State Innovation Grant Program: Wisconsin
Environmental Management Systems and an Environmental Results
Program to Improve Air Permitting for the Printing Sector
(2005 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:
After undertaking an extensive evaluation of its air-
permitting program, the Wisconsin Department of Natural
Resources (WDNR) Air Program sought to improve its
efficiency in environmental regulation and program
implementation. The state was concerned about the
amount of effort and time involved in the air permitting
process and its value in achieving measurable
environmental improvement. Businesses had also
expressed strong interest in having the state adopt a
more comprehensive approach to environmental
regulation. To address these concerns, while also facing
a decline in Department resources, WDNR applied for
and received an EPA State Innovation Grant in 2005 to
help streamline the state's air permitting process and find
innovative permitting alternatives for the printing sector.
More specifically, WDNR planned to design and
implement both:
1) Performance-Based Permits for large printers
with environmental management systems
(EMSs), and an
2) Environmental Results Program (ERP) for
small printing facilities.
Wisconsin also hopes to adapt this pilot project's
methodology and lessons learned to other sectors in the
state.
Project Description
The printing industry in Wisconsin is vital to the state's
economy, with an array of small and large-scale
businesses selling a diversity of products and services.
The sector is also a significant source of volatile organic
compound (VOCs) and hazardous air pollutant (HAPs)
emissions. WDNR's innovative Performance-Based
Permit/ERP project is working across the entire printing
industry to improve air permitting, with specific goals to:
Streamline the permitting process for both printers
and the WDNR and find innovative air permitting
alternatives;
NCEI
NATIONAL CENTER FOR
ENVIRONMENTAL INNOVATION
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Integrate EMSs and permits for the printing sector as
a significant step toward creating a performance-
based approach to managing environmental risk;
Reduce the burden associated with air permitting for
all printers and provide regulatory flexibility; and
Improve the environmental stewardship of
participating facilities by providing tools to increase
their understanding of environmental impacts and
creating incentives for beyond-compliance behavior.
In designing this program, WDNR built on similar programs
developed by Florida, Massachusetts, and Rhode Island as
a foundation for their ERP development, as well as
Colorado's experience in developing an EMS-Permit
approach. WDNR also drew on findings from their permit
improvement initiative, and experiences from the Wisconsin
Department of Commerce's Small Business Assistance
Program, which was already exploring an ERP.
The ERP portion of WDNR's pilot project was developed for
small to medium sized printers with up to 25 tons of VOC
emissions per year. Implementation of the ERP begins with
an initial compliance inspection assessment of a randomly
selected group of printers to determine their baseline
compliance rate. WDNR then provides compliance
assistance materials and a self-assessment checklist to
participating establishments to help facilities understand
the environmental requirements they need to meet, and
encourage them to prevent pollution. Participants must
complete and submit the multi-media self-certification
forms to WDNR. If facilities discover they are out of
compliance, they must submit a return to compliance
(RTC) plan to WDNR; 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.
Through this pilot, WDNR will investigate the effectiveness
of ERP as a regulatory tool and consider whether
participation in an ERP can fulfill the role of a permit. Until
WDNR can fully explore the suitability of a permit exemption
for ERP participants, a registration permit designed
specifically for printers will be issued. This will ensure a
legally enforceable implementation mechanism, but will
substantially reduce the complexity and administrative
burden associated with traditional permitting, often
considered arduous and confusing by small businesses. In
addition, the amount of time required for annual
certification should not be greater than what was previously
needed under traditional permitting.
The second portion of this pilot project, the Performance-
Based Permit, involves developing an alternative permit
structure that employs EMSs as the basis for performance-
based facility permits. Larger printers that successfully
implement an EMS will enter into a contract under WDNR's
Green Tier Program, a voluntary initiative that provides
positive incentives to superior environmental performers.
The enabling statute for Green Tier allows WDNR to issue
a flexible, multi-media, performance-based permit that
utilizes portions of a facility's EMS to demonstrate
compliance with permit conditions and justify operational
changes and expansions. By providing relief from certain
regulatory burdens, such as permit modifications, this
permit can serve as a reward for beyond-compliance
behavior exhibited by facilities entering the Green Tier
Program. The permit should also drive technical
innovation, since its flexible nature will allow a facility to
experiment with ink formulations, control equipment,
printing techniques, etc., without first requiring a permit
revision or modification, as long as it meets conditions of
the permits. Although facilities of any size may qualify for a
performance-based permit, it is assumed that large-sized
printers will be more likely to have the resources and
interest in developing an EMS and meeting the other Green
Tier entrance requirements.
State Innovation Grant Program funding for the pilot
project's development will continue through the end of
2008.
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
environmental performance through pollution prevention
measures. It also supports Strategic Goal #1 to protect and
improve air quality, as well as EPA's Cross-Goal Strategy of
promoting innovation and collaboration with states.
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Project Contacts:
For more specific information on the
Wisconsin State Innovation Grant, please
contact one of the individuals below:
Renee Lesjak Bashel
Small Business Clean Air Assistance Program
Wisconsin Department of Commerce
Madison, Wl
608.264.6153
Renee.Bashel@Wisconsin.gov
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
Kristin Hart
Wisconsin Department of Natural Resources
South Central Region Air Program
Madison, Wl
608.273.5605
Kristin.Hart@Wisconsin.gov
Kathy Mullen
U.S. Environmental Protection Agency Region 5
Chicago, IL
312.886.6074
mullen.kathleen@epa.gov
Beth Termini
U.S. Environmental Protection AgencyRegion 1
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-08-039
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