State Innovation Grant Program: Vermont
Cross-Media Environmental Results Program for the Retail Gasoline Sales
Sector (2004 Competition)
ie innovation urani rrogram 10 support
efforts led by state environmental agencies to test innovative approaches
for achieving better environmental results and improved efficiency in
permitting programs. Between 2002 and 2007, the State Innovation Grant
program competition awarded over six million dollars to support 35 state
projects that test permitting innovation for a variety of regulated entities
including several small business sectors. Asummary of the awards by year
appears in the table below.
State Innovation Grant Program Statistics, 2002-2007
Competition Proposals Proposals Total Program
Year Submitted Selected Funding ($)
2002/2003
$618,000
$1.425 Million
$1.479 Million
Cumulative
$1.243 Million
$1.611 Million
$6.376 Million
"Innovation in Permitting" has been the theme of the State Innovation Grant
competition since its inception. In the last three competition cycles states
received awards for projects in the following three categories:
The Environmental Results Program (ERP) is an innovative
approach to improving environmental performance based on a system
of the interlocking tools of compliance assistance, self-certification
(sometimes, where permissible, in lieu of permitting), and
statistically-based measurement to gauge the performance of an entire
business sector. The program utilizes a multimedia approach to
encourage small sources to achieve environmental compliance and
pollution prevention. (See: http://www.epa.gov/permits/erp/)
Environmental Management System (EMS) is a system involving a
continual cycle of planning, implementing, reviewing and improving the
processes and actions that an organization undertakes to meet its
business and environmental goals. EMSs provide organizations of all
types with a structured system and approach for managing
environmental and regulatory responsibilities to improve overall
environmental performance and stewardship.
(See: www.epa.gov/ems/info/index.htm)
Performance Track is a partnership that recognizes top
environmental performance among participating US facilities of all types,
sizes, and complexity, both public and private.
(See: http://www.epa.gov/performancetrack/)
NCEI has provided awards also for projects testing watershed-based
permitting, and for permit process streamlining in past competitions. For
more information on the history of the programs, including information on
solicitations, state proposals, and project awards, please see the EPA State
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Project Background:
The Vermont Underground Storage Tank (LIST)
program, managed by the Vermont Department of
Environmental Conservation (VT DEC), is trying to
improve sector-wide compliance through the
implementation of an Environmental Results Program
(ERP). In recent years the state has averaged only
about 100 environmental compliance inspections for
LIST operators per year due to a small program staff
size. At this rate it would have taken VT DEC over 10
years to conduct a single evaluation of all LIST
facilities in the state. In 2004, VT DEC applied for and
received an EPA's State Innovation Grant to conduct
a pilot ERP designed to help improve compliance at
more than 1,100 LIST sector facilities.
Vermont's LIST program places special emphasis on
the retail gasoline sector, which has unique and
ongoing compliance issues. For instance, over the
last few years Vermont has brought formal
enforcement cases against retail gasoline sector
facilities at 18 locations, several of which involved
violations of the Vermont LIST Regulations and Clean
Air Act (CAA). Vermont's ERP model should make it
possible to use a combination of state led
inspections and self-certification to assess every
facility's compliance status annually while helping
facilities address regulatory requirements.
Project Description
Vermont's ERP project aims to achieve a
measurable improvement in compliance within the
retail gasoline sales sector, as well as other facilities
regulated by the Vermont LIST program, with regard
to four federally-delegated regulatory programs:
Resource Conservation and Recovery Act
(RCRA) generator requirements;
NCEI
NATIONAL CENTER FOR
ENVIRONMENTAL INNOVATION
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CM Stage II requirements; and
Safe Drinking Water Act (SDWA) Underground
Injection Control (UIC) requirements.
This pilot project will help VT DEC work toward sector-
wide compliance through a combination of enhanced
technical assistance, outreach, and a mandatory self-
certification program. Implementation of Vermont's
ERP begins with an initial compliance inspection
assessment of a randomly selected group of retail
gasoline outlets to determine their baseline
compliance rate. VT DEC then provides compliance
assistance materials, including a workbook detailing
compliance requirements for LIST equipment and
operation as well as fact sheets for the different
requirements by media (i.e. air, etc.) and, a self-
assessment checklist to help facilities understand the
environmental requirements they need to meet and
encourage facilities to prevent pollution. Participants
must complete and submit the multi-media self-
certification forms to VT DEC. If facilities discover they
are out of compliance, they must submit a return to
compliance (RTC) plan to VT DEC; and correct the
compliance problem(s) identified in the RTC plan as
soon as possible. The agency then conducts
inspections at a second sample of randomly selected
facilities to measure changes in the group's
compliance performance over time and gauge the
ERP's success. Both the baseline and follow-up
inspections are multi-media.
This project also establishes sector-specific, cross-
media Best Management Practices (BMPs) to help the
regulated community reduce compliance costs by
addressing all environmental and compliance issues
simultaneously, across all media, rather than narrowly
focusing on specific problems identified during their
last regulatory inspection.
In the long-term, VT DEC hopes the ERP will produce
a number of benefits, including:
Annual multi-media compliance measurement for
100% of the facilities in the sector (compared to
less than 10% previously),
Improved sector-wide compliance,
Increased adoption of best management
practices within the sector,
Reduced emissions and releases, and
Improved communication between the regulated
community and the VT DEC concerning
compliance issues and regulations.
To help achieve these benefits, the Vermont LIST
program has created compliance goals, including:
Increased participation VT DEC seeks to
attain approximately 85% participation by LIST
facilities during the first implementation year, and
95% participation by the end of the second year;
and
Increased compliance VT DEC aims to
improve compliance with priority LIST, RCRA, Air
and UIC requirements by at least 15% by the
end of the second implementation year, as
measured by a comparison of compliance in
baseline and follow-up inspections.
This grant pilot program is funded through September
2008, and Vermont DEC plans to continue running the
ERP beyond the grant period.
Connection to EPA's Goals
This program directly supports EPA's Strategic Goal
#5, focused on compliance and environmental
stewardship, by promoting an innovative approach to
improve compliance and pollution prevention. It also
supports EPA's Strategic Goal #3 by helping preserve
and restore land through improving the way waste is
generated and managed; as well as the EPA's Cross-
Goal Strategy of promoting innovation and
collaboration with states.
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Project Contacts:
For more specific information on the
Vermont State Innovation Grant, please
contact one of the individuals below:
Marc Roy
Vermont Department of Environmental Conservation
Waterbury, Vermont
802.241.3874
marc.roy@state.vt.us
Program Contact:
Sherri Walker
State Innovation Grant Program
U.S. Environmental Protection Agency
Washington, DC 20460 (MC1807T)
(202)-566-2186; FAX (202) 566-2220
walker.sherri@epa.gov
Marge Miranda
U.S. Environmental Protection Agency
Region 1
Boston, MA
617.918.1825
miranda.marge@epa.gov
Kimberly Green-Goldsborough
U.S. Environmental Protection Agency Region 1
National Center for Environmental Innovation
Boston, MA
617.918.1662
termini.beth@epa.gov
United States
Environmental Protection
Agency
Office of Policy,
Economics and Innovation
(1807T)
April 2008
EPA-100-F-08-038
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