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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