EPA NEW ENGLAND'S
         ENVIRONMENTAL JUSTICE
ACTION PLAN FOR FISCAL YEAR 2009

        Prepared by EPA New England's
          Environmental Justice Council
                   November 10, 2008

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
                           EPA NEW ENGLAND'S
                        ENVIRONMENTAL JUSTICE
                    ACTION PLAN FOR FISCAL YEAR 2009
Table of Contents
SECTION 1: NARRATIVE	2
A. Approach to Integrating Environmental Justice	2
B. External Outreach	3
C. Program Evaluation	4

SECTION 2: KEY PRIORITY AREAS	6
Reduction in number of asthma attacks	6
Reduce childhood lead poisoning	8
Reduce pollution in urban environments	10
Clean and safe drinking water	12
Ensuring Compliance	15
EJ Review of Auto Body Assistance Program	18

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

SECTION  1:  NARRATIVE

A. Approach to Integrating Environmental Justice

EPA New England's (NE) commitment to environmental justice is evidenced by its multi-faceted
approach to ensuring the continued integration of environmental justice into regional programs,
policies, and activities.  The EPA NE EJ program is a national model for EJ integration and can
be replicated by others.

The approach includes:
    •  Implementing an EJ policy
    •  Engaging an active EJ Council for guidance and direction
    •  Ensuring EJ awareness throughout the region through mandatory training
    •  Offering  shared learning opportunities (e.g. Lunch & Learns)
    •  Collaborating with our state  counterparts
    •  Developing EJ tools and guidance
    •  Regular tracking and reporting of progress

EJ Policy

In October 2001, Regional Administrator Robert W. Varney reaffirmed EPA NE's commitment
to EJ by issuing a revised EPA New England Regional Policy on Environmental Justice. This
policy sets the parameters and framework against which the region developed this and prior EJ
Action Plans, with specific implementation strategies designed to institutionalize EJ in the
region's daily work.  The policy can be found at: http://www.epa.gov/regionl/ej/ejpolicy.html.

EJ Council

EPA NE's regional EJ Council is charged with the responsibility of developing EJ guidance and
implementing strategies to institutionalize EJ activities throughout the regional office.  The EJ
Council is comprised of the regional EJ Coordinator, the Deputy Office Directors and designated
staff from each of the six program and administrative offices in the region, and is chaired by the
Director of the Office of Civil Rights and Urban Affairs. The EJ Council meets monthly.
Strategic and operational planning around EJ is carried out through the Council, ensuring full
engagement by all regional program and administrative offices. For example, a regional priority
in FY08 was to integrate environmental justice into EPA's Homeland Security efforts through the
Regional Homeland Security Collaborative Network.

EJ Training

EPA NE's Regional Administrator has mandated that all employees be trained in EJ, in order to
acquaint or re-acquaint them with the legal and policy framework of EJ and to provide them with
region-specific case studies illustrating real world issues and accomplishments. Approximately
93% of EPA-NE  employees have been trained as of July 2008.

EJ Tools and Guidance

An EJ Functional Guidance Compendium has been developed to supplement the EJ training by
highlighting some program-specific considerations  that identify how staff can have an impact on
EJ in their daily work. The manual contains ten guidance chapters covering the Brief Users'

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

Guide to the EPA New England EJ Desktop Mapping Tool; Public Involvement; Tribal
Consultation; Contracts and Procurement; Development and Approval of State Programs; Federal
Financial Assistance Agreements; Inspections, Enforcement and Compliance Assistance;
Performance Partnership Agreements with States; Permitting; and Waste Site Cleanup,
Emergency Response and Brownfields. Training on the guidance took place in conjunction with
the compendium's release in calendar year 2004. The EJ Council is currently considering
updating the guidance.

The EJ Mapping Tool is intended as a source of information for Region I personnel —
management and staff— to better inform us about EJ in New England. The Tool is designed to
enhance the quality of our work by providing easy  access to consistent and reliable EJ data. By
having EJ data readily available to help characterize communities throughout New England,
regional staff and management can better ensure that the principles of EJ, such as fairness and
meaningful involvement, are incorporated into our everyday work. The GIS Support Team is
currently working to improve the EJ Mapping Tool by upgrading to new software and adding
new data layers.

Shared Learning

Aside from providing training and guidance materials, the EJ Council has developed several
mechanisms to promote shared learning about EJ among EPA New England staff, including:

   •   Inviting external stakeholders to speak at the region, which has consistently proven to be
       one of the best ways to expand  the office's EJ knowledge base, share information and
       successes, connect staff with external partners and allow  external partners to connect with
       EPA;

   •   Inviting regional employees to  showcase their EJ-related work during monthly EJ
       Council meetings. An agenda item for many EJ Council meetings is the presentation of
       an EJ success story by the program staff. The responsibility for presenting is rotated
       among each office. These presentations often provide great material for feature articles
       in the regional EJ Newsletter, and

   •   Utilizing several broader communication tools as important elements of cross-office
       communication. These include the EJ Program internet and intranet pages, the EJ
       newsletter, the EJ Mapping Tool. The EJ Council ensures that this entire media is
       promoted, and material is regularly solicited from each office for inclusion.
B. External Outreach

The primary goal of the EJ Council's external engagement activities with other federal agencies
and with state, tribal, and local governments is to educate and change behavior and actions to
ensure that EJ is an integral part of the roles and responsibilities of these external partners of EPA
NE.  EPA NE maintains that the key to achieving this goal is to remain actively involved with
these external stakeholders. EPA NE values input from external stakeholders because it enables
the region's program offices to more readily identify environmental issues and target resources to
address them. To build on past successes, the region will continue to use this proactive approach
to ensure meaningful stakeholder involvement.

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

Working with External Stakeholders
As an active partner in community capacity-building, the region has maintained a presence in
external EJ networks that have emerged.  Successful external statewide community-based EJ
networks exist in Massachusetts and Connecticut, and the Northeast EJ Network has a number of
members from other states in New England.  EPA NE regularly has representatives attend major
functions of these statewide and regional community coalitions. EPA NE recognizes that
partnerships and information-sharing with community groups and other federal, state, and local
agencies are key to identifying and resolving many EJ issues.

    •   State Engagement:  EPA New England's Environmental Justice Program has developed
        a new strategy to re-engage the state EJ counterparts at the state level to develop EJ-
        related commitments for Performance Partnership Agreements (PPAs) in the six New
        England states. As a result, our States have all identified concrete activities and
        additional areas of collaboration. In FY09, EPA NE will continue to work to enhance
        communication and dialogue with our state counterparts through a New England All
        States EJ Meeting (held on October 28, 2008) and to begin to have regular EJ conference
        calls with New England States EJ Contacts (e.g. quarterly conference calls). Other
        potential activities include identifying Supplement Environmental Projects (SEPs) that
        will benefit communities with potential EJ concerns and collaboration on a project
        through the State EJ Cooperative Agreement Initiative. In addition, in FY08, EPA NE
        conducted "Fundamentals of EJ Training" for one of our State partners. EPA worked
        with New Hampshire Department of Environmental Services to provide training on
        November 6, 2008.

        Listening Sessions:  EPA NE believes that there is no substitute for regular, sustained
        contact with communities throughout the region to directly observe existing conditions
        and respond to situations.  EPA NE will continue to hold listening sessions with
        community-based organizations throughout the FY09.
C. Program Evaluation

The EJ Council is responsible for tracking and reporting the progress of the items outlined in the
EJ Action Plan, and determining other measures of evaluating the larger concepts of
organizational culture change and institutionalizing of EJ principles throughout the region.
Where possible, the EJ Action Plan includes baseline data to evaluate the extent to which the
region is achieving its measures.

EJ Review

EPA New England has worked with states, municipalities, trade associations, community groups
and others to provide compliance and pollution prevention assistance to auto repair and auto body
shops. EPA published the final version of its new rule that established new requirements for area
sources  conducting automobile refinishing operations, miscellaneous surface coating operations
and paint stripping operations in the January 9, 2008, Federal Register.  The new rule includes
emissions standards for auto body refinishing  operations, spray coating equipment requirements,
employee training requirements and compliance notification requirements.

As a result of the new rule, EPA-NE is planning outreach and training activities for auto body
refinishing operations. An initial assessment of the location of these operations indicates that

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

many are located in areas with environmental justice concerns.  For example, the city of Holyoke,
MA has approximately 69 facilities that repair cars and trucks.

EPA-NE wants to ensure that we are targeting compliance assistance activities in areas that are
disproportionately impacted by auto body refmishing operations.  We will use the EJ review to
conduct a design assessment focusing on the question:

    •  Are the methods we are currently using and planning to use for autobody sector outreach
       well formulated, feasible and likely to achieve intended goals; and should these targeting
       methods be used (as is or improved) in other compliance assistance outreach
       opportunities for sectors similar to autobody sector?

This review will be completed by the end of FY09. Contacts for the review include Amy Braz,
Roy Crystal and Mary Dever. See logic model in the next section for more detail.

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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
SECTION 2:  KEY PRIORITY AREAS
This section highlights, in performance measures matrices, EPA NE's robust, results-oriented activities or key priority areas for FY09.

Reduction in number of asthma attacks
Activities/
Resources/
/Partners
Asthma Reduction
Activities
Activities:
Work with selected
communities
based on funding
with Healthy
Communities
Grants Program
on innovative
asthma reduction
activities which
improve: asthma
management/care;
infrastructure
among
stakeholders and
provide better
asthma
surveillance data.
Influence health
care financing for
asthma and IPM.

Outreach to
Output
Number of health
professionals
trained.
Number of home and
community visits.

Number of
asthmatics reached
and number of
environmental
asthma messages
incorporated into
asthma management
plans.

Number of home
evaluations and
repairs.
Number of asthma
coalitions or
expansion of existing
infrastructure.

Applicable Outcome Measure
Short-term
(awareness)
Increased
awareness and
better
understanding of
proper asthma
management /care.















Intermediate
(behavior)
Timely asthma
interventions based
on assessment of
surveillance data.


Increased advocacy
among target
audiences as well
as more effective
collaborations
between target
audiences and
stakeholders.

Number of people
taking steps to
imrprove their
indoor environments
and reduce asthma
triggers.

Number of health
plans adopting
environmental
Long-term
(condition)
Reductions over a
period of several
years in the
incidence of asthma
related absences (or
increase in days
present),
unscheduled visits to
the school nurses or
emergency room.

Reduction of
incidence of child
asthma due to
environmental
triggers in schools
using reports of visits
to school nurses.
* Depends heavily on
availability of data
from sources outside
of EPA.



Results
1402 individuals
trained - Region
works with state
asthma managers,
funded partners,
community groups
nvti-J n+l>^mn
and other
organizations to
promote EPA and
other applicable
guidance (i.e.
NHBLI) guidance
on asthma
management,
assist with asthma
awareness and
intervention
programs, and
facilitate state and
local coordination.
115 Schools -
Region works with
state Tools for
Schools contacts,
funded partners,
and other school
Point of
Contact
Eugene
Benoit
Marybeth
Smuts
Rhona Julien

















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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Activities/
Resources/
/Partners
regional partners
and other
stakeholders
Train school
teams to
implement EPA's
Indoor Air Quality
Tools for Schools
Program through
grantee and state
training
opportunities to
prevent and solve
indoor air quality
problems in school
buildings.
Resources:

Asthma projects
under the Healthy
Communities
Grant Program
State asthma
partners
Partnerships:
Support Asthma
Regional
Coordinating
Council
Output

Number of schools
implementing EPA's
Tools for Schools
Program.

Number of Tools for
Schools trainings/
conferences




















APF
Short-term
(awareness)





























>licable Outcome Mea
Intermediate
(behavior)
measures.




























sure
Long-term
(condition)





























Results
organizations to
develop statewide
implementation
programs
following a best-
practices
campaign.
Approx. 450
school
administrators,
school nurses,
teachers and
parents have been
trained on how to
implement TfS
and asthma
triggers in the
classroom.











Point of
Contact






























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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Reduce childhood lead poisoning
Activities/ Resources/
/Partners
Virtually End Childhood
Lead Poisoning in
Boston, MA
Activities
-Data gathering and track
results for public health
and other lead standards
(e.g. air)
-Work with partners to
target education and
outreach to
neighborhoods with
highest remaining lead
poisoning rates
-Target inspections,
compliance assistance
and enforcement actions
in Dorchester, Roxbury,
Hyde Park and Mattapan
-Prioritize SEPs for lead
abatement projects in
Boston, MA
Resources:

- Work with partners
below through the Lead
Action Collaborative to
identify annual project-
Output
- Amount of
financial and
tpr*hnir*fl 1
ICOI II IILrCII
fl^^i^tflnr*p frnm
dooioicii IL/C ii ui 1 1
EPA programs
-Number of tips &
complaints
-Number of
Targeted
inspections,
compliance
assistance and
enforcement
actions in
Dorchester,
Roxbury, Hyde
Park, and
Mattapan
- Increased
membership and
participation in
the Lead Action
Collaborative
- Validated
Community
Assessment Tool
(CAT)
\vt \ i i


Applicable Outcome Measure
Short-term
(awareness)
-Increase
awareness of all
stakeholders
-Partners/
stakeholders and
local residents are
more aware of
areas with elevated
blood lead levels
and are targeting
activities and
resources to
service areas with
the greatest
remaining need
- Targeted mailings
related to
Renovation, Repair
and Painting
Program









Intermediate
(behavior)
-Targeted, annual
compliance
assistance
- Targeted, annual
inspections
- Targeted, annual
enforcement actions
- Stakeholders
implement lead-safe
practices in high risk
neighborhoods
- Lead abatement
workers and
renovators are
properly licensed and
certified.
- Increase
effectiveness of
outreach and
education to meet
diverse needs of
target neighborhood
populations in
Dorchester, Roxbury,
Hyde Park and
Mattapan


Long-term
(condition)
- Virtually eliminate
the number of lead
poisoned children
in Boston by 2010.
(Measured by
annual number of
lead poisoned
children and
maintaining low
levels overtime.)














Results
2001 Baseline: 1,123
children with elevated
blood lead levels in
Boston (10 ug/dl or
higher).
2004: 774 children with
elevated blood lead
levels in Boston
2005: 497 children in
Boston had elevated
blood lead levels.
2006: 460 children in
Boston had elevated
blood lead levels.
2007: 362 children in
Boston had elevated
blood lead levels.










Point of
Contact
Kristi Rea

Nancy
Barmakian
















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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Activities/ Resources/
/Partners
specific resource needs
(financial and technical
assistance).
Partners:
Lead Action Collaborative
(LAC), The Medical
Foundation, Sovereign
Bank, The Barr
Foundation, HUD, CDC,
Lasell College, Boston
Public Health
Commission, Dorchester
BOLD Teens,
Massachusetts
Affordable Housing
Alliance (MAHA), Black
Ministerial Alliance, other
stakeholders in Boston,
MA.
Output



















Applicable Outcome Measure
Short-term
(awareness)



















Intermediate
(behavior)



















Long-term
(condition)



















Results



















Point of
Contact




















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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Reduce pollution in urban environments
Activities
Continue implementing
urban river actions on the
Mystic River Watershed
and its tributaries.
Communities along the
Lower Mystic have
environmental justice
concerns and are
negatively impacted by
poor water quality.
Activities
EPA will continue to work
collaboratively to improve
water quality based on
data and findings of
ongoing sampling and
investigations.
Resources

In 2009, EPA will
contribute significant staff
time and $2K for analytical
support for MyRWA's
baseline sampling
program.
Building Partnerships
Collaborative effort with
EPA, the Massachusetts
Dept. of Environmental
Protection (Mass DEP), the
Output
- EPA will host the
first steering
committee meeting
for watershed
stakeholders
- EPA will continue
to assist MyRWA
with baseline
monitoring and will
provide other
monitoring/sanitary
surveys as
resources allow
- EPA will co-host a
science meeting
with Mystic River
Watershed and
Tufts University
- EPA will continue
its enforcement and
permitting efforts in
watershed
communities
- EPA will issue its
annual report card
that will take into
account new
baseline monitoring
sites in the lower
Mystic


Applicable Outcome Measures
Short-term
(awareness)
-Increase
collaboration
among
watershed
stakeholders
- Bring political
attention to the
challenges in the
lower Mystic
River watershed



















Intermediate
(behavior)
- Increase
effectiveness of
outreach and
education
- Increase
compliance and
enforcement



















Long-term
(condition)
- Make the Mystic
River and its
tributary streams
meet the goals of
the Clean Water Act
- Restore the
watershed to both
fishable and
swimmable
conditions based on
measurable water
quality standards
- Increase public
access to the
waterway.















Baseline/Results
2007: Mystic River
Report Card
Grade = D




















Contact
Caitlyn Hunt
(617)918-1748




















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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

U.S. Coast Guard, the
Mystic River Watershed
Association ("MyRWA"),
the Chelsea Creek
Restoration Partnership
and other communities
along the Mystic River


Applicable Outcome Measures







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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Clean and safe drinking water
Activities
Strategy to address
future workforce
shortages for water
operators
Note: The identified
activities, outputs, and
outcomes will be
implemented over the
next several years.
InFYOS, EPA NE will be
exploring the
implementation of these
proposed activities and
identifying ways to
expand efforts for
wastewater operators.
Activities
To the greatest extent
possible, target the
following activities to
historically underserved or
burdened populations:
• Expand MA vocational
technical schools
project or develop new
program in another
state to embed
drinking water
treatment and
Output

# of drinking water
treatment and
operations courses
offered in technical
high schools and
community colleges.

# of new certified
drinking operators
trained.

# of career fairs.

# of outreach
materials
developed.












Applicable Outcome Measures
Short-term
(awareness)

Raise awareness
about operators'
workforce
opportunities





















Intermediate
(behavior)
Increase in
students enrolled in
wastewater and
drinking water
treatment and
operations courses

Increase in certified
water operators



















Long-term
(condition)
Maintain safe water
by having
knowledgeable
certified operators





















Baseline/Results

FY09 - determine
the feasibility of
implementing this
strategy.





















Contact
Jane Downing
Katie Connors
Jackie LeClair





















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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

operations courses into
technical high schools
and community
colleges (certification
programs will be
targeted to academic
programs and
institutions that serve
communities with
environmental justice
concerns.
• Work with partners to
offer career Fairs that
bring together drinking
water professionals
and regulators with
students and guidance
counselors.
• Develop outreach and
marketing materials to
raise awareness about
drinking water
professional
opportunities.
Building Partnerships
• OGWDWand EPANE
Brownfield Job
Training Program
• States' Drinking Water
programs
• National, regional, and
state water works
associations (e.g.
AWWA, NEWWA)

















Applicable Outcome Measures


















































































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   EPA New England's Environmental Justice
   Action Plan For Fiscal Year 2009
                                                         Applicable Outcome Measures
Work with national
associations such as
Water Systems
Council and National
Ground Water
Association to reach
out to professional well
drillers to raise
awareness of
operators workforce
opportunities and
promote cross-training
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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
Ensuring Compliance
Activities
Diesel Idling
Enforcement and
Compliance Assistance
NOTE: This work is part of
a larger OES/OEP strategy
to reduce diesel emissions.
OES outreach under the
National Clean Diesel
Campaign's SmartWay
Transport and Clean Ports
USA programs is not
represented here because
they are not oriented
toward compliance.

OES will focus compliance
assistance and
enforcement of state anti-
idling regulations where
EPA has authority (MA, CT
and Rl) on urban areas &
areas of potential EJ
concern (e.g., CARE
cities).
ENFORCEMENT:
-Inspect fleets and
facilities where chronic,
widespread, excessive
idling of diesel vehicles is
reported or suspected.
-Take informal and formal
Output
ENFORCEMENT
-Inspections
-Enforcement
actions
-SEPs
COMPLIANCE
ASSISTANCE
-Phone calls,
emails, letters, visits
-Meetings,
presentations,
events, handouts
BOTH
-Enforcement press
releases
-Info on EPA NE
Diesel website







Applicable Outcome Measures
Short-term
(awareness)
#OF
REGULATED
ENTITIES
-inspected
-enforced
against
-proposing SEPs
-receiving
individual
attention
-in audiences
receiving info

# OF NON-
REGULATED
ENTITIES
-receiving
individual help
-in audiences
receiving info







Intermediate
(behavior)
# OF REGULATED
ENTITIES
-asking for
information
-passing on
information
-reporting increase
in compliant
behavior
-implementing
SEPs

# OF NON-
REGULATED
ENTITIES
-leveraging state
and EPA authority
-doing their own
compliance
outreach







Long-term
(condition)
Air pollution from
idling diesel-
powered vehicles is
reduced, particularly
near urban
populations
particularly
vulnerable to
asthma and other
illnesses to which
diesel exhaust
contributes.










Results
(2006-2008)
ENFORCEMENT:-
228 Inspections
-15 Informal
enforcement actions
-6 administrative
and judicial
settlements
-4 Referrals to DOJ
-$331,601 SEP$
-$427,332 Penalty $
-37,832 tons of
pollutants avoided
COMPLIANCE
ASSISTANCE:

-20 tools developed
-70 individual
situations addressed
-50 audiences
reached
BOTH:
-6 Press releases







Contact
Joel Blumstein











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       EPA New England's Environmental Justice
       Action Plan For Fiscal Year 2009
                                                            Applicable Outcome Measures
enforcement actions
against violators.

-Encourage opportunities
for respondents to conduct
SEPs.

COMPLIANCE
ASSISTANCE:

-Respond to individual
complaints & inquiries by
working with offender and
authorities to obtain
compliance.

-Fold compliance info into
all outreach to fleets and
facilities under the
SmartWay Transport and
Clean Ports USA  voluntary
programs.

-Help write and broadcast
press on enforcement
actions to appropriate
regulated audiences and
partners.

Resources:

A&P2: .25 FTE

Enforcement: .50  FTE

Building Partnerships:

- Within EPA NE: Part of
larger cross-office diesel
strategy.

- Within EPA: Leverages
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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009

partnership programs.
- Within Region:
Collaboration with states,
municipalities,
business/industry,
institutions and nonprofits
to address cause of
violations, identify
alternatives, and obtain
compliance.






Applicable Outcome Measures



























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EPA New England's Environmental Justice
Action Plan For Fiscal Year 2009
EJ Review of Auto Body Assistance Program
Resources
Activities     Outputs
              Customers
Short-Term
Intermedi
Long-Term
•FTE:
Regional CA
OECA&
OPEI
program
evaluation
expertise
• GIS support
• In-house
graphic
design
•In-house
statisticians

Need:
•Extramural
funds to
support
survey
design,
implementa-
tion &
analysis
•OMB
approval of
pilot
methodolo-gy
&ICRs
  A1ID
  target
  universe &
  create maps
  to target
  assistance
Ol Universe list
and mailing list
created
                     O2 GIS maps
                     w/hot spots ID'd
                     O3 Educational
                     & Training
                     material created,
                     distrib'd
                     O4 # Workshops
                     conducted
                     # Shops trained
                     # Techs trained
                     # others trained
                     O5 # Onsite visits
                     conducted
                     O6 # Compliance
                     notification
                     reviews
                     performed
                        /C2 Trade
                         assns, paint
                         mfrs &
                         distributors
                         , voc tech
                         school auto
                        Vprogs
        ST1 Increase
        knowledge of
        req'ts by target
        audiences
        ST2 Increase
        knowledge of
        P2 & BMP
        options by
        target audiences
        ST3 Increase
        knowledge of
        how to conduct
        self assessment
        to determine
        compliance
        status
                                                                   18
                                            ST4 Increase
                                            knowledge of
                                            how to calculate
                                            emissions &
                                            pollution
                                            reductions
                                                                                   ST5 Increase
                                                                                   knowledge of
                                                                                   how to petition
                                                                                   for exemption
        II Shops provide
        compliance
        notifications by
        2010,2011
                                                                  covenng 7
                                                                  requirement
                                                                  categories ID
                                                                  above in goal 2.
                               12 Shops petition
                               for exemption
                               from Rule
                                                                  13 BMPs & P2
                                                                  practices adopted
                                                                  by shops (DIE &
                                                                  P2RX Ctr)
                               14 Reduction of
                               use of metal HAP
                               coatings
                                                                                                          15 Reduction of
                                                                                                          solvent use
                                                                                       16 Shops switch to
                                                                                       water-based or
                                                                                       other non-HAP
                                                                                       coatings
          LT1 Shops
          reduce
          emissions of
          HAP coatings

          LT2 Reduce or
          eliminate risks
          to communities
          and workers
          posed by HAP
          Coatings
                               LT3 Paint Mfrs
                               completely
                               eliminate HAP
                               coatings for
                               automotive
                               refinishing

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