143
97
25
28
19
130
10
7
26
9
9
%OF
TOTAL
ELIGIBLE
CUUIObB
FACILITIES
(A+B)*100/T
_____
__
03
38
47
100
90
78
7
942
2.1
9
3.9
9
*
3
4
e
7
9
1
10
14
4
22
40
e:\sbtcp98.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE, BY PROGRAM
(DATA FROM 19W SECTION 507 REPORT)
STATE
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
JeffCty.KY
JeffCty.KY
JeflCty.KY
JeffCty.KY
LA*
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
I A
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
INDUSTRY SECTOR
Asphalt Paving ft Roofing Material
Plastic Product*, Misc.
Structural Clay Product*
Concrete, Gypsum & Platter Product*
NonmetaMc Mineral*, Mtec.
Secondary Nonterrou* Mineral*
Nonferrou* BoWng & Drawing
Nontarrou* Foundrle*
Caring*
Primary Metal Product*. Misc.
Fabricated Structural Metal Product*
Metal Service*, NEC
Fabricated Metal Product*, Mbc.
Construction & Related Machine*
Special IndueWal Machine*
General Industrial Machine*
Industrial Machines, NEC
Motor Vehicle* & Equipment
Ship & Boat Building & Repair
Meas.& Cent Devices
San tary Service*
Farm Product. Raw Material*
Laundry, Cleaning, & Garment Service*
Membership Organization*
Engineering & Architectural Service*
Autobody Shops
Printer*
Dry Cleaner*
Misc. (meetly Coaters)
Dry Cleaner*
Crop Preparation
Veterinary Service*
Crud* Petroleum
Trad* Contractor
Tarrazzo, Tile, Etc.
ON ft Gas Service
Heavy Construction
General Contracting Ind.
Asphalt Paving
Printing, Commercial
TabtoOHi.Etc.
Chemical*
Plastic Plumbing Fixture*
Plastic Products, NEC
Concrete Block
Concrete Product*
Concrete, Ready Mbc
Fabricated Rubber
Fabricated Wire
Fsbrtctatod M0tftt Pfoducts
Metal Door*, Etc.
Akcieft
Electroplating
Fabricated Structures
Shipbuilding
Boatbufcttng
Fabricated Steel Plate
Coating/Engraving
Brick, Til*
Aluminum Foundry
Farm Machinery
Ordnance
Refute System*
Scrap Material
Chemical*, Etc.
Bulk Stations
AutobodyShop*
Auto Repair
Repair Shops
Prepack Software
Laundry, Coin Op
Engineering
I
NUMBER OF
ASSISTANCE
GENERAL ON -SITE
W (B)
3
4
2
1
1
1
2
1
1
1
1 1
2
1 3
1
1
1
1
1
1
2
1
2
1
1
14 10
24 16
14 3
414 47
8
2
3
12
1
2
4
3
3
1
6
2
1
8
e
10
13
2
14
2
3
1
1
Z
1
2
17
3
2
2
6
1
3
:s
TOTAL
(A+B)
3
4
2
1
1
1
2
1
1
1
2
2
4
1
1
1
1
1
1
2
1
2
1
1
24
40
17
461
5
2
3
12
1
2
4
;:
g
30
1
4
8
3
1
8
2
1
8
6
10
13
2
14
2
3
1
1
2
1
2
17
3
2
2
6
1
3
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
39
96
9
150
7
4
14
4
8
8
20
82
34
38
40
8
4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
230
226
175
825
714
2
3
12
1
2
57
1
1
9
52
3
13
9
38
2
34
56
10
8
12
27
2
15
43
22
64
24
30
4
3
12
1
2
1
3
27
775
5
6
6
1
3
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/t
8
4
22
1
14
25
14
25
13
13
10
3
11
3
3
13
25
to
9
10
50
0.8
100
100
100
100
100
7
100
100
11
4
33.3
a
100
80
50
12
14
30
13
50
7
50
S3
14
45
20
8
47
50
100
8
100
100
100
67
63
0.4
40
33
100
100
100
c:\»btcpee.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
55555
ME
ME
ME
ME
ME
ME
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
Ml
Ml
Ml
Ml
Ml
Ml
MN
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
INDUSTRY SECTOR
Minerals
Prepared Food
Paint Store
Water Transportation
Leather
Veterinary Incinerators
Auto Body Shops
Sawmills
Rock Crushers
Dry Cleaner*
LKho Printer*
Auto Body
Automotive MAR
Aggregate
Agriculture
Chrome Plating
Contractor
Degreaser
Dry Cleaner
Furniture Reflnlshlng
Gas Station
Small Manufacturer
Metal Coating
Race Track
Poultry Operation
Restaurant
Recycler
Paint Vendor
Solvent Vendor
Printers
Dry Cleaners
Wood Furniture
Metal Working
Metal Platers
Jewelry Manufacturing
Tool ft Die
Auto Body
Optical
Medical Instruments
Other Trades, Unspecified
Consultants/Attorneys
Manufacturers
Services
Trade Associations
Public Agency
Other
Does not operate any follow up.
Cash Grains
Poultry and Egg*
Crop Service*
Crushed a Broken Limestone
NonmetaMc Minerals Services
Construction, Residential
Construction, Nonrecldwitjal
Construction, Highway and Street
Construction, Heavy Except Highway
Contractor*, Misc. Special Trade
Meat Products
Preserved Fruits and Vegetable*
Grain MM Products
Fats and One
Beverages
Broadwoven Fabric Mills. Wool
Misc. Fabricated Textile Products
Logging
SawmWs a Planing Mills
MIHwork, Plywood a Structural
Wood Container*
GENERAL
(A)
33
181
122
11
1
2
35
33
2
2
15
15
3
600
3
35
3
5
1
1
3
1
2
2
600
1300
300
11
5
2
7
2400
2
2
261
275
211
57
16
61
21
11
6
18
61
6
6
1
6
12
8
9
1
8
9
8
4
24
14
11
NUMBER OF
ASSISTANCE
ON-SITE
(B)
1
1
2
1
1
0
1
0
0
1
8
0
0
0
0
2
0
0
2
0
0
1
0
0
0
0
1
0
0
11
2
10
4
2
6
3
2
2
59
2
16
2
1
1
1
1
:s
TOTAL
(A+B)
1
1
2
1
1
33
182
122
11
2
8
35
33
2
2
17
15
3
602
5
35
3
5
1
1
5
2
2
2
611
1300
302
21
9
4
13
2403
4
4
340
275
240
57
16
61
21
11
6
20
77
8
e
1
e
12
8
9
1
8
11
e
i
1
5
24
15
11
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
1
1
2
1
1
33
303
122
43
83
250
1000
2000
500
1000
30
2000
loooo
BOD
500
5000
500
500
100
25
500
100
25
2
1600
1300
500
1500
500
90
150
3600
50
60
22150
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/t
100
100
100
100
100
100
60
100
25
2
3
3.5
3.3
1
2
50
1
0.13
75
0.6
0.7
0.6
1
1
4
1
1
8
100
38
100
60
1.5
1.5
4.4
8.6
66
a
8.6
1.5
c:\tbtcp96.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 19tt SECTION 507 REPORT)
STATE
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MS
INDUSTRY SECTOR
I
Wood Product*, Misc.
Household Furniture
Partition* A. Fixture*
Printing, Com menial
Chemical*, Industrial Inorganic
Plastic* Material* & Synthetic*
Drug*
So*p, ClMfMra. & ToiM Goods
Paints* Allied Product*
Ch»mlc«l», Industrial Organic
Chemical*, Agricultural
Chemical Product*, Misc.
Ho** & Belling & Qa*k*t* & Packing
Fabricated Rubber Product*, NEC
PlaaHc Product*, Mtac.
Handbag* ft Penonal Leather Good*
Structural Clay Product*
Concrete, Qypeum, & Platter Product*
NonntetaHtc Mineral*, Mtsc.
Bleat Furnace & Bailc Steel Product*
Iron & Steel Foundrto
Secondary Nonferrou* Metal*
Nonferrou* Foundrle* (Casting!)
Metal Can* & Shipping Container*
Cutlery, Handtooh, & Hardware
Fabricated Structural Metal Product*
Screw Machine Product*, Bolt*, etc.
Metal Forging* & Stamping*
Metal-Service*, NEC
Construction & Related Machinery
Special Industry Machinery
General Industry Machtiery
Industrial Machinery, NEC
Electrical Industrial Apparatus
Houeehold Appliance*
Electrical Lighting & Wiring Equipment
Electronic Component* & Accessories
Electrical Equt>ment, Misc.
Motor Vehicle* & Equipment
Aircraft* Parts
Transportation Equipment Misc.
Public Warehousing & Storage
Airport*, Flying Fields, ft Service*
Pipeline*, Except Natural Ga*
Telephone Communication*
Electric Service*
Combination UWHy Services
Water Supply
Sanitary Service*
Motor Vehicle*, Part* & Supplies
Umber & Construction Material*
Metal* and Mineral*, Except Petroleum
Electrical Good*
Farm-Product Raw Material*
Nondurable Good*, Misc.
Grocery Store*
GaeoHne Service Stations
Furniture ft Home Furnishings Storage
Fuel Dealers
Retell Store*, NEC
Laundry, Cleaning, & Garment Services
Personal Services, Misc.
Business Services, Misc.
Automotive Repair Shop*
Hospitals
Elementary & Secondary School*
Business Associations
Civic & Social Associations
Engineering ft Architectural Service*
Research & Testing Services
Private Households
Auto Body Shop*
NUMBER OF
ASSISTANCE
GENERAL ON -SITE
(A) (B)
33 2
11
11
8 1
48 14
12
S
8
8
40
28 1
3 4
43
8
8
13
3 1
5
18 1
1
7
1
8
5
6
5
1
1
10 3
8 2
10 2
8 2
11
13
22
8
4
a
8
14
12
8 1
10 4
12
a
5
35
8
a
51 1
a
12
a
a
18
8 1
21
38 5
a
41 3
1
71 a
5
10 1
7 1
27 1
11
14 1
5
708 5
18
a
180 20
I
8
TOTAL
(A+B)
35
11
11
10
82
12
5
6
8
40
28
7
43
6
8
13
4
5
18
1
7
1
8
5
6
S
1
1
13
11
12
10
11
13
22
6
4
a
a
14
12
7
14
12
a
5
35
8
8
52
6
12
6
a
16
10
21
43
6
44
1
77
5
11
8
28
11
15
5
713
18
8
180
NUMBER
OF
ELIGIBLE
FACILITIES
(0)
600
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/[
30
c:\sbtcpae.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1MB SECTION 507 REPORT)
STATE
MS
MT
MT
MT
MT
MT
MT
MT
MT
MT
MT
MT
MT
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NV
NH
NJ
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
INDUSTRY SECTOR
Dry Cleaner*
Auto Repair Shop*
Service Station*
Auto Dealer*
Furniture Dealer*
Dry Cleaner*
Small Manufacturing
Chromium Electroplating
Printers
Educational Institution*
Qa« Distribution
Bakery (only 1 subject to TWe V)
Publisher*
Dry Cleaners
Auto Body Painting
Sand & Gravel
Concrete Batch Mix
Fabricated Metal Products
Printing Trade
Plastics ft Synthetic*
Chemical A Fertilizer Product
Food Processing
Grain Elevator*
Electroplating
Sawmill*
Wood Product*
MlnlnanWUttng- Metal
Military
Realty
Government
Plastic*
Gustations
Engineer/Consultant
Citizen
OH Company
Newspaper
Laboratory
Casino
Construction
Auto
Agriculture/Ranch
Asbestos
Unknown
Not yet tracked.
Data not available.
Sand & Gravel
Concrete Batch
Dry Cleaners
ooaoas
Manutacturtig, Tank
Manufactures, General
Manufadurkig.Wood
Electronic*
Construction
Foundries
Apartment Home*
Automotive/Auto Body
Bakery/food Processor
ChcmfcaVPIattfc*
ComuttantK/Attomeys/Venckirs
Construction/Contractor
Crematory
Dry Cleaner*
Electronic Product*
Environmental Equipment
Fuel Dtap*n*lng/eulk Storage
Graphic Arts
| NUMBER OF
ASSISTANCE
GENERAL ON-8ITE
(A) (B)
87 9
343 7
25 3
75 17
92 1
64 12
23 16
0 5
24 0
8 1
5 0
1 0
3 0
12 4
15 3
10 3
15 5
16 11
24 3
8 4
5 2
10 2
8 1
4 2
3 1
2 1
3
1
3
10
1
8
7
37
2
1
3
1
41
7
2
23
420
6 2
1 0
11 3
3 1
1 0
5 1
354 0
1 1
2 1
1 1
3
18
87
7
184
7
1
28
5
4
13
X 1
:s
TOTAL
(A+B)
86
360
28
82
A3
to
39
5
24
7
5
1
3
16
18
13
20
27
27
12
7
21
7
8
4
3
3
1
3
10
1
8
7
37
2
1
3
1
41
7
2
23
420
8
1
14
4
1
6
354
2
3
2
3
19
87
7
184
7
• 1
26
5
4
13
31
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
395
>eoo
>300
>200
162
96
>1000
8
112
>40
>40
1
>15
238
627
173
206
125
382
unknown
245
63
450
21
14
129
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
3934
675
3536
596
4477
3824
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/I
24
se
10
46
57
100
4
63
21
18
13
100
20
7
3
7
10
22
7
5
3
25
2
29
29
2
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.48
1.04
0.79
0.84
0.29
0.81
c:\tbtep86.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
ND
NO
ND
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OK
OK
f^
UR
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK
INDUSTRY SECTOR
Gravel FUs/AspharVCono-ets
HVAC/PkimUng
Hospitals/Nursing Home*
Machine Shop
MAnutactufwv
Malal Finishers
Metal Platers
Misc.
Print Manufacturer
School
Soul BinkMM Support Groups, Chambe
Surface Cotton
Utttty/CombusUon
DryCteeners
Cotton Oh*
Plastic Molding
Uniform Service
Emergency Gam.
Electric Motor Repair
Concrete, nMu*y Mix
Wood Furniture Industry
SawmN/Lumber
Smell Boat Manufacturing
Metal Fabricators
Printers
Chemical Coatings
Fur Dressing
Chromium Electroplate™
Smafl Grain Elevators
Tire Cord Manufacturer
Asphalt Plants
Business, Misc.
Consultants
Individuals
Incinerator, Operator*
Chromium EtectropMm
Wood Furniture Manufacturers (2 mailings
Auto Body Shops
Printing
Fabricated Metal Products
Rubber 4 Plastic Product!
Wood Products
AMQM, PniiMfy
Stone Quarries
Chemical Manufacturers
Feed/Grain Elevators
Machinery Manufacturing, Misc.
Misc.
Schools
Consukants
Membership Organization*
Gas Stations
Churches
Oi & Qas; Misc. Petroleum
Wood Products. Furniture/Fixtures, MIMwo
PnftWlQt CoMlMTCIsM
Structural Clay Products
Engines a Turbines
Construction Machinery
Electronic Components
Trucking Terminals
Qas Production/DMrbutlon
Automotive Dealers/Service Stations
Laundry
Automotive Repair Shop
Cokegee, UnKwsMes, A Schools
Tires 4 Innertubes
Others Not Identified
..
GENERAL
(A)
_____
B
46
4
1
36
14
19
64
6
2
147
62
22
18
4
2
2
2
1
3
12
2
1
12
2
4
1
2
2
3
3
13
10
44
43
3
100
22
139
64
15
16
12
4
14
21
34
41
18
19
44
7
85
7
3
2
50
35
0
0
0
1
45
10
5
5
22
2
-1100
NUMBER OF
ASSISTANCE
ON-STTE
(B)
6
4
2
1
2
1
0
0
2
12
2
2
2
2
2
1
0
3
2
1
1
0
0
0
0
0
14
14
13
7
6
4
3
3
3
4
16
0
0
0
0
0
1
6
2
0
0
10
1
1
3
0
0
0
0
5
2
0
0
S
TOTAL
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1MB SECTION 507 REPORT)
STATE
OR
OR
OR
OR
OR
OR
OR
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PR
PR
PR
n
RI
RI
RI
R
RI
RI
H
RI
SC
SC
SC
SC
SC
sc
sc
sc
| INDUSTRY SECTOR NUMBER OF
ASSISTANCES
•
1
1
- 1
| Dry Cleaners
| Metal Panting
j Chrome Plating
j Freon Recycling
| Wood Coaling
j Auto Repair
j Construction
1
| Forestry
j Mining & Quarrying
j Construction, Heavy
| Construction
j Food a Kindled Product*
j Textile Mm Manufactory
j Lumbar & Wood
| Furniture Manufacturrig
j Paper Manufactory
I Printing iPubtehhg
| Chemical Manufacturing
| Petroleum Refining
| Rubber a Plastic Manufacturing
j Leather Product*
| Stone, Clay, Glass Manufactory
j Metal Manufacturing, Primary
j Fabricated Metal Manufacturing
| Industrial a Commercial Machlng Manufai
j Electronic Equipment Manufacturing
j Measuring a Analysis Instrument Manufac
| Misc. Manufacturing Industries
j Electric, Gat, & Sanitary
j Wholesale Trade
1 Auto Service Station
j Fleal Estate
j Personal Services
j Auto Repair Services
| Health Services
j Coal Mining
j Oil & Gas Extraction
| Apparel Manufacturing
j Agricultural Services
| Transportation Equipment Manufacturing
| Local/Suburban Transit
j Transportation By Air
j Transportation Services
| LegaJServka*
j Educational Services
j Membership Organizations
| Engineering a Accounting Services
j AdmhiMratrve-Env^onmental Program*
j Non-classBable
1
1 Dry Cleaners
j Auto Shops
| Woodworking Shops
| Wood Products
j Chrome EkKtrophfera
j Chemical Manufacturers
j Metal Finishing
j Textile
| Auto Body
j Marine
j Printing
| PI P2 Conference a Expo
j Dry Cleaner*
| Consultants
j Wood Products
j Manufacturer
j Government
j Painting/Coating
j Solid Waste Processing
j Grain Facilities
GENERAL ON -SITE
(A) (B)
73
5
10
16
33
2
5
7
6
11
6
30
5
5
25
13
39
77
22
18
3
28
26
101
51
60
12
IS
34
27
14
15
87
8
2
1
3
17
14
36
200
238
98
45
50
35
2
1
1
15
12
28
2
2
700
30
24
12
12
12
16
7
5
2
0
0
0
0
0
0
0
0
0
0
1
0
0
1
0
0
0
0
0
0
0
4
1
1
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
50
25
45
0
0
1
10
4
40
0
1
1
5
2
3
2
1
TOTAL
(A+BJ
75
5
10
16
33
2
5
7
6
11
6
31
5
5
26
13
39
77
22
16
3
28
30
102
52
61
12
15
34
27
7
15
15
67
8
2
1
1
1
1
1
1
3
17
14
36
200
238
98
95
75
80
2
1
2
25
16
68
2
3
31
24
17
14
12
19
9
6
NUMBER
OF
ELIGIBLE
FACILITIES
(C)
475
416
150
350
178
2183
960
139
425
2573
12039
999
364
1650
325
S75
4703
607
109
60S
66
914
582
2108
3224
677
258
2087
1366
3545
5712
23102
1412
170
290
3220
266
150
1500
450
107
20
SB
313
106
40O
40
60
%OF
TOTAL
ELIGIBLE
FACILITIES
(A-fB)*100/t
16
1
7
S
19
inslg.
Inslg.
5
1
1
1
3
1
1
8
2
1
12
20
2
4
3
5
5
2
9
5
1
2
1
1
1
1
1
1
1
1
63
5
17
2
5
3
6
15
17
5
c:\sbtcp96.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING, ASSISTANCE. BY PROGRAM
(DATA FROM 1986 SECTION 507 REPORT)
STATE
8C
8C
8C
80
8C
sc
ow
SC
8C
8C
SC
80
SO
SO
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
VT
VA
VA
INDUSTRY SECTOR
Cotton Ota*
Chemical
TextJte*
Metal FkiMikig
Boat Man ufactu tar
Foundry
FfeergtatMMarbta
Conttructon
fTrl»l8ar
rnnwr
MuntefcMl W«M» Undfltlt
Wood Furniture
QaaollncDIetrlbutlon
Chrome Platen
Dry Cleaner*
Local Government
Metal Stamping
Printing
Private/General
SchooMCoHegee
Government, State
Wood Manufacturing
Auto Service*
nocycwrv
Mfcc.
Thermoeet
Auto Repair
DryClMiMra
Prlnten
Wr ood Products
Foundrta (Included In metal flnfcher.)
Auto Body
Metal Flnlehen (include* foundrtee)
Manufactures
Mbc.
WoodHrfnltheft
Wood RcDnhhcn-maMngi
Wood Reflntohwt-phon* eaJh
Wood n0flnnihttfs^pM niRUfiQ
n»i«ii.i»
rnmvrv
Prlnttra — m AHin gs
Prlntwv-phon*>caHs
Pnirtws ^ pww Win Q
Print>c > — pf contain on>
Auto Body (Wlntotilng
Auto Body Rrilniching-phon* rate
Auto Body Rtflnithlng-pwnMIng
DryCtanlng
Dry Ctankig-nuWng*
Dry dewing- phone cats
AggngaaVConcreta
AggregatwConcreta- phone eah
Aggragala/Concrete-permlttIng
AggntgBaVConcrete^pnaMntalfOfie
Chrome Platen
ChfOflW Pta4aW%" IfltWlflQeJ
Chrom* Platera-phon* call*
Chronw Platara— permHUng
Manufacture*
Manufacturer*— maUhige
Manu(aeturef»-phone caBt
Manufacturer* -permitting
Manufacturing vpreeefltatione
Ethytene Guide
Elhylen* Oxide- maiBng.
Noreaponae
Dry Clean en
Dry Cteenen-dkect compliance
I
NUMBER OF
ASSISTANCE
EHAL ON-8ITE
*> (B)
4 2
5
5 2
8 2
3
5
2 1
3 1
2
2
15 2
46 0
8 0
25 1
100 1
28
12
500 31
48 3
6
32
480 20
23 14
31 15
81
78 1
258 1
255
338 1
1388 58
245 26
644
517
18077 11
2
254
48
44
15
280
27
35
30
1
27
13
6
258
10
8
18
4
SO
2
58
13
3
238
84
1
50
2
560 0
68
•8
-
TOTAL
(A+B)
____
6
5
7
10
3
5
3
4
2
2
17
45
8
28
101
28
12
531
51
6
32
480
37
48
81
80
258
255
339
1442
271
644
517
16003
348
387
41
272
82
76
374
2
628
NUMBER
OF
FACILITIES
(C)
n _rn — .
.
15
45 '
10
68
3200
132
878
26214
2352
8970
1711
200
5178
2782
15784
230
270
400
260
200
30
5000
2
750
%OF
TOTAL
ELIGIBLE
FACILITIES
(A+B)*100/[
113
100
60
38
17
38
8
1
17
2
87
11
34
a
150
143
10
105
41
253
7.5
100
83
e:\abtcp88.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VI
VI
VI
VI
WMEcolog
WA (BCCAA
WA(BCCAA
WA (BCCAA
WA (SCAPC
WA (SCAPC
WA (SCAPC
WA (SCAPC
WAfYRRCA
WA(YRflCA
WA(YRRCA
WAfYRRCA
WAfYRRCA
WA(YRRCA
WA(YRRCA
WA(YRRCA
WAfYRRCA
WA(YRRCA
WAfYRRCA
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
Wl*
Wl
Wl
Wl
Wl
Wl
Wl
Wl
WY
WY
WY
WY
WY
WY
WY
WY
WY
INDUSTRY SECTOR
Printer*
Printer* -direct compliance
Wood Furniture Manufacturer*
Wood Fumltuni- direct compliance
Structural Steel Fabrication
Commercial Boiler
Service Station*
Ethylene Oxide Sterilize™
Electroplate™
SawmiH*
Plartc* Unsupported Sheet
Auto Body Shop*
Charcoal Manufacturing
Lanemto
Dry Cleaner*
Printer*
Air Condition
Auto Oarage & Repair Shop*
Dry Cleaner*
Dry Cleaner*
Cabinet Shop*
Auto Body Shop*
Dry Cleaner*
Surface Coating
Chrome Plating
Graphic Art* & Lttho Printing
Dry Cleaner*
Ftbergla**
Printer*
Qa* Station*
Feedlot*
Dakte*
SanoVQravel
Construction
Agricultural
Wood Product*
Spray Booth*
Asphalt
Automotive
Coal Preparation
Concrete
Consulting
Dry Cleaning
E wctroputtin 9
Gasoline attribution
HVAC
Manufacturing
Metal Bntehbig
Mineral Proceulng
Mice.
Printing
Surface Coating
Dry Cleaner*
Adheth**, Induatrlal
Automotive Service*
Chromium Electroplate™
Aeroepace
Rock Cruehera
Wood Flnl*h*f*
Printers
Chrome Plater*
Dry Cleaner*
Auto/Truck Maintenance/Painting
Auto Wrecking
Wood Manufacturing
Newspaper Publishing
Trona Proce**
Government/Federal Facilities
Electric UtillBe*
I
NUMBER OF
ASSISTANCE
GENERAL ON -SITE
(A) (B)
48 0
5
428 2
130
2 1
1
1
1
3
2
1
7
1
2
16 0
15 8
5 5
10 10
900 2
2 3
1 5
1 B
38 4
B
102 12
5 2
3 Z
6 3
152 115
SO 11
6 3
4 2
5
7
4
9 3
10
54 10
41 6
2
5
49 13
22 4
41 4
3
16 2
326 15
60 0
609 15
119 0
21 0
67 0
223 2
235 4
6 0
2 1
164 0
1 0
72 0
1 0
5 0
1 0
1 0
:s
TOTAL
(A+B)
50
427
3
1
1
1
3
2
1
7
1
2
16
10
10
20
902
7
6
9
40
170
7
50
43
5
114
3
2
4
267
61
5
6
5
7
4
12
10
64
10
2
5
32
26
45
3
18
341
60
624
119
21
67
225
239
6
3
164
1
72
1
5
1
1
NUMBER
OF
FI miRi F
CL>l\3IDl_C
FACILITIES
(°)
350
1257
74
N/A
N/A
4
80
138
8
N/A
1
N/A
16
40
84
205
900
16
5
18
73
40
N/A
250
N/A
N/A
80
20
N/A
N/A
N/A
50
N/A
320
SO
400
120
150
300
425
420
5
40
unknown
~28
unknown
unknown
5
unknown
7
%OF
TOTAL
PI IC3IRI P
CLIUID^C.
FACILITIES
(A+B)*100/t
13
34
4
25
4
1
11
100
100
25
12
10
100
12
2
81
50
52
107
120
156
99
14
29
53
56
125
8
100
16
c:\»btcp86.wk3
-------
APPENDIX E-4
SUMMARY OF INDUSTRY SECTORS RECEIVING ASSISTANCE. BY PROGRAM
(DATA FROM 1996 SECTION 507 REPORT)
STATE
WY
WY
WY
WY
TOTALS
INDUSTRY SECTOR
01 (Mining
Coal Mining
Contractor, Qenwal
Qamral Butlmra
NUMBER OF
ASSISTANCES
GENERAL ON -SITE TOTAL
(A) (B) (A+B)
1 0 1
1 0 1
1 0 1
250 0 250
66688 3833
NUMBER
OF
FACILITIES
(C)
4
23
unknown
unknown
%OF
TOTAL
FACILITIES
(A+B)*100/C
25
4
c:\Jbtcp86.wk3
-------
TABLE E-5
SBO OUTREACH ACTIVITIES
ftOQOHn
Alabama
Alaska'
Arizona
Maricopa Cty
P!m*Cty
Arkansas
California
SCAQMO
Colorado
Connecticut
Delaware
Dittrict of
Columbia*
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansa*
JSSDlucJa
Mi
1
a
17
20
N/R
Ye*
100 +
178
7
25
Many
None
Yet*
11
N/A
4
30
40
20
26
13
•tint*
20
1OS
82
60
1,000 +
Unknown
49
1,100
Not ture
'100
N/A
100
150
"3OO
500
723
•peaMflfl Event*
14
24
32
6
3
Dozen*
88
3
25
3
Yes*
12
10
2
6
4
12
681
1,723
1,200
120
200
Hundred*
2,040
36
1,300
150
500
2OO
300
112
50
410
Ntttn6«tc
PWWHIM / T ttonntow
A«el*tence One,
hOtfllM *nd maMnti*)
2
?
Yes
42
2
132
N/A
42
f •^WWWW I^RIWCHM
Medfct COMMA*
1
6
N/A
87.900
1 Number of tw*iiM**e« or Individuals ft**ch«d
Tra4*8hmM
Conference*
2
117
600
Unknown
N*«nWtt*n
4
2,100
quarter!
V
Pm6pt|pe*jf
Flyer*
12
8
3
40 +
S.487
2
15
4
Yes'
12
2
30
2
2
1
3,846
10,000
8OO
Thouaand
*
5,407
700
10,000
500
600
2,000
10,000
203.OOO
1.000
2.000
• fwtwti
9
10
7
3
18
9 +
131
11
25
2
6
1
1
1
10
lee«lBi»a
20
232
300
200
415
Hundreds
Unknown
138
1,000
40
350
50
30
225
1.625
Otter
46*
14*
15
3'
i:
45
36
35
24
2,000
3.OOO
150
-------
TABLE E-5
(Continued)
-^^^^
noe^m
Jofferaon County
Loutelana
Maine
Maryland
MaeaaChuaette
Michigan*
Mbmeeota
Mbtfcsippi
MiMouri
MontMW
Nebmka
Nevada
New Hampshire
New Jartay
New Mexico
New York
North CaroHna
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
ir.' '. MumbaM
Mf
2
NoftA
3
None
None
12
20
6
U-____
nonv
30
54
16
7
4
3
48*
14
Yea
79
32
1.384
200
6OO
8.380
600
1.340
261
91
20
60
2.000
476
:• Jpee*
7
None
14
None
6
4
*
None
6
20
Yea
9
1
5
27
10
No
4
176
1.231
160
200
460
260
732
305
S63
30
100
1.239
300
126
*M«MH*/r«««H*Mf
Aeeleteno* flrw*
280
250+
Yea
7
^fgua^^^MM ikAaVflftatt
r Cofrfwwrte*
2
Yea
Unknown
75
fltataM
. . .f^Wl
12
1
arfteaM
PwWf*
3,326 /
month
3,000
1
3
None
None
4
12
None
14
3
2
1
0
7
4
Yea
3,600
***•
2.430
600
60,000
632
3.350
50
300
0
89.000
600
3,500+
4
tllrtrtal
nonw
None
2
13
ail
ffwnv
3
21
Yea
1
0
8
No
4
eteMMfaMIV
80
60
620
60
724
20
24
0
600
125
3'
None
8*
62»
e1
0
27*
1
Note*
15'
300 +
16,000
80
76
60
0
1,030
35
15
250+
Combined w/SBAP
None
None*
-
-------
TABLE E-5
(Continued)
PvDtjsMt
Puerto Rico
Rhode Island
South Carolina
South Dakota
TMVMftee
Texas
Utah
Vermont
Virginia
Virgin Island*
Washington
Wast Virginia
Wisconsin
Wyoming
TOTAL*
MiiinWof$«M^>^¥tdW/M«rtwofBus^.iiSQTlMvMuafc
M**Dnfjv
Nona
70
40
106
26
138
Nona
31
None
N/R
16
25
3
1,469
200
100
260
625
86O
1
N/A
65
12
21.634
9»*e«jna Event*
1
8
25
25
10
Nona
5
None
4
3
447
75
150
1,215
861
600
1.000
220
N/A
19,662
P^hVft^MI^ 4 TeMfAMfafoBafl
boHfte ami rna«noa)
260
17
37,328
60
125
38,104
260
17
37,328
250
125
38,396
MMfe Coverage
4 +
2
11
1 4.000 -f
18,000
119,900
* — *
TWMMI Snows;
Cenfeferiees
5
3
4
133
500
260
1.000
2,425
Newstettew
4
3.000
Included in Table
E-8: Fact sheets.
Manuals, A Info
Packets
1
22
3,500
14,926
•W
3
too
7
16
titles
•Mninai
6
None
16
1
9,292
•
rtW
1.500
100
4.081
23,800
dist.
6,600
1,000
600
N/A
437,265
Taie^e£t«to £^^^^^^
Yes
1
63
48
e
•vt.»_._
2
None
2
422
30
750
1.347
400
90
7O
9,605
OtNet
26*
26*
3*
3*
1
3'
6*
1*
670
26
25
142
425 +
20
BOO
1 (SBO)
23,986
Totals do not reflect anawer* such as, *yes." Figures such as 500+ are tallied as 500.
•Notes:
AK SBTCP database was not in use until July 1, 1996. Therefore, the numbers listed are only for a 6 month period.
AZ Permit application assistance.
CO Small Business Environmental Fax Network: 14 fax alerts were sent on topics related to environmental issues such as state legislation, rule-making hearings, task force work groups, and other small business
issues. Information sent to 35 member network, of which 17 are trade group representatives.
State Legislation Outreach: Tracked 15 bills on environmental legislation. Related information to businesses and trade groups through the Small Business Environmental Fax Network. Information sent to 35
member Fax Network.
-------
TABLE E-5
(Continued)
DC Nan*. SBO petition vacant for mo»t of reporting parted.
PL Ombudsman's office I* combined with tha SBAP.
IA 3 focu* groupa.
KS 1 permit guidance document.
1 service guide.
1 community regulatory guidebook (only recently printed).
Ml SBO poaition vacant from June through Auguat 1996.
MS 6 teleconference*.
MT 62 aite vltita and 2 permitting guidance.
NO The Governor'i Office and the SBOC regional office* received copies of the 'Environmental Self-Evaluation Guide" developed by the SBO and SBAP. An unrecorded number of guide* were tent out upon
request to bu*ine«*e*. An unrecorded number of mailing* of pollution prevention information were made to bu*bie**e*. An unrecorded number of referral* were made to regional SBDC*.
NJ 6 ta*k force*.
NY Meeting* attended, but did not plve presentation*.
27 aupport group meetings/seminars and 1 teleconference,
OH 16 trade aiaociation membership outreach manual* and 300 printing Industry environmental manual*.
PA Ombudaman position vacant aa of April 1996. Information unavailable.
SO 26 telephona/fax/e-mail contact* from other state SBO* and SBAP*.
25 internal contact* with SBAP.
TX 3 video teleconference.
VA 1 fact sheet for wood furniture manufacturers and 2 fact sheets for RACT printing regulations. Participated in state regulatory development for NSR. State Operating Permit*, PTE Exclusionary Rule, federal
regulatory development SBREFA process for PTE.
WV 3 Panel Secretariat.
6 professional/trade organization.
WY Visit to Colorado CAP (training).
Brochures/Flyers Total: SCAQMD, CA and Ohio both apparently reported the number of brochures/flyers distributed rather than the number of title* developed; therefore, this number i* high.
-------
TABLE E-6
SBO TOLL-FREE HOTLINE INFORMATION
PROGRAM
Alabama
Alaska
Arizona
Maricopa County
Pima County
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
NATIONAL
800-533-2336
None
None
None
800-333-7798
None
None
None
None
800-357-6087
800-926-8111
None
800-433-1247
None
None
IN-STATE ONLY
800-510-2332
800-234-5677, x4337
800-ARB-HLP2
800-388-2121
800-789-4599
645-6093, x3082
800-722-7459
800-EPA-1996
800-451-6027, X2-8598
800-351-4668
800-256-1488*
800-789-9802
800-985-4247
-------
TABLE E-6
(Continued)
PROGRAM
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virainia
NATIONAL
None
800-433-8773
None
800-643-6090
800-810-7227
800-STATE-NY
(800-782-8369)
800-829-4841
800-869-1400
None
None
800-819-9001
800-734-3619
800-447-2827
None
None
None
None
IN-STATI ONLY
800-725-6112
800-992-0900, x 4670
800-837-0656
800-755-1625
800-225-5051
800-452-401 1
800-932-1000
800-GET-DENR
800-592-5482
800-982-2474
-------
TABLE E-6
(Continued)
PROGRAM
Wisconsin
Wyoming
NATIONAL
800-435-7287
None
IN-STATI ONLY
•Notes:
LA Closed November 1, 1996
-------
TABLE E-7
SBAP OUTREACH ACTIVITIES
_
Alabama
Alaska*
Arizona
Maricopa Cty
Pirns Cty
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson Ctv
Oenenl
Yes
707
1,322
120
24
1
780*
Hundreds
9,226
500
400
Yes
20
Yes
728
N/A
130
4,293
2,497
848
244
35
Yes
1,200
707
1,322
120
30
4
780*
Hundreds
9,226
500
300
30
20
N/R
650
130
4,293
2,254
N/R
244
35
Oft-Sfte VMt»
23
45
46
37
1
Hundred
s
2,339
22
325
6
1
25
8
413
132
38
59
Yes
23
46
56
60
13
Hundred
s
2,339
22
325
N/A
1
20
8
365
N/R
38
59
Number of «etvtce* PravMe* / Htiml
(P^pWPIUWpjt WOwwflOpWf
Meetinpe, etc.
30
10*
7
6
4
18
Hundreds
250
24
Combined
w/SBO
No
3
14
69
4
40
5
22
31
25
Yes
1,400
232
300
500
140
415
1,000 +
Unknown
36O
200 +
1,000
-1,000
7
2,310
2,148
N/R
1,000
7
Feet
liaVinftaJb
Packets
12
8
4
7
Hundre
ds
2,861
3
15
Yes
1
5,000
7,530
3
110
>4
11
?
3,845*
10,000
5,000
1,500 +
Thousands
2,861
1,500
5,000
200 +
5,000
7,000
7
6,603
N/R
1,400
?
Mr of Businesses or IndMdWNe Reached
Newdettere
4
7,000
It i Hi i tl n
roniwQfi
*ManZlS»
7
_
192
16
N/R
3
Yes
100
o
Hundre
ds
1*
2*
7,200*
1,318*
the*
Hundred
§
7
850
7
-------
TABLE E-7
(Continued)
•Mk4M*Mt
rrogfajn
Louisiana
Maine
Maryland
Maeaachusetta
Michigan
Minnesota
Misaiealppi
Missouri
Montana
Nebratka
Nevada
Naw Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
OltlflhOfTIA
•aJiiiiJiaVi nt atanffi~Aat ftiiiutilM t Mmirfiaii irf •hMtnMBBi nt InfatMflftiieaaaai ftflMiilfra if "
Penan*
742
164
Yea
210
641'
2.685
Yea
Yea
N/R
780
43
659
467
200
N/A
220
N/A
991
1 1OO
742
164
1,200
210
641
N/R
N/A
780
43
659
467
200
421
220
"500-1,000
6OO
1 100
OMHM
207
12
8
?•
29*
76
36
Yea
42
N/A
22
9
25
N/A
36
Yea
118
26
VWft
207
12
8
93
29
76
36
42
N/A
22
15
25
11
36
N/R
109
26
M**dfM
39
13
7
17
22*
2*
71
13
Yea
21
N/A
5
23
14
24
8
1
12
12
j», **». *"'
760
3,279
600
720
244
470
Hundred*
540
724
N/A
226
740
280
918
600
40
372
2OO
Fe)9f wHsetKr
Manual^ brfQcmMew
facXetB
4
6
800
Yea
61
3
5
641*
Yea
36
500
603
110
3*
4
6
74
2
200 +
761
1,500
2,250
61
1,174
N/R
641
36
500
6O3 +
450
140/190/75
100
215
74
20
T§VirlWW**W^*
4
12
Yea
1
2
3
2,000 +
3.3267
moiitfi
120
9,000
1,500
ft*
»-,., ,.
mv
.. A«*h
18
2*
5
&
N/A
87
40
rMMBR •HO
CDM!MW*
yfffccirtflit
Yea
2*
4"
30
135
90
300
3O
<135
TaaaaaWM^aaa!
2
1
6
6
180
60
90
39
m
i*
3«
11*
8*
19*
4*
T
7*
**.. .
N/A
N/A
681
•
11
N/A
19
23,000
7
105
-------
TABLE E-7
(Continued)
*°'~*
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina*
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
Ecology
Ecology
BCCAA
OAPCA
SCAPCA
Number of
-------
TABLE E-7
(Continued)
PCwflttPif
SWAPCA
YRCCA
Watt Virginia
Wisconsin
Wyoming
TOTAL*
... ... NUffMMf OV.V9(M049 FlOVMIMI * PWWi
ft*****)
7
1,327
264
696
13
37,494
136
1,327
138
696
276
36,411
' flfr-fty **«*
240
41
36
6,348
240
33
35
5,326
*»^ ^^l^ ,
UMMiin
2
4
48
3
1,364
!»,•«-
18
30
2,286
90
36,433
Manual* tntaSiirtk*
Packet*
2
N/A
24
13
21513
192
400
25,983
306
117936
ajaiyeiESttairt
-
33
26846
**1*»»*
f^tMtoM
2
28
2
1029
PMMK fllMi
O0fHB*t*MMMB
Awiwiiiftsji
21
9
641
21
9
840
4
27
8
640
y«tem.
ID 1 «urv*y: Potential MACT Printer*
IN 2 mat* mailing* don* by ga* oompanle* on behalf of IDEM to inform customer* of regulation*. Electronic *«*i*tance: FaxBack-7,200 fax** *nd IDEM Onlloe-1,318 hit* (la*t half of 1996)
LA 1 web page
4 media interview*
3 targeted letters
Ml 641 telephone and In-penon request* for technical assistance (FY95-96).
29 facility tour* and consultation* (no on-tita audit*) by SBAP *t*ff (FY95-96).
22 seminsrs, workshop*, meeting*, etc. that were Insisted externally from SBAP, but included participation by SBAP staff (i.e., a* speakers, resource staff, etc.) (FY95-96).
2 workshops Initiated, developed, and delivered by SBAP (FY95-96).
MA Since SBAP constitute* a subset of OTA activities, only those services and workshop* dealing w/SBAP activities are listed.
MS Auto body shops
NJ 2 P2 for Smell Business Conference
2 Environmental Air Compliance Audit Seminar; 4 Air Permit Workshops & Air Waste Management Conference
NV 11 referrals.
NH 8 EPA Initiative meeting*.
NY 2 Issues of newsletter (Issue 1:4,000, Issue 2: 6,000). Draft* of 3 compliance guides: 140 surface coators, 19O graphic arts, 76 gasoline transport.
OH 19 customer meeting*, 4 mas* mailings, and an unknown number of "hit*" on an electronic BBS and internet homepage.
OK 7 special projects.
-------
TABLE E-7
(Continued)
OR 35 state SBAP», 9 stratospheric ozone. 10 consultants, 25 other (hazardous waste, solid waste, water).
PA 13 Air Quality Imptovement Fund (loan program)
Computer Bulletin Board: 788 contacts/165 new u«er»
28 resource center*
Rl 160 general assistance and on-elte vialt data era eatimate* baaed on afforta of the SBAP with technical support from pollution prevention engineering ataff.
1990 Rhode Island Pollution Prevention Conference and Exposition drew about 700 people over three daya In October. A satellite downlink wa* hosted In May for approximately 30 lithographic printer*.
SC Figure* for SBO and SBAP combined. 4 enforcement negotiations (with SBO).
TN 35 ISBMQ, 1,060 notification*.
UT 2 trade shows/display booth, 2 permit amnesty program*.
VA Served as sponsors and hosts for Wood Furniture and Printing Downlinks at 21 SBOC centers through 2 coordinating offices providing P2 and compliance training to constituents.
WA 1 City/County Pre-Development Conference.
1 NOC/NOI Process.
1 SEPA Process.
WY Visit Colorado CAP meeting.
-------
TABLE E-7
(Continued)
PUBLICATIONS
A number of states provided list, of their avafaMe pubfeation..
CONNECTICUT
Small BtMbnatt ABtlrtanc* Ptoorani Brochure
toNcv Statement and Certificate on Tax CredKe^ Exemption, for Air *>»utlon Conttol Equtoment
Title V Operating Permit Program Booklet, "It1. Time to Decide; If Your Facility i. Subject to tltto V
Fundamental Awlrtance for Small Tltto V Source. (FAST V.) Training Manual
Quid, to EmlMkm Factor*
Compliance Kit for Auto Body Shop*
Compliance Kit for Matal Ftotoher*
Compliance Ktt for Dry Cleaner.
FactShMt on the General Permit to Unit Potential to Emit
KENTUCKY
Publication, prepared by KY Small Bu.lne*. Environmental A..i*t>nce Program
Brochure - Qood New. for Small Business
Training Manual - The Clean Air Act and Your Small Business
Workbook - Kentucky DM.ion for Ah- quality Refrigerant Guide
Workbook - Clean Air Act Compliance for Chromium Emis.loni from Electrolytic_Proce««
Handout - Design Criteria for Stage I Vapor Control Syttem Gasoline Service Station.
^ Sh"*tFlnal Rule Equivalent Emission Limitation. Underth., CAAS1112W), 4/29/94
Final Air ToJSc. Rule for Controlling Ethytene Oxide Emtoaion.. 11 /21 /94
- Final Air Toxic. Rule for Aeroipece Manufacturing. 7/31/96 0«.«ie
Supplemental Notice Propo.4ngRevi.ion. to theCAA Operating Permte Regulation. 8/21«S ,,,..„,««
- Proposed Rukmaking for Constructed, Reconttnicted. or Modified Major Source. Under Section 112(g) of CAA. 3/1/94
Final Air Toxic. General Provtekm. Rule. 3/1/94
Proposed Open Market Trading Rule for Ozone (Smoo) FY.cur*or.
- Rnal Ak Toxic, for the Petroleum Refining Induttrv. 7/28/96
- Propoced Ah- Toxic* Rule for the Secondary Lead Smelter InduMry. 5/31/94 H/IK/OA
- Final Air Toxic. Rule for Chromium Emi..ion. from Hard and Decorative Electroplating and Anodizing Operation., 11/1 b/84
Final Air Rule, for Marine Tank Ve..el Loading Operation., 7/28/95
I Proved &Tf£&«M the M-nuf^ture of Ba.ic Liquid Epoxy Re.in. «xi Non-Nyton Poly.mid. Re.ln.. 4/29/94
- Proposed Rule, for Marine Tank Vessel Loading Operation., 4/29/94
Publication, prepared by Kentucky Air Quality Ombudsman
. Brochure - Kentucky Small Business Stationary Source Technical and Environmental Compliance A««i«tance Program
• Plan - Kentucky Small Bu.lnes. Stationary Source Technical arid Environmental Compliance As.istance Program
• Column - "New. from Air Quality Ombudsman,* March-October 1996
LOUISIANA
Document, distributed by Louisiana SBAP in 1996:
Air Quality Regulations Affecting Wood Furniture
Louisiana Department of Environmental Quality'. Small
Regulation, on the Internet
Rnal Rule Issued for Wood Furniture Manufacturing Operations
Business Assistance Program
VIRGINIA
Wood Furniture Manufacturing MACT Fact Sheet
Lithographic Printing Proce.*e. RACT Rule Fact Sheet „.«..,, --*«•.«.
Flexographic Rotogravure, and Publication Rotogravure Printing Lines RACT Rule Fact Sheet
New SBAP Brochure (Prepared 1996, dittributed 1997)
Self-Assessment Guide (Prepared 1996, distributed 1997)
-------
TABLE E-7
(Continued)
WISCONSIN
Wisconsin's program has created the following recordkeeping report* and charts.
• Dry Cleaning
_ pfrfc consumption churt.
— Weakly monitoring pare concentration in carbon adaorber chart.
— Refrigerated condenser temperature chart for wether.
— Refrigerated condenter temperature chart for dry-to-dry.
— Leak detection in»pection form - corrective action report - initial notification report.
— General operation permit application (reviewed).
— Compliance status report.
• Solvent Cleaning
— Initial notification report.
- NR 423 solvent RACT rule flowchart.
• Chroma Platinq
— Notice of compliance status.
— Ongoing monitoring record*.
— Ongoing compliance status report.
— Notice performance test.
— Work practice standards records.
— Initial notification report.
• Automotive
— Initial notification report.
• Wood Furniture
— Initial notification report (RACT).
Initial notification report (MACT).
• Printing
— Initial notification report.
- MTE calculation sheet (distributed).
— Compliance certification form.
— Recordkeepjng form for all fountain solutions.
— Recordkeeping form for refrigerated fountain solutions.
— Recordkeeping form for blanket or roller washes.
• Crushing
- General operation permit application (reviewed).
— Checklist for crushers.
— NSPS testing requirements.
Wisconsin's Small Business Clean Air Assistance Program Publications
• General Information
— Air Pollution Permits for Small Business
— Clearing the Air on Environmental Consultants
— Clean Air Consultants
— Financial Assistance to Small Businesses for Clean Air Compliance
— Wisconsin's Small Business Clean Air Assistance Program
— Air Pollution Primer for Small Businesses
— Solvent Cleaning Regulatory Overview
— Facts About Air Pollution Control Construction Permits
— Air Operating Permits for Small Businesses
— Salvaging Refrigeration and Air Conditioning Equipment
— Pollution Prevention Clearinghouse Order Form
— Environmental Information Summary
. RACT Facts
— Facts About Solvent Metal Cleaning RACT
— Facts About Wood Furniture Coating RACT
- Facts About Industrial Adhesives RACT
— Facts About Lithographic Printing RACT
— Facts About Motor Vehicle Refinishing RACT
— Facts About Miscellaneous Metal Parts RACT
-------
TABLE E-7
(Continued)
— Fact* About Aerospace Manufacturing and Rework Industry MACT
- Fact* About the Chromium Electroplating MACT
- Facts About Dry Cleaning MACT
- Fact* About Solvent Cleaning. MACT ..» _,
- Facts About Wood Furniture Manufacturing Operations MACT
8
-------
TABLE E-8
SBAP TELEPHONE HOTLINE INFORMATION
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Pima Cty
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
TOLL-FREE
NATIONAL
800-533-2336
None
None
None
None
None
None
800-422-3109
800-578-8898
800-562-2327
None
800-433-1247
IN-STATE ONLY
800-510-2332
800-234-5677
Ext. 4337
800-ARB-HLP2
800-388-2121
800-760-7036
800-789-4599
800-722-7457
800-252-3998
800-451-6027
Ext. 2-8172
800-259-2890
800-789-9802
NOT
TOLL-FREE
520-740-3342
202-645-6093
Ext. 3071
-------
TABLE E-8
(Continued)
PROGRAM
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
\
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
TOLL-FREE
NATIONAL
None
800-662-9278
800-361-4827
800-433-8773
None
800-810-7227
800-829-4841
800-869-1400
800-722-4743
800-819-9001
None
800-734-3619
800-447-2827
800-270-4440
IN-STATE ONLY
800-657-3938
800-725-6112
800-992-0900
Ext. 4670
800-837-0656
800-780-7227
800-755-1625
800-452-401 1
800-253-2674
800-974-9559
NOT
TOLL-FREE
609-292-3600
Not reported
787-767-8025
•
-------
TABLE E-8
(Continued)
PROGRAM
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
TOLL-FREE
NATIONAL
None
800-435-7287
None
IN-STATE ONLY
800-592-5482
800-982-2474
NOT
TOLL-FREE
360-407-6800
-------
TABLE E-9
INFORMATION ON STATE SBAP ELECTRONIC BULLETIN BOARDS OR WEB PAGES
PftOOIIAM
Alatka
Arizona
Msricopa Cty
California
SCAQMD
Colorado
Connecticut
Florida
District of
Columbia
Georgia
Illinolt
Indiana
Kantas
ftUUCttt toARD
onwtiPAOt
ADPWM
http://www.ttat*.
ak.ui/local/
akpaget/ENV.
CONSERV/dtpt/
dac dipt. htm
www.ttata.az.ui/
adeq
http://www.
maricopa.gov/
anvtvc/tbeap.htm
916-322-2826
http://www.
aqmd.gov
www.ctata.co.ua
BBS: 860-424-
4127
com.(ett!ngt:N 81
www.dap.ttate.fi.
ut/alr
202-645-6101
http://www.dnr.
ttate.ga.ui
http://www.
itcommerce.com
IDEM Online:
http://www.ai.
org/idem
FaxBack
Directory:
http://www.ai.org
/idam/faxback.
html
http://tbeap.niar.
twtu.edu
UftAOE
DURJMO
REPORT
rewoD
1957; ™t
operational
Tn199«
Not
".TOW
w«be
A^ISST!
48,000 +
917
r*g«t«c«d
UMTS
1.14^|(73
N/H
150 hit*
N/A
200/
wwk
N/A
616
Ofdar. /
dowrto»d«
IDEM:
1,318
•ince7/96
Fax: 7,200
?(»
l>B^BBBBW^*BBl
No (but
oK9n»
Quality w«l>
•M)
YM
YM
YM
Y*>
YM
Available
oo^^h
network
YM
YM
YM
YM
YM (KS Air
Qua), parm.
and link to
US? PA «rtol
M^ftMM^lHA
7^^ iBI^fnl^WW
YM
YM
YM
YM
YM
WF3U6R
at aama wab
aita
YM
YM
YM
FWMa
Air parmlt
forma
Titto V parmit
appficatlona
YM
Mid*
•x
Ragula-
tory
guidanoa
mamo
YM
INFOW.M
iCSCS.
YM
ITION AVAIL
°ts.-
YM
YM
YM
VM
ABLE
Irs,
YM
Yea
Yea
Jh*¥Wa^M>
Yaa
YM
Sae
YM
.*»
YM
YM
YM
fjaaielMi
YM
(Maar
YM*
YM'
YM*
YM*
YM'
-------
TABLE E-9
(Continued)
LoutetMM
M»rvl»nd
Nevada*
North C.mHn.
MJttf
«m
^KS?°
WMM
vaassss
fi±ffi!
http://www.deq.*
tota.te.iM/OMp/
http://ctoW.nw.iM
/dep/mdaphome.
http://mde.ctat*.
617-727-6M1
mtpI//WWW.OVQ.
•UM.ml.us/Md/
http://www.pca.
http://www.itMs.
mo.ut/dnr/deo/tep
http://www.tci.
http://www.
rtate.nj.ui/
commerce/
Bulletin Board:
506-827-1652
Home page:
nmenv.ttate.nm.
http://www.owr.
ehnr.ttate.nc.ui/
oabo.htm
http://www.owr.
•hnr.ftote.nc.ut/
_u*Lim
Dijmfa
^m
Not
-ar
N/A(onlm
flSfc
r:
214
ffflW
120
JSSAP*
"^cl
Unknown
'SW®1
nOCIM
.. .... MTOMMTIMtAVMAMJe
'
FwdtaMt
Y«
Fatr
v-
^e-r
v«
Y«
<
V«
VM
Y-
^^SKB?_
Y«
Y-
**•*£*»
v«
YM
V-
*
Y«
Y«
Y-
.
iftSSnrrti
V«
Y-
Y«.
Yw
YM
Y«
.
•a*
IMMJMI-
JJ..HL'.'J — J.
..Y«_ .
YM
«*L
Y«»-
Y»-
VM-
YM*
YM*
YM*
-------
TABLE E-9
(Continued)
MKMRAM
Ohio
Oklahoma
Pennsylvania
South Caroline
South Dakota
Tennessee
Texaa
Utah
Virainia
AOOM9S
http://www.epa.
ohio.gov/dapc/sba
/sbalntro.html
http://www. state.
ok.us/'deq/
SBAP maintains
computer bulletin
board under
contract with PRC
at 1-800-864-
7694. Modem
settings:
parity » none; data
bits -8; atop
bits-1;
duplex -f UN.
PA Department of
Environmental
Protection web
•Me with similar
information to the
bulletin board:
http://www.dep.
atate.pe.ua
http://www.rtat*.
ac.ua/dhec/abap.
htm
SCDHEC EQC
Bulletin Board:
803-734-4535 or
3762
http://www.stat*.
sd. us/state/
exacutiva/denr/
denr.html
http://www.rtat*.
tn.ua/environment
http://www.tnnx:.
state. tx. us/exec/
small business/
indexThtml
http://www.eq.
state.ut.ua/eqair/
•bep/*bep3.htm
http://www.deq.
state.va.ua
KMOO
Not
OfMrttfatWl
7BB
174 (horn.
t>*S/96)
Unknown
nVAbww
MrVfc*)
1,079
MIA
M/A
MFOMMATON AVAIAMJE
•M^lbM
YMiees
only)
Ptamd
YM
YM
YM
YM
YM
YM
.ryhajimiain
YM
Phnrad
YM
YM
YM
YM
YM
VM
'-«sr
YM
YM
YM
YM
Ptomd
YM
Ye. thru
linlw
YM
YM
YM
OaMarel
Ptanmd
YM
YM
tt
VM
Ptemd
Y^taU
YM
•MM* 1
VM
PWrad
YM
YM
rr»
YM
YM
YMtt¥U
link.
IT*
YM
YM
-
YM
pear
Vw*
YM'
VM'
YM'
YM'
YM'
-------
TABLE E-9
(Continued)
flKMMUM
Washington
West Virginia
Wisconsin
Wyoming
ADOKfM
Dept. of Ecology:
http://www.wa.
gov/eoology
Air Quality
http://www.wa.
gov/aeology/air/alr
homs.ntml
Olympic Air
Pollution Control
Authority:
http://www.win.
com/'oapca/sba.h
tml
Puoet Sound Air
Pollution Agency:
http://www.
psapca.org/
butlnsst/htm
Northwest Air
Pollution
Authority:
http://www.
ptclflcrim.net/
nwapa/smbus.
htm
Southwest Air
Pollution Control
Authority:
http://www.
cascadlaweb.com
/"ccl/baqap.htm
304-558-3053
http://badger.stat
e.wl. us/agencies/
commerce
307-777-6465
ptntoo
No
Information
Un.^
N/A
Unknown
IMJMMMJJ
YM
YM
YM
n »!»»••<<•
YM
YM
JkBSlMjiMi
Mflll.
YM
P^lS^l-^
•••HlBvBsMjVMl
MFOftMATtON AVAtAKf
iCacB.
YM
YM
"tft-
YM
^
YM
YM
_£^_
OM*Vt
i___
irrwaj-.
YM
YM
Taf
MMB^BMM
(MMha
jH^^^^^
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o»*
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•Other
AK Multimedia information, hazardou* watto, used oil, batteriet, partnership program.
AZ Martcopa Cty: Trip reduction program.
CA SCAQMO: Butinett attittance, compliance program, permit attittance, clean air technologiaa.
IL Online ordering of all clearinghouse documents.
-------
TABLE E-9
(Continued)
IN Link to Legal Service* Agency, order form for IN environment*) regulation*, checklist*.
KS Online verelon of quarterly newsletter*, online veraiona of SBEAP publication*.
KY Regulation promulgation achedule, notice of public hearing*, newsletter.
LA Policy. 40 industries with CAAA rules that affect them, housekeeping suggestions, reporting dates, final rules a* promulgated, financial assistance. Introduction to the ombudsman, SBAP hotline
number, SBAP permit fee schedule, quarterly newsletter "Recordkeeplng.
MA MA multi-madia permitting efforts. Other non-SBAP issue*.
MN Press releases.
MO Requests for assistance.
NJ Checklists.
OH OEPA DAPC Newt Bulletins.
PA Miscellaneous air pollution documents.
SC Publications
TX Copies of regulations and P2 Information available through TNRCC main home page. Industry-specific Information, EnviroMentor Program information, and links to other government sites available
through SBAP home page.
UT Free downloadable computer software.
VA Hotlinks to other federal and state sites, source-specific complianca/P2 information, public notices/rulemakings, board memberships, environmental education, publications, news releases.
WA Linka to industry-specific web sites, environmental conditions and trends, news and events.
WV List of regulation titles.
WY CAP meetings.
Comments:
AK New web site. Have not received any comments from the public. However, the information that is on the web site has been handed out in hard copies. So far, the responses have been positive
about the factsheets. Existing factsheets on air permitting issues have been distributed to interested and affected businesses. Additional factsheets are being prepared baaed on input and
requests from the public and other Department offices.
AZ Maricopa Cty: The first yaar web site was selected top 10 web sites for small business from American Group Purchasing Association. This year, I want to have one of the top 3 sites in the
country.
CA We have recorded a noticeable drop in BBS usage, particularly the last half of 1996. We attribute this, in part, to our expanded web site and more seekers being equipped to reach us via the
Internet. We do seek feedback on both BBS and web site. We plan to decommission the BBS in June 1997 and have a referral on BBS to our helpline and web site, me feedback generally has
been for information requests, and this is usually handled by helpline.
CA SCAQMD: 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.
CT Very favorable reports received (on BBS) in terms of improved accessibility to cumbersome, sometimes hard-to-find information. Requests for more information to be made available. The
department is in the process of establishing a web page and many have requested that the two be linked.
GA We have not received any comments on the web site itself. However, we have had requests for workshops advertised on the web page.
IN Internet: Feedback is not yet being sought.
FaxBack: A survey was sent to users of the FaxBack system. On a scale from 1-7 (useless-very useful), the overall rating for the system was a 6. The FaxBack system serves all businesses
within the state and has been particularly useful to small businesses seeking information on IN's Title V program. Because of the outreach efforts made regarding Title V, CTAP and 0AM were
able to inform businesses of the FaxBack system and to encourage its use. CTAP also worked closely with OAM to ensure that newly created forms and guidance documents were added to the
system. There are over 300 documents available via the FaxBack system, all of which will be made available via the Internet in 1997.
KS No requests for subscriptions received.
ME We have not received any comments. Not soliciting feedback at this time on the home page.
MA Comments from users were generally positive, although now services and items were suggested in several instances.
-------
TABLE E-9
(Continued)
MO We have had eome feedback and have received compimanta about our home page. We have received aeveral requecta for a**i*tanee through the Internet, and the number of requests la
Increaalng considerably.
NV SBAP and SBO do not have currant acceai to an Internet home page nor do they have a bueetin board to which they poet item.. Both SBAP and SBO have acoeae to the Air Quality Buaatin Board
at U.S. EPA. TNa home page la run by the NV SBAP/SBO contractor and include* a lot of P2 laauea. Plane are for NDEPto have acoaaa to a home peg* In 1M7. If eo. SBAP/S8O plan to create
a home page for regulation*, technical Information, and limited P2.
NM Poeittva verbal comment* on the availability of BBS.
NC Received minimal u*e. Mo*t often, client* aought information on financial aa*l*tance or how to start a buatoe**, rather than environmental a**iatanee.
OH Faw (toaa than 6) cuatomara uaad the home page to learn of the SBAP. Moat cuatomer* are not ueing the Internet to find environmental information at thia time, but wage ia expected to
increase In the near future. Moat email bualneaaea report not having the time to do Internet *earche* for information. Home page development he* proceeded moderately, and waa not a high
priority ham during 19*6. SBAP received little feedback on the home page dealgn, with the exception of the CAP, who generally were pleaead with It.
SC Several people have commented pocttivory on Information and link* available on home page.
TX Verbal comment*. Good link* back to TNRCC main home page. Ea*y to maneuver. Great layout.
UT We have not received any feedback from uaar* of thi* aervica.
VA The Small Budne** A**!*tance web page actively aeek* information and critique from our peer*. The development of the SBAP page under EPA Leadership Grant i* juet part of the web *ite
activity of the agency. What I will can the aecond generation or enhanced veraion of the SBAP page wa* jurt recently ported. The agency web atta coordinator la atW developing the counter
program 10 that accurate number* on *lte activity can be developed. Bated on what we have i* that the enhanced' veraion of the SBAP page waa entered 48 time* in 1/87. hi relation to the
web alta, we expect a great deal more activity baaed on approximation* of entry into the DEQ web lite, which currently atanda at approximately 3,000 per month with an ectanated 16,000
entrlea into different page* of the *Ke. DEQ page elao i* currently receiving approximately *ix favorable comment* per month from aatiefied ueen, a number we abo think la indicative of the
usefulness of the afte aa a whole.
WA There la a feedback capability on the web alte. To the beat of our knowledge, there have been no entries.
WV Mo*t of the client* we help aeam to prefer one-on-one and/or telephone assistance from a knowledgeable peraon rather than trying to eearch through computer fee*.
-------
TABLE E-10
MAJOR CAP ACTIVITIES
State
AL
AK
AZ
Maricopa
Cty
Pima Cty
AR
CA
SCAQMO
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
Review of
wadabHKy
.and/or content
N/R
No activities
No activities
N/R
urn
N/A
N/A»
X
X
CAP not
appointed
Not
operational
N/A
N/A
X
None
AppointffMftt/
lifcBi0 *Jf •tflff
Und/df •wtivioti
of offtoonk
X
X
X
Kavtowof
SBO/SBAP
outraach
•fforta
X
X
X
X
RavWw/
ISflflllTHMIt Oft
pfopoaad/
naw .
ngulatiorta
X
DvfihitteffiL^rf
CAP b
^.^ nl. , HitttfTi *
rvSponmnini«M
'
X
X
Attendant*
byCAP
Itwtnowv flrt
traWng
••«MlOfM» •C6U
X
about •ffactfiM
outraaoh.
• nrtaalflia •
•OWIWv
X
X
X
X
emal
fcualnaaa
dOfflOMfNl
baMdoA
00»>UCU
X
dhar
X
X
X
X
-------
TABLE E-10
(Continued)
KS
KY
Jeff. Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NJ
NH
NM
NY
NC
ND
rfocumMrts f or
•nd/or content
X
X
SoeKY
N/A
N/A
X
N/A
X
X
X
N/R
X
•ntf/or •teotion
X
X
X
X
X
ftMfewof
MO/MAP
•utrMoh
•fforts
X
X
X
X
X
X
oomnMnt on
ragutatiom
X
X
X
fefinhfonof^
fttflpMMwtttMM
X
X
*•***
X
X
X
•otfvhtas
X
X
X
X
X
X
X
X
X
X
contacts
X
-•
X
OtfMT
(8wifc«l0w|
X
X
X
X
X
X
-------
TABLE E-10
(Continued)
State
OH
OK
OR
PA
PR
Rl
SC
SO
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Review of
document* far
rearfabWty
and/or content
X
X
X
Unknown
None
N/A
N/A
X
X
None
X
None
X
X
X
19/36%
Appointment/
hMnflofeteff
and/or election
of officer*
X
X
X
X
12/23%
Review of
8BO/SBAP
outreeoh
effort*
X
X
X
X
X
X
X
X
X
19/36%
Review/
OOfflRMflt Off
propomttY
new ^
regufatione
X
X
X
X
X
X
10/19%
Definition of
CAP b
IWCp OfM IDIutWS
X
X
X
X
X
X
10/19%
Attendance
by CAP
IIMtnBMfW At
training
•••MraiWf fttc*
X
5/9%
•^innvvnlV***
•bout effective
outreeot),
•citlvltiei
X
X
X
X
X
X
20/38%
WMt
burineee
eonoeme
bMedon
oofrtAott
X
X
X
X
7/13%
Other
X
X
X
X
X
X
X
17/32%
N/A Not applicable
-------
TABLE E-10
(Continued)
a Includes policies, guideline*, etc.
b Includes estsbUshing interne) procedures, defining meaningful rotes for members, and developing means of measuring effectiveness.
o Such as marketing and review of training programs, guidance document development, etc.
Other activitiaa:
CT Leveraging resources through trade associations, vendors, suppliers, and small business trade publications.
FL CAP met with SBAP 6/96.
GA CAP met 4 times during 1996. GA Air Quality Rules were revised to reflect the CAP's length of service and its structure.
IN Reviewed and commented on new programs and personnel including Agriculture Liaison (position created and filled in 1996), Environmental Performance
Partnership between IDEM end EPA, Environmental Circuit Rider Program, (OEM's proposal to "re-engineer" the agency.
KY Assistance provided to dry cleaners, and upcoming state regulatory calender for small businesses.
MN Due to scheduling difficulties, council only met two times during 1996. Both meetings were productive exchange of information between council members, SBAP
staff, and trade association members (grain elevators, dry cleaners, and service stations).
MS Panel members have continued to be sensitive to concerns of the small business community. Early in the year, the ombudsmen position was emended to include
other media. It is now located outside the air division, which gives it even more independence in dealing with air issues. The ombudsman is 3/4 time to Title V and
two other staff members are 1OO% Title V. A small business newsletter is published monthly that calls attention to the various workshops and their locations.
SBAP has assisted quite e few businesses this year. Other parts of the report will detail these activities. We feel the needs of small businesses are being met quite
adequately.
MT Met with SBO/SBAP to help develop legislative strategy for creating small business environmental loan program. Helped SBO evaluate nominees for small business
award program.
NV Reviewed and instructed staff to prepare letter of concern on auto repair facility technician training. This impacts small businesses, even though technically they
are not stationary sources. Review of new requirements for dry cleaners led to development of a workshop by SBAP's contractor, BEP, for outreach to dry
cleaners on their requirements to get into compliance with new regulations.
NC Members heve spoken to local civic and business groups to share information on our SBAP and identify small business needs.
OR CAP/SBAP sponsored workshop for perchloroethylene solvent dry cleaners and affiliated industries and individuals to discuss environmental regulations. Solvent
vendors, equipment sales and repair representatives, and members of the Oregon and Korean Dry Cleaners Associations attended. CAP assisted SBAP and
Environmental Cleanup staff with implementation of new cross-media program for cleaning contaminated dry cleaning sites. CAP collaborated with Pollution
Prevention Resource Center through SBAP to develop small business technical information brochures and P2 guidance documents.
PA Provided review and comment on legislation transferring the ombudsman office to the Department of Environmental Protection, Office of Pollution Prevention and
Compliance Assistance. Evaluated the roll-over of the Air Quality Improvement Fund into the Small Business First Loan Program.
TX Two meetings.
UT Extended an invitation for the UT P2 Association to send a representative to regular meetings as a liaison to both groups. CAP is preparing an outreach plan for
inviting industry representatives to attend meetings.
WA Participated in Region X "Success Methods" survey.
WV Considered other media (e.g., water solid waste) regulatory impact on small businesses. Initiated actions to institute a small business environmental loan program.
-------
TABLE E-10
(Continued)
Wl Discussed and commented on the reorganization of the Wl DNR. Discussed Treatment of Tribes as States and how it could relate to small businesses. Made
suggestions to representative from IL CAP. Assessed current state initiatives regarding ISO 140OO. Authored "Council's Corner" articles on EPA Policy on
Compliance Incentives for Small Business, NR1.52, and DNR reorganization for the SBAP newsletter.
WY The CAP pursued a departmental policy on not seeking penalties for small businesses that voluntarily disclose non-compliance and seek assistance. In addition, the
CAP believes that the SBAP needs confidentiality to effectively assist small businesses. Also, the CAP approved a SBAP operational plan and Handbook, which
outlines the CAP's authority, duties, and responsibilities. Finally, the CAP supports the establishment of a western states CAP forum to develop an information
exchange network.
Additional comments:
AK Alaska's Title V program was not given interim approval by EPA until December 5, 1996.
CA SCAQMD is a regional regulatory agency permitting approximately 30,000 sources. We are the largest of the 34 air districts in CA. We have historically used
industry, community, and environmental group input into our programs. A CAP-like committee is being developed.
DE CAP not appointed. Unable to motivate the legislators to make appointment.
IL CAP has 3 people appointed. They have not met formally.
IA Pending Governor's appointment.
LA The new administration has appointed only 4 CAP members and they did not meet during 1996.
ME Due to a restructuring of the Department and a temporary reassignment of the Ombudsman, the CAP only met once in 1996. During this meeting, the CAP
reviewed the Department's recently issued Small Business Compliance Incentives Policy.
NV Nevada CAP was still "getting up to speed" on air pollution issues in the state. The main topic of discussion was whether their "jurisdiction" included all three of
the regulatory agencies (one state agency and two county health agencies). It was finally decided that advice could and would be given to all three entities on their
air programs.
NJ Appointments completed in late 1996. Rrst CAP meeting scheduled for 1/10/97.
ND The CAP expressed a willingness to advise the SBAP on multimedia issues; therefore, the CAP meeting last June and those in the future will be multimedia in
nature. The CAP discussed issues regarding the impact of new rules and policies the environmental health section (multimedia) would be implementing.
Rl CAP not yet appointed. SBAP coordinator (1 FTE Environmental Planner hired in November 1996).
SO The South Dakota CAP did not meet in 1996.
VT CAP not yet appointed.
-------
TABLE E-11
MEETINGS AMONG SBO, SBAP, AND CAP
1
FREQUENCY
Daily
Weekly
Biweekly
Monthly
Bimonthly
Quarterly
Biannually
Annually
Occasionally
SBO & SBAP
AK, AZ, AR, CT,
IN, KS, ME, MT,
NH, NC, TN, VA,
WA, Wl, WY
GA. NH, OH, WV
DC, CO, IL, MN,
NV, UT
AL, LA, NJ, NM,
NY
CA
IA, KY, Rl
MS, TX
OK
ID; Jeff. Cty, KY;
MD; Ml; MO; ND;
PA;SD
SBO & CAP
Wl
MA, MT
CT, GA, KS,
Jeff. Cty, KY,
Ml, MN, NH,
NC, WV
AR, ND, TX
/>
NM
AK, ME, WA,
UT, VA
SBO, SBAP, & CAP
Wl
OH
CO, CT, GA, IN, KY,
Ml, MS, NV, NC,
PA, VA, WV, WY
AR, MN, ND, TX
FL; KS; Jeff. Cty,
KY; MT; NM; WA
AK, ME, NE, UT
SBAP & CAP
Wl
CT, GA, Ml,
NC, OR, PA,
WV, WY
AR, MN, ND,
TX
Jeff. Cty, KY;
NH; NM; OK;
WA
AK, ME, VA
Notes:
County programs not counted separately.
AK All meetings involving CAP held as needed or as requested by CAP.
AZ Dual role SBO/SBAP.
Maricopa Cty, AZ No response.
Pima Cty, AZ No response.
AR SBO/SBAP fully integrated.
DE No response.
HI N/A.
1
-------
TABLE E-11
(Continued)
IN SBO/SBAP meetings too frequent to track.
KS SBO and SBAP meet daily via phone and personally at least quarterly.
MD 10 meetings in 1996 as needed.
Ml SBO/SBAP meet as needed.
NH SBO/SBAP operated as one program.
NC For meetings involving CAP, met twice
-------
TABLE E-12
FINANCIAL ASSISTANCE PROGRAMS TO HELP SMALL BUSINESSES
COMPLY WITH CAA REQUIREMENTS
The following states indicated that they are planning or have implemented a small business grant or loan program.
PROGRAM
Arkansas
California
SCAQMD, CA*
Connecticut
Georgia
Indiana
Iowa
Maine
Minnesota
Montana
New York
Ohio
DATE AVAILABLE
TBD
1972
1991
1995
1991
1997 or 1998
TBD
8/94
TBD
1/95
7/95
5/97
TBD
1st half of 1997
NAME OF GRANT/LOAN
Small Business Revolving Loan Fund
CA Pollution Control Rnancing Authority
Air Quality Assistance Fund (South Coast Air Quality
Management District)
Innovative Clean Air Technologies
Air Quality Assistance Fund Loan Guarantee
CLEAN (State's portion)
FAVRS Loan Guarantee Program (P2 and CAA
compliance)*
TBD
P2 Challenge Grants
Property tax exemption
Sales tax exemption
Green Fund
Small Business Environmental Loan Program
1 997 legislative session: proposal to merge 2
existing loan programs
Small Business/Environmental Loan Program
Financing assistance
Grant program
FUNDING LEVEL
$3.5 million
$6.8 billion (bond sales) for projects
ranging from $10,000-$500,000
$1 million remaining (sunsets 1999)
$1 million/year
$1,750,000
$3 million ($750,000 from AQAF)
$5 million
TBD
$200,000 annually
N/A
N/A
$250,000(1995)
$250,000
$750,000 merged funding potential
$600,000 at 6% interest
No preset level*
$150.000 annually*
-------
TABLE E-12
(Continued)
PROGRAM
Pennsylvania
South Carolina
Virginia
West Virginia
Wisconsin
DATE AVAILABLE
1/94, 7/98"
TBD
1/1/98
7/97
12/94
NAME OF GRANT/LOAN
Small Business First Program
N/R
TBD*
WV Small Business Environmental Loan
Wisconsin Housing & Economic Development
Agency (WHEDA) Clean Air Fund
WHEDA Ozone Protection Fund
FUNDING LEVEL
$3 million revolving fund
N/R
TBD
$1-5 million
$1,000- $50,000
$1,000- $50,000
TBD To be determined
N/A Not applicable
N/R No response
•Notes:
CA
CT
NY
OH
PA
VA
SCAQMD: A loan guarantee program called the Air Quality Assistance Fund (AQAF) is available to small businesses located in Los Angeles,
Orange, and the non-desert portions of Riverside and San Bernardino counties. These are not loans, but guarantees of repayment to lenders.
This program was established to offer technical and financial assistance to small businesses to satisfy clean air requirements.
A loan guarantee program was established in 1994. The program was called Financial Assistance for Vapor Recovery Systems and was
primarily established to finance installation of Stage II Vapor Recovery. Preliminary work is underway to expand the program to make
financial assistance generally available for small business environmental compliance.
It is unclear when this program will become active. The New York State Clean Water/Clean Air Bond Act allocated $60 million to assist small
businesses with environmental compliance. The details of how this program will be conducted are still being determined.
Financing assistance provided as a conduit program (i.e., done in conjunction with lending institutions) with no preset funding level. Grant
program will provide grants to cover financing costs of small business loans to comply with CAA regulations. The funding source is a
$0.50/ton set aside from Title V fees, which is estimated to generate $150,000 annually.
The Air Quality Improvement Fund became available January 1994 and was subsequently rolled into the Small Business First Program as of
July 1, 1996.
Virginia is planning a Small Business Assistance CAA compliance and P2 activity loan fund. Legislation is scheduled for the 1997 General
Assembly Session. Hopefully the loan fund will be established and operational by January 1, 1998.
-------
TABLE E-13
LEVERAGING OF RESOURCES
Descriptions of how each component of the SBTCP leverages existing personnel resources (within the state) are provided in
Table E-14. (Comments edited for space.)
STATE OK
TERRITORY
Alabama
Alaska
Arizona
Maricopa
County
Pima County
Arkansas
BRIEF DE»CfUPTION OF MOW RESOURCES ARE LEVERAGED
8BO
SBO staff is allowed the freedom to interact
directly with regulatory staff to get timely
answer to specific business questions. This
eliminates the need to have detailed
knowledge of all environmental programs
available in the SBO office.
Works with Department of Commerce to
reach more small businesses.
Agency ombudsman assists with complaints
from small businesses.
N/R
N/R
Operates through a multi-media, 1 2 member
Advocacy Council with a single member
appointed from each operating division of
the Agency by the Director. Individual
council members provide advice and counsel
on the operations of a small business
assistance oroaram.
MAP
SBAP is conducted as part of overall
permitting program in the Air Division.
Works with Air Quality program to ensure
that efforts are not duplicated. Had only
one private environmental engineering firm
agree to hand out SBAP brochure to small
businesses with which they interact. Local
chapter of AWMA sponsored a program
aimed at small businesses and have stated
that they are willing to help partially fund
any other outreach the SBAP may do in the
future.
Agency permitting engineers and
compliance inspectors frequently refer
businesses to SBAP and assist with
workshops, training sessions, publication
development, etc.
Example of leveraging was 2nd Annual
Small Business Environmental Awareness
Conference using a cadre of professional
volunteers. Co-sponsored (4) industry-
specific workshops with SRP, Association,
and other stake holders.
Program Manager of Information Services
Division manages the Business Assistance
Program with limited assistance from
administrative staff and other division staff.
Sponsors pollution prevention program of
the Agency. Utilizes multi-media inspection
team from the Agency to perform voluntary
compliance audits. SBAP also is recipient
of US EPA Leadership Grant Award.
CAP
SBO/SBAP uses CAP to review fact sheets
and other Departmental information. CAP
members are from all parts of the state. Their
names, addresses, and phone numbers have
been put in different forums to allow
businesses and concerned citizens to contact
an individual outside the Department regarding
Department activities.
Agency CAP representative is the Deputy
Director of the Agency.
N/R
N/R
N/R
-------
TABLE E-13
(Continued)
«T ATE Oft
CIV
California
Appointed by the Governor, supported by
the Cabinet, other state agencies involved.
Some local air districts have this function
and eome local SBAPi are largely
independent. Many etate departmente
assist.
To be operational in 1997.
SCAQMD. CA
SCAQMO eteff ie aeeigned 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.
SCAQMO staff ie assigned to assist one day
par week at Cal/EPA permit assistance
centers. AQMD provides counter-top
displays in city and local government,
business assistance, end permit services to
refer customers to the AQMD'e 1-8OO
SBAP numbers.
SCAQMD is working with other etate and
local programs to obtain ideas on how to
make a C AP-type program work at a regional
level. Our governing Board recently authorized
the development and implementation of a
Local Government and Small Business
Committee.
Colorado
1.5 FTEs are funded by the CO Department
of Public Hearth and Environment. Air
Pollution Control Division. Stationary
Sources to staff the Small Business
Ombudsman Office within the Department
of Regulatory Agencies, Office of
Regulatory Reform. The ombudsman staff
works cooperatively with SBTAP staff to
provide compliance assistance to the
regulated small business community. The
cost for joint meetings, workshops, and
mailings ie shared. Effective 6/30/97. the
ombudsman office will no longer be located
in the Office of Regulatory Reform. Senate
Bill 96-13O7 requires the ombudsman
function to move to the CO Department of
Public Health and Environment/CDPHE.
2 FTEs are funded by and located at the CO
Department of Public Health and
Environment. SBAP staff work to educate
small business owners, internal staff (e.g..
permit engineers, enforcement personnel),
and outside agencies about air quality
regulations.
CO CAP members are not compensated for
their appointments. They are strictly
volunteer. CAP meetings are held at various
members' business locations and at the state
offices on a rotating basis.
Connecticut
CTs SBO and SBAP are merged, and collectively the program leverages technical staff from
within the Air Bureau to provide compliance assistance on air quality issues. The program
utilizes staff from other Bureaus within the Department to provide multimedia assistance
when requested. The program can access technical staff within the Air Bureau on a regular
basis to provide permitting assistance, to help with the development of informational
materials and fact sheets, and to participate in outreach events around the state. Recently,
the SBO position was designated out of the Office of the Assistant Commissioner to begin
to enhance linkages with the Water and Waste Bureaus and 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. SBAP established
effective partnerships with trade associations and vendors representing the autobody
industry, the metal finishing industry, and the gasoline industry.
CTs CAP consists of 10 members. Other
interested individuals attend meetings
regularly and serve as non-voting members.
Expanding participation beyond the 10
appointed members to include non-voting
members has broadened the expertise of the
panel while providing additional resources to
participate in the development of
subcommittees. This is helping to establish
strong ties to the small business community
and to publicize the availability of the SBAP.
Delaware
Ombudsman has access to technical
personnel in engineering to help answer
questions, complete permit applications, and
interpret regulations at both State and
Federal level.
Ombudsman serves as the SBAP.
N/R
-------
TABLE E-13
(Continued)
STATE OR
TERWTOWf
District of Columbia
Rorida
Georgia
Hawaii
Idaho
Illinois
•to -
SBO'a aalary ia paid by tha Stata Air
Program grant.
SBO works with Daparlrnant's senior
management in tha development of
compnance assurance strategies.
The SBO also ia program manager for
Planning and Support program.
N/A; plan to maintain activity within
Department of Hearth.
SBO has worked extensively with
Department of Commerce. Small Business
Development Centers, Technical and
Industnal Extension Service, and Division of
Environmental Quality's Pollution Prevention
Coordinator. For workshops, vendors. INEL
representatives, local POTw managers, ID'S
universities, banking representatives, and
DEQ regional office personnel have been
utilized. SBO has worked closely with other
Region X states (WA. OR, AK) to discuss
common problems and entered into an
agreement with the P2 Research Center to
provide assistance with P2 issues under a
leadership grant that is managed by
Washington State.
SBO located within Office of Small
Business, IL EPA. As such, it has the
Agency's 1 ,20O employees available to
provide one-on-one assistance to
businesses, deliver speeches, and respond
to inquiries.
WM*
No SBAP staff ware hired. SBAP
responsibility was added to an
environmental engineer's responsibility.
However, this has retarded the
effectiveness of the program.
SBAP relies on Department's district air
inspectors in providing compliance
assistance with aU air regulations. SBAP
has begun a new partnership with Small
Business Development Camera in giving
onsite technical assistance. SBAP also
relies on resources from Pollution
Prevention's retired engineers for P2
instructions.
Two Environmental Protection Division
Associates; one retired engineer works part
time.
N/A; plan to maintain activity within
Department of Health.
SBAP works with all sections of DEQ to get
correct and complete information to
businesses. They also work with other
professionals in other media to make sure
that cross media concerns are addressed.
37 SBDC's, 13 procurement technical
assistance centers, 3 international trade
centers, local chamber of commerce.
economic development organizations, IL
Manufacturers Association, IL Retail
Merchants Association, tha State Chamber
of Commerce, National Federation of
Independent Businesses, and many other
suDDort partners.
EftAOfO
cap
N/A
N/R
N/A
N/A; support of activity by Department of
Health.
N/R
N/R
-------
TABLE E-13
(Continued)
•TATHOW
. TfcMWTOIW
woBr pggaurnoN of HOWKEKMJRCCT ARC uvotAaeD
Indiana
SBO hat extensive support from Office of
Air Manaoement.
CTAP haa extensive aupport from Offioa of
Air Management.
N/A
Iowa
SBO hired a student Intern for aaveral
months. Citizens' Aide/Ombudsman,
Deputy Ombudsman, and office staff
contribute their time as necessary to
facilitate the duties of the SBO.
IAEAP hires part time and full time student
assistants and interns from the University of
Northern Iowa to help with client assistance
during periods of heavy demand.
N/R
Kansas
SBO assists with P2 issues, edits division
newsletter, coordinates dissemination of
division (compliance) publications, works
with other assistance providers. SBO is
located in the Office of Pollution Prevention,
Division of the Environment, KDHE, and is
not located within the regulatory arm of the
division.
KDHE elected to have SBAP operated
outside the regulatory agency. KDHE
operates the KS Small Business
Environmental Assistance Program (SBEAP)
by contract to a consortium composed of
the University of Kansas, Kansas State
University, and Wichita State University.
Each university is responsible for portions of
the program, work assignments are based
on which institution was best equipped to
perform these duties. The determinations
were based on each university's available
resources, experience, staffing, and
organization's mission. Technical
assistance is provided through KS's
Pollution Prevention Institute, an
organization that provides small businesses
with environmental technical assistance.
The University of KS Center for
Environmental Education and Training
provides overall progrem coordination and
produces the majority of printed materials
used in the program. Wichita State
University Center for Technology
Application provides database end web site
development for the program.
No budget.
Kentucky
SBO is coordinator on project to add user
friendly features to regulations using
resources across agency. SBO is also
member of Envjronmental Partnership, a
group of agencies that want to improve
assistance to small businesses on
environmental issues. Participation of SBO
in agency Public Information/Education
group, which has 30 members, is another
leveraging method. Division for Air Quality
has designated several people to assist SBO
in completing requests.
KBEAP uses training and seminar facilities
of Small Business Development Center
network. KBEAP pursues opportunities to
speak and provide training at trade shows
and other conferences utilizing a "captive
audience" approach. KBEAP works closely
with the air quality agency on permitting
and compliance issues to provide timely and
accurate information, thereby avoiding
repeating work. Finally, KBEAP
communicates with other assistance
providers for referrals and partnering on
training and assessment activities.
CAP paid travel expenses for PA CAP
Chairman to speak at June CAP meeting.
Penel members have facilitated SBO and SBAP
work with other organizations.
-------
TABLE E-13
(Continued)
•TATtOft
TERMTOftY
Of HOWKCTOUBCCTARtLEVHUOH)
MAP
Jefferson
County
Jefferson County' SBAP makes it*
resource* of engineers, • library, and a
meeting room and equipment available to
Ombudsman as needed.
urn
urn
Louisiana
SBO utilized personnel of Forestry
Laboratory at Louisiana State University to
assist in the presentation of Wood Furniture
Industry Teleconference.
SBAP utilized personnel of Office of Solid
and Hazardous Waste and the Office of
Water Resources to assist in preparing and
implementing an amnesty program for
foundries in LA.
N/A
Maine
SBO works closely with SBAP and other
business service providers such as the
Department of Economic Development and
the Maine Chamber and Business Alliance to
maximize effectiveness.
SBTAP is able to work with staff from
Department's Office of Innovation and
Assistance and other bureaus to assist in
some functions. SBTAP also works with
other business service providers such as the
Maine Small Business Development Centers
to maximize effectiveness.
CAP is a joint panel with 16 members.
Functions of SBTAP oversight were merged
with an existing panel charged with
overseeing Toxics Use Reduction Program.
Maryland
N/A
SBAP leverages extensive resources within
and without MDE. 100% of an air permit
engineer's time is spent on small business
air quality permits.
Designated SBAP contact in every media
administration to coordinate regulatory and
permitting assistance. All outreach projects
conducted jointly with Pollution Prevention
Program. Three permitting engineers of
MDE's Environmental Permits Service
Center are designated resources for
regulatory and permitting information.
MDE's Office of Community Assistance
coordinates logistics for all outreach
activities. Trade associations partner with
SBAP to host and advertise outreach
seminars.
N/A
-------
TABLE E-13
(Continued)
•mMmwv
Massachusetts
Mtehigan
Minnesota
Mississippi
*'' ' »OB=0€«C«PTTON Of HOWRE»
-------
TABLE E-13
(Continued)
•TATCOR
TERWTORY
REVOUR
Missouri
MDNR'e Technical Assistance Program
assists with responding to requests for
assistance from small businesses.
MDNR's regulatory programs provide highly
technical information if TAP cannot respond
to the request itself. The regulatory
programs are not given information to allow
them to identify the facility In question.
Only 2 members of the CAP have been
appointed; however the remaining 5 will be
appointed in the near future.
Montana
MT Department of Commerce administers
nd provide
outreach for SBO through Regional
MT Department i
SBO/SBAP Loan
Program and ]
lies
Development Officers.
SBO formed partnership with MSU P2
Program and US EPA for small business
awards program.
SBO formed partnerships with other
assistance providers in the state to improve
service delivery and communication.
SBO works with personnel from MT
Department of Environmental Quality's
Pollution Prevention Bureau to provide
assistance to small businesses with
multimedia pollution issues.
SBO/SBAP work with permitting engineers
from MT Department of Environmental
Quality's Permitting and Compliance
Division.
SBO/SBAP rely on CAP Chairman and other
members for technical assistance on certain
projects.
Nebraska
N/R
All three programs are managed by the
same person, the 'Public Advocate."
N/R
Nevada
SBO uses BAQ and other agency files to get
background information on problems that
the ombudsman is assigned to investigate.
SBO interviews staff members with
knowledge of facility as well as facility
personnel to get as complete a picture as
possible of the unresolved issues.
SBO uses reference materials of NDEP
bureaus such as manuals, textbooks,
printed literature, etc.
SBAP utilizes expertise of NDEP bureau
staff in various media for technical
information.
SBAP works closely with UNR's Business
Environmental Program through a contract
to provide information to various impacted
industries.
SBAP works closely with the two county air
districts and other state agencies for hands-
on education of the various area sources,
identification of industry needs, and
outreach activities.
SBAP uses libraries of NDEP's bureaus to
research various impacted industries to
better understand their processes.
CAP utilizes information that SBO and SBAP
collect to advise various air quality districts
and SBTCPs on direction that programs should
proceed.
-------
TABLE E-13
(Continued)
*f Alt Oft
TEWTORY
Clark Cty,
NVAir
Washoe Cty,
NV Air
NVBAQ
NVBEP
New Hampshire
New Jersey
New Mexico
- — n,-r-m,-- - ' •" ***
*w» '
F&etGMPflON Of HOWft£*CKMC8*ARf LtV
ERAOKD
- "... ' ••*».'.'' I <*»
Clark County Air Quality uses thair own resources.
Washoe County AQMD has undertaken a number of new programa with the goal of maximizing the effectivenett of their personnel. Foremost
it i the preparation of Public Information Paokett, which answer the vatt majority of questions the publio has, thus relieving staff from the duties
of answering the same questions repeatedly. This also keeps the phone lines clear, which allows speedier responses to those with specific
questions in regard to some of the unique aspects inherent In the diverse industries that AQMD regulate*.
Two times per yeer, BAQ conducte oomplience workshops. One to two staff members are given the task of presenting these workshops
(typically 1 permittina end 1 compliance etefO. Other workshops are presented es changes in federal and state regulations warrant.
BE? •"?mPt» to avoid duplication through coordination and communication of activities. Materials developed by other state and local programs
and EPA are used to develop training and informational materials.
BEP,h*t,°?af*?*d 8inc* 1987 and has an extensive referral network with various trade associetions, agency personnel, University personnel,
and local development authority personnel.
Administrative support from Air Resources
Division. Developing working relationships
with other advocates for energy,
environmental, and legislative issues.
N/R
Coordinating other assistance programs
throughout the Department. Leading
implementation of P2 initiatives through
green zia program and hiring a P2
coordinator.
Close working relationship with NHDES P2
program. Developed cooperative ventures
with trade associations, the university
Coordinates with Air Permit, Air
Enforcement, Air Planning and P2 staffs
within DEP. Coordinates with NJ Institute
of Technology CAP for P2 assistance.
Works with trade associations.
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
industnes.
Administrative support from DES Air
Resources Division.
N/R
Legal assistance to CAP provided by Mr. Bill
Brancard, NM Assistant Attorney General.
8
-------
TABLE E-13
(Continued)
STATE Ofl
TBWTORY
•WfF DESCRIPTION OF HOW RESOURCES ARE LEVERAQED
MAI'
CAP
New York
SBO it working the NIST MEP program to
be sure that we are coordinated in our
activities. In addition, SBO work* with DEC
Pollution Prevention Unit to co-sponsor
events to avoid duplicate outreach
programs. Where policy issues arise, the
Empire State Development, Division of
Policy and Research has assisted the SBO.
SBAP is able to subcontract with technical
assistance providers. The SBAP also co-
sponsors 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. As a unit within
NYSEFC, SBAP is able to utilize support
functions of the corporation and thus not
incur their whole cost (e.g., photocopiers,
fax, computer network maintenance, etc.).
N/R
North Carolina
NC Air Quality Division and Division of
Pollution Prevention and Environmental
Assistance have provided technical support
and helped jointly to develop and hold
workshops aimed at specific businesses and
industry sectors. The three major regulatory
programs (air, water, and hazardous waste)
have lent one senior permit writer to the
SBO for 1 year to develop multi-media
permit information.
See SBO.
See SBO.
North Dakota
No personnel from other departments have
been assigned to assist the SBTCP.
However, the SBDCs and the Governor's
office have been asked to assist in providing
small businesses with certain information
provided by the SBTCP. Within the
Department, the SBO makes direct requests
for assistance of the Division Directors and'
their staff.
SBAP is organizationally inseparable from
the air pollution .control program. The air
pollution control program SBAP staff work
closely with the SBO on assistance matters.
Although not formally recognized yet as part
of the SBAP under the Clean Air Act, other
media programs (other than air) also work
closely with the SBO on assistance matters.
The CAP relies greatly on information from
SBO and SBAP to provide important feedback
to SBO and SBAP. CAP receives information
during CAP meetings with SBO and SBAP
staff present in addition to periodic mailings of
information. Outside agency resources
haven't been leveraged by CAP to data.
-------
TABLE E-13
(Continued)
f-v . *
• f •. f
«TAttO«
THIHIIORV '
ONo
Oklahoma
- • -, ' - , , ' - -'' - am
f f
99O
SBO i» located within OH Air Quality
Development Authority, an independent
ctata agency established to provida
financing assistance to businesses investing
in air quality issues. In addition to tha
budget providad through Titla V fees, SBO
received financial support from Authority
resources.
SBO oooparata* closely with OEPA Division
of Air Pollution Control in general and SBAP
in particular. Thi» ensures provision of
accurate technical information to
businesses. SBO also works with other
state agendas, like OH Department of
Development, to coordinate program
delivery.
finally, SBO run assumed that tha beat
access to small businesses in many
instances is through the various trade
associations, and SBO has worked to
establish solid relationships with: Printing
Industry of OH. OH SmallBuainess Council,
OH Chamber of Commerce, OH Bakers
Association, OH Cleaners Association. OH
Cast Metals Association, OH Chemical
Council. National Federation of Independent
Business OH, Automobile Service
Association of OH, OH Petroleum Marketers
Association, OH Council of Retail
Merchants.
SBO and SBAP functions are a part of the
Customer Assistance Program (CAP), which
is a nonregulatory part of the agency
providing multimedia assistance and
advocacy.
DC*Cft»tl6* OFHOW IttKHKtcet ARf Ltvl
•SUtfT '
. _ ^•'W'TJI -
SBAP is located within OEPA Division of Air
Pollution Control headquarters, allowing
direct access to permitting, inspection,
enforcement, and policy development
questions. SBAP has used OEPA's Public
Interest Canter to promote SBAP through
agency newsletters and for developing fact
sheet layout and graphics.
SBAP usea 5 district offices and 1O local air
agencies to help distribute SBAP literature
end to refer companies to SBAP. SBAP also
has direct e-mail access to district office
staff through a LAN network. SBAP
established contacts in other OEPA divisions
and programs to help with multimedia
problems.
SBAP established mutual referrals with
OSHA on-atte consultation program offered
through the OH Bureau of Employment
Services to help business bridge the gap
between OSHA and EPA concerns.
OEPA established a two-year pilot progrem
for multi-media small business assistance.
which covers a 10 county central Ohio
district and is funded through a special
appropriations bill. SBAP coordinated
several multi-media site visits with this
program and refers non-air questions to
them. They refer all air questions to us.
This program developed a newsletter, to
which SBAP is a regular contributor of air
articles. They formed an advisory group
modeled after CAP and regularly attend CAP
meetings. The program will continue
through 1997, but future funding is
uncertain.
SBO and SBAP functions are a part of the
Customer Assistance Program (CAP), which
is a nonregulatory part of the agency
providing multimedia assistance and
advocacy.
au«H> ; •'
CM*
N/R
SBAP and SBO interact with the Panel on a
regular basis. SBAP staff are very involved in
identifying issues to bring before the Panel for
their discussion and action.
10
-------
TABLE E-13
(Continued)
•TATEOfi
TKMUyOftY
Oregon
Pennsylvania
Puerto Rico
•^D«CR.nK>HWHOWf«OU..CE«ARELiVBUQa>
MO
SBO is located in the director's office. As a
member of the upper management team,
the SBO hes direct access to the director,
department heads, and other regulatory
agencies. He is a leed member of the
agency's Pollution Prevention Advisory
Committee assigned the task of integrating
and overseeing inter-program pollution
prevention activities. He also serves es
liaison to the CAP, SBAP, small business
community, end general public on regulatory
and P2 matters.
SBO Office funded by Department of
Environmental Protection (DEP). SBO uses
local service providers, which are funded by
Department of Community and Economic
Development. The ombudsman position
currently is being relocated to DEP in the
Office of Pollution Prevention and
Compliance Assistance.
Those expenses identified as travel.
transportation, and seminars are reimbursed
by Title V program.
MAP
SBAP serves, on several committees
including a dry cleaner task force assigned
to implement e new P2 end contaminated
site clean up program, the Pollution
Prevention Outreach Team, and the Notional
and Regional Pollution Prevention
Roundtables. Joint technical assistance
visits are performed with RCRA and other
egency staff. EPA-sponsored satellite
teleconferences end educational videos
produced by other stete SBAPs ere used to
educate smell businesses, trade groups.
chemical and equipment vendors,
environmental consultants, and other
service providers. Partnerships have been
formed with the small business development
centers, trede groups, chemical vendors,
equipment sales people end other service
providers. These partnerships facilitete the
transfer of reguletory end technical
information to small businesses. SBAP end
Pacific Northwest Pollution Prevention
Resource Center heve jointly developed
technical information sheets and will soon
publish e P2 reference manual for the
printing industry. These end other printed
materials soon will be posted on the
Internet. SBAP uses training materials and
publications produced by other SBAPe to
transfer information to small businesses and
their affiliates.
DEP has contracted many SBAP services to
a private contractor. SBAP has received
cooperation from trade associations.
utilities, and district libraries in delivering
services.
Use of our Planning Division technical staff
for small business assistance.
Transportation, seminars, conferences paid
bv Title V fees.
CAT
Special workshops are held as part of
regularly scheduled meetings to inform small
businesses about regulatory requirements that
effect them. CAP end the Lene County Small
Business Development Center ere finalizing a
3-hour cross-media training course. A public
information strategy is being developed to
better utilize outside resources such es
educational institutions, state end federal
agencies, local governments, manufacturers,
distributors, and consultante.
DEP provides administrative and technical
support to the committee. CAP meetings ere
held in the Department's building.
Any expenses related with travel.
transportation, etc. are reimbursed by Title V
program.
11
-------
TABLE E-13
(Continued)
•TATEOfi
T6RWTORY
Rhode Island
South Carolina
South Dakota
Tennessee
4NK»
SBO funded entirely from state revenues not
associated with the CAA program.
SBO provides multimedia assistance using
reeources in other program areae. Program
also participates in Environmental Network
Pertnerehlp, which includes representatives
from other providers such as SBDC, Center
for Waste Minimization, Canter for
Environmental Policy at University, MEP-
sponsored programs, etc. Also have used
student interns to help with speciel projects.
SBO supervised by Secretary of the
Department and has direct contact with the
small business assistance program.
SBO and SBAP work closely to support
program activities.
MAP
SBAP (1 FTE) integrated into Department's
existing P2 program housed in the Office of
Technical and customer Assistance. 0.5
FTE (University of Rhode Island Research
Associate) providing technical support to
recentiv-hired FTE.
Program has regular access to technical
persons in Bureau of Air Quality to assist on
permitting issues. BAQ also provides
computer air dispersion modeling at no
charge to eligible email businesses.
The individuals that work in the air program
all contribute to the success of the SBAP.
All components of SBAP functions are
handled by program staff. Some assistance
is acquired through contract services of
program's budget for site inspections and
workshoos.
CM
N/A
SBO serves as secretariat to CAP.
CAP ia made up of individuals from across SD.
There is a good mixture of private individuals
and small business owners.
N/A
12
-------
TABLE E-13
(Continued)
STATE OR
TERRITORY
JR»3F
MO
OP HoWR6»OURCJ> ABC LEVBWOEO
MAP
CAP
Texas
Work with other state and federal agencies
to get information to small waste hauling
businesses. Four border workshops with
Health Department, Texas Department of
Transportation, Department of Public
Safety, US Customs, EPA, US Department
of Transportation, and Texas Workers
Compensation.
Rve Small Business Advisory Committees
(107 members) serve as a link between
SBAP and the small businesses in their area.
EnviroMentor (29 volunteers statewide)
Program provides free onsite environmental
compliance assistance to small businesses.
Work with suppliers to sponsor workshops
end distribute literature to small businesses.
Work with TX Manufacturing Assistance
Centers to deliver onsite assistance to small
businesses. Work with SBDCs to develop
videos, sponsor workshops, and conduct
onsite visits for small businesses.
See SBO.
Diverse membership from around the state.
Utah
SBO Office met with each Division and
received some support for cross referencing
among Division services and Utah's small
businesses. One Division created a
brochure specifically designed to assist
small businesses in becoming familiar with
their services. One outcome of an internal
Division committee was the regional award
of the Small Business Leadership Grant,
"Partnership for Compliance," which
increases the "team" approach through
outreach, networking, and P2 activities.
SBAP collaborates with Department's
Pollution Prevention Program on P2
outreach projects and the development of a
P2 training workshop for Division of Air
Quality permit writers. SBAP referred small
businesses with waste disposal issues to
Division of Solid & Hazardous Waste's
(DSHW) Small Quantity Generator Program
for assistance. If a small business
expresses concern about contacting other
Divisions for assistance, SBAP has
consulted with the appropriate Division and
then relayed information to the business.
Small Business Advisory Committee has
received support from existing division and
department resources. The department's
consulting organizational facilitator has spent
many hours working with the Committee to
establish working priorities and action plans.
Division's Executive Director's Office has
provided clerical support to prepare agendas,
minutes, and work plans.
Vermont
N/R
The program is planning to get assistance
from volunteer retired engineers in the
future. The program also works with small
business associations to help identify those
businesses that need our assistance.
N/R
13
-------
TABLE E-13
(Continued)
*T ATI Oft
TERRITORY
Virginia
Virgin Islands
Washington
t- ifctytftt O^ttCfttf^TlOM 'Of** "HOVI^ «WBakOU«Ma**sfial Aftt« UEV
MK>
Utilizes experience and expertise of SBAP
Director, other DEQ staff, contacts within
SBDC network, Manufacturing Technology
Centers, EPA and trade/business
organizations to monitor the pulse of the
small business community vis-a-vis air
regulatory issues and impacts. When
necessary, assistance in the form of
resources are requested.
Director of the VI Small Business
Development Agency has bsen appointed to
serve in the SBO function without additional
compensation. His support staff may be
compensated.
SBO is agency representative to Governor's
Small Business Improvement Council
composed of smell business owners and
various state agencies responsible for
regulating the state's businesses. SBO is
agency representative to Unified Business
Identifier (UBI) Board composed of state and
federal regulatory agencies impacting
Drimarilv small businesses.
WWWF
SBAP Director also is responsible for Air
Division Air Toxics Program. Leveraging of
2 staff senior air toxic engineers for
implementation of MACT provides the 0.3
FTE. Coordination and utilization of DEQ's
Pollution Prevention, and Compliance &
Enforcement Program resources also
compliments SBAP activities. There also
are SBAP Liaisons (permit engineers) in
each of DEQ's regional offices, who
function on an ao hoc, as needed basis for
outreach, compliance assistance, etc. Their
activity, having become more regular, is
being calculated at 0.2 FTE for this
reporting period. This Regional Office
activity is not yet being tracked on e
consistent basis, but planning is underway
to recognize end report their activity.
Additional resources often are sought from
EPA regional and national offices.
Coordination and utilization of resources
from trade associations, SBDC network, and
business groups provide a base of outreach
support.
N/R
SBAP supports and is supported by the
following cooperative relationships: 1 )
Technical assistance staff for business-
related pollution control/prevention exist in
several other Ecology programs. 2)
Outreach and assistance staff in four of
state's seven local air authorities. 3)
Moderate risk waste staff in the state's 39
counties.
SKACNEDl "'
CAP
Compliance Advisory Board (CAB) has begun
to review materials for lay understanding and
will be providing input on a range of activities
and priorities in the coming months. CAB has
a wealth of expertise, ability, and contacts
from both the public and private sectors,
which will help to expand the resources of the
SBAP.
N/R
One CAP member is the legislative liaison for
Air Quality Program. All other CAP members
are unpaid volunteers (per diem travel,
lodging, and meals are reimbursed). Staff
support provided by SBAP.
14
-------
TABLE E-13
(Continued)
•TATEWt
TEWUTOHY
B£»OURCg»AltfLIVBlAOg)
MAT
Wast Virginia
SBO work* closely with SBAP personnel to
evaluate technical aspects of eirwll business
issues. OEP 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.
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
SBAP through agency enforcement
activities. Other DEP staff, especially
Pollution Prevention (P2) Services, are
available to help coordinate assistance to
small businesses. SBAP also is coordinating
its efforts with other outside assistance
groups, including university and SBDC
efforts. Trade organizations and state
OSHA contacts provide additional
assistance.
AH members serve on a volunteer basis.
Wisconsin
Numerous public and private sector experts
are called upon on an as- nseded basis to
provide assistance to SBO. Experts from
the areas of development, finance, permit
assistance, law, and environmental
compliance/safety have provided
suggestions and guidance.
Periodically, ONR personnel provide
technical review of publications. 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 pollution
prevention and Solid and Hazardous Waste
Education Center personnel on outreach and
publications. SBAP staff consult with
private and public sector professionals as
appropriate.
Personnel from SBAP coordinate meeting
locations, develop agenda topics, and organize
the bi-monthly CAP meetings. Other
individuals from the Wl Department of Natural
Resources, Wl Department of Commerce, and
the University of Wisconsin Solid and
Hazardous Waste Education Center advise the
CAP on an as-needed basis.
Wyoming
One individual in the Department of
Environmental Quality does SBP duties as
about one-fifth of his job. Coverage is
minimal, but linkage to other surrounding
state programs is proving beneficial.
Expanded outreach efforts are being planned
and will be implemented in 1997.
SBAP leverages its resources by
outreaching to affected sources through
various trade associations and professional
organizations. In addition, the SBAP has
established an informational sharing
relationship with other western states'
SBAPs and uses their ideas and outreach
materials. SBAP provides technical
assistance to DEP's PPIS workshops and
serves on the departmental P2 Committee.
Finally, SBO and SBAP serve on the
interagency committee chaired by the
Secretary of State to improve services to
the citizens.
The department plan calls for its other small
business assistance programs to coordinate
with the CAP and SBO as appropriate.
N/A
N/R
Not applicable
No response
15
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TABLE E-14
SUMMARY: SBAP MECHANISMS FOR AVOIDING DUPLICATION AMONG SBTCPs
Program
AL"
AK
AZ
Maricopa
Cty, AZ
Pima Cty,
AZ
AR
CA
SCAQMD,
CA
CO
CT
DE*
DC
FL
GA
HI
ID
Communication/
networking with
SBTCP and «t»t«
agancy paraonnal via
phona, mailing Rat*,
ate.
X
X
X
X
X
X
X
Maetlnga,
confaranca calla and
othar contacta with
SBAP/SBO paraonnal
witNn EPA ragion
X
X
X
X
X
X
Ravia w of EPA
documanta/
contact with
EPA
X
X
X
X
Networking through
atata of ragional air
group maetirtga auch
aaWESTAF
(Weatarn Stataa Air
Raaourcaa)
X
X
X
X
X
X
Raviawof
documanta from
othar pubHc.
prfvata, and/or
univaraity
aourcaa
X
X
X
X
X
X
X
X
X
X
X
X
Information
gat haring from
alactronic
aourcaa*
X
X
X
X
X
-------
TABLE E-14
(Continued)
. '>•••
-
IL
IN
IA
KS
KY
Jeff. Cty.,
KY
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE*
NV
nwtworUfM with '-,
SBTCP»nd*t*t« .
•oency personnel vu
ptone, matting tots,
X
X
X
X
X
X
X
X
X
X
^±±&L
SBAP/SBO personnel
within EPA region
X
X
X
X
X
X
X
X
fte«l«w of EPA
documMits/
EPA
X
X
X
X
X
X
oroup metting* such
a« WESTAR
fbMOUKttsI
X
X
X
X
X
tevtewof
ptlvitte, «nd/or
unhMtifty
koureet
X
X
X
X
X
X
X
X
X
X
X
-
electronic
•ources*
X
X
X
X
X
X
X
-------
TABLE E-14
(Continued)
:
___ :
PHHtram
NJ
NH
NM
NY
NC
NO
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
MA*UMW>fct«M imjltl
SflnrCI* end etete
•gency personnel MM
phone* mailing fists,
etc.
X
X
X
X
X
X
X
tMmmttnn* '
JWWUHBe*
****** w ** J _™* lit
other conucts vvttn
S0AP/SBO personnel
whhin EPA region
X
X
X
X
X
X
X
X
X
X
X
•
Review of EPA
fJ^HWM Vt t-Trt
oocument*/
contact with
EPA
X
X
X
X
X
X
Natworldna thrauoh
mtmtm Mr Hunt/mat *lr
group meetings such
•* urcdTA a
M V¥cj»IAH
Resources)
X
X
X
X
X
X
X
X
X
Review
-------
TABLE E-14
(Continued)
Program
VT
VA
VI*
WA
WV
Wl
WY
TOTAL
Communication/
networking with
S8TCP ana state
agency personnel via
phone, mailing lists,
etc.
X
23/43%
Meeting*,
• conference calls end
other contacts with
SBAP/SBO personnel
within EPA region
X
X
X
X
X
30/57%
Review of CPA
doeumente/
contact with
EPA
X
17/32%
NetwortOna throuah
etete or regional air
group meeting* euch
eeWfSTAR
(Weetern State* Air
Resource*)
X
X
X
X
X
25/47%
Review of
document* from
private, and/or
univereity
source*
X
X
X
X
X
41/77%
mionnauott .
gathering from
electronic
sources*
X
18/34%
* See full response in following table.
a: Includes bulletin board services, web pages, and e-mail networks.
Total numbers represent activities offered by state programs or one of the reporting counties/agencies in the state.
-------
TABLE E-14
(Continued)
SBAP MECHANISMS FOR AVOIDING DUPLICATION AMONG SBTCPs
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
COMMENT RECEIVED
No other SBTCPs exist in our state.
One of the advantages of having a Title V program be so far behind schedule is that the SBTCP has been able to use
other states' information and have lead time to develop the program. Alaska sent out Florida and Washington states'
dry cleaner manuals to local dry cleaners. The manuals have not been changed, rather provided as written. It is
explained that the laws may not be identical, however, the issues that are covered will be the same for a dry cleaner in
Alaska or in Washington or Florida. This has allowed dry cleaners to evaluate the regulatory requirements and their
compliance.
SBAP also modified the Iowa Waste Reduction Center's check list for dry cleaners for use in Alaska. Having it in
electronic form made it very easy to insert the contacts for Alaska.
At the last SBO/SBAP national conference, substantial materials were available that we were able to use in developing
our SBAP general brochure. Other material was useful for becoming familiar with various industries. All material
obtained now is located in our CAO's library.
The other source of information that has been widely used is EPA's TTN Bulletin Board for SBAPs. We have
downloaded material developed by EPA and obtained information from other states that was not downloadable from the
BBS.
Currently, Region X states SBAPs have a contract with the Pollution Prevention Resource Center (PPRC) to develop
factsheets for small businesses. These factsheets are developed so that each state can add the local contact
information. Forms also are sent out electronically so states can add or subtract information if they wish.
The western states, through WESTAR, have teleconferences to keep the others updated on what they are doing.
These are a great way to determine what new materials are available. SBAP material has been shared routinely among
the WESTAR SBAPs based on discussions during the teleconference.
States are keeping much better contact with each other now, and are reaching out to other state agencies to share
information. With the popularity of the Internet and the prospect of pollution prevention hubs that will serve as
clearinghouses for information, it is much more likely that someone has developed something that we can use as a
basis for our products. We currently contact other states and research their information and products prior to
developing our own.
I am always networking with other state programs for information from South Coast, Washington State, South
Carolina, Texas, and Connecticut, etc.
-------
TABLE E-14
(Continued)
PROGRAM
Pima Cty
Arkansas
California
SCAQMD
Colorado
Connecticut
Delaware
District of
Columbia
COMMENT RECEIVED
Continual communications between Pima County program and AZ DEQ, Maricopa Department of Environmental
Services, and Final County Air Quality Control District ensure minimization of applicative efforts. Traditionally,
brochures and factsheets have been developed by Pima DEQ and adapted for use by other programs.
Have a good knowledge of efforts made by other states through newsletters, annual reports, and telephone
conversations. Will contact Oklahoma to participate in compliance audits for the foundry and die casters in Arkansas.
Have contacted other states for case study information
We review other state brochures and web sites for adaptability. We also make available to other states relevant
materials. We adapted a CA Business Association brochure as a part of one of ours.
SCAQMD Small Business office staff attends the State Small Business Ombudsman/Small Business Assistance Program
conferences that are offered by other agencies and maintains contact with other business assistance programs, both
state- and nation-wide to stay abreast of the latest developments.
Information and ideas are shared at bi-monthly conference calls held with other western region state SBO/SBAPs. Joint
projects are discussed and assignments made for obtaining needed information. Currently, the group is exploring
avenues to finance a joint conference for the western state SBO/SBAP staff. Information also is shared through the
Internet. The CO SBO/SBAP researches other states' written materials when creating a brochure or guide for small
businesses.
CT continues to utilize materials developed by other states and EPA. The materials developed by the University of
Tennessee as part of the satellite teleconferences have been extremely helpful. Many of the materials developed by
Texas, California, Iowa, and North Carolina have been made available in formats that make information transfer very
easy. The Small Business Bulletin Board system and the materials provided by Karen Brown, the EPA Small Business
Ombudsman, have been utilized to promote the sharing and exchanging of information.
Within CT, monthly exchanges occur through the Bureau's State Implementation Plan Revision Advisory Committee
(SIPRAC), which helps to promote information exchange and awareness and to avoid duplication. Monthly meeting
announcements and informational materials are mailed to about 350 members. The organization is chaired by the SBO,
an industry representative and a representative of the environmental community.
CT SBAP will provide informational materials to the small business community from other programs within the state
providing relevant services. The focus has been in trying to establish a network of service providers with each
delivering specialized expertise. Improving communication and coordination will continue to be a major focus in 1 997.
Not a problem.
We used other states' brochures to develop a factsheet for our small businesses.
-------
TABLE E-14
(Continued)
PROGRAM
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
COMMENT RECEIVED
We have found California's information for motor vehicles and related material to be applicable to Florida's air program.
Georgia participates in regional conference calls and shares information such as factsheets, permit cover letters, etc.
Georgia has responded via e-mail to Iowa, Texas, Nebraska, and other states on permitting and pollution prevention
issues. Georgia, contacted Massachusetts and Illinois to request copies of materials prepared for their printing
workshops. Georgia contacted Iowa, California, and Texas about developing a customer survey form.
Air program has inquired and received information from several SBTCPs. Air program will continue to request and
evaluate material for incorporation into own SBTCP.
By working through Leadership Grant with Washington, Oregon, and Alaska, the Region 10 states developed several
factsheets in cooperation with the Northwest Pollution Prevention Center.
Quarterly Region V conference calls. An annual meeting in Chicago in July. Gather at the national annual conference.
Communicate with one another electronically.
Participates in quarterly conference calls with other Region V SBAP programs to share information. Program
documents are sent to other states Upon request. Documents regarding mercury, dry cleaners, and the mineral
aggregate industry are automatically sent to all other Region V SBAPs. Indiana developed a dry cleaner brochure,
manual, and 5-Star recognition program that several other states, including Illinois and Wisconsin, are using with little
or no editing. Communicates with other SBAPs to request information or leads to find information (calls, letters,
electronic mail). Reviews EPA documents and contacts EPA for information. Reviews documents created by other
sources (Solid Waste Management Districts, local pollution control or health agencies, private organizations, other state
agencies). Gathers information from electronic sources (this mode of gathering information is limited, as most of
Indiana's SBAP staff does not have Internet access).
IWRC produces the Small Business Assistance Program (SBAP) resource guide, which is updated annually and
distributed at national conferences. The guide lists available resource material and assistance tools (with brief
descriptions) from other states. Whenever possible, IAEAP refers to this guide to avoid duplication.
SBEAP personnel attend trade, professional, and regional/national pollution prevention and small business meetings.
This allows us to keep abreast of work in other states and obtain resources. Whenever possible, we will also request
and use materials from other states and EPA. Specific examples include the wood furniture MACT (Tennessee) and
printer's pollution prevention (Wisconsin) teleconferences that we downlinked. We also share our information with
other states at their request. Specific examples include our Airlines newsletter, the Environmentally Conscious Painting
Manual, provide spaces for participants from adjoining states at teleconference downlink sites, and the 1 1 2(r)
publication. The 112(r) publication was used at a MO Department of Natural Resources workshop and also was
distributed at the most recent EPA Region VII P2 Roundtable meeting.
-------
TABLE E-14
(Continued)
PROGRAM
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
COMMENT RCCGVED
KBEAP uses EPA and other state-developed material on federal regulatory issues. SBO reviews newsletters from other
states for ideas. Information packets from EPA Ombudsman are a valuable source of information on small business
assistance activities. SBO also reviews Internet information. This year, time was spent on preparation of a new
regulation format to incorporate user-friendly features rather than development of publications. Contact people and
examples of user-friendly regulations were located through the SBO network.
A self-auditing manual for body shops currently is being written based largely on one developed in California.
We exchange brochures, and miscellaneous literature with many states. We have used them as a guide to prepare our
literature. For example, we used the wood furniture reporting forms from another state as a guide to prepare a similar
form. SBAP Project Manager serves on a DEQ task force whose objective is to coordinate all outreach programs within
the agency.
We are on the mailing list for many state programs and get brochures and documents from other programs. We
sometimes use this information in our own newsletters and to stock our library. We rely on EPA Ombudsman office to
distribute useful information from other states. SBTAP also is a subscriber to P2 Tech Bulletin Board, which is
accessed by many state SBTAPs.
Maryland's SBAP limits its efforts to providing state-specific regulatory assistance to Maryland businesses, which
cannot be a duplication of other state's efforts. SBAP regularly communicates with EPA Region III to avoid duplication
of effort concerning federal MACT rules.
We communicate with other SBAPs and, as time allows, try to check TTN and other EPA home page information to see
what's being developed and put in practice in other states.
Michigan tries to maintain contact with its EPA Region V SBAP counterparts in an effort to update and exchange
information on each state's upcoming SBAP activities. Initially, Michigan suggested the best way to avoid duplication
of efforts and for timely updates of states' activities was through quarterly conference calls with the EPA Region V
states and a Region V EPA representative. Additionally, as projects are developed, Michigan SBAP staff call other
states to talk with staff who have completed certain guidance documents for or presented certain types of workshops
to state facilities.
Region V quarterly conference calls. Annual Region V SBAP meeting. National SBO/SBAP conference. Personal
communications network with colleagues. EPA information packets from Karen Brown's office.
SBO office communicates with national SBO on planned projects. During these communications, information is
obtained as to whether or not any other states have conducted the same projects. Mississippi used information from
other states in presenting several auto bodv workshops this year.
8
-------
TABLE E-14
(Continued)
PROGRAM
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
COMMENT RECEIVED
Region VII states share information readily and utilize each other's findings. Articles are often used for our newsletter,
"TAP into DNR."
S80/SBAP met twice with other assistance providers in statewide "roundtables" to help each program understand the
types of assistance that are being provided. MT SBO completed a statewide directory of these services for distribution.
There is no other SBAP in the State of Nebraska.
SBO and SBAP attended two annual SBTCP meetings (San Diego, CA and Charleston, SO to get information on what
other state programs have developed. This office also continues to gather information from other state programs. SBO
and SBAP continually gather information from the various US EPA and other federal agency bulletin boards, both
electronically and through the mail.
The Washoe County AWMD was established as a separate regulatory entity by the state legislature and operates on the
same level as the state air quality regulatory agency. However, there is good cooperation between WCAQMD and
NDEP in referring people to the correct agency. Although within the county, there are two incorporated municipalities
(Reno and Sparks), the air district encompasses the entire county and therefore, there is no duplication of
administration.
The Clark County Air Pollution Control Division (CCAPCD) does not have a formal program to prevent duplication.
However, like Washoe County, they are a regional air district, which would avoid duplication of air quality
administration. CCAPCD suggested that the CAP be utilized to avoid duplication among all air agencies providing
assistance.
State BAQ - Because the county air agencies have their own air regulations and different mechanisms for enforcement,
no attempt has been made to coordinate compliance workshops. Other air quality issues, such as mobile sources and
Title V permitting, have been coordinated with the county air agencies.
BEP attempts to avoid duplication through coordination and communication of activities. Materials developed by other
state and local programs and EPA are used to develop training and informational materials.
Network with other SBAPs to see what is being developed elsewhere that could be modified for use in NH. Informal
contact with regional SBAPs for potential joint ventures for cross state border issues. Actively participate in regionally
based organizations (NEWMOA and EPA Region 1) for coordination of effort. Review available assistance literature from
a wide variety of sources (internet, workgroups, EPA, etc.).
SBAP has contacted 20-30 states for the ouroose of information exchanae.
-------
TABLE E-14
(Continued)
PROGRAM
COMMENT RECEIVED
New Mexico
Any time new materials are being developed, we check our library and our contacts in other parts of the country to see
if they have any current publications that we could use instead of "reinventing the wheel." For example: Iowa Waste
Reduction Center — Information in automotive manual was used to develop a set of automotive posters and a P2
manual (completed under US EPA Leadership Grant for TX, OK, and NM). Illinois, Massachusetts, and EPA - Printers
manuals were used to develop Environmental Management Tools to fulfill grant along with TX and OK.
New York
Informal and formal communications among states. Information exchanges at conferences. Information from PA, TX,
and CA was adapted for inclusion in 3 New York state environmental compliance guides (for Surface Coaters, Gasoline
Transporters and Dispensers, and Graphic Arts). New York's "Environmental Self-Audit for Small Business" has been
adapted by several states.
North Carolina
SBO/SBAP annual conference provides both a forum and contacts that help with this. Contact by telephone with a
number of our counterparts also helps. Newsletters and brochures are received from a few of our peers. Many ideas
have been received from other states and we are in the process of developing several fact sheets and a new brochure.
In North Carolina, the SBO is part of a Small Business Partnership Group that includes SBTDC, university, and other
partners. The purpose of this group is to coordinate activities arid avoid duplication.
North Dakota
We receive newsletters from several state SBTCPs. Since we only have 0.50 FTEs committed to small business
assistance, it is important for us to capitalize on the successes of and information available from larger SBTCPs. Also,
WESTAR and EPA Region VIII states have conference calls among the state SBAPs and SBOs where the states discuss
and exchange ideas.
Ohio
SBAP participates in an annual two-day conference with Region V states, usually held in August. The purpose of this is
to share information, literature, and outreach activities with the other state programs. The SBAP has solicited input
from other states on CAP functions, budgets, and customer satisfaction surveys. SBAP aided three other states in
developing confidentiality legislation and/or policy for their SBAP. SBAP is developing a customer satisfaction survey
modeled after Minnesota's and has solicited other states' RACT rules for printing to develop new OEPA permitting
guidance for small printing companies.
Oklahoma
OK SBAP has, to a certain extent, made use of information regarding compliance issues for small businesses produced
by other states. However, because our air quality rules are different than those in other states, the sharing of such
information is limited. We do, at times, adapt for our own uses those ideas/products that other states have produced.
This often decreases the amount of work we have to do in regard to developing such information.
10
-------
TABLE E-14
(Continued)
PROGRAM
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
COMMENT RECEIVED
OR SBAP, because of its very limited resources, is limited in its ability to develop informational documents. Thus, a
variety of documents published by other SBAPs and other resources such as EPA, the Pollution Prevention Resource
Center in Seattle, the Pollution Prevention Outreach Team, the Universities of Tennessee, Minnesota, Iowa, etc. are
used to transfer information to small businesses, their service providers, and the public. In Region X, SBAPs are
funding a full time position at the Pollution Prevention Resource Center to do special projects. During 1 996, the PPRC
published fact sheets on halogenated solvent cleaning, calculating air emissions using information contained on MSDS
sheets, chrome plating, and accidental release prevention. Publication of cross-media P2 guidance book for printing
and publishing, auto repair and finishing, wood furniture manufacturing, metal finishing, and spray applications are
pending. SBAP, EPA, and other materials posted on the Internet are accessed frequently. The 1 5 member WESTAR
SBAPs meet via telephone conferences every other month and exchange ideas and written information. Fact sheets
also are collected at the annual SBO/SBAP conferences and added to OR's information library. SBAP maintains a video
film library containing teleconferences on painting, dry cleaning, chrome plating, wood furniture manufacturing,
halogenated solvents, and other subjects. OR SBAP plans on using the wood furniture coating coursebook and videos
developed by the MN SBAP at a future workshop(s). English and Korean translations of dry cleaner publications
published by the CA Resources Board have been used, among others.
Information from other states, such as fact sheets, brochures, and newsletters, is reviewed. To date, no information
from other states has been used with minimal editing in the Pennsylvania SBAP.
We use copies of the "comic books" developed by California to help small businesses understand the regulations,
recordkeeping, etc. and to provide ideas for P2. They have been very helpful to us, especially the ones that are in
Spanish, since we don't have the means for translation of the rules. We use plenty of the information our SBAP staff
brings from the SBO/SBAP annual conference. Throughout the year, our SBAP staff makes phone calls to other states
to clear doubts on different matters. We also share many ideas and exchange information with other states.
Each year, Rl DEM SBAP staff attend national EPA-sponsored conferences on SBO/SBAP/CAA. Information obtained at
these meetings and through other means is extremely useful and is reviewed for incorporation into Rl DEM fact sheets
and information packets. Rl shares all of its technical information and fact sheets whenever requested. Rl frequently
uses other states' materials when developing its own. Rl DEM is active in the Northeast Waste Management Officials
Association, NE States Pollution Prevention Roundtable, and shares information with other New England states on SBO
and SBAP activities.
Networking with other SBAPs via phone, mailing lists, etc. Review of EPA documents. SC has adapted guidebooks
developed by Texas and Iowa for use in our state. We also have used information provided in newsletters of several
states.
South Dakota avoids duplication through national small business meeting. WESTAR also has been very helpful in
getting individuals that work in the small business program together to exchange ideas. WESTAR has a bulletin board,
which the members have decided to use to exchange ideas.
11
-------
TABLE E-14
(Continued)
PROGRAM
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
COMMENT RECEIVED .
Texas Independent Small Business Marketer of Gasoline Determination form. Minnesota Accident Release Prevention
information sheet. Oklahoma loan workshop modeled. Information is collected from national meetings, bulletin
boards/web pages. Information is researched and states are phoned before projects are initiated.
Michigan requested information from Texas on the wood products industry. Washington reojuested information on the
printing industry. Utah requested information on the auto body industry. Texas requested information from California
on their amnesty programs, but developed our own materials. We share information with other states through an
electronic e-mail network that the Iowa Governor's Office set up.
WY Pollution Prevention Program: "MSDS Fact Sheet." MN Technical Assistance Program: "Alternative Cleaning
Technologies for Vapor Decreasing and Cold Dip Process" and "Reducing Solvent Emissions from Vapor Degreasers."
CO Air Pollution Control Division: "Emissions for APEN Reporting, Solvent Users," "Emissions for APEN Reporting,
Printers," and "Emissions for APEN Reporting, Automotive Paint Booths."
By communicating with other programs on a regular basis.
Communication with other states to identify materials developed and programs that were successful is a course of
business for the VA SBAP. With the reduction in financial resources, we must leverage as much and as many
resources as possible. To that end, the utilization of the SBO/SBAP national steering committee has provided an
increased avenue of resources and material identification. Over the reporting period, a large number of other state
programs have been contacted and, where possible, materials have been used with minimal editing in VA. Activity to
thwart duplication of effort is a prime concern not only at the state level, but at EPA regional and national.
N/A
Have periodic meetings with other Region X SBAPs and participate in WESTAR's (Western States Air Resources) SBAP
group. Exchange relevant publications with other states.
We continue to work with surrounding states in reviewing outreach and workshop materials. We coordinated with
Utah on the wood finishing teleconference. Shared chrome information with adjoining states and acted as a resource
on the NSW NSPS for other states. Participated in regional and national conferences.
We regularly maintain contact with other SBAPs in EPA Region V to ensure the most efficient possible use of materials,
including: participating in quarterly conference calls with Region V states to share information and publications;
attending annual Region V meetings and information exchanges; making electronic information exchanges with other
states on a routine and nationwide basis; developing professional relationships between state programs sharing
information via Internet; exchanging fact sheets and brochures; and developing cross border seminars on shared
environmental concerns.
12
-------
TABLE E-14
(Continued)
PROGRAM
Wyoming
COMMENT RECEIVED
WY SBAP has established oral and written information exchange with a number of regional states' SBAPs and SBOs to
decrease duplication of efforts. In addition, the SBAP coordinates its program with EPA Region VIII. The WESTAR
states SBAPs and SBOs try to meet annually to maximize each state's resources and to further develop their
information exchange network.
13
-------
TABLE E-15
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE PAPERWORK REDUCTION ACT
Program
AL
AK
AZ
Maricopa
Pima
AR
CA
SCAQMD
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
Routine review of
SBTCP
document* for
compliance
N/R
X
None
X
N/A
N/A
N/A
N/A
N/A
Receiving/
providing
information
electronically
X
X
X
X
X
X
Simplified/
consolidated
permit* and/or
forma
X
X
X
X
Eliminating
unttecaaaary
permit* by
incr*a*ing
exemption*
X
X
General
permit* for .
certain type*
of 1ndu*trie*
X
X
Condaeea»y~
to-read
eummary
document*
X
X
X
X
Other
(See below)
X
-------
TABLEE-15
(Continued)
ProQram
IA
KS
KY
Jefferson
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NJ
NH
NM
Boutin* review of
S&TCP
document* for
compliance
N/A
N/A
SeeKY
X
N/A
X
X
N/R
N/A
N/R
Receiving/
providing
information
electronically
X
X
X
Simplified/
. consolidated
permits and/or
form*
X
X
Eliminating
unnecessary
permit* by .
increasing
exemption*
X
General
permit* for
certain type*
of Industrie*
X
X
Condseeasy-
to
-------
TABLEE-15
(Continued)
Program
NY
NC
NO
OH
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
Boutin* review of
S8TCP
document* for
compliance
X
N/A
N/R
N/A
N/A
X
N/A
X
X
N/A
N/A
X
Receiving/
providing
information
electronically
X
X
X
Simplified/
consolidated
permit* and/or
form*
X
X
X
X
Eliminating
unnecewary
permit* by
incraa*ing
exemption*
X
X
X
General
permit* for
certain type*
of indttttriet
X
X
X
X
Cond*eea*y>
to-read
*ummary
document*
X
X
Other
(See below)
X
X
-------
TABLEE-15
(Continued)
Program
WV
Wl
WY
TOTAL
rwuui np f wmwww wt
SBTCP
document* for
compliance
X
N/A
11/21%
Receiving/
provttfng
information
eiectroniceMy
X
11/21%
Simpflfltd/
consottdated
penmfts and/or
form*
X
12/23%
Biminating
unnecessary
permits by
•increasing'
exemptions
6/11%
; General
permits fw
eartain typaa
ofittduatrtaa
X
9/17%
Concdaaaaty>
to-raad
aummary
doeumanta
X
10/19%
Othar
(Saabalow)
8/15%
Other Actions:
CT SBAP, in conjunction with the Department of Revenue Services, developed a simplified process for applicants for reviews of requests
for tax credits and exemptions for air pollution control equipment.
KY Role in development of new regulation format to incorporate user-friendly features.
MA Reduce and recycle paper where possible.
MN Various efforts to condense, streamline, and reduce volume of paper associated with regulations.
MO One-on-one technical assistance for small business to reduce small businesses' time in reading and interpreting regulations.
NM Doublesided printing, waste paper used as scrap, all paper recycled.
OK Developing new permitting approach/philosophy requiring a more common sense approach to regulations.
OR Non-major PTE Title V permits deferred to July 1998.
-------
TABLE E-15
(Continued)
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE PAPERWORK REDUCTION, REGULATORY FLEXIBILITY, AND EQUAL ACCESS TO JUSTICE ACTS
Program
Alabama
Alaska
Arizona
Maricopa Cty
Pima Cty
Arkansas
Comment Received
N/R
No actions taken per se. All materials prepared by the SBTCP are evaluated prior to distribution and, wherever
possible, electronic versions are provided. The SBTCP evaluates materials from the Air Program and makes
recommendations for streamlining or simplifying permit materials for use by small businesses. The SBTCP is evaluating,
in conjunction with other Department programs, the various opportunities for regulatory flexibility and developing
incentives for compliance to promote environmental excellence.
CAP has not met to date, but the SBAP is participating or leading many efforts to follow these Acts. SBAP is
participating on a Public Participation Committee that is evaluating how to more effectively reach out to constituents by
alternative methods, such as e-mail or the Internet.
SBO/SBAP is serving as project manager for the agency web page, which can alleviate a great deal of paperwork. The
agency hopes to provide permit applications, frequently requested reports, guidance documents, rule notices, and
finalized rules.
SBAP continues to work within the agency to provide regulatory flexibility for businesses that have a proven history of
environmental compliance. SBAP has just applied for a grant from EPA Office of Water to set up pilot projects to
investigate regulatory flexibility for businesses implementing an environmental management system. The grant will be
awarded to successful applicants in April.
SBEAP has a great new home page. It contains information about programs, industries that probably need a permit,
calendar with workshops/events, P2 information, enforcement procedures, emission inventory, rules, and regulations.
Most, if not all, are intention of Paperwork Reduction Act and other federal acts.
No particular changes to existing program.
A major work element with SBAP is the interpretation of National Air Emission Standards and the publication of
regulatory documents that are more user friendly. This will continue to be a major work effort in both air and water.
In response to the principles set forth in the Equal Access to Justice Act, SBAP has provided technical support to
several public groups aggrieved by permit actions of the regulatory agency. Primarily, these activities have centered on
land application of municipal sewage waste, corporate hog farming, and groundwater contamination from solid waste
landfill. Funds have been made available from the Department to employ engineering support to citizen groups. This
has been a very interesting facet to SBAP.
-------
TABLEE-15
(Continued)
Program
California
SCAQMD
Colorado
Comment Received
Governor Pete Wilson is leading a
the intent of the Equal Access to
for parties to present their claims
comprehensive streamlining and regulatory reduction program. In an effort to further
Justice Act ARB provides in its administrative proceedings a full and fair opportunity
An example is our Heavy-duty Vehicle Inspection Program hearings. '
SCAQMD is a regional regulatory agency and is not required to have a CAP. However, a CAP-like Local Government
and Small Business Committee is being formed. SBAP has made information and forms available on the Internet. The
agency is piloting a program to allow permits to be submitted electronically. Permit and other AQMD information are
available in multiple languages.
SBO/SBAP continue to review air
small businesses.
regulatory rules and permit applications to assure they are not overly burdensome to
-------
TABLEE-15
(Continued)
Program
Comment Received
Connecticut
Paperwork Reduction Act: 1) CT SBAP has been an advocate for a number of regulatory streamlining efforts including
recordkeeping and reporting requirements for DEP's air quality regulations. Many of these efforts have centered on the
implementation of hew programs such as Title V. More effort has been focused on reducing the number of application
forms that need to be completed as well as an attempt to eliminate any redundant forms or requests for information.
2) SBAP participated in the development of a general permit for small businesses to opt out of the full Title V program.
The development of the FAST Vs Program has encouraged a wholesale revaluation of permitting processes. Areas of
focus have included simplifying recordkeeping requirements, eliminating redundancies, and evaluating areas where
reporting requirements can be eliminated or consolidated. 3) SBAP, along with the Air Bureau's Permitting Section,
have been actively involved in the development of general permits for small sources subject to New Source review
requirements. General permits have been issued for minor sources under Title V, emergency engines, automotive
refinishing, and surface coating. A general permit for small boilers is still under development. The general permits
already adopted eliminate the need for individual reviews and provide a simple, streamlined application process. For
facilities covered under one of these general permits, recordkeeping and reporting requirements will be significantly
reduced. 4) SBAP, in conjunction with Department of Revenue Services, developed a simplified process for applicants
for reviews of requests for tax credits and exemptions for air pollution control equipment.
Regulatory Flexibility Act: To minimize the sometimes disproportionate regulatory burdens imposed on small businesses,
CT SBAP implemented several initiatives to help promote cost effective environmental regulation. 1) FAST Vs
(Fundamental Assistance for Small Title V Sources) represents a "back to basics" approach to air quality permitting.
FAST Vs will be offered as part of an intensive year long effort to provide hands-on permitting assistance to small
businesses. Small workshops currently are being held in locations around the state and will provide hands on
instruction on how to calculate the potential and actual emissions as well as how to complete the General Permit to
Limit Potential to Emit (GPLPE) registration form. A facility training model will be used to provide attendees with
suggestions on how to address Title V requirements for their facility. 2) Compliance Assurance Initiative for Autobody
Shops was developed to provide on-site compliance assistance to auto body shops in CT. The program was designed
to provide intensive, targeted compliance assistance to small shops within the state to raise awareness about
impending Title V requirements and to provide technical assistance on simple streamlined permitting options to meet air
quality requirements. This effort, in many cases, provides auto body shops with access to information and eliminates
costly permit applications and fees for preparation. 3) Review and comment on all new air quality regulations to
provide input on small business impacts. 4) Worked on general changes to the
-------
TABLE E-15
(Continued)
Pfooram
Connecticut
(cont.)
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Comment Received
fee regulation for air emissions. The fee regulation, which recently has been adopted, implements several reductions in
fees for small businesses and eliminates emission-based fees for some general permits.
Equal Access to Justice Act: In an effort to provide a forum for small businesses to participate in the Department's
regulatory process, the CT SBO has been appointed as co-chair of the Air Bureau's Clean Air Act Advisory Committee.
The Committee meets monthly and provides members with updates on new regulatory requirements and technical
assistance. CAP has established several subcommittees dedicated to specific small business sectors. Stakeholder
involvement is initiated as part of the regulatory development process as part of a large Air Advisory Group as well as
part of the CAP.
Every attempt is made to provide assistance in clear and simple plain English and to avoid excessive technical terms.
When technical information is referenced or needs to be reported by a small business, the reason is clearly explained as
well as why it is necessary to provide such information.
N/A
N/A
Paperwork Reduction Act: SBAP requested that the Air Toxics Unit streamline the information requested from small
businesses subject to the Wood Furniture and Printing and Publishing MACT standards. The Air Toxics Unit
incorporated our suggestions and allowed the aforementioned industries to notify the Division and apply for a permit
using the same form.
Regulatory Flexibility Act: Ombudsman prepares an impact statement of each proposed rule and its effect on the small
business community before a rule is adopted by the state. The report is available for the CAP to review.
Equal Access to Justice Act: Not an issue in 1996.
N/A
None this year.
N/A
8
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TABLEE-15
(Continued)
Program
Indiana
Indiana (cent.)
Iowa
Kansas
Comment Received
Paperwork Reduction Act:
General - 1 ) Providing documents electronically via the FaxBack system. 2) Allowing customers to call and receive pre-
recorded information via Custom Connect, a service offered by the local telephone company. 3) Creating an Internet
site to allow customers to access information electronically. 4) Producing concise, easy-to-read documents to assist
customers in understanding and complying with environmental requirements. Some of these documents include
compliance manuals targeted to specific industries, guidance documents, and brochures and flyers. 5) Removing
obstacles to compliance by providing on-site assistance, phone assistance, workshops, and the above mentioned
documents.
Title V - 1 ) Meeting with Clean Air Act Advisory Committee (comprised of interested parties, including the regulated
community, consultants, associations, etc.) to discuss Title V implementation and permitting issues. 2) Forming various
industry workgroups to obtain input on Title V compliance monitoring requirements for each industry. 3) Increasing the
number of tiers under IN's Title V program (from 3 to 4) to offer businesses a more appropriate permit for emissions,
fees, and time required to complete the application. 4) Increasing the number of Source Specific Operating Agreements
offered in the Title V program so that more types of small businesses could take advantage of this permitting
mechanism. 5) Developing a permit-by-rule permitting mechanism to allow businesses with very low emissions to avoid
the need for a Title V permit. 6) Working with industry sectors to develop the SSOA programs so that industry could
give input into the programs. 7) Creating simplified permit applications and record keeping requirements for SSOA and
permit-by-rule sources. 8) Facilitating reduced permitting fees for SSOA and permit-by-rule sources. 9) Providing
businesses with electronic applications (although submitted applications must be in hard copy form due to the agency's
computer limitations). 10) Increasing the number of insignificant activities under the Title V program.
Hazardous Waste - 1 ) Meeting with Hazardous Waste Advisory Workgroup (comprised of interested parties including
the regulated community, hazardous waste haulers, treatment facilities, environmentalists, associations, etc.) to
discuss issues impacting the regulated community. 2) Working with the Office of Solid and Hazardous Waste
Management (OSHWM) to assist them in preparing to conduct a series of visits (informal inspections) to vehicle
maintenance shops. Worked with OSHWM and Automotive Services Association of Indiana to inform shops of
upcoming visits, the intent of the visit, and what to expect.
Regulatory Flexibility Act: 1 ) Allowing companies in violation of environmental rules to participate in supplemental
environmental projects (SEPs), thereby allowing companies to make environmental improvements while reducing their
penalties. 2) See above information regarding Title V permitting options, fees, and recordkeeping requirements. 3) See
above information regarding the Hazardous Waste Advisory Workgroup.
CAP is not operational yet. Pending Governor's appointment.
CAP is to be trained by KDHE's staff attorney at the 2/20/97 CAP meeting. No specific actions regarding these acts
were taken bv the CAP in 1 996.
9
-------
TABLE E-15
(Continued)
Program
Comment Received
Kentucky
SBO, SBAP, and CAP had rolas in tha development of a new regulation format to incorporate user friendly features.
This project supports the intent of the Paperwork Reduction Act and the Regulatory Flexibility Act. SBO talked to the
Agency minority recruitment person on methods of increasing outreach, which lays the groundwork for complying with
the Equal Access to Justice Act.
Jefferson Cty
See Kentucky response.
Louisiana
SBAP created an Internet home page to disseminate information and reduce paperwork. Forms that are sent to small
businesses are kept as brief as possible. We have had no occasion to use the Regulatory Flexibility and Equal Access
to Justice Acts. SBAP prepared summaries of these three acts that will be included in the packets for the new CAP
members.
Maine
CAP routinely reviews documents of the SBTAP.
Maryland
None.
Massachusetts
A good example of the attention to both Paperwork Reduction Act and SBREFA is demonstrated by the MA Printers
Partnership (MP2) program. This program was a joint effort of OTA (SBAP), MA/DEP, US EPA Region I, Printing
Industries of New England, printers, vendors, and consultants designed to significantly simplify compliance issues for
printing firms throughout the state and (nearly completely) across industry sectors. The program workbook approached
the printing process from a multimedia (M2) perspective and summarized all applicable regulations. The workbook
consists of three sections: Section I (24 pages) explaining regulatory requirements as they relate to printing, by process;
Section II (36 questions and related explanations), which comprise the self-certification portion; and the Appendices,
which include statewide information of POTWs, sample signs and postings for hazardous waste areas, background data
on hazardous wastes, Hazardous Air Pollutants, etc. The program replaced the facility's requirement to obtain non-
major air permits, industrial wastewater permits, Class A Recycling Permits, and the annual compliance fees for each of
these programs. Eight workshops were conducted throughout the state, and six hands-on clinics were held to answer
specific questions about Partnership requirements and process implementation.
Several mailings were conducted to the entire printing community of 1,500 printers statewide, and combined
attendance at workshops approached 600. The clinics attracted 44 people for hands-on assistance. 435 companies
joined the program by the certification deadline of 7/1/96. Although the decision was made to allow companies to
continue to join the Partnership program at double the regular fee (still less costly than the cost of permits and fees),
this action was not widely broadcast, and the result was small.
We are collaborating with MA DEP in the design/implementation of the state's Environmental Results Program (ERP) for
the printing industry, which will convert the voluntary pilot program to a regulatory structure. All printers in specified
sectors who are not major sources of air emissions, not Significant Industrial Users (water), and not required to file
SARA TRI or MA/TURA will be required to participate. Program is scheduled to open the self-certification period from
7/1/97 to 8/31/97.
10
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TABLEE-15
(Continued)
Program
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Comment Received
Paperwork Reduction Act: Michigan's SBTCP is in on-going compliance with Michigan's "Management and Budget Act
(PA 431 of 1984)," which required all state agencies to reduce and recycle paper whenever possible. The Act is
modeled after the "Federal Paperwork Reduction Act."
Regulatory Flexibility Act: No actions were initiated by SBTCP under this Act.
Equal Access to Justice Act: No actions were initiated by SBTCP under this Act.
Many efforts to condense, streamline, and reduce volume of paper associated with regulations. Wood Finishing
Enforcement Waiver for administrative violations to get businesses into the system. Seek comments and concerns
from small businesses for better ways to assist them and also encourage and help them to comment on new rules and
policies during development.
Ombudsman and SBAP keep small businesses aware of these Acts and how they are affected by them. CAP reviews
the newsletters and other materials designed to comply with these Acts.
Paperwork Reduction Act: The Department of Natural Resources Technical Assistance Program transmits
documentation via electronic media whenever possible. Much of the assistance we provide is report and permit
preparation and guidance in a one-on-one setting to help Missouri businesses understand the requirements without
having to spend time reading all of the regulations and figuring it out on their own.
Equal Access to Justice Act: While not necessarily a component of this Act, we are targeting small businesses that
may be the least capable of having the capital or human resources to allow them to comply with the Clean Air Act
requirements.
CAP review of all SBO/SBAP publications and productions.
N/R
CAP was made aware of the provisions of these various federal laws. CAP has not the opportunity to provide other
than minimal advice to SBTCP on actions that will meet the letter of each of these laws.
11
-------
TABLEE-15
(Continued)
Program
Comment Received
New Hampshire
Paperwork Reduction Act: Support for DES efforts to implement general permits (permits by rule). Reduction in permit
application requirements for very minor sources. Prepared plain language interpretation letters for CAAA requirements
on a one-on-one basis.
Regulatory Flexibility Act: Support state efforts for self-audit/self-certification. Support efforts involving alternative
compliance requests for regulatory issues. Support for amnesty programs for voluntary disclosure. Work closely with
enforcement bureaus to ensure reasonability in enforcement actions.
Equal Access to Justice Act: Participated in NEWMOA initiative to minimize impact of auto repair and refinishing
operations in low socio-economic areas. (This also was an extension of a NH SBAP initiative to provide compliance
assistance manuals to the industry in NH.) Ensure compliance assistance efforts to identify and address concerns for
minimization of transfer of impacts to low socio-economic areas.
New Jersey
N/R
New Mexico
Paperwork Reduction Act: NM SBAP tries to comply by printing all interagency and outside correspondence using both
sides of the paper. Additionally, all waste paper is used as scratch paper (e.g., emissions calculations, draft memos).
All paper is recycled.
Regulatory Flexibility Act: Action teams comprised on NMED personnel, NM business people, and environmental groups
were developed to take a look at and recommend improvements to the current policies arid regulations.
Equal Access to Justice Act; All state regulations are available on our web site and bulletin board.
New York
Through input of the SBTCP during the regulatory process, streamlined permitting procedures for small businesses have
been incorporated into NY's operating permit program. This will significantly reduce the costs associated with
permitting minor sources and the paperwork required to be submitted to the state regulatory agency.
SBTCP also has developed industry-specific guidebooks and brochures that summarize regulatory requirements in
simple terms, thus reducing the amount of copying and reproduction of extensive regulations.
North Carolina
1) Work in state regulatory arena to increase number of exemptions from permitting of insignificant activities.
Eliminates the need for unnecessary permits. 2) Helped develop cutoffs for different types of operations included in an
exclusionary rule that defines potential emissions as actual. Allows small facilities to use more realistic emission
calculations to meet requirements and minimizes the recordkeeping and reporting requirements. 3) Initiated and helped
develop a simplified permit application for non-Title V facilities. This has reduced paperwork required for an air permit
application by 50%. 4) Continued work on general permits to ease application process and reduce cost of permit.
Work continues on general permits for asphalt plants and aggregates/non-metallic mines. 5) NC is involved in a permit
reform effort with the ooal to reduce paperwork and improve regulatory flexibility.
12
-------
TABLE E-15
(Continued)
Program
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
Comment Received
CAP reviewed documents pertaining to dry cleaner facility pollution prevention and new rules. CAP discussed issues
regarding the impact of new rules and policies of the various media programs that are pertinent to small businesses.
No progress. However, the seventh CAP appointee is an attorney, which should influence the work the CAP does in
1 997 on this subject.
SBAP has been actively involved in a major regulatory revision within the Agency. Recently, our Director developed a
new permitting approach/philosophy requiring a more common sense approach to environmental regulations. This
includes air quality rules, most specifically those that affect small businesses. As a result, SBAP has been and
continues to be actively involved in the process representing the needs of small businesses and developing strategies
that are mutually beneficial to the environment and the small business community.
Paperwork Reduction Act: OR's SBAP and CAP did not impose additional reporting or recordkeeping beyond that
required by federal law. Non-major PTE Title V (50% rule) permits were deferred until July 1 998. Permitting of area
NESHAP sources also have been deferred in accordance with EPA published policies. Permanent exemptions have been
given to decorative chromium electroplating and anodizing businesses using fume suppressants. SBAP also is
considering various regulatory options for small air emission sources, which will alleviate overly burdensome paperwork
and reporting requirements. Options under consideration include prohibitory rules, permit by rule, and general permits.
Regulatory Flexibility Act: OR continues to explore ways to attain full compliance with state and federal regulations
without placing undue burdens on small businesses. Small businesses with actual air emissions less than 50% of major
source threshold need not apply for Title V permit until July 1998. It is estimated that this action will reduce the
regulatory burden for at least 1 ,000 smaller businesses. OR also has elected to defer permitting of non-major dry
cleaning, chrome plating, ethylene oxide sterilizing, and users of regulated halogenated solvents for 5 years in
accordance with the 1 990 CAA.
Equal Access to Justice Act: OR SBAP and CAP are unaware of any provisions in state statute, Title V regulations, or
the Small Business State Implementation Plan that violates or contravenes any requirement set forth in this Act.
Minority business owners serve on the CAP.
N/R
None.
SBTCP program coordinator hired in November 1 996. Formal program currently is being developed. The intent of these
provisions will be incorporated, as appropriate, into the Rhode Island program.
Receiving/providing information electronically. General permits for certain types of industries. Review/comment on
new air regulations to evaluate impacts. Routine review of SBTCP documents for compliance.
13
-------
TABLEE-15
(Continued)
B»ut«w«M
proof wn .
South Dakota
Tennessee
Texas
Utah
Vermont
Comment Received
The department's goal always has been to have simple, easy to understand forms. The forms have not been updated
since the CAP has been appointed. Therefore, the CAP has not had to review any forms yet.
CAP not appointed.
Paperwork Reduction Act: All materials are reviewed by a statewide plain language committee to ensure materials are
brief and easy to read.
Regulatory Flexibility Act: Developed a wood products amnesty program to identify problems and inconsistencies with
air regulations. SBAP is working on revisions to the standard exemption that applies to wood products manufacturers
to reduce reporting and simplify compliance. Developed the foundry initiative, which will identify problems and
inconsistencies with environmental regulations. Recruited small businesses to serve on statewide rule review
committee to review and comment on environmental rules that affect small businesses.
Equal Access to Justice Act: Recruited legal volunteers through the EnviroMentor Program to provide legal expertise to
businesses that cannot afford it.
Paperwork Reduction Act: Committee is providing ongoing input on outreach materials, which includes brochures,
surveys, newsletter, mass mailings, etc. for readability in accordance with this Act.
Regulatory Flexibility Act: SBAP/SBO and Air Quality have provided presentations and training to the Committee on
technical materials and regulatory changes to encourage input and discussion on various changes in state and federal
standards and requirements.
Equal Access to Justice Act: SBO provided regulatory statutes to all CAP members and SBAP staff. SBO conducted
national research on this Act as well as local research with a Utah-based national expert, Dr. Susan Olsen, University of
Utah professor and nationally published authority on this Act. This information was relayed to CAP and SBAP.
No actions in this area have vet been taken.
14
-------
TABLE E-15
(Continued)
Proof am
Virginia
Virgin Islands
Washington
West Virginia
Comment Received
Paperwork Reduction Act: SBAP is making every effort to communicate and provide assistance electronically with all
constituents. EPA Leadership Grant is providing an excellent platform for this electronic development. The program
also is actively involved in development of permit application forms and permit boilerplates to facilitate the ease of
understanding and the reduction of paper in the regulatory process. SBAP was the chair of an internal committee to
develop a general permit exclusionary rule to limit the number of sources impacted by regulations. Additionally, the
DEQ is highly active in paper recycling.
Regulatory Flexibility Act: SBAP participated in joint development of Title V application boilerplate for Title V and the
Wood Furniture Manufacturing MACT to ensure all applicable standards and requirements are covered and are in a
format to enhance understanding. SBAP director participates on behalf of the ombudsman in regulatory development
activities. This year, we participated in the development of a minor NSR permit regulation revision, state operating
permit regulation revision, and a general permit potential-to-emit exclusionary rule. SBAP maintains active dialogue
with the Agency enforcement activity so that small business policies and protocols are kept visible. Enforcement relief
is provided through the utilization of the 507 Enforcement Policy.
Equal Access to Justice Act: SBAP developed and maintains a service-specific listing of contractors willing to work
with small businesses as well as large businesses. Regulation development activities encompass the goals of this Act
by reducing, where possible, the regulatory burden of the small businesses. DEQ has been involved in a regulatory
reform initiative for the last several years, reviewing all of its regulations for applicability, understanding, and possible
improvement.
N/A
CAP has given SBAP full support in participation in Air Quality Program's rulemaking activities to assure compliance
with the Paperwork Reduction Act.
SBAP developed alternate reporting forms for specific industries that consolidate information required for meeting some
state and federal rules (e.g., dry cleaners, chrome electroplaters). SBAP and SBO are working with the
permitting/enforcement group and trade organizations to develop general permits for specific industries. Two
individuals have now been assigned the specific task of developing a coal handling/preparation general permit. SBO
intercedes on behalf of small businesses at their request during enforcement actions. This follows the intent of the
Regulatory Flexibility Act and the Equal Access to Justice Act. SBTCP has an ongoing effort to coordinate and develop
agency policies that consider the limited resources of small businesses and ensure consistent and equitable treatment.
SBAP developed less intimidating forms for minor violations that may be used by enforcement staff. CAP solicited
input from industry on current regulations for use in developing future legislation that may resolve some small business
issues. The panel also is supporting the development of an environmental loan program to help those with inadequate
resources to implement collation prevention measures or install control equipment.
15
-------
TABLE E-15
(Continued)
ttiuiim •IUL
rf VfllOTfl
Wisconsin
Wyoming
Comment Received
Wisconsin SBTCP/CAP initiated several actions in order to comply with the general principals of the Paperwork
Reduction Act including: 1 ) Using written materials developed by other state SBAPs.- 2) Producing rule regulation
summaries that are more concise and easier to read than state and federal statutes. 3) Having CAP review outreach
programs/materials to ensure they are concise, effective, and understandable. 4) Working cooperatively with University
of Wisconsin Extension and Wisconsin DNR on an ongoing basis to prevent duplication of effort. 5) Working to develop
a customer friendly version of permit database.
Wisconsin SBTCP/CAP has been complying with the general principals of the Regulatory Rexibility Act by: 1 ) Bringing
proposed environmental legislation to CAP for review and comment. 2) Ensuring comments made by the CAP are
presented to the state legislature and/or key leaders in state agencies. 3) Acknowledging the problems small
businesses have in dealing with environmental regulations and addressing them by providing direct assistance. This
assistance includes helping with calculations, clarifying rules and standards, sponsoring industry specific seminars,
creating user friendly publications, and providing referrals to other agencies providing assistance. 4) Working closely
with trade associations such as the Wisconsin Fabricare Institute, Printing Industry of Wisconsin, Wisconsin
Manufacturers and Commerce, and many others in developing outreach materials and obtaining feedback on regulations
affecting their industries. 5) Referring businesses to our Small Business Ombudsman, who has statutory reg flex
responsibility and convener power as part of her duties. The Small Business Clean Air Ombudsman (H. Rotnwell) is
separate from the Small Business Ombudsman
-------
TABLE E-16
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE REGULATORY FLEXIBILITY ACT
•>»*«,
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
consoftfotad
peimfts and/or
formt
N/R
X
N/R
N/A
N/A
N/A
N/A
N/A
N/A
N/A
unrtacwary
. parmittby
axamptktt* f or
insignificant
X
Ganaral parmit*
forcartain
industrial
specific parmH*
X
Routina ravfew of
SBTCP documents
forcompKanca
X
X
Amnasty
program
onnawair
ragulations to
•vaUiata impacts
X
X
X
X
Othar
(Saafaatow)
X
X
X
X
-------
TABLE E-16
(Continued)
Program
KY
Jeff Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NJ
NH
NM
NY
Simpttied/
con*ofidate4
permft* and/or
form*
SeeKY
N/A
N/A
X
N/A
N/A
N/R
N/A
N/R
X
Eflminatfne
•feAMH^^A k*V
pviiin«v By
exemption* for
tneHiniflcant
•ctlvrtfe*
General permit*
for certain .
Spa* of
•pacific permit*
X
Routine review of
SBTCP document*
X
X
X
X
X
Amne*ty
program
X
on new elr
ay's** Impart*
X
X
X
Other
(Set betow)
X
-------
TABLE E-16
(Continued)
Program
NC
NO
OH
OK
OR
PA
PR
Rl
SC
SO
TN
TX
UT
VT
VA
VI
WA
Singled/
consolidated
permit* and/or
form*
X
N/A
N/R
N/A
N/A
X
N/A
X
N/A
X
N/A
Efimirwting
unnecessary
mujuiHii Ku
|Mmm»oy
exemption* for
insignificant
actfvrtia*
X
X
X
Central permits
for certain :
t¥fMMt Of
indWriaa/
industrial
specific permit*
X
X
X
X
Routine review of
SBTCP documents
forcompRane*
X
X
X
Amnesty
program
X
nevww/comment
on new air
regulations to
evaluate impact*
X
X
X
X
X
X
X
Other
(See below)
X
X
-------
TABLE E-16
(Continued)
Program
WV
wt
WY
TOTAL
JHntjajffitttf
parrnfef and/or
fount
N/A
7/13%
, axamptlona f of
Irwtgnmcant ,
acitvtaa*
4/8%
General peniiilt
fofwtata
Indurtrfal
•paoifio parrnita
6/11%
Routina review of
CDYr^B _t^ju_m_ij.jut_.
SHTCP oocuniatni
for eomplianc*
X
11/21%
Amnetty
program
2/4%
ontwwaJr
rvjuations to
aM/AJllMta% feMAAAt*
X
X
16/30%
Other
X
X
9/17%
Other Actions:
AK Evaluating opportunities for regulatory flexibility and developing incentives for compliance to promote environmental excellence.
AZ SBAP continues to work within the agency to provide regulatory flexibility for businesses that have a proven history of environmental
compliance. SBAP applied for a grant from EPA Office of Water to set up pilot projects to investigate regulatory flexibility for businesses
implementing an environmental management system.
CT Small workshops to provide hands-on permitting assistance to small businesses. On site compliance to autobody shops.
IN Allowing companies in violation of environmental rules to participate in supplemental environmental projects, thereby allowing companies to
make environmental improvements while reducing their penalties.
NH Support efforts for self-audit, self-certification. Support efforts involving alternative compliance requests for regulatory issues. Work with
enforcement bureaus to ensure reasonable enforcement actions.
OK Developed new permitting approach/philosophy requiring a more common sense approach to environmental regulation.
OR Non-major PTE Title V permits deferred to July 1998 and 5 year deferment granted to non-major dry cleaning, chrome plating, ethylene oxide
sterilizing, and users of regulated halogenated solvents (as per CAA).
VA Enforcement relief provided through 507 Enforcement Policy.
WV SBO intercedes on behalf of small businesses at their request during enforcement actions.
Wl Providing technical/regulatory assistance to small businesses. Developing outreach materials with and obtaining feedback from trade
associations as to their membership needs. Referring small businesses to SBO, who has statutory regulatory flexibility responsibility and
convener power.
-------
TABLE E-17
SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS
OF THE EQUAL ACCESS TO JUSTICE ACT
Program
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
HI
ID
IL
IN
IA
KS
KY
Routine ravfow of SBTCP
document* for eompttane«
N/R
X
N/R
X
N/R
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Pro bono I*ga1 **rvtc«*
FuoOinytaciMliCai
a*»i*tanc« for group*
aggrieved by regulatory
agency action*
X
OttMT
(S*eb«low)
X
X
X
-------
TABLE E-17
(Continued)
, *•
PKWrarfl
Jeff Cty
LA
ME
MD
MA
Ml
MN
MS
MO
MT
NE
NV
NJ
NH
NM
NY
NC
ND
OH
Routine review of SBTCP
documents for compliance
SeeKY
N/A
X
N/A
N/A
N/A
N/R
X
X
N/R
N/A
N/R
N/R
N/R
X
N/A
Pro borto legal *ervic«»
Funding/technical
aeafetattca for group*
aggrieved by regulatory
agency actfont
oth**
(S»e below)
X
X
X
-------
TABLE E-17
(Continued)
Program
OK
OR
PA
PR
Rl
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
Wl
WY
TOTAL
Routine review of SBTCP
document* for compliance
N/R
N/A
N/R
N/A
N/A
X
N/R
N/A
X
N/A
X
N/A
N/R
N/A
N/A
9/17%
>
Pro bono legal services
X
1/2%
Funding/technical
assistance for groups
aggrieved by regulatory
agency actions
1/2%
Other
(See below)
X
X
X
9/17%
-------
TABLE E-17
(Continued)
Other Actions:
CA ARB provides in its administrative proceedings a full and fair opportunity for parties to present their claims. An example is our heavy-
duty vehicle inspection program hearings.
CT SBO serves on Air Bureau's CAA Advisory Committee, which provides updates on new regulatory requirements and technical
assistance. CAP has several subcommittees dedicated to specific small business sectors. Stakeholder involvement initiated as part of
the regulatory development process.
KY SBO talked to Agency minority recruitment person on methods of increasing outreach.
MO Targeting small businesses that may not have the capital or human resources to allow them to comply with CAA requirements.
NH Participated in NEWMOA initiative to minimize impact of auto repair and refinishing operations in low socio-economic areas. Ensure
compliance assistance to minimize transfer of impacts to low socio-economic areas.
NM All state regulations available on web site and bulletin board.
UT SBO conducted national and local research on this Act, which was relayed to SBAP and CAP.
VA SBAP maintains list of service-specific contractors willing to work with small and large businesses.
WV SBO intercedes on behalf of small businesses at their request during enforcement actions.
-------
APPENDIX F
PROGRAM EFFECTIVENESS
-------
TABLE F-1
COMMENTS RECEIVED BY THE SBO OR THE CAP ON THE SBTCP
(Comments edited for space)
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Pima Cty
Arkansas
California
SCAQMD
COMMENT RECEIVED
We get vary favorable feedback on our efforts to assist businesses with environmental compliance issues. Anything to
help navigate the maze of regulations is warmly received.
Positive comments: Very professional staff. Very knowledgeable staff. Information received useful in reducing
pollution. Quick response time.
Negative comments: Do not trust anyone in the Department (ADEC).
Due to the nature of our program, our customers have responded 100% that our services have been excellent and they
are appreciative of our efforts. I personally feel that although we help people understand the current regulations and
their complexity, we need to focus on making those rules more understandable for small businesses. We need to make
upper level management, community members, and environmental groups aware that we can still protect and preserve
the environment with much more understandable rules!
N/R
"This is the first time in 24 years of business that I found someone courteous and really concerned with my problems.
John Bernardo was all of that and more. He listened and actually helped me with the problems." "I have been told by
other business owners that the business assistance program might be eliminated. That would result in less help for
businesses, less information being given, which would result in a negative impact for the environment. I would hope
that the business assistance program would be expanded with more manpower given to education of business owners
and operators." "Many companies believe that they shouldn't invite anyone from a regulatory agency to their site.
People told us that we were taking a big chance or inviting trouble. I believe that our visits from the Business
Assistance Program improved our company tremendously. This past year, much attention has been given to
environmental and safety concerns. We are more environmentally conscious now than we have ever been."
"Glad to have help from a regulatory agency." "Was reluctant to ask for assistance, but was relieved afterwards."
"Wanted to do the right thing, but wasn't sure how to go about it." "Welcome any help they (company) can get."
"Extremely helpful. Very knowledgeable and expeditious regarding my concern and how to address solving my
problem." "Very responsive to our request for help - even though it didn't directly involve this agency." "Your web
page/e-mail is great - a model for all agencies."
Businesses like the improvements in service. Multilingual staff is a great asset. Economic development efforts have
been appreciated. Our efforts to coordinate P2 solutions with water aaencies have been appreciated.
-------
TABLE F-1
(Continued)
PROGRAM
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
" - - ' - - COMMENT RECEIVED
No complaints have been received by the SBO or CAP.
CT SBAP has been recognized by EPA as a national model for innovative approaches to compliance. The Financial
Assistance for Vapor Recovery Systems (FAVRS Loan Program) was cited as a model program by Carol Browner in
materials presented at the White House Conference on Small Business this past year. The program continues to serve
as a model for other programs within DEP and with other State agencies. The program has been cited as a model by
EPA Region I as part of a federal review of the air enforcement program. EPA commented on the positive impact the
SBAP has had in promoting compliance.
Businesses comment regularly that the services provided through the program are extremely helpful. Numerous
comments have been received on the quality of the staff presenting at workshops and training sessions as well as
responding to phone calls and providing on-sfte technical assistance. Numerous comments have been received on the
clarity of materials provided, particularly the FAST Vs training manual, which provides step by step instruction on
calculating emissions to determine Title V applicability. Several comments have been received that training sessions
have been extremely valuable and should be repeated.
"Very helpful in completing a permit application." "Glad to have someone representing interest of small business."
"Nice to know who to call with a question about compliance."
None.
N/A
"The SBAP's patience and understanding when clarifying in laymen's terms really pleased us." "The prompt response
of the SBAP really pleased me. Thanks for your assistance." "I was explained clearly about the guidelines and my
company's status and options. This was very important to us." "When you explain the rules (wood furniture), it is so
simple. Thank you so much."
N/A
None.
Most all comments received either by mail, in person, or by phone have been very complimentary since we have
stressed the usage of our "Illinois EPA's Quick Answer Director." The comments received by the SBO now are
answered ouicklv and intelligently. The clients' reauests are beina directed to the right technical person or persons.
-------
TABLE F-1
(Continued)
PROGRAM
Kansas
COMMENT RECEIVED
Indiana Verbal comments made to or regarding CTAP: At the Governor's Conference on the Environment, two dry cleaners
talked at length about CTAP's work with the trade association and how the new cooperation is what small business
owners want from a regulatory agency. Comments received from auto body shops were mostly positive, along the line
of, "Best thing IDEM has ever done." At a recent workshop, a participant told the group he would prefer to address
questions to IDEM's CTAP group than to consultants, because he trusted our knowledge and insight more than a
consultant's.
Comments from Title V workshop evaluations: "After going to 2 other seminars (consultant-run), this is the best one
I've been to. Very helpful." "I really liked the applicability worksheets. First time I've seen such a straight forward
approach to this issue." "All was good." "Good workshop!"
Comments regarding FaxBack and other tools to obtain information from IDEM: "Where was FaxBack and Custom
Connect 20 years ago?" "Making the Locator List available to external customers is the best thing IDEM has ever
done!" "These services (FaxBack, Custom Connect, and the Locator List) are making Indiana a leader in providing
needed information."
Iowa Small businesses who have used the services of the IAEAP have been very pleased with their expertise,
professionalism, and dedication. This observation is based on verbal accounts relayed to the SBO at public meetings
and in phone conversations. IAEAP continues to be nationally recognized for their innovative programs and
publications.
The greatest compliments we receive come from "repeat" clients. Many of our callers have asked us for assistance
many times and always express their appreciation for our many free services. Several consultants have expressed their
appreciation for the many publications we provide. Responses on evaluations of workshops indicate an overwhelming
appreciation for services provided, and support and gratitude from trade associations. One of the best (verbal)
responses the SBEAP received was the comment that "this is really good use of Government funds."
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TABLE F-1
(Continued)
PROGRAM
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
COMMENT RECEIVED
(Sample of comments provided.) "Excellent program. Great help for small businesses. When will similar service be
offered for water and solid waste?" "Chris Melton was superb! I BEAP saved me not only money - but time, sweat,
and tearsl Thank you." "One of the best ideas ever!" "KBEAP saved us thousands of dollars; we could not afford an
air quality consultant. We manage our wastes generated appropriately, but it would still be beneficial to have a second
opinion to see if we could minimize our wastes more. I do want to know more about water wastestreams." Most
definitely as a small company, we want to comply with the regulations, but sometimes find it difficult to get accurate
information. Good service! " " We would have been hard pressed to comply with the new air quality regulations
without this assistance."
Economic Development Cabinet raised questions about clarity of SBAP printed information on confidentiality. Concern
was expressed about amount of publicity on national telecast.
I have not received any comments from the regulated community, positive or negative, on the effectiveness of the
SBTCP in Jefferson County.
(Sample of comments provided.) "Leah helped me beyond the call of duty. When I had question, she had the answers.
I could not have asked for a better assistant. Leah did an excellent job." "Leah Rogers provided all the technical
assistance and forms needed. She also did all the necessary calculations and provided assistance over the phone. She
was very professional and efficient." "Anything the SBAP can do for the independents is greatly appreciated. This is
the first time, that I am aware of, that the GOVERNMENT does anything to help. This is quite a bit different from the
way the NORM permits were handled - it is definitely not threatening and my company really appreciates the service
you have just provided. THANK YOU." "There should be more publicity about the assistance." "Continue to employ
people with the character, concern, and ability of Mr. Martin."
Overall initiatives receive positive comments. Typical - "It's about time." "SBTAP was a great help."
N/A
N/A
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TABLE F-1
(Continued)
PROGRAM
COMMENT RECEIVED
Michigan
SBO: No specific comments, but overall feedback on the services provided by the SBO has been positive.
SBAP, Education and Outreach: SBAP held three education and outreach events during the 1995-96 fiscal year: two
workshops (one for the Renewable Operating Permit and one for Hard and Decorative Chromium Electroplaters) as well
as one teleconference (Wood Furniture Manufacturers). Evaluation forms were completed by participants at each event
with most participants rating the event as "Good" or "Excellent."
SBAP, On-Site Technical Assistance: SBAP also received three appraisal letters from customers complementing the
effort and quality of personalized outreach assistance provided.
Minnesota
1996 SBAP annual customer survey with many comments about program. New ongoing SBCAP customer follow up
questionnaire.
(Sample of comments received.) "MPCA helped us build a new vapor degreaser, which allowed our company to
drastically reduce our emissions and use of solvent. The guidelines were clear and the assistance and plans were
detailed - we also appreciated the visit here at our plant." "I am able to conserve better and to prevent any waste. I
am more cautious." "The volume of environmental regulations seems ever increasing and increases our cost of doing
business. More effort should be devoted toward streamlining regulatory requirements and reporting needs. There is a
need to make reporting and license/permit applications more user friendly."
Mississippi
N/R
Missouri
None.
Montana
SBO/SBAP received letters of thanks from two dry cleaners, a hot tub manufacturer, a chromium electroplater, five
gasoline distribution centers, a representative from a large coatings manufacturer, a tire shredding operation, and a
group of grain elevator operators.
Nebraska
From a bottling company, "The Small Business Assistance Program has been extremely helpful during the process for
determining our obligation under the Title V requirements." From a manufacturing facility, "The Nebraska Department
of Environmental Quality was very good to work with, especially the Small Business Assistance Program. The efforts
of many of the staff at NDEQ have made my job much easier. From the Fabricare Association, "A very sincere thank
you to the assistance that was provided to our members through the Small Business Assistance Program of Nebraska."
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TABLE F-1
(Continued)
PROGRAM
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
COMMENT KtCaVHJ
SBAP has received oral communications from various paniculate generating facilities on the need and benefit of the
SBTCP. Both SBAP and SBO receive comments from industry representatives that this program is the "best kept"
secret in the state, indicating that more public relations work may be necessary to make industry aware of this
program.
"I was pleasantly surprised to find out a regulatory agency actually provided assistance in meeting rules and
regulations." (coating operation)
During a state legislative hearing on a bill requiring state agencies to establish assistance programs, the NHDES SBAP
was singled out as the type of initiatives the legislation was seeking to have established. All of the business owners
and operators that have received assistance from the SBAP/SBO have made very positive comments concerning the
program and the agency's attitude for cooperative compliance.
None.
A customer service survey was created by SBAP and positive comments include: "You're doing an excellent job.
Please keep up the good work." "Very polite and helpful." "Keep up the good work."
The only negative comment that was received was: "Make the dry cleaners self audit checklist easier to read. In
particular, question #7 on page 9."
Received many letters of appreciation.
"Departments like yours make small business proud to be in North Carolina." (Owner of a small furniture company)
"The purpose of this letter is to send a heartfelt sincere thank you for the assistance received from your office for the
air permit application." (Small metal fabricator businessman) "There is no telling how many man hours would have
been spent to work out all the calculations necessary to complete the forms without your help." (President of a small
business) "Thank you for your presentation and assistance at our meeting last month." (President of an association in
NC) "Thanks to all information and materials that you have shared with me during your visit to our company." (Person
in company responsible for all environmental requirements) "We greatly appreciated your presentation and your
willingness to assist our businesses in complying with these new regulations." (Association president)
None received.
-------
TABLE F-1
(Continued)
PROGRAM
COMMENT RECEIVED
Ohio
Ohio businesses that have worked with SBTCP react favorably to its existence. The most frequent reaction is surprise
that a program will actually help a business work through the nitty gritty calculations and permit challenges. Many
businesses approach the SBO or SBAP with trepidation, based on "stories" they have heard. This approach is
frequently the business' first voluntary contact with a state agency. It is clear that the most valuable service provided
by the program to date is TRANSLATION: What do the rules mean? How do they apply to me? What do I do with this
form?
The most intensive work with a single industry has been with small printers. The trade association, Printing Industry of
Ohio, forged a leadership position and defined its mission as achieving a "culture change" in how small printers
approach environmental compliance. Initial indications are that the ENVIROPRINT OHIO project accomplished this; a
more complete evaluative study is currently in the final stages.
The negative comments tend to center on the same issues, which frustrate program staff: Why doesn't the program
reach more people more quickly? Why hasn't the entire regulatory agency taken this approach?
One of the most frequently raised issues is the necessity to have the program be multimedia and not restricted to air
issues. Small businesses do not take media based distinctions; in fact, many do not distinguish between different
government agencies.
Oklahoma
OK SBAP, as part of the Customer Assistance Program, continues to receive extremely positive feedback from those
we have assisted in the past year. While some businesses may not appreciate being regulated, without exception each
one has been very grateful for the help they have received from our program. We anticipate involving small business
more in the regulatory process as the Panel continues to grow into its mission.
Oregon
No negative comments were received during the 1996 reporting period. SBAP saw an increase in the number of
businesses and individuals seeking assistance, which may indicate greater acceptance of the program. A written memo
was received from a dry cleaning equipment vendor for sponsoring a workshop. SBAP helped a small rendering
business with a tax credit application for expenses incurred to eradicate an odor problem; the company was granted tax
credits. A CAP member received positive comments from a dry cleaning business owner who received an on-site
compliance evaluation. A private painting contractor who previously received SBAP technical assistance requested an
evaluation of his proposed water based painting system. Individuals affiliated with the secondary wood products
industry and several wood finishing businesses verbally thanked the SBAP for broadcasting the EPA/University of
Tennessee wood furniture manufacturing teleconference. Several dry cleaning businesses verbally expressed
unqualified appreciation for services provided.
-------
TABLE F-1
(Continued)
PROGRAM
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
COMMENT RECEIVED
SBO position has been vacant since 4/96. This information is unavailable.
In the meeting held with the CAP, we gave them a brief insight of the SBAP. They liked the purpose of this program,
but it seems that if our office doesn't take the lead, no one will.
(Selected comments from letters received.) "Just a note to compliment Roger Green[e] of your staff.. .We appreciate
the fact that we have a single contact person to go to 'when things get a little slow.'" "As you probably hear many
more complaints than you deserve, I want to take a minute to express my appreciation for all of your efforts to move
the process along on the 'Fidelity Permits.' It was an outstanding effort-we thank you and my guess is the Governor
thanks you."
Comments have been consistently positive.
Contacts with the Small Business Ombudsman generally have been positive and in the form of requests for information
or points of contact within regulatory programs. Often these contacts involve air sources with questions outside the air
program. Contacts to the Small Business Ombudsman regarding assistance from the Small Business Assistance
Program have been very favorable.
TN Air Pollution Control Board, which has the authority to establish the program's funding level, has been
complimentary of program efforts following program update presentations. TN Association of Business complimented
activities conducted by the program. Businesses have indicated they are pleased that such a program exists.
Consultants have expressed their happiness to see a voluntary compliance program for small businesses implemented.
"Santos Olivarez assisted us a great deal. I really appreciate all of the help and assistance that he gave us. Your
department should be proud to have such a person within your organization." "Educate small manufacturers. Provide
NR primer to TMAC field engineers." "Keep us informed on any changes in the news. Thank you all very much for
helping us keep in compliance with EPA rules and regulations." "It was about as easy as it could get thanks to Tim
Mays and Polly Gustafson. The people in Austin that I dealt with were more than helpful. Never in government have I
had this good." "Cut down government involvement in our day to day business lives while making life better for all. I
was pleased at the Director's swiftness in response and clarification."
8
-------
TABLE F-1
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
COMMENT RECEIVED
Appreciate opportunity to comment on regulations and to provide feedback. Appreciate technical presentations,
however would prefer fewer presentations. Appreciate outreach review and input opportunities, but concerned their
voice may not be heard in overall review. Would like more regular and substantive meetings. Comment that '95
Amnesty program was too short for business community; would prefer "Industry Amnesty" windows be provided for
specific businesses. Would like longer on-site visits. Concerned that businesses are not receiving needed information,
even with extensive outreach efforts. Concerned about confidentiality with enforcement, especially for on-site visits.
Concerned about heavy penalties to small businesses that are unaware of requirements. Concerned that permit
approval process is too lengthy, thus delaying business operations.
No comments.
We have received positive comments on the usefulness and the ability of business to access non-regulatory technical
assistance that is willing to listen and understand the regulatory difficulties of the sources. "It is refreshing to see the
cooperative effort and support provided by and through the VA Small Business Assistance Program." "I would like to
take this opportunity to thank you for traveling all the way from Richmond to help with my permitting quandary."
CAP - not yet named. No comments from SBO.
CAP received no specific comments on the SBTCP.
All comments have been positive. "I would like to take this opportunity to express my sincere appreciation for the
consideration your employees have given me these past few weeks regarding the 'Air Quality Standards' as it applies to
a very small business concern such as ours. These people were very knowledgeable in the field in which they work and
they were most helpful to me, a layman. It's great to know that there's still hope for the small business people in this
world of giants."
Comments from businesses served by program staff: "Think your approach is creative and getting better results
because companies are more willing to cooperate because they are less afraid of reprisals or fines." (Dave Kitzinger,
Kitzinger Cooperage Corporation) "As a distributor of VOC-containing products, we have passed through your
information to our customers. They have been successful in reducing emissions." (Knute Jacobsen AIC, Inc.) "All my
questions were answered and the reference material I requested was provided quickly and in a comprehensive manner.
It's hard to see how you can improve on that." (Jack Bates, Diversified Woodcrafts) "We have been able to make
recommendations to our clients using your examples." (Joseph Kramer, Badger Lab & Engineering Company, Inc.)
Based on our customer opinion surveys we conduct regularly, 83% of our customers would recommend our program to
others.
-------
TABLE F-1
(Continued)
PROGRAM
Wyoming
COMMENT RECEIVED
The National Federation of Independent Small Businesses (NFIB) has stated to the CAP and the SBO that small
businesses need to know that they can request SBAP assistance and that the agency will not seek penalties when non-
compliance is disclosed. The CAP requested that such a policy be adopted by the department to cover multimedia
sources.
N/A Not applicable
N/R No response
10
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TABLE F-2
NATURE OF COMPLAINTS RECEIVED/INITIATED BY THE SBO OR THE CAP
AND INFORMATION OF THEIR RESOLUTION
(Responses edited for space)
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
Pima Cty
Arkansas
California
COMPLAINT/COMMENT
N/R
Smalt business not being treated fairly, asked to do
something Department did not ask of others.
Corrective action required by Department is financial
burden and exceeds environmental benefit.
Department actions not consistent between various
offices around the state.
Permitting staff not responsive or understanding to
customers' needs.
Timelines for permit application approval too long.
Inconsistency between inspector and permit engineers in
interpreting rules.
RESOLUTION
Worked with small businesses to achieve compliance with
regulations and demonstrated consistency in programs.
Worked with program staff to achieve balance between
corrective action and financial burden to individual with
acceptable level of environmental protection.
Worked with Directors and Commissioner Office to
ensure consistency statewide.
Serve as mediatory between the two and work directly
with permitting staff to not only complete current
application, but be sensitive to small business needs.
Continuing to develop General Permits and currently
participating on committee to develop license timeframes
for implementation in 1 998.
Help draw issues to the attention of managers and lead
process to develop a consistent approach for handling
issues. Develop an open line of communication between
the two organizations.
N/R
None received or noted.
Generally complaints directed toward the Agency are routed to our Public Information Section or received by the
Director and assigned to a respective division for resolve. Consequently, complaints are not a major assignment of the
SBO. Assignment of complaints by the Director are typically long term problems, which have not been resolved by a
specific division.
Forms need to be simplified.
Not knowing what or how to proceed.
Help work through the forms and make connections with
appropriate people.
Streamline and speed up the process.
-------
TABLE F-2
(Continued)
PROGRAM
SCAQMD
Colorado
Connecticut
Delaware
District of
Columbia
Florida
COMPLAINT/COMMENT
The agency needs to make information available through
general media, especially radio and television news talk
programs.
Small business publication needs to more clearly identify
upcoming issues.
RESOLUTION
Resolution in progress. Develop and work with media to
implement a business services-type PSA for local
distribution.
Reformat publication.
N/R
Complaints have been received that meeting
announcements are sent out late and do not provide
enough advance notice.
Seminar and workshop attendees would like us to provide
coffee and snacks, particularly for morning-long training
sessions.
People requesting general assistance would like more staff
available to provide technical assistance.
State open burning regulations are arbitrary and
capricious.
CAA requirements for small businesses are overly complex
and costly.
Fear that requesting assistance may result in a monetary
penalty or some other action.
For monthly meetings of the Clean Air Advisory
Committee, an electronic version of the committee
mailing list is being developed.
No decision has been made on how to address this.
Minimizing overhead enables workshops and seminars to
be provided to small businesses at no charge and
eliminates unnecessary administrative duties, which are
difficult with a small staff.
This is difficult to address, since it appears that demand
will almost always exceed available resources,
particularly during lean fiscal times.
Regulation 1 3, open burning regs, will be revised in an
attempt to make it more straightforward and consistent.
Every attempt is make to clearly explain what needs to be
done in order to comply with the requirements in the
CAA. Information on funding sources to finance needed
changes is given to requesting small businesses.
Offer confidentiality to persons requesting assistance.
Will be implementing a penalty mitigation policy for those
businesses that report non-compliance and seek
assistance in achieving compliance.
None.
N/A
-------
TABLE F-2
(Continued)
PROGRAM
Georgia
Hawaii
Idaho
Illinois
COMPLAINT/COMMENT
SBO received • complaint from a chemical manufacturer in
Atlanta. This manufacturer received a proposed consent
order from Environmental Protection Division/Air Protection
Branch citing many violations of state air rules and ordered
the company to comply and pay a $3,000 penalty. The
owner retained a law firm to respond to the alleged
violations. The attorney contacted the Ombudsman and
formally requested his involvement.
RESOLUTION
Ombudsman initiated an investigation regarding the
alleged violations. Because of the Ombudsman's
findings, a new consent order was prepared and
presented to the owner for approval. The new consent
order removed many of the cited violations and eliminated
the penalty. It also included a fugitive emission control
plan prepared by the SBAP. The plant owner and his
attorney agreed to the terms in the new consent order.
The plant is in compliance with the air rules, equipment
was purchased to reduce fugitive pollutants, and the
plant's work environment improved.
N/A
None.
The nature of the complaints generally were from "phone call inquiries." They were sent to the wrong person, no one
answered their call, switched around through the agency, too much down time before they were assisted. We are
currently working new ideas to combat this problem. Our personnel is more conscientious of the clients' wants and
needsl
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TABLE F-2
(Continued)
PROGRAM
Indiana
Iowa
COMPLAINT/COMMENT
There were some complaints about needing to do VOC
tracking on auto painting. The auto body shops did not
know how to do this, nor did they want to spend time on
this type of project.
There were some complaints regarding the trainers at the
Title V workshops. Some trainers are engineers/technical
staff who have a very good understanding of Title V, but
are not well suited as trainers.
At one Title V workshop, we walked attendees through
the process of integrating the Title V application (which
was in 4 parts due to revisions). Attendees complained
about using workshop time for this laborious process.
There were questions regarding the guarantee of
confidentiality.
There was some internal conflict regarding the roles of
CTAP and the Office of Enforcement.
Numerous financing questions/concerns.
Complaint regarding complexity and volume of forms.
Complaints regarding complexity of regulations and a lack
of a "plain English" guide to help determine facility
requirements.
RESOLUTION
The Office of Air Management, together with CTAP,
worked to develop a non-rule policy decision to simplify
VOC tracking. The policy allows shops to keep records of
the coatings used, reflecting how refinishers actually mix
and apply coatings.
CTAP held a "train the trainer" session to assist technical
staff in conducting sessions for Title V training. Replaced
trainers who showed no interest in conducting training or
no improvement in their training skills.
CTAP responded by developing a document entitled,
"Instructions for Revising Title V Application Packet,"
which allowed participants to go through this process on
their own.
CTAP developed a confidentiality policy and published it
in the Indiana Register.
CTAP and the Office of Enforcement held meeting where
CTAP reported on the progress made regarding working
through Supplemental Environmental Projects and other
programs.
Provide packet of information regarding available
financing alternatives and tax incentives.
On-going participation in a construction permit task force.
Have revised the forms, received comments from a test
group of businesses, and are making final revisions.
Successfully proposed changes to the Small Source
Operating Permit rules. Within the Construction Permit
Task Force, a sub-committee developed, edited, and
published a series of fact sheets. They will be available
in the spring on the Department of Economic
Development's fax-back system.
4
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TABLE F-2
(Continued)
PROGRAM
Kansas
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
Missouri
COMPLAINT/COMMENT
RESOLUTION
Most of the complaints/inquiries the SBO receives regard the necessity for permits or if the permit is already in place.
SBO has been provided with the ability to view the regulators' permit files in private. Often, this answers the question,
"Do 1 already have an air permit?"
One particular complaint occurred because of a change in air emission fees causing the business to pay duplicate fees
for one year. Unfortunately, this was not resolved to the business' satisfaction; however, it should not happen in future
years.
Many inquiries are received by individuals just beginning a business and want to know what they need to do to comply
with environmental regulations. We have developed the Roadmap to Environmental Permits and a Service Guide. Also,
we have established a positive relationship with other state/federal agencies that deal with new, expanding, or existing
businesses, such as the Kansas Department of Commerce and Housing, Small Business Development Centers, Small
Business Administration, etc. Many state/federal agencies are representod at our quarterly Business Assistance Group
meetings, which facilitate referrals and help foster a spirit of cooperation among those of us who assist businesses
with a variety of issues.
Economic Development Cabinet.
National telecast publicity.
1 have initiated a complaint that the SBTCP was not
keeping adequate paperwork on their services, making
data difficult and time-consuming to retrieve.
1 have initiated the complaint that the SBTCP was not
properly represented to the CAP.
No complaints have been received.
None
Several meetings have been held to develop solutions to
concerns. Revisions to documents are pending.
SBAP met with SBO and DAQ to discuss different
approaches to publicity.
A more effective process for keeping statistics will be
implemented for this calendar year.
A representative will be assigned to interface with the
CAP.
All questions are handled in a problem solving mode. No
major issues brought to CAP.
None
N/A
None
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TABLE F-2
(Continued)
PROGRAM
Michigan
Minnesota
Mississippi
COMPLAINT/COMMENT
Enforcement intercession.
Permit status inquiries.
Permit application assistance.
Brownfield redevelopment inquiries.
Difficulties with local regulatory district offices.
Air Quality Permitting Requirements for Soil Roaster -
Complaint included unresponsiveness of AQD staff, lack of
flexibility, and level playing field issues.
Many new start up companies have difficulty in getting all
the environmental information they need. They want to
do the right thing and it is difficult for the SBO to gather
everything and feed confident that nothing has been
missed.
Small business extremely angry that they received huge
fine for SARA Title 313 violation. SBAP had helped them
with AQ permit, site visit, etc., but did not mention 31 3
requirements.
Auto body shop owners expressed their desire to comply
with environmental regulations and institute P2 practices.
RESOLUTION
Mediate between businesses and agency.
Ask regulatory department staff.
Work with businesses and the state permit-issuing
department staff.
Provide state department contacts; follow up on
department commitments.
Mediate between regulatory department district staff and
businesses.
Responsiveness issues resolved by making a change in
permitting engineer. Flexibility issues still being
determined, but probably through an amendment process.
Level playing field issues with associated industries (land
farming, landfill cover, etc.) will be proposed for
multimedia look at the industry through multimedia rule or
new permit.
Working to make start up business assistance a priority
for SBO during next year. Working with
multimedia/agency workgroup to develop plan for
comprehensive assistance. Same workgroup developed
general environmental assistance guide.
Shows once again a need for some level of multimedia
efforts and basic knowledge of other programs that small
business may be subject to. Encouraged business to
cooperate with EPA and demonstrate all of their good
faith efforts. In future, like the wood finishing
workshops, will include a "heads up" brief overview of
SARA and ERC requirements. This small piece of
information possibly could have prevented this violation
from occurring.
Four workshops were organized by SBO and SBAP to
address these concerns. Workshops were presented in
Jackson, Grenada, and Biloxi.
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TABLE F-2
(Continued)
PROGRAM
Montana
Nebraska
Nevada
Washoe Cty
AQMD
Clark Cty
NVBAQ
NVBEP
COMPLAINT/COMMENT
RESOLUTION
No complaints received.
N/R
Permitting concerns.
Compliance concerns.
For the past 2 years, over % of the complaints have been
in regard to nuisances involving construction activities
such as tracking of mud on city streets, dust complaints,
and the lack of water trucks to control dust.
The biggest complaint facing BAQ is in regard to permits
and time frames for issuance. Because of the
requirements under CAAA of 1 990, there are a number of
facilities that need to be repermitted with Title V permits,
while others were repermitted to keep them out of the
Title V program. The repermitting process has caused
delays in permit issuances and backlogs of several
months.
No complaints, onlv reauests for air duality assistance.
Explained the regulations and showed how federal law did
not allow for much flexibility.
Provided forum for regulators and industry representatives
to resolve compliance issues.
AQMD tightened requirements on dust control plans that
construction projects are required to obtain and abide by.
The AQMD attempts to resolve all complaints with the
least possible inconvenience to all parties. In the vast
majority of cases, simply letting the violator know that
there is a problem results in sufficient corrective action.
In 1996, AQMD received 573 complaints of which 77
resulted in a formal warning and only 36 in the issuance
of a citation.
All facilities regulated by the Health District are eligible
for assistance. They have permitted about 3,000
facilities including some 1 ,500 construction activity sites,
600 gas stations, 1 50 dry cleaners, 1 50 paint booths,
minor stationary sources and major stationary sources.
They provide information and answer questions, but do
not actually prepare permit applications on behalf of the
permittees. They do assist them in answering questions
about completing such applications.
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TABLE F-2
(Continued)
PROGRAM
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
COMPLAINT/COMMENT
Inability to interpret regulatory applicability.
Too many different regulations to understand.
Common sense alternative compliance options not
allowed.
RESOLUTION
Provide case by case determinations.
Work with all media programs to avoid duplication of
effort including the development of industry specific
compliance manuals.
Work with regulatory development personnel to ensure
regulations are performance and not prescriptive based.
None
N/A
N/R
Conflicting information from consultants and regulators.
Cost of permit, especially with the PE seal requirement.
Permit requirements too complex/cannot understand the
requirements. The cost of complying is too much.
We briefed the clients on regulatory requirements and met
all interested parties to clarify issues.
Developing a Permit Guide Manual.
Expanded the exemptions for smaller businesses.
Encouraged use of general permits, cutting costs in half
or eliminating need for a permit.
No complaints were received.
Relatively few complaints have been received by the SBO.
Those tend to center on inability to communicate with a
local or regional air regulatory agency and/or inspector.
A two person sawmill that received the "run around" in
regard to our Air Quality Division determining their need
for a permit.
No complaints were received during the 1 996 reporting
period.
Preferred response is to connect the complaint with SBAP
staff. To date, this has been completely successful. This
does not mean the business was happy with the
regulatory outcome; it does mean that the complainants
felt they received honest and comprehensible answers.
After representing the needs of the facility, a letter was
issued to the owners clarifying the matter. Further this
produced a clarification within our own Agency about the
issue in question.
N/R
8
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TABLE F-2
(Continued)
PROGRAM
COMPLAINT/COMMENT
RESOLUTION
Puerto Rico
None.
Rhode Island
N/R
South Carolina
Cost of PE seal requirement.
BAQ developed general permits for some industry sectors,
which preclude need for PE.
South Dakota
Contacts are seldom in the form of complaints, therefore,
a better description of this table would be "Contacts" and
"Resolution of Contacts."
Who should I talk to about this issue or concern?
Direct party to the appropriate DENR staff person, usually
in the Small Business Assistance Program.
Do you have some information on this subject?
Provide information to party and direct party to SBAP
staff or other DENR staff for additional information.
What permits do I need for my business?
Provide party with DENR permitting guide and direct thorn
to appropriate DENR staff.
Tennessee
None.
Texas
A family-owned business that produces brass and
aluminum parts had been spreading excess shavings on
their property. An EPA investigation declared the property
an illegal hazardous waste landfill. EPA ordered the
business to pay a penalty of $817,000 and to clean up the
site immediately. The business did not have the resources
to do so.
A dry cleaner was investigated by TNRCC and found to be
out of compliance with hazardous waste disposal, storage,
and handling rules.
A water supplier for a small Texas community sent a letter
to the Governor's office complaining about the number,
frequency, and cost of tests they were required to perform
on their water system.
SBAP talked with the business and EPA to come up with
a solution. EPA agreed to waive the administrative
penalty, the business agreed to cover and fence the
contaminated site and install monitoring wells to ensure
contamination does not spread, and the business agreed
to clean up the site entirely within five years.
SBAP spoke to the dry cleaner and developed a
compliance plan. The dry cleaner came into compliance.
The owner reports increased sales and says the entire
operation is improved. The cleaner won an award from a
local business council for their efforts.
SBAP worked with the Water Utilities Section of the
TNRCC to secure a waiver for the water company. The
waiver allows the company to forego certain tests and
perform others less frequently, which results in savings of
time and money.
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TABLE F-2
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
COMPLAINT/COMMENT
A small city's Publicly Owned Treatment Works (POTW)
contracts with a private lab to do its testing. The lab
gives the POTW results of its tests. The POTW was told
by a TNRCC regional investigator that they did not have
sufficient testing documentation on site.
One business felt they should have been included in the
Amnesty program.
Competitor complained that another company was allowed
to participate in Amnesty program, but did not qualify.
Small business was not properly notified of rejection of
hearing request on time.
Several concerns expressed regarding general
confidentiality issues. It was also reported that an outside
program that was advertising confidentiality was not
considered to be confidential.
RESOLUTION
SBAP contacted several regions and found that the
amount of documentation required varied from region to
region. A policy was developed and distributed that
explains what type of information is needed from
POTWs.*
Complaint was reviewed, but business did not meet
qualifications for number of employees.
A previous exemption had been provided by executive
order, which the Amnesty Program allowed for through
case-by-case review.
Company was ushered through the process and agreed to
settlement opportunity. Also, hearing request notification
concern was reported to Air Quality attorney for follow up
to prevent future problem.
After legislative review by Utah's Attorney General's
Office, it was determined that although a self-audit bill
exists, it did not cover on-site visits. Further, federal and
state government records are, in many cases, open and
available for public review.
N/A
Do not understand the regulations.
How can small businesses participate or be represented in
regulation development?
How can small businesses pay for regulatory emissions
controls?
Assist with understanding of the regulations and
permitting.
Provide representation and notice of upcoming regulatory
activity.
Helped to foster the creation of a revolving loan fund for
CAA compliance.
N/A
N/R
10
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TABLE F-2
(Continued)
PROGRAM
West Virginia
Wisconsin
Wyoming
COMPLAINT/COMMENT
SBO received complaints from several small businesses on
"heavy handed enforcement" involving excessive fines and
unfair and excessive inspections and inspectors. Also,
complaints have been received concerning unreasonable
rules and regulations; excessive environmental clean up
and equipment costs; the relative high cost of permit
applications; and delays in permit processing. In addition,
small businesses have also identified a problem concerning
air permit requirements for the relocation of small mobile
sources that they consider unreasonable and not
commensurate with the potential environmental
improvements.
"We wish the government would leave us alone."
No complaints received by SBO.
RESOLUTION
When small companies complain about excessive fines,
the SBO ensures that the ability to pay is considered and
the need to be sensitive to the financial position of small
businesses is discussed with enforcement personnel.
Also, the onerous practice of enforcement starting with
unreasonable fines to obtain a final negotiated fine that is
still excessive for the small business was brought to
enforcement's attention. This highhanded penalty
practice has generally been discontinued except egregious
cases. Also, the principles of the "Small Business
Regulatory Enforcement Fairness Act of 1 996" are now
generally being followed.
The permit section has expanded a "permit determination
procedure," which has decreased the need for "up front"
permit application fees and reduced administrative costs
for small businesses to some extent. The real permit
processing benefits for small businesses will come with
the use of "general permits" for both small stationary
sources and mobile sources. The SBO solicited 1 9 states
for general permit examples, and the SBAP is working
with the permit section and has dedicated two engineers
to the general permit development project.
SBO alerted the Director of DEP to the small business
disruption problems that result from having inspectors
from several WVDEP offices conduct multiple, separate
inspections for their specific concerns rather than having
one multimedia inspection. The DEP Director has given
the Assistant Chief the project of bringing the responsible
parties together to solve the problem.
Attempted to remove from mailing list. The person filing
the complaint did not give their name, address, or
telephone number.
N/A
N/R
Not applicable
No response
11
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TABLE F-3
SIGNIFICANT PROGRAM ACCOMPLISHMENTS, AWARDS, AND RECOGNITIONS
PROGRAM
Alabama
Alaska
Arizona
Maricopa
County
Pima
County
Arkansas
California
SCAQMD
ACCOMPLISHMENTS
N/R
N/R
N/R
SBEAP and Salt River Project have co-sponsored 3 industry specific workshops for metal finishing/electronics, automotive, and printing.
Partnerships like this are the way we leverage our marketing. Since 1 /96, SBEAP has helped 56 small businesses obtain their air quality
permit. Started a new environmental intern program with Paradise Valley Community College. A complementary article in the Business
Journal (4/96) discussed our program and companies we've helped. Several companies provided testimonials. Home page selected as
one of the top 10 web sites for small business. SBEAP was a recipient of the National Association of Counties Award (6/96). This award
recognized model programs that are innovative in improving and promoting county government in the US. SBEAP, in conjunction with the
AZ Department of Environmental Quality (ADEQ) hosted the 2nd Annual Small Business Environmental Awareness Conference, a one-day
conference in Scottsdale. The agenda topics included air, hazardous and solid waste, wastewater, Internet, legal issues, and OSHA. 30
sites have been assisted in completing their emissions inventory paperwork since 1/96. We feel the program has been successful
because of the items listed above; also the number of sites we've helped has doubled since 1 996, with very positive evaluations.
Positive newspaper article about program.
Recipient of the 1 996 Distinguished Service Award from the Arkansas Environmental Federation.
Ten stakeholder forums (8 initial and 2 follow up) were held throughout CA in 1 996 to identify how the State's air quality management
system can best prepare for the challenges that will be faced in the future. Goals included: identification of program strengths and
weaknesses, how current programs can be improved, and identification of what stakeholders see as major areas of concern for the future.
Stakeholders from across the state including industry, trade organizations, and environmental and public health advocacy groups attended
to help constructively answer these questions via facilitated input, discussion, and debate. Key themes were compiled from the first 8
forums and the ARB and local air districts reviewed these prominent issues and briefed stakeholders on what is already in progress or
being planned in response to their concerns.
The key concerns identified included: carry forward a clear and strong science-based air program, reduce regulatory complexity and cost,
strengthen air quality public information/awareness programs, continue involvement of stakeholders in air programs, and pursue
proportionate emission reductions. Stakeholder and agency representatives are planning to come together to form "Tiger Teams" (focus
groups) to work on follow up addressing these key concerns during 1 997.
We have formed a small business meeting group with local Air Districts and business representatives.
N/R
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TABLE F-3
(Continued)
PROGRAM
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
ACCOMPLISHMENTS
SBO continues to receive positive comments from the small business community about the Small Business Environmental Fax Network
fax alerts. SBO/SBTAP staff traveled throughout CO to provide compliance assistance to dry cleaners at 9 separate locations in regard to
the 9/1 6/96 MACT standard deadline. In addition, a workshop was held for state inspectors to update them on new requirements. SBO
initiated a work group to review current APEN forms and make revisions to simplify them. SBO set up a meeting of various local, state,
and federal programs in CO that provide free services to small businesses to create a better awareness of each program and to create
networking opportunities. SBAP sent chrome plating information.
N/R
N/R
With our severely limited resources, we reach more people by attending trade associations' annual seminars and making presentations
there. SBAP made a presentation at the Korean Drycleaners Association annual seminar where 700 business owners and their employees
attended.
The Program received a $1 50,000 Leadership Grant. This funding was used to develop Environmental Facility Survey Guidance manuals
for multimedia environmental audits. From these manuals, two training seminars were given to the Florida Small Business Development
Center's (SBDC's) energy auditors based at their 21 centers. The Grant funds were also used to purchase printed materials on
environmental technical assistance and related matters for the 21 SBDC libraries. Multimedia slide materials were developed for
presentations to the printing industry. A fact sheet on "why, what, where, and how government regulations affect dry cleaners" was
also developed and distributed to the industry.
SBAP performed 25 compliance assistance site visits. SBO resolved a conflict between the Air Protection Branch and a small business
owner. The information was presented to Karen Brown's office as a small business success story. SBAP staff prepared 3 articles for
inclusion in an environmental journal and two small business newsletters. SBAP/SBO joined with government, industry, and trade
organizations to sponsor 20 workshops during 1996. We targeted dry cleaners, wood furniture manufacturers, and printers. SBAP/SBO
staff made presentations at more than 30 workshops and seminars during 1 996. SBAP's SIP was approved during 1 996.
N/A
None.
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
Illinois
SBAP, being located in the same office of the statewide Small Business Development Center network, allows for clients to get linked to
both environmental assistance as well as other business assistance services such as financing, business planning, expansion assistance,
procurement opportunities and export assistance. We have formed many partnerships, especially with the Illinois EPA Bureau of Air and
the IEPA Office of Small Business. Together, we have made great strides in helping companies get the environmental compliance
information they want and need, but did not know where or how to get before.
The SBAP and staff are involved in other air related projects such as being a pilot state in the Great Printers Project, the Gold Star
Program for dry cleaners, participation in the Governor's Pollution Prevention Advisory Council, the Clean Break Environment Amnesty
Project, and Governor's Small Business Environmental Task Force, to name a few. We also partner with the Illinois Waste Management
and Research Center of the Solvent Alternatives Project and refer clients to them that need on-site pollution prevention assistance. The
SBAP was awarded a certificate of commendation by Director Mary Gade with the IEPA for our help on the Clean Break Project in
November 1996. The help and support of the IEPA is both critical and appreciated to ensure the success of the Illinois SBAP.
The following are quotes from assisted clients: "I very much appreciate the fact that there are programs like this in Illinois government
trying to help small businesses such as ours deal with these extremely difficult and complex environmental issues." "Even though we are
trying our best to comply, we are reluctant to work with IEPA directly due to bad experiences with them and other agencies in the past."
"That meeting saved our company thousands of dollars and an incalculable amount of time, while at the same time pushing us much
closer to full comoliance status with the IEPA.
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TABLE F-3
(Continued)
PROGRAM
ACCOMPUSHMEMTS
Indiana
Dry Cleaners: The IN Drycleaning and Laundry Association (IDLA) published a compliance manual after receiving a grant for this project
from IDEM. For IDLA's efforts on this project, they were given an award from the Central Indiana Technical and Environmental Societies,
Inc. CTAP drafted a second manual for the dry cleaning industry that was more simplified than the IDLA manual, allowing small
businesses to easily understand their compliance requirements. The IDLA manual continues to serve as a reference manual for dry
cleaners that have detailed questions. CTAP has since revised its manual and has also revised its dry cleaner brochure. CTAP's dry
cleaner program continued to receive applications for our 5-Star Environmental Recognition Program and, in some cases, has upgraded the
number of stars earned by those who are participating in the program.
Mineral Aggregate: An environmental compliance manual for IN's aggregate producers was published in January 1996. The IN Mineral
Aggregates Association received two awards: one from the National Stone Association and another from the Central IN Technical and
Environmental Societies, Inc. for its efforts in working with CTAP to develop the IN Permitting Compliance Manual for the aggregates
industry.
Mercury: CTAP began working with the Heating, Ventilating and Air Conditioning (HVAC) industry to encourage the reduction and
recycling of mercury thermostats. The industry is interested in participating in a pledge program (pledging to encourage the reduction and
recycling of mercury thermostats), and is waiting for the mercury recycling program to begin. The producers of mercury thermostats
have joined forces to create the Thermostat Recycling Corporation, allowing them to share the costs associated with this endeavor. This
new corporation is scheduled to offer mercury thermostat recycling in early 1997. In the meantime, CTAP created a mercury factsheet
for the HVAC industry and is working to finalize the pledge program. CTAP plans to initiate its pledge program as soon as the Thermostat
Recycling Corporation is ready to begin offering its services.
Vehicle Maintenance: IDEM's Office of Solid and Hazardous Waste Management (OSHWM) visited a number of auto maintenance shops
in northern IN. The purpose of these visits was not to "inspect" the shops, but rather to help educate shop owners and managers of the
proper management of their wastes (although OSHWM does have regulatory authority, which was used in some instances). CTAP
worked with OSHWM and the Automotive Services Association of IN to inform and educate the shops of OSHWM's initiative and
purpose. CTAP and OSHWM also are working together to assist the vehicle maintenance industry by initiating a program that includes a
compliance manual, brochures, workshops, and a 5-Star recognition program. CTAP currently is working on the compliance manual,
which will include compliance requirements as well as pollution prevention and good housekeeping suggestions.
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TABLE F-3
(Continued)
PflOQRAM
ACCOMPLISHMENTS
Iowa
The IAEAP tracks client evaluation with a form. Based on a sample of 131 responses, quality of service is rated as "good* or "excellent"
by 98 percent. Of the same respondents, 97% would recommend IAEAP to other clients.
SBO response: The Iowa Small Business Ombudsman is unique in that the position functions under the direction of the Iowa Citizens'
Aide/Ombudsman office, which is a legislative office that has statutory powers to keep investigative records confidential and issue
subpoenas. It is a non-partisan, independent agency where action can be taken to resolve complaints. This provides the SBO with a
wealth of support and information, as well as the distinct advantage of independence from any regulatory agency. The following
activities have made a significant difference for the businesses in Iowa in 1996. 1} After two years of meetings, a revised, streamlined
version of the construction permits should be going to the printer in March 1997. The process was grueling and sometimes controversial,
but the product was well worth the struggle. 2) DNR implemented a one year amnesty program for as-built construction permits. They
continued to send out Notice of Violation letters however, confusing the businesses who were trying to come into compliance. DNR
agreed to change the letters to include thanking the businesses for their efforts to come into compliance, encouraging them to review
their existing operations before the amnesty period expired, and a list of sources for permit assistance. 3) Iowa National Federation of
Independent Business conducted a joint mailing with the SBO to a select group of members identified by SIC code. The mailing resulted in
almost 150 calls in less than two weeks. The maioritv of the businesses needed a construction permit or an operating permit.
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
Kansas
A series of Air Emission Inventory and Class II Permit Application Assistance workshops were completed. The workshops were held in
Wichita, Salina, Overland Park, and Chanute to facilitate attendance throughout the state. Some comments from the course evaluations
included, "Overall, the workshop in Salina was great I" "Keep up the good work; it is people like you who care and bring the information
to us." "Thanks again for a great workshop!" "This workshop was great; the small groups were really helpful." Many participants
thanked us for being available to them, for providing easy interpretation of regulations, and for answering specific questions. The small
group break-out sessions were especially popular. Follow-up assistance and on-site assessments were provided to several workshop
participants. SBEAP worked with a manufacturer of farm equipment on their air emission inventory. As a result of the inventory and the
realization that they needed a Class I (Title V) permit, the company started exploring pollution prevention and waste minimization
opportunities. They also realized that they needed an air permit in the past, so we worked with them and the agency to get them into
compliance without a penalty. They currently are eliminating out-of-date or obsolete materials. They have improved their storage and
material tracking and are now reclaiming paint overspray for reuse. The company also began to investigate the advantage of using
waterbased paints.
A manufacturer of lawn mowers assigned an individual to environmental compliance who had very little knowledge about compliance and
was concerned about ensuring the company's ability to comply with environmental regulations. This person was provided with a major
amount of assistance with compliance and pollution prevention knowledge, which provided them with the ability to explore new options,
including the reduction of their hazardous waste generator status by switching to non-hazardous materials.
SBEAP also worked with a company that manufacturers Lucite parts. Since EPA has no emission factors on estimating air emissions from
this process, we suggested a method using existing employee exposure data and information about air changes in their fabrication room
to get a gross estimate of emissions. We worked with KDHE's Bureau of Air and Radiation to get approval for this method. The
company found that they are not a major source, and we recommended several pollution prevention measures they could take. In order to
reduce evaporative losses of their monomer (methyl methacrylate), we suggested switching from open top glass containers to HOPE
squeeze bottles.
SBEAP worked with the MidAmerica Manufacturing and Technology Centers (MAMTC) to assist a company considering installation of a
phosphate wash line to precede their paint line. This visit proved to be a success due to the coordination of our efforts with engineering
process changes suggested by MAMTC. The collaboration allowed us to provide the company with pollution prevention ideas and air
emission compliance information. Although they do not need a Title V permit, they were unaware of the thresholds and plan to look into
alternative paints lower in HAPs.
The Kansas AIRLines, the SBEAP's quarterly newsletter, has a circulation of 7,000 per issue, including over 200 new subscribers in 1996.
In addition to the newsletter, three major publications were developed and distributed including one for auto body and one for wood
furniture. The fact sheet for rotogravure and wide web flexographic printers was revised and updated. Over 500 requests for SBEAP
publications were filled this year.
Two national teleconferences were downlinked: P2 for Lithographic Printers was shown at 5 locations with 55 participants statewide;
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TABLE F-3
(Continued)
PROGRAM
Kansas (cont.)
Kentucky
Jefferson
County
Louisiana
Maine
Maryland
Massachusetts
ACCOMPLISHMENTS
the MACT standard for wood furniture manufacturers was downlinked to 5 sites, and we worked with several state vocational and
technical schools to provide environmental compliance information to students about to enter the industry.
Two important relationships were developed with trade associations, especially to assist with practical methods for information
dissemination. We developed a strong relationship with the Printing Industry Association and the Society of Collision Repair Specialists.
Kansas was asked to provide testimony on the small business assistance program for the US House Subcommittee for Small Businesses
in Washington, DC. This testimony was given at the request of Representative Meyers of the 1 st Kansas Congressional District.
Kansas SBEAP world wide web page was activated in September. A database system supports the outreach activities of the SBEAP
program. As of January 1 , 1 997, more than half of the SBEAP publications were available on the web site and can be downloaded by
clients. They have been placed on the web site in such a manner as to allow clients to download and print the documents in almost the
exact format and style of the original printed documents.
Significant accomplishments for the year include: Recognition of value of SBAP services by clients and Division for Air Quality.
Increased involvement of Panel Members in program development. Coordination by SBO of agency project to develop a regulation format
that incorporates user friendly features.
N/R
SBO and SBAP cooperated with LSD Forestry Laboratory and Department of Economic Development to organize a full day wood furniture
small business expo with the EPA teleconference as the focal point. The Secretary of the Department of Economic Development spoke at
the luncheon and several other speakers presented topics of interest to the attendees.
SBAP worked with a multimedia group to develop an amnesty program for the foundries in Louisiana. This was the first time this type of
cooperation was utilized to assist the small businessman.
Expanded Small Business Compliance Incentives policy beyond air issues to a multimedia policy. Our SBCIP has been used as a model for
other enforcement relief policies such as CLEAN-P2, Star Track, and a draft audit policy. Under these policies, the Department expects to
realize compliance and environmental gains that may not have been achieved through other means.
Recognition of appreciation at 1 996 Awards Dinner of the Korean Drycleaner Association of Maryland and the Korean Drycleaner
Association of Greater Washington. Letter of appreciation from Maryland's largest autobody paint vendor. Letter of appreciation from a
Maryland regional Chamber of Commerce.
MA Printers Partnership has been hailed nationwide as one of the most innovative compliance assistance programs to date. During 1 996,
we made presentations to several national organizations including the National SBAP Conference and EPA's Common Sense Initiative
subcommittee on printing. Several of the program structures have been tentatively adopted by the CSI/Print group for inclusion as the
backbone of their Flexible Multimedia Permittina Project.
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TABLE F-3
(Continued)
fROORAM
ACCOMPLISHMENTS
Michigan
This past spring, Michigan's SBAP, also known as the CAAP, presented a second round of workshops on the state's Renewable
Operating (RO) Permit Program. The workshops were developed and delivered by the staff of the SBAP. The workshops took place at six
statewide sites and were directed toward the needs of small and medium-sized businesses. The workshops provided timely information
regarding changes to the RO Permit Program and how to fill out the RO permit application. Interest and attendance at each workshop
exceeded our expectations with more than 390 attendees. As a complement to a previously held workshop in FY 94-95, Michigan's
CAAP presented a second workshop for facilities with Chromium Emissions from Hard and Decorative Chromium Electroplating and
Chromium Anodizing Tanks. Approximately 78 people attended. Finally, the CAAP participated in the EPA-sponsored "Wood Furniture
Manufacturers" teleconference in September 1996. Approximately 60 people attended. To provide as much information as possible to
workshop or teleconference participants, the CAAP followed-up each event with a "Question and Answer" guidance document that
addressed additional questions that arose at the workshops/teleconference.
Since its inception, Michigan's CAAP also has developed a number of guidance publications for businesses seeking assistance with air
Quality-related matters. In particular, with the initiation of the state's RO Permit Program, Michigan's CAAP developed a "Renewable
Operating Permit Program: Guidebook for Completing Forms," which guides business and industry through the intricacies of filling out the
RO permit application forms and submitting an "administratively" complete application. To assist with MACT compliance, the CAAP also
has produced a fact sheet that shows wood furniture manufacturers how to comply with the recently issued Wood Furniture
Manufacturers NESHAP. The CAAP continues to address the needs of business and industry with the development of "industry guides*
that approach compliance from a multimedia, multi-agency perspective. The object of these guidebooks is to encapsulate all the
regulatory requirements for a single industry into one, simple to understand document. Recently, Michigan's CAAP took the lead in the
development of a guidebook for the Fabricare Industry and is assisting in the multi-agency effort to develop a similar guide for the
Lithographic Printing Industry.
Michigan's CAAP is part of a wider multimedia agency called the Environmental Assistance Division (EAD). EAD is dedicated to providing
timely and effective information and assistance to Michigan's businesses, public agencies, and the general public in understanding and
marketing their environmental protection responsibilities.
8
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TABLE F-3
(Continued)
PROGRAM
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Washoe
Cty, NV
ACCOMPLISHMENTS
SBO - Seeing real movement in multimedia assistance for small business sectors, but some work needed in coordinating these efforts
better.
Small Business Environmental Loan Program - All $250,000 has been lent. Six loans went to dry cleaners to upgrade their equipment (5
dry-to-dry machines, 1 aqueous machine), and 1 wood finisher upgraded spray equipment to accommodate the use of water borne
finishes. All payments to date have been made in full and on time. During this legislative session, we have upper management and
commissioner support to merge two existing small business loan programs for bigger pot of money and for more broad multimedia/P2
capital improvements.
SBAP - Wood Finishing Leadership Grant: Participated in workgroup to develop a compliance guide for the Wood Furniture Manufacturing
NESHAP's work practices standard, established an enforcement waiver for the wood finishers, rewrote the hazardous waste and air
quality self audit checklists, established and published "The Finish Line" newsletter, developed 1/2 day multimedia and P2 workshops for
the small/medium wood finishers shops.
SBO and SBAP, in conjunction with the Air Toxics Section of the Air Division, are developing simplified versions of Air Permit Applications
for perc and petroleum dry cleaners.
The Technical Assistance Program has received many "thank you" letters commending the staff for their efforts. More this year than the
previous year. The Technical Assistance Program receives over 1 ,200 calls per month on the toll free telephone line. Staff are asked to
give presentations and workshops across the state.
SBO continues service as Region 8 representative on National SBO/SBAP Steering Committee as member of the MT State University
Pollution Prevention Program Advisory Committee and as a member of the Incineration Rules Development Team for the MT Department
of Environmental Quality. SBO also was a member of a group assembled by the state Environmental Quality Council to examine
environmental self-audit legislation and a separate team that examined used tire disposal issues. CAP member, Joe Topel, owner of
Missoula Textile Services (Missoula), won the second annual Small Business Achievement in Environmental Excellence award from the US
Small Business Administration, the MT SBAP, and the MSU P2 Program.
N/R
SBAP - N/A
Washoe County AQMD has undertaken a number of new programs with the goal of maximizing the effectiveness of their personnel.
Foremost is the preparation of the Public Information Packets, which answer the vast majority of the public's questions, thus relieving
staff from the duties of answering the same questions repeatedly. This also keeps the phone lines clear allowing speedier response to
those with specific Questions in reaard to some of the uniaue aspects inherent in the diverse industries that AQMD reaulates.
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TABLE F-3
(Continued)
PROGRAM
Clark Cty,
NV
NVBAQ
NVBEP
New Hampshire
New Jersey
New Mexico
ACCOMPLISHMENTS
The Health District's air pollution control program involves regulations for a variety of stationary sources generally regulated by CAA and
non-stationary sources, particularly construction activity. Construction activity is the largest component in the emissions inventory for
inhalable paniculate matter for which the Valley is one of the six areas designated * serious" in the US. The compliance assistance
basically involves answering routine questions from permittees and assisting them with implementation of their operating permit
conditions. Our permit specialists/enforcement officers routinely discuss permit issues with permittees. This outreach program has been
occurring for years and is an ongoing procedure.
None.
The air quality compliance outreach program for BEP consists of 6 primary components as defined under contract with SBAP at NDEP.
The program began operation in August 1 996. The following components were completed by December 1 996. 1 ) Operation of a toll-free
information and assistance line. 2) Maintenance of Air Compliance/Pollution Prevention resource center. 3) Development of NDEP
Emission Inventory fact sheet and revision of multimedia dry cleaning industry fact sheet, printing P2 fact sheet, and other training
materials distributed at the dry cleaning and printing seminars. 4) Delivery of dry cleaning seminar entitled, "Ironing the Wrinkles Out of
the Drycleaning Air Regulations" (32 attendees representing 29 businesses). A P2 seminar for printers was provided in 1996 that
addressed air P2 and permitting issues (90 attendees). 5) Taped 3 videos of the satellite downlink: Wood Furniture, Chrome
Electroplating, and ISO 14000. These tapes have since been loaned to 7 individuals. 6) Seven on-site consultations concerning air
quality issues have been conducted.
BEP provided outreach through the NV Mining Association Environmental Committee and was publicized in numerous newsletters. The
program also is publicized through brochures distributed by state and local environmental agency inspectors and the various development
authorities in NV.
Began an initiative to identify as many small business technical assistance providers as possible. (This is not limited to environmental
issues as most small businesses need a broad approach to assistance that will integrate all issues in a financially sound manner.) Initiated
the paperwork and funding to establish a NH-based APDLN satellite training site, which is expected to be completed 4/97. Gave
presentations to three industry trade associations that previously were very reluctant to allow a "regulatory" speaker to attend their
meetings. Presentations were very successful and resulted in a number of requests for on-site assistance. Developed and distributed the
"AirGuide" compliance assessment manual for use by businesses, consultants, and regulatory staff in evaluating operations for
compliance with CAAA requirements. This manual will be expanded to cover other media in the near future.
Environmental Air Compliance Audit Series - training outside individuals in air auditing; those completing series are places on list of
"qualified" auditors that is provided by hard copy and DEP BBS to small businesses. Part of the package includes information on how to
select a consultant. Over 1 00 individuals have completed the training.
Small Business Directory of Information - developed and available to small businesses by hard copy or DEP BBS.
N/R
10
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
New York
On 4/22/96, Conrad Simon, Director, Air & Waste Management Division of US EPA, Region 2, wrote a congratulatory letter that starts:
"This letter is being sent to you to express the...(US EPA)...Region II Office's recognition of the tremendous job the Division of Small
Business Environmental Ombudsman...Office has done on reaching out to the small business community in New York. In addition, EPA
Region II recognized that the Ombudsman's Office has served in a leadership role for all small business assistance programs nationwide
and is recognized as a "model program" by many states.
SBTCP was directly involved in the negotiations on rewriting New York State's general permitting regulation (6NYCRR Part 201). SBTCP
was able to convince the regulatory agency that a three tiered system was better than a single permitting approach to all businesses. As
a result, there is a system of registration for minor sources that simplifies permitting with a one page, no calculations form; a general
permit application for sources that can cap out of Title V; and a Title V application for major sources. The regulatory structure eases the
paperwork requirements for many small businesses.
The Ombudsman worked with the NY State Department of Environmental Conservation to draft a voluntary compliance policy. Although
the redrafting of the permit rule prevented the Ombudsman from conducting an outreach mailing on NY State's voluntary compliance
policy, over 100 sources came into compliance through the SBTCP.
The Environmental Ombudsman's office developed a database of Small Business Assistance Groups (SBAGs) that include: chambers of
commerce; trade associations; educational institutions; federal, state, local, and county governments; economic development agencies;
planning boards; consultants; attorneys; and many others. This list includes over 2,100 listings and is used to multiply the effect of
outreach. As an example, one chamber of commerce in Syracuse represents over 1,800 members and a sampling of 43 SBSGs shows
over 100,000 businesses are reached by the multiplying effect of the information provided to these groups. An important aspect of this
is a close working relationship between the multiplier and the SBO. The Ombudsman's Office works on establishing and maintaining this
interaction so that the SBSG has a good understanding of what services the SBTCP can provide.
11
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
North Carolina
A Permit Reform initiative in NC has resulted in the formation of a new Environmental Permit Information Center (EPIC) to answer
questions of clients about all environmental permits and develop user friendly permit factsheets. This center is part of the Office of the
Small Business Ombudsman.
Developed a multimedia environmental compliance manual for wood furniture industry. Held several workshops to provide hands-on
assistance to the wood furniture small businesses in NC.
Small businesses continue to have a regular seat at the table as air rules and procedures are developed. This is accomplished by their
participating on several Air Quality internal work groups as well as legislative work group on air toxics.
Rule changes continue that will clarify present rules and regulations to limit permits to only significant air pollution contributors. A
registration process is under discussion. Changes to the potential to emit definition and new emission factors will benefit many small
businesses.
A 100% increase in technical assistance including on-site assistance to wood furniture companies, service stations, dry cleaners, small
boat manufacturers, metal plating companies, and others.
North Dakota
Certain advantages realized through the SBAP/SBO structure include: 1) Because the Department staff administering programs that affect
small businesses are housed in the same building as the ombudsman, the SBO can conveniently visit the director of the air pollution
control program (who is also a CAP member), the SBAP coordinator, or any member of the Environmental Health Section. This
arrangement is conducive for informal and frequent meetings. 2) The ombudsman is invited to attend the Environmental Health Section
Division Directors' meetings, which are held twice a month. This helps the SBO to be aware of media program developments and policy
developments that may have an impact on small business. This also provides an opportunity for the SBO to present new concepts (e.g.,
self-audit policy) and also interjects small business perspective to pertinent issues. 3) The ombudsman serves as a clearinghouse for P2
documents for the Environmental Health Section.
12
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TABLE F-3
(Continued)
PROGRAM
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
ACCOMPLISHMENTS
SBAP provided on-site assistance to 109 companies. This resulted in assisting with 135 permit applications, which, most likely, would
never have been submitted without the aid of the SBAP. The companies would have certainly received notices of violation from actual
OEPA inspectors for these unpermitted sources. Although difficult to quantify, this assistance has saved each company anywhere from
$1,000 to $10,000 in professional consulting fees.
SBAP received special recognition in a thank you letter to OEPA Director Don Schregardus from the Printing Industry of Ohio (PIO) for
SBAP's involvement in the ENVIROPRINT project.
SBAP established good working relationships with the permitting and enforcement staffs of the 5 OEPA district offices and 1 0 local air
agencies. The field office staff, which includes enforcement personnel, continue to refer companies to SBAP for assistance.
SBAP played a major role in implementing OEPA's new fee system for non-Title V facilities. Introductory letters and SBAP brochures
were mailed to 21 ,000 facilities in the air permit system. In addition to answering many calls, SBAP developed guidance for all OEPA
field offices on how companies should correctly complete the new fee reports. SBAP continues to provide follow up support to help non-
responding facilities.
SBO's major accomplishments in 1996 centered on building solid working relationships with key state trade associations including:
Printing Industry of OH, OH Small Business Council, OH Chamber of Commerce, OH Bakers Association, OH Cleaners Association, OH
Cast Metals Association, OH Chemical Council, National Federation of Independent Businesses OH, Automobile Service Association of
OH, OH Petroleum Marketers Association, and OH Council of Retail Merchants.
Based on the contacts made during 1996, SBO expects significant outreach to member businesses in 1 997.
ECOS Award for the Customer Assistance Program.
Pollution Prevention Outreach Team Best Management Practices for the Automotive Industries. Dry cleaners workshop. Initiation of a
Pollution Prevention Tax Credit Program. Initiation of a Dry Cleaner Pollution Prevention and Contaminated Site Cleanup Program. Laid
groundwork for Cross-media Pollution Prevention Green Sticker Program. SBAP-PPRC Commercial Printing Compliance and Pollution
Prevention Workbook. SBAP-Small Business Development Center Education Project. Sponsored EPA-University of Tennessee satellite
teleconference on wood furniture manufacturing. Improved communications with vendors, community colleges, and trade groups.
N/R
We are trying very hard to get this program 1 00% effective even though we don't have the SBO and CAP here to help us. Every small
business we help counts as an accomplishment.
The Rl Pollution Prevention Conference and Exposition attracted over 700 people in late October 1 996. The conference provided Clean
Air Act. SBO. and SBAP information on a larae scale.
13
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TABLE F-3
(Continued)
PROGRAM
South Carolina
South Dakota
Tennessee
ACCOMPLISHMENTS
SBAP has been recognized by other media programs within the Agency as a valued resource for working with the regulated community.
Strong relationship developed with BAQ Compliance/Enforcement group that has resulted in increased awareness of small businesses'
financial situation. SBO has been chosen to take lead in developing a small community technical assistance/outreach program for
Agency.
N/R
A program staff person was on a panel of national experts for a chrome plating national teleconference. TN's chrome plating manual was
used as the document to accompany the national chrome plating teleconference. Efforts with printers have resulted in registration and
exemption from permit requirements for 1 8 printing facilities. SBAP Program Manager serves on the Advisory Board for the state's Small
Business Development Centers. TN's Air Pollution Control Board, which has the authority to establish the program's funding level, has
been complimentary of program efforts following program update presentations. Workshop evaluations indicated the participants found
the workshops to be good or excellent. TN Association of Business complimented activities conducted by the program. National
teleconference efforts were initiated by TN on regulatory compliance for small business. These teleconferences targeted the first small
business industry arouos reaulated under the 1 990 CAAA. which include drv cleaners, chrome olaters. and vaoor deareasina facilities.
14
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
Texas
Spray booth demonstration project. SBAP received a grant from EPA to demonstrate a low-cost automotive spray booth in El Paso. The
project helped auto body repair shops from Mexico and the U.S. leam how to reduce waste and comply with environmental regulations.
SBAP helped develop a rule that will eliminate date stamping of cosmetics, windshield wiper fluid, etc. Businesses will comply by printing
on the label, "This product was produced in compliance with state of Texas laws." Manufacturers will save $200 to $400 per batch. It
will no longer be necessary to buy stamping machines at a cost of $10,000 to $15,000. Companies that could not afford the machines
will not have to hire employees to stamp products by hand.
To encourage voluntary compliance, SBAP helped develop an amnesty program for the wood products industry. The program, which
began January 1, 1996 and runs through August 31, 1997, allows small businesses in this industry to comply without fear of penalties.
We received inquiries from 388 businesses interested in participating in the amnesty program. As a result of our efforts, a standard
exemption for the wood products industry is being created to streamline compliance requirements.
The Environmental Management Systems Grant will give small businesses a simple tool to identify environmental costs associated with
their businesses and an immediate way to reduce costs and help the environment at the same time.
The U.S. General Store Grant will provide small businesses with a plain language informational brochure on how to use the internet;
hands-on Internet training; and a system of web home pages to help them identify ways to minimize waste, comply with environmental
rules, and prevent pollution.
The RCRA Grant will provide on-site technical assistance to small businesses on ways to reduce their hazardous waste generation and
teach them to complete the necessary waste forms.
The Texas-Mexico Border Region Grant will expand pollution prevention and compliance to support Spanish speaking small business
owners in the Texas-Mexico border reaion.
15
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
Utah
Establishment of Permitting de Minimis: SBAP initiated the establishment of a permitting de minimis, or minimum permitting level, for
small sources in this reporting period. Up until the proposed de minimis rule, all sources of air pollution were required to submit a permit
application, known as a Notice of Intent (NOD to obtain an Approval Order (AO). After submitting a NOI, most smaller sources were not
required to obtain an AO, since pollution control options were deemed economically unfeasible during the engineering review. Recognizing
that the NOI requirements were time-consuming and expensive for small businesses and served no environmental benefit, the SBAP
initiated a permit streamlining effort. The first phase of the permit streamlining effort was the permitting de minimis. The permitting de
minimis rule was adopted at 500 pounds/year per Hazardous Air Pollutant (HAP) or 2,000 pounds/year for a combination of HAPs and 5
tons/year for any of the criteria pollutants. A Registration Notice was established for small sources in non-attainment areas. SBAP
currently is developing the Registration Notice form, worksheets, and factsheets.
P2 Training Workshop for Air Quality Permit Writers: SBAP collaborated with Department of Pollution Prevention Program (P2 Program) to
develop a P2 training workshop for Division of Air Quality permit writers. Funding for the training program was provided through a grant
from the P2 Program to SBAP. A pilot study will be conducted following the training to maximize the effectiveness of the training and to
evaluate the effectiveness of incorporating a P2 approach into a small business* air permit, known as an Approval Order.
The P2 training program is an essential step in DAQ's goal of promoting P2 in the permitting process. P2 training will provide the New
Source Review (NSR) engineers with an understanding of P2 concepts and examples of practical applications. With this knowledge, NSR
engineers will have the expertise required to promote P2 in both the pre-issuance and permit development phases of the permitting
process. The training workshop is scheduled to be delivered in February 1997.
Small Business Compliance Policy: SBAP initiated the development of a Small Business Compliance Policy and Penalty Mitigation Rule this
reporting period. The purpose of the policy is to clarify the responsibilities of the SBAP and Division of Air Quality's Compliance Section
when providing compliance assistance to small businesses and to provide provisions for evaluating penalty assessments to small
businesses. The policy is consistent with EPA Small business Enforcement Policy, EPA Self Audit/Self Disclosure Policy, Senate Bill 84
and Senate Joint Resolution S.J.R. 6, and the 1990 CAAA.
Newsletter: Introduced first edition of "Air News" newsletter with total circulation of 3,500 copies to small businesses, agencies, higher
education, trade associations, libraries, etc. The first edition was introduced in fall 1996 with the "Utah Small Business Environmental
Resources" list, which provides statewide contacts for environmental issues.
Scoping Activity: A Small Business Scoping Activity was conducted on December 12, 1996, which is an element of the EPA Small
Business Leadership's "Partnership for Compliance" Grant. This grant was awarded to the Division of Air Quality. Representatives from
various small businesses, agencies, and organizations participated in the activity to identify barriers to achieving compliance with
environmental regulations. Information gathered at the scoping activity will be used for "Partnership for Compliance" outreach activities.
16
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TABLE F-3
(Continued)
PROGRAM
ACCOMPLISHMENTS
Utah (cont.)
Clear the Air Awards: The first annual 'Clear the Air' awards program was conducted with the Salt Lake City Rotary Club and Utah's Lt.
Governor in January 1996, which honored over 30 businesses, individuals, organizations, and government entities for their efforts to
reduce air pollution. The second annual 'Clear the Air* awards program nominations and outreach/educational campaign was launched in
fall 1996, while awards will be given again in January 1997.
GIS Ozone Visualization: A special 3-dimensional topographical video was created in coordination with Utah State University's award-
winning Space Dynamics Laboratory. The 2-minute video publicly debuted with the Salt Lake Rotary Club in conjunction with the 'Clear
the Air' awards program. The video was picked up by a local television station, and discussions are currently underway to conduct daily
ozone forecasts as part of weather reports as well as to produce educational videos on Utah's air quality conditions for statewide
distribution.
Consulting Engineers' Roundtable: An annual multimedia roundtable conference has been coordinated with the Division Executive
Directors for open dialogue with and material distribution to engineers who work with Utah businesses. This event is held annually in
January as a precursor to the state legislative session. Approximately 60-80 engineers attend and participate.
Vermont
Although this report may not reflect a great deal of activity for 1996, the fact that a full time employee was hired in December as a Small
Business Compliance Advisory Program Engineer is a huge step forward in Vermont's effort to comply with the Clean Air Act's
requirement for a Small Business Assistance Program. This new position should satisfy the SBAP portion of the overall program, and a
CAP is almost complete (as of February 1997). Discussions on how to satisfy the Ombudsman requirement have begun, but there is no
clear indication of how this is going to be accomplished at this time. As intended in Vermont's legislation, our program is multimedia in
nature, covering the regulatory programs across the Department of Environmental Conservation.
U.S. Virgin Islands
I would like to get more training through the Peer Match Program so that I may be better equipped to make presentations at seminars or
workshops. Need a better understanding of just what this is all about. Need staff to be hired that regular inspections can be done. Need
additional funding to get all this done. Was approved to peer match with California by Karen V. Brown, however, this has not taken place
as of 1/10/97. (Marylyn A. Stapleton, SBTAP Coordinator)
Virginia
SBAP is very proud of the receipt of a $150,000, 3 year Leadership Grant to explore and provide compliance assistance and P2
information through the Internet.
SBAP participated in fostering the creation of legislation to establish a revolving loan fund from which small businesses can access capital
for CAA regulatory compliance and P2 activity.
SBAP is proud of the project association with EPA's Office of Compliance Chemical, Commercial Services, and Municipal Division to
develop a mentoring program for Korean dry cleaners through the Greater Washington Korean Dry Cleaners Association and also the
production of a compliance video highlighting the most common areas of non-compliance while depicting an EPA Enforcement Inspection.
Hopefully, both will be able to be used on a national basis.
17
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TABLE F-3
(Continued)
PROGRAM
ACCOMPUSHMENTS
Washington
ECOLOGY CRO: 1) Enforcement avoided through technical assistance. DeAtley Company's portable rock crushing operations have had a
number of compliance problems. Enforcement meetings produced an agreement whereby training would be provided in lieu of a penalty
action. A workshop was conducted and attended by approximately 85% of DeAtley rock crushing unit employees, including management
and crusher operators. Client evaluation: Evaluation forms returned rated the workshop from good to very helpful and very useful. All
responses to the question, "Do you thing this is a good way for regulators to provide information to your company?" were positive. 2)
Technical assistance encourages pollution prevention beyond legal requirements. Wells and Wade Fruit Company requested permission to
burn several hundred fruit bins. Although such burning is allowable, Ecology believes recycling and reuse are preferable. Ecology staff
researched and located a number of woodwaste recyclers willing to travel to eastern Washington and provided a list of companies to
Wells and Wade. This technical assistance resulted in disposal of the bins through chipping and recycling instead of burning. Client
evaluation: Client reported to staff that the transaction had worked very well. Appreciation for extra assistance in research and phone
calls were expressed. 3) Technical assistance encourages voluntary compliance. Land clearing and construction projects generate
numerous dust complaints during the dry season in eastern and central Washington. In response to a particularly difficult construction
season, staff developed a focus sheet targeting air pollution prevention on building and construction projects. This focus sheet will be
made available through local building and planning departments. So far, one local agency has agreed to attach the focus sheet to their
building permits. Client evaluation: The local agency mentioned above agreed it may help encourage voluntary compliance.
YRCCA: 1) Feedlots: A series of meetings was held with operators to discuss complaints, concerns, and the opinions for a dust control
abatement process. Procedures were suggested for voluntary compliance to clean air standards regarding these agricultural operations.
2) Dairies: Reviewed available options for controlling manure/wastes for odor emissions including spray fields, agricultural zones, insect
control/reduction and dust abatement measures. Met with representatives of technical firms that offer various solutions for manure
problems. 3) Construction dust: Conducted several monthly meetings/hearings on dust control policies/procedures that will mitigate
concerns created during the course of construction (i.e., blowing dust from dirt piles, excavation or extrication activities, and demolition
projects). We're establishing a permitting process for requiring dust control measures within each of the 14 municipal jurisdictions
located within our region. Developed written plans/policies for implementing these requirements along with the accompanying
informational booklets and brochures defining/describing these regulations. Currently under review are the distribution methods for
getting these handouts to the public contractors with several different options being considered. An arena also being explored is the cost
sharing of the publishing expenses for these handouts with various entities and representatives from the construction trades. 4)
Agricultural Wood Burning Reduction: Expected to be the main focus for our 1997 BAP activity. Preliminary studies indicated that orchard
pruning or tree removal and grafting operations provide a fuel load that when incinerated makes an enormous contribution to the PM 10
level within our jurisdictional boundaries. Based upon even the most preliminary figures, indicators show a definite need to develop
alternatives against the agricultural burning of wood wastes. Included in this program will also be open field burn off; road, fence, and
irrigation right of way weed control by fire; and the burning of old fence, hop, and grape posts that have been treated chemically against
wood rot. 5) Gasoline Vapor Compliance: Targeted area retail and wholesale distributors advising them of the upcoming future
compliance regulations for the distribution/marketing/production of gasoline. Reviewed existing procedures for implementing the new
policy requirements as they are adopted.
18
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TABLE F-3
(Continued)
PROGRAM
Washington (cont.)
West Virginia
Wisconsin
Wyoming
ACCOMPLISHMENTS
6) Asbestos Program: Developed and implemented a standardized county-wide approach for the proper removal or disposal of asbestos
containing materials. Established policies and procedures for identifying, defining, and enforcing state/federal mandated requirements for
abating any asbestos problems in residential and commercial dwellings. Identified those licensed contractors for providing asbestos
removal or stabilization work.
SBAP has continued periodic meetings with various other agencies and organizations that provide environmental compliance and pollution
prevention assistance to businesses (small to medium sized). The intent has been to increase the effectiveness of the individual programs
by extending the client bases and coordinating efforts to assist these clients. These groups include: WVDEP Pollution Prevention
Services; WVDEP Waste Minimization; The Marshall University Center for Environmental, Geotechnical, and Applied Sciences; The
Marshall University Procurement Technical Assistance Center; The Robert C. Byrd Institute for Advanced Flexible Manufacturing; The
West Virginia University Industrial Extension Service; and the National Institute for Chemical Studies (NICS).
Work on a joint outreach/informational brochure has been completed and 2,000 copies distributed to the members. In addition to the
groups noted above, the brochure also references the WV Partnership for Industrial Modernization (WVP1M) and the National Technology
Transfer Center (NTTC). The group has loosely termed itself the "WV Environmental Coalition" and has started work on a multimedia
environmental awareness poster for its next project.
SBAP has committed to devote two people for developing general permits, particularly for the coal industry. Other materials-handling
general permits should be developed later in the year. Intensive outreach to dry cleaners to assist with compliance certification and
record keeping was initiated in the fourth quarter. WV was one of the first states in Region III to recognize that the Municipal Solid Waste
NSPS would impact businesses that meet the Section 507 definition of "small." Subsequently, outreach was done and a workshop was
conducted on the new requirements.
SBAP has been working with the enforcement group to develop less intimidating and simpler forms when violations are discovered.
Although a "field citation" form has been developed, it has not yet been approved by the Chief.
SBO has developed a Revolving and Low Interest "Small Business Environmental Loan Program," which has received an enthusiastic
endorsement by the chief of the WV Division of Environmental Protection (WVDEP) and the WV Senate Small business Committee. This
bill will be presented to the 1 997 legislature.
SBO also has convinced the Director of DEP to study the merits of consolidating small business inspections performed by the various
offices within the WVDEP. For example, service stations are inspected by the Office of Air Quality, the Office of Water Resources, and
the Office of Waste Management. It is proposed that since the Office of Waste Management has most of the "concerns," they should
become the lead office and perform all the inspections.
N/R
N/R
19
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APPENDIX G
COMPLIANCE ASSURANCE ISSUES
-------
TABLE G-1
COMMON COMPLIANCE PROBLEMS
COMPLIANCE PROBLEM
Not understanding regulatory requirements
Operating without a permit
Incomplete record keeping
Uncertain of permitting requirements
Uncertain how to determine emission inventories/general lack of technical experience
Financing for control requirements
Uncertain how to complete forms/complicated paperwork
Operating outside NSPS or MACT
Improper storage/disposal of hazardous waste
Fear of regulatory agency/arbitrary regulatory enforcement
Failure to use/finding the right equipment/technology to comply with applicable standards
Confused over multiple permitting requirements/need for multimedia permits
Overwhelmed by quantity/complexity of regulations
Uncertain as to which government agency to contact/when to contact
Lack of sufficient notification by or getting accurate information from regulatory agency
Non-compliance since risk of inspection and penalty seem remote
No manifest for special or hazardous waste
Labeling of storage areas
f PROGRAMS
28
26
16
14
12
10
10
10
7
6
6
5
4
3
2
2
1
1
% PROGRAMS
53
49
30
26
23
19
19
19
13
11
11
9
8
6
4
4
2
2
County and regional programs not counted separately.
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TABLE G-1
(Continued)
PROGRAM RESPONSES
Programs were asked for information on the most common compliance issues addressed during the course of providing technical assistance. Individual
program responses are listed below. Comments are edited for space.
PROGRAM
Alabama
Alaska
Arizona
Maricopa Cty
PimaCty
Arkansas
California
Kern County
APCD
COMPLIANCE ISSUES
General lack of understanding of regulatory rules and requirements.
Dry Cleaners: Of the dry cleaners visited, only one was tracking their 1 2 month rolling perc purchase total correctly. Most ask why a
calendar year was not selected. Second-most common problem is recording of inspection. The dry cleaners are inspecting as required, but
some only write down the inspections if there was something wrong. Did not realize they had to record all inspections, even if there were no
problems discovered.
Auto Shops: Usually, the most common problem is associated with labeling and storage of used oil.
Since most of the small businesses do not have a Title V air permit, there has not been a lot of issues with compliance at this time. Most of
the SBAP's effort is to notify businesses of the upcoming Title V application deadline and help them determine if they need a permit, an
enforceable limit to avoid a permit, or if they are even covered by Title V.
Operating without a permit. Operating without control device, such as paint booth, baghouse, etc. No records of chemical usage or other
records.
Our primary obstacle has been bringing businesses into compliance. Many businesses that should have an air quality permit are still operating
without one. As a non-regulatory program, we can only work with sites to bring them into compliance voluntarily. Our program is funded by
air permit fees.
Difficulty in understanding regulations. Difficulty in completing required permit applications. Difficulty with PTE concept. Uncertainty
whether proposed revisions are minor or major. Requirements for synthetic minors. Recordkeeping requirements (especially for dry cleaners).
With respect to metal fabricators, a lot of business owners have been unaware of how to get rid of hazardous waste materials (sludge).
Companies do not understand regulations and cannot take the time to understand, so requirements, such as annual usage reporting, slip
through.
Since our Local Air Districts issue the permits, this is largely inapplicable at our state level. Our workshops with those we regulate prior to
rule adoption are well attended and have excellent participation.
Difficulty keeping records, which shows the facility is operating in compliance with our rules. For a rule to be US EPA approvable,
recordkeeoina reauirements are orettv onerous!
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TABLE G-1
(Continued)
PROGRAM
Placer
County
APCD
Santa
Barbara
APCD
SCAQMD
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
COMPLIANCE ISSUES
This answer applies to auto refinishing, dry cleaners, cabinet shops, and printing companies. Small business sources have never had to be
concerned before about air permits. There is much confusion about difference between Air District requirements and Hazardous Waste
requirements. They need more than one explanation and sometimes they don't want to Understand. Most small shops have no one person
assigned to basic permitting and recordkeeping duties. In general, the Air District is perceived only as a fund-raising entity in government,
charging "excessive" fees for no tangible product. Most shops contacted have very limited staff and operating cash.. We have attempted to
counteract these impressions with workshops, offers of assistance with forms, and in general, trying to be patient with them.
Whether or not a business needs an APDC permit. Lack of understanding of the permit process. How to keep records in accordance with
rule and permit requirements. Finding the right equipment and/or technology to comply with applicable standards. Finding appropriate
alternatives to solvents.
Dealing with the cost of control technologies, especially for low emitters. Recordkeeping for regulatory agencies is too laborious. Takes too
long to obtain a permit to construct.
Lack of understanding about regulatory requirements. Lack of resources to implement control technology.
Difficulty in staying on top of the overwhelming number of regulations that apply to small businesses. The importance for regulatory agencies
to ensure that a level playing field is maintained. Non-complying facilities should not be rewarded and that high performing facilities should be
recognized as such. Pieces of equipment/processes that require minor permits. Confusion over how to meet recordkeeping and reporting
requirements required by the regulators. Confusion over state and federal regulations and areas where they overlap. Notification and testing
requirements.
Most common problem expressed by most industry sectors is that they do not understand the regulations, because they are poorly written
and overly complicated. Most do not know whether or not they need a permit to construct or operate. Much confusion about Title V and
properly completing permit applications.
Lack of permit for new equipment. Not knowing when and why to notify the regulatory agency. For instance, do not know whether to notify
agency for change of ownership or installation of new equipment.
Compliance assistance is conducted by the Department's district air inspectors. This past year, the Department created a general air permit
program for area sources. Many area sources are small businesses. Inspections of these area sources began in late 1 996. Reporting
analysis is not complete or available until the electronic database is completed. However, information from the CFC program shows that
recordkeeping was the most frequent non-compliance issue.
Two areas that we have identified are inadequate recordkeeping and facilities operating without permits.
Technical assistance provided involved issues related to the interpretation and understanding of the regulations and permit requirements.
N/R
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TABLE G-1
(Continued)
PROGRAM
Illinois
Indiana
Iowa
Kansas
Kentucky
Jefferson
Ctv
COMPLIANCE ISSUES
Unpermitted equipment in manufacturing and metal parts fabricating (operating permits-air; pollution control device permits-air).
Waste: no manifests for hazardous and special wastes.
Auto repair: not air conditioning/Title V certified. Some have air permits but not land permits.
They need multimedia permits. The cost of coming into compliance. Lack of understanding. Fear of the regulatory agency.
Constructing or operating without a permit. Uncertain of permitting requirements for new and existing businesses. Uncertain of other
requirements (OSHA, DOT, etc.) that they need to follow. Uncertain of the regulations, don't know what they need to do in order to be in
compliance. Overwhelmed by the regulations, especially where there are overlapping regulations (either multi-media such as air, water, and
waste regulations or regulations of OSHA, DOT, Fire Marshall, etc.). Uncertain of which government agency to contact. Not understanding
the need for permits by both state and local agencies; believe that having one permit will cover all requirements. Dry cleaners uncertain how
to comply with new standards required by Dry Cleaners NESHAP. Dry cleaners don't know how to figure solvent mileage. Don't know what
VOCs are or how to track VOCs. Operating outside of MACT requirements. Lack of notification by the agency of rules that will impact
businesses. Uncertain of how to properly keep records. Fear of regulatory enforcement. Heating/cooling industry uncertain of what to do
with old mercury thermostats (or mercury bulbs). Uncertain of what to do with used fluorescent light bulbs, oil, antifreeze, and other misc.
products.
RE Title V: Uncertain of permitting requirements. Don't understand that they can drop from one tier of the program to the next (to ease the
permitting and fee requirements). Don't know how to calculate emissions. Uncertain of how to complete the application. Uncertain of
compliance monitoring requirements. Uncertain of due dates for applications and fees.
Various questions regarding: TRI reporting and compliance, Universal Waste Rule, Voluntary Remediation Program, MACTs.
Nearly all clients need to get New Source Review permits (also known as construction permits). Many need assistance with Emission
Inventory development; applicability determination with Title V, NSPS, and NESHAP; and recordkeeping, completing forms, responding to
inquiries from regulatory agencies.
The overwhelming majority of facilities are willing to comply. One common problem for manufacturers is distinguishing between the various
environmental enforcement agencies (county or local, KDHE, and EPA) and offices within each of these agencies. As a result, some believe
they are in compliance for all their environmental issues even if a regulatory inspection was done on a limited scale. Lack of understanding of
regulations also is a common problem. Generally, there continues to be frustration from people who have been given environmental
responsibilities without adequate training and resources.
SBAP has assisted facilities that did not have construction and operating permits, whose emissions were exceeding legal limits, and others
that were not aware of Title V permitting requirements.
The most common compliance problem has been lack of permits and reporting. Most small businesses in Jefferson County are not out of
compliance with oresent air aualitv standards.
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TABLE G-1
(Continued)
PROGRAM
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
COMPLIANCE ISSUES
Understanding new rules and regulations. Understanding and completing emission inventories and permit applications.
Not knowing they were subject to certain regulations. Not understanding regulatory requirements. Not having necessary permits. Problems
are across all industry sectors.
Lack of information, lack of paperwork (permits, recordkeeping).
Generally, compliance problems have been the same as previously identified: lack of awareness of regulations and lack of understanding of
the rules when awareness does exist. The increase in technical assistance/compliance assistance (TA/CA) activities has increased both
awareness and understanding. However, information we have received from business indicates there are problems associated with
enforcement also.
1 ) Companies are reluctant to come forward for fear of enforcement activity if regulatory agencies become aware of a situation of non-
compliance. 2) Companies, especially in small business sectors, do not feel compelled to go to the effort of coming into compliance, because
the risk of inspection and penalty seems remote.
Industry-specific compliance information is being compiled for some industry sectors with which we are involved in TA/CA projects. For
example, of the 1 00 DEP inspections conducted of printing facilities in conjunction with MP2 project, the five most commonly cited areas of
non-compliance were problems with hazardous waste regulations such as 1 ) failure to properly label the hazardous waste storage area, 2)
failure to list start of accumulation date on drum label, and 3) failure to keep all VOC-containing materials tightly covered at all times.
In Michigan, there is a tremendous volume of governmental regulation that business must comply with on a day-to-day basis ranging from
environmental (e.g., air, land, water, and waste permitting; fire safety issues; etc.) to labor force issues (e.g., OSHA regulations). For some,
it is overwhelming; there are not enough hours in the day to stay on top of all these requirements.
The states' SBAPs should be or are synthesizing these regulations/requirements into more simple and understandable terms for such
businesses. To address this issue, Michigan, like other states, is in the process of developing handbooks for specific industries (e.g., dry
cleaners, auto body industry, etc.) that contain a comprehensive, yet simple organization of the requirements.
One compliance issue that seems to resurface constantly is where to find the right piece of pollution control equipment to achieve compliance
with a state or federal regulation.
New businesses having difficulty in getting a comprehensive information package that includes all media and extends beyond MPCA rules to
OSHA, ERC, counties, etc. New permittees having difficulty in keeping up with recordkeeping and calculations required for compliance with
permits. People not understanding the permitting program and how it applies to their facility.
Dry Cleaning Industry: Incomplete reports and operating outside of regulation (MACT).
Drv Cleanina Industrv-Petroleum NSPS: Incomolete reoorts and ooeratino outside NSPS.
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TABLE G-1
(Continued)
PROGRAM
Missouri
Montana
Nebraska
Nevada
Washoe Cty
Clark Cty
NVBAQ
NVBEP
New
Hampshire
New Jersey
New Mexico
. '' . ' , <'"'•••' ' - : ' \ COMPLIANCE ISSUES ; ' ',
The Missouri Department of Natural Resources' Technical Assistance Program is multimedia and receives requests for all types of
environmental compliance assistance. In regard to requests for assistance relating to the Clean Air Act, Emissions Inventory Questionnaires
(BQ), construction and operating permit assistance ranks at the top. Many small businesses have never completed an BQ and request our
assistance. Other requests are from facilities that were not aware they needed a construction permit before they installed their equipment
and subsequently received a "notice of violation* (NOV) when they were inspected by the department's air inspectors. These facilities are
referred to us for assistance in completing an application for a construction permit. Others request assistance in completing their
construction permit applications before installation. The operating permit is a new requirement for Missouri's small businesses and they have
been requesting training and assistance in completing these applications.
Non-compliance with MACT standard reporting deadlines. Failure to use totally enclosed, filtered, and ventilated spray booths in body shops
and some small manufacturing operations. Poorly maintained equipment. Poor hazardous material and waste management practices.
The most common compliance problem for small business is not knowing or being unsure of what their obligations are under the regulations.
Typical type of assistance is to provide a site visit to identify the waste streams, determine the Potential To Emit, work through the actual
emission factors, and assist in filling out applications for permits. In the process, Pollution Prevention Opportunity Assessment is provided
along with technical assistance where needed.
SBAP finds that companies do not understand regulations or the regulatory process and are often operating without a permit. Depending on
the providers, the counties have more "urban" problems. For example, a person complained about permit conditions, but he didn't understand
40 CFR Part 60 on New Source Performance Standards (NSPS).
The most common compliance problems associated with air quality in Washoe County are in order: dust/tracking/no water on construction
sites, odors from industrial operations, burning/smoke, and asbestos.
There are a number of facilities that do not have proper "Authority to Construct" or proper "Operating Permits." Sometimes, inspectors
encounter facilities with excess emissions. When these events are discovered, notices of violation are issued, calling for either corrective
action and/or proposing penalties to be assessed by the ARC Hearing Board.
In the early 1 990s, BAQ issued 1 permit for each emission unit. In response to complaints from the regulated entities, BAQ consolidated
these permits into 1 facility-wide permit that eliminated a lot of redundant language. BAQ also worked to improve the language and
requirements contained in the permit to help owners and operators with understanding the permit process.
BEP has not identified any trends at this time. However, they have only been providing services since September 1 996.
Not understanding regulatory requirements. Operating without a permit or a determination that a permit is not required. Improper
classification and/or disposal of hazardous wastes.
Permit problems: Not up to date, lack of, too high Potential To Emit, etc.
Most facilities needino SBAP assistance lacked oermits.
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TABLE G-1
(Continued)
PROGRAM
COMPUANCE ISSUES
New York
Typical problems, consistent across industry sectors, include: Unaware of applicable regulations. Not having a valid operating permit. Unable
to understand permit application. Businesses often lack the financial resources to comply with regulations. Businesses are frequently under
the impression that if they apply for and are issued one permit, they are in compliance with all requirements. (For example, many businesses
are in compliance with the NY City Department of Environmental Protection regulations, but do not have a state permit.)
North Carolina
Unpermitted facilities. Confusion about whether an air quality permit is required. Businesses lack the technical expertise to identify air
pollutants, emission sources or points, and calculating emissions. The number of facilities needing a permit or not complying with air quality
regulations is unknown.
North Dakota
The most common problem is small businesses understanding the regulations. Regulations need to be written in a manner that is much easier
to understand. EPA should change their "Once in-Always In" policy for MACT standards.
Ohio
The most common compliance problem has been lack of permits. Approximately 10% of those who received on-site assistance had permits.
Lack of permits is the most common violation found by inspectors, and correcting this is the main focus of SBAP assistance efforts.
Companies also report problems with understanding regulations, redundant reporting and recordkeeping requirements, and getting straight
answers from the regulatory agency.
Many companies also felt the OEPA could do more proactive outreach and education or otherwise provide a single avenue for companies to
get regulatory information.
It appears small businesses in some heavily regulated industry sectors (e.g., chemical) benefit from a "trickle down" understanding of
environmental regulations from their larger competitors. Other less regulated sectors, like dry cleaning and printing) do not seem to have such
a benefit. SBAP received very few assistance requests from chemical companies.
Oklahoma
The major problem we encounter is a facility that is unpermitted for air emissions. We are working, as an Agency, towards addressing
noncompliance through more common sense approaches to regulation. The most common reason people are out of compliance with air
permitting requirements is ignorance to the rules, which they may ignore because they do not understand them or they are too burdensome as
far as time commitment. _____
Oregon
Don't understand regulations. Operating without proper permits. Inadequate or no records. Not submitting Form R, TRI reports. Have not
calculated emission levels. Employees not trained to practice P2. Improper waste disposal (e.g., evaporating solvents to avoid RCRA). Don't
understand pitfalls of cross-media transfer of pollutants. Lack knowledge of alternative, less polluting technologies. Failure to seek technical
assistance to avoid non-compliance.
Pennsylvania
Missing plan approvals or permits due to grandfathering of sources. Vapor degreasers in relation to MACT.
Puerto Rico
Incomplete reports, lack of knowledge on compliance matters, translation of rules and documents related to environmental matters. Getting
into compliance sometimes may be too expensive (equipment, paperwork, etc.). Permit requirements from other offices.
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TABLE G-1
(Continued)
PROGRAM
COMPLIANCE ISSUES
Rhode Island
Lack of knowledge regarding the requirements of the air regulations generally result in lack of permits for equipment, violations of VOC limits,
and violations of HAP limits.
South Carolina
Operating without a permit, which is usually a result of a lack of knowledge of regulatory requirements or the fear of regulatory agency and
associated costs of compliance.
South Dakota
South Dakota has not experienced a compliance problem with small businesses.
Tennessee
Not understanding how to complete permit forms. Dry cleaners not understanding required controls. Not knowing which government agency
to contact. Financing options for control requirements. Not knowing better operating options including less toxic solvent substitutions.
Texas
Waste: Businesses are not aware that they need to notify TNRCC about how they handle their waste, that they need to classify their waste,
and that there are limits on how long they can store hazardous wastes on site.
Air: Businesses are not aware that they cannot create a nuisance and that they need to have a permit or standard exemption before they
begin construction of their facility.
Foundries: Opacity exceeded.
Dry Cleaners: Businesses are confused about the difference between chillers and refrigerated condensers.
Auto Body: Businesses are not aware that they need standard exemptions, are not aware of stack height requirements, and are not aware of
ventilation requirements.
Miscellaneous: Businesses feel that paperwork is too complicated. They have to hire a consultant. Businesses do not have the necessary
funds to meet compliance regulations.
Utah
Permit Streamlining Needs: Many small businesses do not have the necessary air permits, known as Approval Orders, to discharge emissions
into the ambient air. Businesses are either unaware of the requirement or lack the knowledge or terminology to understand permitting
requirements, and therefore do not obtain necessary permits. Some businesses choose to ignore the permitting requirements and feel that
there is a slim chance that they will be involved in a compliance action. The new permitting de minimis for the Division of Air Quality serves
to simplify and clarify the permitting requirements for small businesses.
Need for Multimedia Assistance: this issue has been identified by other state assistance providers at various forums, but its importance
cannot be over-emphasized. In the course of providing technical assistance, SBAP staff are requested to provide assistance on other
regulatory requirements and issues beyond just air quality. Most businesses view the "single media" assistance as an incomplete service,
since businesses need to address other environmental compliance issues. Many states have addressed the need for multimedia assistance by
developing "one stop" regulatory assistance centers for businesses. In Utah, SBAP established a working relationship with other Divisions to
provide a more effective assistance package to businesses. Small businesses have benefitted from that relationship by receiving assistance
referrals through SBAP to other Divisions in the Department of Environmental Quality.
8
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TABLE G-1
(Continued)
PROGRAM
Vermont
Virginia
Virgin Islands
Washington
Ecology
BCCAA
OAPCA
SCAPCA
SWAPCA
YRCCA
West Virginia
COMPLIANCE ISSUES
N/A
VA's compliance assistance efforts have been primarily directed at the source categories coming under regulation by MACT standards. A
common compliance problem to date has been the difficulty of the foreign national ownership of the dry cleaners to fully grasp what is
necessary for on-going recordkeeping. The most difficult concept continues to be that of the twelve month rolling purchase log. An alliance
with EPA's Office of Compliance Chemical, Commercial Services, and Municipal Division to develop a mentoring program through the Greater
Washington Korean Dry Cleaners Association and to produce a video is ongoing and highlights the problem compliance areas and seeking to
eliminate them and foster continued and complete compliance.
Last year's report addressed the issue of "operating without a permit." This continues to be an issue but, as last year, has only arisen
several times. We continue to feel that "operation without a permit" will be an ongoing issue for VA, especially as we begin to provide
additional permitting assistance outreach for Title V.
The issue of compliance affordability has and will continue to be an issue. Hopefully with the development of a revolving loan program, the
emphasis on this issue will diminish.
None
Lack of understanding of air quality agency jurisdictions. Lack of understanding of environmental liabilities. Lack of understanding of
interaction between regulations for each media (air, water, hazwaste). Hunting for answers from various staff and agencies that provide the
easiest way out. Faulty operating and air quality control equipment.
Building device without minor new source review by government authority. Pervasive throughout all small business except dry cleaners and
rock crushers. Letting air pollution control equipment deteriorate. Annual or once every five years inspections mitigate this. Trying to keep
old equipment running beyond its natural life.
Lack of specific permits, particularly notices of construction. Incomplete reporting of required information.
Recordkeeping. Modifications to facilities. Bringing new sources into registration process and bringing them "up to speed" on requirements.
Air quality controls, control alternatives, etc.
Lack of permits. Ignorance of the regulations.
Sources dislike regulatory authority and permitting fees. Regulatory jargon and complexity. Filling out permit applications.
The most common compliance problem this year has been in lack of state construction/installation permits when required. This may have as
much to do with problems in our permitting rule(s) as it does with the regulated community. There have been considerable deficiencies
meeting the dry cleaning MACT, mostly with monitoring/recordkeeping requirements. SBAP has exerted a tremendous amount of effort to
follow uo with drv cleaners who were identified bv enfc-rcemen^ as havinq deficiencies.
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TABLE G-1
(Continued)
PROGRAM
COMPLIANCE ISSUES
Wisconsin
Cost of new equipment or modifications required by environmental regulations. Concerns about the amount of time required to prepare
applications for required permits or recordkeeping. Fear that regulatory enforcement may be arbitrary or capricious. Difficulty in completing
required mathematical calculations to determine MTE and PTE. Too many regulations. Too much paperwork. "Where can I oo to oet helo?"
Wyoming
Solvent users: Understanding MSDS and MACT standards.
N/A
N/R
Not applicable
No response
10
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TABLE G-2
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
IMPROVEMENTS
More open communication between sources and regulatory agencies
Increased compliance
Greater understanding of the regulations
Reduced apprehension regarding environmental compliance
Improved attitudes about complying with regulations
Increased registration and permitting of existing sources
Improvement in pollution prevention management practices
Greater environmental understanding through on-site visits (versus phone calls or mailings)
Better record keeping
Involvement in regulatory development process
Recycling and reuse
Inclusion of environmental compliance early in business plans
Better hazardous waste disposal
f PROGRAMS
30
20
18
12
12
11
10
10
4
2
1
1
1
% PROGRAMS
57
38
34
23
23
21
19
19
8
4
2
2
2
County/air district responses are included with state responses and are not counted separately.
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TABLE G-2
(Continued)
PROGRAM RESPONSES
Programs were asked for information on the improvements in regulatory understanding and compliance. Individual program responses are listed below.
Comments are edited for space.
PROGRAM
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Alabama
This information has not been tracked by SBAP. From the SBO perspective, it appears that more business people are calling about possible
environmental permit requirements and restrictions prior to making a full commitment to a new business venture.
Alaska
All site visits have shown an improvement in compliance with regulatory requirements. In general, small businesses in Alaska want to ensure
the environment remains clean. However, they are wary of talking to our Department. The main fear is enforcement and having to spend
money they do not have in a short period to fix things.
In general, most businesses are in compliance with the substantive parts of environmental regulations. They usually need assistance with
recordkeeping and reporting requirements, assistance in filling out permit applications, or help with how to properly dispose of waste.
The Compliance Assistance Office has been very well received by businesses and the communities around the State. The CAO offers its
services enforcement-free, and thus creates a relationship of trust with businesses. Site visits focus on environmental benefits and business
improvements, which often result in economic savings for the business. The enforcement-free site visits performed by the CAO provide
businesses with the same level of review that they would get with an enforcement-related inspection. However, the visits are not
overshadowed with fear of violations or enforcement actions and generally result in greater compliance. Additionally, the CAO promotes
pollution prevention rather that end-of-pipe solutions. Where possible, we provide the business with modifications or recommendations,
which result in reductions of pollutants, substitution of materials, and reduces potential for emissions that are regulated.
Arizona
This year will bring a greater effort toward developing some metrics that will provide this type of measurement to determine how compliance
has been affected by SBAP. Probably the biggest change is that now businesses have a place to go when they have a question regarding
compliance.
Maricopa Cty
N/R
Pima Cty
Field Enforcement Officers have noted increased awareness and concern regarding abiding by regulations by the regulated community. Also,
more inquiries about P2 techniques and processes. Finally, permitting staff have noted more complete air quality permit applications being
submitted.
Arkansas
Businesses are very willing to change processes, eliminate wastes, etc. in order to provide a cleaner environment. As a result of our
workshops and audits, businesses are relieved to hear common sense approaches to complying with regulations.
California
Our many publications and their wide distribution have greatly increased the awareness of regulatory requirements and who to contact to get
help. Accordingly, the number of contacts has increased significantly. Our education efforts have resulted in significant improvements in
self-compliance. -
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TABLE G-2
(Continued)
PROGRAM
IMPROVEMENTS IN REGULATORY UNDERSTANDMG AND COMPLIANCE
Kern Cty
APCD
Placer Cty
APCD
They really appreciate being helped by us to comply.
We have noticed that about half responded positively to our attempts to assist. What they seem to appreciate the most is our willingness to
try to convey the regulations and Permit Conditions in "plain English."
Santa
Barbara
APCD
The benefits of our business assistance activities include: a greater understanding/awareness of APCD requirements by regulated sources, a
better working relationship between business and APCD, an understanding that we all are working together toward a common goal, timely
responses to questions from regulated sources and the general public. How our Business Assistance Program helps our regulated sources is
highlighted by work we recently completed with a local autobody shop. The shop's owner was very confused about the APCD's permitting
process and what he needed to do to obtain an APCD permit. He also needed to obtain a building permit from the city to construct his paint
spray booth. We were able to work with the building department and the shop owner to determine what was needed for the building permit
and were able to assist him in completing the necessary APCD permit application forms. This source is now in the permitting process and is
on his way to obtaining an Authority to Construct. Both the autobody shop and the APCD benefit - the autobody shop will soon be able to
begin operating and the APCD knows the source is in compliance. A relationship has been established that should enable both parties to
maintain communication and ensure continued compliance.
SCAQMD
Many dry cleaning operations have switched to dry-to-dry, refrigerated, closed loop systems without a regulatory requirement for this
equipment. We worked through trade associations and suppliers to provide information. AQMD also worked through community banks to
provide equipment financing and provide a guarantee. Also, many companies are switching to aqueous cleaners as a result of P2 contract to
give them such assistance.
Colorado
Awareness of air regulatory requirements has improved. Less confusion in regard to who must apply for permits and how they must operate
under the permits. More involvement by businesses in the formulation and updating of rules and regulations. More willingness of small
businesses to seek assistance with their compliance issues.
Connecticut
More sources are willing to seek regulatory assistance from a regulatory agency. More small businesses are getting involved in the regulatory
development process. We expect to see increases in compliance rates for small business sectors targeted for assistance. We have had
positive feedback that small businesses are less fearful of DEP. Also, more small businesses are availing themselves to P2 solutions at an
earlier stage when P2 can be most effective.
We have seen the relationship between the CT SBAP and representatives of several small business sectors develop and mature to a level
where a meaningful dialog is occurring on a regular basis. This is resulting in a more effective dialogue with a number of small business
sectors such as auto body shops and metal finishers, and the structuring of compliance assistance initiatives that are well designed to meet
environmental goals in an efficient manner.
Delaware
Businesses that have received assistance seem to be less hesitant in asking for help with other issues. After receiving assistance, they
understand that the intent of the program is to provide assistance in meeting environmental regulatory requirements and not in assessing
penalties or in some wav limiting their ability to conduct business.
-------
PROGRAM
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
TABLE G-2
(Continued)
IMPROVEMENTS W REQULATORY UNDERSTANDS AND COMPLIANCE
After SBAP presentation at the Korean Drycleaners Association, 1 received a lot of requests for initial notification forms and letters notifying
us of ownership and equipment change.
Since the general air permits for area sources are new this fiscal year, district personnel are still learning what the regulations are and how to
use them in compliance assistance activities. Staff are not in the position to observe or to measure a trend in behavioral changes and
environmental improvements.
To measure the effectiveness of the dry cleaner workshop, the audience was asked to complete evaluation questionnaires. The workshop's
overall rating was 4.2 (the scale was 1-5 with 5 being the highest). The evaluation sheet also included the question: "How familiar are you
with the dry cleaner air rules before the workshop and after the workshop?" The results from the 46 evaluations turned in were:
'Before the workshop?" Very: 9 Somewhat: 30 Unfamiliar: 7
"After the workshop?" Very: 33 Somewhat: 1 3 Unfamiliar: 0
The success of the workshop was determined by correlating the compliance rate of those that attended the workshops to those that did not.
The eight dry cleaners that attended a workshop prior to the planned compliance assistance visit had a higher rate of compliance compared to
those that did not.
We are also tracking the number of facilities requesting compliance assistance visits to facilities inspected by the Enforcement Program. To
date, we have completed 1 5 compliance assistance visits; however, the dry cleaners audited by the SBAP have not been inspected by the
Enforcement Program after our visits.
N/R
A better trust and improved working relationship with industry has developed. DEQ now is looked at as an agency that will help to solve
problems.
SBAP provides compliance assistance and information to smalt businesses. However, our best example of helping companies reach
compliance status is through a project called "Clean Break." This is an amnesty project for small businesses that IEPA Office of Small
business has sponsored and asked the DCCA SBAP to assist them in marketing and with client intake. Come companies that fear contacting
the regulatory agency for assistance now have an option. Whether a client calls the IEPA Office of Small Business or the DCCA SBAP, they
are encouraged to participate in Clean Break and receive a site visit by IEPA staff to confirm compliance or identify non-compliance issues.
Once into the process, small business receives the support and information they need to reach compliance.
The project is in its third project stage, now being available statewide to all companies with 200 or fewer employees. Governor Edgar
announced this exoansion in January 1997.
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PROGRAM
MPROVEMENTS IN REGULATORY UNDERSTANDS AND COMPUANCE
Indiana
More businesses are in compliance due to increased communication and trust between businesses and CTAP (and also between businesses
and IDEM's Office of Air Management and Office of Solid Waste & Hazardous Waste Management).
Increased compliance due to assistance provided by CTAP and some of the regulatory programs within IDEM. Assistance includes:
workshops, on-site assistance, phone assistance, brochures, manuals, meetings, workgroups, identifying training opportunities or associations
that may be of assistance, etc.
Request for additional compliance assistance workshops.
Request by industry sectors for compliance assistance programs that are specific to their needs.
Increased number of applications have been submitted to IDEM and permits issued to businesses due to increased awareness of the need for
permits and due to the assistance provided by CTAP and IDEM's Office of Air Management.
More businesses are developing and implementing necessary plans and training (spill prevention, haz com, etc.).
Better recordkeeping due to IDEM's working with businesses to simplify the requirements and due to assistance provided to businesses.
Improvements in P2 practices. Many businesses impacted by Title V implemented P2 practices to back out of the program.
Increased recycling and reuse.
Improved attitude regarding IDEM including a willingness to repeatedly call with questions and to encourage neighboring businesses to seek
assistance (some businesses will call CTAP on behalf of other businesses that are fearful of contacting us).
Positive feedback regarding IDEM's customer-oriented approach, including CTAP's offering assistance prior to new rules taking effect.
Iowa
IAEAP continues to have a steady backlog ("300 site visits and 100 permits). Direct mailing has been done to grain facilities, dry cleaners,
manufacturers, auto body shops and received very good response.
On-site visits have been integrated with technical assistance. Clients are provided assistance until they are in compliance or choose to
remain out of compliance.
SBO response: Without a survey or a thorough review of DNR records, it is difficult to know what percentage of the businesses contacted by
the SBO have improved their compliance status. The DNR has a tracking list for construction permits, and it is always satisfying to see a
company you have worked with submit a permit application.
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TABLE G-2
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PROGRAM
IMPROVEMENTS IN REG" IATORY UNDERSTANDING AND COMPLIANCE
Kansas
SBEAP addresses these issues by providing assistance through university staff free of charge and in a confidential and non-threatening
atmosphere. SBEAP staff provide comprehensive assistance in determining applicable environmental requirements as well as specific help
with completing any needed permits and forms. Customers seem genuinely pleased with our service, describing it as beneficial use of
government resources.
Kentucky
The program has resulted in submission of better quality permit applications and regulatory information to the Division for Air Quality. This
has led to a shorter review time, improving the relationship between the Division and small businesses. The information provided to small
businesses by the SBAP staff has increased awareness of the Division's role in environmental regulations. It also has assisted small
businesses in meeting Title V permitting requirements in a timely manner.
Through meetings, presentations, and her monthly column, the SBO is building a good working relationship with state trade associations. The
monthly column is published in 12 state trade association newsletters with a circulation of 15.000.
Jefferson
Cty
Some of the small businesses, especially the body shops, have begun to self-report minor non-compliance issues and solicit help prior to
changes in operations.
Louisiana
We do not track this phenomena; however, replies to our evaluation requests indicate that the businesses we have assisted have a better
attitude toward the environmental regulatory community.
Maine
There is a definite rise in compliance among businesses we have focused on. Until the businesses are notified, many of them do not know
they are subject to a rule or don't fully understand a rule. Once initial contact is made, businesses are more likely to request additional
assistance.
This year, SBTAP discovered 19 sources that were operating without the proper permits. These sources are now licensed or in the licensing
process.
Maryland
Small businesses have obtained necessary state environmental permits, initiated required recordkeeping under the reports and MACT rules,
and have submitted required reports for MACT rules.
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TABLE G-2
(Continued)
PROGRAM
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Massachusetts
The following information is taken from the analysis of MP2 project in which 100 random inspections of printing facilities were conducted (50
pre and 50 post program). Instead of simply categorizing facilities as being "in compliance" or "out of compliance," a list of 19
"environmental business practice indicators (EBPIs) were developed (with yes/no responses requested).
Awareness of Environmental Stewardship Responsibility: 1) Is educational information about environmental printing specifications available
for customers? 2) Has facility tried any new P2 techniques during the last two years?
Chemical Stewardship: 3) Does facility track net financial cost of using hazardous chemicals? 4) Has facility switched to "greener" materials
in the past two years? 5) Does facility have a hazardous waste identification number? Hazardous waste generator status: 6) Does facility
keep weekly log of hazardous waste storage area inspections? 7) Does facility segregate and label hazardous wastes? 8) Does facility have
clear signage over sinks and drains? 9) Does facility have clear signage regarding emergency procedures at telephones in work areas? 10)
Does facility keep containers of VOC-laden materials covered? 11) Does facility recycle paper? Film? Ink? Photoprocessing chemicals?
Photochemical rinsewater? Plates?
Impact on the Environment: (Answer yes if true.) 12) There is no evidence of an imminent environmental threat. 13) Facility does not
discharge any industrial waste to a septic system.
Pre-Press (Impact of Silver): 14) Does facility use photoprocessing equipment? If yes, does facility have a silver recovery unit? If yes, are
maintenance logs kept? Does facility meet MWRA standard of 2 ppm silver? For facility without silver recovery, do you ship
photoprocessing waste off site?
Press (Impact of VOCs on Air): 15) Has facility calculated its VOC emissions? If yes, the annual amount is . Unit: If heat set
lithographer, estimate Ibs. of ink used in 1995: 16) Are shop towels stored in a closed container? 17) Has facility stopped using press
wash containing chlorinated solvents? 18) Does facility use press wash product which has low VOC content, low vapor pressure or is water-
miscible? 19) Is a < 10% isopropyl alcohol or alcohol-free solution used?
Michigan
This fiscal year (1996-1997), the SBAP has begun attaching a survey to its guidance publications to measure the guidance's effectiveness
with SBAP customers. SBAP also intends to measure the effectiveness of SBAP-sponsored training sessions on compliance with a follow-up
survey after the scheduled event.
Minnesota
Many new small companies permitted for the first time. Fewer calls about emissions inventory, coming in without assistance needed to fill
out inventory. People continuing to call for help, but questions becoming much more specific showing a better understanding of the rules and
regulations. Better relationships between industry and government; "assistance" direction getting much praise.
Mississippi
There has been an increased awareness of both targeted sectors in regulatory requirements and P2 practices.
Missouri
We have some anecdotal information in the form of individuals thanking us for the assistance provided. Sometimes this comes in the form of
a "thank you" letter written directly to us or to others in the department with whom they are dealing. Other forms have come verbally from
the individuals telling us how much they appreciated our assistance. Still another form of appreciation is when they refer other businesses to
us.
We currently are working on a method to track these activities. However, we do not have our database structured to include this information
at present.
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TABLE G-2
(Continued)
PROGRAM
Montana
Nebraska
Nevada
Washoe Cty
Clark Cty
NVBAQ
NVBEP
IMPROVEMENTS M REGULATORY UNDERSTANDS AND COMPLIANCE
All dry cleaners in the state have complied with the MACT standard in terms of reporting requirements and pollution control equipment.
All chromium electroplaters in the state have completed notification reports, and the one hard chrome plating business in the state is in a
compliance agreement with SBO/SBAP and EPA Region VIII.
Most of the automobile refinishing shops in the state are now aware of the required changes in coatings and are making the necessary
adjustments to their businesses as a result of an SBO/SBAP sponsored workshop and repeated statewide correspondence.
On-site consultations remain the most effective method for improving understanding and awareness of regulatory requirements.
Correspondence is often ignored and workshops are not always well attended.
SBAP is continuing to provide timely and helpful information. As the business community uses the SBAP more often, more businesses
request assistance. Word of mouth is working very well in Nebraska. There is a steady increase in the number of businesses that are
requesting site visits.
SBAP - This is a relatively new group and has not developed a method for tracking and conducting case analyses. However, we have seen an
increase in the number of phone calls from industry and an increase in the number of referrals from other state and local agencies.
AQMD has not kept any specific tracking records of the number of citizen inquiries and permit violation in regards to each specific industry.
They have made efforts in the form of information being given out to each business owner during their annual inspection. AQMD inspectors,
as they inspect a facility, continually explain the regulations and procedures to the business owners and managers so that they understand
what needs to be done and why. The business owners have a greater understanding and are able to deal with problems as they arise
throughout the year and rectify any problems before their subsequent inspections. In addition, AQMD recently hosted a seminar for the
citizens and businessmen of Washoe County in regard to the presence of asbestos, and the care and procedures needed for its abatement.
Also, AQMD is interested in interacting with business and industry and have had representatives attend various professional and industrial
organizations' meetings. The improvements that they have observed include a greater understanding of the regulations that businesses are
required to abide by and a greater willingness to rectify any problems before a citation is necessary to be issued.
The only area tracked is environmental improvements. "Air quality indicators" include measurements for carbon monoxide and inhalable
paniculate matter. Carbon monoxide levels have been dropping in the Las Vegas Valley. Inhalable participate levels have remained roughly
consistent. Both these developments may be considered remarkable in light of the Valley's long-term continuing growth.
The goal of the compliance section is to reduce the number of violations issued each year. This goal precipitated the semiannual compliance
workshops in 1989. A tracking of this goal has demonstrated moderate success.
Better understanding and awareness was achieved for various industrial sectors, with an emphasis on a seminar given to dry cleaners in
December 1996. Behavioral changes and environmental improvements would be a natural result of the seminar, but have not been tracked
specifically in relation to air quality assistance. BEP conducted a survey of program effectiveness in which 89% of respondents found that
BEP services helped them better understand and comply with environmental regulations. The other 1 1 % left this blank or put "not
aoDlicable." 61 % imolemented P2 measures as a result of BEP assistance.
8
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PROGRAM
New
Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
TABLE G-2
(Continued)
IMPROVEMENTS M REGULATORY UNDERSTANDWG AND COMPLIANCE
Based on the substantial increase in word of mouth referrals, it appears more businesses are actively seeking assistance to see what
regulations may be applicable and if they are in compliance. In addition, businesses that have contact with the SBAP are more willing to work
towards compliance (and in a number of cases, exceed compliance) because they feel they are a partner in the process and not being forced
to comply. The "cooperative compliance" approach seems to work much better than the "command and control" attitude of old.
Trade associations working with members to achieve better compliance, re. permit issues.
A client survey was developed in 1 996, and two of the questions address this. The questions on the survey are: 1 ) Do you now have a
greater interest in improving the environment? 2) Are you now more aware of environmental laws? All 1 3 respondents answered "yes" to
these questions.
Many previously unpermitted businesses in NYS now have permits as a result of SBTCP outreach and compliance assistance. The majority of
callers to the SBAP hotline are seeking regulatory information with regulations, providea they know of their existence and can understand
what they must do to comply. It also reinforces the need for SBTCP, since small businesses are unable to obtain the information and
assistance they need from elsewhere. There is a direct correlation between outreach efforts and the number of businesses that call SBTCP
for assistance. With increased outreach, which has already begun in 1 997, the number of businesses calling SBTCP and DEC to achieve
compliance also has increased.
Improvements have resulted from small businesses learning what is required and how to complete forms. The confidential policy of this
office has encouraged business to ask if they need a permit or what requirements apply. As the businesses find out what is expected of
them, their compliance increases. Recordkeeping is still a great burden for small business. Simplifying the requirements improves
compliance.
It is difficult to assess the environmental improvement or compliance improvement that may have resulted from the assistance the SBAP or
SBO provided. However, any assistance provided surely made it easier for business to comply. With regard to dry cleaners, the state has a
95% success rate in receiving the compliance reports from regulated sources. This success rate can be directly attributed to the SBAP.
Printing Industry of Ohio (PIO) reports a major buyer of printed material in Ohio now is requiring suppliers to follow PIO's ENVIROPRINT
manual for continued business.
Those who have received on-site assistance expressed sincere appreciation for our efforts and report feeling more at ease when dealing with
OEPA. This has been demonstrated through additional calls to SBAP referred contacts and from several trade organizations voluntarily
promoting SBAP and SBO services.
We have not really tracked such issues, but we believe that the culture is changing within our own Agency to address increasing
environmental comoliance throuah more common sense accroaches to environmental reaulation.
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TABLE G-2
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PROGRAM
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
IMPROVEMENTS IN REGULATORY UNDERSTANOMG AND COMPLIANCE
There is a growing awareness of cost associated with unpermitted pollutant discharges, hazardous waste disposal, and liabilities resulting
from accidental releases in many small business sectors. During this reporting period, eleven dry cleaners have either installed new dry-to-dry
or aqueous cleaning machines and are eligible for P2 tax rebates. One dry cleaner replaced a perchloroethylene transfer machine with a new
high flash point petroleum cleaning solvent machine, reducing perc usage by approximately 750 gallons per year. An electronic equipment
manufacturer and wholesale fixture business installed aqueous cleaning machines. Conversion to aqueous cleaning enabled these companies
to avoid Title V air permits and Toxic Release Inventory reporting. Powder coating technologies are becoming more popular to comply with
MACT, GACT, and worker safety regulations. There was a 32% increase in general technical requests in 1 996.
N/R
Even though businesses still don't like dealing with environmental matters, once they get to know our main purpose, they usually keep in
touch with us for an update on requirements and suggestions. Very important is the fact that the businesses feel more at ease if they are
treated very nicely.
Overall outreach, communication, and availability of SBO and technical assistance outreach services continue to have a positive impact on
behavior and environmental compliance.
Reduced fear of small businesses in asking questions on regulatory requirements and compliance issues. This leads to increased compliance
and identification of sources.
The department's technical assistance activities have helped small businesses understand and comply with the new federal requirements.
Program assistance has resulted in 75% regulatory response compliance rate for new MACT standard impacted companies. Program
evaluations indicate that workshop participants gained a greater understanding of the regulations. Businesses have expressed interest in
ensuring compliance in all areas of their business that may impact the environment.
Wood Products Industry: In 1 996, 1 ,780 businesses in the wood products industry were contacted by SBAP as part of an industry-specific
outreach to promote compliance. These outreach efforts allow enforcement divisions of the agency to focus their resources on other
industries maximizing environmental protection. As a result of this outreach, the number of wood products manufacturers calling on the
hotline for assistance rose from less than 50 in 1995 to 388 in 1996.
There was a 73% increase in the proper handling of ^on-hazardous waste, a 1% increase in conducting hazardous waste determinations, a
43% increase in waste related recordkeeping, a 77% increase in transporting of hazardous wastes off site within required time limits, and a
52% increase in disposal of hazardous waste at an approved facility.
Auto Body Industry: During a 14 month period beginning in 1995, SBAP conducted site visits for the auto body industry. The average initial
compliance rate was 72%. After initial assessments, SBAP made follow up visits to measure compliance. The average compliance rate had
improved to 88%. In addition, SBAP site visits saved each auto body shop an average of $1,200 through reduced costs for materials,
consult! no fees, and avoided penalties.
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TABLE G-2
(Continued)
PROGRAM
Utah
Vermont
Virginia
Virgin Islands
Washington
Ecology
BCCAA
OAPCA
IMPROVEMENTS IN REGULATORY UNDERSTANDING AND COMPLIANCE
Participation in Industry Workshops/Seminars: SBAP presented information on air quality issues, regulations, and SBAP services at various
industry workshops, seminars, and meetings. As a result of this outreach effort, we have received requests for assistance from industry
attendees after the outreach activity. These assistance requests varied considerably, from MACT compliance assistance to permitting
assistance. During the early years of SBAP, considerable staff time was devoted to the development of environmental conferences and
workshops. The majority of these workshops and conferences were poorly attended. During this reporting period, SBAP focused on
identifying other in-roads for reaching small businesses.
On-site Assistance: Small businesses are generally more receptive to on-site visits when it is recommended by a peer. A special targeted
industry campaign with the printing industry during fall 1 995 has continued to encourage industry requests and inquiries statewide. On-site
visits appear to be valuable in providing information in a comfortable setting and therefore, education seems to be longer lasting.
N/A
There is a strong relationship of compliance assistance activity to the awareness and acceptance by the existing regulated or newly regulated
community. We saw with the dry cleaners in 1994 that their acceptance of responsibility to comply with regulations was a direct result of
their understanding of the requirements, the costs of compliance, the benefits of compliance, and that there was a willing party (SBAP) to
provide information and assistance outside a perceived hostile environment. As indicated in last year's report, the initial results of the June
1 8, 1 994 deadline for initial notification reports was met by 73% of Virginia dry cleaners. Continued cooperation between the state and
interested trade associations ensured continuing wide coverage of compliance assistance activities, consistency of information, and follow
up. As reported last year, SBAP provided 7 initial compliance workshops, which followed in September 1 996 with another 6 final compliance
workshops. Notification report compliance in Virginia reached approximated 84% in October 1 996.
We are finding that a large part of the success of any outreach assistance is a continued interest in and delivery of a non-regulatory
assistance message to the affected source population. This includes concise understandable materials, a recognition of the minimal available
time for a source to participate in outside activities beyond his daily business, and the provision of options for compliance. All these are
critical to the success of a compliance assistance effort. Results of compliance assistance activity will not necessarily yield verifiable results
immediately. Compliance assistance activity should be viewed as a system, a support system, that will yield incremental results arriving at
full compliance.
N/R
Improved compliance across all media by dry cleaners and improved cooperation between Ecology and the state dry cleaners trade
association.
Dry cleaners will call us before they operate a new perc dry cleaning machine. Rock crushing plants call us to get a permit before they start a
new job.
Better understanding of the agency's mission by the regulated community and how the agency can provide technical assistance through
SBAP. More industries and sources willing to call the agency for assistance instead of avoiding contact with the agency until detected or
comolaints lead the aaencv to the source. Less freauent oleas of ianorance on the cart of the sources.
11
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TABLE 6-2
(Continued)
PROGRAM
SCAPCA
SWAPCA
YRCCA
West Virginia
IMPROVEMENT* IN REGULATORY imDERSTANDMQ AND COMPUANCE
Use of lower pollutant emitting materials, specifically lower VOC content and toxicity (e.g., converting from MEK to a less toxic solvent).
Increased use of SCAPCA personnel as a resource for business assistance information rather than as an enforcer.
In general, our customers want to comply with as minimal an effort as possible. Our assistance expedites that compliance and allows them
to get back to their primary business activity. Our program also works with the agency to improve maintenance plan compliance and to
develop other customer friendly outreach programs and projects to assist the regulated community, including dry cleaners and paint
distributors this year.
Better understanding of why regulations are needed. Improved attitude from sources toward the agency. Less reluctance to ask the agency
questions. More cooperative approach with respect to incorporating changes. Willingness to apprise when compliance by others is not being
met.
Improved awareness by small businesses results from almost every contact (i.e., phone, brochure, on-site audit, etc.). Also teleconferences,
training, and all outreach activities result in improved awareness of the environmental responsibility by small businesses. For example, all dry
cleaners in WV have been contacted at least once and many three times. All are aware of the changes in operation and equipment required,
and the majority are now in compliance.
Chrome plating facilities subject to MACT standards have reached a high rate of awareness due to outreach and workshops from the SBAP.
Follow UD calls/visits indicate that the orooram has been effective in educatino and encouraoino Dialers to comolv with the new standard.
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TABLE G-2
(Continued)
PROGRAM
tMPROVEMENTS IN REGULATORY UNDERSTANDS AND COMPLIANCE
Wisconsin
In 1996, we saw an increase in the number of calls for assistance. Small businesses are better informed by our program because our efforts
are reaching them and our materials and presentations are clear and understandable. Some of our clients have made changes to their
facilities based on guidance provided by our program. When we asked our clients if they had been able to reduce their air emissions as the
result of the assistance provided by the SBCAAP, we received the following comments.
"We have invested in the latest type of equipment to comply with all controls." Burlington Cleaners
"We now use HVLP spray equipment to reduce overspray and use low VOC products." Osseo Ford Sales & Service
"Now we cover our plating baths when not in use." Badger Labs
"I purchased a new dry to dry cleaning machine." Donaldson's One-Hour Cleaner
"We now do a better job of monitoring during hours of operation, run limits operations on some days, and encourage carpooling and public
transportation." Kitzinger Cooperage Corporation
Due to our outreach efforts, 87 out of the 130 rock crushers not in compliance due to not submitting a general operating permit application
came into compliance or notified the DNR that they are not affected by permitting requirements. As a result of our dry cleaning outreach and
workshops, 12 out of 21 facilities with old transfer machines or ineffective dry to dry machines upgraded their equipment.
The level of knowledge and understanding by our business clients appear to be increasing. We anticipate further success and we continue to
target and penetrate unreached business sectors. In a recent survey of our customers, 82% felt their understanding of air regulations
increased because of our program and they would recommend our services to others. 46% of our customers have been able to reduce their
air emissions as the result of receiving assistance from SBAP.
Wyoming
Measurable improvements in compliance are very difficult to determine without a MACT standard small business inspection and compliance
program. Intuitively, over the last year, small businesses have shown a slight increase in discussing problems with SBAP. The trust
necessary for improving this communication link needs to be expanded greatly to increase the effectiveness of assisting small businesses
with compliance issues.
N/A
N/R
Not applicable
No response
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TABLE G-3
RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA
PROGRAM
RECOMMENDATION
Institute Multimedia Pollution Control Efforts
Arizona
Placer Cty, CA
SCAQMD, CA
Iowa
Massachusetts
Minnesota
New Hampshire
North Carolina
North Dakota
South Carolina
Utah
Consolidate all reporting requirements from all environmental programs for each industry. Regulate facility by industry
sector, not by media (one stop shopping for all environmental government concerns). Stop revising individual Acts
(i.e., CAA, CWA, SDWA, etc.) and regulate businesses by industry sector.
Separate air and waste issues in the minds of the small business. Explain graphically why small businesses need to
have permits and pay $400-500 for the permit when they will not be doing anything different before and after
permitting. Allow "streamlining" where appropriate, possibly combining air and waste issues in one operating permit,
one annual inspection, etc.
Coordinate regulations so that they are prioritized nationally and allow a set of air, water, solid and hazardous waste
regulations (that impact one industry) to be issued within the same time frame.
SBO response: Federal legislation needs to be passed that will broaden the role of the SBO to encompass all forms of
pollution.
Make all compliance assistance programs multimedia by definition. Creation of the artificial (single media) distinction
doesn't work well for small businesses and doesn't improve implementation for the agency.
EPA needs to start thinking more in terms of multimedia/P2 sector and/or process rules and regulations.
Continue efforts to have SBAPs fully multimedia.
Continue the effort to make environmental information and assistance multimedia. Small businesses expect
environmental assistance to help with all regulations affecting them. They find it difficult to understand why they
need to deal with 4 or 5 different agencies.
Allow SBTCPs to use their funding in multimedia pollution control assistance and not restrict use of funding to solely
air pollution control assistance.
Make outreach and assistance by SBAPs multimedia.
Multimedia Support and Coordination: Many small businesses that seek SBTCP assistance request cross-media
support and assistance. SBAP receives numerous requests from small businesses to establish a "one stop" regulatory
assistance center.
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TABLE G-3
(Continued)
PROGRAM
Virginia
West Virginia
Wisconsin
Wyoming
RECOMMENDATION
Expansion of programs into multimedia with appropriate funding provided by EPA for other media (water/waste).
SBO's duties should also be expanded to include all DEP Offices (multimedia) and that adequate staffing be provided.
SBTCPs should have multimedia authority, not just for the CAA, but for CWA, RCRA, and CERCLA as well.
The CAP believes that the SBAP will be more effective in the multimedia arena and not limited to air quality only.
Increase / Ensure Adequate Funding for All Small Business Assistance Programs
Alaska
Arizona
Colorado
Indiana
Iowa
Michigan
More federal money to support state SBTCPs. Also, more federal funds or grants for small businesses to be able to
hire consultants for complicated issues and for equipment upgrades required by MACTs.
Mandate with appropriate funding true multimedia compliance assistance programs.
Provide more financial and information resources to SBO/SBAPs.
Increased funding/continued adequate funding. As the word spreads through the regulated community, CTAP has
received more and more requests for compliance assistance. There are a number of projects that CTAP could be
taking on if we had additional personnel.
Ensure adequate funding for SBAPs. Support efforts by SBAPs to expand and improve the technical assistance they
provide. Eliminate national compliance assistance centers and funnel the funding to state programs.
Provide more money to state SBTCPs to develop and utilize innovative ways for distribution of 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 would allow an SBTCP to work with federal and state
government as well as business, industry, and statewide educational institutions to coordinate and package
environmental compliance and pollution prevention information that is specific to industry sectors. The information
would be introduced to students at the secondary or post-secondary level so that by the time the student enters the
workforce, he/she will brina timely, relevant and useful knowledae/experience to specific industry or business.
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TABLE G-3
(Continued)
PROGRAM
Montana
New Hampshire
New Jersey
Ohio
Oregon
Tennessee
Virgin Islands
Wyoming
RECOMMENDATION
Redirect compliance assistance center resources to EPA regions to provide direct, hands-on training to SBO/SBAP
personnel. The training should be held in actual small business locations so personnel can learn first hand the
processes they're trying to improve. Redirect same resources to the state SBO/SBAPs to enable them to provide more
on-site assistance.
Maintain and expand core funding for SBAP activities. Competitive grants should be drastically reduced or eliminated.
The SBAPs work extremely well together and share material, research and expertise without wasting time chasing
funding. EPA needs to give us the authority, responsibility, and trust to fulfill our obligations under the CAAA with
proper funding.
EPA should provide funding to states when needed. EPA should set up regional meetings, conferences, etc. to help
states that have travel problems.
US EPA needs to devote more resources to US Small Business Ombudsman program and other mechanisms to support
state level efforts.
The greatest obstacle to meeting all the regulatory requirements of the CAA is the lack of resources. Many SBAPs are
functioning at 1 FTE. Training, financial, and support assistance are in great demand.
Federal financial support for each state to attend national meetings would go a long way to ensure attendance during
budget crunch times.
More training for coordinator and staff.
Adequate funding and resources need to be allocated to establish a multimedia SBAP that can provide a broader
technical and compliance assistance program.
Utilize the Internet and Other Electronic Resources for Information Exchange
Arizona
California
Make all environmental reporting and recordkeeping electronic with one environmental form due annually. Then let
the multitude of agencies all have access to the information and pull from it what they need, rather than businesses
having to send ten different forms to eight different governmental agencies. This includes the multitude of emergency
response plan requirements that currently exist.
Provide free downlink locations for participating in training.
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TABLE G-3
(Continued)
PROGRAM
Montana
Nevada
Oregon
Rhode Island
RECOMMENDATION
Stop giving money to UTC to produce video teleconferences that are 3 hours long and consist of talking regulators.
Montana's small business owners have neither the time nor the interest to participate in lengthy teleconferences in the
middle of their days. Moreover, they have no interest in listening to bureaucrats talk about the regulations. Instead,
make short (1/2 hour) videos on compliance with actual case studies for distribution by SBO/SBAPs.
Better dissemination of information, maybe electronic in form, would be helpful. There should be a program where the
specific goal of disseminating information should be to augment the services of the providers of information, be it
SBAP, SBDC, or regulatory agencies.
Training - Offer 1 to 2 hour teleconferences on all upcoming NESHAPs affecting small businesses. 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.
Utilize electronic media wherever possible. MACT teleconferences are valuable and should continue.
Expand National Advertising to Increase Program Exposure
Alaska
Maricopa Cty, AZ
Illinois
Iowa
Jeff. Cty, KY
In general, need more white hat help on both the state and federal level to locate and educate the small businesses on
what is required of them.
1 would think we need a national PSA campaign highlighting why business needs to comply and how SBAP can help
them.
Increase outreach to let businesses know we exist.
EPA needs to expand its national media efforts/campaign.
Very small business owners do not see themselves as part of the "regulated community." They see themselves as
"citizenry" who are self-employed or who own a small shop. They may not take the time to be involved in a trade
association or read industry trade journals. Therefore, the best way to reach them to inform them of their obligations
regarding air pollution is to reach them as citizens. The CAA regulations and standards need to be more visible to the
common man and given a higher profile. Use TV ads, billboards, radio spots, etc. to raise the consciousness of air
pollution and what it means to the ordinary man.
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PROGRAM
New Hampshire
South Carolina
Utah
RECOMMENDATION
Ensure SBAPs are the primary contact for environmental compliance and assistance. There is no substitute for the
professional knowledge possessed by the SBAPs for environmental issues.
Publicize available assistance on national level.
Publicity: National Public Service Announcements and a toll-free national hotline would be beneficial in promoting
SBAP/SBO services. Small businesses could then be referred to states for local support and technical assistance.
Provide / Facilitate Acquisition of Generic Outreach and Training Materials
New York
Ohio
Pennsylvania
Rhode Island
Utah
Washington
Formalize technical and compliance information outreach to environmental consultants. One third of calls to SBAP
hotline come from attorneys/consultants; 18% for SBO. Frequently, the consultant has already called the state
regulatory agency for information and was referred to SBAP. Providing information to consultants eventually helps the
small businesses, but it is not part of SBTCP's mandate and can take time away from direct contact between SBAP
and small businesses. All states should be required to implement a program to train consultants to keep them
informed of regulatory changes. If informing consultants is to be a part of SBTCP's responsibilities, let that
responsibility be formalized and defined so that SBTCPs can take a proactive approach in providing outreach to
consultants.
The US EPA-developed brochures for the chrome plating and solvent degreasing MACT standards have been helpful.
Improved outreach for awareness of new regulations such as the MACT for degreasers. 1 don't know how.
All federal materials should include one-page, simple-to-read factsheets.
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.
BCCAA: Train regular state and local inspectors to provide technical assistance. Let them wear both the hats of
compliance and technical assistance. Reduce federal and state level SBAPs to coordinate functions.
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PROGRAM
RECOMMENDATION
Establish Mechanisms to Finance Environmental Compliance Equipment
Arkansas
SCAQMD, CA
Michigan
Minnesota
Montana
New York
Oregon
South Carolina
Texas
Grants/loans made more available to pick up where compliance issues drop off.
Provide tax or other incentives for manufacturers of coatings and resins to develop new products that exceed most
stringent current regulations. Small businesses in CA, for example, depend on formulations and chemistry developed
elsewhere. We have stringent regulations, yet represent a small part of the total market.
Provide grants or low interest loans (under the administration of SBTCPs only) for small- and medium-sized businesses
for access to design engineers for modification of current facility processes and control equipment to reduce air
emissions.
Need more incentives for small businesses to make costly improvements including financial assistance programs, tax
exemptions, etc.
Make more resources available for small business finance programs and research projects on new equipment.
Improve small business' access to funding to purchase equipment necessary to achieve compliance. Presently, small
businesses have difficulty obtaining financing for environmental compliance projects and appear to be unable to obtain
loans from the Small Business Administration (SBA) if they are out of compliance with regulations. Government
support could include capitalizing state or federal revolving loan programs, establishing matching grant programs, or
enhancing SBA's ability to provide grants/loans to small businesses in order to come into compliance. Small
businesses who cannot purchase equipment with their own, usually limited, funds and who are unable to obtain
loans/grants will either continue to operate out of compliance with CAA, shut down, or relocate.
Financial - Develop a national policy that allows small businesses to invest in P2 technologies in lieu of air permits.
Institute a revolving fund to finance small business technology conversions. Fund small business R&D projects with
emphasis on P2. Increase grant funding to SBAPs.
Federal financing available by revolving loan or grant program for compliance requirements.
Work with lending institutions to provide funds for environmental compliance. Use good science and realistic facts as
the basis for regulations and share copies of studies. Focus on results (i.e., improved environment), not equipment.
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PROGRAM
Utah
Virginia
Washington
West Virginia
RECOMMENDATION
Financial Assistance for Compliance: Although the establishment of SBTCPs provides technical support to small
businesses, many small businesses continue to lack the financial resources for pollution control equipment to P2
methods. The creation of financial compliance assistance, such as low interest revolving loan programs, would
greatly enhance CAA compliance and SBTCP services.
Provision of revolving loan fund seed money by SBA for small business compliance activities.
SWAPCA: Pollution control financing assistance and off-the-shelf control technology solutions for common business
scenarios.
The proposed state "Revolving Low Interest Small Business Environmental Loan Program" should be given priority.
The costs of compliance and/or the costs of pollution prevention are disproportional for small businesses, because the
majority of the emission requirements are not related to an economy of control scale. It is recommended that new
regulations be drafted or redrafted where necessary, to truly consider the compliance problems faced by small
businesses, taking into consideration realistic and practical environmental requirements. Also, for each regulation,
practical de minimi's levels should be established, below which, permits would not be required. Despite the Section
507 enforcement policy, SBREFA, et al., typical EPA enforcement actions for dry cleaning violations seems to be
about $10,000. This is excessive considering the capital cost of a common dry-to-dry machine at about $50,000.
Expand / Facilitate Effective Communication Between State and Federal Agencies
California
Colorado
Florida
Iowa
Compile a user-friendly report that contains the best state programs among the 50 states and support adaptation of
appropriate aspects by states.
Encourage better communication between EPA and state and local programs.
Expand and experiment with various outreach activities. Create a two-way network with state field inspectors who
are doing compliance assistance activities. Information gathered by field inspectors can provide a measure on the
effectiveness of the outreach, forecast deficiencies and help in planning future activities.
Expand communication between state and federal agencies to address environmental issues from a small business
perspective. Facilitate/encourage networking of assistance providers (e.g., ensure involvement of SBAPs in the Small
Business Regulatory Assistance Act under consideration in Congress).
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PROGRAM
Minnesota
Nevada
New Hampshire
New Jersey
Oregon
South Dakota
Tennessee
Washington
Washington
RECOMMENDATION
As the MPCA and SBAP work to create innovative programs with positive environmental outcomes, need EPA to be
more flexible in allowing these to happen.
SBAP - There needs to be a better organization of federal information. The amount of paperwork coming into the
office is overwhelming.
EPA (through federal and regional SBOs) needs to continue to provide a coordinating role for increased
communications. EPA Region 1 has been very helpful in interstate communications, which has been an asset in
avoiding duplication of effort.
EPA should pass information (i.e., MACT standards) much faster to states.
SBAP Support Policies - Develop an easy-to-use national technical assistance tracking and reporting database.
Develop a national small business mentoring program. Develop a national cross-media P2 green sticker recognition
program. Develop a simple version of ISO 1 4000 for small business.
EPA should step up their efforts in helping states identify sources or categories of sources that will be affected by
maximum achievable control technology standards.
Greater support and involvement at EPA regional offices are needed for program activities.
Ecology: Stop writing guidance from the federal level that is intended for sources. Federal regulations usually are
substantially rewritten before implementation at state and local levels. The federal outreach materials serve only to
confuse the sources. Instead, provide substantive outreach to the state and local agencies, allowing them to design
outreach materials that best fit the needs of the sources directly under their jurisdiction.
OAPCA: Informed County and City Agencies: Often times a small business obtains all the necessary building permits
and receives an MDNS or DNS without even contacting the local air authority. Local building departments need to
recognize that rock crushers, spray booths, boat yards, and other types of new small businesses may need approval
by the local air authority prior to starting construction. OAPCA has an outreach program for educating local building,
planning, and environmental departments, which has greatly improved the situation in OAPCA's jurisdiction. It
appears there may be a need for more work in this area.
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(Continued)
PROGRAM
Alabama
Alaska
Arkansas
California
Placer Cty, CA
SCAQMD, CA
RECOMMENDATION
Allow Flexibility in Rules Applying to Small Business
Finalize and adopt the interim transition policy that excludes industries whose actual emissions are less than 50% of
major source thresholds from obtaining unnecessary synthetic minor operating permits. Experience in Alabama has
shown that as many as 75% of specific categories of industries would be able to avoid the permitting process and
that their existing records can demonstrate compliance with being classified as a minor source.
Need to eliminate any type of rolling totals or averages. If tracking is required, should be based on calendar month or
calendar year.
On a state level, the hourly fee that is charged to permitted facilities will cost small businesses more than if they were
to pay solely an emission fee as EPA would do if they ran the program. On the state level, need to have a set fee or
flat emission fee for small businesses so that they know what the cost will be.
On a state and federal level, need to have some type of incentive to reduce emissions. The federal rule of "once in,
always in" is almost a disincentive to reduce emissions. The rules should allow businesses to reduce emissions and
thus reduce regulatory requirements.
Need to allow for exemptions from SIP requirements, certain NSPS requirements, and MACT requirements. An
example is an opacity standard, which is very expensive for a small business to install opacity monitors or become a
certified Method 9 visual reader. Should allow small businesses to be exempt or have a very easy way to determine
compliance as is required by Title V. For opacity, it could be if the stack is "smoking" heavily or not.
Instead of creating more regulations, concentrate on solutions for existing regulations.
Explore ways under Title V implementation to minimize burdens on small businesses.
Recommend simplifying regulations and making them conform nationwide for industries such as dry cleaners, auto
refinishers, etc.
Reduce recordkeeoina reauirements -- use purchase records or purchase and inventory records for small sources.
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PROGRAM
Connecticut
Delaware
Indiana
Kentucky
Louisiana
RECOMMENDATION
Simplify and Consolidate Federal Requirements: The complexity of some of the federal MACT standards and CTGs will
prove to be incomprehensible to most small businesses. In this area in particular, there are so many requirements that
apply on top of other existing federal and state requirements, it will be virtually impossible for small businesses to
comply with all of them.
Somehow, regulators who write regulations MUST become more aware of the ability of those being regulated to grasp
the intent and purpose of regulations. Those being regulated need to have environmental regulations, at both the
federal and state level, written in a manner that are easily interpreted and understood. They need to know that when
they take time away from their business to do what is necessary to be in compliance, the time they spend will not end
in frustration from trying to get at the WHO, WHAT, WHERE, and WHY of environmental regulatory compliance.
Compliance is required by law; however, that should not mean that regulators are not in tune with how to make
compliance as simple as possible. Just because it is the law should not mean that regulators and agencies fail to
"market" environmental regulatory compliance and relate compliance as a benefit to be derived by large and small
businesses alike. The IRS, EPA, and DNREC are all held in the same regard among the vast majority of businesses
because of a lack of common sense and practical methods of environmental regulatory compliance.
Re-think how and why we regulate small sources. If the actions required and the dollars invested by a small business
in order to be in compliance cannot be directly linked to improvements in the air, water, or land, then do not ask them
to spend the time or money. Make regulatory compliance meaningful, especially to small businesses. The large
majority of businesses 1 come into contact with want to do the right thing when it comes to the environment, but
when compliance amounts to nothing more than filling out another pile of meaningless paperwork, cooperation from
small businesses is justifiably hard to come by.
Flexibility in applying regulations to small businesses.
Federal program stability. Procedures that allow states flexibility to use non-traditional methods of bringing small
businesses into compliance. Recognition that concepts like "potential to emit" may require modification when applied
to categories of small businesses. Awareness that a detailed paperwork system to prove that a permit is not
necessary is inefficient.
Find a simpler, more understandable method of regulating small businesses. We have essentially downscaled
regulations for major sources and applied them to small businesses. It is cumbersome, complicated, and ineffective.
We should take a whole new look at how we regulate small business.
10
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PROGRAM
Maryland
Minnesota
NVBEP
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
RECOMMENDATION
Change MACT standards to make recordkeeping easier and eliminate most reporting requirements.
Need to realize that "one size fits all" rules do not work well - small businesses operate under very different
circumstances than large businesses - need to really look at more size exemptions and "insignificant activities." More
outreach and education to sectors can and do get more environmental benefits than complex rules and permitting.
It would make more business sense to use the SBDC in each state more efficiently so that information provided to
businesses could be perceived by that business as being confidential. During regulation development, it would be
good to make information that is more "business friendly" available to SBDC and SBAP. This would help in reaching
more affected businesses and create an avenue for dialogue between regulators and businesses.
Continue to work on changing the definition of "potential to emit" to reflect a reasonable estimate of "actual potential
emissions."
Modify EPA enforcement policy ("once in, always in") to allow major sources to voluntarily reduce emissions below
major thresholds to become small "non-major' sources. Simplify requirements and reduce the paperwork. It is still
difficult for a small business to be certain all applicable record requirements are met.
Allow states flexibility in administering rules and policy they adopt that are intended to assist small business (e.g.,
different versions of amnesty that result in compliance).
More MACT standards need to include small business applicability or exemption criteria. For example, the wood
finishing MACT included "exemption levels," which were based on material usages, not emissions. This approach is
much easier for both companies and regulators to understand and work with. Many times, SBAPs focus on how small
businesses can avoid permitting and reporting requirements (i.e., CDSQGs, FESOPs, permit-by-rule exemptions) and
some SBAPs have taken the lead to develop new exemptions for their state. These kinds of efforts must be supported
by US EPA. It is usually difficult for states to get these types of exemptions approved in a SIP.
Continue to allow states an increasing amount of flexibility to design and implement their own minor source permitting
program. This helps us as we continually seek ways to help the small business community through the design of
comprehensive and philosophically sound approaches to air quality regulation.
Regulatory - Reward P2 by abolishing the "once in, always in" policy. Adopt realistic potential to emit criteria for
small businesses.
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(Continued)
PROGRAM
South Carolina
Utah
Washington
West Virginia
Wisconsin
RECOMMENDATION
Increase standard exemptions for small sources. Redefine potential to emit for small sources to actual emissions.
Exemption from Title V Permitting Requirements for Area Sources: Upcoming Title V permitting requirements will
create an additional layer of paperwork requirements for area sources without significant environmental benefits. Any
necessary monitoring, emission standards, and recordkeeping requirements can be administered effectively through
state New Source Review programs. At this time, areas have been temporarily deferred from the permitting
requirements.
OAPCA: New Source Review (NSR) Reform: Many small businesses are still large enough to be classified as "minor
sources." New minor sources are subject to minor new source review under WAC 1 73 "00-1 10 and are required to
obtain approval of a Notice of Construction application prior to commencing construction of the facility. This presents
a problem for new small businesses since the state new source review requirements under WAC 173 "00 are so
complicated. I believe that Ecology's current efforts to "reform" Washington's NSR regulations will go a long way
toward helping small businesses. In particular, we believe the following NSR changes would simplify minor NSR and
shorten the time for a small business to gain NOC approval: 1) Clear exemption thresholds defined in the regulations
for determining which sources are exempt from having to go through the NOC process. 2) Predetermined BACT for
certain source categories or a state BACT clearinghouse for area sources to take the mystery out of BACT in the
permitting process. 3) Statewide uniform Approval Orders and O&M plans for certain area sources.
Small businesses need increased assistance in the "permit process" and/or the permit process for small businesses
needs to be greatly simplified. SBAP should be expanded to provide assistance to more small businesses, to include
placing SBAP representatives in the regional offices in the state of WV. In addition simple yet enforceable, "General
Best Management Practice Agreements" should be explored for small sources in lieu of complicated permits where
possible.
Eliminate motor vehicle refinishing RACT pre-cleaning and equipment requirements upon implementation of national
rule in 1997.
Avoid Duplication of Effort in Compliance Assistance Activities
Connecticut
Coordination of Technical Assistance Providers: The coordination of technical assistance should be a priority on the
federal level. Isolated grar ts through EPA, SBA, NIST, and DOC have resulted in the proliferation of state technical
assistance providers. In some cases, this has increased confusion for small businesses and has led to redundant
functions for TAPs.
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(Continued)
PROGRAM
District of
Columbia
Georgia
Illinois
North Dakota
Wisconsin
RECOMMENDATION
To use trade associations for information dissemination. The small businesses trust their associations more than they
trust government representatives.
We would eliminate the duplication of services assigned to the various agencies to assist small businesses with
environmental issues.
Continue to develop partnerships with other small business assistance providers.
Ensure that the proposed federal compliance assistance centers do not duplicate the efforts of the state SBTCPs,
which would be a waste of tax payer money. If the centers are established, one role of the centers that may be
helpful to the states would be to serve as a clearinghouse for documents. Any federal compliance assistance centers
established need to keep the state SBTCPs informed of their capabilities and materials upon which SBTCPs can
capitalize. Small businesses are more likely to request state and local assistance before federal assistance.
Ensure that federal programs do not duplicate efforts at state level.
Promote Compliance Assistance Versus Enforcement
Maricopa Cty, AZ
Connecticut
Illinois
Iowa
A federal program could be created that offers small businesses an opportunity to fill out an EPA Compliance Incentive
Form. Businesses can use the EPA Compliance Voucher for a limited specified time as a resource for compliance
incentive. This should increase the level of trust between EPA, state environmental departments, and small
businesses.
Enforcement: States and small businesses need support in the area of compliance assurance and measuring
compliance. EPA Regional Offices (Enforcement and the Regional Counsels) need to look broadly at compliance
measures and avoid narrowly defined measures to evaluate state enforcement programs. State SBAPs have
implemented many innovative programs that have enhanced compliance. Measures should be based on a variety of
indicators that are much broader than number of referrals, amount of penalty, etc. These measures could include
emission reductions, permit requirements avoided, and P2 measures implemented.
Continue to focus on compliance assistance instead of enforcement.
Compliance assistance centers have the potential to become an important resource tool to SBAPs. Resource would be
better utilized bv funding/strengthen! na existing centers instead of establishing new ones.
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(Continued)
PROGRAM
Massachusetts
Minnesota
New Hampshire
Ohio
Puerto Rico
RECOMMENDATION
Demonstration of good faith. Currently, listing a facility as being "in compliance* or "out of compliance" is not as
indicative of environmental protection as one might think. We should establish a multimedia set of "weighted"
Environmental Business Practice Indicators for small business that actually reflect the most important environmental
protection issues. A facility that demonstrated compliance with the weighted indicators (let's call them the 10
Commandments of Environmental Business Practice) would be making a "good faith" demonstration of attempt to
comply with all laws. This would be implemented in conjunction with OECA's Compliance Incentive schemes, but
replace the much more cumbersome criteria they apply for a business to be granted a penalty waiver for less serious
issues of non-compliance.
EPA must support SBAP and other programs that wish to get people in the system and do the right thing from that
day forward and not punish them for past history of administrative violations (i.e., enforcement waiver for wood
finishing initiative).
EPA needs to keep a good balance between compliance assistance and enforcement with assistance efforts offered
first. Enforcement should be utilized only after assistance is rebuked or the violation is willful, knowing, and serious.
US EPA needs to continue to improve coordination with state programs in the development, announcement, and
implementation of new assistance initiatives. There is a very clear impression in the small business community that
US EPA is backing away from any commitment to emphasizing the "carrot" rather than the "stick," and accordingly,
business has a renewed interest in staying invisible and not worrying about compliance until caught. This view is
based on the realistic opinion that most small businesses will never see an inspector.
Keep on working with the enforcement people and the people who make the laws so that compliance will be more
effective and reasonable for small businesses.
Develop Plain Language Materials
Pima Cty, AZ
Arkansas
Illinois
More information in the regulations up front about why there are 1 89 HAPs and 6 NAAQS pollutants. Information on
health effects and impact on local economies would bring regulations into perspective for the regulated community.
Publish regulations that are easy to understand.
More understandable information (plain enolish guides).
14
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(Continued)
PROGRAM
Texas
Virginia
Washington
Washington
RECOMMENDATION
Writ* Federal Register notices in plain language. Develop short summary brochures for complicated regulations (i.e.,
chrome NESHAP brochure). Rod and agree on one term to describe something rather than using two or three. Notify
businesses about applicable rules through other sources in addition to the Federal Register.
Continue emphasis and increase activity on the part of EPA in reaching full program integration with all rulemakings.
Lay understandability should be an indispensable hallmark of all regulations prior to promulgation.
OAPCA: Try to write regulations in a way so everybody can read them and understand them. Currently, it is often
hard to understand exactly what businesses need to do to be in compliance. Provide workshops and telecourses, etc.
to train state and local agency personnel on new regulations that will affect the small business community.
SCAPCA: Clarify regulations. Reformat regulations to be more user-friendly. More descriptive fact sheets. More
industry-specific manuals; the Ecology dry cleaner manual is a success story. More information on health effects of
air pollutants. Resource lists. Multimedia inspections. Multimedia seminars.
Other
Alaska
Maricopa Cty, AZ
Placer Cty, CA
SCAQMD, CA
Colorado
Iowa
Allow small population states to reduce the size of CAP. Or, allow states with very small SBTCPs (1 or 2 people total)
to reduce the size of the CAP.
A "Determination of Applicability" program would be very helpful that can answer both whether a business needs an
Air Quality Permit and, if so, to what regulatory agency they should apply. If a business is required to have a permit
under a federal law that is administered by a state and then delegated to a local government, the business owner is
legitimately confused. As a result, the timeliness for an application to the proper regulatory agency for an Air Quality
Permit is hampered despite a small business owner's willingness to be compliant.
For landfill gas and soil remediation projects, meeting emission requirements, estimating emissions for application, and
performing screening risk assessment if required.
Regulate federal sources - this will help small businesses see that they are not being asked to do the whole job.
Allow state SBO/SBAPs to operate with unconditional confidentiality in regard to discovered violations with an
exception such as when imminent endangerment to public health or the environment.
SBO needs to be included in the implementation efforts of the Small Business Regulatory Fairness Act.
15
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(Continuad)
PROGRAM
Maine
New Hampshire
Pennsylvania
Virginia
Washington
Wisconsin
RECOMMENDATION
Include incentives for pollution prevention in all new rules.
EPA should minimize direct outreach efforts to small businesses. The vast majority of small businesses 1 deal with do
not trust EPA, but they do have a higher trust level for the state programs and agencies.
Strong enforcement presence so that small businesses seek assistance instead of remaining hidden or unknown.
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?
YRCCA: More local orientation with respect to implementation of CAA. County officials should be further enabled to
work with local sources. Local air quality agency staff should participate in local service and business organizations.
Local agencies of all types should be more active in cooperative functions
EPA should insist that all regions become equally active in order to maintain a uniform CAP effort throughout the USA.
Continue to develop opportunities for private/public sector cooperation between regulated industry and government
agencies like the Great Printers Project. Encourage and provide incentives for small businesses to adopt environmental
management systems.
No recommendations reported:
Hawaii, Idaho, Kansas, Mississippi, Missouri, Nebraska, New Mexico, Vermont
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TABLE G-4
CONFLICT OF INTEREST/CONFIDENTIALITY ISSUES
The SBTCPs provided information as to how their programs address internal or external conflicts of interest (COD or perception
that this program may not be confidential.
STATE OR
TERRITORY
Alabama
Alaska
Arizona
Maricopa Cty
Pima Cty
Arkansas
COI ISSUES AND RESOLUTIONS
SBO is used as the primary point of contact for the SBTCP. When the SBO receives calls from businesses regarding
compliance problems or questions, answers to those inquiries are solicited from the regulatory program personnel while keeping
the caller's name and company confidential. If the nature of the subject was such that in imminent threat to human health or
welfare was perceived, then confidentiality would not be offered and the caller would be advised to report the condition
immediately.
Under Alaska law, all files and information retained by SBAP and SBO are open to public review. The only exception is
information that is traditionally recognized, such as attorney-client, ongoing enforcement sensitive, or personnel records. Since
the SBAP/SBO is non-enforcement, it does not use any of the attorney-client or enforcement privileges. Personnel records are
not relevant to the businesses we assist.
SBAP and SBO have an ongoing dialogue with the Department's Air Quality Section. There is an informal agreement that the
Air Quality Program will not review the SBAP/SBO files. The Air Quality Program agrees that any violation of air quality
regulations need to be discovered and documented by an Air Quality Inspector. This approach is explained to the businesses
that request assistance from SBAP.
SBAP and SBO do provide technical information to sources that call in and do not identify themselves. Also through the state
web pages, businesses will be able to obtain information anonymously.
To date, there have not been any problems with other sections of the department requesting to see our files. Also, there have
been no requests from the public to view or copy SBAP files on businesses we have helped.
SBAP was moved out of the Air Quality regulatory program and housed under the Director's Office in a newly created
Compliance Assistance Section. Agency policies have been developed regarding the On-site Compliance Assistance and a
renewed effort has been made to work with the Compliance & Enforcement Programs within the Agency.
N/R
In four years of operation, PDEQ Business Assistance Program has never encountered a question or concern about
confidentiality of information provided during compliance assistance. Perhaps the reason is that BAP staff are sincere in their
approach and actions, have a successful track record and positive reputation, and are working on a local level with local staff,
which lends itself to establishing and maintaining trust.
Aaencv does not encounter conflicts of interest.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
California
SCAQMD
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
(XM ISSUES AND RESOLUTIONS
The Ombudsman's Office is part of the Air Resources Board Chairman's Office and no CO! or confidentiality issues have arisen
yet.
SBAP is located within a regulatory agency, but not in enforcement section. It is located in the Public Advisor's unit, which has
a state legislative requirement to assist businesses. SBAP's role clearly defined in meetings with executive staff.
Memorandum of Understanding between enforcement unit and SBAP under development. Written guidelines exist for
enforcement staff and for SBAP when coordinating on-site confidential meetings.
SBO is located in an agency independent of the air pollution regulatory agency, so the problem has not presented itself in regard
to the SBO. SBAP is located in the air pollution regulatory agency; however they are removed from the enforcement section of
their department. As of yet, a problem has not occurred.
Program is very open in that it does not offer confidentiality. Enforcement relief policies usually outlined for specific small
business sectors. Referrals made to other programs offering confidentiality. Program offers access to high quality regulatory
assistance and it appears that such assistance is very much in demand.
There are two issues here. One is an internal, and the other is whether or not clients believe that what information is offered
by them regarding compliance issues will actually be treated as confidential. Frankly, 1 find the internal issue to be more
challenging than dealing with clients. The regulatory and enforcement personnel seem to have some reluctance to provide
information when names and identifying information are not associated with the request. For instance, if 1 ask general
questions concerning compliance, or say 1 am working with a small business and want general information about compliance,
there is some reluctance to supply this information without knowing names or people or businesses.
Telling clients that they can feel free to discuss their compliance status and needs without fear of being reported to
enforcement personnel is believable by most, but others are highly skeptical. We are planning to implement a formal policy
within the Department that will address confidentiality within the Office of Business and Permitting, which includes the SBAP
and the P2 program.
COI is inevitable in our program because the SBAP performs many other regulatory functions. SBAP also is a permit engineer
who may recommend enforcement actions for noncompliance of her permit conditions. SBO is not a regulator and thus has no
such appearance of conflict.
Program has not had a case where confidentiality was challenged.
SBAP avoids the discussion and review of confidential materials with compliance and enforcement personnel. When in
discussions with other programs in EPD about a small business client, the business names are not used; or, circumstances are
presented and assurances are secured before any sensitive materials are discussed.
No comments.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
CCH ISSUES AMP RESOIUTK3WS
Idaho
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.
Illinois
SBAP is at the IL Department of Commerce and Community Affairs, a non-regulatory agency. Companies are allowed
confidentiality because we do not regulate. Our purpose is to assist. We can get information for the client, maintain their
anonvmitv if thev so chose, and assist them with their regulatory needs.
Indiana
CTAP is statutorily required to maintain confidentiality. In addition to the statutory requirement, a non-rule policy was
published in the IN Register to discuss our implementation of the statute.
To avoid a potential conflict of interest regarding confidentiality, CTAP is located within IDEM's Office of Pollution Prevention
and Technical Assistance (OPPTA), which is a non-regulatory office. OPPTA had previously been located across the hall from
the Office of Enforcement, but moved to a separate building in early 1995. In addition, visitor access to our office is restricted.
Guests must be escorted when visiting non-CTAP personnel and are prohibited from entering the CTAP area.
A detailed document on procedures to ensure confidentiality is under development, providing guidance for scenarios that CTAP
is likely to encounter. In addition, CTAP staff are required to sign a statement agreeing to abide by the confidentiality policy,
both upon joining CTAP and again when they leave. _____
Iowa
IAEAP is funded by DNR Air Quality Bureau (AQB). Contract terms require disclosure of EAEAP client list to DNR-AQB. The
annual disclosure identifies client names and addresses, but does not include facility specific information. IAEAP informs
clients that "confidentiality" does not exist.
IAEAP considers the disclosure list insignificant for the following reasons: 1) Majority of clients must submit permit applications
to DNR, which contain facility specific information. 2) To encourage voluntary compliance, DNR does not target small
businesses that are receiving assistance from IAEAP. ____
Kansas
SBAP is under contract, which states that specific information regarding businesses (such as name, specialty, nature of inquiry,
or other trade information) will not be reported to the regulatory agency; only numbers by SIC codes are reported.
The Ombudsman (Public Advocate) has the approval by the division director and bureau directors to keep information
confidential.
Confidentiality has not been as issue.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Kentucky
Jefferson Cty
Louisiana
Maine
Maryland
Massachusetts
COI ISSUES AND RESOLUTIONS
KY SBTCP is based on independence from the regulatory program. SBO is located in the Cabinet Secretary's Office. SBAP is
offered through the Center for Business Development outside state government. CAP members are appointed by Executive
Order of the Governor.
The Economic Development Cabinet raised questions about the language used by SBAP regarding client confidentiality. After
much discussion, revisions to these materials are pending.
SBAP is administered from the Air Pollution Control District, therefore confidentiality is not an issue. The small business owner
is, however, offered a fine-free correction period in which to come into compliance without penalty.
We publish the following policy on our Internet homepage: "The Small Business Assistance Program (SBAP) personnel will not
voluntarily reveal any environmental information received from a small business to any regulatory agency, except: 1 ) a criminal
act has been committed, 2) the violation is a serious hazard to life or the environment, or 3) the company is a repeat violator."
We have not been involved in any situation where there was a conflict of interest or the perception that this program may not
be confidential.
Department has adopted the Small Business Compliance Incentives Policy based on EPA guidance.
This is not a problem. Most assistance is not personal assistance, but dissemination of information or assistance over the
phone, which allows companies to remain anonymous. We do minimal on-site assistance.
N/R
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TABLE G-4
(Continued)
STATE OR
TERRITORY
COt ISSUES AND RESOLUTIONS
Michigan
External Conflicts of Interest: Confidentiality is not an issue because the current services provided by SBTCP are proactive.
SBAP is eluding the confidentiality issue by developing guidance publications, workshops, and conducting phone consultations.
At present, these activities do not warrant the collection of sensitive data. Additionally, SBAP does not perform on-site audits,
so facility-specific information is not collected.
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 SBTCP files or databases
will not be shared with the regulatory agency (Ml Air Quality Division). At present, Michigan'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: 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 Clean Air Act. 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 avoiding internal conflicts of interest.
Minnesota
MOD between SBCAP and AQ/CES working well. Does not seem to be any perception problems with SBCAP and SBO
operating within regulatory agency. We have the good reputation of helping people and word has spread through regulated
community.
Success in extending enforcement waiver to other media programs for wood finishing initiative demonstrates support for the
goals of the program and no conflict of interest problems.
There has been no serious challenge to either SBCAP or SBO programs' "confidential" handling of client information.
Mississippi
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 Policy for SBAP's option 2;
therefore, no written correspondence on the compliance status of a small business is maintained by SBO and SBAP.
Missouri
Any violations found by the Technical Assistance Program are not reported to the regulatory programs unless they are
determined to be an imminent threat to human health and/or the environment. Our information for a facility remains "off limits"
to the regulatory programs until an enforcement action is taken by the regulatory programs by their own findings. They then
can request to look at our files. The information in the file can either help or hurt the facility depending on whether they
heeded our recommendations.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Montana
Nebraska
Nevada
Washoe Cty
Clark Cty
NVBAQ
NVBEP
' ' ' '' " : '
COI ISSUES AND RESOLUTIONS
SBO/SBAP has not come across any potential cases of conflict of interest. However, several challenges to its policy of
confidentiality have arisen. Each challenge was denied because the businesses in question had entered into compliance
agreements with SBO/SBAP. SBO/SBAP follow the EPA Compliance Incentives for Small Business Policy for each business
with which it works and guarantees confidentiality and protection from enforcement provided the business in question follows
the terms of the compliance agreement.
NE's SBAP is under the Management Services Section within the Department of Environmental Quality. The ability of the
Public Advocate to work with all sections and programs within the agency does not pose any major problems.
For the SBAP, it is difficult, if not impossible, under our state disclosure laws, to provide complete confidentiality. However,
we are sensitive to the needs of the small business community, and they may remain anonymous. We also may refer them to
the BEP that is under contract to the SBAP, where their communications need to be kept confidential. SBAP has not had any
requests for records and no business SBAP has assisted has asked for confidentiality.
There has not yet been any situations in which there has been any question of, or problems associated with, the confidentiality
of SBAP. As yet, there has been no hint of conflict of interest in regard to this program that AQMD is aware.
They are not aware that their system's program has elicited any claims of conflict of interest or that parts of the program were
not confidential.
Through the excess emission reporting regulation, a company may report excess emissions to BAQ without enforcement action
providing they meet the criteria set forth within the regulation. This reporting regulation is emphasized during the workshops.
BEP provides third party confidential assistance and is located in the NV Small Business Development Center (NSBDC) operated
out of the University of Nevada, Reno. The program has a strong reputation for protecting client confidentiality and this is a
major reason that the SBDC is used to deliver environmental assistance. BEP offers "free and confidential" assistance to the
business community, which is clearly stated in all of the distributed literature and mentioned during conversations on the
assistance line. Such an approach has eliminated any internal and external conflicts of interest. The various regulatory
agencies have accepted the fact there is a program that a small business can confidentially contact to get information regarding
air aualitv violations and oermittina. even if thev are in violation of various reaulations.
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TABLE G-4
(Continued)
STATE OR
TERRfTORY
COt ISSUES AMD RESOiUTIOHS
New Hampshire
SBO and SBAP in NH are granted considerable leeway to assure confidentiality. OECA policy is used as a general policy for
compliance and is augmented by a "self auditing" law and a P2 law, which grant audit privilege and confidentiality to small
businesses.
In addition, there are many accessions where complaints received by the Air Resources Division are referred to SBAP when
they involve small businesses. These complaints are usually related to nuisance type issues that can be resolved through
education. This referral policy frees up the limited enforcement staff to concentrate on more serious issues.
It has proven to be very effective to work in partnership with the enforcement group to ensure the ultimate goal of
environmental well being is met in the most efficient manner possible.
New Jersey
SBTCP agreement with OEP Enforcement that SBTCP information is confidential. SBTCP explains this at meetings, seminars,
conferences, etc.
New Mexico
NM SBAP does not offer confidentiality. Instead, SBAP developed an amnesty program for small businesses (only those
meeting the qualifications of a small business) who are making a good faith effort to comply with state and federal air pollution
control regulations. The details of this program were developed with the Air Quality Bureau (AQB) staff responsible for
enforcing state and federal air pollution control regulations. A small business must contact SBAP requesting assistance before
amnesty will be considered. Amnesty will not be considered for violations that the AQB has discovered through other means
(i.e., state/federal inspections prior to small business contact with SBAP, or citizen complaints/tips given to AQB prior to small
business contact with SBAP). When a small business contacts SBAP requesting assistance, if eligible for amnesty, SBAP will
notify the AQB enforcement section that the business is being granted amnesty and the business is protected from any legal
actions or fines that may be levied.
SBAP will continue amnesty for the small business until the violation is corrected, but only if the small business is working with
SBAP and making good faith effort to correct the violation. The amnesty policy does not cover any criminal actions or any
violation that may create a serious or immediate threat to the health of the people or the environment. SBAP will review the
business' good faith efforts at least every 90 days. Amnesty may be terminated if the business is not showing good faith
efforts to correct a violation(s). Amnesty only will be granted once to a small business person for the same violation.
Any information that is observed by or revealed by SBAP and claimed as a trade secret by the small business will be treated as
such by the department to the extent allowable under state law. The procedure for identifying trade secrets to the department
is described in NMED's Public Records and Inspection Policy.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
COt ISSUES AMD RESOLUTIONS
New York
Neither the SBO or SBAP is located within New York State's regulatory enforcement agency, the Department of Environmental
Conservation (DEC). Additionally, NY State has legislated confidentiality for both SBO and SBAP. This information, obtained
by SBTCP in the course of providing compliance assistance, is exempt from the Freedom of Information Law.
All SBTCP contacts are held in strictest confidence, and requests to DEC for information or regulatory clarification are made
without revealing the client's identity, unless the SBTCP has obtained prior approval from the client to do so.
SBAP's offices are in the same building as the central offices of DEC. Having identical street addresses has meant that SBAP
must take great pains to assure clients that materials they send to SBAP during the course of receiving technical assistance are
not shared with DEC and are held completely in confidence.
North Carolina
In November 1993, NC Department of Environment, Health, and Natural Resources issued a Confidential Policy for the Offices
of Waste Reduction and Small Business Ombudsman. Since the entire SBAP and SBO are in the Office of the Small Business
Ombudsman, the policy applies to all operations of the SBTCP. The policy states that the regulatory divisions will not seek to
obtain information about compliance of any individual from the two assistance offices. Further it states that the OWR and SBO
will maintain confidentiality of information to the maximum extent allowed bv law.
8
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TABLE G-4
(Continued)
STATE OR
TERRITORY
CO) ISSUES AND RESOLUTIONS
North Dakota
There are advantages and disadvantages to the organizational structure of SBAP and SBO. As structured, SBAP and SBO may
not appear to be free from conflict of interest. Although SBAP staff are part of the permit section, which is separate from the
compliance section, it is difficult to know whether small businesses are reluctant to request assistance from SBAP, since SBAP
staff are part of the air pollution control regulatory program. Also, it is unknown whether small businesses are reluctant to
request assistance or confide in the SBO since the ombudsman is housed within and employed by the Department of Health.
Besides serving as SBO, the ombudsman has other duties that support the administrative functioning (e.g., coordinating
emergency response, quality assurance, pollution prevention, and various staff training needs) of the Environmental Health
Section. The Department has had very few enforcement actions involving small business and the SBO's assistance regarding
enforcement matters has not been requested to date. 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.
The environmental programs of the Department's Environmental Health Section have traditionally been assistance and
compliance oriented, with enforcement reserved for recalcitrant violators or where damage to health and/or environment has
occurred. Even prior to the establishment of the SBAP or SBO, the Department's emphasis has been on educating and
assisting the regulated community to achieve compliance. With the establishment of SBAP and SBO, the fundamental
approach to compliance hasn't changed noticeably. However, with the establishment of SBAP and SBO, there has been more
outreach to actively advertise the Department's assistance-oriented philosophy.
With respect to confidentiality, dialogue between SBO and SBAP has resulted in the understanding that small businesses may
reveal certain information to SBO that may be treated confidentially and not disclosed to, or sought to be disclosed from, the
SBAP. Information disclosed by small business directly to SBAP staff would not be turned over to the compliance program
staff for enforcement purposes; however, it is expected that a plan for correcting any violations would be developed. When
needed, compliance assistance will be provided from SBAP.
It is the SBAP's and SBO's position that confidentiality (disclosure of violations to enforcement staff) has really been a non-
issue in North Dakota.
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, SBAP has spoken directly with the district office to resolve the problem. This
was done only with prior approval of the company.
In addition, both SBO and SBAP in Ohio operate under very strict state confidentiality laws specifically written for these
programs. The strength of the language gives comfort to businesses.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
COI ISSUES AMD RESOLUTIONS
In OK, SBAP is housed in the Customer Assistance Program within the Department of Environmental Quality. As a result, we
are provided with a strong identity in regard to confidential assistance. Our group is supported very strongly by our Agency
management and as a result of this, we are provided with the tools we need within our own Agency to provide quality
confidential assistance.
Information disclosed and minor violations discovered from on-site small business technical assistance visits are protected by
state statute except when there is reasonable cause to believe there is a clear and immediate danger to public health or safety
of the environment. In accordance with the state statute and the confidentiality option set forth in EPA's Office of
Enforcement and Compliance enforcement policy, the OR SBAP adopted a written Confidentiality Policy. In summary, the
policy requires 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 separate confidential files, and perform
follow-up consultations to assure resolutions of violations discovered during on-site visits.
This policy has not caused any conflicts on interest inside or outside the agency. To the contrary, it allows additional flexibility
to bring small businesses into environmental compliance. For example, it allows SBAP to assist a small business that faces
enforcement through other channels by allowing the staff to assist with P2, applying for permits, and mitigating penalties via
supplemental environmental projects (SEPs). In such cases, OR's Confidentiality Policy is congruous with EPA's Policy of
Compliance Incentives for Small Businesses.
Many services of the PA SBAP have been contracted to a private company. The terms of this contract prohibit the contractor
from providing client names and addresses to the regulatory agency. The contractor primarily seeks contracts with government
agencies, and therefore dies not normally have small business clients outside of the SBAP contract. This arrangement, to date,
has avoided any problems with conflict of interest and has provided a solution to the confidentiality issue.
All businesses that might be affected by regulations and have problems getting into compliance are referred to the SBAP staff
for all the necessary help.
Rl DEM has been operating a non-regulatory technical assistance program since 1 987. Since that time, we have worked with
more than 200 companies and have gained the trust of many more. Conflicts of interest are avoided through close coordination
with the regulatory Office of Air Resources.
SBAP/SBO are located in Administration, away from regulatory section of agency. This has not been an issue between
Program and regulatory staff.
It has not been a problem so far.
TN developed a self-auditing policy, which is currently being disseminated across the state, and feedback is being sought. The
regulatory agencies (there are five in our state) have demonstrated tremendous support for program activities. They respect
the confidential nature of our oroaram. We have not exoerienced problems.
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TABLE G-4
(Continued)
STATE OR
TERRITORY
Texas
Utah
Vermont
Virginia
Virgin Islands
CCM ISSUES AND RESOLUTIONS
In 1 993, SBAP developed a Confidentiality Policy for small businesses that was adopted by the TNRCC Commission. SBAP
operates under a multimedia TNRCC policy that provides for confidentiality from the enforcement program of the agency. We
work closely with TNRCC Executive Office, Enforcement, and Field Operations to ensure that all are aware of the
Confidentiality Policy. The Enforcement Division now refers small businesses to our office for confidential assistance. All
printed materials developed by SBAP contain confidentiality policy statement. The confidentiality policy that started with the
Air Program has been expanded to all media that the TNRCC regulates.
Several concerns expressed regarding general confidentiality issues. It was also reported that an outside program that was
advertising confidentiality was not considered to be confidential. After legislative review by UT's Attorney General's Office, it
was determined that although a self-audit bill exists, it did not cover on-site visits. Further, federal and state government
records are, in many cases, open and available for public review.
N/R
DEO implemented and utilizes EPA's Section 507 Enforcement Policy.
The issue of confidentiality has not been a major problem. It is still felt this issue will take on more importance as the SBAP
moves further into voluntary complimentary compliance audits as additional resources become available. The ability to deliver a
quality product to the customer is only as good as the credibility of the provider. The ability to correct deficiencies and non-
compliance situations through the 507 Enforcement Policy provides a non-confrontational means to achieve compliance
assistance and deliver a quality product. It is also important to realize that the ability to fix a problem with relative ease can be
put into the category of a smart business decision.
Within DEQ, the continued involvement of SBO/SBAP with the Enforcement and Compliance Office also helps to ensure an
understanding of the needs on both sides of compliance enforcement issues, fully recognizing that compliance is the ultimate
goal. As EPA expanded the 507 Policy to water in waste in June 1 996, the VA legislature also has provided additional tools to
the business community in the form of voluntary remediation and voluntary audit privilege.
N/A ._ .._'.._
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TABLE G-4
(Continued)
STATE OR
TERRITORY
CO! tSSUeS AMD RESOLUTIONS
Washington
Revised Code of Washington, Chapter 70.94.035: "The department (of Ecology) shall establish a technical assistance unit
within its air quality program, consistent with the CAA,...No representative of...the technical assistance unit...may have
enforcement authority...Consultation(s)...shall not be regarded as an inspection or investigation...No enforcement action shall
be taken...for violations...unless and until the facility owner or operator has been provided reasonable time to correct (any)
violation." Violations that pose immediate threats to public health and the environment may result in immediate enforcement
action.
SBAP staff are obligated to report personally-detected violations (i.e., from on-site visits) to agency enforcement staff.
Reporting is discretionary in the case of suspected violations or those suggested by the source with the exception of those
posing "imminent threat.'
BCCAA
If small business requests it, we can take off the regulatory hat and just help them without documenting deficiencies or writing
notices of violation. However, this can be part of the enforcement policy of the field inspector. He can simply say, "I didn't
see all these problems. I will be back in three months. Can you have A..., B..., C...corrected by then or do you need more
time? Look in the Yellow Pages under...or call... and get some help." Air quality authorities are allowed to give warning
tickets. They also are allowed to give detailed corrective action. Standard civil penalties can be mitigated to a fraction of the
standard penalty if a small business spends a lot on correcting the problem.
The field persons see the good and the bad. The field persons need to be freed by their supervision and management to help
the small businesses with their field knowledge or to have them call an experienced inspector or engineer for help.
OAPCA
OAPCA utilizes its own SBAP record form. One section of that one-page form addresses "Compliance Assistance Site Visit
Acknowledgment." It explains terms of an agreement and allows the business owner to sign indicating that there will not be a
conflict of interest between assistance and enforcement (i.e., specific times are set in which no enforcement will be taken
while compliance is achieved). The agency strives to maintain confidentiality with the previously mentioned forms and
information.
SWAPCA
Program is subcontracted outside the agency.
YRCCA
The intent of avoiding any conflict of interest, either real, imagined, or perceived, must come about as a result of the comfort
level of the parties involved. An inspection of a facility might expose certain conditions that make that operation "out of
compliance" to a particular regulation. Rather than immediately imposing a correction notice, a business assistance solution to
the problem might be an alternative method to resolving the situation.
This approach can be used successfully if the terms/conditions are negotiated and written down as to what procedures are to
be followed. This cooperative approach should achieve the same objective as levying a penalty that is to improve air quality for
our jurisdiction. This partnership between the parties involved offers what business owners have indicated is required to keep
compliance regulations from becoming economically burdensome.
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(Continued)
STATE OR
TERRITORY
CO< ISSUES AMD RESOLUTIONS
West Virginia
SBAP operates separately and independently from the enforcement group of the agency. Also, SBAP currently is housed in a
separate physical location. To better help small businesses, enforcement refers some violators to SBAP for technical
assistance to facilitate compliance. In fact, the referrals from enforcement have increased dramatically this year. 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 in imminent danger. However, to ensure that compliance is eventually achieved, SBAP will
make on-site assessment files available to enforcement after an 18-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.
Wisconsin
Wisconsin SBAP/SBO is a cooperative effort between Wl Department of Natural Resources (DNR) and the non-regulatory
component of Wl Department of Commerce. The primary responsibility for interacting with business rests with Department of
Commerce staff. A memorandum of understanding has been established between Commerce and DNR that allows business to
speak to Commerce staff on a confidential basis. As a rule, we ask our customers if they do not want to be identified if we
have to discuss their situation with DNR representatives.
Wyoming
The problem of COI or the fact that SBAP does not have confidentiality has not been resolved internally or externally. CAP has
recommended that confidentiality is necessary for an effective SBAP; however, the department has maintained that state
statute prohibits confidentiality since all received information must be available to the general public, other than trade secrets.
CAP believes that the result of this impasse is a less than effective SBAP where the bottom line is to provide compliance and
technical assistance to the small business community. The Department initiated the drafting of its Small Business Voluntary
Disclosure and Incentive Rule that provides penalty waivers for small businesses that voluntarily disclose non-compliance and
work with the Department to achieve compliance.
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