State Innovation Grant
Program
Vermont:
A Cross-Media Environmental Results Project
for the Retail Gasoline Sales Sector
The EPA State Innovation Grant Program was established in 2002 to help strengthen EPA's innovation partnerships
with States and Tribes and is a direct result of the Agency's innovation strategy, Innovating for Better Environmental
Results: A Strategy to Guide the Next Generation of Innovation at EPA (http://www.epa.gov/innovation/strategy).
To support the Innovation Strategy, the 2002 grant program focused its efforts on projects that related to one of
four priority issues: reducing greenhouse gases, reducing smog, improving water quality, and reducing the cost
of drinking water or wastewater infrastructure. In addition, EPA sought projects that test incentives that motivate
"beyond-compliance" environmental performance, or move whole sectors toward improved environmental
performance. This series of fact sheets features the State projects selected for funding under the Grant Program.
Contacts:
Marc Roy
Vermont Department of Environmental
Conservation, 103 S. Main Street/ West
Office Building, Waterbury, Vermont 05671-
0404, marc.roy@anr.state.vt.us
Chris Rascher
US EPA Region 1, Boston, MA,
rascher.chris@epa.gov
Marc Olender
US EPA National Center for Environmental
Innovation, Washington, DC, 21466,
202-566-2238, olender.marc@epa.gov
Background
With a small staff, the Vermont Underground Storage Tank (UST)
program currently conducts approximately 100 environmental
compliance inspections per year and does not anticipate having
new resources in the foreseeable future to significantly increase
the number of inspections. At the current rate of inspection, it
would take the Vermont UST Program over 10 years to evaluate
its facilities once. Under the Environmental Results Program (ERP)
model, an assessment of every facility's compliance status would
be conducted and submitted to VT DEC on an annual basis.
The Vermont UST program is an established program seeking
improved sector-wide compliance. The ERP model can achieve
this goal through a combination of enhanced technical assistance,
outreach, and a mandatory self-certification program. The Vermont
Resource Conservation and Recovery Act (RCRA) Program under
which USTs are regulated has found the retail gasoline sector to
have unique, and altogether too common, compliance problems.
In the last few years, the Vermont RCRA program has forwarded
formal enforcement cases against retail gasoline sector facilities
involving 18 locations. Several of these cases also involved
violations of die Vermont Underground Storage Tank Regulations
and Clean Air Act (CAA).
NCEI
NATIONAL CENTER FOR
ENVIRONMENTAL INNOVATION
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Project Description
This project uses the ERP model to achieve a
measurable improvement in compliance with sections
of four federally-delegated regulatory programs (UST,
RCRA generator requirements, the CAA Stage II
requirements, and the Safe Drinking Water Act
(SDWA) Underground Injection Control (UIC)
requirements) at facilities within the retail gasoline sales
sector as well as other facilities regulated by the
Vermont UST program.
This project establishes sector-specific, cross-media
Best Management Practices (BMPs) as well as other
compliance guidance materials. The purpose of the
BMPs encourage facilities to go "beyond compliance"
to reduce waste, pollution and emissions. This project
encourages the regulated community to achieve
reduced compliance costs by addressing all compliance
and environmental issues at once through cross-media
BMPs (that lead to compliance) rather than narrowly
focusing on specific problems identified during the last
regulatory inspection.
Benefits of the Project
In the long-term, it is expected that this approach will
yield these benefits:
• Annual multi-media compliance measures
across 100% of the facilities in the sector
(compared to less than 10% currently)
• Improved sector-wide compliance
• Reduced emissions and releases
• Reduced costs of compliance and program
administration
• Improved communication between the
regulated community and the VT DEC
concerning compliance (regulatory
improvements, self-reporting)
The compliance goals so the project will achieve the
benefits are:
• To reach approximately 85% participation by
the sector facilities during the first
implementation year
• To reach 95% participation by the sector
facilities by the end of the second
implementation year
• To improve the initial rates of compliance (as
determined by the initial and follow-up random
inspections) with the involved UST, RCRA, Air
and UIC requirements by at least 15% by the
end of the second implementation year (the
third project year)
Project Plan
The project will last two years, beginning late 2004.
United States
Environmental Protection
Agency
Office of Policy,
Economics and Innovation
January 2005
EPA-100-F-05-007
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