d EPA United States Environmental Protection Agency Office Of Policy And Reinvention (2131) EPA 233-R-01-001 July 2001 Status Of The State Small Business Stationary Source Technical And Environmental Compliance Assistance Program (SBTCP) Report To Congress For The Period January to December 1999 ------- REPORT TO CONGRESS STATUS OF THE STATE SMALL BUSINESS STATIONARY SOURCE TECHNICAL AND ENVIRONMENTAL COMPLIANCE ASSISTANCE PROGRAM (SBTCP) FOR THE REPORTING PERIOD JANUARY - DECEMBER 1999 PRESENTED BY: KAREN V. BROWN SMALL BUSINESS OMBUDSMAN OFFICE OF THE SMALL BUSINESS OMBUDSMAN U.S. ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC JULY 2001 ------- ACKNOWLEDGMENTS The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is grateful for the support of the dedicated staff of the State Small Business Stationary Source Technical and Environmental Compliance Assistance Programs (SBTCPs), including the Small Business Ombudsmen (SBOs), Small Business Assistance Programs (SBAPs), and the Compliance Advisory Panels (CAPs) in the preparation of this fourth Report to Congress. All states and territories submitted timely reports to make this report complete and comprehensive. i ------- TABLE OF CONTENTS Page ACKNOWLEDGMENTS i LIST OF COMMON ACRONYMS vii EXECUTIVE SUMMARY ix 1.0 INTRODUCTION AND REPORT OVERVIEW 1 -1 1.1 Rationale and Objective of the Report to Congress 1-1 1.2 Data Collection Methodology 1-1 1.3 Pilot Online Data Collection System 1-3 1.4 Report Organization 1-4 2.0 OVERVIEW OF THE SBTCP 2-1 2.1 Background 2-1 2.2 Small Business Ombudsman 2-2 2.3 Small Business Assistance Program 2-2 2.4 Compliance Advisory Panel 2-3 2.5 EPA's Responsibilities Under Section 507 of the CAA 2-3 2.6 Small Business Assistance Cooperative Agreement Program 2-4 2.7 Federal Small Business Assistance Program 2-5 3.0 SBTCP STATUS, BUDGETS, STAFFING AND ORGANIZATION 3-1 3.1 Operating Status 3-1 3.2 Budgets 3-2 3.3 Staffing Levels 3-8 3.4 Administrative Locations of SBO and SBAP Components 3-9 4.0 SBTCP ACTIVITIES AND SERVICES 4-1 4.1 Industry Sectors Assisted by the SBTCPs 4-1 4.2 Activities and Services 4-4 4.3 Assistance Requests 4-8 4.4 Cap Activities and Services 4-9 4.5 Financial Assistance Programs 4-10 4.6 Minimizing Duplication of Efforts 4-11 4.7 SBTCP Compliance with Section 507(d)(2) 4-13 5.0 PROGRAM EFFECTIVENESS 5-1 5.1 Program Goals 5-1 5.2 Program Highlights and Accomplishments 5-4 5.3 Tips and Barriers 5-6 5.4 Success Stories and Case Studies 5-7 iii ------- TABLE OF CONTENTS (continued) Page 6.0 COMPLIANCE ASSURANCE ISSUES 6-1 6.1 Common Compliance Problems 6-1 6.2 Compliance Problems in Particular Industry Sectors 6-2 6.3 Recommended Changes to Facilitate Small Business Compliance with the CAA 6-3 6.4 Program Confidentiality and Conflict of Interest 6-5 6.5 Use of EPA's Small Business/Small Communities Policy 6-6 LIST OF TABLES Table No. Title Page 1-1 Online Reporting Pilot Participants 1-4 3-1 Operating Status of the SBTCP Components 3-1 3-2 Start of Operations for SBTCP Functions 3-2 3-3 1999, 1998, and 1997 SBTCP Operating Budget Ranges 3-3 3-4 SBTCP Reporting Period Budget Comparisons 3-4 3-5 1999 SBO Operating Budget Ranges 3-6 3-6 1999 SBAP Operating Budget Ranges 3-7 3-7 1999 CAP Operating Budget Ranges 3-7 3-8 1999 Staffing Levels (as FTEs) Serving the SBO & SBAP Functions 3-8 3-9 CAP Appointments 3-9 3-10 Administrative Locations of SBO and SBAP 3-9 3-11 Regulatory/Nonregulatory Locations of SBO and SBAP 3-10 4-1 Top 10 Industry Sectors Assisted 4-2 4-2 Top 10 Industry Sectors Assisted by Programs 4-2 4-3 Industry Sectors Targeted for Assistance 4-3 4-4 Outreach Activities and Businesses Reached 4-4 4-5 Notable Outreach Strategies 4-6 4-6 Information Available on Internet Home Pages 4-7 4-7 Air-only Versus Multimedia Assistance 4-8 4-8 CAA/Multimedia Assistance Requests 4-9 4-9 Major CAP Activities 4-10 4-10 Financial Assistance Programs 4-11 4-11 Programs That Report Cooperative Efforts for SBTCP Functions 4-12 4-12 SBTCP Mechanisms for Avoiding Duplication 4-13 4-13 SBTCP Activities to Follow the Intent of the Paperwork Reduction Act 4-15 4-14 SBTCP Activities to Follow the Intent of the Regulatory Flexibility Act 4-15 iv ------- TABLE OF CONTENTS (continued) Table No. Title Page 4-15 SBTCP Activities to Follow the Intent of the Equal Access to Justice Act 4-16 5-1 Program Goals 5-2 6-1 Common Compliance Problems 6-1 6-2 Compliance Problems in Industry Sectors 6-2 6-3 Industry Sector Appearance in Compliance Categories 6-3 6-4 1999 SBTCP Recommendations for Improving Compliance 6-4 6-5 Small Business/Small Community Policy Use 6-6 6-6 Small Business Policy Activities 6-7 APPENDICES A 1999 SBTCP Reporting Form B Federal Small Business Ombudsman C Federal Small Business Assistance Program D SBTCP Status, Budgets, Staffing, and Organization E SBTCP Activities and Services F Program Effectiveness G Compliance Assurance Issues v ------- Page Intentionally Blank vi ------- LIST OF COMMON ACRONYMS Below is a list of major abbreviations and acronyms that are commonly used in this report. BACT Best Available Control Technology BACM Best Available Control Measures CAA Clean Air Act as amended in 1990 CAP Compliance Advisory Panel COI Conflict of Interest EMS Environmental Management System EPA Environmental Protection Agency FESOP Federally Enforceable State Operating Permit FTE Full-time Equivalent HAP Hazardous Air Pollutant ICR Information Collection Request LAER Lowest Achievable Emission Rate MACT Maximum Achievable Control Technology MOU Memorandum of Understanding MSDS Material Safety Data Sheet NAAQS National Ambient Air Quality Standards NESHAP National Emission Standard for Hazardous Air Pollutants NOV Notice of Violation NOx Nitrogen Oxides NSPS New Source Performance Standards NSR New Source Review vii ------- OECA Office of Enforcement and Compliance Assurance OMB Office of Management and Budget P2 Pollution Prevention PERC Perchloroethylene PM Particulate Matter PTE Potential to Emit RACT Reasonably Available Control Technology RCRA Resource Conservation and Recovery Act RMP Risk Management Plan SBA Small Business Administration SBAP Small Business Assistance Program SBDC Small Business Development Center SBO Small Business Ombudsman SBREFA Small Business Regulatory Enforcement Fairness Act SBTCP Small Business Stationary Source Technical and Environmental Compliance Assistance Program SIC Standard Industrial Classification SIP State Implementation Plan UST Underground Storage Tank VOC Volatile Organic Compound viii ------- EXECUTIVE SUMMARY The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman (SBO) is pleased to submit this fifth Report to Congress describing the activities and accomplishments of the state Small Business Stationary Source Technical and Environmental Compliance Assistance Programs (SBTCPs) during the reporting period, January 1 - December 31, 1999. This report is being submitted in accordance with Section 507(d), Monitoring, of the Clean Air Act, as amended in 1990 (CAA), which directs EPA to provide Congress with periodic reports on the status of the SBTCPs. This oversight responsibility has been delegated by the EPA Administrator to EPA's Small Business Ombudsman (SBO). The Report also includes a general report on the EPA SBO's actions to monitor the SBTCPs. This report addresses two of the EPA SBO's key oversight responsibilities: • Render advisory opinions on the overall effectiveness of the SBTCPs, difficulties encountered, and degree and severity of enforcement [507(d)(1)], • Make periodic reports to Congress on compliance of the SBTCPs with the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act [507(d)(2)], The SBTCPs are designed to assist small businesses comply with the requirements of the CAA through state-operated programs. Each SBTCP is required to include three components or functions: an SBO, a Small Business Assistance Program (SBAP), and a Compliance Advisory Panel (CAP). SBTCP staff members continue to fill an important role as facilitator or mediator between small business owners/operators and regulatory agencies, enhancing communication to promote understanding and sensitivity on both sides. Based on the information reported, improvements in compliance occur because businesses have someone to turn to for assistance and advice, and to act as an effective liaison with regulatory agencies. ix ------- During this fifth year of monitoring the SBTCPs, 920,384 small businesses have been reached (as tallied by assistance efforts to specific industry sectors). This is slightly lower than the 1,002,445 reported in 1998. Beginning in 1998, the number of businesses assisted was tallied both by industry sector and eight separate types of assistance. This format more fully captures the true picture of businesses assisted by the programs. Many programs have improved their recordkeeping strategies, resulting in higher quality and more comprehensive data. SBTCP operational growth has stabilized over the past several years. All states and territories have SBAPs. Only Massachusetts and Vermont are without SBOs. However only 43 programs have operational CAPs. While some states have been working to establish a CAP and obtain CAP appointments, several states have not begun to initiate the CAP function. Budgets for the SBTCPs have a wide range from $5,000 to over $1.3 million for 1999. As programs mature and the cost of establishing programs stabilize, more programs are projecting fairly consistent budgets for the next reporting period (38 this year versus 41 last year). Ten programs project budget increases for 2000, up from six last year. Ninety-eight percent of SBTCPs provided specific information on their assistance to 72 industry sectors in eight assistance categories The top ten industry sectors receiving assistance by SBTCPs in 1999 were: TOP 10 INDUSTRY SECTORS ASSISTED Cross Sector* Other (not classified)* Organizations/Associations* Auto/Body Maintenance, Repair, Refinishing* Auto/Motor Vehicles & Equipment Dry Cleaning/Laundry Services* Machine Shop Government* Furniture Manufacturing/Repair/Wood Finishing Attorney/Consultant/Engineer Note *: Also in the top 10 in 1998. X ------- The top ten industry sectors that received assistance from the most programs were: TOP 10 INDUSTRY SECTORS ASSISTED BY PROGRAMS Dry Cleaning/Laundry Services* Auto/Body Maintenance, Refinishing, Repair* Printing/Graphic Arts* Furniture Manufacturing/Repair/Wood Finishing* Organizations/Associations* Other Government* Metal Fabricating/Finishing* Agriculture/Farming/Crop Service Attorney/Consultant/Engineer* Note *: Also in the top 10 in 1998. Toll-free hotlines, on-site visits, seminars, mailings, and publications are among the wide range of outreach mechanisms used to serve the small business community. Other state-of-the-art outreach activities, such as Internet home pages, are seeing increased use. Programs also noted outreach strategies they found to be particularly effective in assisting small businesses. At least ten programs each mentioned the following strategies: workshops (21 programs), direct mailings (16), on-site visits and direct contact (14), and cooperative efforts (14). From year to year, programs have stressed the value of direct contact in building trust and confidence in the business community. Because of their nature, on-site visits and workshops typically reach fewer businesses than "mass" outreach strategies like mailings and publications. However, programs indicate that the quality of the contacts made through direct interaction between business owner and technical assistance provider can lead to improved compliance. While the CAA called for the establishment of SBTCPs for air-related issues, a number of states began their programs as multimedia (offering assistance with water, solid and hazardous waste, etc. in addition to air); more have transitioned their programs to multimedia. Thirty-seven programs indicated they have a full or partial multimedia assistance focus. Their small business clients need and expect it. Small businesses xi ------- appreciate "one stop shopping" for their compliance and technical assistance questions, rather than working through numerous media-based departments. Thirty-seven of the 43 operational CAPs provided information on a variety of their activities. Primary CAP activities were reviewing new and proposed regulations, state legislative actions, and SBTCP documents. CAPs are pursuing many diverse avenues in becoming effective partners in the technical assistance programs. The unique roles and specialized skills of the members make them valuable resources in SBTCP development. The value-added activities of these CAP members underscore the need for states still without operational CAPs to complete the appointment/reappointment process and initiate the CAP function. Seventy-nine percent of SBOs (down from 83 percent in 1998), 94 percent of SBAPs (up from 91 percent in 1998), and 58 percent of CAPs (up from 51 percent in 1998) report some sharing of resources within their state/territory. Generally, programs recognize the efficiency and value of coordinating their efforts with each other and also with environmental agency departments, state agencies, and other organizations. All programs report actions to minimize duplication of efforts among SBTCPs. Sharing information is a practical approach to maximizing program efficiency while enhancing the cost-effectiveness of funding spent on individual programs. Section 507 directs EPA's SBO to monitor the SBTCPs' efforts to follow the intent of the provisions of the Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts. • Ninety-four percent of programs report taking specific actions associated with the Paperwork Reduction Act, with the most common action being receiving and providing information electronically. • Eighty-nine percent of programs report taking specific actions consistent with the intent of the Regulatory Flexibility Act. The primary activities by programs were ensuring that small businesses could participate in rulemaking and reviewing SBTCP documents for compliance. • Seventy-nine percent of SBTCPs reported specific actions similar to those associated with the Equal Access to Justice Act. Most commonly mentioned were routinely reviewing SBTCP documents for compliance and reviewing xii ------- instances where state actions against small businesses appear unjustified. The number of programs reporting specific actions to follow the intent of the provisions of these Acts has been growing since 1996. Their actions appear to be better targeted to the specific intent of each Act and in addressing the unique needs of small businesses. As a new reporting element for 1998, programs were asked to define and prioritize their own program goals. They also were asked to discuss strategies to evaluate their goals and the results of this measurement process. Increasing understanding of environmental obligations and improving compliance rates were the two most frequently listed goals (both this year and last). For evaluation, most programs focused on the number of businesses reached and the types of assistance offered to measure their success. Measuring compliance improvements has been attempted by only a few states to date. All SBTCPs provided insight on compliance issues addressed while providing technical assistance to small businesses. The two most common compliance problems mentioned by small businesses were, "Not understanding the regulatory requirements," and "incomplete recordkeeping." The former has been the number one compliance problem cited for the last four years. Compliance issues have remained consistent from year to year. Identifying key problems and gaps in understanding by the small businesses have helped the SBTCPs to best target their assistance efforts. ------- Thirty-eight SBTCPs provided recommendations for changes to facilitate small business compliance with the CAA as outlined below. SBTCP RECOMMENDATIONS FOR IMPROVING COMPLIANCE Increased funding/continued adequate funding for SBTCPs Allow flexibility/simplification in applying regulations to small businesses Simplify paperwork/reporting requirements Regulations written in plain English Grants/loans for small businesses Multimedia assistance Generic outreach and training materials Expand/facilitate effective communication between state and federal agencies Develop compliance incentives Develop a national public relations/advertising program Clean and simple audit privileges/voluntary disclosure policies Programs were asked to describe how their SBTCP avoids internal or external conflicts of interest or the perception that their program may not be confidential. Eighty-nine percent of programs reported no problems concerning confidentiality or with conflict of interest issues during the course of providing services regardless of whether a confidentiality policy is in place. Program structures range from a guarantee of confidentiality (most common) to offering no confidentiality. Many programs have policies that protect small businesses from penalties if violations are discovered during the course of their receiving technical assistance. Finally, programs were asked how they used EPA's Policy on Compliance Incentives for Small Businesses or a comparable state policy for small businesses/small communities. Very few states are making use of this policy or developing their own. Eighteen states indicated that either the small business EPA or state policy has been adopted, but only two states indicated the policy has been put to use. Three programs have adopted a small communities policy, but none reported any use. Programs likely are not yet tracking such statistics, as evidenced by the high number of programs not answering this question. Overall, the SBTCPs offer important one-on-one contacts, provide valuable information such as the need to have operating permits, maintaining records, compliance options, pollution prevention technologies and techniques, and compliance requirements. This xiv ------- assistance enables small businesses to arrive at informed decisions and more effectively come into compliance. CONCLUSIONS AND RECOMMENDATIONS • As has been noted since 1995, SBTCPs are being run by hardworking, dedicated staffs who operate successful programs with what they report to be often limited budgets and resources. Small businesses are grateful for the technical assistance and personalized attention from people they can trust. In this fifth year of gathering information from the programs, over 920,000 small businesses have been reached (as tallied by industry sector). • SBTCPs facilitate dialog between the small business community and the regulatory community, fostering trust, and improving attitudes and awareness towards regulatory compliance. • SBTCPs have significant expertise and are increasingly becoming multimedia as states want to offer this type of assistance, and small businesses are requesting it. Programs are seeking ways to expand the scope and quality of the services they offer and the means to fund the enhanced services. To maximize their budgets and staffing capabilities and to minimize duplication of effort, programs are encouraged to use the resources of the federal SBO and SBAP plus those developed by other SBTCPs. • Again in 1999, commonly identified compliance problems include not understanding regulatory requirements and improper recordkeeping. Many current SBTCP activities are designed to remedy such problems. The concerns regarding these problems underscore the critical role of the SBTCP in providing vital technical assistance and promoting compliance by establishing trust and greater understanding. • In conducting the Federal program, EPA has followed the requirements of the Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts. EPA's SBO has monitored SBTCP activities for following the intent of the provisions of these three Acts. The number of programs reporting specific activities associated with these Acts has significantly increased in the past several years. The careful review of SBTCP documents and the development of simplified forms and permits are among the positive actions implemented to fulfill the intent of the Acts. • Program activities primarily emphasize mechanisms to reach larger audiences (e.g., mailings, hotlines). However, one-on-one assistance has been reported as a key method in bringing small businesses into compliance, and programs are encouraged to increase their emphasis on personalized assistance. Allocation of adequate resources to permit on-site visits by program staff is important. On-site xv ------- visits (as tallied by industry sector) totaled 9,103, down from more than 14,600 in 1998. • Efficiency of information transfer (among SBTCPs and to small businesses) can be realized through the increased use of Internet home pages. Presently, 50 programs operate a home page. Programs again are encouraged to explore the potential of the Internet for sharing information with small businesses and with other SBTCPs. • Only 15 percent of SBTCPs reported the availability of financial assistance programs in 1999, down from 21 percent last year. Small businesses have expressed their need for creative financing mechanisms. Programs are encouraged to explore the potential for sponsoring or facilitating financial assistance programs for pollution control or pollution prevention capital expenses and to use existing financial programs as models. • SBTCPs report that they are often under funded and understaffed as they provide their current level of services. Because of this, they may be challenged to expand their function both in air-related outreach and multimedia technical assistance. EPA could develop Interagency Personnel Agreements to provide staff to states that are shorthanded or need assistance in revitalizing their programs. • SBTCPs are encouraged to better utilize the expertise of their CAP members to enhance improvements in their technical assistance programs. As has been noted in the four previous Reports, several states still do not have operational CAPs. A number of CAPs also need to address vacancies of the CAP due to expired terms. • The current system of CAP appointments by state governor and legislature slows or hinders CAP progress and development. This system should be revised to simplify CAP appointments or states could pursue the formation of advisory bodies with similar functions. • The annual SBO/SBAP conference (held in Tampa, FL in 1999) is a perfect networking opportunity for program staff and CAP members from across the country. Working groups could be convened at this conference to address specific issues identified in this Report, and to develop recommendations to EPA and Congress on SBTCP operations. • EPA's Small Business Cooperative Agreement Program provides a much needed infusion of funds to SBTCPs. This grant program will nurture innovative approaches to small business assistance and facilitate information transfer to other state assistance programs. Without such funding, many of the grant recipients may not have been able to pursue their projects. xvi ------- 1.0 INTRODUCTION AND REPORT OVERVIEW 1.1 RATIONALE AND OBJECTIVE OF THE REPORT TO CONGRESS The U.S. Environmental Protection Agency's (EPA's) Small Business Ombudsman is pleased to submit this Report to Congress describing the accomplishments and activities of the state and territory Small Business Stationary Source Technical and Environmental Compliance Assistance Programs (SBTCPs) during the January 1 - December 31, 1999 reporting period. This is the fifth Report to Congress on this important program designed to help the small business community understand and cost-effectively comply with the requirements of the Clean Air Act (CAA) as amended in 1990. This report is submitted in accordance with Section 507(d), Monitoring, of the CAA, which directs EPA to provide Congress with periodic reports on the SBTCPs. This oversight and reporting responsibility has been delegated by the EPA Administrator to the EPA Small Business Ombudsman (SBO). This report is intended to address two of the EPA SBO's responsibilities with respect to the SBTCPs. 1. Render advisory opinions on the overall effectiveness of the SBTCPs, difficulties encountered, and severity of enforcement [507(d)(1)], 2. Make periodic reports to Congress on compliance of the SBTCPs with the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act [507(d)(2)], 1.2 DATA COLLECTION METHODOLOGY Information to assess the SBTCPs was collected through a relatively simple, standardized Reporting Form, which is designed to streamline the reporting process. During the fall of 1994, EPA's SBO, with assistance from SBTCP personnel, developed the criteria for a standardized Reporting Form. A draft Form was distributed to the state 1-1 ------- programs for review in November 1994, and the Form was further refined during the National SBO/SBAP Conference in January 1995. Programs also were asked to comment on EPA's Office of Enforcement and Compliance Assurance's (OECA's) sample questions regarding compliance assessment. In March 1995, EPA's SBO applied for Information Collection Request (ICR) Approval from the Office of Management and Budget (OMB) for the Reporting Form. The Form subsequently was approved and was assigned OMB Number 2060-0337, expiration date July 31, 1998. In June 1998, the EPA SBO submitted a request for ICR renewal. State program representatives conducted a lengthy review and revision process of the Reporting Form. Questions were streamlined, several redundant and less pertinent questions were eliminated, and other questions were added at the request of the states. OMB approved the renewal request, and the Form was assigned OMB Number 2060-0337, expiration date September 30, 2001. In December 1999, EPA's SBO distributed copies of the SBTCP Annual Reporting Form (for the reporting period January through December 1999) to state/territory SBTCP contacts (primarily SBOs). These contacts were requested to coordinate completion of this Form among their SBO, SBAP, and CAP. The Reporting Form was provided in hard copy and on computer disk for ease of completion and to reduce the reporting burden. A copy of the 1999 SBTCP Reporting Form is enclosed as Appendix A. Programs were not asked to create information that they did not have; therefore, some SBTCPs were not able to answer all questions posed. Based on the information requested in the Reporting Form from the first year of reporting, programs were encouraged to revise the types of statistics they track in subsequent years to simplify completing future reports. Programs were asked to complete and submit the Form to the EPA's SBO by February 15, 2000. The information provided in the Forms was compiled and analyzed to produce this report. The 50 states, plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands, submitted 1999 SBTCP Reports (53 programs total) to EPA's SBO. 1-2 ------- In addition, California and Kentucky have distinct air quality districts or counties with regulatory jurisdiction within their states, which also submitted full or partial reports. For California, the South Coast Air Quality Management District submitted a full report, and a number of air quality districts provided various levels of general information, primarily in narrative formats. For Kentucky, Jefferson County submitted a partial report. For statistical purposes of this report, data from states that submitted multiple reports have not been combined except where noted. Raw data for the separate air quality districts are shown in the appendices. Percentages have been rounded. According to the Federal Register of November 13, 1996, Volume 61, Number 220, Pages 58284-94, EPA promulgated a direct final rule conditionally exempting the Territory of American Samoa, the Commonwealth of the Northern Mariana Islands (CNMI), and the Territory of Guam from the requirements of Title V of the CAA. Therefore, reports were not received from American Samoa, CNMI, and Guam. 1.3 PILOT ONLINE DATA COLLECTION SYSTEM A new program to further streamline the reporting process was piloted for the 1999 reporting year. Twenty-two SBTCPs volunteered to complete and submit their reports online; participating programs are listed in Table 1-1. The reporting form was converted to an online format, accessible through a conventional Internet browser. Each pilot participant received a confidential login and password to open his or her secure form. Participants could answer questions by typing information, ticking check boxes, and selecting choices from drop down menus. They could save their responses, edit them at any time, and print their form. Technical assistance through Concurrent Technologies Corporation (CTC), Johnstown, PA, developer and host to the online reporting system, was always available to the pilot participants. 1-3 ------- TABLE 1-1 ONLINE REPORTING PILOT PARTICIPANTS Florida Missouri Oregon Vermont Hawaii Montana Pennsylvania Virginia Kentucky Nebraska Rhode Island Wisconsin Louisiana New Hampshire South Carolina Wyoming Maine New Jersey South Dakota Minnesota Ohio Texas Once participants were satisfied with their answers, they locked and submitted their form for processing. Participants provided valuable feedback on the usability of the form, which enabled CTC to make corrections and refinements to the system. Full implementation of the online reporting system for all 53 states and territories is scheduled for the 2000 reporting year. 1.4 REPORT ORGANIZATION This report is organized into six main sections, the Executive Summary, and Appendices, which include the specific information and data as provided by the individual SBTCPs. Section 1.0 Section 2.0 Introduction and Report Overview Overview of the SBTCP - This section provides an overview of the three components of the SBTCP (i.e., the SBO, the SBAP, and the CAP) as well as EPA's responsibilities under Section 507. Information on the 1999 Small Business Assistance Cooperative Agreement Program is included. Section 3.0 SBTCP Status, Budgets, Staffing, and Organization - This section encompasses these four categories of information about the SBTCPs. 1-4 ------- Section 4.0 SBTCP Activities and Services - In this section, assistance to industry sectors and the types and levels of services provided by the SBTCPs are discussed including efforts to comply with the Paperwork Reduction, Regulatory Flexibility, and Equal Access to Justice Acts. Financial assistance program information also is included. Section 5.0 Program Effectiveness - Program goals and evaluation strategies are discussed. General information on some of the accomplishments and highlights of the programs in 1999 are outlined. Program tips and barriers plus success stories and case studies also are included. Section 6.0 Compliance Assurance Issues - Information on the effectiveness of the SBTCPs in providing compliance assistance support to state small businesses is provided in this section. Recommendations to facilitate compliance and confidentiality issues are discussed. Finally, programs report on their use of EPA's Small Business/Small Communities Policy. 1-5 ------- 2.0 OVERVIEW OF THE SBTCP 2.1 BACKGROUND Congress recognized the particular problems that many small businesses would have in dealing with the CAA's complex requirements. A typical small business employs fewer than 50 people and is the only business operated by the owner - it is the corner dry cleaner, the "mom and pop" bakery, the auto repair shop, the tool and die company, or one of a host of other local business establishments. Many small businesses have been in the same family and neighborhood for generations. To a small business owner, air pollution control regulations may seem very complex. Many may not be able to afford to hire lawyers or environmental specialists to interpret and comply with all the requirements they may be responsible for in the Act. Most may be hard pressed to learn about even basic requirements and deadlines that affect them, let alone the more complicated issues they have to address to control air emissions, such as: • The types of pollutants their company emits that are subject to the Act's requirements. • The methods they can use to estimate emissions for a permit application. • The types of control technologies that are best and least costly for controlling a specific production process or chemical substance they use to make goods and services. • Process or substance substitutes they can use to prevent or reduce emissions. As part of Section 507 of the CAA, the U.S. Congress mandated that each state/territory establish an SBTCP to assist small businesses comply with the requirements of this Act through state-operated programs. Each SBTCP (also commonly referred to as a "Section 507 program") is required to include the following three components or functions: • Small Business Ombudsman (SBO) • Small Business Assistance Program (SBAP) • Compliance Advisory Panel (CAP). 2-1 ------- The CAA also required states/territories to develop a State Implementation Plan (SIP) for implementing an SBTCP by November 1992. Congress envisioned that these programs would be in place before small businesses began to feel the direct effects or deadlines of the Act. As of December 31, 1999, 50 of 53 states/territories (94 percent) had received approval from EPA for their SIPs implementing Section 507 of the CAA. States/territories whose SIPs have not yet been officially submitted and/or approved are: • Hawaii - not yet submitted • Rhode Island - submitted, but not approved • Vermont - submitted draft. 2.2 SMALL BUSINESS OMBUDSMAN The state/territory SBOs serve as the small business community's representative where small businesses are impacted by the CAA. The SBO's key responsibilities may include: • Reviewing and providing recommendations to EPA and state or local air pollution control authorities regarding development and implementation of regulations impacting small businesses. • Disseminating information about upcoming air regulations, control requirements, and other matters relevant to small businesses. • Referring small businesses to appropriate specialists for help with specific needs. • Conducting studies to evaluate the effects of the CAA on state and local economies, and on small businesses generally. 2.3 SMALL BUSINESS ASSISTANCE PROGRAM The SBAPs are the technical and administrative support component within the state governments. The SBAPs have access to air quality experts, technically proficient engineers, scientists and managers, and environmental specialists who provide information and assistance to small businesses on matters of: • Determining applicable requirements under the Act and permitting assistance • The rights of small businesses under the Act • Compliance methods and acceptable control technologies 2-2 ------- • Pollution prevention and accidental release prevention and detection • Audit programs. 2.4 COMPLIANCE ADVISORY PANEL The CAPs are created at the state level and are comprised of at least seven members: • 2 members who are not owners of small business stationary sources - selected by the Governor to represent the public. • 2 members who are owners of small business stationary sources - selected by the lower house of the state legislature. • 2 members who are owners of small business stationary sources - selected by the upper house of the state legislature. • 1 member from the state air pollution permit program - selected by the head of that agency. The responsibilities of the CAP are to: • Render advisory opinions concerning the effectiveness of the SBTCP, difficulties encountered, and degree and severity of enforcement. • Report on the compliance of the SBTCP with the intent of the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act. • Submit periodic reports to EPA's SBO. • Review information for small business stationary sources to ensure it is understandable to the layperson. 2.5 EPA SBO's RESPONSIBILITIES UNDER SECTION 507 OF THE CAA Section 507(d), Monitoring, directs the EPA to monitor the SBTCPs and to provide a report to Congress. This responsibility has been delegated to EPA's SBO, whose oversight duties are to: • Render advisory opinions on the overall effectiveness of the SBTCP, difficulties encountered, and degree and severity of enforcement [507(d)(1)], • Make periodic reports to Congress on the compliance of the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act [507(d)(2)], 2-3 ------- • Review information issued by the SBTCPs to ensure that it is understandable to the layperson [507(d)(3)], • Have the federal SBAP serve as the secretariat for the development and dissemination of reports and advisory opinions [507(d)(4)], Further information on the activities and accomplishments of EPA's Office of the Small Business Ombudsman may be found in Appendix B-1. 2.6 SMALL BUSINESS ASSISTANCE COOPERATIVE AGREEMENT PROGRAM On October 6, 1999, the EPA SBO announced the ten recipients for the 1999 Small Business Assistance Cooperative Agreement Program. A funding pot of $900,000 in awards up to $100,000 each was available for state SBOs and SBAPs. The awards reflect EPA's commitment to support innovation in existing networks that help businesses prevent pollution and comply with the law. The projects chosen for funding represent a wide range of small business sectors, offer the potential for demonstrating innovative ideas, and have far-reaching benefits to other state assistance programs. Twenty-three applications were submitted from across the United States. The ten cooperative agreement recipients are: • California South Coast Air Quality Management District ($100,000) - Assist small businesses in reducing air emissions with a focus towards the water heater and boiler manufacturing industries. • Colorado Department of Public Health and the Environment ($84,177) - Market the SBO/SBAP and train state Small Business Development Center (SBDC) personnel on environmental issues so they can better educate small businesses. • Kansas State University Pollution Prevention Institute ($99,984) - Provide direct technical assistance to dry cleaners, automotive repair/auto body, and metal finishers. Develop SBO/SBAP promotional materials. • Maine Department of Environmental Protection ($60,821) - Provide technical assistance for compliance and pollution prevention to selected small business sectors. • Minnesota Pollution Control Agency ($96,824) - Implement sector-based compliance assistance to the reinforced plastics and boat manufacturing industries. 2-4 ------- • Montana Department of Environmental Quality ($75,000) - Market and evaluate the effectiveness of the SBO and SBAP. • New Jersey Department of Environmental Protection ($84,000) - Market services to other state small business providers in a joint effort with the state Commerce Department. • New York Environmental Facilities Corporation ($83,681) - Demonstrate the improved environmental benefits derived from providing assistance to gasoline dispensing sites and transport vehicles, particularly Stage II requirements. • South Carolina Department of Health and Environmental Control ($93,000) - Measure the success of the technical assistance program in helping auto repair shops and salvage yards. • Wyoming Department of Environmental Quality ($68,960) - Conduct reviews of proposed new standards affecting small businesses, develop mailing packages to inform businesses, and develop a comprehensive data base sorted by SIC code and matched to new proposed standards. The EPA SBO will provide periodic updates to various trade associations on the progress of these projects. After the two-year projects are completed, results will be published and distributed to the small business community, SBTCPs, and other interested parties. A copy of the Cooperative Agreement Application Guidance Package may be found in Appendix B-2. 2.7 FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM EPA, through the Federal SBAP, provides technical guidance for the SBTCPs' use in implementing their programs. Information on the activities of the Federal SBAP may be found in Appendix C. 2-5 ------- 3.0 SBTCP STATUS, BUDGETS, STAFFING, AND ORGANIZATION Information on the operating status (Section 3.1), budgets (Section 3.2), staffing levels (Section 3.3), and administrative locations of the three components of the SBTCPs (Section 3.4) for the January - December 1999 reporting period may be found in this chapter. A listing of state/territory Ombudsman, SBAP, and alternate SBAP contacts is included in Appendix D-1. 3.1 OPERATING STATUS As of the end of 1999, 51 SBOs (96 percent of the 53 states and U.S. territories) and all 53 SBAPs (100 percent) had been established and were providing assistance to small businesses. Only 43 programs reported that their CAPs were operating; however, 45 programs reported that their CAPs had been established. These numbers are unchanged from 1998. Operating status for each SBTCP components is shown in Table 3-1; programs whose SBOs, SBAPs, and CAPs are not yet established or operational also are identified. TABLE 3-1 OPERATING STATUS OF THE SBTCP COMPONENTS COMPONENTS ESTABLISHED1 COMPONENTS OPERATIONAL1 # Programs % Programs # Programs % Programs SBOz 51 96 51 96 SBAP 53 100 53 100 CAPJ 45 85 43 81 Notel: Programs indicated if their SBO, SBAPs, or CAPs had been established (i.e., created by legislation), and if they were also providing services. Programs were considered operational if the SBOs had been appointed, SBAPs were providing services, and CAPs had conducted at least one meeting, even if not all CAP members had been appointed. Note 2: As of 12/31/99, Massachusetts and Vermont did not have SBOs. Note 3: As of 12/31/99, CAPs were reported not to be established or operating in 8 programs: California, Hawaii, Iowa, Maryland, Massachusetts, Rhode Island, Tennessee, or the Virgin Islands. In addition, Arizona reported that their CAP had been established, but was not yet operating. Alabama did not provide operational data for its CAP. This information is unchanged from 1998. 3-1 ------- Details on when the SBOs, SBAPs, and CAPs were reported to be established and operational may be found in Appendix D-2. A summary of the start of operations for the three SBTCP functions is shown in Table 3-2. TABLE 3-2 START OF OPERATIONS FOR SBTCP FUNCTIONS SBO SBAP CAP Number Total Number Total Number Total Pre-1990 1 1 1991 1 2 1992 11 11 12 14 1 1 1993 20 31 16 30 9 10 1994 9 40 16 46 12 22 1995 8 48 5 51 10 32 1996 1 52 4 36 1997 2 50 3 39 1998 1 51 1 53 4 43 % operational 12/31/99 96% 100% 81% 3.2 BUDGETS Information about the total SBTCP operating budgets may be found in Section 3.2.1, with details on the SBO, SBAP, and CAP budgets contained in Sections 3.2.2, 3.2.3, and 3.2.4, respectively. 3.2.1 1999 Reporting Period The total operating budgets for the SBTCPs varied from $5,000 (District of Columbia) to over $1,300,000 (New York) for the 1999 reporting year. 1999 operating budget ranges for the SBTCPs are shown in Table 3-3; 1998 and 1997 ranges also are shown for comparison. Details on the operating budgets, by program, for the individual SBO, SBAP, and CAP components, including the source of these funds, may be found in Appendix D-3. 3-2 ------- TABLE 3-3 1999, 1998, and 1997 SBTCP OPERATING BUDGET RANGES 1999 1998 1997 BUDGET $ # Programs % Programs1 # Programs % Programs1 # Programs % Programs1 0 1 - 100,000 9 17 8 15 10 19 100,001 - 200,000 16 30 15 28 15 28 200,001 - 300,000 7 13 10 19 7 13 300,001 -400,000 8 15 9 17 12 23 400,001 - 500,000 5 9 4 8 3 6 500,001 -600,000 3 6 3 6 1 2 600,001 - 700,000 2 4 1 2 700,001 - 800,000 1 2 800,001 - 900,000 1 2 1 2 1 2 900,001 - 1,000,000 1 2 >1,000,000^ 2 4 1 2 >2,000,000J 1 2 1 2 No data provided" 1 2 TOTAL 53 53 53 Note 1: County budgets are not combined with state budgets, nor are they counted separately. Note 2: Texas (1999, 1997), New York (1999). Note 3: New York. Note 4: Hawaii. 3.2.2 Comparison of Previous and Projected Budgets A comparison of budgets from 1998, 1999, and 2000 (projected) is valuable in tracking program growth and resource allocation. Programs were asked to indicate significant budget changes (greater than ten percent) from year to year and to provide insight into any major shifts (more than ten percent) in funding levels. SBTCP reporting period budget comparisons are shown in Table 3-4. 3-3 ------- TABLE 3-4 SBTCP REPORTING PERIOD BUDGET COMPARISONS BUDGET DECREASE (> 10% change) BUDGET CONSISTENT (< 10% change) BUDGET INCREASE (> 10% change) INSUFFICIENT DATA FOR COMPARISON1 # Programs % Programs # Programs % Programs # Programs % Programs # Programs % Programs 1998 to 1999 Reporting Period 8 15 36 68 9 17 0 0 1999 to 2000 Reporting Period 3 6 38 72 10 19 22 4 Note 1: Not all programs provided budget amounts. In order to establish trends, combined budgets for the SBO, SBAP, and CAP were examined. This was necessary, as some programs indicate combined budgets for two or three facets of their programs, while other programs may have had one or two facets of their programs inactive during a reporting period. Note 2: Arizona, Missouri. In reviewing the combined budgets for the SBO, SBAP, and CAP functions of the SBTCPs, nine programs (17 percent) indicated a budget increase (of at least ten percent) from the 1998 to 1999 reporting periods. Ten programs (19 percent) showed an increase from the 1999 to 2000 reporting periods. As programs mature and the cost of establishing programs stabilizes, more programs are projecting fairly consistent budgets for the next reporting period (38 this year as compared to 41 last year). The number of programs projecting a budget increase for 2000 increased from six to ten. According to responses received, projected budget increases primarily were related to the expansion of services and staff additions or the receipt of grants. Examples of reasons given for budget increases greater than ten percent are provided below: • In the District of Columbia, the ombudsman position was filled in September 1999. ($5,000/1999 to $46,000/2000) • New Hampshire received a two-year, $150,000 grant to implement the PrintSTEP pilot program in the state. ($100,000/1999 to $150,000/2000) • The rise in Virginia's 2000 projected budget is from increases in salary, fringe, and programmatic money, and extra funds projected for the CAP training at the SBO/SBAP national conference. ($257,000/1999 to $306,800/2000). 3-4 ------- Thirty-six programs (68 percent) report steady budget levels (less than a ten percent change) for the 1998 to 1999 reporting periods, and 38 programs (72 percent) indicate consistent budget levels from the 1999 to 2000 (projected) reporting periods. Eight programs (15 percent) showed a decrease (more than ten percent) from the 1998 to 1999 reporting periods, while three programs (6 percent) projected a decrease from the 1999 to 2000 periods. Budget reductions often are attributed to staff loss or expiration of grant funds. Ninety-one percent of the programs reported either a consistent or increasing budget from the 1999 to 2000 (projected) reporting periods. Budgets for the 1998, 1999, and 2000 (projected) reporting periods for the SBO function, SBAP function, and CAP function may be found in Appendix D-4. 3.2.3 SBO Operating Budgets Forty-two SBOs have their own budgets (versus having their budgets combined with other SBTCP functions). Budgets for these SBOs are concentrated in a range below $200,000, with 39 of 42 SBOs reporting budgets between $0 and $200,000. (The three exceptions are the SBOs of Connecticut at $325,000, Ohio at $226,000, and New York $500,000.) The primary source of funding for all programs is Title V fees (72 percent), which are collected at the state/territory level. Other sources of funding include grant funds, permit and other fees, and state general funds. A program may have combined the budget for two or all SBTCP functions (i.e., SBO/SBAP, SBO/CAP, or SBAP/CAP). For example, a program may report a combined SBO/CAP budget and a separate SBAP budget, which would be reflected in the appropriate single or combined budget categories. The range of 1999 operating budgets for the SBOs with their own budgets is shown in Table 3-5. A comparison of SBO budgets for the past three years is not practical, as a different number of SBOs have had their own budgets each year. 3-5 ------- TABLE 3-5 1999 SBO OPERATING BUDGET RANGES(42 non-combined budgets) Budget ($) # Programs % Total Programs O1 2 4 1 - 25,000 8 15 25,001 - 50,000 7 13 50,001 - 75,000 8 15 75,001 - 100,000 8 15 100,001 -200,000 6 11 200,001 - 300,000 1 2 3000,001 - 400,000 1 2 400,001 - 500,000 1 2 Combined budgets 9 17 Not applicable, no response^ 2 4 TOTAL 53 Note 1: Louisiana, Vermont. Note 2: Massachusetts, Puerto Rico. 3.2.4 SBAP Operating Budgets Forty-one SBAPs have their own budgets. SBAP budgets are spread across a wider dollar range as compared to the SBOs with 14 programs between $0 and $100,000, 9 programs between $100,001 and $200,000, and 6 each between $200,001 and $300,000 and $300,001 and $400,000. Budgets range from $3,500 (District of Columbia) to a high of $890,000 for New York. Title V fees again are the main funding source (64 percent of all programs); funds from EPA grants, permit and other types of fees, and general revenues also are used to support SBAPs. The range of 1999 operating budgets for the SBAPs with their own budgets is shown in Table 3-6. A comparison of SBAP budgets for the past three years is not practical, as a different number of SBAPs have had their own budgets each year. 3-6 ------- TABLE 3-6 1999 SBAP OPERATING BUDGET RANGES(41 non-combined budgets) Budget ($) # Programs % Total Programs 1 - 25,000 4 8 25,001 - 50,000 2 4 50,001 - 75,000 3 6 75,001 - 100,000 5 9 100,001 -200,000 9 17 200,001 - 300,000 6 11 300,001 - 400,000 6 11 400,001 - 500,000 2 4 500,001 - 600,000 2 4 600,001 - 700,000 1 2 800,001 - 900,000 1 2 Combined budgets 11 21 No response1 1 2 TOTAL 53 Notel: Connecticut. 3.2.5 CAP Operating Budgets Thirty-nine CAPs have their budgets calculated separately, ranging from $0 to a high of $10,500 (Missouri, followed closely by Wyoming at $10,000). Ninety-four percent of CAPs with their own budget operate with $5,000 or less. Title V fees are the most commonly listed funding source for all CAPs (51 percent). The range of 1999 CAP operating budgets is shown in Table 3-7. A comparison of CAP budgets for the past three years is not practical, as a different number of CAPs have had their own budgets each year. TABLE 3-7 1999 CAP OPERATING BUDGET RANGES(39 non-combined budgets) Budget ($) # Programs % Total Programs O1 17 32 1 - 1,000 4 8 1,001 - 2,000 6 11 2,001 - 3,000 4 83 4,001 - 5,000 6 11 10,000 - 11,000 2 4 Combined budgets 11 21 No data provided^ 3 6 TOTAL 53 3-7 ------- Note 1: CAPs reporting "N/A" or "as needed" also were counted as "0" if they administratively were assigned their own budgets. Note 2: Alabama, Connecticut, Massachusetts. 3.3 STAFFING LEVELS Forty-five programs (85 percent) report operating their SBOs with two or fewer full-time equivalents (FTEs) as shown in Table 3-8. This number has increased from 41 in 1997, and 44 in 1998. Texas is a significant exception, with 36 FTEs serving the SBO function. In 1999, 36 programs (68 percent) operated their SBAPs with four or fewer FTEs (down from 38 programs in 1998), which includes both paid and unpaid staff and may include retired engineers. There are some notable exceptions to these staffing levels, such as Louisiana and Indiana, which each report using 12 FTEs to support their SBAP function. Also, Texas reported the services of 70 unpaid "EnviroMentors" who assist with SBAP duties, for 106 FTEs supporting Texas' SBAP. Specific details on program staffing levels for the SBO and SBAP functions may be found in Appendix D-5. TABLE 3-8 1999 STAFFING LEVELS (as FTEs1) SERVING THE SBO & SBAP FUNCTIONS # FTEs # Programs SBO SBAP 0-0.09 3 1 0.1 - 1 31 9 1.1-2 11 12 2.1 - 3 3 8 1 CO 6 4.1 - 5 1 3 5.1 -6 4 6.1 - 7 1 2 CO 1 3 12 2 36 1 106 1 Not applicable, no response^ 2 2 TOTAL 53 53 Note 1: An FTE is considered to work 40 hours/week. For example, two people working 20 hours/week would be equivalent to one FTE. Note 2: SBO - Massachusetts, New Mexico. SBAP - Georgia, Delaware. 3-8 ------- Twenty-eight programs (53 percent), compared to 30 last year and 31 in 1997, report that at least the required seven members have been appointed to their CAPs. An overview of CAP appointments is shown in Table 3-9. In CAPs with fewer than seven members, several programs indicated that expired terms on their CAPs have not yet been filled or that their CAPs have not yet been established. Program statistics of the number of CAP members in each category (small business, state agency, general public, not yet appointed, other) may be found in Appendix D-6. TABLE 3-9 CAP APPOINTMENTS # Programs % Programs Minimum 7 members appointed 28 53 Less than 7 members appointed 21 40 Not applicable, no response 1 4 8 Note 1: California, Massachusetts, North Carolina, Rhode Island. 3.4 ADMINISTRATIVE LOCATION OF SBO AND SBAP COMPONENTS As shown in Table 3-10, 51 programs indicated that their SBOs are located within a state/territory-related agency, typically the environmental agency. The majority of programs (48) report to have located their SBAPs within a state/territory-related agency, typically the environmental agency. Four programs (Kansas, Kentucky, Nevada, and Pennsylvania) contract their SBAP function to an outside agency or organization. As defined in Section 507, the CAPs are to be independent entities, operating outside of any agency. TABLE 3-10 ADMINISTRATIVE LOCATIONS OF SBO AND SBAP Location SBO SBAP # Programs % Programs # Programs % Programs State-related agency 51 96 48 91 University-related (contracted) 3 6 Private contractor 1 2 Mixed1 1 2 Not applicable, no response1 2 4 TOTAL 53 53 Notel: Rhode Island. Note 2: Massachusetts, Vermont. 3-9 ------- As indicated in Table 3-11, 21 SBOs are located in a regulatory section within their agency, while 30 SBOs are housed in a nonregulatory section. Twenty-four SBAPs reported their location in a regulatory section, 28 indicated nonregulatory, and one program reported association with both regulatory and nonregulatory offices. Some programs feel that location in a nonregulatory section of an agency may be less intimidating to small businesses than dealing with staff that are part of an enforcement section. TABLE 3-11 REGULATORY / NONREGULATORY LOCATIONS OF SBO AND SBAP SBO SBAP # Programs1 % Programs # Programs % Programs Regulatory 21 40 24 45 Nonrequlatory 30 57 28 53 Mixed1 1 2 Not applicable/No response^ 2 4 TOTAL 53 53 Note 1: Massachusetts. Note 2: Massachusetts, Vermont. Complete information for the administrative location of each SBO, SBAP, and CAP may be found in Appendix D-7. 3-10 ------- 4.0 SBTCP ACTIVITIES AND SERVICES Information regarding the activities and services of the SBTCPs is provided in this section. Industry sectors assisted by the SBTCPs are discussed in Section 4.1. An overview of SBTCP activities and services is provided in Section 4.2. SBTCP assistance requests are outlined in Section 4.3. CAP activities are outlined in Section 4.4. Financial assistance programs are described in Section 4.5 A discussion of how programs minimize duplication through cooperative efforts may be found in Section 4.6. SBTCP efforts to comply with the intent of the Paperwork Reduction Act, Regulatory Flexibility Act, and the Equal Access to Justice Act are summarized in Section 4.7. Beginning with the 1998 reporting year, information on SBTCP services to specific industry sectors was gathered under a new format designed to make the resulting data more complete and meaningful. Please refer to the Reporting Form in Appendix A for the questions pertaining to program activities and services (Section 3). 4.1 INDUSTRY SECTORS ASSISTED BY THE SBTCPs Programs were asked to report on their assistance to 72 industry sectors in eight assistance categories. The industry sectors and assistance services into which programs could categorize their efforts were standardized in 1998. Not all states kept information as to industry sectors assisted or total assists provided. Notes on data calculation are included with the various data tables in the appendices. Fifty-two SBTCPs (98 percent) provided information on the types of industry sectors and number of facilities that their programs assisted in 1999; data from county and air district programs were included with their state's activities. The top ten industry sectors receiving SBTCP assistance (by number of assists) in 1999 are shown in Table 4-1. 4-1 ------- TABLE 4-1 TOP 10 INDUSTRY SECTORS ASSISTED Industry Sector # Assists Cross Sector* 353,493 Other (not classified)* 122,788 Organizations/Associations* 105,063 Auto/Body Maintenance, Repair, Refinishing* 89,025 Auto/Motor Vehicles & Equipment 45,036 Dry Cleaning/Laundry Services* 34,150 Machine Shop 23,271 Government* 7,652 Furniture Manufacturing/Repair/Wood Finishing 6,150 Attorney/Consultant/Engineer 5,819 Note*: Also in the top 10 in 1998. The top 10 industry sectors that received assistance from the most programs are shown in Table 4-2. Dry cleaning and auto body maintenance have been the two industry sectors helped by the most programs for the last three years. TABLE 4-2 TOP 10 INDUSTRY SECTORS ASSISTED BY PROGRAMS Industry Sector # Programs Dry Cleaning/Laundry Services* 44 Auto/Body Maintenance, Refinishing, Repair* 43 Printing/Graphic Arts* 39 Furniture Manufacturing/Repair/Wood Finishing* 39 Organizations/Associations* 39 Other 39 Government* 38 Metal Fabricating/Finishing* 38 Agriculture/Farming/Crop Service 36 Attomey/Consultant/Engineer* 36 Note*: Also in the top 10 in 1998. The number of businesses reached by industry sector may be found in Appendix E-1. This same list also has been reordered by the number of states providing assistance (Appendix E-2). A summary of individual program responses may be found in Appendix E-3. Programs were asked if they targeted any specific industry sectors for assistance. Forty-five programs (85 percent) indicated they focused on certain high priority 4-2 ------- industries. Of the 45 industries mentioned, the following sectors were targeted by at least seven programs, as shown in Table 4-3. TABLE 4-3 INDUSTRY SECTORS TARGETED FOR ASSISTANCE Industry Sector # Programs Dry Cleaning/Laundry Services 23 Auto/Body Maintenance, Refinishing, Repair 23 Metal Fabricating/Finishing 11 Furniture Manufacturing/Repair/Wood Finishing 9 Concrete/Aggregate 7 Printing/Graphic Arts 7 Other 7 4.1.1 Total Businesses Assisted As tallied by industry sector, SBTCPs reported they assisted 920,384 businesses in 1999; this is slightly lower than the 1,002,446 reported for 1998. Beginning in 1998, the number of businesses assisted was tallied both by industry sector and eight separate types of assistance. This format more fully captures the true picture of businesses assisted by the programs. Also, many programs have improved their recordkeeping strategies, resulting in higher quality and more comprehensive data. When studying the data, several points should be considered. In general, "total businesses reached," as reported by each Section 507 program, is used as the "official" count for this report. Some programs tried not to double count the number of businesses assisted within a given industry sector. Two programs and one county did not keep data by industry sector, and only "total businesses reached" was given. Six programs tracked the types of services they offered or the industry sectors they assisted, but did not compile data. A tally of "total businesses reached," as reported by each program, may be found in Appendix E-4. 4-3 ------- 4.2 ACTIVITIES AND SERVICES An overview of activities and services provided by the SBTCPs is discussed in this section. Programs were asked to provide information about their services separately from the types of assistance requests they received. 4.2.1 Outreach Activities and Businesses Reached The number of programs offering specific outreach services plus an aggregate of the number of businesses reached through these services in 1999 is presented in Table 4- 4. These outreach activities and services are designed to introduce small business people to the available assistance services and to identify common problems and issues to be addressed on a more specific basis. Beginning with the 1998 reporting year, programs reported their outreach statistics for their SBO, SBAP, and CAP combined. Information was requested by the type of assistance (e.g., hotline, on-site visit, etc.) and by industry sector served. The types of outreach activities and industry sectors on which programs could report were standardized. TABLE 4-4 OUTREACH ACTIVITIES AND BUSINESSES REACHED (by number of programs offering) ACTIVITY # Programs % Programs Total Businesses Reached1 Seminars/Workshops 44 83 42,534 On-site visits 43 81 9,103 Hotline 43 81 63,216 Mailings 42 79 342,910 Publications 38 72 386,110 Other 26 49 34,875 Home page^ 23 43 68,703 Teleconferences 17 32 4,067 Note 1: "Total businesses reached" is tallied using industry sector assistance data. Some programs tried not to double count. For example, if one printer called a hotline 5 times, one program may count this as 5, while another program may count as 1. Therefore, "total businesses reached" by industry sector will not equal total businesses reached by type of assistance. Note 2: 50 programs reported having web sites under the question directly addressing this issue. 4-4 ------- The most common outreach activities, offered by about 80 percent of programs, were: • Seminars/workshops • On-site visits • Hotline • Mailings. Such activities remain as some of the most common services offered by the programs from year to year. Detailed information, by program, about the number of occurrences and the number of businesses reached by each reported activity is presented in Appendix E-5. 4.2.2 New Publications As noted above, more businesses were reached through publications than through any other method. Thirty-eight programs reported outreach to 386,110 business through publications. Programs were asked to provide a list of new documents they prepared in 1999, which may be found in Appendix E-6. Examples of the types of publications produced include: • Fact sheets • Manuals • Assistance request forms • Emission calculation worksheets • Brochures • Resource guides and directories • Dry cleaners' calendar • Training workbooks and checklists • Permit guides • Newsletters • Posters • Annual reports • Technical papers • Generic compliance plans. 4-5 ------- Many programs share publications with each other, adapting one state's publication for their own needs. 4.2.3 Notable Outreach Strategies Also beginning in 1998, programs were asked to note outreach strategies they found to be particularly effective in assisting small businesses. Of the 25 strategies noted by the 48 programs (91 percent) that answered this question, the following received mention by at least 10 programs, as shown in Table 4-5. TABLE 4-5 NOTABLE OUTREACH STRATEGIES Outreach Strategy # Programs Workshops 21 Direct mailings 16 Cooperative efforts 14 On-site visits/direct contact 14 From year to year, programs have stressed the value of direct contact - primarily via on-site visits, but also through workshops - in building trust and confidence in the business community. Because of their nature, on-site visits and workshops typically reach fewer businesses than "mass" outreach strategies like mailings and publications. However, programs indicate that the quality of the contacts made through direct interaction between business owner and technical assistance provider can lead to improved compliance. Effective outreach strategies as noted by each program may be found in Appendix E-7. 4.2.4 Internet Web Pages The number of programs that are using Internet web pages to disseminate technical assistance information continues to grow. (Programs are no longer reporting use of electronic bulletin board services.) Fifty programs (94 percent) currently operate home pages, up from 48 in 1998, 41 in 1997, and 28 in 1996. The types of information available on these home pages are listed in Table 4-6; detailed information on the home pages, including web site address, usage, and comments received, may be found in Appendix E-8. 4-6 ------- TABLE 4-6 INFORMATION AVAILABLE ON INTERNET HOME PAGES Type of Information # Programs % Programs Program description 32 58 Contact listings 31 58 Links 31 58 Permitting information 30 57 Permit forms 29 55 Regulations 28 53 Pollution prevention information 28 53 Guidance documents/fact sheets 28 53 Multimedia 28 53 Calendar of events 27 51 List of publications 25 47 Policies 25 47 Emissions inventory 22 42 CAP information 19 36 Other 7 13 Note*: Programs without web sites: New Hampshire, Puerto Rico, and Virgin Islands. While most programs either do not ask for or have not received feedback on their web sites, a number of programs provided information on comments that users have submitted. A sampling of responses is shown below. • When Georgia received their new site address, they requested feedback from Environmental Protection Department personnel. Some of the associates have provided very reliable and encouraging comments, most commonly that the information is easy to read and access. • New Mexico established a web focus group to assist in feedback and suggestions for improving the web site. The most common suggestions were to add more information and improve site organization. • Wyoming's web site has no formal feedback mechanism, but they do receive comments from site users. Most ask for additional information or points of contact. A small number ask for help in downloading documents or finding related links. Internet home pages are efficient mechanisms for SBTCPs to disseminate information to small businesses, as evidenced by the increasing use of electronic media over the last four years. Because the Internet is practical for information transfer from the federal SBO and SBAP, between programs, and to the small business community, and expanded web page content should continue to be pursued. 4-7 ------- 4.3 ASSISTANCE REQUESTS 4.3.1 Air-only Versus Multimedia Assistance Section 507 of the CAA calls for the establishment of technical assistance programs for air-related issues. However, a number of states began their programs as multimedia (offering assistance with water, solid waste, hazardous waste, etc. in addition to air) and more have since transitioned their programs to multimedia assistance, as shown in Table 4-7. TABLE 4-7 AIR-ONLY VERSUS MULTIMEDIA ASSISTANCE Assistance Focus # Programs % Programs Multimedia 37 70 Air-only 16 30 More and more programs are offering multimedia assistance, because their small business clients need it and expect it. Small businesses appreciate "one stop shopping" for their compliance and technical assistance questions, rather than working through numerous media-based departments. Each program's assistance focus is shown in Appendix D-1. 4.3.2 Types of Assistance With this consideration, as a new element for the 1998 reporting year, SBTCPs were asked for data on the type of assistance requested (e.g., regulatory information, permitting, recordkeeping, etc.). Programs could indicate the number of CAA-related requests and the number of multimedia requests for assistance. Forty-six programs (87 percent) provided data on CAA/multimedia assistance requests. These data are summarized in Table 4-8. Individual program responses may be found in Appendix E-9. 4-8 ------- TABLE 4-8 CAA/MULTIMEDIA ASSISTANCE REQUESTS Type of Assistance Requested CAA Requests Multimedia Requests Total Requests Compliance/Regulatory Information 10,914 5,742 16,656 Monitoring 779 119 898 Recordkeeping 844 196 1,040 Financial/Funding Information 450 641 1,091 Permitting 5,117 1,233 6,350 General CAA Information 1,593 414 2,007 Add to Mailing List 620 168 788 P2 Assistance 987 1,573 2,560 Other 3,986 5,808 9,794 TOTAL REPORTED REQUESTS* 25,391 16,297 41,688 Note *: Total requests are as reported by the programs. Numbers will not add up, since some programs merely indicated they provided a certain type of assistance, but did not provide data. Some did not have data by assistance type, but did provide totals. Requests for compliance/regulatory information far outnumbered any other type of assistance request at 16,656. "Other" types of information received 9,794 requests followed by requests for permitting information at 6,350. Businesses made almost 10,000 more CAA-related requests for information than they did for multimedia - 25,391 as compared to 16,297. CAA assistance outnumbered multimedia assistance in every assistance category except for "other" and P2 assistance. Such data are not surprising, since the SBTCPs were established to provide CAA assistance. Since 37 programs (70 percent) indicate they provide full or partial multimedia assistance, multimedia requests are expected to rise in the coming years. 4.4 CAP ACTIVITIES AND SERVICES Forty-three CAPs indicated they were operational during the 1999 reporting period, 37 of which reported activities. The primary CAP activities were reviewing and commenting on new/proposed regulations (28 CAPs) and on state legislative actions (21 CAPs). These were followed by reviewing SBO/SBAP documents (20 CAPs). 4-9 ------- This year's primary activities shifted from last year, when reviewing SBTCP outreach efforts and documents were most commonly reported. This new focus on reviewing regulations and legislative actions could point to the maturing of some CAPs as they turn their focus from administrative details to dealing more directly with small business issues. Major activities of the CAPs during the 1999 reporting period are shown in Table 4-9. A program summary of CAP activities may be found in Appendix E-10. TABLE 4-9 MAJOR CAP ACTIVITIES Activity # Programs % Programs Review/comment on new/proposed regulations, policies, etc. 28 53 Review/comment on state legislative actions 21 40 Review of SBO/SBAP documents 20 38 Define CAP responsibilities 19 36 Appoint staff/elect officers 18 34 Meet with small businesses/trade associations 18 34 Attend training seminars, conferences, etc. 17 32 Review of SBTCP outreach efforts 17 32 Other 4 8 CAPs continue to raise their participation and visibility in their state's technical assistance programs. The unique roles and specialized skills of the members make them valuable resources in the development of the SBTCPs. Effective communication among the three components of the programs and among CAPs in all programs will continue to effectively and efficiently define the role of the CAP and fully maximize the skills of CAP members in assisting small businesses. Some states still have not formed their CAPs or do not have operational CAPs due to a slow appointment/reappointment process. These states are strongly encouraged to make CAP functionality a priority. 4.5 FINANCIAL ASSISTANCE PROGRAMS Information about financial assistance programs offered to small businesses to address environmental compliance needs (e.g., capital expenses associated with pollution prevention or control equipment) is provided in Table 4-10. 4-10 ------- TABLE 4-10 FINANCIAL ASSISTANCE PROGRAMS # States/territories offering grants/loans 8 Grants/loans offered 131 States/territories planning grants/loans 2 Note 1: Some states/territories offer more than one financial assistance program. Eight states/territories (15 percent) offered 13 financial assistance programs during the 1999 reporting period. Two SBTCPs have plans to offer financial assistance programs to small businesses in the near future. This is down from 16 financial assistance programs offered by 11 states in 1998 and 10 grants/loans offered by seven states in 1997. Detailed information about these financial assistance programs is provided in Appendix E-11. Creative financing mechanisms fulfill a need conveyed to programs by small businesses; offering financial assistance was a common recommendation made for improving compliance by SBTCPs themselves. The number of states/territories that offer some type of small business financial assistance program has fallen slightly after a very slow rise over the past several years. Programs are encouraged to explore funding opportunities for small businesses within their state or territory. 4.6 MINIMIZING DUPLICATION OF EFFORTS Programs reported on the extent to which they used state/territorial agencies and departments, organizations, and other resources to maximize efficiency and minimize redundancy, as discussed in Section 4.1.1. Programs also provided information on their strategies to exchange information and resources with other SBTCPs, which is summarized in Section 4.4.2. 4.6.1 Cooperative Efforts Information provided in this section is vital to understanding how some programs with limited budgets and resources are functioning. Generally, programs report that all three components of their SBTCPs recognize the efficiency and value of coordinating their 4-11 ------- efforts with each other and with other environmental agency departments, state agencies, and organizations. A summary of the number of SBTCP functions that cooperatively manage resources is shown in Table 4-11. Descriptions of programs' cooperative efforts may be found in Appendix E-12. TABLE 4-11 PROGRAMS THAT REPORT COOPERATIVE EFFORTS FOR SBTCP FUNCTIONS # Programs % Programs SBO 42 79 SBAP 50 94 CAP 31 58 Forty-two programs (79 percent) report some level of cooperative effort to enhance the SBO function. The SBO often coordinates information development and dissemination, training, and workshops/seminars with such entities as other state agencies, Chambers of Commerce, trade associations, non-profits, universities, public utilities, and Small Business Development Centers. The overall concerns of small businesses are being taken into account, as many SBOs provide multimedia information, coordinate outreach with non-air programs, or intervene on behalf of a small business with other agencies. Some SBOs also serve in other roles within the state environmental agency. Fifty programs (94 percent) indicate some level of cooperative effort by the SBAP function in order to maximize their programs' effectiveness. Strategies and sources of assistance are quite similar to those used by the SBOs. Thirty-one CAPs (58 percent) report leveraging resources within their state/territory. While the CAPs, by design, are independent entities, many receive administrative support and technical resources from the state/territory environmental agency, the SBO, or the SBAP. The number of programs reporting cooperative efforts has remained fairly consistent from year to year. 4.6.2 Mechanisms for Avoiding Duplication of Efforts Among SBTCPs All programs reported actions to minimize duplication of efforts among SBTCPs, thus increasing the overall cost-effectiveness of individual programs. As an example, 4-12 ------- industry-specific information developed by one program would have wide applicability to other programs involved with similar industries. Mechanisms that programs employ to avoid duplication of effort are presented in Table 4-12; program details for this topic are found in Appendix E-13. TABLE 4-12 SBTCP MECHANISMS FOR AVOIDING DUPLICATION Mechanism # Programs % Programs Communication/networking within SBTCP & state agency 52 98 Meetings, conference calls, etc. with SBTCPs in EPA region 51 96 Review of EPA documents, contacts with EPA 47 89 Information gathering from electronic sources 47 89 Review of documents from other public, private, or university sources 44 83 Networking through state/regional air groups (e.g., WESTAR) 44 83 Subscribe to SBO or government ombudsman listserve 31 58 Other 9 17 The most common technique (in 98 percent of programs) to avoid duplication of effort was communicating and networking with SBTCP and state agency personnel via phone, mailing lists, etc. This was closely followed by contact with other programs within the same EPA region through conference calls and other means at 96 percent. These also were the most common techniques in 1998. Gathering information from electronic sources, including Internet use for information transfer, continues to be one of the most promising mechanisms for avoiding duplication of effort among programs. Use of this method has remained fairly consistent for the last three years. Posting information from the federal SBO and SBAP, other private and university sources, and state programs facilitate efficient use of resources and would encompass all of the mechanisms to avoid duplication. Additionally, 31 programs reported subscribing to applicable listserves, an increase of five from the 26 in 1998. (A listserve is a program that allows users to mass-distribute electronic mail messages.) 4.7 SBTCP COMPLIANCE WITH SECTION 507(d)(2) Section 507(d)(2) of the CAA requires EPA's SBO to periodically report to Congress on SBTCP actions to follow the intent of the provisions of the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act. EPA's SBO Office continues its outreach actions toward assisting the SBTCPs in this effort. 4-13 ------- Key EPA SBO outreach activities under the CAA Section 507(b) pursuant to these statutes include: • Conducted educational activities at the EPA SBO Regional Liaison Conference, Washington, DC, August 1999. • Provided information on statutes at the 1999 National/State SBO/SBAP Conference in Tampa, FL. • Responded to telephone hotline inquiries in regard to the three statutes. • Distributed copies of the three statutes by request to state contacts. • Provided states with copies of the 1996 Small Business Regulatory Enforcement Fairness Act (SBREFA), which strengthens and amends the Regulatory Fairness Act, and SBREFA Implementation Guidance documents. • Offered information on the three statutes on the small business environmental home page. 4.7.1 SBTCP Activities Associated with the Paperwork Reduction Act Fifty programs (94 percent) reported specific activities associated with the intent of the provisions of the Paperwork Reduction Act, up from 48 programs in 1998. This Act was designed to minimize the burden and maximize the practical utility and public benefit associated with the collection of information by or for a federal agency. The most common action taken to follow the intent of the provisions of this act was receiving/providing information electronically (77 percent of programs). While other activity categories are showing slight decreases, more programs are taking significant steps in following the intent of the provisions of the Paperwork Reduction Act. Actions taken by SBTCPs in following the intent of the provisions of the Paperwork Reduction Act are listed in Table 4-13 and are detailed, by program, in Appendix E-14. 4-14 ------- TABLE 4-13 SBTCP ACTIVITIES TO FOLLOW THE INTENT OFTHE PAPERWORK REDUCTION ACT Activity # Programs % Programs Receiving/providing information electronically 41 77 Routine review of SBTCP documents for compliance 35 66 General permits for certain types of industries 32 60 Simplified/consolidated permits or forms 32 60 Routine review of SBTCP information collection activities 29 55 Eliminating unnecessary permits by increasing exemptions 23 43 Other 5 9 4.7.2 SBTCP Activities Associated with the Regulatory Flexibility Act Forty-seven programs (89 percent) reported activities to follow the intent of the provisions of the Regulatory Flexibility Act during 1999, the same as in 1998. The Regulatory Flexibility Act requires that when a number of regulations will have a significant economic impact on a substantial number of small entities, "a regulatory analysis must be performed to explore options for minimizing those impacts." Those actions most often implemented are prioritized in Table 4-14. TABLE 4-14 SBTCP ACTIVITIES TO FOLLOW THE INTENT OFTHE REGULATORY FLEXIBILITY ACT Activity # Programs % Programs Ensure that small businesses can participate in rulemaking 39 74 Routine review of SBTCP documents for compliance 38 72 Periodic rule review for impact on small business 28 53 Amnesty program 15 28 Other 6 11 SBTCPs have played a major role in ensuring awareness of the effects of regulatory requirements on small businesses as well as promoting environmental compliance in the small business community. SBTCP personnel have made significant strides in explaining the effects of legislation/regulations on small businesses to regulatory agencies through their role as mediators between these two groups. The two primary activities reported by programs in following the intent of the Regulatory Flexibility Act was ensuring that small businesses can participate in rulemaking (39 programs) and reviewing SBTCP documents for compliance (reported by 38 programs). SBTCPs continue to be effective advocates of the small business perspective and have helped negotiate flexible application of regulatory requirements that provided great benefits to 4-15 ------- small businesses. Actions taken by SBTCPs in response to the Regulatory Flexibility Act, by program, may be found in Appendix E-15. 4.7.3 SBTCP Activities Associated with the Equal Access to Justice Act Forty-two programs (79 percent) reported specific activities to follow the intent of the provisions of the Equal Access to Justice Act, up from 41 programs in 1998. The purpose of this Act is to provide certain parties who prevail over the Federal government with covered litigation in an award of attorneys' fees and other expenses under appropriate circumstances. Specific actions include reviewing SBTCP documents for compliance (again, the most common activity, conducted by 31 programs), and reviewing instances where state actions against small businesses appear unjustified (27 programs). SBTCP actions to follow the intent of the provisions of the Equal Access to Justice Act are shown in Table 4-15 and detailed, by program, in Appendix E-16. TABLE 4-15 SBTCP ACTIVITIES TO FOLLOW THE INTENT OF THE EQUAL ACCESS TO JUSTICE ACT Activity # Programs % Programs Routine review of SBTCP documents for compliance 31 58 Review instances where state actions against small businesses appear unjustified 27 55 Providing funding/technical assistance for groups aggrieved by regulatory actions 17 32 Other 4 8 Pro bono legal services 1 2 4-16 ------- 5.0 PROGRAM EFFECTIVENESS Internal and external assessments of SBTCP program effectiveness are reviewed in this section. Program goals and evaluation strategies are discussed in Section 5.1. Program highlights and accomplishments are found in Section 5.2. In Section 5.3, SBTCPs offer tips and barriers in operating their programs. Success stories and case studies are included in Section 5.4. 5.1 PROGRAM GOALS At each national SBO/SBAP conference since 1995, SBTCP representatives have discussed strategies to measure the success of compliance assistance programs. With the revision of the SBTCP Reporting Form for 1998, SBTCPs were asked to define and prioritize their own program goals. They also were asked to discuss strategies to evaluate their goals and the results of this measurement process. Programs are at different stages of development and have varying resources. Self- defined goals allow each program to strive for success and measure its achievements within its means. Performance measurement tools can take a variety of forms from simple to sophisticated. • Methods of tracking number of attendees at events. • Types of numerical data collected for activities and methods of collection. • Surveys to measure customer satisfaction after attending an event or receiving assistance. • Surveys to determine quality of service provided or request suggestions for improvement. • Detailed program analysis or evaluation. • Statistical analysis of return on investment in program. SBTCPs were asked to indicate goals for their programs, ranking them in terms of priority. Their responses are summarized in Table 5-1. 5-1 ------- TABLE 5-1 PROGRAM GOALS # Programs # Programs Declaring Goal Declaring This Goal (regardless of rank) As #1 Goal Increase understanding of environmental obligations 47 31 Improve compliance rates 42 12 Provide site specific compliance assistance 32 4 Increase understanding of permitting 20 1 Increase understanding ofCAA 12 4 Encourage self-auditing 6 1 Other 4 4 Increasing understanding of environmental obligations (47 programs, 89 percent) and improving compliance rates (42 programs, 79 percent) were the two most frequently listed goals, regardless of priority ranking. These two goals also garnered the most number one priority rankings, with 31 and 12 programs, respectively, declaring these to be their main goals; they also were the top two in 1998. 5.1.1 Goal Evaluation Importantly, programs then were asked how they evaluated whether their stated goals were being met. Programs were encouraged to base their assessments on quantifiable terms, where possible. Some programs, still in the developing stage, would need to rely on qualitative strategies to assess their goal progress. SBTCPs reported a variety of strategies to evaluate their program goals. These included: • Various customer feedback mechanisms (customer satisfaction/value of service). • Questionnaires/satisfaction surveys. • Tallies of hotline calls, on-site visits, workshops, etc. • Publications developed and distributed. • Improvements in compliance rates. Most programs focused on the number of businesses reached and types of assistance offered to measure their success. 5-2 ------- Finally, programs were asked to describe the results of their measurement process. Many SBTCPs discussed data and client feedback related to various outreach efforts. For example: • Georgia met its technical assistance goals for 1999, which included: 1) Publicize the toll-free telephone assistance line. 2) Prioritize small business technical assistance needs by industrial classification, and prepare two compliance assistance documents. 3) Make 12 site assessment audits. 4) Assist 12 small businesses with permitting. 5) Respond to 500 requests for assistance via telephone within 24 hours, and complete any required on-site follow-up visits at the client's convenience. 6) Make six joint inspections with compliance inspectors from other Air Branch programs to maintain familiarity with small business technologies. 7) Make six joint "white hat" compliance assistance visits with inspectors from the DNR Hazardous Waste Programs to dry cleaning establishments. • In Iowa, returned evaluation forms showed that over 95 percent of respondents found the services to be "excellent" and "very helpful" and would recommend the program to other businesses. Among other indicators, increased client referrals, repeat visit requests from past clients, and a steady backlog of site visit requests show the program has earned the confidence of the small business community. • Vermont's hotline calls increased from 146 in 1998 to 329 in 1999. The number of on-site visits rose from 19 in 1998 to 36 in 1999. Several programs measured improvements in compliance resulting from their technical assistance efforts. • Arizona has found on-site visits to be very effective with over 70 percent of violations detected being corrected by the time of the follow-up visit. Issues not corrected by that time usually are more complex or require significant capital expense. • In Florida, the SBAP distributed dry cleaner calendars so businesses could easily enter data on their calendars, then tear off and send in the information each month to meet reporting requirements. The compliance rate for recordkeeping increased from 12 percent in 1996 to 83 percent in 1999. • Texas measures compliance before and after assistance through questionnaires, and customer surveys for hotline calls, site visits, and workshops. For example, 57 workshops were conducted in 1999 with 1,784 attendees. Compliance data are only available for the auto body and auto repair industries, as those were the only surveys returned. For these industries, compliance with air issues increased by 39.4 percent and 21.0 percent, respectively. Compliance with waste issues increased by 19.6 percent for the auto repair industry. Waste issue compliance for the auto body industry could not be calculated due to an insufficient number of surveys returned. 5-3 ------- Individual program goals and their priority rankings, goal evaluation strategies, and results of this measurement process may be found in Appendix F-1. 5.2 PROGRAM HIGHLIGHTS AND ACCOMPLISHMENTS Forty SBTCPs (75 percent) reported on important accomplishments, awards, and recognitions for their work with the small business community. The SBTCPs continue to facilitate communication and improve trust between the regulatory agencies and small businesses. Many programs have forged strong partnerships with such groups as trade associations, small business development centers, and small business associations to broaden outreach efforts to the small business community. Many states also have developed industry-specific initiatives that include compliance manuals, workshops, and on-site visits. In this section, key accomplishments are highlighted based on the frequency in which they were mentioned. An overview of program accomplishments and highlights for 1999 are provided in Appendix F-2. 1. Forging partnerships with other organizations and agencies was mentioned by 11 programs as being a significant accomplishment. • Colorado's dry cleaner guidance document project has been significant in that the SBO/SBAP have established new partnerships with federal, state, industrial, and private entities. • Illinois SBAP made significant strides in strengthening its formal relationship with the IL EPA Bureau of Air. Since the SBAP is located outside the regulatory agency, the SBAP relies heavily on the BOA to identify potential small business impacts and problem areas they encounter in small business compliance. • In Puerto Rico, a cooperation agreement was signed between the Environmental Quality Board and the Commerce Development Administration. This agreement combines funds to operate the SBO and SBAP, increasing the participation of the Commerce Development Administration and its contacts in the small business community to enhance awareness of environmental regulations. 2. Ten programs were pleased with the publication of various documents. • Minnesota's SBAP created and published the "Environmental Guide for Small Businesses in Minnesota," which provides businesses with easy access to 5-4 ------- environmental, health, and safety regulations, and financial assistance information. The guide also is on MPCA's Internet site with links to pertinent regulations, statutes, and other online resource sites. • Missouri's Pollution Prevention/Compliance Guides have been well received by industry. Written in an easy-to-understand format, the guides provide the necessary information for a facility to comply with regulations, plus offer P2 opportunities and ideas. • New York's SBAP generated several technical outreach materials in 1999 that were well received by businesses. Two of these publications, "Choosing an Environmental Consultant: Guidelines for Small Businesses" and "On-site Technical Assistance for Clean Air Act Compliance" received awards from the Mohawk Chapter of the Society for Technical Communication. 3. Nine programs reported work on multimedia projects or moving their whole assistance program to multimedia leadership. • Kansas felt the move to multimedia was necessary for their program. By combining P2 and SBAP services, clients were provided with comprehensive compliance assistance, while P2 was promoted. A number of businesses have implemented Environmental Management Systems because of the highly successful workshops, manuals, and assistance provided by the technical assistance component of the program. • In Mississippi, multimedia continues to work well. Customers are confident they can contact us for answers to all environmental issues. • New Hampshire was one of the three states awarded grants to implement the PrintSTEP program at the state level. This grant will allow the program to accelerate a multimedia outreach and compliance assistance effort to this important sector. This will be the third major industry sector to benefit from the goal of providing multimedia assistance. 4. A strong on-site assessment program was noted by nine programs. • In Ohio, 99 percent of the SBAO's site visit customers said they would contact the program again for help. In 1999, the SBAO staff traveled over 29,000 miles providing on-site assistance to 144 companies in 44 of Ohio's 88 counties. Agency field staff often have expressed their thanks for helping small businesses rectify violations. • To provide better services to small businesses and leverage resources to gain the maximum effort for the dollar, Texas operates a site visit program. In 1999, 228 site visits were conducted for 171 businesses. Compliance increased by an average of 10 percent for all industries combined. • In the Virgin Islands, inspection of automobile repair and refinishing shops is almost complete on St. Thomas and St. John. 5-5 ------- Other accomplishments mentioned less frequently include holding conferences and workshops, sponsoring recognition and award programs, and receiving EPA grants. 5.3 TIPS AND BARRIERS At the request of the SBTCPs, a new section was added to the Reporting Form for sharing tips or barriers first developed or recognized by a program. Thirty-six programs (68 percent) shared their suggestions. The two most commonly suggested tips, of the many that were offered, were: 1. Partner with other programs and organizations (10 programs). • Massachusetts suggests using emergency planning requirements to promote prevention, since everyone has to have emergency plans. Focusing on this also involves local officials who have to respond to emergencies. This connects them to the facility's preventive efforts and the idea of chemical use reduction. • New Jersey's SBO/SBAP work with trade and business groups to sponsor or co-sponsor events to ensure member participation and to provide greater outreach with little or no cost to the state program. 2. Tailor the outreach message/provide sector-specific information so businesses can relate (7 programs). • Arkansas has had success in communicating pollution in economic terms. When a business is polluting, they often are losing chemicals or commodities, which simply is bad business. • Michigan's SBO and SBAP must work closely with the air quality regulatory program prior to initiating any outreach. For example, the SBAO worked with the air agency along with business and industry to address air quality compliance issues before workshop implementation. By holding a peer review session before the actual workshop, SBAP can modify its presentation to make the program as clear and smooth-flowing as possible. Less frequently mentioned tips include: • Maintain and update web site. • Provide multimedia information. • Conduct on-site visits to learn how small businesses do things. SBTCPs also were asked to identify barriers to their work. The two most commonly mentioned were: 5-6 ------- 1. Lack of funding/resources (9 programs). • One barrier for the District of Columbia's program has been the inability to hire full time SBO and SBAP staff and provide funding to accomplish set program goals. • In Virginia, resource constraints have hampered the ability to provide on-site assessments on a continuing basis. 2. Incomplete/inactive CAP (7 programs). • Appointments/establishment of the CAP continues to be an issue in Hawaii. The formal legislative appointment process serves as a barrier (logistical and practical) to Hawaii ever establishing a CAP. • North Carolina continues to have significant problems getting timely CAO appointments. The specific requirements for minority and majority legislative appointments, the turnover of executive staff, and appointments to a purely advisory board have created problems. The 2000 election year will guarantee even more difficulties. For these reasons, North Carolina will pursue a non- appointed, broad-based collection of individuals from small businesses, trade associations, etc. to act as an advisory board. A complete list of each program's tips and barriers may be found in Appendix F-3. 5.4 SUCCESS STORIES AND CASE STUDIES Another new addition that began with the 1998 reporting year is the request for success stories and case studies. These can serve as strong examples of a program's effectiveness and provide insight and inspiration to other small businesses and SBTCPs. Thirty-seven programs (70 percent) shared their success stories or case studies. Several success stories are included below. Success stories and case studies from all programs may be found in Appendix F-4. • In 1999, the South Coast Air Quality Management District's (CA) SBAP noted inconsistencies in how a certain permit fee exemption was being applied to small businesses, which had no prior history with the AQMD. A memo was sent to all engineering managers to alert them to this issue. In addition, whenever the SBAP staff helped complete an application that was entitled to the exemption, they included a note to the review engineer highlighting the exemption. This action saved businesses from paying a 50% surcharge for their permits. • A dry cleaner was referred to the Georgia SBAP for assistance by one of the enforcement programs. The SBAP visited the cleaner and determined that his 5-7 ------- compliance problems centered around his lack of familiarity with the dry-to-dry machine and recordkeeping. Staff members assisted him with the recordkeeping requirements and brought in a Union retailer to train him in the proper use of the machine. Union provided their assistance at no charge to us or the dry cleaner. The facility was reinspected several months later by the enforcement program and was found to be in compliance. Iowa Environmental Assistance Program (IAEAP) provided permitting assistance to an independent, 12-employee facility that produces custom aluminum and zinc castings for diverse manufacturers. After a review of the facility's operations and air emission sources, IAEAP determined that the company needed air quality construction permits for two existing casting emission sources and for two additional (new) casting sources that it planned to install. These applications subsequently were approved by IDNR, and construction permits were issued for the four sources. The permits required particulate matter (PM10) stack testing and opacity testing for the existing sources, which cost approximately $8,600. IDNR accepted an alternative testing regime proposed by IAEAP and the company in which one stack would be tested with additional testing only if the first test results showed excedence of allowable standards. As a result, the company saved $4,600 on their stack testing requirements. Gulf Wire Corporation, New Orleans, Louisiana, was the recipient of the first pollution prevention award for a small business. The company reduced its use of trichloroethylene, used to clean the welding wire it produces, by 20 percent. Missouri's on-site assessment team advised an aluminum smelting facility to recycle their pallets and cardboard. The team located an appropriate recycling facility to take the materials, which resulted in a savings of approximately $2,000 per month in disposal costs. New York's SBEO advocated for several owners/managers of residential properties in New York City that had been issued an Order of Consent for failure to submit a complete Title V Facility Permit application. The SBEO opposed the DEC Title V permitting violations and civil penalties, because failure to accept the emission cap in a timely manner did not cause a threat to health, safety, or the environment. As a result of meetings between the SBEO and DEC/EPA, DEC reduced the penalty amount for facilities whose actual emissions qualify for registration. Ohio's SBAP worked to reduce the permit fees for a customer. After many conversations, phone calls, e-mails, and meetings between the district and HQ staff, misunderstandings about the size and emission potential of the permitted sources were resolved. As a result, the permit fee was reduced from $4,000 to $300! Neighbors of a woodworking facility in central Pennsylvania complained about dust from the operation, and a DEP inspector told the facility to correct the problem. ENVIROHELP staff conducted a site visit and informed the facility that the air pollution control device was overloaded and recommended installing a second device such as a fabric filter. ENVIROHELP also provided information about financing available through DEP. Ultimately, the company used one of the financing options to purchase a fabric filter. 5-8 ------- • A West Virginia company with a portable crusher was issued an Notice of Violation and Cease and Desist order, which would have resulted in a $10,000 minimum fine and a $1,000 permit fee if a permit was found to be required for this process. SBAP acted as the company liaison and facilitated an OAQ Permitting determination of "No Permit Needed" and assisted OAQ Enforcement in the withdrawal of the NOV and C&D. • The Wisconsin SBAP brought a permitting issue to the attention of the Wl DNR, which resulted in the agency drafting a permitting exemption for auto body shops. The way current regulations are written, very small sources of air pollution were unable to fall under a permitting exemption. Although most body shops are well below the permitting threshold, they still need to apply for an air permit. The SBAP initiated a meeting and several site tours of body shops so the DNR rule writers could get a better idea of the emissions from these small sources. As a result, the agency agreed to a variance to the permitting regulations to exempt small auto body shops. 5-9 ------- 6.0 COMPLIANCE ASSURANCE ISSUES Each year, EPA's Office of Enforcement and Compliance Assurance (OECA) requests information on the SBTCPs' effectiveness in providing compliance assistance to small businesses. Common compliance problems are discussed in Section 6.1. Compliance issues in particular industry sectors are identified in Section 6.2. Recommendations to facilitate compliance are outlined in Section 6.3. Program confidentiality issues are discussed in Section 6.4. Finally, in Section 6.5, information is provided on the use of EPA's Small Business/Small Communities Policy. 6.1 COMMON COMPLIANCE PROBLEMS All SBTCPs provided insight on compliance issues addressed while providing technical assistance to small businesses. Common compliance problems, listed by decreasing occurrence for 1999, are shown in Table 6-1 and are compared with responses from 1998 and 1997. Responses for 1999 are detailed, by program, in Appendix G-1. TABLE 6-1 COMMON COMPLIANCE PROBLEMS 1999 1998 1997 Compliance Problem n Programs % Programs n Programs % Programs n Programs % Programs Not understanding regulatory requirements 52 98 51 96 49 92 Incomplete recordkeeping 51 96 48 91 42 81 Uncertain how to determine emission inventories/lack of technical expertise 50 94 45 85 45 85 Uncertain how to complete forms/complicated paperwork 48 91 42 79 44 83 Uncertain of permitting reguirements 48 91 42 79 37 70 Fear of regulatory agency or arbitrary enforcement 46 81 46 87 42 81 Operating without a permit 40 75 42 79 39 74 Improper storage/disposal of hazardous waste 30 57 25 47 29 55 Operating outside NSPS or MACT 24 45 22 42 23 43 Financing for pollution control reguirements 23 43 24 45 31 58 Failure to use proper eguipment to comply with applicable standards 18 34 18 34 12 23 Other 3 6 5 9 5 9 Not understanding regulatory requirements, incomplete recordkeeping, and a lack of technical expertise are virtually universal compliance problems, as reported by 50 or more programs each. Identifying key problems and gaps in understanding by the small businesses have helped the SBTCPs to best target their assistance efforts. 6-1 ------- 6.2 COMPLIANCE PROBLEMS IN PARTICULAR INDUSTRY SECTORS Added to the reporting process in 1998, programs were asked to indicate if certain compliance problems were prevalent in any particular industry sector. Twenty-one programs (40 percent) indicated at least one industry sector. Their responses are summarized in Table 6-2 and shown in full in Appendix G-1. TABLE 6-2 COMPLIANCE PROBLEMS IN INDUSTRY SECTORS Compliance Problem (# industry sectors mentioned) Industry Sector Specified (# programs indicating this sector) Not understanding regulatory requirements (11) Auto body (2) Metal finishers (1) Auto maintenance shops (2) Printers (1) Dry cleaners (2 Propane dealers (1) Surface coaters (2) Thermoset resin (1) Foundries (1) Wood products (1) Livestock operations (1) Operating without a permit (8) Aquaculture (1) New York City sources with city- Auto body (1) only permit (1) Furniture stripping (1) Surface coaters (1) Gas stations (1) Wood products (1) Metal finishers (1) Incomplete recordkeeping (10) Dry cleaners (10) Foundries (1) Surface coaters (2) Metal finishers (1) Auto body (1) Printers (1) Auto service (1) Thermoset resin (1) Chrome plating (1) Wood products (1) Uncertain of permitting requirements (3) Metal finishers (2) Aquaculture (1) Dairies (1) Uncertain how to determine emission inventories (3) Rock crushers (1) Small facilities (1) Surface coaters (1) Uncertain how to complete forms (6) Dry cleaners (2) Propane/ammonia dealers (1) Auto body (1) Small businesses (1) MACT sources (1) Surface coaters (1) Lack of financing (7) Degreasers (1) Small facilities (1 )| Dry cleaners (1) Surface coaters (1) Fiberglass (1) Tanks (1) Sandblasters (1) Operating outside NSPS/MACT (5) Dry cleaners (3) Chrome plating (1) Wood furniture manufacturing Solvent cleaning (1) (2) Thermoset resin (1) Improper storage of hazardous waste (8) Auto body (1) Metal finishing (1) Auto repair (1) Surface coating (1) Dry cleaning (1) Thermoset resin (1) Manufacturing (1) Wood products (1) Fear of regulatory agency (7) Dry cleaners (2) Printers (1) Auto service (1) Small businesses (1) Gas stations (1) Surface coaters (1) Metal finishing (1) Failure to use proper equipment (2) Degreasers (1) Surface coaters (1) 6-2 ------- Of the 11 categories of compliance problems, the number of categories in which a particular industry sector appears is shown in Table 6-3. TABLE 6-3 INDUSTRY SECTOR APPEARANCE IN COMPLIANCE CATEGORIES Industry Sector # of Compliance Problem Categories Surface coaters 9 Dry cleaners 7 Metal finishers 6 Auto body shops 5 Wood products 5 Auto maintenance shops 4 Small/medium businesses 4 Thermoset resin 4 Degreasers 3 Printers 3 Gas stations 2 Aquaculture 2 Chrome plating 2 Foundries 2 Propane/ammonia dealers 2 MACT sources 1 Rock crushers 1 Tanks 1 Livestock 1 Fiberglass 1 New York City sources 1 Dairies 1 Sandblasters 1 Furniture strippers 1 Manufacturing 1 Surface coaters appear in nine compliance problem categories. Dry cleaners and metal finishers closely follow, each appearing in seven and six categories, respectively. These three sectors also appeared most frequently in 1998. 6.3 RECOMMENDED CHANGES TO FACILITATE SMALL BUSINESS COMPLIANCE WITH THE CAA Recommendations made by SBTCPs for changes, at the state or federal level, to help small businesses comply with the CAA are summarized in Table 6-4. SBTCP staff members are uniquely qualified to make such recommendations, since they address current CAA compliance problems encountered by small business and attempt to provide effective solutions. Specific program responses may be found in Appendix G-2. 6-3 ------- TABLE 6-4 1999 SBTCP RECOMMENDATIONS FOR IMPROVING COMPLIANCE Recommendation # Programs % Programs Increased funding/continued adequate funding for SBTCPs 12 23 Allow flexibility/simplification in applying regulations to small businesses 10 19 Simplify paperwork/reporting requirements 8 15 Regulations written in plain English 6 11 Grants/loans for small businesses 6 11 Multimedia assistance 5 9 Generic outreach and training materials 4 8 Expand/facilitate effective communication between state and federal agencies 3 6 Develop compliance incentives 3 6 Develop a national public relations/advertising program 3 6 Clean and simple audit privileges/voluntary disclosure policies 2 4 Thirty-eight programs (72 percent) provided at least one recommendation for changes to improve small business compliance with the CAA. The priority of responses for 1999 nearly parallel those of 1998. Continued and increased funding for the state SBTCPs (ranked second last year) was mentioned by 12 programs as being the prime recommendation for improving compliance. As previously noted, a number of states operate with limited budgets and staffs. The personalized approach to technical and compliance assistance is expensive but has been shown to be effective in reaching the small business community; 23 percent of state programs believe that adequate financial resources are vital to continued and expanding high quality service. Another common recommendation, allowing flexibility and simplification in applying regulations to small businesses (ranked first last year), was mentioned by 10 programs. As in 1998, the third most common recommendation stressed by eight programs called for simplifying paperwork and reporting requirements, a suggestions that mirrors the number twp recommendation. 6-4 ------- 6.4 PROGRAM CONFIDENTIALITY AND CONFLICT OF INTEREST In early 1995, EPA's SBO worked with the SBTCPs and EPA's Office of Enforcement and Compliance Assurance to reach an agreement regarding the confidentiality of assistance provided to businesses via the SBTCP. Programs were asked how they avoid conflicts of interest (COI) and maintain confidentiality, particularly in those cases where the SBO or SBAP is located within the regulatory agency. Forty-seven programs (89 percent) reported no problems with COI or confidentiality issues regardless of whether a confidentiality policy is in place. Five programs did not respond to the question or indicated the question was not applicable (Alabama, Alaska, Maryland, Puerto Rico, and South Dakota). One program indicated that COI is unavoidable (District of Columbia). Responses to this question have remained consistent from year to year. SBTCPs consistently report that, for the most part, COI and confidentiality are non-issues in operating their programs. Program structures range from guaranty of confidentiality (more common) to providing no confidentiality. For example, assistance programs may be housed in non-regulatory departments, or a program may refer a business in need of technical assistance to such a provider that will guaranty confidentiality. Most programs provide for confidentiality of trade secrets. Many programs have policies that protect small businesses from penalties if violations are discovered during the course of their receiving technical assistance. Program responses to the issue of COI and confidentiality may be found in Appendix G-3. The following example responses reflect the range of COI issues and resolutions (from having an established confidentiality policy to having no such policy). • In Connecticut, compliance assistance efforts have been well defined. Assistance efforts are pursued proactively, separate from the Department's enforcement activities. Internally, efforts are coordinated to ensure roles and responsibilities between assistance and enforcement are clear and distinct. 6-5 ------- • During the developmental phase of the District of Columbia's program, a conflict of interest between the SBTCP and the Compliance and Enforcement branch was inevitable. Additional staffing and resources will eliminate or resolve this aspect of the program. • Louisiana has had no problems regarding confidentiality with state enforcement, because the state has a Freedom of Information Act. Regional EPA inspectors come into Louisiana, unannounced, and levy heavy fines on small businesses, which results in the perception that our program is not confidential. • Tennessee's Department of Environmental Conservation established a state audit policy. Top Department officials support the confidentiality of the program. The regulatory programs understand the benefits of confidentiality. The program will partner with other assistance agencies and regulatory programs to ensure compliance and regulatory understandings. • In Wyoming, the issue of confidentiality was previously addressed by the CAP. The existing state statute does not provide protection from discovery in legal proceedings from Freedom of Information Act requests. The Department is concerned about making adequate information available to the public and has no intention of pursuing a change in the law. 6.5 USE OF EPA'S SMALL BUSINESS/SMALL COMMUNITIES POLICY As a new reporting element in 1998, programs were asked if they used EPA's Policy on Compliance Incentives for Small Businesses (Small Business Policy) or a comparable state policy for small businesses/small communities. EPA's Small Business Policy, signed May 20, 1996, provides incentives to small businesses to participate in on-site compliance assistance programs and to conduct environmental audits. Under this policy, EPA will eliminate civil penalties provided the small business satisfies certain criteria. In 1999, as in 1998, very few states are making use of EPA's policy or developing their own, as shown in Table 6-5. TABLE 6-5 SMALL BUSINESS/SMALL COMMUNITY POLICY USE Policy Use Small Business Policy Act# programs Small Community Policy Act# programs Uses EPA policy 5 1 Developed state policy 12 2 Uses both EPA and state policy 2 0 NA/NR/None/Not used 34 50 6-6 ------- For both small businesses and small communities, SBTCPs then were asked to list: • The number of small entities qualifying under the policy. • The number of small entities attempting to use the policy; still under consideration. • The number of small entities attempting to use the policy, but not qualifying. • Total dollar amount of penalties reduced. Program responses are summarized in Table 6-6 and are shown in full in Appendix G-4. All references to small entities are for small businesses; programs did not report any use of the Small Communities Policy. TABLE 6-6 SMALL BUSINESS POLICY ACTIVITIES Policy Activities Programs Using Policy# of entities # Programs Indicating NA/NR/None/Not used Small businesses qualifying under the policy SC-1 TN - 17 51 Small businesses attempting to use policy; still under consideration TN - 17 52 Small businesses attempting to use policy, but not qualified SC-1 TN - 1 51 Total $ amount penalties reduced SC - $2,500 52 As was seen in 1998, the Small Business/Small Communities Policy seemingly has had little use. Programs likely are not yet tracking such statistics, as evidenced by the high number of programs not answering this question. 6-7 ------- APPENDIX A 1999 ANNUAL REPORTING FORM ------- STATE SMALL BUSINESS STATIONARY SOURCE TECHNICAL AND ENVIRONMENTAL COMPLIANCE ASSISTANCE PROGRAM (SBTCP) ANNUAL REPORTING FORM FOR THE PERIOD 1/1/99 TO 12/31/99 OMB NO.: 2060-0337 EXPIRATION DATE: 9/30/01 *** Completed forms are due by February 15, 2000 *** I inclosed is a blank copy of the Annual Reporting Form lor the State Small Business Stationary Source Technical and Iinvironmental Compliance Assistance Program (SBTCP) under the Clean Air Act (CAA) as amended in 1990. This Form covers information from Januan through I December 1999 and requests information on each of the three components of the SBTCP: • Small Business Ombudsman (SI JO) • Small Business Assistance Program (SBAP) • Compliance Advisory Panel (CAP) As you complete this Form, please remember that we are collecting objective information on each SI 3'1'CP. This report is not an evaluation of vour program. For vour convenience, we provided electronic copies of the Form in WordPerfect (SBTCP.WPD) and Microsoft Word (SBTCP.DOC). INSTRUCTIONS FOR COMPLETING THIS FORM 1. Please complete the electronic version of the Form. If you need additional space for your answers, enlarge the boxes provided for your responses. Do not answer questions by referring to attached documents or a previous SBTCP report. 2. You should already collect the information requested on this Form. I low ever, if a question asks for data you do not have, please provide a brief explanation of why it is not available. For future reports, you may need to revise the statistics that you track. 3. Once you have completed the Form, please return the disk and a completed hardcopy of the Form in the enclosed, pre-addressed mailer. If this mailer is missing or if you wish to use your own envelope, please return the disk and hardcopy to: Ms. Karen V. Brown Small Business Ombudsman ATTN: SBTCP Annual Report U.S. Environmental Protection Agency (2131) 401 IM Street, SW Waterside Mall, Room 3423 Washington, D.C. 20460 4. If you use your own mailer, please include on the mailer the words. "Iilectronic Media I inclosed." WHAT IF I HAVE QUESTIONS? If you have any comments or questions for how to improve this Form, please call the U.S. IiPA Small Business Ombudsman (IiPA SBO) at the numbers listed below . You can reach the SBO Monday through Friday from 8:30 a.m. to 5:00 p.m. (IiST). After these hours, you can leave a message on the answering machine, which is connected to the toll-free 800 number. (202) 260-0490 (Telephone) (800) 368-5888 (Toll-free I lotline) (202)401-2302 (Facsimile) ------- WHY IS EPA REQUESTING THIS FORM? As pail of the CAA. the U.S. Congress required that each state and territory establish a Small Business Stationary Source Technical and I Environmental Compliance Assistance Program (SBTCP) to help small businesses comply with this Act. As pail of its reporting requirements to Congress. HPA includes information about the SBTCP programs using information you provide on this Form. HPA has given the responsibility for this report to its SBO. who uses this Form as a standard information collection tool. SUGGESTIONS FOR COMPLETING THIS FORM • Gathering information for this report is definitely a team effort' Hnlist the help of key contacts from the SBO. the SBAP. and the CAP. and ask them to complete applicable sections. • One person should take responsibility to complete and submit this Form (most likely the SBO). • Refer to last year's Report to Congress and the information you provided on your Reporting Form last year when completing this year's Reporting Form. ------- SECTION 1 SOURCE OF THE INFORMATION This section is designed to collect standardized information about the SBTC V'.v completing this b'orm, and whom to contact if we have questions. 1.1 Name of state, territory, or local agency for which this report is being submitted. 1.2 Who should be contacted (primary and alternate contacts) if there are any questions regarding the information contained in this Form? /•'or the question "Relationship to SBTC" ire would like to know the relationship of that person to the SB1X program (i.e., CAP ('hairperson, SIX), etc.). Be sure to include the area code for the telephone and facsimile numbers, and also a telephone extension if appropriate. PRIMARY CONTACT ALTERNATE CONTACT Name Title Relationship to SBTCP Organization Address Address Citv. State. Zip Telephone Number Facsimile Number E-mail Hotline (national? state? toll free?) Internet home page ------- SECTION 2 STATUS, BUDGETS, STAFFING, ORGANIZATION This section is designed to collect four types of standardized information about your state's SBTCP: Status, Budgets, Staffing Levels, and Organization. The information you provided in last year's report will be helpful in answering the questions in this section. STATUS 2.1 When was your SBTCP established? Please note that in Question 2.2, ire are asking when each component of your SBTCP was began to operate (provide services), which may be different. SBTCP Comnoncnt Month and Year of Establishment SBO SBAP CAP 2.2 When did the SBTCP begin to provide operations (month and year)? To be consistent, for the SBC), indicate the effective date of appointment: for the SBAP, indicate the date it began providing assistance to small businesses: and for the (11\ indicate the date of the first meeting — even if not all members of the CAP were appointed by the time of the first meeting. SBTCP Comnonent Month and Year Onerations Be<«an SBO SBAP CAP BUDGETS 2.3 Please provide summary information on the funding for each component of your SBTCP (for the period January through December 1999). Please indicate the source of funding. /•'or example, sources of funding might include: Title I fees, specific appropriation of state funds, the operating budgets of existing programs, or some combination of sources. These budgets should include direct salaries, fringe benefits, materials cf supplies, etc. To keep it simple, please round your budgets to the nearest S100. If budgets are combined for 2 or for all components of your program, please indicate. 4 ------- 1999 BUDGET (S} SOURCE OF FUNDING (nlease describe} SBO SBAP CAP TOTAL 2.4 What was your SBTCP's budget in 1998? What is the expected SBTCP budget during the next reporting period (January through December 2000)? . l.v with the previous question, please round all numbers to the nearest S / 00. If these programs did not exist (or i fere not active) in 1999, please indicate. Also, please indicate if any program budgets are combined. 1998 BUDGET (S} 2000 PROJECTED BUDGET (S} SBO SBAP CAP TOTAL 2.5 Briefly describe any significant changes of more than 10% in the level of funding between the 1998, 1999, and 2000 annual budget periods. /•'or example, a previous period may have seen a high level of fines that were credited to the SBTCP program, perhaps Title I' revenues were lower than projected, or state appropriations may have been reduced or eliminated. STAFFING With these questions, ire want to know how many people support each component of your SBTCP. 2.6 How many people, measured as full-time equivalents (FTEs), support the SBO? Please complete this question for the staffing levels that are current as of December 1999. .1 n I'll: is considered to work 40 hours week. P'or example, 2 people working 20 hours week would be equivalent to / h'Tli. It is possible that the SBO has other responsibilities and does not perform this function on a full time basis, l-'or example, if they perform this function approximately 20 hours week (or 50% of their time), this would be equivalent to an 0.5 I'l li. SBO Function Number of FTEs SBO Other staff TOTAL STAFF ------- 2.7 How many people, measured as full-time equivalents (FTEs), support the SBAP? How many of these people are paid or serve as unpaid volunteers? How many of these people are retired engineers? Please complete this question for the staffing levels that are current as of December 1999. ! se the same definition for an I'll: as discussed in Question 2.6. Il'e want to know if the programs use unpaid volunteers as well as "retired engineer"programs for their equivalent) to support the SB. IPs. SBAP Staff Number of FTEs (including retired engineers, naid or unnaid) Paid Unpaid Volunteers TOTAL STAFF Retired Engineers Number of FTEs Paid Unpaid Volunteers TOTAL RETIRED ENGINEERS 2.8 How many people are currently serving on your CAP? Please indicate how many people have been appointed to your CAP as of December 1999. Please indicate each ('.1/' member's affiliation (i.e., small business, state regulatoiy agency, general public, etc.) If appropriate, indicate the number of people who have not been appointed to your CAP as of December 1999. When complete, this table should list a total of at least 7 people (including appointed and not yet appointed). AFFILIATION NUMBER OF PEOPLE ON CAP Owner (or representative) of small business State regulatory apencv General public Not vet appointed Other (please specify) 6 ------- ORGANIZATION 2.9 Please briefly describe where each component of your SBTCP is located/organized. Please indicate if the component is located in a regulatory agency, another agency, a university, etc. P'or example, in some programs, the SB. IP is in the state regulatoiy agency. If so, please list the name of the agency and the appropriate department, division, etc. (for example: Department of Environmental Protection, Bureau of Waste ,\ lanagement). Please indicate if the administrative location is regulatoiy or nonregulatoiy. (ienerallv, the CAP is independent and is located outside of all agencies, with each individual appointed as defined in Section 507. If your SBAP is contracted to an outside organization, please complete Question 2.11. SBTCP COMPONENT BRIEF DESCRIPTION OF ADMINISTRATIVE LOCATION REGULATORY OR NONREGULATORY? SBO SBAP CAP 2.10 Has management of all or part of the SBAP been contracted to an outside organization? If VPS, please complete Question 2.1 P YES NO 2.11 What is the outside organization that is operating your SBAP? SBAP Contractor Address Citv. State. Zip Telephone Number Facsimile Number Project Manager (or principal point of contact) IWJ Budget Term of Contract Portion of Program Under Contract 7 ------- 2.12 Does your program offer air-only assistance, or has your program moved into multimedia assistance? Air only Multimedia x ------- SERVICES PROVID%fc^i9^ITIES CONDUCTED 3.1 Briefly describe the assistance services of your SBO and SBAP. What is the number of eligible facilities, by industry sector, that your program assisted in 1999? He are interested in compiling statistics on the types of assistances and number of businesses reached, by industiy sector, through a variety of assistance seivices by the SBO and SBAP combined. To help you in completing this question, the following tables are provided. • In Table A, please list the number of each type ofseivice offered and the number of businesses reached, by industiy sector, through various outreach activities. If you only know the total businesses reached per industiy sector, please indicate this number in the "total" column in the right side of the table. If you only have information on the total number of businesses reached by various types of outreach activities, please indicate this in the "total" row at the bottom of the table. If multiple industiy sectors were reached by a particular outreach activity (for example, a permitting training program that was relevant to any industiy sector), please place this information in the "cross sector" categoiy. If you only track whether these activities occurred (and not the specific number of occurrences), please simply "check" the appropriate column. The number(s) next to each industiy sector is its 2-digit (major group) or 3-digit (industiy group) SIC' code. • In Table B, please indicate the total number of each type of assistance requests you receive by C.IA requests and multimedia requests. Please note that the options for the types of seivices have been limited. Please classify• the seivices you offer into one of these categories. If no categoiy is suitable, you can use the "Other" categoiy. You do not need to define what you have placed in the "Other" categoiy. The Report to ('ongress will reflect only these categories. XOTIi: An eligible facility is defined as a stationaiy source that: • Is owned and operated by a person that employs 100 or fewer individuals. • Is a small business concern as defined by the Small Business . let. • Is not a major stationaiy source. • Does not emit 50 tons or more per year of any regulated pollutant. • limits less that 75 tons per year of all regulated pollutants. 9 ------- Please indicate number of each type of service offered and the number of businesses reached for each relevant industry sector (# services / #businesses reached). TABLE A Industry Sector (SIC) Hotline Onsite Visit Seminars/ Workshops Publications Home Pa«e Teleconference Mailings Other TOTAL BUSINESSES REACHED Fxample Industry (xx) 1 10 7 7 3 200 4 500 1 200 3 100 2 50 1.067 Aerospace (37) Agriculture Farming Cron Sen ice (01. (17) Airports Air Transportation (45) Analytical Medical Instruments (38) Asbestos Remediation (17. 32) Asphalt (295) Attorney Consultant Fn»ineer (81. 87) Auto Motor Vehicle Dealers & Fquipment (55. 501) Auto Body Maintenance. Repair. Retinishin" (75) Bakeries (546) Moat Manut'acturin" (373) Boilers (34. 50) Business Sen ices (73) Chemicals Products (28) 10 ------- TABLE A Industry Sector (SIC) Hotline Onsite Visit Seminars/ Workshops Publications Home Pa«e Teleconference Mailings Other TOTAL BUSINESSES REACHED Communications (481 Concrete Aggregate (321 Construction Contractor (15. 16. 171 Cotton (iins (072) Crushed Stone Products Sand & ("navel C141 Dairy Feedlots Livestock (021 Degreasers Dry Cleaners Laundry Sen ices (7211 1 Electronics 1 Electric (Equipment Repair (36. 762) 1 Electroplating Chrome Plating (347l" (Engines & Turbines (3511 Food Beverage Products & Processing (20. 5141 Foundry Smelter. Forging. Casting W) !•'limiture Manufacture Repair Wood Finishing (25. 764) Gasoline Distribution (wholesale retail) (517. 5541 ------- TABLE A Industry Sector (SIC) Hotline Onsite Visit Seminars/ Workshops Publications Home Pa«e Teleconference Mailings Other TOTAL BUSINESSES REACHED Government (91. 95) (irains (irain Klevators f()l 1.4221 1 lospitals Medical 1 lealtli Sen ices (80) 1 lotels Motels (70) Incinerators Landfills Landfill (ias (495) Leather Fur (31. 2371 Machine Shon (3591 Machine Lquipment Manufacturing & Repair (35) Manutacturin". Misc. Metal Fabrication Finishing (34) Minims (Metal & Coal) (10. 12) Organizations Associations (86) Paints & Painting Coatings (172. 285) Paper Manufacturing & Products (26) Personal Sen ices (72) 12 ------- TABLE A Industry Sector (SIC) Hotline Onsite Visit Seminars/ Workshops Publications Home Pa«e Teleconference Mailings Other TOTAL BUSINESSES REACHED Petroleum Products. Storage. Pipelines (29. 461 Pharmaceuticals (283) Plastic Manufacturing Products (308) Plumbing 11VAC (171) Printing (iraphic Arts (27) Private Citizen Real 1 {state (65) Recreation Sen ices (79) Recycling (509) Renair. Misc. (76) Research & Testing Facilities 1 .aboratories (873) Restaurants (581 Retail Wholesiile Trade (50. 51. 59) Rubber Manufacturing Products (30) Sawmills Fogging Wood Products (24) Schools (82) Stone Clay Glass (32) Textiles & Apparel (22. 23) ------- TABLE A Industry Sector (SIC) Hotline Onsite Visit Seminars/ Workshops Publications Home Pa«e Teleconference Mailings Other TOTAL BUSINESSES REACHED Transit (Passenger) (41) Transportation Kuuinment (M) Transportation Sen ices (42. 44. 471 Utilities (49) Veterinarians (074) Waste Waste 1 laulinu (495) Wastew ater Treatment (495) Cross Sector Other TOTAL 14 ------- Please indicate the total number of assistance requests your program receives by Clean Air Act requests and multimedia requests. TABLE B TYPE OF ASSISTANCE REQUESTED TOTAL# OF RFOIJFSTS CAA Requests Non-air/IMultimedia Requests Compliance/Regulatory Information Monitoring Recordkeeping Financial/Funding Information Permitting General CAA Information Add to General Mailing List P2 Assistance Other TOTAL 3.2 Please list any high-priority industry sectors that your program targeted for assistance during this reporting period. 3.3 Briefly describe any outreach methods that were particularly effective for your program and why (e.g., number of businesses reached, cost effectiveness, improvements in compliance). ------- 3.4 Please provide a list of new documents that were prepared and distributed by your program during this reporting period. List industry sector, if applicable. 3.5 If your SBTCP services include an electronic bulletin board or Internet home page, please list the information that is accessible. Information Available Through the Bulletin Board or Home P;u>e Please check annronriate boxes Program description Contact listings Copies of regulations Permitting information Permit forms Emission inventory Policies Guidance documents, fact sheets, etc. Information on P2 options Multimedia List of available publications CAP information Calendar of events Links to related sites Other (please list) Do you ask for feedback on your web site or bulletin board? If so, what are your most common comments? 16 ------- How many times was your electronic bulletin board or home page accessed during the 1999 reporting period? COMPLIANCE ADVISORY PANEL 3.6 What were the major activities of the CAP during this reporting period? Maior CAP Activities Please check annronriate boxes Review of documents for readabilitv and/or content Appointment/hiring of staff and/or election of officers Review/advisement on SBO/SBAP outreach activities Review/comment on new/proposed regulations Review/comment on state legislative actions Defining CAP responsibilities Attendance bv CAP members at training sessions Meeting with small businesses/associations Other (please list) OTHER SERVICES/CONDUCT OF ACTIVITIES 3.7 Does your program have or is yourprogram planning a grant or loan program to assist small businesses comply with the CAA? YES NO If YES, please indicate the date (month/year) such a grant or loan program became/will become available and the funding levels for each. DATE AVAILABLE GRANTOR LOAN? NAME OF PROGRAM FUNDING I.EVE I, 17 ------- 3.8 Briefly describe the types of cooperative efforts that each component of the SBTCP has in place. How are you partnering with others? This question is critical to understanding how some programs, with limited budgets and resources (typically with the SB. IP and SBC) components) function, l-'or example, what types of cooperative efforts are in place with personnel from other departments, agencies, or organizations? SBTCP COMPONENT BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP 3.9 How does vour program avoid duplication of efforts with SBTCPs in other states or territories: lie want to find out to what extent programs share or exchange information with SBTCPs in other states and territories, l-'or example, did other programs develop factsheets or information packets that your SBTCused (with minimaI editing)? Strategy to Avoid Dunlication of Efforts Please check annronriate boxes Communication/networking w ithin own SBTCP and state agency personnel via phone, e-mail, mailing lists, etc. Meetings, conference calls, and other contacts with SBO/SBAP personnel within EPA region Networking through state or regional air group meetings (such as WESTAR-Western States Air Resources) Review of EPA documents/contacts with EPA Review of documents from other public, private, and/or university sources Information gathering from electronic sources Subscribe to SBO listserve or government ombudsman listserve Other (please list) IX ------- 3.10 Please indicate what actions were initiated by your SBTCP/CAP to follow the intent of the provisions of the Paperwork Reduction Act, the Regulatory Flexibility Act, and the Equal Access to Justice Act. The CAP is responsible for critiqueing how well the SBTCP follows the intent of the provisions of these three federal acts. To make it easy to complete this question, various possibilities for each. let are listed in the tables below. Please add additional items as appropriate. PAPERWORK REDUCTION ACT Please check annronriate boxes Routine review of information collection activities conducted by SBAP to ensure the information request is not duplicative or unnecessarilv burdensome Routine review of SBTCP documents for compliance Receiving/providing information electronicallv Simplified/consolidated permits or forms Eliminating unnecessary permits by increasing exemptions for insignificant actions General permits for certain tvpes of industries Other (please list) RF.GUIATORY FLEXIBILITY ACT Please check annronriate boxes Ensure that small businesses are allowed to participate in rulemakings that have an effect on them Ensure that all existing rules periodically are reviewed to determine their impact on small businesses and changed as necessarv Routine review of SBTCP documents for compliance Amnestv program Other (please list) F.OIJAL ACCESS TO JUSTICE ACT Please check annronriate boxes Routine compliance review of SBTCP documents Review of instances where state actions against small businesses appear unjustified Pro bono legal services Funding/technical assistance for groups aggrieved by regulatory actions Other (please list) 19 ------- SECTION 4 PROGRAM EFFECTIVENESS These questions are designed to collect information about program goals, measurement of effectiveness, and results. 4.1 What are your program's goals? Please indicate up to 3 choices, but number in terms of priority. RANK PROGRAM GOAL To increase the regulated community's understanding of their enyironmental obligations. To increase the regulated community's understanding of the permitting process. To increase the regulated community's understanding of the CAA. To provide site-specific compliance assistance. To encourage self-auditinu. To improve the compliance rates of the regulated community. Other (please explain). 4.2 How are you evaluating whether your above-stated goals are or are not being met? b'or example, you may use questionnaires, statistics on the number of businesses helped in a certain manner, the number of new permits issued, etc. Ideally, your goals and assessment strategies will be stated in quantifiable terms (e.g.. The SliTCP will target 2 business sectors through mailings, seminars, and on-site assistance to increase their rate of permit filings by 50%.). Your program may still be at the stage where your goals are of a more general nature (e.g.. The SB1X 7' will provide seivices to small businesses through a hotline, on-site visits, seminars, etc.). 20 ------- 4.3 What are the results of this measurement process? Did your SB'IX 7' meet its program goals' Did the measurement system work9 What statistics or comments did your SBTCgather to indicate that your goals have or have not been met? 4.4 Please feel free to include any information about your program that you would like to highlight (i.e., significant accomplishments, awards, recognitions, move to multimedia, etc.). ------- 4.5 Please share any tips/hints/barriers first developed or recognized by your program (e.g., Tips: Performance based reporting ideas, Hints: Ways to optimize program delivery, Barriers: Legislative mandate for appointing CAP and potential conflict with reporting process). 4.6 Success stories/case studies are strong examples of a program's effectiveness. Please share any success stories/case studies, including type of business(es) helped, existing problems, outreach methods used, improvements in compliance, etc. 22 ------- SECTION 5 COMPLIANCE ASSISTANCE 5.1 What are the most common compliance problems identified by the facilities? In the course of providing technical assistance, what have been the most common compliance issues addressed' Examples of compliance problems may include incomplete reports, lack of permits for new equipment or changes in processes, operating outside of Maximum Achievable Control Technology (MACT) or .Wir Source Performance Standards (XSPS), or unpermitted emissions. Please indicate if certain problems are prevalent in any particular industiy sector. A number of possible answers are listed below. Please check all those appropriate. Common Compliance Problems Any specific industry sector? Please check appropriate boxes Not understanding regulatory requirements Operating without a permit Incomplete recordkeeping Uncertain of permitting requirements/need for multiple permits Uncertain how to determine emission inventories/general lack of technical experience Uncertain how to complete forms/complicated paperwork Lack of financing for pollution control equipment/technologies Operating outside NSPS or MACT Improper storage/disposal of hazardous waste Fear of regulatory apencv/arbitrarv regulatory enforcement Failure to use or find the right equipment to comply with applicable standards Other (please list) Please list any specific regulations, monitoring, or recordkeeping requirements that are particular problems. Please add any additional comments you have regarding common compliance problems. ------- 5.2 What changes would you recommend, at either the state or federal level, to assist small businesses to comply with the CAA? Please list any suggestions you have. We intend to compile the list of recommendations and highlight these in the report to ('ongress. 5.3 Briefly describe how the SBTCP avoids internal or external conflicts of interest (COI) or perception that this program mav not be confidential. Briefly describe any issues that may have developed and how tney were resolved. In early / 995, HP. 1 's SIX) worked with the SBTC'Ps and HP. 1 's Office of Enforcement and ('ompliance Assurance to reach an agreement regarding the confidentiality of assistance provided to businesses via the SBTC 'P. With this question ire want to know how programs avoid ('OI and maintain confidentiality — particularly in those cases where the SHIP is in the regulatoiy agency. 5.4 Has your program used EPA's Policy on Compliance Incentives for Small Businesses (Small Business Policy) or a comparable state policy for small businesses/small communities? If so, please provide narrative details on your activities in the boxes below, and then complete the table for the period January through December 1999. SMAIl BUSINESS POIJCV ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES 24 ------- # Small Entities Qualifying Under the Policy # Small Entities Attempting to Use Policy, Still Under Consideration # Small Entities Attempting to Use Policy, But Not Qualifying Total S Amount of Penalties Reduced Small Business Policy Small Communities Policy This is the end of the 1999 SBTCP Annual Reporting Form. Thank you, and all contributors, for the completeness and accuracy of your Report. A copy of the EPA 1999 Report to Congress will be provided upon its submittal. 25 ------- APPENDIX B FEDERAL SMALL BUSINESS OMBUDSMAN ------- APPENDIX B-1 OFFICE OF THE EPA SMALL BUSINESS OMBUDSMAN U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF THE SMALL BUSINESS OMBUDSMAN 1200 PENNSYLVANIA AVENUE, NW (2131) WASHINGTON, DC 20460 800-368-5888 202-260-0490 (in DC area) 202-401-2302 (fax) The Office of the Small Business Ombudsman serves as an effective conduit for small businesses to access EPA and facilitates communications between the small business community and the Agency. The Office reviews and resolves disputes with EPA and works with EPA personnel to increase their understanding of small businesses in the development and enforcement of environmental regulations. The SBO's primary customer group is the nation's small business community. Significant secondary customer groups include state and EPA regional small business ombudsmen and national trade associations serving small businesses. In response to the identified needs of the Office's target customer groups, the SBO has undertaken a variety of major outreach efforts including: • Serving as liaison between small businesses and the EPA to promote understanding of Agency policy and small business needs and concerns. • Staffing a small business hotline that provides regulatory and technical assistance information. • Maintaining and distributing an extensive collection of informational and technical literature developed by the various EPA program offices. • Making personal appearances as a speaker or panelist at small business-related meetings. • Interfacing on an on-going basis with over 70 key national trade associations representing several million small businesses and with state and regional ombudsmen who serve businesses on the local level. Also in contact with over 450 additional national organizations that represent millions of small businesses. • Providing guidance on the development of national policies and regulations that impact small businesses. The SBO actively seeks feedback on its responsiveness to small business' inquiries and ever- evolving needs, primarily in the areas of technical assistance and advocacy. The SBO can 1 ------- "package" relevant information for the most effective and efficient delivery -- be it through training seminars, fact sheets, or position papers -- to its target audience. Individual outreach activities are tracked and reported by the SBO on a monthly basis. Key statistics include numbers and types of hotline calls and written inquiries; nature and results of small business advocacy efforts; and personal appearances at conferences, seminars, and training sessions. Random, informal quality checks of customer satisfaction ensures that program performance meets or exceeds customer expectations. The SBO also serves as the Agency's Asbestos Ombudsman. Information concerning asbestos management may be obtained through the same toll-free hotline service as that which serves small business needs. SBO STAFF EPA's Small Business Ombudsman is Karen V. Brown, who was appointed to this position by Administrator Lee Thomas in 1985. In 1988, she was named the Agency's Asbestos Ombudsman in addition to her small business duties. Ms. Brown has served the Agency since 1981 holding a series of management positions. She is a graduate biologist and chemist. Robert C. Rose, an Industrial Engineer, joined the Office of Asbestos and Small Business Ombudsman as Deputy Ombudsman in 1991. He has over 30 years of management service with EPA. Staff Assistants to the Ombudsman are James Malcolm, Chemical Engineer; Arnold B. Medbury, P.E., Mechanical Engineer; Larry O. Tessier, P.E., Civil Engineer; and Thomas J. Nakley, Civil Engineer. TOLL-FREE HOTLINE SERVICE The Ombudsman operates a toll-free hotline for the convenience of small businesses, trade associations, and others seeking access to the Ombudsman. A member of the Ombudsman's staff will answer between 8:30 AM and 4:30 PM EST. Message-recording devices for calls during non-business hours and overload periods are provided. All calls are personally handled on a fast turn-around basis. The toll-free hotline number is: • 800-368-5888 • 202-260-0490 (in DC area) 2 ------- Callers request information on a variety of topics including: • Clean Air Act regulations • Underground storage tank notification • Small quantity generator requirements • Effluent standard guidelines • Used oil • Asbestos compliance • Waste minimization/pollution prevention • Pesticide registration fees. Increases in the number of direct-dial calls and hotline calls (from 4,000 calls per year in the early 1980s to the current level of 1,000 - 1,500 calls per month) and the associated distribution of technical and informational literature, growth in requests for personal appearances at conferences and workshops, and an expansion in participation in policy-making activities are evidence of the customer groups' confidence in the integrity and proactive stance of the SBO. REGULATORY TRACKING AND ANALYSIS The SBO performs a careful review of all proposed regulatory actions published in the biannual regulatory agenda to make a prima facia determination of small business impact. From the agenda, certain proposed regulations are selected that appear to have the potential for adverse impact on small businesses. In 1999, the SBO reviewed and/or monitored over 100 regulatory actions with some significant degree of intensity. In all instances, the SBO endeavored to minimize the requirements (especially reporting and record keeping) on small businesses. Equally significant is the level of voluntary compliance with EPA regulations by the small business community as a result of the rapport established between the Ombudsman and trade associations during the developmental phase of the regulations. MAJOR INITIATIVES IN 1999 The SBO's efforts to assist the small business community continue at a high level. Key accomplishments and activities for 1999 (some of which are on-going) include: • Hosted sixth National Small Business Ombudsman and Technical Assistance Program Conference in Tampa, FL, which was attended by 47 states, 2 territories, and the District of Columbia (200 participants). Set plans and issued a grant to the state of Montana's Department of Environmental Quality to coordinate a seventh conference in June 2000 in Missoula. • Developed external stakeholder guidance and acted as a principal participant in the Agency's Eighth Regulatory Tiering (prioritizing) Process. 3 ------- • Coordinated individual meetings and follow-up meetings among major small business trade associations and the EPA Deputy Administrator, Assistant Administrators, and Agency Small Business Program Office representatives to discuss small business initiatives and issues. Several meetings were held in 1998 and on June 11 in 1999. • Finalized EPA's 1998 Small Business Ombudsman Report to Congress under Section 507 of the 1990 Clean Air Act Amendments. • Cooperatively managing the Small Business Regulatory Enforcement Fairness Act of 1996 Small Business Entity Outreach Sub-group to implement Act requirements. • Conducted Small Business Liaison Conference for EPA Regional Small Business Representatives on August 3-4, 1999, which was attended by over a dozen state small business program representatives. • Upgraded the EPA Small Business Ombudsman Internet home page at www.epa.gov/sbo. • Participated in 40 to 50 EPA Regulatory work groups as formal reviewers to represent small business concerns. • Conducted a state Compliance Advisory Panel Training and Networking Meeting in Tampa, FL in April 1999 for 22 CAPs using a newly completed Compliance Advisory Panel Management Manual to assist state CAPs with their CAA responsibilities. Planning another all-day state CAP training program in Missoula, MT for June 2000. • Issued a State Resource Guide for Small Business Assistance Programs. • Issued an Environmental Management Assistance Guide for Small Laboratories. This document currently is being upgraded and expanded. • Developing a Source Book on Environmental Auditing for Small Business. • On October 6, 1999, awarded Cooperative Agreements to ten states to improve their small business technical assistance and outreach programs and to measure their assistance effectiveness. (Previously conducted a one-day orientation program for potential awardees on August 5, 1999.) 4 ------- APPENDIX C FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM ------- APPENDIX C EPA'S FEDERAL SMALL BUSINESS ASSISTANCE PROGRAM The EPA provides technical guidance for the use of the states/territories in the implementation of their programs. The Federal Small Business Technical Assistance Program (Federal SBAP) is coordinated by the Information Transfer Group (ITG) of the Office of Air Quality Planning and Standards (OAQPS). Other EPA programs participating in activities to assist the states include the Office of Compliance, the Chemical Emergency Preparedness and Prevention Office, and the Pollution Prevention Division. ELECTRONIC ACCESS The Federal SBAP is actively involved in expanding the use of electronic media as a tool for access to EPA information by small businesses, state SBAPs, and the general public. • The SBAP home page on the World Wide Web, part of the Technology Transfer Network (TTN), provides access to EPA small business assistance information and materials. Links to other small business-related sites also are provided. The SBAP home page address is www.epa.gov/ttn/sbap. In 1998, users retrieved over 1,500,000 files from the TTN. • The SBAP home page serves as a communication link for state SBAPs and includes a list of state and EPA smalf business program contacts. The home page also provides a forum to share information and outreach materials developed specifically for small businesses. • The Office of Air and Radiation, Policy and Guidance home page, also part of the Technology Transfer Network, contains proposed and final rules; background, guidance, and plain- English fact sheets; and implementation strategy updates and schedules. PLAIN ENGLISH GUIDANCE MATERIALS The Federal SBAP prepares materials for use by the states to explain new EPA CAA rules in plain English. These include detailed guidebooks with options for compliance, including pollution prevention; sample reporting and recordkeeping forms; and example calculations. These are distributed to state SBAPs as well as directly to small businesses; both hard copy and electronic formats are provided to allow for state-specific customization and reproduction as needed. • Halogenated Solvent Cleaning (completed May 1995) • Chromium Electroplating and Anodizing (completed May 1995) • Wood Furniture (completed September 1997) • Potential-To-Emit (1999). 1 ------- SATELLITE SEMINARS The Federal SBAP is working with EPA's Small Business Ombudsman (SBO) and OAQPS's Education and Outreach Group to present a series of satellite downlink seminars to educate small businesses on new EPA air regulations. Past seminars include: • Perc Drycleaners (May 1994) had 3,000 participants at 197 sites in 48 states, one Canadian site, and two in Mexico. • Halogenated Solvent Cleaning/Deareasing (May 1995) had 1,300 participants at 101 sites in 45 states, one site in Canada, and two in Mexico. • Chromium Electroplating (November 1995) had 2,000 participants at 140 sites in 43 states. • Green and Profitable Printing (May 1996) was presented in cooperation with EPA's Office of Compliance through the Printer's National Environmental Assistance Center. • Wood Furniture Manufacturing (September 1996) had approximately 1,900 participants at 140 sites in 34 states. • Consumer Products (October 1998) had approximately 600 participants at 100 sites in 40 states. This project included a post-broadcast help-site on the Internet, and distribution of broadcast video tapes upon request. ANNUAL CONFERENCE From 1993 to 1997, EPA held an annual SBO/SBAP Conference, which was co-sponsored by OAQPS*s Federal SBAP and the EPA SBO. Beginning in 1998, responsibility for the annual conference was moved to an individual State program; funding was provided by EPA in the form of a grant. The host State was assisted in conference planning by a committee of State program representatives. The purpose of this meeting is to: • Facilitate communication among the state programs. • Facilitate implementation and operation of small business assistance programs. • Interpret regulatory and policy developments affecting small businesses. OTHER PARTNERSHIP ACTIVITIES The Federal SBAP is working with staff from EPA's Office of Policy, Office of Compliance, and Pollution Prevention Division to determine a strategy to encourage all of the various small business assistance providers (i.e., SBAPs, Small Business Development Centers, pollution prevention programs, Manufacturing Extension Programs, etc.) to coordinate efforts within their state. This would provide small businesses with easier access to comprehensive business and environmental assistance. 2 ------- APPENDIX D SBTCP STATUS, BUDGETS, STAFFING AND ORGANIZATION ------- TABLE D-1 STATE SMALL BUSINESS ASSISTANCE PROGRAMS KEY CONTACT LISTING Updated 7/20/01 Under state column, (A) denotes an «air only assistance program. (M) denotes a multimedia assistance program. STATE OMBUDSMAN SBAP OTHER SBAP ALABAMA (M) Blake Roper, Ombudsman Office of Education and Outreach AL Department of Environmental Management P.O. Box 301463 Montgomery, AL 36130-1463 334-394-4355 334-394-4383 (F) 800-533-2336 (national) rbr(®adem. state, al. us Mike Sherman Ar Division AL Department of Environmental Management P.O. Box 301463 Montgomery, AL 36130-1463 334-271-7873 334-279-3044 (F) 800-533-2336 (national) rnhsi® adem. state, al. us ALASKA (A) Tom Turner (acting) AK DEC 555 Cordova Street Anchorage, AK 99501 907-269-7582 907-269-7687 (F) 800-510-2332 (state) tturner(®envircon.state, ak. us ARIZONA (M) Ira Domsky AZ DEQ 3033 N. Central Avenue Phoenix, AZ 85012 602-207-2365 602-207-4872 (F) 800-234-5677 (state) imd(®ev. state, az. us ARIZONA - Maricopa County Richard Polito Maricopa County SBEAP 1001 N. Central, Suite 200 Phoenix, AZ 85004 602-506-5102 602-506-6669 (F) rpolito@mail.maricopa.gov Maureen Lynch or JaeChang Maricopa County SBEAP 1001 N. Central, Suite 500 Phoenix, AZ 85004 602-506-5150 or 5149 602-506-6669 (F) mlynch@mail.maricopa.gov or ichana@mail.maricoDa.aov D-1 -1 ------- STATE OMBUDSMAN SBAP OTHER SBAP ARKANSAS (M) Joe Bob Garner Department of Environmental Quality P.O. Box 8913 8001 National Drive Little Rock, AR 72219-8913 501-682-0866 501-682-0880 (F) 888-233-0326 (national) aa rner@adea.state.ar. us Amanda Gregory Department of Environmental Quality P.O. Box 8913 8001 National Drive Little Rock, AR 72219-8913 501-682-0819 501-682-0880 (F) 888-233-0326 (national) areaorv(®adea.state, ar. us CALIFORNIA (A) Kathleen Tschogl Office of the Ombudsman California EPA Air Resources Board 2020 L Street P.O. Box 2815 Sacramento, CA 95814 916-323-6791 916-323-2393 (F) 800-272-4572 (state) ktschoal(®arb.ca.aov Peter Venturini California EPA Air Resources Board Stationary Source 2020 L Street P.O. Box 2815 Sacramento, CA 95814 916-445-0650 916-327-7212 (F) (800) 272-4572 (State) Dventuri(®arb.ca.aov Jeff Lindberg California EPA CARB-Office of Sm. Business Ombudsman 2020 L Street P.O. Box 2815 Sacramento, CA 95814 916-323-6791 916-323-2393 (F) jlindber@arb.ca.gov CALIFORNIA - South Coast (A) Tim Brown Public Advisor South Coast Air Management District Small Business Assistance Office 21865 E. Copley Drive Diamond Bar, CA 91765 909-396-3235 909-396-3638 (F) tbrown@aqmd.gov Larry Kolczak, Community Relations Manager South Coast Air Management District Small Business Assistance Office 21865 E. Copley Drive Diamond Bar, CA 91765 909-396-3215 909-396-3638 (F) 800-388-2121 (State) 800-CUT-SMOG (state) Lkolczak@aamd.aov COLORADO (M) Nick Melliadis CDPHE OCS-INF-A1 4300 Cherry Creek Drive, South Denver, CO 80246-1530 303-692-2135 303-691-1979 (F) 800-886-7689 (state) nick.melliadis@state.co.us Chuck Hix CDPHE APCD/55/B-1 4300 Cherry Creek Drive, South Denver, CO 80246-1530 303-692-3148 303-782-0278 (F) chuck.hix@state.co.us D-1-2 ------- STATE OMBUDSMAN SBAP OTHER SBAP CONNECTICUT (M) Tracy Babbidge, Ombudsman Small Business Assistance Program Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 860-424-3382 860-424-4063 (F) 800-760-7036 (state) tracv babbidae@DO state ct us DELAWARE (A) Kim Finch DE DNRC 89 Kings Highway Dover, DE 19901 302-739-6400 302-739-6242 (F) kfinchi® dnrec.state.de. us Bob Barrish DE NREC 715 Grantham Lane Newcastle, DE 19720 302-323-4542 302-323-4561 (F) bbarrish(®dnrec state de us DISTRICT OF COLUMBIA (A) Sandra Handon DC Dept of Health/EHA/AQD Air Quality Division 51 N Street, N.E., 5th Floor Washington, DC 20002 (202) 535-2255 (202) 535-2881 (F) shandon@dchealth.com N. Olivia Achuko Air Quality Division EHA/Department of Health 51 N Street, NE, 5th Floor Washington, DC 20002 (202) 535-2997 (202) 535-2881 (F) noa@mail environ state dc us FLORIDA (M) Elsa Bishop Small Business Ombudsman Environmental Administrator Division of Air Resource Management Office of Air Communication & Outreach 2600 Blair Stone Road, MS-5500 Tallahassee, FL 32399-2400 850-414-8399 850-922-6979 (F) 800-722-7457 (state) elsa bishoD(®deD state fl us Elsa Bishop Dual role as SBAP Director Stephen McKeough 850-921-9584 Bruce Thomas 850-921-7744 Kim Tober 850-488-1348 Same address, fax, and hotline for all GEORGIA (M) Anita Dorsey-Word GA SBAP DNR/EPD/APB 4244 International Parkway, Suite 120 Atlanta, GA 30354 404-362-4842 1-877-427-6255 (Toll Free) 404-363-7100 (F) adword(®mail dnr state aa us D-1-3 ------- STATE OMBUDSMAN SBAP OTHER SBAP HAWAII (M) Patrick Felling HI Department of Health Environmental Ombudsman 919 Ala Moana Boulevard, Suite 219 Honolulu, HI 96814 808-586-4528 808-586-7236 (F) Dfellina(®eha health state hi us Robert Tam HI Department of Health Clean Air Branch 919 Ala Moana Boulevard Honolulu, HI 96814 808-586-4200 808-586-4359 (F) rtam@eha.health.state.hi.us Willie Nagamine HI Department of Health Clean Air Branch P.O. Box 3378 Honolulu, HI 96801 808-586-4200 808-586-4359 (F) IDAHO (M) Sally Tarowsky Small Business Advocate Idaho DEQ 1410 N Hilton Boise, Idaho 83706 208-373-0472 208-373-0342 (F) starowsk(®dea state id us ILLINOIS (A) Donald Squires Illinois EPA/DAPC Small Business Ombudsman 1021 N. Grand Avenue East, 2nd Floor P.O. Box 19276 Springfield, IL 62794-9276 217-785-1625 217-785-8346 (F) 888-372-1996 (state) eoa8139@eDa.state.il. us Roslyn Jackson Illinois Department of Commerce and Community Affairs 620 East Adams, 3rd Floor Springfield, IL 62701 217-524-0169 217-785-6328 (F) 800-252-3998 (state) rjackson@commerce.state.il. us Jackie Neuber IL EPA Bureau of Air 1021 N. Grand Ave. East Springfield, IL 62794 217-782-9333 217-782-1875 (F) epa2157@epa.state.il. us INDIANA (M) Erika Seydel Cheney IDEM - OB&LR 100 N. Senate P.O. Box 6015 Indianapolis, IN 46206-6015 317-232-8598 317-232-6647 (F) 800-451-6027 (press 0, request X2-8598) (state) esevdel@dem.state.in.us Cheri Storms IDEM SBA 100 N. Senate, Room 1320 P.O. Box 6015 Indianapolis, IN 46206-6015 317-233-1041 317-233-5627 (F) 800-451-6027 cstorms@dem.state.in.us Marc Hancock IDEM-CTAP Ista Building 150 W. Market Street, Suite 703 Indianapolis, IN 46206 317-232-8172 317-233-5627 (F) 800-988-7901 mhancock@dem.state.in.us IOWA (M) IA Department of Development Small Business Liaison 200 E. Grand Street Des Moines, IA 50309 515-242-4761 515-242-4749 (F) 800-358-5510 (state) John Konefes IA Waste Reduction Center University of Northern Iowa 1005 Technology Parkway Cedar Falls, IA 50614-0185 319-273-8905 319-268-3733 (F) 800-422-3109 (state) konefes@uni.edu Wendy Walker IA Department of Natural Resources 7900 Hickman Road Urbandale, IA 50322 515-281-8574 515-242-5094 (F) wendy. walker@dnr.state, ia. us D-1-4 ------- STATE OMBUDSMAN SBAP OTHER SBAP KANSAS (M) Janet Neff Environmental Ombudsman Office of Pollution Prevention KS DH&E Forbes Field, Building 283 Topeka, KS 66620 785-296-0669 785-291-3266 (F) 800-357-6087 (national) ineff(®kdhe state ks us Richard Nelson Pollution Prevention Institute Kansas State University 133 Ward Hall Manhattan, KS 66506-2508 785-532-4999 785-532-6952 (F) 800-578-8898 (N) rnelson@ksu.edu Sherry Davis, Industrial P2 Specialist Pollution Prevention Institute 133 Ward Hall Manhattan, KS 66506-2508 785-578-8898 785-532-6452 (F) 800-578-8898 (N) sbd@ksu.edu KENTUCKY (A) Rose Marie Wilmoth, Air Quality Representative Office of Commissioner Department for Environmental Protection 14 Reilly Road, Ash Building Frankfort, KY 40601 502-564-2150, x128 502-564-4245 (F) 800-926-8111 (national) wilmoth(®nrdeD nr state kv us Gregory C. Copley, Director Kentucky Business Environmental Assistance Program Gatton College of Business and Economics University of Kentucky Lexington, KY 40506-0034 606-257-1131 606-323-1907 (F) 800-562-2327 (national) occodH (©DOD.ukv.edu Susan Weaver Division of Air Quality KY DNR&EP 803 Schenkel Lane Frankfort, KY 40601 502-573-3382 502-573-3787 (F) susan.weaver@mail.state.ky.us KENTUCKY - Jefferson County (A) Cara S. Waddell Small Business Air Pollution Ombudsman Department of Planning & Environmental Management 810 Barrett Avenue, Room 637 Louisville, KY 40204 502-574-5164 502-574-8188 (F) LOUISIANA (M) Jim Friloux, Small Business Ombudsman LA DEQ P.O. Box 82263 Baton Rouge, LA 70884 225-765-0735 225-765-0746 (F) 800-259-2890 (state) jim_f@deq.state.la.us Dick Lehr LA DEQ P.O. Box 82135 Baton Rouge, LA 70884-2135 225-765-2453 225-765-0921 (F) 800-259-2890 (state) richard_l@deq.state.la.us Beth Altazan-Dixon LA Department of Environmental Air Quality Division P.O. Box 82135 Baton Rouge, LA 70884-2135 225-765-2450 225-765-0921 (F) 800-259-2890 (state) beth a@dea.state.la.us D-1-5 ------- STATE OMBUDSMAN SBAP OTHER SBAP MAINE (M) Ron Dyer Department of Environmental Protection Office of Innovation and Assistance State House, Station 17 Augusta, ME 04333 207-287-4152 207-287-2814 (F) 800-789-9802 (state) ron e dyer@state me us www state me us/deD Roy Krout, Coordinator Small Business Assistance Program Department of Environmental Protection State House, Station 17 Augusta, ME 04333 207-287-8550 207-287-2814 (F) 800-789-9802 (state) roy t krout@state me us www state me us/deD Jim Brooks Department of Environmental Protection Bureau of Air Quality State House, Station 17 Augusta, ME 04333 207-287-2437 207-287-7641 (F) MARYLAND (M) Don Jackson MD Department of the Environment Office of Community Assistance 2500 Broening Highway Baltimore, MD 21224 410-631-3165 410-631-4108 (F) 800-633-6101, X3772 (state) diackson(®mde state md us Andrew Gosden MD Department of the Environment Environmental Permits Service Center 2500 Broening Highway Baltimore, MD 21224 410-631-4158 410-631-4477 (F) 800-633-6101 X4158 (National) aaosden@mde.state.md. us MASSACHUSETTS (M) MICHIGAN (A) Cindy Douglas Ml Economic Development Corporation Victor Building 201 N. Washington Square Lansing, Ml 48913 517-373-4600 517-241-3689 (F) doualasc(®michiaan ora Dave Fiedler MDEQ Environmental Assistance Division P.O. Box 30457 Lansing, Ml 48909 517-373-0607 517-335-4729 (F) 800-662-9278 (national) fi edl e rd(® state, m i. us MINNESOTA (M) Charlie Kennedy MPCA/PPRF/SBO 520 Lafayette Road St Paul, MN 55155-4194 651-297-8615 651-297-8676 (F) 800-985-4247 (state) charlie kennedv(®Dca state mn us Troy Johnson MPCA/MDRF/SBAP 520 Lafayette Road St. Paul, MN 55155 651-296-7767 651-282-6247 (F) 800-657-3938 (state) trov.iohnson(®Dca. state, mn. us D-1-6 ------- STATE OMBUDSMAN SBAP OTHER SBAP MISSISSIPPI (M) Jesse Thompson Small Business Ombudsman MS DEQ 2380 Hwy. 80 West P.O. Box 20305 Jackson, MS 39289 601-961-5167 601-961-5541 (F) 800-725-6112 (national) jesse_thompson@deq.state, ms. us Randy Wolfe Small Business Technical Assistance Dir. MS DEQ 2380 Hwy. 80 West P.O. Box 20305 Jackson, MS 39289 601-961-5166 601-961-5541 (F) 800-725-6112 (national) 800-361-4827 (national) randv wolfe@dea. state, ms. us Cathy Johnson SBAP MS DEQ 2380 Hwy. 80 West P.O. Box 20305 Jackson, MS 39289 601-961-5676 601-961-5541 (F) 800-725-6112 (national) cathyJohnson@deq.state.ms.us MISSOURI (M) Leigh Walton State of Missouri, Office of the Governor State Capitol Jefferson City, MO 65102 573-751-3222 573-526-5808 (F) 800-361-4827 (national) waltol@mail.dnr.state, mo. us Byron Shaw, Jr. DNR Technical Assistance Program 1659 E. Elm Street P.O. Box 176 Jefferson City, MO 65102 573-526-6627 573-526-5808 (F) 800-361-4827 (national) nrshawb@mail.dnr.state, mo. us MONTANA (M) Bonnie Rouse Department of Environmental Quality P.O. Box 200901 1520 E. 6th Avenue Helena, MT 59620-0901 406-444-3641 406-444-1499 (F) 800-433-8773 (national) brouse@state.mt.us Warren Norton Department of Environmental Quality Air Quality Division P.O. Box 200901 1520 E. 6th Avenue Helena, MT 59620-0901 406-444-2960 406-444-1499 (F) 800-433-8773 (national) wnorton@state.mt.us Ned Pettit Department of Environmental Quality Business and Community Assistance P.O. Box 200901 1520 E. 6th Avenue Helena, MT 59620-0901 406-433-8773 406-444-6836 (F) 800-433-8773 (national) nDettit(®state.mt.us NEBRASKA (M) Tom Franklin Public Advocate Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 402-471-8697 402-471-2909 (F) torn.franklin® ndea.state, ne. us D-1-7 ------- STATE OMBUDSMAN SBAP OTHER SBAP NEVADA (M) Marcia Manley Small Business Ombudsman NV Department of Environmental Protection 333 West Nye Lane Carson City, NV 89706-0851 775-687-4670, x3162 775-687-5856 (F) 800-992-0900, x4670 (state) mmanlev(®aovmail state nv us Janet Goodman Small Business Program Manager NV Department of Environmental Protection 333 West Nye Lane Carson City, NV 89706-0851 775-687-4670, x3067 775-687-5856 (F) 800-992-0900, x4670 (state) iaoodman(®aovmail. state, nv. us Kevin Dick UNR/NV SBDC Business Environmental Program College of Business Administration-032 Reno, NV 89505-9975 775-784-1717 775-784-4237 (F) NEW HAMPSHIRE (M) Rudolph Cartier Dual Role as Ombudsman and SBAP Principal Rudolph Cartier Air Resources Division Department of Environmental Services 6 Hazen Drive Concord, NH 03301-2033 603-271-1379 603-271-1381 (F) 800-837-0656 (state) r_cartier@des.state, nh. us NEW JERSEY (M) Chuck McCarty NJ Commerce and Economic Growth Commission 20 West State Street P. 0. Box 820 Trenton, NJ 08625-0820 609-984-6922 609-777-4097 (F) 800-643-6090 (national) Chuck McCartv(®commerce state ni us Ky Asral NJ DEP P.O. Box 423 Trenton, NJ 08625-0423 609-292-3600 609-777-1330 (F) kasral@dep.state.nj.us Jeanne Mroczko Pollution Prevention Permit Coordinator SBAP NJ DEP P.O. Box 423 Trenton, NJ 08625-0423 609-292-3600 609-777-1330 (F) jmroczko@dep. state, nj. us NEW MEXICO (A) Sandra Ely NMED AQB 2048 Galisteo Street P.O. Box 26110 Santa Fe, NM 87505 505-955-8091 505-827-1523 (F) 800-810-7227 (national sandra elv(®nmenv.state.nm.us Steve Dubyk NM ED/AQB Harold Runnels Building P.O. Box 26110 Santa Fe, NM 87502 505-827-2859 505-827-0045 (F) 800-810-7227 (national) steve dubvk(®nmenv.state.nm.us D-1-8 ------- STATE OMBUDSMAN SBAP OTHER SBAP NEW YORK (A) Keith Lashway, SBEO Director Environmental Ombudsman Unit 30 S. Pearl Street Albany, NY 12245 518-292-5348 518-292-5889 (F) 800-782-8369 (national) klashway@empire.state.ny.us Marian Mudar, Ph.D. Environmental Program Manager Small Business Assistance Program NYS Environmental Facilities Corporation 50 Wolf Road Albany, NY 12205 518-457-9135 518-457-8681 (F) 800-780-7227 (state only) mudar@nvsefc.ora Patrick Lentile Bureau of Technical Support NYS Dept. of Environmental Conservation Division of Air Resources 50 Wolf Road, Room 110 Albany, NY 12233 518-457-7450 518-457-0794 (F) pxlentli@gw. dec.state, ny. us NORTH CAROLINA (M) Edythe McKinney NC DENR Customer Service Center Small Business Assistance Program 1640 Mail Service Center Raleigh, NC 27699-1640 919-733-0823 919-715-6794 (F) 877-623-6748 (national) edvthe.ckinnev@ncmail.net Tony Pendola NC DENR Customer Service Center Small Business Assistance Program 1640 Mail Service Center Raleigh, NC 27699-1640 919-733-0824 919-715-7468 (F) 877-623-6748 (national) tonv.Dendola@ncmail.net Karen Davis NC DENR Customer Service Center Small Business Assistance Program 1640 Mail Service Center Raleigh, NC 27699-1640 919-733-0951 919-715-7468 (F) 877-623-6748 (national) karen.davis@Dncmail.net NORTH DAKOTA (M) Dana Mount ND Department of Health 1200 Missouri Avenue P.O. Box 5520 Bismark, ND 58506 701-328-5150 701-328-5200 (F) 800-755-1625 (state) dmount@state.nd.us Chuck McDonald ND Department of Health 1200 Missouri Avenue P.O. Box 5520 Bismark, ND 58506 701-328-5188 701-328-5200 (F) 800-755-1625 (state) cmcdonald@state.nd.us Jeff Burgess ND Department of Health 1200 Missouri Avenue P.O. Box 5520 Bismark, ND 58506 701-328-5188 701-328-5200 (F) 800-755-1625 (state) iburaess@state.nd.us OHIO (A) Mark Shanahan Clean Air Resource Center 50 West Broad Street, Room 1901 Columbus, OH 43215-5985 614-728-3540 614-752-9188 (F) 800-225-5051 (state) mark.shanahan@aqda.state.oh.us Rick Carleski Ohio EPA/DAPC Lazarus Government Center P.O. Box 1049 Columbus, OH 43216 614-728-1742 614-644-3681 (F) 614-644-4830 (state) rick. carleski@eDa.state, oh. us Bob Hodanbosi OEPA/DAPC Lazarus Government Center P.O. Box 1049 Columbus, OH 43216 614-644-2270 614-644-3681 (F) D-1-9 ------- STATE OMBUDSMAN SBAP OTHER SBAP OKLAHOMA (M) Steve Thompson Deputy Executive Director Department of Environmental Quality 1000 NE 10th Street P.O. Box 1677 Oklahoma City, OK 73101-1677 405-702-7100 405-702-7181 (F) steve. thompson@deqmail.state, ok. us Alwin Ning Customer Services Division OK Department of Environmental Quality 1000 NE 10th Street PO Box 1677 Oklahoma City, OK 73101-1677 405-702-6100 405-702-1317 (F) 800-869-1400 (national) alwin. nina@deamail. state, ok. us Kyle Arthur Customer Services Division Department of Environmental Quality 1000 NE 10th Street P.O. 1677 Oklahoma City, OK 73101-1677 405-702-6100 405-702-1317 (F) 800-869-1400 (national) kvle.arthur@deamail.state.ok.us OREGON (A) Paul Burnet OR DEQ 811 SW 6th Avenue Portland, OR 97204-1390 503-229-5776 503-229-6945 (F) 800-452-4011 (state) burnet.paul@deq.state.or.us Jill Inahara OR DEQ Air Quality Division 811 SW 6th Avenue Portland, OR 97204 503-229-6147 503-229-5675 (F) 800-452-4011 (state) inahara.iill@dea.state.or.us PENNSYLVANIA (M) Bruce Z. McLanahan Office of P2 & Compliance Assistance PA DEP RCSOB P.O. Box 8772 Harrisburg, PA 17105-8772 717-772-5942 717-783-2703 (F) bmclanahan@state.Da.us Gerald (Ted) Laubach PA DEP, Bureau of Air Quality RCSOB P.O. Box 8468 Harrisburg, PA 17105-8468 717-787-1663 717-772-2303 (F) glaubach@state.pa.us Cecily Beall Tetra Tech EM, Inc 1800 JFK Boulevard, 6th Floor Philadelphia, PA 19103 215-656-8709 215-972-0484 (F) 800-722-4743 (national) beallc@ttemi.com PUERTO RICO (A) Luis Velez Administrator, Commercial Development Administration Office P.O. Box 4275 San Juan, PR 00902 787-384-8614 787-294-0148 (F) Maria Rivera PREQB-SBAP HC 91, Box 9197 Vega Alta, PR 00692 787-294-0101, 0132, 0127x324 787-772-9497 (F) Dr sbaD@hotmail.com RHODE ISLAND (M) Joe Antonio Rl Department of Environmental Management Technical/Customer Assistance 235 Promenade Street Providence, Rl 02908 401-222-6822, x4410 401-277-3810 (F) 800-253-2674 (state) D-1-10 ------- STATE OMBUDSMAN SBAP OTHER SBAP SOUTH CAROLINA (M) Phyllis T. Copeland, SBO Small Business Ombudsman SC Dept of Health & Environmental Ctrl 2600 Bull Street Columbia, SC 29201 803-898-3997 803-898-3939 (F) 800-819-9001 (national) coDelaDti® col umb30. dhec state sc us James Robinson SC Dept. of Health & Environmental Ctrl. 2600 Bull Street Columbia, SC 29201 803-898-3981 803-898-3939 (F) 800-819-9001 (national) robinsjc@columb30. dhec.state, sc. us Willie Morgan, Permitting Liaison SC Dept. of Health & Environ. Ctrl. 2600 Bull Street Columbia, SC 29201 803-898-3957 803-898-3939 (F) 800-819-9001 (national) morganwj@columb30. dhec.state.sc. us SOUTH DAKOTA (M) Joe D. Nadenicek Small Business Ombudsman SD Department of Environment & Natural Resources Joe Foss Building 523 East Capitol Pierre, SD 57501 605-773-3836 605-773-6035 (F) 800-GET-DENR (7 state access in area) ioe nadenicek(®state sd us TENNESSEE (M) Ernest C. Blankenship TN Department of Environment & Conservation L&C Tower, 8th Floor 401 Church Street Nashville, TN 37243-1551 615-741-6262 615-532-8007 (F) (800) 734-3619 (National) eblankenshiD(®mail state tn us Linda Sadler Small Business Assistance Program L&C Annex, 8th Floor 401 Church Street Nashville, TN 37243-1551 615-532-8012 615-532-8007 (F) 800-734-3619 (national) lsadler@mail.state, tn. us TEXAS (M) Israel Anderson Small Business Ombudsman TNRCC (Mail Code 112) P.O. Box 13087 Austin, TX 78711-3087 512-239-5319 512-239-3165 (F) 800-447-2827 (national) ianderso@tnrcc.state.tx.us Tamra-Shae Oatman Small Business Asst. Prog. Mgr TNRCC (Mail Code 106) P.O. Box 13087 Austin, TX 78711-3087 512-239-1066 512-239-1065 (F) 800-447-2827 (national) toatman(®tnrcc. state, tx. us D-1-11 ------- STATE OMBUDSMAN SBAP OTHER SBAP UTAH (M) Renette Anderson UT Department of Environmental Quality Office of the Small Business Ombudsman 168 North 1950 West Salt Lake City, UT 84114-4810 801-536-4478 801-536-0061 (F) 800-458-0145 (national) randerso@deq state ut us Ron Reece, Environmental Engineer UT Department of Environmental Quality Division of Air Quality 150 North 1950 West P.O. Box 144820 Salt Lake City, UT 84114-4820 801-536-4091 801-536-4099 (F) (800) 270-4440 (national) rreece@dea.state. ut. us VERMONT (M) Judy Mirro VT Environmental Assistance Division Laundry Building 103 South Main Street Waterbury, VT 05671 802-241-3745 802-241-3273 (F) 800-974-9559 (state) iudvm@dec.anr.state.vt.us Kevin Bracey VT APCD/ANR Building 3 South 103 South Main Street Waterbury, VT 05671 802-241-3841 802-241-2590 (F) kevinb@dec. anr.state, vt. us VIRGINIA (M) John Daniel, Air Division Director VA Department of Environmental Quality 629 E. Main Street P.O. Box 10009 Richmond, VA 23240 804-698-4311 804-698-4510 (F) 800-592-5482 (state) jmdaniel@deq.state, va. us Richard Rasmussen Manager, Small Business Assistance Prog. VA Department of Environmental Quality 629 E. Main Street P.O. Box 10009 Richmond, VA 23240 804-698-4394 804-698-4510 (F) 800-592-5482 (state) rarasmusse@dea.state.va.us VIRGIN ISLANDS (A) Marylyn A. Stapleton VI Department of Planning & Natural Resources Environmental Protection Division Small Business Assistance Program Terminal Building, 2nd Floor Cyril E. King Airport St. Thomas, VI 00802 340-774-3320x5167 or 5119 340-714-9528 (F) 340-714-9529 (state) envDroti@viaccess.net Marylyn A. Stapleton Dual Role as Ombudsman and SBAP Principal Jasmine A. Blyden VI Department of Planning & Natural Resources Environmental Protection Division Small Business Assistance Program Terminal Building, 2nd Floor Cyril E. King Airport St. Thomas, VI 00802 340-774-3320x5167 or 5119 340-714-9528 (F) 340-714-9529 (state) D-1-12 ------- STATE OMBUDSMAN SBAP OTHER SBAP WASHINGTON (A) Bernard Brady WA Department of Ecology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 360-407-6803 360-407-6802 (F) bbra461 ©ecv.wa.aov WEST VIRGINIA (A) Dave Bassage Small Business Ombudsman WV Division of Environmental Protection 1356 Hansford Street Charleston, WV 25301 304-558-5929 x203 304-558-3998 fax dbassage@mail.dep state wv us Fred Durham WV DEP, Office of Air Quality Small Business Assistance Program 7012 MacCorkle Ave., SE Charleston, WV 25304 304-926-3647 304-926-3637 (F) 800-982-2474 (state) fdurham@mail.deD.state.wv. us Gene M. Coccari Technical Specialist WV Office of Air Quality 7012 MacCorkle Avenue Charleston, WV 25304 304-926-3731 304-926-3637 fax gcoccari@mail.dep.state.wv.us WISCONSIN (A) Pam Christenson Wl Small Business Clean Air Asst. Program 201 West Washington Avenue, 6th Floor P.O. Box 7970 Madison, W 53703-7970 608-267-9384 608-267-0436 (F) 800-435-7287 (national) Dchristenson@commerce.state.wi.us Renee Lesjak Bashel Wl Department of Commerce 201 West Washington Avenue P.O. Box 7970 Madison, W 53703-7970 608-264-6153 608-267-0436 (F) 800-435-7287 (national) rlesiakbasheli® commerce, state, wi. us Tom Coogan Wl Small Business Clean Air Asst. Program 201 West Washington Avenue, 6th Floor P.O. Box 7970 Madison, W 53703-7970 608-267-9214 608-267-0436 (F) 800-435-7287 (national) tcooaani® commerce, state, wi. us WYOMING (M) Dan Clark, Small Business Ombudsman WY Department of Environmental Quality Herschler Bldg. 4-W 122 W. 25th Street Cheyenne, WY 82002 307-777-7388 307-777-3773 (F) dclark@missc.state, wy. us Charles Raffelson, Tech. Asst. Prog. Coord. WY Department of Environmental Quality Herschler Bldg. 4-W 122 W. 25th Street Cheyenne, WY 82002 307-777-7347 307-777-5616 (F) craffe@missc.state, wy. us Tina Jenkins, Env. Program Principal WY Department of Environmental Quality Rule Making & Air Toxics Sheridan Field Office 1043 Coffeen Ave, Suite D Sheridan, WY 82801 307-672-6457 307-674-6050 (F) cjenki@missc.state, wy. us D-1-13 ------- TABLE D-2 DATES OF ESTABLISHMENT AND COMMENCEMENT OF SBTCP OPERATIONS STATE OR TERRITORY MONTH & YEAR OF ESTABLISHMENT MONTH & YEAR OPERATIONS BEGAN SBO SBAP CAP SBO SBAP CAP Alabama 5/93 7/94 7/97 5/93 7/94 N/R Alaska 6/95 6/95 6/95 6/95 6/95 6/95 Arizona 1/93 1/93 1/93 1/93 3/94 N/O Arkansas 11/93 11/93 6/95 11/93 11/93 6/95 California 10/92 before 1990 N/E 4/95 before 1990 N/O South Coast* 6/89 6/89 2/98 6/89 6/89 2/98 Colorado 12/97 7/92 7/92 12/97 9/92 4/94 Connecticut 4/93 4/93 12/94 4/93 4/93 12/94 Delaware 12/95 12/95 4/98 12/95 12/95 4/98 District of Columbia 12/94 12/93 2/96 9/95 1/94 2/98 Florida 11/92 11/92 1/93 11/92 11/92 1/93 Georaia 2/92 11/92 5/93 7/92 7/93 11/94 Hawaii 7/98 7/98 N/E 7/98 7/98 N/O Idaho 10/93 4/94 5/94 10/93 4/94 5/94 Illinois 5/92 9/92 9/98 5/92 11/94 9/98 Indiana 3/93 1/95 7/95 3/93 3/94 7/95 Iowa 10/95 N/R N/E 10/95 10/92 N/O Kansas 7/93 7/93 7/93 11/93 3/94 12/93 Kentucky 6/92 (part time) 2/95 (full time) 7/94 10/94 6/92 (part time) 2/95 (full time) 10/94 3/95 Jefferson Ctv 8/95 11/95 See state resD. 8/95 11/95 See state resD. D-2-1 ------- STATE OR TERRITORY MONTH & YEAR OF ESTABLISHMENT MONTH & YEAR OPERATIONS BEGAN SBO SBAP CAP SBO SBAP CAP Louisiana 11/92 11/92 10/93 11/92 11/92 10/93 Maine 10/93 10/93 10/93 11/93 4/94 4/94 Marvland 4/94 4/94 N/E 4/94 4/94 N/O Massachusetts N/R 11/92* N/R N/R 11/92* N/R Michiaan 10/95 9/94 9/94 10/95 9/94 9/94 Minnesota 4/92 4/92 4/92 6/93 8/93 9/93 Mississippi 7/93 7/93 7/93 7/93 7/93 7/93 Missouri 8/92 8/92 8/92 5/94 5/94 4/98 Montana 12/93 12/93 1/94 12/93 12/93 2/94 Nebraska 11/92 11/92 7/93 11/92 11/92 7/93 Nevada 1/95 1/95 12/95 3/95 1/95 1/95 New HamDshire 11/94 1/93 11/95 11/94 1/93 3/96 New Jersev 3/93 11/92 12/95 3/93 11/92 1/97 New Mexico 10/92 10/92 10/94 9/94 1/93 11/95 New York 4/92 4/92 7/94 1/93 4/92 8/97 North Carolina 1/93 8/93 11/94 1/93 8/93 11/94 North Dakota 4/92 4/92 5/92 4/92 4/92 6/93 Ohio 10/94 10/94 10/94 12/94 4/95 1/96 Oklahoma 6/94 6/94 6/96 10/94 10/94 6/96 Oreaon 8/91 8/91 1/94 1/92 11/91 11/94 Pennsylvania 11/92 11/92 11/92 5/93 1/94 4/93 Puerto Rico 10/97 11/94 1/96 10/97 11/94 3/96 D-2-2 ------- STATE OR TERRITORY MONTH & YEAR OF ESTABLISHMENT MONTH & YEAR OPERATIONS BEGAN SBO SBAP CAP SBO SBAP CAP Rhode Island 5/95* 11/96* N/E 5/95* 11/95 N/O South Carolina 8/93 8/93 8/94 8/93 8/93 8/94 South Dakota 11/93 11/92 4/94 11/93 11/92 4/94 Tennessee 1/93 1/93 N/E 3/93 11/93 N/O Texas 2/92 1/92 11/92 2/92 1/92 11/92 Utah 1/94 1/94 1/94 5/94 1/93 6/95 Vermont N/E 12/96 4/96 N/O 12/96 10/97 Virainia 8/92 3/93 11/95 4/93 7/93 11/95 Virain Islands 1/93 1/93 N/E 1/93 1/93 N/O Washinaton Fall 92 Summer 93 Summer 93 Fall 92 Summer 93 Summer 93 West Virainia 4/94 11/93 1/95 12/94 5/94 3/95 Wisconsin 4/92 4/92 4/92 11/92 12/92 8/94 Wyoming 3/92 3/92 3/92 5/94 11/93 5/95 *Notes South Coast, CA In this agency, the SBO and SBAP functions are combined. The Governing Board's Local Government & Small Business Assistance Advisory Group serves as the CAP function. MA OTA established SBAP 1/90. MA SIP designated OTA as SBAP lead 11/92. Rl SBO position vacant as of 6/99. SBAP run by P2 group prior to 11/96. D-2-3 ------- TABLE D-3 1999 SBTCP BUDGET INFORMATION AND FUNDING SOURCES STATE OR TERRITORY 1999 BUD( UJ rn H 0 SOURCE OF FUNDING SBO SBAP CAP TOTAL SBO SBAP CAP Alabama 180,000 181,500 N/R 361,500 Title V fees; air, water, RCRA arant funds Title V fees, air permit fees N/R Alaska 118,500 118,500 AK Clean Air Protection Fund established to fund Title V Droarams Arizona 185.000 185.000 Air aualitv permit fees Arkansas 64,000 179,500 2,625 246,125 State appropriation - permit fees State appropriation - permit fees State appropriation - permit fees California 200.000 340.000 N/A 540.000 State budaet act State budaet act N/A South Coast 114,500 820,500 15,600 950,600 Funding for all thre application fees, at 25% from annual o e programs: about 45% from permit >out 30% from emission fees, and about Deratina fees. Colorado 60,000 250,000 0 310,000 CDPHE general fund CDPHE Air Pollution Control Division, stationary sources - permitting & annual emission fees N/A Connecticut 325,000 N/R N/R 325,000 State fund that supports a number of programs for implementing the CAAin CT. Vehicle registration fees fund CT*s clean air program. Title V fees cover costs incurred from Title V permitting activities. N/R N/R N/A Not applicable N/R No response D-3-1 ------- 1999 BUD( UJ rn H 0 SOURCE OF FUNDING STATE OR TERRITORY SBO SBAP CAP TOTAL SBO SBAP CAP Delaware 80,000 Allocated from SBO as needed Allocated from SBO as needed 80,000 Title V funds N/R N/R District of Columbia 1,500 3,500 0 5,000 Air grant/Title V operating permit fees Air grant/Title V operating permit fees N/R Florida 45,500 143,900 Funded under SBAP 189,400 Title V fees Title V fees Title V fees Georaia 50.000 125.000 5.000 180.000 Title V fees Title V fees Title V fees Hawaii 100,000 85,000 N/A 185,000 Title V fees (special fund) Title V fees (special fund) N/A Idaho 50,164 (personnel) 900 (operations) 0 51,064* 70% from Title V fees, 30% from PPIS arant match (paid with Title V fees) N/R Illinois 70.000 348.000 2.000 420.000 Title V fees Title V fees Title V fees Indiana 150,000 700,000 3,000 833,000 Special fund, permit fees, aeneral revenues Special fund, permit fees, aeneral revenues Legislature Iowa* 80,851 361,000 0 441,851 100% Title V fees. IA DNR 100% Title V fees, IA DNR N/A Kansas 100,000 400,000 No budget - only travel allowance 500,000 Fee funds primarily from air Fee funds from media programs (air, water, waste, remediation) Air fee funds Kentucky 129,400 278,501 Included in SBO budaet 407,901 Title V fees Title V fees Title V fees Jefferson County 40,000 85,000 See state response 125,000 EPA 105 grant, county general funds EPA 105 grant, county general funds N/R Louisiana 0 400,000 0 400,000 Funded by other Droarams No change N/A Maine 75,000 95,000 As needed (nealiaible) 170,000 General fund Title V fees Title V fees N/A Not applicable N/R No response D-3-2 ------- STATE OR TERRITORY 1999 BUD( UJ rn H 0 SOURCE OF FUNDING SBO SBAP CAP TOTAL SBO SBAP CAP Maryland 3,500 61,000 N/A 64,500 MDE indirect funds MDE indirect funds N/A Massachusetts N/R -360,000 N/R -360,000 N/R Large quantity toxic users N/R Michigan* 90,300 537,000 0 627,300 State & county fees, restricted funds State & county fees, restricted funds Unfunded Minnesota 77,500 259,400 1,000 337,900 Air fees, 105 grant AQ/HW/WQ fees, 105 grant, WQ & SBREFA grant, AQ env. enf. Air fees, 105 grant Mississippi 150.000 150.000 5.000 305.000 Title V fees Title V fees Title V fees Missouri 54,600 462,000 10,500 527,100 Title V & other fees Title V fees, general revenue, federal grant Title V & other fees, general revenue, federal arant Montana 82,000 3,000 2,000 87,000 Air quality permit fees Air quality permit fees Air quality permit fees Nebraska 105.000 N/A 105.000 Title V fees Title V fees N/A Nevada 79,900 90,500 54,200* 350,000* 2,600 522,800* NDEP indirect cost pool NDEP indirect cost pool, NDEP air quality management fund (permit fees), various state & federal grants, permit fees NDEP air quality management fund (permit fees) New Hampshire 25,000 75,000 Included in SBAP 100,000 Emission fees Emission fees N/A New Jersey 80,000 85,000 1,500 166,500 Operating permit fees Operating permit fees Operating permit fees New Mexico 10,000 205,000 <1,000 216,000 Title V fees, other state funds Title V fees, grants, other state funds Title V fees, other state funds N/A Not applicable N/R No response D-3-3 ------- STATE OR TERRITORY 1999 BUD( UJ rn H 0 SOURCE OF FUNDING SBO SBAP CAP TOTAL SBO SBAP CAP New York 500,000 890,000 1,800 1,391,800 NY state clean air fund supported by Title V fees NY state clean air fund supported by Title V fees NY state clean air fund supported by Title V fees North Carolina 350.300* 350.300 Title V fees North Dakota 30.000 30.000 1.000 61.000 Title V fees Title V fees Title V fees Ohio 226,000 257,400 Included in SBAP budget 483,400 Title V fees, parent agency subsidy Title V fees Title V fees Oklahoma 14,420 152,431 Included in SBAP budaet 166,851 Agency indirect costs Title V fees N/A Oreaon 36.800 102.600 2.500 141.900 Title V fees Title V fees Title V fees Pennsylvania 110.000 571.000 5.000 686.000 Title V fees Title V fees Title V fees Puerto Rico N/A 249.095 N/A 249.095 N/A Special fund N/A Rhode Island 50,700 119,000 0 169,000 State general fund Title V fees N/A South Carolina 36.500 84.000 1.500 122.000 Title V fees Title V fees Title V fees South Dakota 25.000 10.000 5.000 40.000 Title V fees Title V fees Title V fees Tennessee 201.900 N/A 201.900 Title V fees N/A Texas 1.116.000* 1.116.000 151 arant funds Utah 53,000 79,000 2,000 134,000 Title V fees, state funds, EPA •Partnership for Compliance* arant Title V fees Title V fees Vermont 0 41.500 0 41.500 N/A State aeneral fund N/A Virginia 10,500 246,100 600 257,200 General funds Permit fees, federal trust, EPA leadership arant Permit fees N/A Not applicable N/R No response D-3-4 ------- STATE OR TERRITORY 1999 BUD( UJ rn H 0 SOURCE OF FUNDING SBO SBAP CAP TOTAL SBO SBAP CAP Virain Islands 150.000 150.000 N/A 300.000 Title V fees Title V fees N/A Washinaton 40.000 200.000 5.000 245.000 Title V fees Title V fees Title V fees West Virginia 30,000 140,000 5,000* 195,000 Title V fees, aaencv penalties Title V fees, agency penalties Agency penalties Wisconsin 163.950 163.950 Title V fees, emission inventory fees Wyoming 25,000 75,000 10,000 110,000 Title V fees Title V fees Title V fees "Notes: ID Budget is for the state fiscal year from July 1, 1998 through June 30, 1999. IA Budget is for the 1999-2000 fiscal year from July 1999 through June 2000. Ml Funding is for the state*s fiscal year of October 1, 1998 through September 30, 1999. NV The $350,000 is for SBDC-BEP and includes state and county contracts for a combined total. The NDEP contract amount of $54,200 for an SBDC-BEP contract was only added once for the 1999 budget total. NC Budget for 1999-2000 fiscal year. TX Budget for FY 1999. WV CAP expense reimbursement only. Actual yearly expenses are <$1,000. N/A Not applicable N/R No response D-3-5 ------- TABLE D-4 COMPARISON OF 1998, 1999, AND 2000 BUDGETS and DESCRIPTIONS OF SIGNIFICANT FUNDING CHANGES STATE OR TERRITORY BUD 3ET FOR 1998 REPORTING PER OD (S) BUC GET FOR 1999 REPORTING PERIC 3D(S) BUDGET FOR 2000 RER DRTING PERIO D(S) SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL Alabama 175 000 165 000 N/R 340 000 180 000 181 500 N/R 361 500 180 000 181 500 N/R 361 500 112 700 112 700 118 500 118 500 118 500 118 500 Arizona* 185 000 N/R 185 000 185 000 N/R 185 000 N/R Unknown Arkansas* 64 500 264 500 2 500 331 500 64 000 179 500 2 625 246 125 70 400 197 450 2 887 262 157 California 200 000 340 000 0 540 000 200 000 340 000 N/A 540 000 200 000 340 000 N/A 540 000 110 000 1 100 000 0 1 210 000 114 500 820 500 15 600 950 600 120 000 830 000 20 000 970 000 60 000 250 000 0 310 000 60 000 250 000 0 310 000 60 000 335 000 0 395 000 325 000 325 000 325 000 325 000 325 000 325 000 80 000 80 000 80 000 80 000 80 000 80 000 District of 5 000 8 000 3 000 16 000 1 500 3 500 0 5 000 24 000 17 000 5 000 46 000 Florida* 222 400 222 400 189 400 189 400 46 900 148 200 Funded under SBAP 195 100 50 000 125 000 5 000 180 000 50 000 125 000 5 000 180 000 50 000 150 000 5 000 215 000 100 000 60 000 N/A 160 000 100 000 85 000 N/A 185 000 100 000 65 000 N/A 165 000 66 950 30 900 0 97 850 50 164 900 0 51 064 52 317 8 000 N/R 60 317 Illinois* 75 000 349 500 500 425 000 75 000 348 000 2 000 420 000 70 000 357 000 3 000 430 000 Indiana 150 000 700 000 3 000 853 000 150 000 700 000 3 000 853 000 150 000 700 000 3 000 853 000 81 226 347 000 0 428 226 80 851 361 000 0 441 851 100 373 361 000 0 451 373 125 000 429 443 0 554 443 100 000 400 000 0 500 000 100 000 400 000 N/R 500 000 Kentucky 123 200 270 375 Inc w/SBO 393 575 129 400 278 501 Inc w/SBO 407 901 133 282 286 856 Inc 420 138 40 000 85 000 See KY 125 000 40 000 85 000 See KY 125 000 40 000 85 000 See KY 125 000 I ouisiana 0 400 000 0 400 000 0 400 000 0 400 000 0 400 000 0 400 000 40 000 114 000 154 000 75 000 95 000 170 000 75 000 95 000 170 000 Maryland 3.500 61.000 0 64.500 3.500 61.000 N/A 64.500 3.500 61.000 0 64.500 N/A Not applicable N/R No response D-4-1 ------- STATE OR TERRITORY BUD 3ET FOR 1998 R EPORTING PER OD ($) BUC GET FOR 1999 REPORTING PERIC 3D(S) BUDGE FOR 2000 RER DRTING PERIO D(S) SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL N/R 360 000 N/R 360 000 N/R 360 000 N/R 360 000 N/R 360 000 N/R 360 000 71 300 416 400 0 487 700 90 300 537 000 0 627 300 83 500 513 200 0 596 700 75 000 225 000 1 000 300 000 77 500 259 400 1 000 337 900 81 700 280 000 1 000 362 700 150 000 150 000 5 000 305 000 150 000 150 000 5 000 305 000 160 100 160 100 5 000 325 200 52 000 440 000 10 000 502 000 54 600 462 000 10 500 527 100 N/R N/R N/R N/R 84 000 4 000 2 000 90 000 82 000 3 000 2 000 87 000 86 000 5 000 2 000 93 000 Nebraska 105 000 N/A N/A 105 000 105 000 Same as SBO N/A 105 000 105 000 N/A N/A 105 000 Nevada* 92 300 168 800 2 600 263 700 79 700 494 700 2 600 577 000 101 000 148 100* 34.000* 100 000* 350 000* 2 600 546 700 25 000 75 000 100 000 25 000 75 000 100 000 25 000 150 00 175 000 80 000 70 000 1 500 151 500 80 000 85 000 1 500 166 500 80 000 85 000 1 500 166 500 10 000 205 000 <1 000 216 000 10 000 205 000 <1 000 216 000 10 000 215 000 1 500 226 500 1 170 000 1 000 000 3 000 2 173 000 500 000 890 000 1 800 1 391 800 500 000 890 000 1 800 1 391 000 North Carolina* 333 400 N/A 333 400 350 300 350 300 366 0 0 N/A 366 090 30 000 30 000 1 000 61 000 30 000 30 000 1 000 61 000 30 000 30 000 1 000 61 000 Ohio* 208 000 229 000 No sep 437 000 226 000 257 400 No sep 483 400 210 000 335 000 No sep 545 000 Oklahoma 14 000 147 992 162 000 14 420 152 431 166 851 14 853 152 32 167 285 35 000 97 800 2 300 135 100 36 800 102 600 2 500 141 900 38 400 108 000 2 600 149 000 Pennsylvania 90 000 560 000 5 000 655 000 110 000 571 000 5 000 686 000 116 000 531 000 5 000 652 000 15 000 75 000 10 000 100 000 N/A 249 095 N/A 249 095 N/A 200 000 N/A 200 000 49 000 115 000 0 164 000 50 700 119 000 0 169 000 0 122 600 0 122 600 South Carolina 40 000 78 000 1 500 119 500 36 500 84 000 1 500 122 000 38 000 86 500 1 500 126 000 25 000 10 000 5 000 40 000 25 000 10 000 5 000 40 000 25 000 10 000 5 000 40 000 900 000 900 000 201 900 201 900 201 900 201 900 987 140 987 140 1 116 000 1 116 000 1 926 300 1 926 300 Utah- 54 000 148 000 2 000 204 000 53 000 79 000 2 000 134 000 156 000 98 000 2 000 256 000 Vermont 0 38 000 0 38 000 0 41 500 0 41 500 0 42 750 0 42 750 Viraima* 10.000 285.000 5.000 300.000 10.000 246.100 O o CD 257.200 11.300 290.200 5.300 306.800 N/A Not applicable N/R No response D-4-2 ------- STATE OR TERRITORY BUD 3ET FOR 1998 R EPORTING PER OD ($) BUC GET FOR 1999 REPORTING PERIC 3D(S) BUDGE FOR 2000 RER DRTING PERIO D(S) SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL SBO SBAP CAP TOTAL 55 000 55 000 0 110 000 150 000 150 000 N/A 300 000 150 000 150 000 5 000 305 000 40 000 200 000 5 000 245 000 40 000 200 000 5 000 245 000 40 000 200 000 5 000 245 000 50 000 140 000 5 000 195 000 30 000 140 000 5 000 195 000 45 000 140 000 5 000 195 000 158 359 158 350 163 950 163 950 169 400 169 400 Wyoming* 25 000 75 000 10 000 110 000 25 000 75 000 10 000 110 000 25 000 75 000 10 000 110 00 *Notes, including explanations of significant changes (more than 10%) in funding levels among the 1998, 1999, and 2000 budget periods: AZ A reorganization of ADEQ«s Compliance Assistance resources currently is underway. The reorganization is moving assistance resources to the regional offices to make their services more readily available in rural communities where assistance is often needed, but lacking. 2000 funding levels are not yet in place for the function. AR Consolidation with Customer Service has provided more personnel and expertise. Business Assistance program went from 2 to 3.5 FTEs. SBAP funding in 1998 included a $100,000 appropriation from a federal grant that has since expired. The 1999 budget reflects state funds dedicated to SBAP. South Coast The 1999 budget was lower than in 1998 primarily because of a reorganization that reduced the number of staff assigned to the SBO and SBAP. SBAP was awarded EPA grants in FY2000. Program funding has remained constant at $325,000. Resources have been reallocated to provide program support and expansion on specific program initiatives such as the development of a CD-rom. Existing resources have been shifted within the Department to provide additional program support as necessary. The ombudsman position was filled September 1999. Had 2 EPA grants FY99 (7/98-6/99). 1999 funding reductions due to replacement of more senior staff with lower classifications. Goal to add an additional position in FY2000. SBAP - difference in amounts reflects the difference of approved budget and actual expenditures. SBO - additional needs assessments for small business compliance requirements and regulatory impact analyses are scheduled for development. SBAP - received an additional $50,000 in 1998 to conduct a series of hands-on workshops on developing risk management plans for 112r-affected sources in Iowa. Received an additional $30,000 in 1999 to develop a system to assist businesses in Scott County with emission inventory development. FY2000 projected budget reflects only the core program funding (same as 1999); additional funding may be added later. N/A Not applicable N/R No response CO CT DC FL GA IL IA ------- KS Although it appears that funding was reduced, additional duties were assigned and paid from different funding sources. Ml SBTCP funding is based on collected air permitting fees for the state's Title V program. In 1998, the fee structure was increased to support the SBTCP for FY98-99. Both the SBO and SBAP experienced funding increases with changes of 26.7% and 29%, respectively, between FY97-98 and FY 98-99. Funding for the overall SBTCP grew by 28.6% during this time. Funding realized in FY98-99 turned out to be less than originally appropriated, so projections were made for reduced appropriations in FY99-00 that would result in a budget decrease for the SBO and SBAP of 7.5% and 4.4%, respectively. Overall, the SBTCP will see decreased funding from FY98-99 to FY99-00 of 4.9%. MN 24% increase in the SBAP budget between 1998 and 2000 is a result of hiring an additional staff person. NV SBAP amounts are for NDEP, Washoe County, Clark County, and SBDC-BEP, respectively. SBDC-BEP budget includes state and county contracts for a combined total. The total budget figures do not reflect combined budgets. Clark County Air Program contracted with the SBDC-BEP for technical assistance services in FY2000. Funding for the NDEP SBAP was reduced due to expiration of federal SBAP Leadership Grant. FY2000 shows an increase due to inclusion of the SBDC-BEP budget in its entirety; only the contract amount with the NDEP for air quality assistance had been included in previous reports. NH Received a two year $150,000 grant to implement the PrintSTEP pilot program in the state. NJ In FY2000, the SBAP received an EPA grant for $84,000. This award funds the production of collateral materials and outreach efforts for the state's technical assistance program. NY Budgets are for fiscal year. Due to changes in the FY99-00 New York State budget, appropriations to the SBEO were reduced from $1,170,000 to $500,000 per year to accurately reflect past activities and staffing levels. Due to lengthy contract negotiations with DEC, the SBAP has never been able to fully expend its budgeted contract funds. EFC is unable to take proactive steps to spend down its contract without a fully executed contract in place. For that reason, for FY99-00, DEC cut the funding to SBAP from $1 million to $890,000, a figure close to the SBAP«s billing to DEC for FY98-99. NC The year 2000 brings further integration of the Customer Service Center (CSC) and the small business programs. For the purpose of this report, the CSC budget was not included. FTEs show actual time spent directly on small business activities. OH SBAP - In 1998, a significant portion of the supervisor's salary was charged to another program due to temporary job assignment, causing the budget to be low. The 2000 budget reflects an allowance for one additional staff member, but hiring has not been approved. Rl SBO left for another position in June 1999. No current plans to refill this position. TN Multimedia organizational opportunities and structural realignment resulted in Title V fee funding program support changes. TX The increase from 1999 to 2000 was due to a division reorganization (merging of Small Business and Local Government Assistance sections with Pollution Prevention and Industry Assistance) plus addition of 20 field positions in FY2000. N/A Not applicable N/R No response D-4-4 ------- UT SBO - The 2000 budget includes the remainder of the Partnership for Compliance grant funds ($102,000), which are obligated and will be spent by October 1, 2000. SBAP - This program had an unfilled position for the last half of 1998 and all of 1999. VA Funding for 1999 represents actual expenditures. The 1999 actual of $257,200 in relation to the 1999 projected budget of $265,000 reflects the loss of the Internet person in September 1999. The reduction from the 1998 (FY99) projected budget to the actual 1999 expenditures represents an adjustment resulting in a realistic tightening of actual expenditures to projected amounts. The increase in the 2000 projected budget of $306,800 over the 1999 projected budget of $265,000 is from a $24,100 increase in salary and fringe, extra funds projected for the CAP training at the SBO/SBAP National Conference, and an increase of approximately $10,000 in programmatic money. Note the proposed 2000 budget represents a shift from utilization of a FY2001 basis to a calendar year basis for the year 2000. WV SBO budget has decreased because the Ombudsman was semi-retired and worked approximately 20 hours per week until November. He subsequently fully retired and we hope to find a full time replacement this year. WY No significant change in anticipated direct funding for program. However, the office has received a Compliance Assistance Grant from EPA for approximately $68,000 to be spent over a two year period; this grant will be managed by the SBO. N/A Not applicable N/R No response D-4-5 ------- TABLE D-5 STAFFING INFORMATION A summary of the number of full time equivalents (FTEs) that support the SBO function and SBAP function is shown in Table D-5. With respect to the SBAP, the number of paid and unpaid staff is shown separately. The utilization of retired engineers to serve the SBAP also is indicated. STATE OR TERRITORY SBO FUNCTION (# FTEs) SBAP FUNCTION (# FTEs) SBO OTHER STAFF TOTAL SBO STAFF PAID UNPAID "retired ENGINEERS TOTAL SBAP STAFF Alabama 3.00 0 3.00 2.00* 0 0 2.00 Alaska 1.00 0 1.00 1.00 6.00 0 7.00 Arizona 0.25 0.25 1.25 0 1.25 Arkansas 0 0 0 3.50 0 0 3.50 California 4.00 1.00 5.00 Unknown Unknown* South Coast 0.60 0.55 1.15 8.00* 0 0 8.00 Colorado 1.00 0 1.00 2.00 0 0 2.00 Connecticut 1.00 0 1.00 1.00 0 0 1.00 Delaware 1.00 0.30 1.30 District of Columbia 0.30 0.30 0.30 0 0 0.30 Florida 0.25 0.50 0.75 2.75 0 0 2.75 Georaia 0.50 0 0.50 2.00 0 0 2.00 Hawaii 1.00 1.00 2.00 1.75 0 0 1.75 Idaho 1.00 0 1.00 0* 0 0 0 Illinois 1.00 0 1.00 5.00 0 0 5.00 Indiana 2.00 0.25 2.25 12.00 0 0 12.00 Iowa 1.00 0 1.00 5.00 0 0 5.00 N/A Not applicable N/R No response D-5-1 ------- STATE OR TERRITORY SBO FUNCTION (# FTEsi SBAP FUNCTION (# FTEsi SBO OTHER STAFF TOTAL SBO STAFF PAID UNPAID "retired ENGINEERS TOTAL SBAP STAFF Kansas 1.00 0.50 1.50 5.50 0 0 5.50 Kentuckv 1.00 0.50 1.50 4.00 0 0 4.00 Jefferson Countv 1.00 0 1.00 2.00 0 0 2.00 Louisiana 0.25 0 0.25 12.00 0 0 12.00 Maine 1.00 0 1.00 2.00 0 0 2.00 Marvland 0.05 0 0.05 1.00 0 0 1.00 Massachusetts 8.00 8.00 Michiaan 0.50 0.50 1.00 8.00 0 0 8.00 Minnesota 1.00 0 1.00 4.00 0 0 4.00 Mississippi 2.00 2.00 5.50 5.50 Missouri 1.00 0 1.00 7.65 0 0 7.65 Montana 1.00 0.50 1.50 0.10 0 0 0.10 Nebraska 1.00 0 1.00 1.00 0 1.00 1.00 Nevada 1.00 0 1.00 6.00* 0 0 6.00 New HamDshire 0.25 0 0.25 3.25 0 0 3.25 New Jersev 1.00 0.50 1.50 1.00 0 1.00 New Mexico 3.00 0 0 3.00 New York 5.50 1.50 7.00 7.00 0 0 7.00 North Carolina 1.00 0.50 1.50 2.50 0 0 2.50* North Dakota 0.50 0 0.50 2.00* 0 0 2.00 Ohio 0.50 0.80 1.30 4.00 0 0 4.00 N/A Not applicable N/R No response D-5-2 ------- STATE OR TERRITORY SBO FUNCTION (# FTEsi SBAP FUNCTION (# FTEsi SBO OTHER STAFF TOTAL SBO STAFF PAID UNPAID "RETIRED ENGINEERS TOTAL SBAP STAFF Oklahoma 0.10 0 0.10 3.30 0 0 3.30 Oreaon 0.15 0.20 0.35 1.00 0 0 1.00 Pennsylvania 1.00 2.00 3.00 5.50 5.50 Puerto Rico 1.00 1.00 2.00 0 0 2.00 Rhode Island 1.00 0 1.00 2.50 0 0 2.50 South Carolina 1.00 0 1.00 2.50 0 0 2.50 South Dakota 0.50 0 0.50 0.14 0 0 0.14 Tennessee 2.00 0* 2.00 2.00 0* 0 2.00 Texas 36.00 0 36.00 36.00 70.00* 0 106.00 Utah 0.50 0.50 3.00 3.00 Vermont 0 0 0 1.20 0 0 1.20 Virainia 0.10 0.90 1.00 4.20 0.30 0 4.50 Virain Islands 1.00 0 1.00 3.00 0 0 3.00 Washinaton 0.50 0 0.50 2.50 0 2.50 West Virainia 0.50 0.10 0.60 1.20 0 0 1.20 Wisconsin 0.50 1.50 2.00 1.25 0 0 1.25 Wyoming 0.50 0 0.50 1.00 0 0 1.00 N/A Not applicable N/R No response D-5-3 ------- *Notes: A The number of retired engineers serving as paid or unpaid SBAP FTEs is included in these specific columns. Use of retired engineers (paid or unpaid) is documented separately in the 'Retired Engineers* column. AL 10% of time of staff of 20. CA SBAP staffing unknown, as staffing varies per air district size and resources. South Coast 1 Community Relations Manager, 3 Engineers, 2 Inspectors, 0.5 Senior Public Information Specialist, 0.5 Public Information Specialist, and 1.0 Secretary. ID There are no dedicated FTEs to the SBAP. In early 1999, there were 10 FTEs assisting the SBO; however, since the reorganization of DEQ took place in mid-1999 and the loss of the SBO in May 1999, there has been no SBAP in place for most of 1999. The new SBO was hired in mid-December 1999. We currently are determining how the SBAP will receive technical assistance staff. For the immediate future, source-specific permitting inquiries will be routed to the respective regional office (six in ID) for processing. General technical questions will be handled by the SBO. NV 1.50 NDEP staff, 4.5 SBDC-BEP staff. NC An additional 1.00 FTE worked for the customer service center. ND 0.50 air, 1.50 other media. TN Services provided by division staff as needed. TX 70.00 EnviroMentors. N/A Not applicable N/R No response D-5-4 ------- TABLE D-6 CAP COMPOSITION STATE OR TERRITORY NUMBER OF PEOPLE ON CAP SMALL BUSINESS OWNER STATE REGULATORY EMPLOYEE GENERAL PUBLIC NOT YET APPOINTED OTHER Alabama 4 1 2 Alaska 4 2 2 Arizona 4 1 2 Arkansas 7 1 California N/A N/A N/A N/A South Coast* 4 2 7 Colorado 3 0 2 1 1 Connecticut 3 2 4 0 1* Delaware 5 1 1 District of Columbia 3 1 2 Florida 4 1 2 Georaia 4 1 2 Hawaii 7 Idaho 7* Illinois 2 1 3 1 Indiana 4 1 0 2 0 Iowa 7 Kansas 3 4* N/A Not applicable N/E Not established N/R No response D-6-1 ------- STATE OR TERRITORY NUMBER OF PEOPLE ON CAP SMALL BUSINESS OWNER STATE REGULATORY EMPLOYEE GENERAL PUBLIC NOT YET APPOINTED OTHER Kentucky 5 1 2 1 2 Jefferson Countv See KY Louisiana 4 2 2 0 2 Maine 4* 2 2 0 8 Maryland 7 Massachusetts N/R Michiaan 4 1 2 Minnesota 7* Mississippi 3 1 2 1 Missouri 2 1 2 2 Montana 4 1 1 1 Nebraska 4 1 2 0 1 Nevada 3 1 2 1* New Hampshire 4 1 2 New Jersev 4 1 2 New Mexico 1 1 5* New York 1 8* North Carolina N/A* North Dakota 4 1 2 Ohio 3 1 3* N/A Not applicable N/E Not established N/R No response D-6-2 ------- STATE OR TERRITORY NUMBER OF PEOPLE ON CAP SMALL BUSINESS OWNER STATE REGULATORY EMPLOYEE GENERAL PUBLIC NOT YET APPOINTED OTHER Oklahoma 4 2 1 Oreaon 3 2 3 Pennsylvania 6 2 1 2 Puerto Rico 2 1 3 1 Rhode Island N/R South Carolina 4 1 1 South Dakota 4 1 2 Tennessee 7 Texas 4 1 2 Utah 4 1 2 Vermont 5 2 Virainia 4 1 2 Virain Islands 7 Washinaton 2 1 1 3 West Virainia 2 1 4* Wisconsin 4 1 3 1 Wyoming 4 1 2 2 N/A Not applicable N/E Not established N/R No response D-6-3 ------- "Notes: South Coast 4 trade association representatives, 2 South Coast board members, 7 general public (including 4 city council members, 2 government agency officials, and 1 general public). The South Coast Air Quality Management District is a regional regulatory agency, NOT a state agency. In CA, there are 34 regional air quality management districts. At South Coast, the governing board's Local Government & Small Business Assistance Advisory Group functions as a CAP. CT 1 vacancy due to increased professional commitments. ID ID is in the process of notifying the Governor and other legislative leaders of the need to appoint the CAP members. IL 7 were appointed, 1 resigned. KS Currently awaiting new appointees. ME 2 seats vacant. MN The CAP is being reappointed. NV Pending new appointment. NM Expired terms. NY The terms of 8 CAP members have expired. New CAP members have not been named. NC CAP is inactive at this time. We are moving to establish an equivalent representative board. OH Awaiting reappointments. WV Replacements for previously filled positions. N/A Not applicable N/E Not established N/R No response D-6-4 ------- TABLE D-7 ADMINISTRATIVE LOCATION OF SBTCP COMPONENTS For SBO and SBAP functions, (R) denotes location is a regulatory agency; (N) denotes a non-regulatory agency or a non-enforcement division. CAPs are considered to be independent entities, located outside any agency, even though they may indicate that they receive administrative assistance from a regulatory or nonregulatory agency. BRIEF DESCRIPTION OF LOCATION STATE OR TERRITORY SBO SBAP CAP Alabama Department of Environmental Management, Office of Education & Outreach (N) Department of Environmental Management, Air Division (N) N/R Alaska Department of Environmental Conservation, Compliance Assistance Office (N) Department of Environmental Conservation, Compliance Assistance Office (N) Private, uncompensated individuals from small business & general public. One member is a Department emDlovee. Arizona Department of Environmental Quality, Compliance Assistance Section (N) Department of Environmental Quality, Compliance Assistance Section (N) Managed by Department of Environmental Quality, Compliance Assistance Section Arkansas Department of Environmental Quality, Director's Office (N) Department of Environmental Quality, Customer Service Division (N) Department of Environmental Quality, Customer Service Division California Air Resources Board (ARB), Office of the Ombudsman (R) Throughout ARB, Office of the Ombudsman, Office of the Chairman, local Air Pollution Control Districts (R) ARB, Office of the Chairman South Coast South Coast Air Quality Management District is a regional, single media (air only) regulatory agency whose four-county jurisdiction includes most of Los Angeles and Riverside Counties, all or Orange County, and the most populated portion of San Bernardino Countv. (R) Colorado Department of Public Health & Environment, Office of Customer Service (R) Department of Public Health & Environment, Air Pollution Control Division, Regulatory and Compliance SuDDort Unit (R) Independent. Connecticut Department of Environmental Protection (R) Department of Environmental Protection fR) Department of Environmental Protection N/A Not applicable N/R No response D-7-1 ------- BRIEF DESCRIPTION OF LOCATION STATE OR TERRITORY SBO SBAP CAP Delaware Department of Natural Resources & Environmental Conservation, Secretarvs Office (N) Department of Natural Resources & Environmental Conservation, Secretarvs Office (N)) Independent District of Columbia State agency (R) State agency (R) N/R Florida Department of Environmental Protection (N) Department of Environmental Protection (N) Coordinated by SBO/SBAP Georgia Environmental Protection Division, Air Protection Branch, Planning & Support Program (N) Environmental Protection Division, Air Protection Branch, Planning & Support Program (N) One CAP member is the Compliance Permitting Program manager in the Air Protection Branch. The rest of the CAP is outside all aaencies. Hawaii Department of Health, Director's Office (N) Department of Health, Clean Air Branch (R) Not yet established Idaho Division of Environmental Quality, Community Affairs (N) Division of Environmental Quality, Community Affairs assisted by Technical Services Division (R) Appointments made in accordance with Section 507 Illinois Environmental Protection Agency (R) Department of Commerce & Community Affairs (N) Department of Commerce & Community Affairs Indiana Department of Environmental Management, Office of Business Relations & Leaislative Affairs (N) Department of Environmental Management, Office of Pollution Prevention & Technical Assistance (N) Independent Iowa Department of Economic Development (N) Air Emissions Assistance Program (IAEAP), IA Waste Reduction Center (IWRC). University of Northern Iowa (N) Pending legislators* appointment Kansas Department of Health & Environment, Plannina & Prevention Section (N) Contracted* to University of KS, KS State University. Wichita State University (N) Voluntary Kentucky Office of the Commissioner (R) University of Kentucky* (N) Panel members appointed by the Governor Jefferson Countv Air Pollution Control District (N) Air Pollution Control District (R) See KY N/A Not applicable N/R No response D-7-2 ------- BRIEF DESCRIPTION OF LOCATION STATE OR TERRITORY SBO SBAP CAP Louisiana Department of Environmental Quality (R) Department of Environmental Quality (R) Independent Maine Department of Environmental Protection (R) Department of Environmental Protection (R) Outside Department as defined by Section 507 Maryland Department of the Environment, Environmental Permits Service Center (R) Department of the Environment, Environmental Permits Service Center (R) N/A Massachusetts N/R Office of Technical Assistance (N), Department of Environmental Protection (R)* N/R Michigan Ml Economic Development Corporation, Business Ombudsman's Office (N) (economic development aaencv) Department of Environmental Quality, Environmental Assistance Division (N) N/A Minnesota Pollution Control Agency, Policy & Plannina Division (N) Pollution Control Agency, Metro District (N) Independent Mississippi Department of Environmental Quality, Environmental Resource Center (R) Department of Environmental Quality, Environmental Resource Center (R) Department of Environmental Quality, Environmental Resource Center Missouri Governor's Office (N) Department of Natural Resources, Division of Environmental Quality, Technical Assistance Proaram (R) Department of Natural Resources, Division of Environmental Quality, Technical Assistance Proaram Montana Department of Environmental Quality, Pollution Prevention Bureau (N) Department of Environmental Quality, Pollution Prevention Bureau (N) Department of Environmental Quality, Pollution Prevention Bureau Nebraska Department of Environmental Quality, Environmental Assistance (N) Department of Environmental Quality, Environmental Assistance (N) Department of Environmental Quality, Environmental Assistance Nevada Division of Environmental Protection, Office of the Administrator (R) Division of Environmental Protection, Bureau of Air Qualitv (R) Independent Bureau of Air Quality Division of Environmental Protection, Bureau of Air Quality (BAQ). NDEP is the primary state regulatory agency for environmental issues. BAQ has oversight of air issues statewide except for stationary sources in Washoe and Clark Counties. (R) N/A Not applicable N/R No response D-7-3 ------- BRIEF DESCRIPTION OF LOCATION STATE OR TERRITORY SBO SBAP CAP Washoe Cty Air Quality Proa ram Washoe County District Health Department, Air Quality Management Division (county regulatory agency for air quality issues) (R) Clark Cty Air Quality Proa ram Clark County Health District, Air Pollution Control Division (county regulatory agency for air quality issues) (R) BEP-UNR Small Business Development Center, Business Environmental Program (BEP), University of Nevada Reno (UNR) (under contract with NDEP BAQ and Washoe County District Health Department, Air Pollution Control Division to provide outreach materials, workshops, hotlines, and on-site assistance regarding air quality, hazardous waste, pollution prevention, and other environmental issues. (N) New Hampshire Office of the Commissioner (R) Air Resources Division (R) Air Resources Division New Jersey Commerce & Economic Growth Commission (N) Department of Environmental Protection (R) Department of Environmental Protection New Mexico Environment Department (R) Environment Department, Air Quality Bureau. Control Strateav Section (R) Independent and located outside the aaencv New York Empire State Development (economic development department) (N) NY State Environmental Facilities Corporation, Technical Advisory Services Division (state public benefit corporation) (N) Department of Environmental Conservation, Bureau of Technical Support North Carolina Department of Environment & Natural Resources, Customer Service Center (N) Department of Environment & Natural Resources, Customer Service Center (N) Independent North Dakota Department of Health, Environmental Health Section Chief's Office (N) Department of Health, Environmental Health Section fair, water, waste) (R) Independent, located outside all aaencies Ohio Air Quality Development Authority (N) Environmental Protection Agency, Division of Air Pollution Control (R) Independent Oklahoma Executive Director's Office (N) Customer Services Division (N) Organized through Customer Services Division Oregon Department of Environmental Quality, Director's Office (R) Department of Environmental Quality, Air Qualitv Division (R) Outside agency; liaison to SBAP, SBO. small businesses N/A Not applicable N/R No response D-7-4 ------- BRIEF DESCRIPTION OF LOCATION STATE OR TERRITORY SBO SBAP CAP Pennsylvania Department of Environmental Protection (N) Contracted* (N) Independent Puerto Rico Commercial Development Administration (N) Environmental Quality Board, Air Quality Area (R) Not in full operation Rhode Island Department of Environmental Management, Director's Office (N) Department of Environmental Management, Office of Technical & Customer Assistance; University of Rl (N) Will be located outside DEM. South Carolina Department of Health & Environmental Control, Environmental Quality Control Administration (N) Department of Health & Environmental Control, Environmental Quality Control Administration (N) Department of Health & Environmental Control, Environmental Quality Control Administration South Dakota Supervised by Department of Environment & Natural Resources Secretary (R) Department of Environment & Natural Resources, Air Program (R) Independent Tennessee Bureau of Environment, Department of Environment & Conservation (R) Division of Community Assistance, Department of Environment & Conservation (N) Not yet appointed Texas Natural Resource Conservation Commission (N) Natural Resource Conservation Commission, Small Business & Local Government Assistance (N) Natural Resource Conservation Commission, Small Business & Local Government Assistance Utah Department of Environmental Quality, Office of Planning & Public Affairs (R) Department of Environmental Quality, Division of Air Quality, Operating Permits Section (R) Department of Environmental Quality, Division of Air Quality, Office of Plannina & Public Affairs Vermont N/A Department of Environmental Conservation, Environmental Assistance Division (N) Department of Environmental Conservation, Environmental Assistance Division Virginia Department of Environmental Quality, Air Programs Coordination (R) Department of Environmental Quality, Division of Pollution Prevention & Compliance Assistance (N) Independent Virgin Islands Department of Planning & Natural Resources (R) Department of Planning & Natural Resources (R) Not yet named N/A Not applicable N/R No response D-7-5 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF LOCATION SBO SBAP CAP Washington* Department of Ecology, Air Quality Proa ram (R) Department of Ecology, Air Quality Proa ram (R) Independent West Virginia Division of Environmental Protection (R) Division of Environmental Protection, Office of Air Quality (R) Located outside all agencies. Wisconsin Department of Commerce, Business Development Assistance Center (N) Department of Commerce, Business Development Assistance Center (N) Department of Commerce, Business Development Assistance Center Wyoming Department of Environmental Quality, Office of Outreach, Administrative Division (N) Department of Environmental Quality, Office of Outreach, Administrative Division (N) Independent citizens panel *Notes MA Technical advice through nonregulatory OTA. DEP source of regulatory information. WA SBO is agency representative to the Governor's Small Business Improvement Council composed of small business owners and various state agencies responsible for regulating the state's businesses. SBO is agency representative to Unified Business Identifier Board composed of state and federal regulatory agencies impacting small businesses. SBAP supports technical assistance staff for business-related pollution control/prevention in other Ecology programs, outreach and assistance staff in the state's seven local air quality control agencies, and moderate risk waste staff in the state's 39 counties. One CAP member is the legislative liaison for the Air Quality Program. All other CAP members are unpaid volunteers (per diem, travel, lodging, and meals are reimbursed). Staff support provided by SBAP. N/A Not applicable N/R No response D-7-6 ------- Four states have contracted the management of the SBAP to an outside entity. Information on SBAP contractors is provided below. STATE CONTRACTOR TERMS Kansas Mr. Marvin Hunt University of Kansas Division of Continuing Education 1515 St. Andrews Drive Lawrence, KS 66047 785-864-9196 785-864-5074 fax 1999 budget - $400,000 Term of contract - 7/1 through 6/30 KU - newsletter, resource center. KSU - on-site visits, answers to questions, workshops, and manuals and other materials. Ms. Jean Waters Kansas State University Pollution Prevention Institute 133 Ward Hall Manhattan, KS 66056 785-532-6501 and 800-578-8898 785-532-6952 fax Kentucky Mr. Gregory C. Copley, Director Kentucky Business Environmental Assistance Program Gatton Building, Room 227 University of Kentucky Lexington, KY 40506-0034 606-257-1131 606-323-1907 fax 1999 budget - $278,501 Term of contract - one year Nevada Mr. Kevin Dick NV SBDC, Business Development Program University of Nevada-Reno 6100 Neil Road, Suite 400 Reno, NV 89511 775-689-6688 775-689-6689 fax 1999 budget - $350,000 Term of contract - 7/1/00 through 6/30/01 Provides air quality, hazardous waste management, and multimedia pollution prevention assistance. Pennsylvania Ms. Cecily Beall Tetra Tech EM, Inc. 1800 JFK Boulevard, 6th Floor Philadelphia, PA 19103 215-656-8709 215-972-0484 fax 1999 budget - $571,000 Term of contract - 2 years Technical assistance D-7-7 ------- APPENDIX E SBTCP ACTIVITIES AND SERVICES ------- TABLE E-1 SBTCP ASSISTANCE TOTAL STATES PROVIDING ASST. / TOTAL BUSINESSES REACHED INDUSTRY (SIC) TOTAL STATES PROVIDING ASST. TOTAL BUSINESSES REACHED Cross Sector 30 353,493 Other 39 122,788 Organizations/Associations (86) 39 105,063 Auto/Body Maintenance, Repair, Refinishing (75) 43 89,025 Auto/Motor Vehicle Dealers & Equipment (55, 501) 30 45,036 Dry Cleaners/Laundry Services (721) 44 34,150 Machine Shop (359) 22 23,271 Government (91, 95) 38 7,652 Furniture Manufacture/Repair/Wood Finishing (25, 764) 39 6,150 Attorney/Consultant/Engineer (81, 87) 36 5,819 Printing/Graphic Arts (27) 39 5,438 Metal Fabricating/Finishing (34) 38 5,274 Concrete/Aggregate (32) 34 5,008 Construction/Contractor (15, 16, 17) 31 4,440 Electroplating/Chrome Plating (347) 34 4,339 Transportation Services (42, 44, 47) 20 3,919 Petroleum Products, Storage, Pipelines (29, 46) 28 3,828 Agriculture/Farming/Crop Service (01, 07) 36 3,518 Waste/Waste Hauling (495) 24 3,019 Paints & Painting/Coatings (172, 285) 35 2,838 Hospitals/Medical Health Services (80) 30 2,705 Foundry/Smelter, Forging, Casting (33) 28 2,693 Private Citizen 32 2,425 Landfills/Landfill Gas (495) 20 2,239 Asbestos/Remediation (17, 32) 22 2,115 Sawmills/Logging/Wood Products (24) 30 2,026 Manufacturing, Misc. 31 1,917 Retail/Wholesale Trade (50, 51, 59) 22 1,619 Gasoline Distribution (wholesale/retail) (517, 554) 34 1,605 Boilers (34, 50) 22 1,592 Recreation Services (79) 9 1,582 Dairy/Feedlots/Livestock (02) 20 1,565 Chemicals/Products (28) 32 1,364 Schools (82) 31 1,315 Boat Manufacturing (373) 20 1,271 Plumbing/HVAC (171) 18 1,251 Recycling (509) 30 1,075 Plastic Manufacturing/Products (308) 34 1,064 Real Estate (65) 24 1,016 Veterinarians (074) 10 945 Rubber Manufacturing/Products (30) 13 904 Food/Beverage Products & Processing (20, 514) 26 831 Machine/Equipment Manufacturing & Repair (35) 31 806 Electronics/Electric Equipment/Repair (36, 762) 24 802 Wastewater Treatment (495) 34 798 E-1 -1 ------- TABLE E-1 SBTCP ASSISTANCE TOTAL STATES PROVIDING ASST. / TOTAL BUSINESSES REACHED INDUSTRY (SIC) Crushed Stone Products/Sand & Gravel (14) Restaurants (581) Utilities (49) Business Services (73) Asphalt (295) Transportation Equipment (37) Mining (metal & coal) (10, 12) Research & Testing Facilities/Laboratories (873) Degreasers Engines & Turbines (351) Personal Services (72) Hotels/Motels (70) Aerospace (37) Grains/Grain Elevators (011, 422) Pharmaceuticals (283) Stone/Clay/Glass (32) Textiles & Apparel (22, 23) Bakeries (546) Analytical/Medical Instruments (38) Repair, Misc. (76) Paper Manufacturing/Products (26) Communications (48) Incinerators Airports/Air Transportation (45) Leather/Fur (31,237) Cotton Gins (072) Transit (passenger) (41) TOTAL STATES TOTAL BUSINESSES PROVIDING ASST. REACHED 28 681 12 646 29 606 21 589 25 579 17 549 15 518 23 496 24 415 10 375 15 374 15 321 16 312 16 237 10 205 16 194 15 155 12 152 13 132 10 131 22 88 16 87 18 74 13 73 7 22 3 12 2 6 E-1-2 ------- TABLE E-2 SBTCP ASSISTANCE TOTAL STATES PROVIDING ASST. / TOTAL BUSINESSES REACHED TOTAL STATES TOTAL BUSINESSES INDUSTRY (SIC) PROVIDING ASST. REACHED Dry Cleaners/Laundry Services (721) 44 34,150 Auto/Body Maintenance, Repair, Refinishing (75) 43 89,025 Furniture Manufacture/Repair/Wood Finishing (25, 764) 39 6,150 Organizations/Associations (86) 39 105,063 Printing/Graphic Arts (27) 39 5,438 Other 39 122,788 Government (91, 95) 38 7,652 Metal Fabricating/Finishing (34) 38 5,274 Agriculture/Farming/Crop Service (01, 07) 36 3,518 Attorney/Consultant/Engineer (81, 87) 36 5,819 Paints & Painting/Coatings (172, 285) 35 2,838 Concrete/Aggregate (32) 34 5,008 Electroplating/Chrome Plating (347) 34 4,339 Gasoline Distribution (wholesale/retail) (517, 554) 34 1,605 Plastic Manufacturing/Products (308) 34 1,064 Wastewater Treatment (495) 34 798 Chemicals/Products (28) 32 1,364 Private Citizen 32 2,425 Construction/Contractor (15, 16, 17) 31 4,440 Machine/Equipment Manufacturing & Repair (35) 31 806 Manufacturing, Misc. 31 1,917 Schools (82) 31 1,315 Auto/Motor Vehicle Dealers & Equipment (55, 501) 30 45,036 Hospitals/Medical Health Services (80) 30 2,705 Recycling (509) 30 1,075 Sawmills/Logging/Wood Products (24) 30 2,026 Cross Sector 30 353,493 Utilities (49) 29 606 Crushed Stone Products/Sand & Gravel (14) 28 681 Foundry/Smelter, Forging, Casting (33) 28 2,693 Petroleum Products, Storage, Pipelines (29, 46) 28 3,828 Food/Beverage Products & Processing (20, 514) 26 831 Asphalt (295) 25 579 Degreasers 24 415 Electronics/Electric Equipment/Repair (36, 762) 24 802 Real Estate (65) 24 1,016 Waste/Waste Hauling (495) 24 3,019 Research & Testing Facilities/Laboratories (873) 23 496 Asbestos/Remediation (17, 32) 22 2,115 Boilers (34, 50) 22 1,592 Machine Shop (359) 22 23,271 Paper Manufacturing/Products (26) 22 88 Retail/Wholesale Trade (50, 51, 59) 22 1,619 Business Services (73) 21 589 Boat Manufacturing (373) 20 1,271 E-2-1 ------- TABLE E-2 SBTCP ASSISTANCE TOTAL STATES PROVIDING ASST. / TOTAL BUSINESSES REACHED TOTAL STATES TOTAL BUSINESSES INDUSTRY (SIC) PROVIDING ASST. REACHED Dairy/Feedlots/Livestock (02) 20 1,565 Landfills/Landfill Gas (495) 20 2,239 Transportation Services (42, 44, 47) 20 3,919 Incinerators 18 74 Plumbing/HVAC (171) 18 1,251 Transportation Equipment (37) 17 549 Aerospace (37) 16 312 Communications (48) 16 87 Grains/Grain Elevators (011, 422) 16 237 Stone/Clay/Glass (32) 16 194 Hotels/Motels (70) 15 321 Mining (metal & coal) (10, 12) 15 518 Personal Services (72) 15 374 Textiles & Apparel (22, 23) 15 155 Airports/Air Transportation (45) 13 73 Analytical/Medical Instruments (38) 13 132 Rubber Manufacturing/Products (30) 13 904 Bakeries (546) 12 152 Restaurants (581) 12 646 Engines & Turbines (351) 10 375 Pharmaceuticals (283) 10 205 Repair, Misc. (76) 10 131 Veterinarians (074) 10 945 Recreation Services (79) 9 1,582 Leather/Fur (31,237) 7 22 Cotton Gins (072) 3 12 Transit (passenger) (41) 2 6 E-2-2 ------- TABLE E-3 HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE PROGRAM HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE Alabama Dry cleaners, bakeries, sawmills Alaska N/R Arizona N/R Arkansas Agricultural aerial applicators, gasoline stations, saw mills, anhydrous ammonia fertilizer facilities, foundries California Auto body refinishing, dry cleaning, furniture refinishing. South Coast Special notices were mailed to several industry categories informing them of new requirements and offering help on our toll-free hotline. Industries included auto paint shops, auto repair shops, machine shops, and furniture stripping/refinishing shops Colorado SBO/SBAP - Developing a multimedia P2 compliance guide for dry cleaners. SBAP - Developed and is distributing multimedia P2 guides to the automotive industry. Developed a multimedia compliance guide for the restaurant industry Developed on-line compliance assistance with web sites for chromium electroplating and anodizing, printing and publishing, and offsite and recovery operations. Connecticut Government (state and local) and institutions Delaware Dry cleaners. District of Columbia Dry cleaners, utility boilers, gas stations, auto body shops, bus idling, asbestos remediation. Florida Distributed dry cleaner compliance calendars for 2000. Distributed Y2K compliance tool kit for dry cleaners, degreasers, electroplaters, and printers. Conducted statewide printer workshops, "Printers Protecting the Environment." Distributed 1,500 program change advisories to asbestos contractors Georgia Perc dry cleaners. Hawaii Dry cleaners Idaho Auto body shops, printers, dry cleaners Illinois SBAP worked with IEPA on Clean Fuel Fleet Program initiatives and Short Form Annual Emission Report filers General Lifetime Operating Permits were created for aggregate processors Also focused on Risk Management Plans and perc dry cleaners N/A Not applicable N/R No response E-3-1 ------- PROGRAM HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE Indiana Dry cleaners, vehicle maintenance shops, collision repair/auto refinishing, fiberglass reinforced product manufacturers, wood furniture manufacturers, printers, hospitals, schools, TRI reporters, child care facilities, HVAC contractors/suppliers, degreasers, metal finishers/electroplaters Iowa Mass mailing to 112(r) affected facilities in connection to the RMP development workshop conducted later. The list of affected clients initially was developed after a needs assessment study. Main focus was on an amnesty list (of 167 developed in 1997, amnesty applicable to state permitting) consisting of several business types. Kansas Metal finishing, industrial cleaning, wood finishing, dry cleaners, foundries, above ground and underground storage tanks Kentucky N/R Jefferson Cty N/R Louisiana Dry cleaners, architectural coating manufacturers, fiberglass/cultured marble, sandblasters, paint users, agricultural industries Maine Businesses subjected to 112(r) of the CAA (propane, chlorine, ammonia, etc.), vehicle repair facilities Maryland N/R Massachusetts Companies with emergency plans, solvent users, toxics users, sawmills, autobody shops. Michigan SBO - Advanced manufacturing, high technology SBAP - The following industries were provided specialized assistance for compliance with the state's emission inventory reporting: surface coating, electroplating, foundries, hot mix asphalt, aggregate, oil and gas production, and municipal solid waste SBAP also targeted a cross section of industries for technical assistance through guidance document development and workshops on state and federal regulations governing particulate mater (fugitive dust). The following activities were targeted for fugitive dust compliance assistance road maintenance and repair; salvage work at trucking and rail yards; abrasive building or equipment blasting; mining/mineral use and processing; hot mix asphalt and concrete batch plants and terminals; glass, concrete, rock crushing, or building demolition; travel on unpaved shoulders, parking lots, vacant lots, and alleys; and work at bulk storage of agricultural grain, minerals, gravel, sand, sinter, cement, stone, clay, gypsum or glass. Minnesota Small manufacturers, auto body and mechanical repair, above ground storage tank owners/operators, aqueous-based parts washers Mississippi Sawmills. Missouri N/R Montana Sand, gravel, asphalt producers, dry cleaners, wood furniture producers, small combustion sources, water and wastewater treatment plant owners/operators, propane and anhydrous ammonia users. N/A Not applicable N/R No response E-3-2 ------- PROGRAM HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE Nebraska Manufacturing, painting operations Nevada Automotive repair and refinishing, mining, sand and gravel/concrete aggregate, construction, facilities generating VOCs. The SBDC-BEP also targeted hospitality and real estate in conjunction with assistance contacts they have with Washoe County Air Quality. New Hampshire Automotive repair/refinishing, metal finishing New Jersey Dry cleaners, auto retailers, auto body repair facilities, plastics facilities, printing/graphic arts facilities New Mexico Asphalt plants, rock crushers, sand and gravel, concrete batch plants, automotive paint and body, spray painting, abrasive blasting New York Dry cleaners and cross industry sectors of permitted sources located outside New York City with potential to emit above major thresholds. Most of these sources had the option to cap actual emissions under Title V limits. North Carolina Dry cleaners - We began developing a compliance assistance calendar patterned after the one that Florida developed. We added tips to each month, which help businesses understand the regulations. Tips included information on pollution prevention and compliance assistance for air, water, and waste management. Electric motor manufacturers - We assisted them in developing better environmental tests to determine the environmental impact of their industry. The information collected allows them to keep an exemption that exists for air quality rules. Wood furniture manufacturers - We worked with small furniture companies to help them understand the MACT requirements for wood furniture and how these requirements relate to the state's air toxics requirements. Large manufacturers were able to negotiate an SOC to give them additional time to comply with state rules, if they meet federal standards. The SOC was not always of benefit to smaller companies, and we helped them to see this issue. North Dakota Medical waste incinerators, oil and gas production, general contractors, electricians, architects, schools (for asbestos), automotive repair and service, construction sites, feed lots Ohio Metal finishers/metal parts fabricators were targeted for assistance, because state RACT coating rules were amended in June 1999. The rule change requires metal painting operations using over 3 gallons of coatings/day in the Cleveland, Akron, and Cincinnati areas to use VOC-compliant coatings. Previous exemption level was 10 gallons/day. SBO - Program targeted dry cleaners for financial assistance and outreach efforts for auto dealers and collision repair shops. In the latter two, grants were approved for the respective state trade associations to develop "Environmentally Responsible Management" manuals and deliver them through seminars. Oklahoma Dry cleaners, consumer product manufacturers, fiber reinforced plastics manufacturers Oregon Automotive repair shops, autobody shops, dry cleaners, halogenated solvent users. Pennsylvania N/R N/A Not applicable N/R No response E-3-3 ------- PROGRAM HIGH PRIORITY INDUSTRY SECTORS TARGETED FOR ASSISTANCE Puerto Rico N/R Rhode Island Auto body, metal finishing, fish processors, the arts community. South Carolina Propane dealers, concrete ready-mix batch plants South Dakota N/R Tennessee Dry cleaners, water/wastewater operations, government, 112(r) potentially affected facilities Texas Small quantity generators of hazardous waste; auto body and auto service facilities; dry cleaners; metal finishers; industries subject to storm water regulations; auto dealers; foundries; printers; wastewater and public drinking water systems; auto salvage facilities; dairies; surface coaters; grit, grease, and septage waste generators and haulers; wood products facilities; concrete batch plants Utah Wood furniture manufacturers Vermont Vehicle service, wood products Virginia Propane dealers for 112(r) compliance provisions of the CAA, small businesses for Internet training, VOC and HAP emitters Also developed federal state guide. Virgin Islands Auto body and repair shops, dry cleaners Washington OAPCA - Extensive outreach to and registration of spray coating operations, including auto body shops, fiberglass shops, and cabinet shops to find sources that might need to be registered or need a New Source Review, plus any other business assistance. SCAPCA - Surface coating facilities were prioritized for assistance, because local regulations were revised, resulting in modifications to over half of our registered surface coaters. West Virginia WV SBAP assisted the Clean Air Council in its development of the WV section of the EPA publication, "Grasping for Air...The Small Business Guide to Key Federal and State Air Regulations." This guide book specifically targeted VOC and HAP sources, specifically painting and coating sources. The WV section focused on the VOC RACT rule covered under state regulation 45 CSR 21 and the toxic air pollutants (TAPs) covered under state regulation 45 CSR 27. Wisconsin Businesses affected by 112(r) RMP regulation, metal finishers targeted for EPA enforcement initiative in VOC nonattainment areas, automotive industry permitting exemption Wyoming Auto repair and auto body shops, construction/contractors, medical facilities, petroleum production and service, outdoor recreation N/A Not applicable N/R No response E-3-4 ------- TABLE E-4 SBTCP ASSISTANCE TOTAL BUSINESSES REACHED* TOTAL BUSINESSES PROGRAM REACHED Alabama 939 Alaska 82 Arizona 27,007 Arkansas 102,301 California 34,374 South Coast, CA 39,270 Colorado X Connecticut 5,130 Delaware X District of Columbia X Florida 156,399 Georgia 48,015 Hawaii 1,083 Idaho 399 Illinois 16,711 Indiana 23,247 Iowa 2,667 Kansas 986 Kentucky 11,234 Jefferson County, KY 498 Louisiana 21,699 Maine 1,594 Maryland 154 Massachusetts 7,178 Michigan 22,940 Minnesota 77,997 Mississippi 5,000 Missouri 8,944 Montana 1,029 Nebraska NR Nevada 12,160 New Hampshire 973 New Jersey 31,328 New Mexico 1,539 New York 23,778 North Carolina 9,025 North Dakota X Ohio 17,688 Oklahoma 1,107 Oregon 1,324 Pennsylvania 16,274 Puerto Rico 93 Rhode Island X E-4-1 ------- TABLE E-4 SBTCP ASSISTANCE TOTAL BUSINESSES REACHED* PROGRAM TOTAL BUSINESSES REACHED South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Virgin Islands Washington West Virginia Wisconsin Wyoming TOTAL 920,384 6,605 63,703 2,491 10,350 5,434 54,393 14,152 10,832 19,107 593 558 x --NOTE* "Total businesses reached" as reported by the states is used as the "official" count for this report. --Some programs tried not to "double count" total businesses reached. --Two programs and one county did not keep data by industry sector, and only "total" businesses reached" was given. (Jefferson County, KY; NH; NC;) --Six states kept information on the services they offered or the industry sectors they assisted, but did not compile data. (CO, DE, DC, ND, Rl, SD) --NE did not respond to this question. E-4-2 ------- TABLE E-5 SBTCP ASSISTANCE TOTAL BUSINESSES REACHED BY ASSISTANCE TYPE Many states tried not to double count total businesses reached when collecting their data Therefore, data cannot be summed across to find total businesses reached for each state Many states only provided the number of businesses assisted and did not include the number of each type of assistance provided PROGRAM HOTLINE ON-SITE VISITS SEMINARS/WORKSHOPS PUBLICATIONS HOMEPAGE TELECONFERENCE MAILINGS OTHER Alabama 822 98 98 19 19 Alaska 1 28 53 Arizona 976 11 20 26.000 Arkansas 271 46 235 7 813 5 5 59 100.803 44 84 California 5.583 17 205 36 1.056 2 922 X 20 3 12.000 3 13.639 South Coast. CA 3.633 192 20 622 4 35.600 731 Colorado X X X X X X Connecticut 2.104 210 210 34 1.655 1 3 910 250 Delaware X X X X District of Columbia NA Florida 319 6 571 2 1.513.000 26 26 5 4.183 Georgia 719 53 9 123 17 45.098 1.754 Hawaii 107 29 29 5 271 3 380 4 10 4 286 Idaho 35 11 11 1 353 Illinois 501 15 680 9.229 7 6.301 Indiana 2.785 245 245 32 1.491 16 4.305 3.691 14 10.730 Iowa 14 88 88 50 1.400 1.115 1.115 Kansas 598 23 58 4.897 28 28.380 Kentucky 754 90 77 16 402 18 5.800 653 3 5 12 893 15 1.650 Jefferson County. KY 117 48 8 47 286 Louisiana 37 1.100 546 41 14.000 4.360 1.615 Maine 11 439 1 1.000 Maryland X 1 8 X 148 148 Massachusetts 128 2.650 400 4.000 Michigan 1.295 43 43 34 2.971 10 15.493 2.598 517 517 23 23 Minnesota 1.122 109 109 10 480 19 72.200 3 4.065 1 1 Mississippi Missouri 2.644 162 162 79 4.742 847 847 60 2 245 16 64 Montana 92 6 6 6 172 10 836 2 12 Nebraska NR Nevada 1.304 64 118 62 1.988 57 4.061 27 59 354 4.518 80 112 New Hampshire 573 14 14 9 350 6 36 New Jersey 1.478 5 17 1.290 2 600 2.090 25.839 26 New Mexico 5 7 7 1 8 7 12 6 1.256 2 251 New York 1.954 15 15 22 6.008 6 7.671 9 8.130 52 North Carolina 2.500 40 35 6.000 450 North Dakota X X X X X X X Ohio 1.470 144 144 258 1.335 9 8.650 2.350 5 3.468 646 271 Oklahoma 648 36 36 18 149 7 430 1.035 Oregon 99 46 6 154 1 14 1.024 Pennsylvania 862 12 12 14.200 1 1.200 Puerto Rico 79 58 2 112 2 Rhode Island X X X X X X X X South Carolina 5 5 9 258 8 18.600 59 59 185 185 South Dakota X X X Tennessee 664 19 29 774 24 788 1.119 16 4.306 22 491 Texas 3.306 226 171 57 1.784 4 9.965 281 139 48.196 Utah 25 4 70 15 1.474 1 30 100 13 785 2 36 Vermont 329 36 13 225 3 Virginia 456 3 3 28 575 11 3.890 4.562 1 3 19 856 1 5 Virgin Islands 179 33 2 5.520 Washington 21.906 4.503 80 1.696 17 2.532 2 20 23.541 193 West Virginia 76 14 14 2 50 1 100 1 318 Wisconsin 486 31 31 30 1.303 1.330 9.595 97 1.407 Wyoming 468 574 574 4 73 3 6.000 1.188 3 746 14 1.783 TOTAL 63,216 2,299 9,103 1,117 42,534 1,095 386,110 3 66,703 109 4,067 1,276 342,910 2,429 34,875 E-5-1 ------- TABLE E-6 NEW DOCUMENTS PREPARED AND DISTRIBUTED BY SBTCPs IN 1999 PROGRAM 1999 SBTCP DOCUMENTS Alabama N/R Alaska • Newsletter • Web page • Permit questionnaire • Post card reminder Arizona N/R Arkansas • Fact sheets for aerial applicator "fly-ins" • Consolidated various Customer Service Division brochures into a packet • Reformatted small business loan package • Prepared media overview pamphlets (air, water, solid waste, hazardous waste) via Customer Service outreach California • Business Assistance Resource Guide for California Environmental Management - This document provides a reference for businesses in the state when they are seeking a contact in the various environmental programs. The guide includes contact numbers and information at federal, state, and local levels for air, water, pesticides, wastes, hazardous waste, and general business assistance needs. • Environmental Financing Resources for California Businesses - This document serves as a desk reference to funding available through federal, state, local, and private financing authorities. We expect this guide to be constantly evolving to incorporate the latest information. • Air Pollution Glossary - Several years ago, we developed a glossary of air pollution terms to help the public understand air quality terminology. In 1999, this document was updated and expanded to include more than three times the number of terms. All ARB rulemaking documents, presentations, and workshop announcements are published both in hard-copy and on our website. These include staff reports, technical support documents, workshop agendas and presentations, and many other regulatory development support materials. This has been an ongoing effort to reach interested parties with the information they need to better participate in our process. Additionally, many of the air districts continually update and publish new information to help businesses connect with resources available to them. N/A Not applicable N/R No response E-6-1 ------- PROGRAM 1999 SBTCP DOCUMENTS South Coast • Business Assistance Resource Guide (revised and updated, standard handout for trade shows, conferences, meetings) Distributed a number of special notices to specific industry categories to remind them of new requirements: • Special Notice to Automotive Repair Shops - Requirement to switch to water-based cleaners. Sent to 14,000 shops. Included lists of suppliers and hazardous waste haulers. This effort also is considered a pollution prevention effort. • Special Notice to Users of Batch Loaded Cold Cleaners for Solvent Degreasing - Requirement to switch to water-based cleaners. Mailed to 23,000 shops. Included lists of suppliers and hazardous waste haulers. This effort also is considered a pollution prevention outreach effort. • Special Notice to Furniture Stripping Operations - Requirement to obtain permit. Mailed to 300 shops. Various CA Air Districts Butte County • Basin Newsletter • Clean Air Kids - newsletter • Protecting Those We Serve - brochure • Air Quality Permits - brochure • Residential Burning - brochure • Agricultural Burning - brochure • Public Records Information - brochure • The Hearing Board - brochure • Enforcement Procedures - brochure • Ambient Air Quality Reports & Annual Summaries Santa Barbara • On the Air - newsletter Colorado • Pressing Concerns - A Complete Guide to a (Dry) Cleaner Environment • Online compliance assistance web sites for chromium electroplating and anodizing, printing and publishing, and offsite recovery operations • Guidance documents for land development, asphalt and concrete production, wood finishing, asphalt roofing, and metal surface coating Connecticut • Municipal Public Works Hazardous Waste Guidance Package • State Parks Initiative Guidance • Aerosol Can Policy Fact Sheet • Guidance Documents for Conditionally Exempt Small Quantity Generators Delaware N/R N/A Not applicable N/R No response E-6-2 ------- PROGRAM 1999 SBTCP DOCUMENTS District of Columbia • Grasping for Air - A Small Business Guide to Key Federal and State Air Regulations by the Clean Air Council (to be distributed in 2000) Florida • 2000 Dry Cleaners Calendar • Printers Protecting the Environment - workbook • Y2K Compliance Tool Kit • SBAP Conference Planning Manual • Asbestos Program: Notification of Program Changes for Asbestos Contractors Georgia • Environmental Protection Division's Inspection Guide • 2000 Dry Cleaner Compliance Calendar (with hazardous waste tips) • 1999 SBAP Brochure Hawaii • Dry Cleaner Calendar - multimedia • Frequently Asked Questions • Hazardous waste advisories for dry cleaners and grease trap material recycling Idaho • Autobody shop brochure Illinois • Medical Waste Rule - fact sheet • Aggregate Processors - fact sheet • Cold Cleaning - fact sheet • Clean Air Clips - quarterly newsletter • Construction and Demolition Debris - fact sheet • How Do I Manage Asbestos in My Building? - fact sheet • How Do I Manage Asbestos in My House or Apartment Building? - fact sheet • How Do I Manage My Used Rags and Other Absorbents? - fact sheet • Managing and Reducing Parts Washer Wastes - fact sheet • Mobile Power Washing: Keep It Clean - fact sheet N/A Not applicable N/R No response E-6-3 ------- PROGRAM 1999 SBTCP DOCUMENTS Indiana • Vehicle maintenance - 5-Star application, customer brochure, mentor list, participant list, vendor list • Child care - 5-Star application • 100% Club - application, fact sheet • New Environmental Rules for Cold Cleaning Degreasing Operations in Clark, Floyd, Lake, and Porter Counties - fact sheet • Mercury Thermostat Reduction & Recycling Program: Architects and Mechanical Engineers Brochure and Certificate • Pollution Prevention Annual Report • IDEM Annual Report • OPPTA brochure • Strategic Goals Program brochure for metal finishers and publicly owned treatment works • Foundry and metal finishing - listing of most common RCRA violations was prepared by the Office of Solid and Hazardous Waste Management and distributed to foundry and metal finishing sector trade associations and individual facility contacts Iowa • RMP development assistance program for 112(r) affected sources • Resource Guide 2000 - finalized electronic version, which covers all SBO/SBAP programs nationwide • Program for Enhanced Environmental Recordkeeping (PEER) - developed and piloted computerized program, currently geared for manufacturing, will be expanded later Kansas • Policies, Procedures, and Guidance Documents Update for 1999 - contains all internal documents developed by the Division of Environment during 1999 for the enforcement of environmental regulations • Dry Cleaners Compliance Calendars (six versions, depending on source category) • Increase Your Bottom Line - Manage Cleaning Solvents Better • P2 You Can Do in Your Finishing Shop - Pollution Prevention for the Electroplating and Metal Finishing Industry • Complying with New Used Oil Regulations • Pollution Prevention for the Wood Manufacturing and Finishing Industry • Recycling and P2 Help Cobalt Save Money N/A Not applicable N/R No response E-6-4 ------- PROGRAM 1999 SBTCP DOCUMENTS Kentucky • The B.E.A.P. Report - newsletter • Don't Let Mother Nature Call - advertisement in 5 state publications • KBEAP kitchen magnets • Environmental Resources for Small Business - booklet • Kentucky's Best Kept Secret - article published in KY Journal of Industry and Commerce Prepared by the Air Quality Representative for Small Business • Columns - four columns written and distributed to 11 state newsletters with circulation of 45,600 per mailing Jan: Expect Stronger Emphasis on Pollution Prevention from Air Quality March: Small Businesses and DAQ Regional Offices May: Panel Seeks Award Nominations Oct: Air Quality Small Business News • Articles - published in Land, Air & Water, 1999 publication of the KY Natural Resources and Environmental Protection Cabinet with circulation of 13,000 March: Harry "Bo" Hoe is Honored by Small Business Panel March: Web sites for Small Businesses with Air Quality Questions June: Three Kentucky Businesses Receive Assistance from TAP June: Nominations Sought for Small Business Air Quality Stewardship Award Sept: Patton Appointees Take Oath at Air Quality Small Business Panel Meeting Sept: Secretary Bickford Presents Air Quality Stewardship Awards Dec: Program Helps Small Business Tackle Big Job • Press releases - statewide distribution May: Panel Seeks Nominations for Small Business Air Quality Stewardship Award May: Governor Patton Announces Appointments (released by Governor's office) Sept: Small Businesses Receive Air Quality Stewardship Awards • Miscellaneous May: KY Small Business Air Quality Stewardship Award - 1999 Fact Sheet July: Small Business Stationary Source Compliance Advisory Panel Orientation Manual Jefferson Cty N/R Louisiana • SBAP quarterly newsletter - 3,400 distributed • Dry cleaner compliance calendar - 650 distributed • 1998 SBAP Annual Report - 325 distributed • SBAP/ DEQ flyers - 100,000 distributed • SBAP brochure - 1,000 distributed N/A Not applicable N/R No response E-6-5 ------- PROGRAM 1999 SBTCP DOCUMENTS Maine • Model Facility Guide for Vehicle Repair Facilities Maryland N/R Massachusetts • Model integrated emergency plans Michigan SBAP • Emission inventory reporting workbook to assist businesses with implementing and complying with the new electronic Ml reporting system • Set of emission inventory calculation worksheets - surface coating, electroplating, foundries, hot mix asphalt, aggregate, oil and gas production, and municipal solid waste • How to Manage Fugitive Dust - draft fact sheet as a companion guidance for a program workshop on fugitive dust Minnesota • Environmental Guide for Small Businesses in Minnesota - user friendly guide for small manufacturers to the state's environmental regulations. Intended to give businesses enough information to determine if they are subject to a regulation and sources of additional assistance. Multimedia, interagency guide includes OSHA, emergency response, P2, and financial assistance. Mississippi N/A Missouri • Missouri Aquaculture Environmental and Regulatory Guide, SIC Code 0273 • Pollution Prevention at Hot Mix Asphalt Plants, SIC Code 2951 Montana • Industry Outreach Newsletter to Drycleaners (draft 1999, mailed 2000) • Industry Outreach Newsletter to Wood Furniture Manufacturers (draft 1999, mailed 2000) • Industry Outreach Newsletter to Concrete, Asphalt, and Sand and Gravel Producers • Small Business News - RMP Newsletter for Wastewater Treatment Plants • Small Business News - RMP Newsletter for Ammonia and Propane Dealers • MACT Update Newsletter for businesses with combustion devices • Asbestos brochure for homeowners (draft 1999, mailed 2000) Nebraska • Consultants and Engineers Directory for use by those seeking professional assistance on environmental issues. N/A Not applicable N/R No response E-6-6 ------- PROGRAM 1999 SBTCP DOCUMENTS Nevada • Ombudsman brochure - multimedia • SBAP brochure - multimedia • TRI reporting aid for precious metals mining • NV Waste Reporter (ongoing newsletter) • Emissions inventory fact sheet (updated) • Seminar packages for "Managing Dust in the Desert" seminars - construction and mining • Seminar packages for hazardous waste and air permitting • Seminar packages for automotive waste management and reduction • Seminar packages for reducing environmental impacts in the hospitality industry - hotels, restaurants, etc. • Environmental health and safety agencies - fact sheet New Hampshire • Automotive Sector Environmental Compliance Manual (updated, distribution in early 2000) • Spray Booth Manual, which includes information on fire safety, zoning considerations, booth design and operations, and environmental regulations (began development, printing scheduled for mid 2000) New Jersey • Sector-specific packages for workshops with dry cleaners, auto retailers, auto body repair facilities, plastics facilities, and printing/graphic arts facilities • Program brochure (distributed through mailings, trade shows, workshops) New Mexico • General Construction Permits for Aggregate Rock Crushers, Asphalt Batch Plants, and Concrete Batch Plants - fact sheet • List of Bureau and Department Contacts • Comparison table for current and proposed public notification processes • Timeline comparison of current and proposed public notification processes • Contact list of government agencies • Who Should I Contact for Information on Air Quality in New Mexico? - brochure • Open Burning-Backyard Burning Questions and Answers - brochure • Regulations for Operating Automotive Paint and Body Shops (draft) - brochure New York • Choosing an Environmental Consultant: Guidance for Small Businesses - a 28-page guidebook for small businesses that need to hire an environmental professional to help them address problems at their facility • Ventilation and Vapor Barrier Systems for Perc Drycleaning Operations - a 16-page guidebook for perc dry cleaners that need to construct or install a vapor barrier and general ventilation system around their dry cleaning machinery • Accomplishments of the Small Business Assistance Program (SBAP): 1994-1998 - a brochure summarizing the efforts of the SBAP during a 5 year period • On-Site Technical Assistance for Clean Air Act Compliance - a brochure describing the SBAP's on-site technical assistance capabilities, aimed at increasing usage of this service North Carolina • Open Burning - fact sheet • FAQ web page regarding environmental issues after the hurricanes N/A Not applicable N/R No response E-6-7 ------- PROGRAM 1999 SBTCP DOCUMENTS North Dakota • Corrosion Protection for USTs - information document • Before You Renovate or Demolish-STOP - asbestos pamphlet Ohio SBO • Enviroprint Ohio printing industry manual (update) SBAP • Applicability Checklist for miscellaneous metal parts coaters subject to OH RACT rule changes • OH EPA Engineering Guide #56 - regulation applicability and permitting issues for the printing industry (Division policy document revised by SBAP) Oklahoma • Dry Cleaning Small Area Sources Fact Sheet • Dry Cleaning Large Area Sources Fact Sheet • Refrigerated Condenser Monitoring Log Sheet • Carbon Adsorber Monitoring Log Sheet • Leak Detection and Repair Fact Sheet • Perchloroethylene Consumption Log Sheet Oregon N/R Pennsylvania • Newsletter • EnviroHelp business cards • The Small Business Ombudsman - brochure • The Small Business P2 Assistance Account - brochure • P2/E2 Site Assessment - brochure • The Small Business P2 Assistance Account - grant program application • P2/E2 Site Assessment Grant Program - grant program application Puerto Rico N/R Rhode Island • Policy for the use of evaporators in electroplating and metal finishing operations • Fact sheet on evaporator policy for metal finishers • MOU for auto body shops • Fact sheet for public works garages South Carolina • Air dispersion modeling questionnaire for 112(r) • Concrete ready-mix batch fact sheet • Multimedia fact sheet for printers South Dakota • SD Environmental Permitting and Regulation Guide - one-stop guide that covers environmental issues, permitting, and regulations for all industry sectors in the state N/A Not applicable N/R No response E-6-8 ------- PROGRAM 1999 SBTCP DOCUMENTS Tennessee • 1999 CAA Overview Manual • 1999 CAA Overview - slide presentation • Energy workshop - announcement brochure • 112(r) manual revision targeting water/wastewater operations • 112(r) slide presentation revision targeting water/wastewater operations • Dry cleaner workshop - slide presentation • 112(r) public notification requirement reminder packet Texas • Small Quantity Generator Guide (multi-sector) • Storm Water Permitting Fact Sheet (multi-sector) • The Advocate Compliance/Regulatory Update (5 issues mailed bimonthly) Utah • New State Air Quality Rules for Wood Furniture Operations in Salt Lake and Davis Counties Vermont • Wood Products Compliance Guide Book • Auto Finishing Pamphlet • Metal Fabrication Compliance Guide Book (not yet complete) • Dairy Industry Compliance Guide Book (not yet complete) Virginia • Propane Gas Compliance Package • VOC & HAP Guide (under development) Virgin Islands • Self-audit Inspection Guide • Metal parts coating • Permitting compliance • Rules and regulations for small businesses • Auto Air Condition Guide • Screening checklist for auto repair shops • Recordkeeping forms for dry cleaners • Recordkeeping forms for automotive refinishers • Self-audit checklist for all industries N/A Not applicable N/R No response E-6-9 ------- PROGRAM 1999 SBTCP DOCUMENTS Washington Ecology • Pilot Environmental Audit of Selected Hospitals SWAPCA • Newsletter • Web site (BAP page and links) SCAPCA • Y2K Enforcement Policy (targeted major sources and those with computerized monitoring • Asbestos information sheet for contractors • Compliance Assistance Program recognition decals West Virginia • Perc Dry Cleaning Compliance Calendar Wisconsin • Clean Air Advisor Dry Cleaning Calendar - 3 issues, based on FL SBAP model • Air Pollution 101 - presentation • RACT and MACT - presentation materials Wyoming • Waste oil disposal - updated information packet • Wood manufacturers - updated information packet • Medical facilities - updated information packet • Environmental checklist for newspaper publishers • Environmental checklist for printers N/A Not applicable N/R No response E-6-10 ------- TABLE E-7 NOTABLE OUTREACH METHODS PROGRAM NOTABLE OUTREACH METHODS Alabama Onsite visits are the most effective means of determining compliance and determining what facilities need additional help. Alaska N/R Arizona N/R Arkansas Our statewide "fly-ins" were particularly effective in fostering trust and accountability between the Department and the aerial applicators. Our Regional Solid Waste Management District directors have provided business contacts around the state, especially for our loan program. We regularly present opportunities for SBA at trade shows and industry association meetings throughout the state. California Many district SBAPs, especially in the larger districts, routinely conduct surveys of industry to determine how the programs can be improved. One such survey was designed and implemented by the Santa Barbara County APCD. Survey results indicate where our programs can be more responsive and give us feedback that helps our efforts. South Coast Direct mailings of special notices explaining new requirements generated many phone calls requesting assistance and additional information. For example, a requirement to switch from oil-based solvents to water-based cleaners generated a lot of calls requesting information about suppliers of the water-based cleaners. Also, a courtesy call program was conducted through which any company that has allowed its permit to expire by failing to pay the annual fee despite 3 written notices was personally contacted by phone. This process allowed more than 600 companies to reactivate their permits in time to avoid becoming subject to new BACT/LAER requirements and possible penalties. Staff personally visited more than 100 city building and safety offices to inform them of a requirement to ensure that before granting occupancy permits to new businesses, the business must obtain a clearance letter verifying that they have the necessary air quality permits. This program has helped bring hundreds of new businesses into compliance with permit requirements. Colorado The SBAP program initiated a quarterly newsletter, "Compliance Advocate," in October 1999, which increases communication with small businesses in a cost effective way. One-on-one delivery of guidance documents has truly reached the customer and emphasized the need for SBO/SBAP programs. Increased the number of monthly site visits to 80 per person, thus reaching more businesses per month. Connecticut Seminars and workshops. List serves and e-mail responses Delaware On-site meetings with small business owners. District of Columbia The most effective and cost efficient methods to date have been with the inspectors. N/A Not applicable N/R No response E-7-1 ------- PROGRAM NOTABLE OUTREACH METHODS Florida Dry cleaner calendar - 1,803 distributed statewide. Improved compliance with recordkeeping requirements. Compliance improvements from 1996-1999: Location 1996 % Compliance 1999 % Compliance Broward County 20 100 Orange County 10 92 Central District 6 95 State-wide 12 83 280 people attended 4 regional "Printers Protecting the Environment" workshops. A follow-up compliance survey was generated and will be distributed in 2000. Georgia We mailed more than 700 [compliance and recordkeeping] calendars in December 1998. The SBAP started receiving requests for the 2000 calendars in November. We sponsored a series of workshops entitled, "I am from the Government and I am Here to Help" in six cities. We added two workshops after being flooded with calls requesting that we hold the workshop in their cities. We were requested by the Southern States Dry Cleaner Show to do a modified, 4-state version of our workshop at their annual dry cleaner show in 2000. The Southern Dry Cleaner Show is the largest one in the southeast. Hawaii Dry cleaning calendar - Multimedia and responsive to the needs of small businesses. Training/seminars, mailings, videos - These outreach methods were effective, because of reception and interaction gained with specific businesses. Idaho Outreach methods include technical assistance provided over the telephone, through e-mail, conducting on-site visits, and mailing publications Illinois We have had particular success in timing our assistance with the enforcement process. In the CFFP and AER projects, we were able to measure those that came in as a result of our efforts before enforcement began. In the CFFP project, we were able to remove 800-900 businesses from the non-compliant list (out of 2,000). AER initiative was able to remove one-third of those bound for enforcement (134 of 372). Both initiatives were very cost effective for the program. The SBAP worked cooperatively with the IL Emergency Management Agency, the IL EPA, and the Waste Management Research Center to offer nine workshops throughout the state to inform companies of their Risk Management Program requirements. 140 companies attended the workshops. Identifying the roles of all the agencies early in the planning process proved to be very helpful in preventing duplication of efforts. N/A Not applicable N/R No response E-7-2 ------- PROGRAM NOTABLE OUTREACH METHODS Indiana Posting an increasing amount of information on the web has allowed external customers to easily access our documents and peruse information. The site received 3,691 hits in 1999. We continue to use the fax-on-demand system, making information available to small businesses that do not yet utilize the web. Meetings and workshops were held in locations convenient to various industries. Compliance assistance site visits were scheduled for anyone requesting such assistance. Metal Finishers/Electroplaters • Workshops and on-site assistance were provided to help companies complete the application forms. In addition, regularly scheduled meetings with stakeholders were held to discuss relevant needs. • IDEM's work with metal finishers and POTWs through the Strategic Goals Program (SGP) has greatly improved communication and feedback with this industry sector. We anticipate individual facility compliance will improve as facilities are made aware of the free, confidential compliance and technical assistance available to them. They also have been encouraged to participate in developing the SGP incentives to be made available to individual facilities as they make progress in achieving facility-based SGP goals. • Five workgroups that were developed through SGP have received considerable interest and participation from metal finishers. Workgroups include: RCRA issues, financial and technical assistance, POTW/pre-treatment issues, recruitment, and recognition/incentives. • An IDEM-SGP web site was developed with links to IN assistance providers and national metal finishing web sites. Multimedia Compliance Pilot • External meetings held separately with the wood furniture, foundry, and metal finishing sectors at the beginning and throughout the pilot project to introduce the objectives and key staff involved, provide status updates, and answer questions. We reiterated compliance assistance currently available from CTAP and the IN Clean Manufacturing Technology and Safe Materials Institute. We also asked for input on compliance incentives of interest to each sector based on superior performance. • Two waste determination workshops were presented at the request of the wood furniture sector, and compliance information packets were developed and distributed. This and other supplemental information also were added to CTAP's wood furniture sector website. Vehicle Maintenance • Two additional workshops were held to complete a statewide workshop series that began in 1999. Workshop evaluations were consistently positive. • IN kicked off its 5-Star Environmental Recognition Program for Vehicle Maintenance Shops Thirty-eight shops have joined the program, taking steps above and beyond their regulatory requirements to earn each successive star. N/A Not applicable N/R No response E-7-3 ------- PROGRAM NOTABLE OUTREACH METHODS Indiana (cont) HVAC-R/Plumbing • In addition to working with the HVAC-R and plumbing contractors and suppliers, the Mercury Thermostat Reduction & Recycling Program has expanded to include architects and mechanical engineers who specify thermostats in new construction and renovation projects. To date, 142 contractors, suppliers, architects, and mechanical engineers are participating in the program. Dry Cleaning • Regional compliance workshops were held again in 1999. Workshop evaluations continue to be positive, and violations found by inspectors continue to decrease. • On-site assistance was provided to those who requested a site visit. This type of assistance truly helps small business owners to understand the rules, and also helps build good working relationships between the business owners and SBAP personnel. Industry-wide • A plain English, Internet-based multimedia permit guide was developed to assist potential permit applicants and interested citizens alike. Iowa SBAP completed a series of presentations with the SBO to various local chambers of commerce, conducted radio interviews, and provided information for newspaper articles and paid advertisements. Following are a few examples of how clients are referred to the SBAP: state DNR and EPA (infrequently) inspectors, trade associations and business groups, client referrals, SBO referrals, and referrals from other IWRC programs. N/A Not applicable N/R No response E-7-4 ------- PROGRAM NOTABLE OUTREACH METHODS Kansas The Kansas Department of Health and Environment provides an annual environmental conference. In September 1999, almost 300 people attended the conference, held in Wichita. The conference is attended by businesses, industries, community leaders, consultants, attorneys, engineers, government, and university staff. Information provided included: regulatory updates, pollution prevention, financial assistance programs, environmental management systems, new technologies (including alternative energy sources), SBREFA, and several other topics of interest to attendees. One feature of the conference is the Pollution Prevention Awards presentation. Awards are given to those businesses, industries, communities, or individuals who have provided a significant contribution to the prevention of pollution. Also offered this year were five seminars located across the state for people considering starting or expanding a business. The seminars were provided by the Small Business Assistance Group, an organization comprised of state and federal staff who offer assistance to small businesses. The seminars were presented in conjunction with area Small Business Development Centers, which coordinated locations and registrations. Traditional workshops continue to be an important outreach tool as are site visits as are site visits and the telephone hotline. These methods provide excellent opportunities to answer specific, direct questions and to identify previously unrecognized environmental concerns. There is a trend toward forming local safety and environmental networks. SBEAP is providing information at local meetings, as many participants cannot attend the state meetings. Our SBEAP web page continues to be an effective way to distribute publications and information. The newsletter generates many calls to the technical assistance program. One of the publications we developed and distributed this year was the Dry Cleaner's Compliance Calendar. Modeled after Florida's calendar, we also have included the multimedia regulations to which Kansas dry cleaners are subject. In addition to the NESHAP requirements, perc cleaners must comply with hazardous waste rules, and both perc and petroleum cleaners must comply with secondary containment and other prevention measures instituted by the Bureau of Environmental Remediation. Kentucky Notification letter of new regulations sent by the regulatory agency containing information on the SBAP. Contact with industry-specific assistance groups (e.g., wood manufacturing organizations). Direct contact with new businesses featured in trade and business publications. Periodic column written by the AQRSB that is sent to 11 state newsletters with total circulation of 45,600 per mailing. Jefferson Cty N/R Louisiana Mailed flyers to 100,000 businesses through the State Department of Revenue. Manned booth at conference with 1,500 attendees. Hosted hazardous waste seminar with 28 attendees. Put quarterly newsletter on the Internet. Distributed 650 compliance calendars to dry cleaners. SBAP engineers attended 30 meetings, conferences, workshops, and seminars with 20,486 attendees. SBAP engineers participate in high school and college activities. Designated the first pollution prevention award to Gulf Wire Company, which was presented by the Speaker of the House of Representatives at the state capital in May. N/A Not applicable N/R No response E-7-5 ------- PROGRAM NOTABLE OUTREACH METHODS Maine For 112(r) outreach, mailed EPA guidance documents, promoted training seminars through direct mailing of brochures to interested parties, used trade associations and business groups to promote seminars, and used a consultant to conduct seminars This resulted in a high turnout for the seminars and favorable evaluations. Maryland N/R Massachusetts Helpful approaches included solvent VOC tracking software; autobody, dry cleaning, and printing outreach; and DPW outreach Schools continued to seek help, driven by the prospect of enforcement. Michigan SBO The primary methods of outreach are via the Ml Economic Development Corporation's (MEDC's) web page, which directs businesses to the SBO and SBAP staff at the Ml Department of Environmental Quality. Additional customers are generated by referrals from the MEDC's Account Managers. They call on companies and redirect their requests for environmental assistance to the SBO's office. SBAP The SBAP continues to handle a large volume of customers through its technical assistance hotline and statewide workshops. Minnesota Created an Environmental Guide for Small Businesses in Minnesota Quarterly SBAP newsletter Above ground storage tank workshops - 35 businesses reached; workshops continuing in 2000. Coordinated or wrote environmental articles for three auto body and mechanical repair journals - reached 11,400 businesses six to twelve times a year. Created a site visit reminder post card, which is mailed to the businesses a few days prior to a site visit - businesses are reminded to have records, etc. ready, which has improved the efficiency of the site visit. Mississippi Workshops were effective. We also did outreach through Chambers of Commerce throughout the state, which worked well. Missouri Direct mailings seem to be the most effective method of contact. Attendance at workshops is always much greater when direct mailings are done. On-site visits seem to be effective in helping facilities achieve compliance. Involvement of associations is very important to reach the maximum number of facilities within industry sectors. Montana We began doing newsletters targeted to an individual sector in 1999. They have been VERY well received by the targeted audience. We received several letters of appreciation and many phone calls and emails. The goal of the newsletters was to increase the awareness and acceptance of the SBO and DEQ among potential small business clients. They definitely got clients to call in and ask questions, and the most frequent comment was, "I want to do the right thing, but it is just so hard to figure out what that is." The newsletter tells them in a friendly, non-threatening format. This definitely reaches a larger and more receptive audience than driving around doing site visits. The SBO created and produced the newsletter with input from various bureaus in the DEQ and from materials obtained on the Internet. Our goal is do one newsletter per month. The average audience is 200 businesses per issue. Nebraska Referrals for this program through those who have used the services in the past seem to be the best outreach. The quality and type of assistance are greatly appreciated by business and industry. Another effective outreach strategy is following up with the business or industry after a workshop or seminar has been provided N/A Not applicable N/R No response E-7-6 ------- PROGRAM NOTABLE OUTREACH METHODS Nevada Developing generic fact sheets and other outreach materials in cooperation with county air quality programs and sharing costs as allowable make outreach more cost effective. In some instances, the SBAP had the resources to develop outreach materials and the county agencies had funds for mailing. New Hampshire Industry sector-specific compliance manuals seem to be the most effective outreach method, followed by on-site visits. Compliance manuals that also address other health and safety issues seem to be the most appreciated. New Jersey Cooperative mailings with various trade associations or having the trade association do the actual mailing publicizing regulatory assistance workshops. New Mexico Open burning brochure has met with great enthusiasm and is still in great demand. Face to face meetings concerning air quality updates and goings-on have met with approval from industry and interested parties. New York Postcard mailings continue to be an effective way for the program to disseminate information to businesses regarding important regulatory changes or deadlines. The SBEO developed postcards with simple, single messages of key information. Postcards are less expensive than letters to mail, and the simple messages catch the attention of business owners. Once the business owner contacts the SBEO, they are given the full spectrum of assistance, beyond the one issue described in the postcard that prompted the phone call. After initial compliance assistance is given, many callers are then referred to the SBAP for technical assistance. In conjunction with the postcards, the program developed advertisements with the same simple, single message, and included the SBEO logo and toll free hotline number. The ads were placed in trade magazines and membership newsletters. The advertisements served both to reinforce the message to business owners who had already seen the message once in the mail, and also to reach industry consultants, vendors, equipment manufacturers, etc., who may have been missed in the mailing. North Carolina We were able to help all 3,000 or so small and synthetic minor facilities and 450 dry cleaners this year by working with Air Quality on redesigning emission inventory forms to make them easier to fill out and requesting less information. Our work in redesigning inventory forms took place this year, although inventory data reporting and extensive small business assistance will occur in 2000. North Dakota Informational mailings have been the most used outreach method. Because there are so many sources potentially affected by the rules, individual contact is not practical. Talks to trade groups also have been effective. Ohio The SBAP continues to maintain a good working relationship with the inspectors and permit writers located at 12 field offices We visit them so they know us and the SBAP mission. As a result, 70% of the companies requesting site visits are referred to us by district field staff. On several occasions, these positive relationships have allowed the SBAP to interact directly with the field inspector on the company's behalf to resolve violations (mostly paperwork) found during an inspection. The SBO continues to focus efforts on general outreach to the small business community. For example, we were able to generate articles in 41 publications with a combined circulation of 1,172,944. In addition, we have continued aggressive outreach to the state legislature, holding 149 meetings with legislators or their staff members. N/A Not applicable N/R No response E-7-7 ------- PROGRAM NOTABLE OUTREACH METHODS Oklahoma Our outreach for the dry cleaners was very effective. We had five workshops state-wide and received notification reports from approximately 450 of the 600 dry cleaners in OK. Over 100 of them were subject to state permitting requirements and thus registered for a general permit that we developed as part of this outreach We worked in conjunction with the OK Small Business Development Centers, which helped this project to reach more businesses and achieve greater success. Oregon Technical assistance (both air quality and hazardous waste) visits were made to every dry cleaner in the state (approximately 400). This was an excellent way to get information to the dry cleaners, but it was very labor intensive. Improvements in compliance have not yet been tabulated. Pennsylvania N/R Puerto Rico N/R Rhode Island On-site assistance and workshop for autobody shops South Carolina In an effort to maximize the compliance among small propane dealers subject to the Risk Management Plan, the state Propane Board was included in outreach efforts This included free air dispersion modeling for facilities and presentations made at industry meetings to help in the completion of the required materials. South Dakota We developed an Environmental Permitting Guide that covers all environmental media in which the department works. The guide includes a list of industries and references the environmental programs that may apply to each. The guide also provides a description of each program, permitting requirements, permit flow charts, and contact information. The guide also has been placed on our Internet site and has links to each program area. This has been a great outreach product for us. Tennessee CAA overview workshops were repeated for the fifth year, and attendance remained good. Over 200 businesses attended the workshops. Dry cleaner superfund regulation compliance workshops were well attended, and follow-up phone calls indicated the workshops helped attendees. Regulatory compliance notifications to affected industry resulted in numerous phone calls for information and assistance. On-site, one-on-one assistance to small employers was well received. N/A Not applicable N/R No response E-7-8 ------- PROGRAM NOTABLE OUTREACH METHODS Texas Site visit program - 226 site visits were conducted in 1999 for 171 businesses. (This total includes follow-up visits.) Workshops - 57 workshops were conducted in 1999, with a total attendance of 1,784. Data on compliance improvements are only available for auto body and auto repair. Compliance improvements for air issues were 39.4% and 21%, respectively. For waste issues, the compliance increase for auto repair was 19.6%; for auto body, the compliance change could not be calculated due to insufficient number of surveys returned. Regulatory notifications - The SBLGA mailed two notifications, one to 1,249 dairies, and one to 1,596 metal finishers. Hotline - 3,306 calls received in 1999. Average compliance increase for air issues for all industries was 31.6%, and 32.2% for waste issues. "FYI" publications - Distributed 3 environmental articles to 665 newspapers statewide. Press releases - Announcements of regional staff placement were mailed to 800 statewide newspapers. 20 compliance assistance staff were placed in 16 field offices Regional staff participated in local COGs, chambers of commerce, and local government committees. Compliance Commitment Partnership - Businesses that agree to implement compliance and pollution prevention suggestions made by contractor during site visits and are accepted into the program receive a one year reprieve from routine inspections. Eleven applications have been approved to date. Section slide shows and display boards were developed for use at presentations. Site visit marketing program - Approximately 29,000 site visit flyers were mailed to businesses in four regions of the state, and approximately 6,000 flyers were included in mailings of annual waste summary report forms to small quantity generators. Metal finisher and surface coating workshops - SBLGA staff made presentations at statewide workshops in partnership with local governments and trade organizations. 115 people attended the surface coating workshops, and 105 people attended the metal finisher workshops. Utah The DEQ SBTCP is a member of the UT Business Resource Network (UBRN). As such, we attend various business-oriented events, and this has been a successful, cost-effective method of distributing our information. Vermont Sector-specific trainings are always well attended N/A Not applicable N/R No response E-7-9 ------- PROGRAM NOTABLE OUTREACH METHODS Virginia Once again, we feel that the continuing development and use of our SBAP web site (www deq state va.us/osba/smallbiz html) is proving successful in providing compliance and pollution prevention information. Our monthly "hit" average is increasing - from 300 in 1998 to 380 in 1999. Also, we feel that direct compliance assistance outreach continues to be the single most effective means of compliance assistance delivery. Use of trade groups and other partners in outreach efforts also is very effective. Through a partnership with the VA Propane Gas Association, we were able to deliver 112(r) requirements and hands-on training for the completion of Risk Management Plans to propane distributors and some of their customers. We used a series of 5 workshops around the state, which reached 86 vendors. Our hands-on classroom Internet training and the Internet Training Guide (copy available online) for small businesses was very successful. Utilizing computer labs around the state, we held 11, 4-hour interactive sessions for small businesses to teach them basic skills in using an Internet browser and the web to find regulatory compliance information. Over 1,000 guides were distributed and training delivered to approximately 100 businesses. A regional partnership was created with EPA Region III and other Region III state programs to develop a federal/state guide to VOCs and HAPs. The draft guide highlights federal requirements and include a separate section for each state's requirements. Virgin Islands Mailings and correspondence total was 30 Brochures and manual information packets were 50, total seminars was 0, and permit and compliance assistance was 30 Washington OAPCA Sent out almost 450 questionnaires by mail to let businesses know who we were and to get information from them on what their businesses did. Because of the quality of data with which we were working, we found that some businesses did only upholstery or furniture sales, some were closed or could not be reached with the information we had, and some had received a business license but never started the business. Of the businesses we attempted to contact, we found 26 businesses that needed to be registered (14 of which also required NSR). 144 businesses currently are being tracked by OAPCA as non-registered sources (meaning they do some sort of coating, but are too small to register, or they currently do not spray coat). Most of the businesses were just not aware that we existed or that they needed to contact us (they were not notified when they got their business license). The agency also spent considerable time educating owners of spray coating operations on state and local regulations. The result was improved compliance. NWAPA Hotline is very effective. Weekly ad space in construction reporter is an excellent way to contact businesses (for example, on outdoor burning and asbestos-related requirements). SCAPCA Hired a photographer to take pictures of compliant stacks. These were used in information sheets and on a display so that facilities would have visual examples and descriptions to follow when modifying their exhaust stacks. SWAPCA Newsletter Paint/coating tracking and reporting spreadsheet N/A Not applicable N/R No response E-7-10 ------- PROGRAM NOTABLE OUTREACH METHODS West Virginia Mass mailing to POTWs and drinking water suppliers (that may store chlorine in amounts over 2,500 pounds) regarding the provisions of Section 112(r) of the CAA. This allowed the SBAP to inform these small governmental entities of the potential need for a Risk Management Plan (RMP) By undertaking this project in conjunction with Marshall University's Environmental Management Incubator, the SBAP was able to assist in getting vital information to the regulated public for little or no cost to the WV Office of Air Quality. EPA publication #550-F98-007 was included in this mailing. A follow-up is planned for 2000 to determine the effectiveness of this information outreach. Many POTWs likely made plans to store less than the threshold amount as a result of being informed of the regulatory requirements, which allowed them to come into compliance without filing RMPs. Wisconsin Involved in the Federation of Environmental Technologists (FET), the state-s environmental trade association Participated in their annual conference with an SBAP display and presentation. Attended air-related meetings sponsored by WDNR (Clean Air Task Force) Used Marketplace database for industry-specific mailings. Wyoming The Department, through its Office of Outreach (SBO, SBAP, P2 Coordinator, and Emergency Response Coordinator), publishes a newsletter three times a year, which provides multimedia compliance information to selected businesses and government agencies as well as points of contact for additional information on a full range of environmental topics. Each issue of the newsletter is mailed/distributed to about 6,000 entities in the state and consistently generates return calls. The staff from the Office of Outreach regularly travels throughout the state doing one-on-one site visits (over 500 in 1999) with small businesses in targeted business categories Our handout literature, business sector check sheets, and newsletter articles open doors to businesses that previously have been apprehensive talking to DEQ regulatory personnel. These one-on-one contacts routinely provide new opportunities for compliance assistance and P2 initiatives. N/A Not applicable N/R No response E-7-11 ------- TABLE E-8 SBTCP WEB PAGES In the first table, web page addresses, usage statistics, and comments/feedback from users are listed. In the second table, various types of information accessible through each program's web site are shown. Please note that many web site addresses have changed from 1998. Proaram Web Paae Address Usaae Durina ReDort Period Comments Reauested? Alabama www.adem.state.aLus 50.000+ N/R Alaska www.state.ak. us/local/akpages/env.conserv/dawq/a am/mainair.htm Unknown Yes, but too early to determine. Comment section put into place 1/1/00. Arizona www.adea.state.az.us N/R N/R Arkansas www.adeq.state.ar.us N/A Feedback goes to our webmaster. Until recently, we had limited capabilities on our web site, but we anticipate integrating customer feedback in the near future. California www.arb.ca.gov 4 million hits 1.1 trillion bytes transferred 89.3% search enaine hit rate Yes, informally. We provide both an e-mail and telephone -helpline* for stakeholders to provide input and to ask for assistance. Additionally, we are developing a formal survey to obtain feedback from web site users. South Coast www.aamd.aov N/A Excellent source of information. Colorado www.cdphe.state.co.us/ic/sbomain1.html www.cdphe.state.co.us/ap/rcs_main.html 4/99-12/99 SBO-1,328 SBAP-654 Not requested. Connecticut httD://deD.state.ct.us/air2/smallbus.htm N/A N/R Delaware www.dnrec.state.de.us N/R N/R District of Columbia www.dchealth.com N/A N/A Florida www.dep.state.fl.us/air/outreach/sbap N/A An e-mail link for comments or questions is available. Five states have downloaded the Drv Cleaners Compliance Calendar for use in their states. N/A Not applicable N/R No response E-8-1 ------- Proaram Web Paae Address Usaae Durina ReDort Period Comments Reauested? Georgia www.gasmallbiz.org N/A When we received our new site address, we requested feedback from EPD personnel. Some of the associates have provided very reliable and encouraging comments. The most common ones are that the information is easv to read and easv to access. Hawaii www.hawaii.aov/health/eh/cao N/R N/R Idaho www2.state, id. us/deq N/A Opportunity for feedback was not available in 1999, but will be available 1/24/00. Illinois www.epa.state.il.us www.commerce.state.il.us 9,229 N/A Indiana www.state.in.us/idem/ctap 3,691 Yes, but we have received no comments. We are developing a survey form for use on our web site. Iowa www.state.ia.us/sbro 47,000 SBO - no. SBAP - Yes, IWRC web site recorded an average of 3,900 user sessions per month. Average time spent per user is 10 minutes, 6% of users are from outside the US. Kansas www.kdhe.state.ks.us 11.106 We aet a varietv of auestions. but most often, thev concern reaulations. Kentucky www.state.ky. us/agencies/nrepc/dep/smbizair http://gatton.gws.uky.edu/KentuckyBusiness/ kbeaD/kbeaD.htm 653 There is a comments or suggestions option at the bottom of the KBEAP site; no comments have been received. Jefferson Ctv www.aDcd.ora N/R N/R Louisiana www. dea. state. la. us/assista nce/sba D/i ndex. htm 14.000 N/R Maine www.state.me.us/deD N/A We are not solicitina feedback at this time on the homeDaae. Maryland www.mde.state.md.us N/A Comments not reauested. Massachusetts www.maanet.state.ma. us/ota N/A No sianificant comments received. Michigan www. deq.state, mi. us/ead/eosect/caap SBAP-2,598 SBO - Yes, but the system is relatively new, so there are very few SBO- specific comments to date. SBAP - No. feedback is not actively solicited. Minnesota www.Dca.state.mn.us/Droarams/sbaD D.html 4.065 N/R Mississippi www. dea. state, ms. us N/A N/A Missouri www. dnr. state, mo. us/dea/taD/hometaD. htm -4.800 N/R N/A Not applicable N/R No response E-8-2 ------- Proaram Web Paae Address Usaae Durina ReDort Period Comments Reauested? Montana www dea state mt us N/R N/R Nebraska www dea state ne us N/R N/R Nevada www.state.nv.us/ndeD/sba/sba01.htm N/A No comments received. New Hampshire pending N/R N/R New Jersey www.state.nj.us/commerce/caasbo.htm www.state.nLus/deD/oDDDc/sbaahtm SBO-939 SBAO-1.970 N/R New Mexico www.nmenv.state.nm.us N/A We have established a web focus group to assist in feedback and suggestions for improvement on our web site. The most common suggestions received are (1) need more information, and (2) need better oraanization. New York www.empire.state.ny.us www.nysefc.org SBAP-1,768 Consultant guide downloads-53 Newsletter downloads-207 SBEO- 3,920 User sessions- 463 (started 9/1/99) Visitors to the SBAP web site can submit questions and requests for further information. Numerous requests are received monthly. North Carolina www.envhelp.org/sb -6,000 (accessed throuah P2) N/A North Dakota www.health.state.nd.us Unknown except for asbestos @ 1.000 Asks for comments. Ohio www.state.oh.us/carc/ www. epa.state, oh. us/dapc/sba/sbaintro SBAP -2,350 SBAP - Web page contains an on-line feedback survey on web site usefulness. However, we have not received any responses. In 1999, more companies submitted questions via e-mail and learned about the SBAP throuah the Internet than in 1998. The exact number is not known. Oklahoma www. dea.state, ok. us N/A We do ask for comments, but have not received anv thus far. Oreaon www.dea.state.or.us N/R N/R N/A Not applicable N/R No response E-8-3 ------- Proaram Web Paae Address Usaae Durina ReDort Period Comments Reauested? Pennsylvania www deD state Da us 14.200 N/R Puerto Rico None N/A N/R Rhode Island www state, ri. us/dem N/R We do ask for feedback, but SBAP-SDecific data are not available. South Carolina www.state.se. us/eac/admin/html/sbaD. html 700 Feedback is reauested. but no comments have been received. South Dakota www.state.sd.us 524,412 (for entire dept. Internet site) Yes, requests for permitting information and database information requests on point sources and monitoring data. Tennessee www.state.tn.us/environment 1.119 Feedback not reauested. Texas www.tnrcc.state.tx.us/exec/small_business www.tnrcc.state.tx.us/exec/sbea 281 (SBLGA site) Technical questions about compliance issues for various industries, available publications, how to participate in the EnviroMentor program, dates/locations of workshoDS. Utah www.deq.state.ut.us/eqoas/bus_home.htm www.dea.state.ut.us/eaair/Dermits/sbaD3.htm N/A Do not ask for feedback. Vermont www.anr.state.vt.us/dec/ead/eadhome/sbaD.htm N/R Will ao online in 2000. Virginia www.deq.state.va.us/osba/smallbiz.html 4,562 (26% increase over 1998) Yes, but we still have not received any substantive comments. Virain Islands N/R N/R N/R Washington www.wa.gov/ecology NWAPA-1,000 SWAPCA- 6.293 SWAPCA - Comments are solicited by e-mail (comments@swapca.org). SCAPCA - Yes, but not much feedback. Occasionally, someone requests electronic form submittal. West Virginia www. dep.state, wv.us/oaq Files transferred: OAQ-125,359 SBAP-733 Do not ask for feedback. Wisconsin www.commerce.state.wi.us N/A Wl SBAP has a very small presence on the W Department of Commerce's web page (agency in which our program is housed). Currently, none of our documents is on the web. We plan to improve this area tremendously by the end of 2000. Hits cannot be tracked, as our site is a very small part of a large (and ineffective) aaencv web Daae. N/A Not applicable N/R No response E-8-4 ------- Proaram Web Paae Address Usaae Durina ReDort Period Comments Reauested? Wyoming http://deq state wy us -1,700 No formal feedback mechanism is in place at this time. However, we do get comments from individuals who access the site. Most ask for additional information or points of contact. A small number ask for assistance in downloading documents or finding related links. N/A Not applicable N/R No response E-8-5 ------- INFORMATION AVAILABLE ON SBTCP WEB PAGES INFORMATION AVAILABL E Proaram Description Contact Listinas Reaulations Permit Info Permit Forms Emissions Inventory Policies Guidance Documents/ Fact Sheets P2 Info Multimedi a List of Publication s CAP Info Calendar of Events Links Other* AL x x x x x x X AK x X X X X X x X x x X X AZ X X X x x X X X X AR X X X X X X X X X x X CA X X X X X X X X X X X X X S. Cst. X X X X X X X X X X X X X CO x x X X X X X X X X X CT x X X X X X X X X X X DE X X X X X X X X DC N/A FL X X GA x X X X X X X X X X X HI X X X X X X X X X X X X X X ID X X X X X X X X X X X IL X X X X X X X X X X IN X X X X X X X X X X X X X IA X X X X X X X X X KS X X X X X X X X X KY X X X X Jeff. Ctv X X X X X X X LA X ME X X X X MD X X X X X X X X N/A Not applicable N/R No response E-8-6 ------- INFORMATION AVAILABL E Proaram Description Contact Listinas Reaulations Permit Info Permit Forms Emissions Inventory Policies Guidance Documents/ Fact Sheets P2 Info Multimedi a List of Publication s CAP Info Calendar of Events Links Other* MA x x x x x X X x x x X X Ml x X X x X x X MN X X X MS X X X MO x X MT X X X X X X X X X X X X X X NE X X X X X X NV X X X X X X X X X X X X NH X X X X X X X X X X X X X X NJ X X X X NM X X X X X X X X X X X NY X X X X X X X X NC X X X X X X X X X X X X ND X X X X X X X X X X X OH X X X X OK X X X X X X X X X X X OR X X X X X X X X X X X X X X PA X X PR N/A Rl X X X X X X X SC X X X SD X X X TN X X X X X X X X TX UT X X X X X X X X VT X X X X X X N/A Not applicable N/R No response E-8-7 ------- INFORMATION AVAILABL E Proaram Description Contact Listinas Reaulations Permit Info Permit Forms Emissions Inventory Policies Guidance Documents/ Fact Sheets P2 Info Multimedi a List of Publication s CAP Info Calendar of Events Links Other* VA VI x x WA x X x x x x x x x x x x x WV X X X x x x X x x x x X Wl X X X x X X X X X X X X WY X 'Notes & Other S. Coast Newsletter, notifications of rule workshops, compliance assistance information, training class schedules, clean air technologies. Jeff. Cty. Daily air monitoring data. MA Case studies. MN Environmental Improvement Loan Program. NC FAQ regarding environmental issues after the hurricanes. OH Mailbox for questions. PA Energy efficiency, financial assistance, environmental accounting, strategic environmental management, Y2K. VT Email. N/A Not applicable N/R No response E-8-8 ------- TABLE E-9 CLEAN AIR ACT AND NON-AIR/MULTIMEDIA ASSISTANCE REQUESTS BY TYPE OF ASSISTANCE REQUESTED CAA = Clean Air Act Requests M = Non-air/Multimedia Requests Compliance/ Regulatory Information Monitoring Recordkeeping Financial/ Funding Information Permitting General CAA Information Add to Mailing List P2 Assistance Other Total Requests State CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M AL 26 488 1 7 3 3 12 240 15 5 25 62 763 AK 6 3 10 0 5 1 4 0 0 29 AZ 15 215 18 3 33 9 82 18 216 30 40 311 85 905 AR 53 72 6 89 25 17 10 3 24 1 190 98 392 CA 1188 595 21 868 61 300 800 3833 South Coast 1188 595 21 868 61 300 800 3535 CO 521 71 21 0 74 13 8 2 342 19 90 0 0 0 48 0 16 0 1120 105 CT Not tracked DE 5 20 10 30 55 10 DC 20 12 22 8 2 64 FL 37 25 4 2 18 11 6 3 33 22 18 11 0 0 23 14 53 39 192 127 GA 175 67 158 12 12 56 224 10 7 642 79 HI 67 8 8 0 4 0 0 0 8 0 40 3 4 0 5 0 0 0 136 11 ID* 28 13 10 38 13 E-9-1 ------- Compliance/ Regulatory Information Monitoring Recordkeeping Financial/ Funding Information Permitting General CAA Information Add to Mailing List P2 Assistance Other Total Requests State CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M IL 190 171 25 1 17 1 16 19 5 40 4 11 32 19 369 182 IN* N/A IA 60 100 10 20 10 1100 400* 1200 500 KS 50 385 55 55 68 77 2 1 81 227 14 1 100 30 136 27 48 327 1030 KY 200 125 0 0 60 10 20 20 100 40 50 0 0 0 25 15 16 8 471 218 Jeff Cty. N/R LA 1091 0 0 0 0 0 107 0 106 0 0 0 170 0 11 11 0 0 1485 11 ME 27 109 27 109 MD 10 10 2 30 30 4 50 50 90 96 MA 100 200 200 400 300 600 Ml* 502 N/A 0 N/A 0 N/A 0 N/A 197 N/A 0 50 0 N/A 0 N/A 346 95 1045 145 MN 305 184 33 3 63 5 61 51 381 59 39 26 26 2 21 15 21 34 950 379 MS 12 32 15 15 15 220 100 300 10 10 5 602 132 MO 416 930 0 4 231 38 1 22 353 217 196 0 0 0 0 95 174 2942 1371 4248 MT 45 8 0 0 5 2 0 30 0 0 2 0 0 0 0 1 40 36 92 77 NE N/R NV 506 754 30 5 150 600 691 1354 NH X X X X X X X X X X X X NJ 145 190 2 12 19 7 5 4 41 23 27 35 4 14 6 24 170 312 419 621 NM 35 8 5 5 53 E-9-2 ------- Compliance/ Regulatory Information Monitoring Recordkeeping Financial/ Funding Information Permitting General CAA Information Add to Mailing List P2 Assistance Other Total Requests State CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M NY 1088 5 80 357 361 63 1891 63 NC X X X X X X X X -90% 10% ND X X X X X X X X X 100 400 OH N/R OK 195 99 2 1 361 1 4 564 99 OR 102 2 1 1 6 19 11 42 182 2 PA 130 128 1 6 195 199 2 7 1 100 22 41 359 473 PR N/A Rl N/R SC 50 50 100 50 50 50 100 250 SD N/R TN 161 69 16 7 17 7 65 27 32 24 27 32 14 14 323 139 TX 1236 780 1 41 118 99 714 1454 1535 UT 8 31 3 13 88 13 3 68 6 170 63 VT 21 321 1 5 1 15 3 6 25 10 35 1 1 40 405 VA 102 21 2 7 9 26 2 56 12 5 8 173 33 371 85 VI 8 10 5 75 90 300 3 491 WA 1685 26 735 5 6 2457 WV 44 3 2 36 3 2 85 5 Wl 136 4 24 72 20 55 14 214 539 E-9-3 ------- Compliance/ Regulatory Information Monitoring Recordkeeping Financial/ Funding Information Permitting General CAA Information Add to Mailing List P2 Assistance Other Total Requests State CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M CAA M WY 145 190 2 12 19 7 5 4 41 23 27 35 4 14 6 24 170 312 419 621 Total 10914 5742 779 119 844 196 450 641 5117 1233 1593 414 620 168 987 1573 3986 5808 25391 16197 Grand Total" 16656 898 1040 1091 6350 2007 788 2560 9794 41688 Notes: The sum of the grand total row does not equal the sum of the total requests column. Some programs indicated they provided assistance in a particular area but did not provide data. However, they may have provided an actual -total requests* figure. ID Limited information was available to answer this question. The data contained in this report is for the period 1/1/99 - 5/28/99. IN SBAP does not track calls in this format. Rather, we track calls by industry sector, as reflected in data submitted elsewhere in the reporting form. IN currently is in the process of developing a tracking database that will better allow us to track calls by industry sector and by CAA/multimedia request. IA •Other* calls were to SBAP; remainder indicated were to SBO. Ml The multimedia and other request categories reflect customer assistance provided by the SBO only, while totals reflect activity by both SBO and SBAP. NV Totals reflect requests received from all assistance providers (NDEP, Washoe County, Clark County, and SBDC-BEP) and may not be separated by CAA and multimedia. E-9-4 ------- TABLE E-10 MAJOR CAP ACTIVITIES State Review of documents for readabilitv and/or content ADDointment/ hirina of staff/ election of officers Review of SBO/SBAP outreach efforts Review/ comment on DroDosed/ new regulations Review/ comment on state leaislative actions Definition of CAP responsibilities Attendance bv CAP members at trainina sessions, etc. Meetina with small businesses/ ass&d (toons Other" AL N/R AK X X X X AZ N/A AR X CA N/A South Coast X X X X X X CO X X X X X X CT X X DE X X X DC N/A FL X X X X GA X X X X X X HI X X X X X X X X ID N/A IL X X X X IN X X X X IA N/R KS X X X KY X X X X Jeff. Cty N/R E-10-1 ------- State Review of documents for readabilitv and/or content ADDointment/ hirina of staff/ election of officers Review of SBO/SBAP outreach efforts Review/ comment on DroDosed/ new regulations Review/ comment on state leaislative actions Definition of CAP responsibilities Attendance bv CAP members at trainina sessions, etc. Meetina with small businesses/ ass&d (toons Other" LA N/R ME X X X X MD N/R MA N/A Ml X X X X X X MN X X X X X X X X MS X X X MO N/R MT X X X X X X NE X X X X NV X X X X X NH X X X X X NJ N/R NM N/R NY N/R NC N/A ND X X X X X X OH X OK X X X X OR X X X X X PA X PR X X E-10-2 ------- State Review of documents for readability and/or content ADDointment/ hirina of staff/ election of officers Review of SBO/SBAP outreach efforts Review/ comment on DroDosed/ new regulations Review/ comment on state leaislative actions Definition of CAP responsibilities Attendance bv CAP members at trainina sessions, etc. Meetina with small businesses/ ass&d Eteons Other" Rl X X X X X X X X SC X X X X X X SD* X X X X X X X X TN N/A TX X X X X UT X X X X X X VT X X X VA X X X VI N/A WA X X X WV X Wl X WY X X X X "Notes and Other: S. Coast Participate in recordkeeping simplification and permit streamlining activities. KY Award program and orientation. SD CAP did not meet during reporting period. TX Writing letters to provide advice to TNRCC and EPA. Wl Regional CAP conference. E-10-3 ------- TABLE E-11 FINANCIAL ASSISTANCE PROGRAMS TO HELP SMALL BUSINESSES COMPLY WITH CAA REQUIREMENTS PROGRAM DATE AVAILABLE NAME OF GRANT/LOAN FUNDING LEVEL Alabama None Alaska None Arizona None Arkansas 1998 Small Business Revolvina Loan Fund $1 million California 1972 CA Pollution Control Financina Authority (loan) Proiects -$10,000 to $50,000 1995 Innovative Clean Air Technoloaies farant) $1 million/vear FY98-99 Carl Mover HDD ReDlacement Incentive Proaram farant) $19 million FY98-99 Rice Straw Demonstration Fund farant) $1 million South Coast 1994 Air Qualitv Assistance Fund floan auarantee)* $2 million Colorado None Connecticut None Delaware None District of Columbia None Florida None Georaia None Hawaii Available, but no information aiven. Idaho None Illinois None Indiana None Iowa None E-11-1 ------- PROGRAM DATE AVAILABLE NAME OF GRANT/LOAN FUNDING LEVEL Kansas None Kentucky None Jefferson Ctv N/R Louisiana None Maine None Maryland 1/00 Small Business Pollution ComDliance Loan Proaram $750,000 Massachusetts None Michiaan None Minnesota 7/97 Small Business Environmental ImDrovement Loan Proaram $750,000 MississiDDi None Missouri None Montana None Nebraska None Nevada None New HamDshire None New Jersev None New Mexico None New York 9/99 EPA Pollution Prevention Incentives for States Grant $285,000 North Carolina None North Dakota None Ohio 1/95 OH Air Qualitv DeveloDment Authority Loan market 7/95 Small Business Assistance Fund farant) $150.000/vear Oklahoma None E-11-2 ------- PROGRAM DATE AVAILABLE NAME OF GRANT/LOAN FUNDING LEVEL Oreaon None Pennsylvania 4/1/99 Pollution Prevention Assistance Account (loan) $3.5 million 7/19/99 P2/E2 Site Assessment Grants $1 million Puerto Rico None Rhode Island None South Carolina None South Dakota None Tennessee None Texas None Utah None Vermont None Virainia 2/00 Small Business Environmental ComDliance Assistance Fund (loan) $625,000 Virain Islands None Washinaton None West Virginia Mid-1998 WV Small Business Environmental Loan $550,000 ($50,000 aen.+ $500,000 UST) Wisconsin None Wvomina None *Notes: S. Coast The AQMD currently is reviewing this loan guarantee program to determine how to make the funds more accessible to businesses. Recommendations are expected in Spring 2000. E-11-3 ------- TABLE E-12 COOPERATIVE EFFORTS Descriptions of how each component of the SBTCP has developed cooperative efforts among existing personnel resources are provided in Table E-12. STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Alabama Organizationally allied with P2 Unit and Section 319 Nonpoint Source Unit to allow sharing of resources and Dersonnel. Alaska Works with the Department of Commerce to reach more small businesses. Participates in regional and national P2 roundtables. Participates in the Governor-s Council on Small Business Assistance Programs to eliminate possible duplication of efforts and to have better coordination and referrals among aaencies. Works with the AK SBDC and MEPs. Works with Air Program to ensure that efforts are not duplicated. Works with local businesses to review information that affects them. SBO/SBAP use the CAP to review fact sheets and other Departmental information. CAP members are from all parts of the state. Their names, addresses, and phone numbers have been put in different forums to allow businesses and concerned citizens to contact individual members reaardina DeDartment activities. Arizona Information referral network with Small Business Association, AZ Department of Commerce, and various small business industry trade associations. Also works with Maricopa County SBEAP and ADEQ internal program staff to help reach their taraet audience. Same as SBO. N/R Arkansas SBO has retired and has not yet been replaced. We partner with the Department of Economic Development, the Small Business Development Center, the AR Environmental Federation, the AR Manufacturer-s Association, and other trade associations on training and compliance assistance efforts. Advisory opinions are made by the panel to serve small business needs and to provide business perspective to the Department. The panel reviews information for small businesses subject to environmental regulations to assure the information is understandable to the lavDerson. California Outreach efforts are conducted in conjunction with the CA Air Pollution Control Officers Association, industry trade associations, local chambers of commerce, and other CA state agencies. Cal/EPA operates a number of permit assistance centers with the support of the 35 local air districts. These efforts include displays and presentations at trade association meetings, counter-top assistance, and business/permit services to refer customers to district contacts. Under review by Governor Davis. South Coast Outreach efforts are coordinated with other public agencies, trade associations, chambers of commerce, and local government representatives. Outreach ideas are shared with other SBAPs, the Air & Waste Management Association, and the CA Air Pollution Control Officers Association. South Coast-s Public Advisor participates with other states in activities coordinated through EPA-s SBO. South Coast staff assist at 5 Cal/EPA permit assistance centers, which promote one-stop permitting for a variety of environmental agencies. We work with city building and safety departments to ensure that businesses obtain air quality permits before being granted occupancy permits. The staff also work with fire departments and hazardous waste agencies to ensure that automotive repair shops and machine shops are using water-based cleaning solutions rather than Detroleum solvents. The local government and Small Business Advisory Group communicate with the state Air Resources Board and US EPA regarding a range of issues including BACT/LAER, socioeconomic impacts, and SBREFA. The Advisory Group also explores small business financing programs with other agencies. N/A Not applicable N/R No response E-12-1 ------- STATE OR TERRITORY RIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Colorado Partners with the various micro-loan lenders on behalf of small businesses, and continues to conduct workshops with the SBDC. Involved in a unique partnership with US EPA, US SBA, local dry cleaner association, and dry cleaner owners to develoD a multimedia comDliance auide. Works closely with the industry trade associations. Partners with the Department-s P2 group on several outreach activities. Works closely (referrals) with the Department-s APCD Enforcement Unit. Continues to meet with SBAP quarterly and participates in quarterly conference calls. Attends national CAP training with CAP members at large. Connecticut SBO and SBAP are merged, and collectively the program leverages technical staff from within the Department to provide compliance assistance. The SBO position is designated from the Office of the Commissioner to enhance the multimedia capabilities of the SBAP. Additional resources are leveraged through partnerships with trade associations, quasi-public agencies, other state agencies, public utilities, local chambers of commerce, and programs established at CT universities. The SBAP has established effective partnerships with trade associations and vendors representing the autobody industry, the metal finishing industry, and the aasoline industrv. The CAP has 10 members. Other interested individuals attend meetings regularly and serve as non-voting members. The CAP has helped to establish relationships with the small business community and to publicize the availability of the SBAP. Delaware Open exchange of information concerning industry sectors targeted for compliance assistance. Good overall workina relationshiD with reaulatorv Droarams at state and federal level. (SBO has dual role as SBAP.) N/R District of Columbia N/A Florida In Florida, SBO/SBAP functions are combined. We ha enhance assistance within the Agency. We have partn the FL Manufacturina Technoloav Centers to enhance ve partnered with our district staff and local staff to ered with the Small Business Development Centers and ocal assistance and availabilitv. CAP Chair has assisted in outreach efforts to dry cleaners and was a presenter at the 1999 National Conference. Georgia The SBAP has a gentleman-s agreement with the Hazardous Waste Program on providing multimedia technical assistance to dry cleaners. The SBAP partnered with the Small Business Development Center, the Atlanta Gas Light Company, and the South Eastern Fabricare Association on a series of workshops entitled, -I am From the Government and I Am Here to Help.* The workshop was held in six locations. N/R Hawaii Memorandum of Agreement with Environmental Management Division and Environmental Health Administration to provide multimedia coverage. Small Business Development Center and Environmental Permitting training seminar for dry cleaners. State of Hawaii laboratory analyzed dry cleaning wastewater samples to determine concentration levels. Information was used to advise dry cleaners as to regulatory impact of wastewater disDosal. Joint training with city and county of Honolulu, DOH Wastewater Branch, DOH Solid/Hazardous Waste Branch, DOH Clean Air Branch, and SBDC on environmental permits that were specific to dry cleaners. N/A Idaho Through May 1999, the SBO has worked with several other organizations, including ID SBAs, SBDCs, and the Northwest Pollution Prevention Resource Center. The SBO also finds the SBO/SBAP Annual Conference to be auite useful. The SBAP participated in monthly meetings through May 1999. Not active in 1999. N/A Not applicable N/R No response E-12-2 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Illinois N/R Work regularly with IEPA BOA with formalized procedures being developed. Work with trade associations on particular rules and provide them with newsletter of UDdates. N/R Indiana N/R SBAP maintains regular contact with IDEM offices. We borrow and share information with other state SBAPs. SBAP submits annual confidentiality reports to the CAP. SBAP generally provides CAP with quarterly updates on our initiatives, including providing the CAP with a copy of the annual SBTCP report. The CAP provides guidance on SBAP focus areas. Iowa Working with economic development officials and community leaders to advise on environmental regulations. Developing fact sheets on NESHAPs with industry concentration in IA. IAEAP uses part time and full time student assistants and interns from the University of Northern Iowa to help with client assistance and other program activities. As needed, staff from IWRC (in addition to the 5.0 FTEs for IAEAP) are used from time to time. N/R Kansas SBO organized a group of state/federal agency staff who work with businesses to facilitate better referrals and understanding of available services. SBO works extensively with regulatory bureaus and universitv technical assistance Droaram. Technical assistance program works with MAMTC, PETE, and other P2/technical assistance programs to facilitate coordination and cooperation. In addition, SBAP is working with local department programs, such as the P2 Alliance in Wichita. CAP works with SBO and SBAP through meetings and telephone contacts. Kentucky Air Quality Representative for Small Business (AQRSB) writes a column for distribution periodically and responds to requests for technical assistance. Division for Air Quality (DAQ) has designated several people to assist AQRSB in completing requests and drafting columns for state newsletters. AQRSB worked with KBEAP, DAQ, and Jefferson County to prepare an orientation manual. DAQ assisted AQRSB in developing draft Danel bv-laws. A large number of state agencies, university programs, and business groups are used for client referrals, and seminar and outreach opportunities (in particular, the KY Small Business Development Center, the Division for Air Quality, the SBO, and state economic development and agriculture agencies). Panel members assist the AQRSB and KBEAP in working with organizations they represent. Reappointed members assisted with orientation of new members. Jefferson County The SBO and SBAP are members of the Jefferson County Pollution Prevention Team (JCP2T). This is an alliance of environmental regulators and service providers in the County that has been spearheaded by the Metropolitan Sewer District. The goal is to provide free one-stop shopping for pollution prevention information and services to County business and industry. As most large firms have the resources to research and implement P2 techniques without free consultation, the JCP2T most often serves the small business communitv. N/R N/R Louisiana N/A SCORE, DEQ permit section, trade associations, SBDCs Trade associations, environmental leadership. N/A Not applicable N/R No response E-12-3 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Maine SBO works closely with SBAP and other business service providers, such as the Department of Economic and Community Development, ME Chamber and Business Alliance, ME SBDC, ME MEP, ME Metal Products Association, ME Wood Product Association, and other business groups to maximize effectiveness. The SBTAP works with the staff from the DEP-s Office of Innovation and Assistance and other bureaus to assist in some program functions. The SBTAP also works closely with the SBO and business groups named to the left. The CAP is a joint panel comprised of 18 members. Functions of SBTAP oversight were merged with an existing panel charged with overseeing the Toxics Use Reduction and Pollution Prevention programs. Maryland N/R The SBAP works with the other administrations to reach small businesses. ARMA has two engineers who provide permitting services to small businesses. The SBAP works closely with the P2 program on outreach activities. Input from other administrations is used to determine sectors to target for assistance. Two engineers in the Environmental Permits Service Center answer permitting questions from small and larae businesses. N/R Massachusetts N/R OTA works with the enforcement agencies to provide general information about trends we see in the field and to find out about enforcement Driorities. N/R Michigan The SBO works closely with the company referrals made by the staff of the Ml Economic Development Corporation who are assigned to make initial contacts with the state-s business and industry for economic development expansion and retention. Additionally, the SBO helps to promote SBAP projects through the Ml Economic Development Corporation-s publications. The SBAP developed a pattern of working closely with and seeking consultation from not only the regulatory air quality agency, but also other multimedia divisions and units of the regulatory agency, business and industry associations, SBAP counterparts in EPA Region V, as well as other state agencies when developing and implementing its outreach efforts (e.g., statewide workshops and fact sheet/auidebook develoDmentV Works closely with the state-s SBO and SBAP. Minnesota The SBO partners with the MN Technical Assistance Program and the MN Office of Environmental Assistance to promote and coordinate P2 and financial assistance activities, MN-s SBDCs to promote environmental assistance activities through the SBDC offices, the MN Ombudsman Roundtable to coordinate ombudsman services throughout the state, and with various trade associations and vendors to promote environmental and financial assistance services among their memberships and client bases. The SBAP partners with the MN Technical Assistance Program to promote P2 activities and each others programs, the SBDCs to coordinate environmental compliance service delivery (including distribution of the new Environmental Guide to Small Businesses in MN) and each others programs, MN Office of Environmental Assistance to promote P2 and each others programs, MN Emergency Response Commission to coordinate RMP and 112(r) technical assistance, and internal agency groups to represent small business concerns during agency activities includina rulemakina and Dermittina. The CAP is being reappointed. Mississippi Cooperates with regulatory programs, P2, trade associations, and Dublic oraanizations. See SBO. See SBO. N/A Not applicable N/R No response E-12-4 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Missouri The SBO attended one of our CAP meetings. The SBAP supplies technical assistance as needed to the SBO. The SBAP works closely with the CAP, supplying information as required. The SBAP works with the Department-s regulatory programs to obtain expertise in specific areas when needed. The SBAP also partners with the SBDCs and other assistance Droviders to reach MO businesses. The CAP is supported by the SBAP and is looking at ways to assist businesses by hearing their problems and making recommendations to the regulatory agencies and by giving the SBAP direction as to the best methods to assist businesses. Montana Cooperated with the MSU Extension Service P2 Program in providing P2 services to clients and developing printed materials. Partnered with SBDC to offer loans for energy conservation and pollution Drevention. In MT, the SBO and SBAP are essentially one person. We modified the FL dry cleaner calendar for MT. Using CAP literature from other programs. Nebraska SBO, SBAP, and CAP are all run by the same Derson. See SBO. See SBO. Nevada SBO utilizes BAQ and other agency files to get information on issues that the ombudsman is investigating and coordinates with enforcement staff to resolve issues. SBO interviews staff with knowledge of a facility, as well as facility personnel, to establish a complete picture of an issue to determine solutions. Ombudsman services are coordinated with the county health departments, including the air quality programs, and assistance is provided when needed. SBO interfaces with various business organizations by attending monthly meetings and networking with business professionals, including Economic Development, local government, fire departments and state fire Marshall-s office, community colleges and universities, etc. SBAP uses the expertise of NDEP staff in various environmental programs for technical information. SBAP works closely with the SBDC to provide information and technical assistance to the business community and to coordinate dissemination of outreach materials and workshops. SBAP works closely with the county air pollution control programs for hands-on education of the various sources, identification of industry needs, and outreach activities. SBAP, Washoe ana Clark County Health Districts, and the SBDC-BEP work with economic development offices to encourage businesses and to explain the requirements for new air pollution sources looking at locating to NV. NDEP Bureau of Air Quality (BAQ) provide direct assistance to businesses regarding permitting and compliance. Workshops are conducted as changes in federal and state regulations warrant. The BAQ has contracted with the SBDC-BEP for technical assistance, including seminars, outreach, and on-site consultations as requested by small businesses. The SBDC-BEP implemented a cooperative agreement with the state OSHA consultation program in 1999 and has support from the Manufacturing Assistance Partnership program. Other partnerships include chambers of commerce, development authorities, and communitv colleaes. CAP uses the information that the SBO and SBAP collect to determine needs within the business community and to identify methods to support and assist small businesses. CAP members network with representatives from their individual areas of business and bring concerns before the SBO and SBAP. Issues are identified and recommendations to the agency are made. Washoe County Air Quality Management Proaram. NV Air quality permitting and enforcement staff provide assistance for small businesses in completing permits, monitoring, and compliance. Staff work cooperatively with the SBO regarding program development and mutual outreach activities. Staff work with local business develoDment centers and often meet with DrosDective NV businesses to identify their environmental Dermittina reauirements. N/A Not applicable N/R No response E-12-5 ------- BRIEF DESCRIPTION OF COOPERATIVE EFFORTS STATE OR TERRITORY SBO SBAP CAP Clark County Air Quality Program Air Quality program staff use direct mailings to affected businesses, Internet postings, workshops, public speaking, and various outreach materials, such as brochures and information packets. Permitting and enforcement personnel assist small businesses to comply with permitting, monitoring, and operation. Assistance also is aiven for Dollution Drevention. when aDDroDriate. New Hampshire Administrative support from the Air Resources Division. Continued to expand working relationships with other local, state, regional, and national advocates for energy, environmental, legislative, and business issues. Continued to work with and expand cooperative ventures with other DES compliance assurance groups as well as outside partners. Administrative assistance from Air Resources Division. New Jersey Interagency agreement between NJ Commerce and NJDEP for administration of the SBO responsibilities through NJ Commerce. SBAP acts as staff to the CAP. SBAP coordinates with Air Permit, Air Planning, and P2 programs within DEP. Coordinates with NJ Institute of Technology's Technical Assistance Program for P2. SBAP and SBO work with numerous business and trade associations and NJ SBDCs. Interagency agreement between NJ Commerce and NJDEP for administration of the SBO responsibilities through NJ Commerce. New Mexico N/R SBAP uses the expertise and availability of other agencies, such as SBDCs, chambers of commerce, economic development, and local environmental field offices, for outreach. SBAP, along with other bureaus, developed multimedia informational material for public outreach. For example, during the NM State Fair, we and other bureaus developed and manned an informational outreach booth. A cooperative effort among SBAP and several state and local programs vielded a brochure on backvard burnina. NM Assistant Attorney General-s Office is providing legal assistance to CAP. New York SBEO routinely co-sponsors workshops and conferences with the SBAP, the DEC, and trade associations. SBEO also regularly works with the New York City Department of Environmental Protection-s Environmental Economic Development Assistance Unit to assist businesses in NYC. SBAP co-sponsors technical workshops with other technical assistance providers, including local agencies, trade groups and associations, and DEC-s Pollution Prevention Unit to leverage outreach to industry sectors and to avoid duplication of effort. In addition, SBAP uses DEC-s technical staff to review fact sheets and articles for SBAP-s technical newsletter. SBAP also invites equipment vendors and representatives from companies that develop technologies to provide in-house technical workshops for staff. The SBAP always invites DEC-s technical staff and other representatives of state agencies to these workshops so they might share the learning exDerience. None. North Carolina We work cooperatively with Division of Pollution Prevention and Division of Air Quality on a weekly basis on workshops and training programs, and to identify compliance assistance opportunities. The integration of the Customer Service Center provides stronger links to waste, water, and natural resource Droarams. N/R N/A N/A Not applicable N/R No response E-12-6 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP North Dakota The ombudsman makes referrals to the SBDCs in the state, and they reciprocate. SBAP works with trade associations, other state agencies, and other organizations to get information to affected businesses. CAP members work with trade associations they represent. Ohio SBO has always assumed it needed close working relationships with organizations already reaching small businesses in OH. This year, we worked with 20 different trade associations, ranging from the OH Cleaners Association to the OH Bankers Association. In addition, we worked with 28 of the state-s SBDCs and 24 local chambers of commerce. Finally, the SBO provided financial support to projects by the OH Auto Dealers Association, the Automotive Services Association of OH, the OH Chemical Council, the Printing Industry Association of Northern KY and OH, and the Institute for Advanced Manufacturing Sciences for programs targeted at small business. In most cases, the SBO investment was leveraged at least 3 to 1. SBAP is represented on several wortaroups within the Division of Air Pollution Control, this enables the SBAP to included in RMP mailings, non-Title V fee reports, permitting policies, and MACT outreach efforts. OEPA-s Public Interest Center has been used to run a feature article on the SBAP in the Agency newsletter and to provide graphics/layout support for SBAP fact sheets. SBAP regularly corresponds and visits 12 OEPA field offices to promote its services. SBAP regularly provides referrals to the Department of Employment Services and the Bureau of Workers Compensation programs for OSHA assistance. The SBAP provides air pollution assistance to a central OH multimedia environmental assistance office. SBAP also is a member of the OH State Environmental Network, which is a collection of business assistance Droviders. Lack of timely appointments has hindered the CAP-s development. Oklahoma Work within the agency-s regulatory divisions to represent small business issues, particularly with resDect to rulemakina and rule reform. SBAP is the lead group providing assistance to and representing the needs of small businesses in OK. SBAP works closelv with SBO and CAP. The CAP has been active in evaluating new and existing state air rules. Oregon None. The BAP partnered with the SBDCs to offer pollution prevention workshops that were not successful. An SBDC network staff member attends our CAP meetings. The BAP also has been working with the Department-s hazardous waste technical assistance program. The BAP is involved in the Pollution Prevention Outreach team, which is comprised of local reaulatorv aaencies. None. Pennsylvania SBO is able to draw upon the expertise and assistance of all of PA DEP-s regional and central office staff as well as that of the PA Environmental Assistance Network. SBAP works cooperatively with trade associations and also is a member of tne PA Environmental Assistance Network, which allows it to draw on the exDertise of all of the consortium members. PA DEP provides administrative support to the committee, and CAP meetings are held at the Department-s central office building in Harrisbura. Puerto Rico We are developing support programs with commercial oraanizations. EQB provides technical assistance staff from the Plannina Division and Air Toxic Proaram. N/R Rhode Island SBO is funded entirely from state revenues not associated with the CAA. SBO position has not been filled since June 1999 with no plans to refill this position at this time. SBAP (2 FTEs) integrated into Department-s existing Pollution Prevention Program housed in the Rl Department of Environmental Management-s Office of Technical and Customer Assistance. 0.5 FTE (University of Rl Research Associate) providing technical suDDort to SBAP. N/A N/A Not applicable N/R No response E-12-7 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP South Carolina SBO provides multimedia assistance using resources in other Agency program areas. Contacts are maintained with the outreach and educational staff members in the various program areas. The Media Relations Office of the Agency also has provided access to media sources to spread the word about the SBTCP. Program has regular access to technical staff in the Bureau of Air Quality to assist on permitting issues. Air Quality also provides computer dispersion modeling at no charge to eligible small businesses. Other program areas also provide staff members to assist with technical questions and to participate in meetings to discuss permitting issues with small businesses. SBO serves as the secretariat to the CAP. South Dakota The Secretary of the Department supervises the ombudsman. The ombudsman has direct contact with the SBAP. The individuals that work in the air program all contribute to the success of the SBAP. CAP is made up of individuals across SD. There is a good mixture of private individuals and small business owners. Tennessee SBO has access to other needed Departmental resources to assist SBAP function when deemed necessary. Reorganization of program allows access to county and municipal technical assistance agencies, a training facility, and inclusion of program information in educational material dissemination. Partnerships have been developed with the Division of Superfund, the dry cleaner associations, the Pollution Prevention Program, the state energy office, and water/wastewater ODerations. Not operating. Texas Partners with small business, trade groups, and local governmental organizations through Small Business Advisory Committees to distribute information on SBLGA-s programs, workshops, and regional staff, and to receive input on regulations and issues affecting small businesses. Assists enforcement division by calling entities that were issued default orders, stresses the importance of communicating with TNRCC, and assists with the enforcement process in general. Regional SBLGA staff partnering with local organizations to better reach and assist local entities. Assists Wastewater Permits Division by calling small businesses and local governments whose wastewater permits are expiring to remind them of the importance of reapplying on time. In conjunction with Bill J. Priest Institute-s SBDC, producing videos for metal finishers on regulatory compliance and pollution prevention. Participates in Metal Finishers Strategic Goals Program by partnering with EPA, states, local wastewater treatment programs, and industries. Assisted in developing a goals worksheet and goals attainment system. Participates with local governments in giving workshops for metal finishers and surface coaters throughout Texas. Inserted 5,900 site visit cards and Small Quantity Generator Guides into Annual Waste Summary reports mailed out by TNRCC-s Industrial and Hazardous Waste Section. Utah We are a member of the SBA award-winning UBRN, an organization of many small business assistance providers in the state, including SBDCs, Community and Economic Development, Forest Service, and a number of funding entities. This has been very effective in referrals and in educating other agencies about environmental reflations. The SBAP works with the Department-s Pollution Prevention Program. The SBAP refers companies to Water Quality and Solid/Flazardous Waste. The SBO/SBAP and CAP meet about every other month. Information is faxed and e-mailed as necessary. N/A Not applicable N/R No response E-12-8 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Vermont No SBO. The VT Environmental Assistance Partnership includes the DEC-s Environmental Assistance Division (P2, SBCAP), the VT Manufacturing Extension Center, the SBDC, and the VT Economic DeveloDment Aaencv. Works with the P2 and SBCAP programs. One member of the CAP is from the SBDC. Virginia Uses national air program contacts where appropriate. On behalf of the SBO and the CAP, the SBAP actively tries to use the contacts and credibility of the following organizations: other state SBAPs and SBOs, the VA SBDC network, the VA Manufacturing Technology Center, the VA Chamber of Commerce, the A.L. Philpott Manufacturing Extension Partnership, the VA Environmental Business Council, US EPA Region III Business Assistance Center, the VA Chamber of Commerce, the VA Manufacturers Association, and manv others. Trade groups, other CAPs. Virgin Islands We are partnering with the Department of Licensing & Consumer Affairs and with the APC Section of our Department of Planning & Natural Resources and the Government DeveloDment Bank. We are partnering with the Department of Licensing & Consumer Affairs and with the APC Section of our Department of Planning & Natural Resources and the Government DeveloDment Bank. Not yet named. Washington N/R Combined effort between Ecology and seven local air quality authorities. Cooperative efforts between various Ecoloav deDartments fe.a.. medial N/R West Virginia The SBO works closely with SBAP personnel to evaluate technical aspects of small business issues. Also, DEP personnel outside the air office are available for consultation. Resources outside the agency are consulted on speciality projects, generally at no cost or exchanged for in-kind services. The SBAP works with other air quality staff, when necessary, to evaluate permit and Title V applicability for small businesses. A significant number of clients are referred to the SBAP through agency enforcement activities. Other DEP staff, especially Pollution Prevention Services (P2) are available to help coordinate assistance to small business. The SBAP is also coordinating its efforts with other outside assistance groups, including Academic and Small Business Development Center efforts. Trade organizations and state OSHA contacts provide additional assistance. All members serve on a volunteer basis. Wisconsin SBO supervises the SBAP staff and serves on the CAP to facilitate communication. The SBAP works closely with the Wl DNR-s sector specialists on joint projects and activities. The SBAP also works with the P2 specialists in the state on trainings, workshops, grant applications (PPIS), and other activities. Members of the DNR Small Business External Advisory Committee are invited to participate in our CAP meetings, since they are a similar group with a similar mission. N/A Not applicable N/R No response E-12-9 ------- STATE OR TERRITORY BRIEF DESCRIPTION OF COOPERATIVE EFFORTS SBO SBAP CAP Wyoming Cooperation between the Outreach office and the regulatory programs of our Department has continued to develop throughout this year. There is regular interchange in dealing with queries to the Department on matters ranging from permitting to emission monitoring to locaF level educational programs and about every other subject that can be imagined on a continuing basis. The office also has been active in state, regional, and national programs including the Southwest Technical Air Forum, the Western Air Resources organization, the Clean Snowmobile Challenge 2000 design competition, and the Western Regional Air Partnership. The SBAP continued to provide technical permit assistance to the small business community and coordinate such with the Air Quality Division. The SBAP coordinated the dissemination of MWI regulations through two presentations to the WY Hospital Association and meetings with individual hospital representatives. The SBAP assisted the P2 Program in developing checklists for the newspaper and printing community plus wood manufacturing businesses and used oil generators. The SBAP, working through several trade associations, coordinated a 112(r) training session and served as site coordinator for the APDLN telecasts. Also, the SBAP assisted the office with its display booth at four conventions where compliance assistance and P2 information was given to the public. In addition, the SBAP coordinated two training sessions for the Tampa SBO/SBAP conference and coordinated its outreach activities with WESTAR states and EPA. The CAP has continued to operate with a full slate of members throughout the year. New members are approaching their duties with enthusiasm, and the team is working together to find ways to improve our compliance assistance efforts. N/A Not applicable N/R No response E-12-10 ------- TABLE E-13 SUMMARY: SBAP MECHANISMS FOR AVOIDING DUPLICATION AMONG SBTCPs Program Communication/ networkina within SBTCP& state aaencv personnel via Dhone. mailina lists, etc. Meetinas. conference calls and other contacts with SBAP/SBO personnel within EPA region Networkina throuah state/ regional air arouD meetinas such as WESTAR (Western States Air Resources) Review of EPA documents/ contact with EPA Review of documents from other Dublic. private, or universitv sources Information aatherina from electronic sources Subscribe to SBO or aovt. Ombudsman listserve Other* AL X X X X X AK X X X X X X X X AZ X X X X X AR X X X X X X CA X X X X X X South Coast X X X X X X X X CO X X X X X X X CT X X X X X X X DE X X X X X X X DC X X X X X FL X X X X X X GA X X X X X X HI X X X X X X X ID X X X X X X IL X X X X X IN X X X X X X X IA X X X X X X X KS X X X X X X X N/A Not applicable N/R No response E-13-1 ------- Program Communication/ networkina within SBTCP& state aaencv personnel via Dhone. mailina lists, etc. Meetinas. conference calls and other contacts with SBAP/SBO personnel within EPA region Networkina throuah state/ regional air arouD meetinas such as WESTAR (Western States Air Resources) Review of EPA documents/ contact with EPA Review of documents from other Dublic. private, or universitv sources Information aatherina from electronic sources Subscribe to SBO or aovt. Ombudsman listserve Other* KY X X X X X X X Jeff. Cty N/R LA X X X X X X X ME X X X X X X X MD X X X X MA X Ml X X X X X X X MN X X X X X X X X MS X X X X MO X X X X X X MT X X X X X X X NE X X X X NV X X X X X X X NH X X X X X X X NJ X X X X X X X NM X X X X X NY X X X X X NC X X X X X X X X ND X X X X X X X OH X X X X X X X N/A Not applicable N/R No response E-13-2 ------- Program Communication/ networkina within SBTCP& state aaencv personnel via Dhone. mailina lists, etc. Meetinas. conference calls and other contacts with SBAP/SBO personnel within EPA region Networkina throuah state/ regional air arouD meetinas such as WESTAR (Western States Air Resources) Review of EPA documents/ contact with EPA Review of documents from other Dublic. private, or universitv sources Information aatherina from electronic sources Subscribe to SBO or aovt. Ombudsman listserve Other* OK X X X X X X OR X X X X PA X X X X X X X PR X X X X Rl X X X X X X SC X X X X X X X SD X X X X X TN X X X X X X TX X X X X X X X UT X X X X X X X VT X X X X X VA X X X X X X X X VI X X X X WA X X X X X X WV X X X X X X Wl X X X X X X X X WY X X X X X X X N/A Not applicable N/R No response E-13-3 ------- "Other AK Works with region SBAPs and P2 programs. Participates in federal facility roundtable and state, regional, and national P2 roundtable. AR National SBAP Steering Committee conference calls. S. Coast Subscribes to P2 and printing industry listserves. KY AQRSB represents Region 4 on national steering committee. MN Attendance at national SBO/SBAP conference. NC The SBO is an active participant in the Governors Small Business Council. This includes small business, SBTDC, community colleges, and all agencies in state government that provide small business services. ND Subscribes to several other states* newsletters. UT UT Business Resource Network. VA SBO/SBAP National Steering Committee, P2 Roundtable. Wl Shared our customer tracking with other states. N/A Not applicable N/R No response E-13-4 ------- TABLE E-14 SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS OF THE PAPERWORK REDUCTION ACT Program Routine review of SBTCP information collection activities Routine review of SBTCP documents for compliance Receiving / providing information electronically Simplified / consolidated permits and/or forms Eliminating unnecessary permits bv increasing exemptions General permits for certain types of industries Other (See below) AL X X AK X X X X AZ X X X X AR X CA X X X South Coast X X X X X X CO X X X X CT X X DE N/R DC X X FL X X X X GA X X X X X HI None ID X X X X IL X X X X IN X X X X X X IA X X X X X X N/A Not applicable N/R No response E-14-1 ------- Program Routine review of SBTCP information collection activities Routine review of SBTCP documents for compliance Receiving / providing information electronically Simplified / consolidated permits and/or forms Eliminating unnecessary permits bv increasing exemptions General permits for certain types of industries Other (See below) KS X X X X X KY X X X X X X Jefferson N/R LA X X X X X X ME X MD X MA X X Ml N/A MN X X X X X X MS X X MO X X X X X X MT X X X X NE X X X X NV X X X X NH X X X X X X NJ X X X X X X NM X X X X X NY X X X NC X X X X X X N/A Not applicable N/R No response E-14-2 ------- Program Routine review of SBTCP information collection activities Routine review of SBTCP documents for compliance Receiving / providing information electronically Simplified / consolidated permits and/or forms Eliminating unnecessary permits bv increasing exemptions General permits for certain types of industries Other (See below) ND X X X X X X OH X X X OK X X X X X OR X X X X X PA X X X PR N/R Rl X X X SC X X X X X SD X X X TN X X X X X X TX X X X X X X X UT X X X X X X VT X X X X VA X X X X X VI* X WA X X X X WV X X X X Wl X X X X WY X N/A Not applicable N/R No response E-14-3 ------- "Other Actions and Notes: South Coast Members participated in Permit Streamlining and Recordkeeping Simplification efforts in 1999. AL Permit by rule for Concentrated Animal Feeding Operations. FL Distributed dry cleaner calendars for recordkeeping. KY Need for clarification in this area. TX Concise, easy to read summary documents. VA Duplex printing. VI Work being done by SBTAP coordinator; CAP not yet appointed. N/A Not applicable N/R No response E-14-4 ------- TABLE E-15 SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS OF THE REGULATORY FLEXIBILITY ACT Program Ensure that small businesses can DarticiDate in rulemaking Periodic rule review for imDact on small businesses Routine review of SBTCP documents for compliance Amnesty program Other (See below) AL X AK N/R AZ X X X AR N/R CA X South Coast X X CO X X CT X X DE X X DC X FL X X X GA X X X HI None ID X X IL X X X IN X X X X IA X X X X KS X X X KY X X X E-15-1 ------- Program Ensure that small businesses can DarticiDate in rulemaking Periodic rule review for imDact on small businesses Routine review of SBTCP documents for compliance Amnesty program Other (See below) Jeff Cty N/R LA X X X X ME X X X MD N/R MA X Ml N/A MN X X X X MS X X X MO X X X X MT X X NE X X X NV X X X X NH X X X NJ X X X NM X X NY X NC X X ND X X X X OH X OK X X X OR X X X X E-15-2 ------- Program Ensure that small businesses can DarticiDate in rulemaking Periodic rule review for imDact on small businesses Routine review of SBTCP documents for compliance Amnesty program Other (See below) PA X X PR N/R Rl X X SC X X X SD X X X TN X X X X TX X X X X UT X X VT X X X VA X X X VI* X X X WA X X X WV X X X X Wl X X WY N/R E-15-3 ------- "Other Actions and Notes: IN Confidentiality. IA Voluntary audit policy. KS Audit policy. KY Need for clarification in this area. MO DNR has its own Enforcement Policy. TN Department policy modeled after the national SBAP audit policy. VI Work being done by SBTAP coordinator; CAP not yet appointed E-1 ------- TABLE E-16 SBTCP ACTIONS TO FOLLOW THE INTENT OF THE PROVISIONS OF THE EQUAL ACCESS TO JUSTICE ACT Program Routine review of SBTCP documents for compliance Review instances where state actions against small businesses appear unjustified Pro bono legal services Funding/technical assistance for groups aggrieved by regulatory actions Other (See below) AL N/R AK X AZ X X AR N/R CA X X X South Coast X CO X X X CT N/R DE N/R DC X FL X X GA X X HI None ID X IL X IN X IA X X X N/A Not applicable N/R No response E-16-1 ------- Program Routine review of SBTCP documents for compliance Review instances where state actions against small businesses appear unjustified Pro bono legal services Funding/technical assistance for groups aggrieved by regulatory actions Other (See below) KS X KY X X Jeff Cty N/R LA X X X ME X MD N/R MA N/R Ml N/A MN X X MS X X X MO X X X MT None NE X X NV X X NH X X NJ X X X NM N/R NY X NC X X N/A Not applicable N/R No response E-16-2 ------- Program Routine review of SBTCP documents for compliance Review instances where state actions against small businesses appear unjustified Pro bono legal services Funding/technical assistance for groups aggrieved by regulatory actions Other (See below) ND X OH X OK X OR X X PA X PR N/R Rl X X SC X X SD X TN X X X TX X X X X UT X VT N/R VA X X VI* X X WA X X WV X X X Wl X X WY X X N/A Not applicable N/R No response E-16-3 ------- "Other Actions and Notes: South Coast Town hall meetings, neighborhood assessment program. KY Need for clarification in this area. ND The Department media programs, including SBAP, are aware of what equal access to justice and environmental justice concerns are; however, the Department is not aware of any problems in North Dakota. VI Work being done by SBTAP coordinator; CAP not yet appointed. WY Self audit legislation. N/A Not applicable N/R No response E-16-4 ------- APPENDIX F PROGRAM EFFECTIVENESS ------- TABLE F-1 SBTCP PROGRAM GOALS AND MEASUREMENT STRATEGIES SBTCPs were asked to indicate up to 3 program goals, numbering them in terms of priority. These goals are ranked by the programs in the following table. Program Increase regulated community's understanding of environmental obligations Increase regulated community's understanding of permitting Increase regulated community's understanding of CAA Provide site- specific compliance assistance Encourage self-auditing Improve compliance rates of regulated community Other (See below) AL 1 2 3 AK 1 5 6 2 4 3 AZ 1 3 2 AR 2 3 1 CA 1 2 South Coast 2 3 1 CO 4 2 3 1 CT 1 2 3 DE 1 2 3 DC 2 3 1 FL 1 3 2 GA 1 3 2 HI 1 2 3 ID 2 3 1 IL 2 1 3 N/A Not applicable N/R No response F-1 -1 ------- Program Increase regulated community's understanding of environmental obligations Increase regulated community's understanding of permitting Increase regulated community's understanding of CAA Provide site- specific compliance assistance Encourage self-auditing Improve compliance rates of regulated community Other (See below) IN 1 2 3 IA 2 1 3 KS 2 3 1 KY 3 2 1* 1 3* 2* Jefferson 1 2 LA 2 4 6 3 5 1 ME 1 2 3 MD 1 2 3 MA 2 3 1 Ml 3 (SBO) 2 (SBAP) 2 (SBO) 3 (SBAP) 1 (SBAP) 1 (SBO) MN 1 2 3 MS 1 3 2 MO 3 1 MT 1 2 3 NE 1 3 2 NV 1 3 2 NH 1 3 2 NJ 1 2 3 NM 1 3 2 N/A Not applicable N/R No response F-1-2 ------- Program Increase regulated community's understanding of environmental obligations Increase regulated community's understanding of permitting Increase regulated community's understanding of CAA Provide site- specific compliance assistance Encourage self-auditing Improve compliance rates of regulated community Other (See below) NY 1 2 3 NC 1 2 3 ND 3 2 1 OH 1 2 3 OK 1 3 2 OR 1 3 2 PA 1 2 3 PR 1 2 3 Rl 1 3 2 SC 2 3 1 SD 2 3 1 TN 1 2 3 4 TX 1 3 2 4 UT 2 3 1 VT 2 3 1 VA 1 3 2 VI 3 4 2 1 WA- Ecology N/R N/A Not applicable N/R No response F-1-3 ------- Program Increase regulated community's understanding of environmental obligations Increase regulated community's understanding of permitting Increase regulated community's understanding of CAA Provide site- specific compliance assistance Encourage self-auditing Improve compliance rates of regulated community Other (See below) WA- OAPCA 4 1 2 3 6 5 WA- NWAPA 2 3 1 WA- SWAPCA 3 2 5 1 6 4 WA- SCAPCA 2 3 1 WV 3 2 1 Wl 2 1 3 WY 1 2 3 4 "Other Goals and Notes: CA Other #1 - Increase the regulated community's participation in developing permitting and compliance programs. Other #2 - Identify stakeholder financial and training needs and develop resources that meet those needs. S. Coast Ensure small business participation in rule and policy development. DC Publish and distribute brochures along with maintaining a hotline. KY Rankings marked indicate the goals of the Air Quality Representative for Small Business. Other goal: To increase participation of small business stationary sources in the development of the air quality program. ME Encourage businesses to implement P2. MA Assist the regulated community in using P2 to reduce environmental impact and improve health and safety conditions in the workplace. N/A Not applicable N/R No response F-1-4 ------- Ml Serve as a liaison between the business community and compliance/regulatory staff. MT Increase potential client awareness of services. NM Direct efforts to make permitting easier for the regulated community. PA Increase the use of P2 and SEM. PR Strengthen our capacity by expanding our orientation program using our Agency resources. Rl Create and provide plain English materials. TN Decrease the negative environmental impact through P2. TX Decrease enforcement orders issued to small businesses. WY Encourage adoption of P2 initiatives. N/A Not applicable N/R No response p_"|_5 ------- SBTCPs were asked how they plan to evaluate whether the above-stated goals are being met as well as the results of this measurement process. PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS AL We have not developed a system for evaluating this achievement. Our assistance generally is given on the basis of requests from small businesses, therefore we are limited to assistina those who ask for our assistance. N/R AK Monitoring a number of businesses reached in a given business sector and comparing their records to violations noted for that sector overall. Out of 6 dry cleaners visited by the SBAP, zero received violations. 100% of those dry cleaners not visited received Notice of Violations. AZ On-site visits are evaluated with a follow-up visit 60 days after the facility receives our report. At that time, we measure the change in compliance. Outreach goal of improving understanding of environmental issues is evaluated based on number of presentations and number of attendees, along with a survey of the presentation. Another goal of the program is to respond quickly and without transferring people within the Department, if possible. This goal is tracked throuah our contact loa. On-site visits have proven to be very effective, with over 70% of violations detected being corrected by the time of the follow-up visit. Issues not corrected by that time usually are more complex or require a significant capital expense. Outreach through presentations has been very effective for our program. Just having our names and faces in front of a variety of people helps encourage them to call and seek help more readily. By developing a few template presentations and then modifying for a specific audience, we are able to tailor a presentation for a specific audience while not spending a great deal of time. We have received high marks for these efforts. AR Over the last year, our program has undergone significant changes, as the SBAP moved from the Ombudsman's office to the Customer Service Division. We currently track success as numbers of completed activities including an internal tracking database. As our program stabilizes and matures, we will be able to base our success on the ability of businesses to cope with their environmental requirements. N/R N/A Not applicable N/R No response F-1-6 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS CA Goal 1 - We continue to seek ways to increase our outreach efforts through the use of strategic partnerships. By working closely with industry, we successfully develop outreach campaigns to disseminate information throughout the regulation development process. Much of the focus is on the use of existing resources available through industry and other government organizations. We also continue to improve our web site with many pages being updated several times a week as new information becomes available. Goal 2 - While we seek to increase stakeholder access to financial resources, at this time we have no mechanism in place that evaluates our effectiveness to this end. We have published two new documents aimed at helping small businesses access the financial assistance and expertise needed to further reduce emissions and remain compliant. Goal 1 - Santa Barbara Air Pollution Control District conducted a survey to assess performance in areas of customer service. In the most recent survey (reported 11/99), over 88% of respondents indicated that businesses are satisfied or extremely satisfied with the permitting and inspection services provided by the District. This is up from 85% in 1998 and 80% in 1996. South Coast Every year, a work plan with quantifiable goals is developed in coordination with the budget. The work plan includes federal, state, and local agency programs that need to be implemented by the SBAP. Assessments of goals is evaluated using statistics generated by our computerized client tracking system, which allows tracking by business sector and activity. For some outreach activities (such as those pertaining to our rules on the switch from oil-based to water-based solvents), informal telephone surveys are conducted and compared to periodic compliance audits to evaluate success. For efforts like our Expired Permit Courtesy Call Program, staff determine the number of expired permits that are reinstated within the regulatory deadline. We met or exceeded our goals for all our key program indicators based on statistics from our computerized client tracking system and from telephone surveys, which were compared to compliance audits. For example, requests for permitting application assistance increased by 57% over the previous year. This is partly due to a booming economy, but also because the SBAP has two more engineers than it had the previous year. These engineers assist customers who would otherwise have been referred to the Engineering Section where the calls would distract staff from their primary goal of reviewing permit applications and issuing permits. By having experienced engineers assist businesses in completing the applications, the District had the benefit of receiving nearly 900 applications that were complete and ready for the Review Engineer to process. Similarly, the number of on-site technical consultations increased by 28% over the previous year. This is due in part to an increased enforcement presence in the field, which tends to encourage businesses to seek assistance before being visited by an inspector. The number of requests for rule interpretations more than doubled. This is due to mass mailings that made thousands of businesses aware of new requirements pertaining to solvent cleaning and offered our toll-free number for further information. Subsequent telephone surveys and compliance audits have shown high levels of compliance with these rules, due in part to the outreach efforts of the SBAP. A "courtesy call" program has been implemented for businesses that have inadvertently allowed their permits to expire. Through this program, about 600 permits are reinstated each year that would have otherwise expired. This has reduced the noncompliance rate without placing any additional burden on the agency's inspectors or attorneys, and has prevented 600 permit applications from being added to the workload of the Agency's engineering staff. Customers further benefit bv avoidina penalties and new BACT requirements. N/A Not applicable N/R No response F-1-7 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS CO Continue to mail customer feedback surveys to visited small business customers. Results are tracked in a database. Continue to conduct industry-specific workshops and obtain evaluation forms from participants. The survey process has continued to provide direct comments from small business customers. SBAP/SBO can follow up with any suggestions received from customers. The industry-specific workshops have allowed us to continue improving workshop presentations. The feedback has alerted us to specific small business needs. CT We are evaluating program effectiveness with questionnaires and surveys. We also have developed outcome based measures of performance as part of targeted initiatives. Outcome measures include number of facilities submitting permit applications as a result of outreach, increases in compliance with specific requirements, and increases in compliance rates. CT's SBAP pursued measurement efforts very narrowly for specific, well-defined compliance objectives. For specific compliance assistance efforts, the SBAP met programmatic goals. However, we continue to see an expansion of the regulatory universe that cannot be addressed through current resources. DE We evaluate our performance towards achieving our goals through feedback from business organizations, environmental consultants, regulatory program within DNREC, and perhaps most importantly from businesses that have been helped by our SBAP. One very important component of our program is to facilitate meetings of regulatory program representatives and business owners at their site to explain, determine, and achieve compliance with environmental regulatory compliance. Every attempt is made to do this in a non-threatening, assistance- oriented manner. We are constantly looking for ways to increase compliance levels and to reach all businesses needing assistance, especially those that may be apprehensive about approaching the regulatory programs for help. In one respect, our goals are met every time we help a small business achieve compliance. DC In this calendar year, the SBAP will institute a tracking system for various program goals, such as hotline calls, compliance and enforcement inspector reauests. and total businesses reached. N/A N/A Not applicable N/R No response F-1-8 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS FL Goal 1 - Increase understanding: A) Monitor 800 line for regulatory and technical assistance inquiries. An increase in calls from a particular industry typically follows an outreach activity, or can indicate where additional outreach activities are required. B) Conduct training and associated pre- and post- training surveys. C) We target one significant small business industry per year. Goal 2 - Improve compliance: A) Above training increases awareness and thus raises compliance rates. B) Developed and distributed dry cleaners compliance calendar. C) Developed follow-up survey for printers attending "Printers Protecting the Environment" workshop. Survey will be distributed in 2000. Goal 3 - Encourage self audits: Developed self audit road map for printers, which was distributed during training workshops and available bv downloadina from our web Daae. SBAP met many goals in 1999. Statistical data showed which types of businesses and how many businesses of each industry type were reached. 1. Dry cleaner calendars were distributed to enable businesses to easily enter data on their calendars, then tear off information each month to send in to meet reporting requirements. In 1996, there was a 12% compliance rate in recordkeeping. In 1999, recordkeeping and reporting compliance increased to 83%. 2. Responded to 319 requests for regulatory and technical assistance (received via 800 line, letters, emails, etc.). N/A Not applicable N/R No response F-1-9 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS GA SBAP prepared measurable objectives to help us achieve our 1999 goals, which are grouped by Education and Technical Assistance. Education: 1) Publish 4 newsletters during 1999. 2) Maintain a combined database of small businesses by SIC code for targeted sector outreach. 3) Sponsor an exhibit at one trade association conference. 4) Make 12 informational presentations to professional groups and civic associations. 5) Maintain a web page for small business owners to use for distributing relevant information in a timely manner. 6) Provide effective staff development and training in current methodologies and practices, and ensure that each staff member attends at least one training course or small business assistance conference. 7) Maintain a repository of pollution prevention and SBAP resources. 8) Market the program via radio, television, and press releases to inform small business owners of the multimedia assistance services now available to them. Technical Assistance: 1) Publicize the toll-free telephone assistance line. 2) Prioritize small business technical assistance needs by industrial classification and prepare two compliance assistance documents. 3) Make 12 site assessment audits. 4) Assist 12 small businesses in permitting assistance. 5) Respond to 500 requests for assistance via telephone within 24 hours and complete any required on-site follow-up visits at the client's convenience. 6) Make 6 joint inspections with compliance inspectors from other Air Branch Programs to maintain familiarity with small business technologies. 7) Make 6 joint "white hat" compliance assistance visits with inspectors from the DNR Hazardous Waste Programs to dry cleaning establishments. The SBAP exceeded our work plan goals. Our measurement system worked. HI The ability of the SBTCP to reach targeted industry sectors with accurate multimedia regulatory compliance information indicators. Completeness of mail/distribution lists and feedback from industry representatives regarding coverage and quality of information disseminated. Use of SBO/SBAP staff (number of contacts) by targeted industry sector. Classification of enforcement action assistance, and clarification of regulations and permit Drocessina/technical assistance. Site visit reauests. Received positive feedback from industry that outreach efforts were effective. For each indicator, there was measurement or response statistical data collected for each indicator (mentioned to the left), which shows acceptance and use of the SBTCP program elements. ID In 1999, no methods were established to determine the program's effectiveness and whether or not our goals were being met. However, the SBO/SBAP continued to track the number and types of assistance requested, phone calls received, meetings attended, and site visits conducted while the Droaram was operational in 1999. With the loss of the SBO in May and the subsequent inactivity of the program until mid-December, ID has been unable to meet its goals for 1999. N/A Not applicable N/R No response F-1-10 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS IL We are using targeted efforts with the IEPA BOA to identify the number affected by a given rule, develop understandable information in the beginning, measure those that come into compliance in the front end, identify those that have not responded to compliance dates, and make a further assistance effort to inform them of impending enforcement actions. We then get a new group to comply and can measure that against the final number targeted for enforcement. This has been a areat measure for our Droaram and has been fairlv inexpensive. The two initiatives we began this year that follow this pattern have been very successful. CFFP compliance increased nearly 50%, and AER compliance increased 32%. IN We are evaluating whether we met our goals by using the Environmental Performance Partnership Agreement and tracking our progress. Mercury - We collected over 700 pounds of elemental mercury and other mercury devices and debris and over 3,000 fluorescent bulbs. 90% of IN's counties have on-going mercury collections. Mercury and Steel Mill Initiative - In 9/99, US EPA, IDEM, and the Delta Institute published a report about mercury in the three major IN steel mills. The mills worked hard to develop this first phase of the project. HVAC - Approximately 18% of all are in the Mercury Thermostat Reduction & Recycling Program. Workshop evaluation forms are distributed at every workshop for feedback and follow-up. Set a goal of getting 60 facilities into the child care program and had 53 by the end of the year. Conducted 15 workshops across the state covering a variety of topics. Developed a searchable dry cleaner database for our web site. Updated our web site to be one of the best at IDEM. For the most part, the goals were met. The measurement system worked, but we are in the process of developing a more user-friendly system for tracking our activities. We worked cooperatively with our target industries; provided comprehensive compliance manuals, workshops, and on-site assistance; and continued our recognition program. All workshop evaluations have provided consistent, positive feedback, and companies continue to request our assistance. N/A Not applicable N/R No response F-1-11 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS IA Our system focuses on evaluation of services. We do not have a system to track and relate client evaluation to specific program goals. We send an evaluation form to every on-site client or detail assistance (defined as any assistance involving more than one hour of staff time) client. They rate the quality and usefulness of assistance. Completed and returned evaluation forms are entered into a database, which can generate a number of reports based on the client evaluations. Also, we develop case studies of clients we have worked with, as aDDroDriate. Returned evaluation forms show that over 95% of respondents found the services to be "excellent" and "very helpful" and would recommend our services to other businesses. Evaluation feedback is only one part of the measurement for meeting program goals. Among other indicators, increased client referrals, repeat visit requests from past clients, and a steady backlog of site visit requests show us we have earned the confidence of the small business community. KS Following all on-site assessments, workshops, and conferences, evaluation forms are sent to participating businesses. Six months later, those businesses receiving on-site assistance receive another evaluation to determine if advice provided has been implemented by the business. In addition, numbers and comments provided by the businesses are recorded. Evaluations are provided after every workshop, which relates to our second ranked goal regarding the "regulated community's understanding of their environmental obligations," and to determine the quality of the workshop. Workshop evaluations show extremely positive results. Evaluations also are conducted quarterly with people that called the hotline for assistance. As we get a number of repeat callers, each individual is only surveyed once per year. The surveys assess both the quality of our assistance and whether better understanding of regulations was achieved as a result of the assistance. We also measure whether or not the caller made any changes that resulted in less pollution or improved compliance. From May 1998 to June 1999, 23 surveys were sent to facilities where we had done site assessments. 20 were returned. 100% said: 1) The written report we provided was delivered in a timely fashion. 2) They would recommend our services to others. 3) The information was what the needed or asked for. On a scale of 1-10, the following rankings were received: Report content = 8.35. Report length = 7.95. Readability = 9.30. The most popular features of the report were the executive summary and waste reduction opportunities. Time spent by the businesses reviewing and implementing report recommendations was estimated at 231 hours. The dollar value of the service was estimated at $16,600. 95% said the report, in combination with the site visit, was enough to implement some recommendations. Out of 119 recommendations, 51% were implemented and 15% are planned to be implemented, for an estimated annual savings of $17,435. We began surveying telephone customers in 1999. 138 surveys were conducted of hotline callers. 44% made changes as a result of calling, 75% understand the regulations better, 26% were able to reduce waste as a result of calling, and 83% will use our services aaain. N/A Not applicable N/R No response F-1-12 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS KY The SBAP, in conjunction with the SBO, requests completion of client evaluation cards as specific assistance efforts are finished. The SBAP negotiated goals in the contract with the regulatory agency (e.g., number of businesses assisted, number of outreach activities, and other goals). The SBAP tracks hours assisting clients by on-site assessments, emissions and permit determinations, and permit preparation. The AQRSB developed 2 questionnaires during 1999 to assist in evaluating 2 services. These services include the work of the Department for Environmental Protection in staffing and responding to the CAP and orientation of new members. The SBAP evaluates its efforts to provide compliance assistance and educational information to small businesses through evaluation cards; requests for "success stories" prepared by the Ombudsman; meetings and discussions with business industry organizations; and working with the regulatory agency, CAP, and other stakeholders. The SBAP exceeded its 1999 goals outlined in the contract with the state agency for clients assisted and outreach activities. The SBAP was unable to meet its goal for newsletter publication. AQRSB developed a survey and sent it to the CAP members to help the DEP evaluate its assistance to the Panel. Using a scale of 1 to 5, with 1= poor service and 5 = excellent, the Department received a 4.5. An evaluation form also was developed for the orientation program, which received a high rating. Jefferson Ctv N/R N/R LA Performance evaluation forms are sent to our clients whom we have assisted. We have two levels of assistance: "contacts" and "assists." Contacts receive advice by phone and in seminars. Assists receive extensive engineering assistance, such emission inventories, permit applications, and on-site audits. We maintain a database of these activities and compare with previous time periods. We maintain a database on SBAP activities and compare them with the previous year. Our performance evaluations from our clients are consistently favorable. Our number of contacts and assists steadily increase every year. Our goals have been met. ME Customer comment cards are sent out with all written information. Evaluations are used at all trainings. Evaluations from 112(r) training indicate 76% of attendees who could not opt out of the program indicated they received adequate information to achieve compliance. MD During 1999, the SBAP's goals were to provide assistance to small businesses that called or e-mailed assistance requests. The SBAP also worked to increase awareness of the program both in the Department and in the reaulated communitv. N/R MA We have used questionnaires, and we ask how we are doing when we are interacting with businesses. We have had focus groups with invited recipients of our services. We follow up with companies to see how well our advice worked for them. We track data on their performance. We use evaluation forms for our events. The feedback on our events and visits is consistently highly positive. The data from the companies we work with show they have reduced their toxics use and waste substantially, improved compliance, and usually saved money doing so. In our latest data summary, we found that 64% of the compliance suggestions we offered were implemented. N/A Not applicable N/R No response F-1-13 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS Ml SBO - The SBO evaluates its services from the feedback received by economic development staff who visit companies statewide, plus measures the number of businesses assisted and cases that have been closed. The SBO also uses the comments generated by the Ml Economic Development Corporation's overall department effectiveness service evaluations. SBAP - The SBAP targeted the following objectives for completion during FY98-99 (10/98-9/99), based on individual staff work plan objectives: - new workshops = 17 - new guidance documents = 5 - publication revisions = 3 - responses to requests for technical assistance = 1,020 - on-site visits = 30 - articles for newsletters, etc. = target not set - partnership opportunities = target not set - presentations = target not set SBO - Positive experiences with SBO staff are often mentioned in the Ml Economic Development Corporation's overall department effectiveness service evaluations. SBAP - The SBAP evaluates the quality of its services and effectiveness by reviewing its projected and actual program objectives and the level of technical assistance provided on both a monthly and annual basis. Some of the measurement tools that the SBAP uses include the review and summary of the overall responses from customer surveys that accompany all new and revised SBAP guidance publications, the responses from evaluation forms that are returned after each SBAP workshop, and the appreciation letters submitted by satisfied program customers. New workshops = 16 completed (objective met 94.1%) Overall evaluations on a 1-5 scale with 5 = excellent: - Regulatory staff training on the Ml Air Emission Reporting System (1 site) = 4.1 - Ml Air Emission Reporting System workshops (13 sites) = 4.5 (average for all) - Regulatory staff training on emission calculations (1 site) = not measured - Managing fugitive dust (1 site) = 4.1 Percent of attendees anticipating future action or compliance based on workshop activity (as reported by attendees): - Regulatory staff training on the Ml Air Emission Reporting System = NA - Ml Air Emission Reporting System workshops (13 sites) = 86.4% (average for all) - Regulatory staff training on emission calculations (1 site) = NA - Managing fugitive dust (1 site) = 68% New guidance documents = 8 completed (objective met and exceeded by 60% with 7 finished and 1 draft) Overall evaluation of guidance documents, on a 1-5 scale, with 5 = excellent: - Emission Calculation Worksheets: surface coating, electroplating, foundry, hot mix asphalt, aggregate, oil and gas production, municipal solid waste = NA - Managing Fugitive Dust Fact Sheet = draft Publication revisions = 2 completed (objective 66% met) - Ml Air Use Permit Technical Manual updated twice during this period = NA Responses to requests for technical assistance = 1,246 completed (objective met and exceeded by 22.2%) On-site visits = 41 completed (objective met and exceeded by 36.7%) In-house permit assistance meetings = 23 completed (objective met) Articles for newsletters = 35 completed (objective met) Partnership opportunities = 53 completed (objective met) Presentations = 18 completed (obiective met) N/A Not applicable N/R No response F-1-14 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS MN Completed evaluations - SBO conducted a review of loans made through SBAP's Small Business Environmental Improvement Loan Program to evaluate their environmental and economic impacts. Completed evaluations - The review of loans made through the Small Business Environmental Improvement Loan Program indicated a strong degree of success in terms of increasing environmental awareness through significant pollutant reductions and economic savings. Upcoming evaluations - MN received a Section 507 grant from EPA to conduct and measure the effectiveness of a sector- based, nonregulatory compliance assistance initiative within MN's fiber reinforced plastics (FRP) industry. This initiative will evaluate whether we are reaching our goals within the FRP industry and potentially serve as a model to evaluate whether we are reaching our goals in other sectors. We also are implementing a new computerized tracking system (SBAP Tracker) that will allow the program to perform detailed analysis on the types and numbers of businesses reached, nature of contact, contact frequency, need for follow-up, etc. These data will be used annually to evaluate program effectiveness and to make work Dlan adiustments where aDDroDriate. Upcoming evaluations - Results garnered from the Section 507 grant and the new SBAP Tracker will be reported next year. MS N/A N/A MO We send an evaluation survey to every fifth facility helped. Our on-site assessment team performs a follow-up on each facility they visit to see if the recommendations have been followed. We are continuing to write industry-specific P2/compliance guides and other technical bulletins. The surveys indicate that the assistance provided is very good and much appreciated. They also give an indication that the assistance processes used are helping facilities achieve environmental compliance. Follow-up on the on-site assessments indicates that most violations are being corrected and that P2 recommendations are being followed. In some cases, the P2 recommendations have saved the facility money and lessened their environmental compliance reauirements. MT Increase the number of businesses reached through mailings of newsletters, fact sheets, brochures, etc., and increase their participation in the newsletter writing process. Increase the number of calls to the hotline. Decrease the number of enforcement cases for businesses that appear to be ignorant of the rules. Increase small business awareness of free P2 services and increase requests for those services. Increase the number of favorable comments about SBAP and DEQ by small business communitv. We made a significant increase in the number of materials produced specifically for business sectors and received several letters from targeted businesses expressing their appreciation. We also had favorable responses from businesses targeted through workshops. The effort is too new to determine if it is increasing the public's knowledge of P2 services and their willingness to ask for audits. Note: Hosting the 2000 SBO/SBAP conference has taken a CONSIDERABLE amount of effort from the one-person MT SBO/SBAP. NE The program will continue to provide on-site visits and seminars to assist business and industry in understanding their obligations under state and EPA laws. A monthly reporting system, along with an activities report help the Agency understand what types of problems are perceived in the field. A spreadsheet of the number of on-site visits and other information also is kept month bv month. N/A Not applicable N/R No response F-1-15 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS NV The SBDC-BEP conducts client surveys to assess program effectiveness. Evaluation forms are used at training seminars. Quantitative measurement efforts of impacts of on-site assistance provided by the SBDC-BEP were initiated in 1999. Results of the SBDC-BEP client survey: - 99% of 70 respondents felt that BEP assistance was explained in plain English. - 95% felt the BEP understood their business operation. - 95% improved operations due to assistance. - 89% indicated that BEP made them more aware of other environmental health & safety regulations that apply to their operations (OSHA, fire, waste discharges). - 80% indicated the BEP referred them to other useful information sources. - 74% indicated they had passed on information provided by BEP to other businesses or referred other businesses to BEP. - 45% of businesses indicated they reduced their waste generator status since usina BEP services. NH We continued to use fairly general measurements for effectiveness (such as number of manuals requested, number of on-site visits performed, etc.). We continued to have a number of referrals from complaints forwarded to the SBTAP from enforcement bureaus, which result in quantifiable numbers. We are continuing efforts to quantify industry sectors in the state for measuring sector penetration. During 1999, we began an effort to quantify the printing sector, which will continue into the first half of 2000. We are still grappling with the implementation of an effective and consistent measurement program. Although we have anecdotal information on the success of program activities (such as number of on-site visits), we are still evaluating performance-based measures. We are developing several measurements as part of the PrintSTEP program to determine what types of data we can collect without an undue time and effort burden, yet still show environmental improvement. This effort, coupled with an increased use of self-mailing follow-up surveys, should help us better determine completion of our goals. NJ Recordkeeping on the number and type of businesses assisted through the program. Use of surveys at all workshops, seminars, and trainina sessions. Use of Dhone loas. N/R N/A Not applicable N/R No response F-1-16 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS NM A year ago, we re-evaluated our overall SBAP goals. We decided to redirect our efforts to make the permitting process easier for small businesses, to reach more businesses, and to reach whole sectors wherever possible. In keeping with the nature of activities initiated the previous year, we continue toward making the permitting process easier for small businesses, while shortening the time needed to get a permit. Starting last year and following into this year, the Air Quality Bureau started to develop General Permits for categories of similar sources, making the application process easier and achieving a 30-day turnaround. The first General Permit for oil and gas compressor stations has been put into effect, and a second one for the oil and gas industry is in the works. We are also continuing work on General Permits for rock crushers and asphalt plants. We continue developing new regulations for concrete batch plants, spray painting, and abrasive blasting operations. This new development allows operations to file a registration form agreeing to comply with regulations and would eliminate the need for the lengthy permitting process. NM's SBAP has renewed efforts to improve our web site to make it more accessible, user friendly, and informative. Further, in our efforts to reach and interact with more small businesses, we have put together community outreach programs and materials used during the State Fair and for city/county meetings. We continue to develop fact sheets and brochures, as needed, to answer questions for industry and interested parties. We feel we are meeting the goals set for our program. We believe that we will continue to improve in our service to the small business community as we progress down this avenue of service with input and suggestions from the serviced community. Feedback from meetings with the public sector and clients indicate that developing an easier, more understandable permit process is a positive step in assisting small businesses. N/A Not applicable N/R No response F-1-17 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS NY The program primarily uses statistics on the response rates to mailings and the number of hotline calls, ombudsman cases, mailings, permits completed, and on-site audits that occur each year. The SBAP tracks the numbers of hotline calls, audits conducted, permits and registrations completed, and attendance at workshops. The SBAP has surveyed all program contacts via our newsletter, Clean Air News, for their feedback on the content and frequency of the newsletter. Responses were favorable, indicating reader satisfaction. The SBAP conducted 15 audits this year and provided site-specific assistance to these businesses. We responded to 1,178 hotline calls with requests that ranged from routine program information to very specific technical assistance. We provided permitting assistance, completing 14 state facility permits and 75 minor facility registrations. We conducted or participated in 8 workshops, seminars, or expositions for industries affected by air pollution control regulations, reaching an audience of approximately 5,200 businesses. The SBAP followed up with 18 companies that the SBAP had audited during FY98-99 to determine if they had implemented SBAP's recommendations and if they needed further assistance. The SBAP conducted a telephone survey of each company audited using a prepared survey form to ensure that each company responded to the same set of questions. Analysis of the survey responses revealed that small businesses receiving an SBAP audit acted on 90% of the technical recommendations. The SBEO tracks the number of hotline calls and the number of ombudsman cases completed each year. There were 776 calls to the ombudsman hotline in 1999, which represents about a 10% increase over 1998. In 1999, the SBEO focused most of its outreach and compliance assistance efforts on the dry cleaning industry sector. The SBEO conducted two regulatory alert postcard mailings to dry cleaners who failed to notify EPA and DEC under the NESHAP notification requirements. Based on a comparison of the NESHAP databases maintained with DEC, the compliance rate among dry cleaners increased by approximately 50% within a six-month period. The SBEO conducted several regulatory alert postcard mailings to dry cleaners on specific provisions and compliance schedules of the dry cleaning regulation. Overall, these informational alerts tend to increase the regulated community's understanding of their obligations by providing clear and consistent description of regulatory requirements and increases compliance rates among affected businesses. The SBEO and SBAP maintain a case referral and tracking system to assure that businesses that contact the program for compliance assistance are ultimately provided with assistance throughout the regulatory process, ensuring an effective increase in compliance rates among the regulated community who seek program services. N/A Not applicable N/R No response F-1-18 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS NC A new engineer joined the staff during the second quarter of this year. He has a great deal of experience with software and electronic data recording. We instituted a new database tracking program to monitor calls, e-mails, site visits, etc. Also, the Department has committed to improve performance measurement in all programs and will provide some assistance to the Customer Service Center to improve tracking and establish measurement aoals and objectives. Due to our limited resources, we were not able to invest the time required to perfect the information management system. We expect to have performance measurement in place next year to help us more objectively report our successes. ND One indicator of our effectiveness is the compliance status of small businesses. There is a high level of compliance among small businesses in ND. We feel our assistance efforts have been successful in achieving our goals. The UST program uses an annual compliance Questionnaire. No statistics have been compiled. Qualitatively, the vast majority of small businesses are in compliance. The UST program achieved 95% compliance as of December 1998. OH SBAP Goals 1 & 2 - The SBAP conducts a follow-up satisfaction survey of all site visit recipients to assess quality of assistance provided, actions taken, etc. In 2000, the SBAP also will be surveying the 12 Agency field offices to assess our performance and their perceived value of the SBAP. SBAP Goal 3 - A strategy to examine how many of our customers file required permit paperwork is being developed for 2000 using the Agency's new electronic permit tracking system. A much broader strategy to assess the compliance rate of the entire small business community has not yet been developed. SBP - The SBO has a slightly different set of priorities, which do not conflict with SBAP. The SBO would agree with awareness of current regulations. However, our second goal is to provide access to information about CAA requirements and the business/economic analysis of clean air. Our third goal is to assist in financing small business air quality investments. Measuring effectiveness includes number of outreach activities, level of program exposure to the small business community, and number of loans and arants made. SBAP - Surveys indicate over 98% of customers would use the SBAP again and would serve as a program reference. Over 90% indicate that completing required permit applications would be impossible without SBAP assistance. In addition, 99% of customers said we explained regulations in plain English. Working regularly with our field offices has resulted in them referring 70% of our site visit customers. SBO - Our outreach efforts continue to get stronger each year. We worked with 20 different trade associations, 28 SBDCs, and 27 local governments to get information to small businesses. SBO support of industry-specific environmental "how to" manuals is creating plain language explanations of air (and for all media through other funding sources) regulations to printers, dry cleaners, auto dealers, auto collision repair shops, small metal working shops, and small chemical companies. Finally, in 1999, we provided 11 small businesses with loans totaling $483,800. OK Our goals are established and measured through our Agency's internal FOCUS document. Further, we have developed some basic recordkeeping and tracking documents to determine how active we are in particular areas as well as how effective we are. We believe we are meeting the program's goals. N/A Not applicable N/R No response F-1-19 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS OR The goals of the BAP are more general in nature. We do not have a good system for evaluating the effectiveness of the program. We hope that the work of the EPA SBO/SBAP program will develop a method we can use. A tracking system that feeds directly into this electronic report would be WONDERFUL' Technical assistance is currently tracked as far as the number of calls, on-site visits, mailings, etc., but we do not track reductions in air pollution or improvements to the environment. Some program goals are being met as far as educating the regulated community about their environmental obligations. This is indicated by the technical assistance tracking method developed for the AK DEC that is currently being used. The current measurement system does not work as well as desired. An improved measurement system needs to be developed, but limited resources have prevented this from happening. Fewer on-site technical assistance visits are being requested than is desirable. PA Measurement tools are beina developed. N/R PR Goal 1 - We are establishing a measurement method to count how many businesses we have reached. Goal 2 - By the number of businesses that have requested information or orientation about the program. Goal 3 - Bv establishina alliances with interested oraanizations. The SBTCP has not completed its goals because we are establishing accurate measurement methods. Rl Our work with industry through on-site assistance, plain English fact sheets, and industry/government work groups has led to the creation of new policies and MOUs. These deliverables ensure continued work with targeted industry sectors. Maintaining databases on industries, which includes the assistance activities provided to them, also has helped us to meet our program goals. Case studies highlighting assistance performed -- and thus pollution reduced or eliminated -- reinforces our success in getting the regulated community to understand their environmental obliaations. People respond well to teleconferences and on-site assistance when the assistance is provided by professionals who are familiar with specific industry problems and who have experienced problems by trial and error. Success stories in working with the nonregulatory branch of the state and federal environmental agencies also are helpful. SC Continuous review of assistance requests with attention paid to whether or not help was requested prior to intervention from Aaencv staff. The number of businesses requesting assistance or permitting information prior to regulatory intervention has increased. SD N/R N/R TN Post-workshop evaluations, follow-up phone surveys of workshop attendees, number of workshop attendees, number of technical assistances that result in less pollutants or permits, number of educational materials distributed. Yes, we have met our goals. Attendance at SBAP workshops typically were higher than those offered by similar programs. Over 60% of dry cleaners who passed the certified dry cleaner test were attendees of the SBAP's test prep workshop. Workshop evaluations averaged between 4-5 on a 1-5 scale. Permit and compliance assistances have resulted in fewer permits and less environmental impact. N/A Not applicable N/R No response F-1-20 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS TX Measuring industries' compliance before and after assistance through questionnaires and customer service surveys for all hotline calls, site assistance visits, and workshops. Tracking the number of small businesses using Supplemental Environmental Projects (projects toward which small businesses may apply a portion of the penalty owed under an enforcement order, which benefit the environment in the community where the violation occurred), and the number of small businesses issued default orders (orders issued to entities that do not respond to Notices of Violation). For hotline, year-end overall air and waste compliance figures fell short of our 90% goal. For workshops, year-end compliance for auto body and auto service exceeded 90% for air issues, but fell below 90% for waste issues. Additional outreach will be conducted for the industries for which compliance rates were below 90% and targeted to a specific media. The measurement system was successful in that it showed us the industries for which outreach was successful, as well as what types of outreach were effective. The data also showed us where further outreach is needed. Industry-specific compliance data for site visits, hotline, and workshops are shown in the notes section below. Site visits - Individual business compliance status after a site visit varied. Some businesses implemented all changes recommended from the site visit and achieved 100% compliance. Other businesses only implemented a few of the changes. The minimum compliance level after a site visit was 32%. The site visit program was extremely successful for the majority of businesses that participated in the program. Hotline - 3,306 calls were received in 1999. The overall compliance increases, measured from comparing results of 566 pre- and 133 post-surveys averaged 31.6% for air issues and 32.2% for waste issues. Industry-specific compliance increass for air and waste issues are shown in the notes section below. Workshops - 57 workshops were conducted in 1999 with 1,784 attendees. Compliance data are only available for the auto body and auto repair industries, as those were the only surveys returned. For the auto body and auto repair industries, compliance with air issues increased by 39.4% and 21.0 %, respectively. Compliance with waste issues increased by 19.6% for the auto repair industry. Compliance increase for waste issues for the auto body industry could not be calculated due to an insufficient number of survevs returned. UT SBTCP provides services to small businesses through a hotline, on-site visits, seminars, etc. We do not have a process in place to measure program goals. VT Sector targeting increased the number of hotline calls and on- site visits. Hotline calls increased from 146 in 1998 to 330 in 1999. The number of on-site visits increased from 18 in 1998 to 36 in 1999. N/A Not applicable N/R No response F-1-21 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS VA For this program year, we evaluated our goals by tracking assistance types and industry sectors. In addition to using general compliance assistance daily activities, we concentrated on completing the Internet Leadership Grant (3/99) and delivering Internet training to the small businesses of the Commonwealth (targeted mailings went out to over 18,000 businesses). We also wanted to concentrate on delivering assistance to propane gas facilities; to complete and launch our SBAP pilot mentoring program, the VA EnviroMentor program; and to initiate the Small Business Environmental Compliance Assistance Fund. Each of these was accomplished. All these goals are obviously staff-dependent and rely on the dissemination of information regarding regulatory and permitting requirements to potentially-affected sources. We feel that the assistance provided to a single client or the information dispensed through partnerships and other productive interfaces are sometimes difficult to quantify in terms of effort or output. Capturing these types of partnership activities and the resultant referrals by the parameters of assistance type and industry sectors helped is difficult. For example, the negotiation of an MOA with the VA Department of Business Assistance for the administration of the loan fund was a long process. This process, which resulted in a single product, created the opportunity for many beneficial contacts and the opportunity to interface with small business representatives, which will serve the Droaram bevond the loan fund development process. Internet training, 112(r) outreach to propane facilities, launching the EnviroMentor pilot, and completion of the parameters for the Small Business Environmental Compliance Assistance fund were all achieved. The ability to empirically measure the results of compliance assistance or P2 activities remains very difficult. Compliance assistance is very "soft-sided" and does not necessarily produce results that are immediate, definitive, or discernible. The advent and increasing acceptance of Environmental Management Systems in the business world should help to resolve this dilemma. VI Presently, we are working on rules and regulations for permitting some industries. We also worked on self-auditing and believe that by the end of 2000 all will be in place. Our goals are being met in a manner that is satisfied based on personnel. We met our program goals set for FY99. We used a work plan and checked its status on a monthly basis. N/A Not applicable N/R No response F-1-22 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS WA By responses from sources; by availability of SBAP services; by developing SBAP materials; by comparing ratio of Notice of Violation to enforcement inspections, compliance rates, and staff feedback. OAPCA - Continues to provide as diverse services as possible to small businesses through its hotline, mailings, on-site visits, and via the web site. NWAPA - Facility compliance during compliance inspections will improve if the business assistance program is effectively getting information out. No systematic progress measurement system is in place. A call tracking system ensures that requests are addressed. No problems are evident. SCAPCA - Our goals are general and are not easily quantifiable. To meet our goals, we continue to develop, on an as-needed basis, informational tools (e.g., information sheets, newsletters, presentations, etc.) to increase compliance among our registered facilities. NOV ratio is decreasing. WV The SBAP surveyed a significant sample (23) of clients who received "detailed assistance." Clients evaluated 5 categories: overall rating, ultimate value of information, quality of assistance, quantity of assistance, and timeliness of assistance. These were rated from excellent (5) to poor (1). SBAP provides services to small businesses through a hotline, on-site visits, seminars, etc. Many of our assistance efforts come through referrals by OAQ Permitting and Enforcement. However, in 1999, the SBAP decided to take a more pro-active approach to providing outreach to specific industry sectors. A review was done of the violations written by OAQ Enforcement over the past 5 years to identify specific industry sectors to target for outreach. This resulted in the development of the Dry Cleaner Compliance Calendar and other planned outreach. Average rating = 90% (4.51-5, between very good and excellent). Survey response rate = 78.3% (18/23 forms completed and returned). SBAP is expanding this process. However, the follow-up to the other programs implemented in 1999 will take place sometime in 2000. Only through this means can we determine if the measurement system is accurate and working. N/A Not applicable N/R No response F-1-23 ------- PROGRAM STRATEGIES TO EVALUATE GOALS RESULTS OF MEASUREMENT PROCESS Wl We work closely with the DNR's Bureau of Air Management to help determine if our goals are being met. We focus a large part of our assistance efforts on permitting issues. Smaller businesses in W need to apply for a State Operating Permit (SOP). We track the number of permit applications received by the Bureau to see how many smaller businesses are applying. By tracking number of calls and requests received by the SBCAAP, we can see if there is an increase year to year and whether businesses are using our program to gather compliance information. We analyze where requests come from and the business sector seeking assistance. Every call to the Wl SBCAAP is logged into an Access database. We record the type of business, type of assistance provided to the customer, and other relevant information. All seminars and presentations are measured through evaluation forms. On the form, we ask for their baseline of knowledge prior to the seminar and ask them to compare it to their level of knowledge after the seminar. We usually see an increase in the 75% range. In past years, we have done a needs assessment and benchmarking survey. This was not done in 1999 due to a staff shortaae. The number of businesses reached for 1999 declined by 29% for the W SBAP. However, we operated our program with only one FTE for the majority of the year. This decline does not adequately show the results of our work for the year. Our program emphasizes workshops and training seminars over one-on-one site visits. With such a small staff (1 person), we need to focus on activities that get us the most "bang for the buck." We conducted 30 seminars in 1999, reaching 1,303 businesses. WY A mail-in survey to assess our performance for 1999 was sent to our newsletter recipients. Responses are being tabulated at this time. We also are working diligently through an EPA compliance assistance grant to refine both our information sharing with the entities we serve and our effectiveness in helping them find cost-effective ways of complying with new environmental regulations that affect them. We have made significant progress on goals 1, 2, and 4 through our newsletter, community presentations, conference displays, and on-site visit programs. Many of the businesses and small government entities we have served are below limits requiring permitting in this state, but there is ample anecdotal evidence that our contacts are producing results. Our ongoing feedback survey for the year has been tailored to gather information on the impacts of that information on actual operating procedures for the full range of affected entities. Results of that survey will be reported through our ongoing compliance assistance grant program. N/A Not applicable N/R No response F-1-24 ------- *Notes Texas Site Visit Program - The overall AVERAGE compliance of businesses for all media (air, water, and waste) after a site visit was completed is shown in the table below. Industry Sector % Compliance Post-Site Visit Wood manufacturing 73 Auto body 82 Metal finishing 72 Dry cleaning 89 Foundries 78 Surface coaters 76 Auto repair 77 Thermoset resin 69 Auto dealers 78 General industry 71 N/A Not applicable N/R No response F-1-25 ------- Hotline - Baseline and year-end compliance figures, compliance increases, and number of calls for specific industries were as follows: Industry % Compliance Increase Auto Body air 31 3 waste 30 3 Metal Finishers air 38 1 waste 14 6 Other air 37 2 Industries waste 31 9 Auto Repair air 15 4 waste 376 Dry Cleaners air 56 5 waste 53 1 Wood Products air 366 waste 42 1 Printers air 33 9 waste 19 8 Chrome air 24 4 Platers waste 0 Thermoset air 35 1 Resin waste 30 3 All Industries air 31 6 waste 32 2 N/A Not applicable N/R No response F-1-26 ------- TABLE F-2 SIGNIFICANT PROGRAM ACCOMPLISHMENTS, AWARDS, AND RECOGNITIONS PROGRAM ACCOMPLISHMENTS Alabama N/R Alaska N/R Arizona N/R Arkansas Even in our period of transition, our small business revolving loan fund has remained popular. This year we made 27 loans totaling $270,000 to small businesses. California The Ombudsman's Office (OMB) provides customer assistance and complaint resolution to stakeholders regarding the Air Resources Board's (ARB) programs and activities, tracks stakeholder involvement in ARB regulation, and assists ARB Divisions and Cal/EPA with outreach forums. OMB is the primary point of contact at the state level for small business assistance needs, including permitting, compliance, and financial assistance information. OMB initiated, coordinates, and supports the CA Air Pollution Control Officers Association/ARB Business Assistance Committee. South Coast In 1999, the Air Quality Management District Hearing Board specifically asked that the SBAP staff assist any small business that needs a variance from the rules. They helped train the SBAP staff in the most troublesome aspects of obtaining a variance so we could improve these businesses' understanding of how to testify before the Hearing Board. As a result, the Hearing Board process moves more expeditiously, and more small businesses are successful in pleading their cases for additional time to comply. The AQMD encouraged the formation of a coalition of industry trade associations and regularly meets with this "Small Business Alliance" to help identify and resolve problems affecting small businesses. Members of the "Small Business Alliance" serve on various advisory groups for the agency and assist with outreach efforts. The computerized client tracking system we have been using has served as a prototype for other business assistance offices. Colorado SBAP's grant from EPA will build partnerships with other assistance providers throughout the state. SBAP is working with our P2 program on a project to improve measuring the effectiveness of compliance outreach versus enforcement inspections. The dry cleaner guidance document project has been significant in that the SBO/SBAP have established new partnerships (the task force is represented by various federal, state, industry, and private members). This project has been positive from the start, and the final document is expected to be well received. Connecticut N/R Delaware N/R District of Columbia N/A N/A Not applicable N/R No response F-2-1 ------- PROGRAM ACCOMPLISHMENTS Florida Dry cleaners compliance calendar has been downloaded and is being modified for use in at least five other states. Printers Protecting the Environment Workbook has been selected for inclusion in the 2000 EPA Audit Source Book, and is available for downloading from our web site. Georgia During 1999, SBAP produced and distributed 19 public service announcements to television stations in Macon, Savannah, Columbus, and Augusta. The seventh CAP member was appointed. The position had been vacant for 2 years. The EPD Director sent a letter to EPD managers explaining the history of the SBAP and the types of services provided. The letter was designed to show support of the program at the highest levels. SBAP helped prepare an overview of the NESHAP requirements for inclusion in a multimedia guide for dry cleaners. The Ombudsman and the SBAP Coordinator appeared on a talk show in Columbus, GA. They discussed the merits of a business using the SBAP. SBAP requested to be listed in the next Government "blue pages" of the phone book. With the aid of our CAP, the SBAP received a dedicated toll-free number in October 1999. The previous number was shared by three programs. SBAP received 120 calls on the toll-free number from October 15 to December 31, 1999. SBAP prepared a multimedia inspection guide for the Division. This compliance assistance tool explains EPD's inspection process. SBAP was visited by Karen V. Brown, US EPA SBO, in May. Her visit increased our visibility within EPD. SBAP reached out and touched more than 48,000 businesses in 1999. We provided on-site assistance to 53 businesses. SBAP sponsored a series of workshops entitled, "I Am From the Government and I Am Here to Help" in 6 cities. We added two workshops after being flooded with calls requesting that we hold the workshop in additional cities. We were requested by the Southern States Dry Cleaner Show to do a modified, 4-state version of our workshop at their biannual dry cleaner show in Spring 2000. This show is the largest in the southeast. Hawaii N/R Idaho ID's program has not been active since 5/99. Since 12/13/99, I have been working diligently to understand the requirements and the needs of the program to resume state implementation. N/A Not applicable N/R No response F-2-2 ------- PROGRAM ACCOMPLISHMENTS Illinois SBAP has made significant strides this year in strengthening its formal relationship with the IL EPA Bureau of Air. Located outside the regulatory agency, the SBAP relies heavily on the BOA to identify potential impacts to small business and problem areas they encounter in small business compliance. A formal workplan and small business procedures have been developed and will be extremely beneficial to the program planning process. Indiana CTAP was involved in IDEM's Multimedia Initiative, which was implemented in July 1998 and ran through June 1999 in 5 industry sectors: metal finishing, wood furniture, foundries, electric utilities, and pharmaceutical manufacturing. During the course of the pilot, approximately 120 multimedia inspections were conducted, ranging from screening inspections to full-blown process-based inspections. Eight specific recommendations came forth from the pilot and are currently being evaluated by agency compliance/enforcement managers. As a result of implementing the pilot, most agency compliance inspectors now will conduct multimedia screening inspections during each regular facility inspection. In addition, IDEM has finalized our Self-Disclosure and Environmental Audit Policy. Both compliance assistance and inspection staff have roles in promoting the Policy to small businesses in the state. An IN Strategic Goals Pledge Program for metal finishers and publicly owned treatment works was kicked-off in November 1999. Metal finishers and POTWs pledge to work towards the goals outlined in the National Metal Finishing Strategic Goals Program. CTAP helped develop a Non-rule Policy document for the fiberglass industry regarding styrene emissions and continues to assist businesses involved in the rule making process for this industry. CTAP began a Childcare 5-Star program, the first of its kind in the nation, which had 53 participants in 1999. CTAP provided free lead risk assessments for 23 childcare facilities and over 1,500 homes in IN. CTAP collected over 700 pounds of mercury from homes in 1999 to be recycled. Seventeen schools signed onto the mercury pledge program in 1999. The 100% Club was announced in January 1999 with the application going out in January 2000 and due by March 31, 2000. This Club recognizes companies in full compliance with environmental regulations and rewards companies that go above and beyond their requirements. Governor O'Bannon signed the Greening the Government Executive Order on April 22, 1999, which requires all state facilities to double-side documents, use re-refined oil, and establish a recycling coordinator. The Order also created a Task Force to work on other P2 opportunities. N/A Not applicable N/R No response F-2-3 ------- PROGRAM ACCOMPLISHMENTS Iowa We had a multimedia program in place even before the air program started. The IWRC multimedia program and the IAEAP (SBAP) complement each other, provide clients with "one stop shopping" service, and make what we have to offer very attractive. In the past year, in addition to the core program, we were involved with the following projects. - A project to update the 1999 Resource Guide and make it available only electronically with search capabilities. This will be made available at the 2000 annual conference in MT. - An EPA/IDNR-funded project to provide one-on-one RMP development assistance (workshops) to affected companies. Based on pre- and post- workshop surveys, 63% estimated that it took them less than 12 hours (including 4 hours at the workshop) to comply with RMP requirements. 295 facilities received one-on-one assistance, 98% rated the workshop as excellent, and 40 companies requested on-site visits. - IAEAP developed industry-specific, spreadsheet-based emission estimation programs to generate emission inventories and estimates for permit applications. Input data are collected from small businesses using a 2-4 page industry-specific questionnaire. IAEAP developed programs for small manufacturing operations, dry cleaning facilities, printing operations, and grain handling facilities. These programs are continuously updated. Kansas We feel that our move to multimedia was necessary for the continued success of the program. By combining the P2 and SBAP services, clients were provided with comprehensive compliance assistance while P2 was promoted. In addition, a number of businesses have implemented Environmental Management Systems because of the highly successful workshops, manuals, and assistance provided by the technical assistance component of the program. EMS encourages not only environmental compliance, but P2 as well. This program strives to network with other agencies that provide not only environmental assistance but general business assistance (such as the SBA, SBDCs, and the Department of Commerce and Housing). This networking, which works both ways in referrals, provides the businesses with accurate information "the first time" and eliminates their need to search phone directories. To address nonpoint source pollution, we adopted the US Department of Agriculture Home*A*Syst materials for Kansas. This program is designed to help people identify environmental risks in their homes and surrounding property and is useful for both urban and rural populations. This program has been well received throughout the state. Many cooperative extension agents are now promoting it, and our office continues to facilitate the program. To reward underground storage tank owners for complying with regulations, we sent each compliant gas station a poster and window decal featuring a groundhog saying, "Thanks for the Tanks." Compliance information and our program information were included. We taped radio public service announcements for broadcast throughout the state that explained about the new regulations and gave our toll-free number for questions. Kentucky During 1999, SBSSCAP gave its second Small Business Air Quality Stewardship Awards. The awards were presented at a luncheon at the Lt. Governor's Mansion. The program has generated good will and publicity for all participants. Jefferson County N/R Louisiana We organized a 2-day strategic planning session in October 1999 at the LUMCON facility in Cocodrie, LA with the DEQ SBO to plan next year's goals. We presented the first P2 award in May to Gulf Wire Company. We also began a P2 audit program. Maine ME SBTAP is fully multimedia. N/A Not applicable N/R No response F-2-4 ------- PROGRAM ACCOMPLISHMENTS Maryland SBAP coordinated MD's participation in the National Metal Finishing Strategic Goals Program. This is a voluntary program developed under the Common Sense Initiative that encourages metal finishers to go beyond compliance. States, POTWs, and metal finishers all are eligible to participate. The SBAP hosted two meetings for potential participants in 1999 and anticipates more efforts for this program in 2000. SBAP was responsible for developing the regulations for MD's Small Business Pollution Compliance Loan Program. The loans are for upgrading or replacing air pollution control equipment. Businesses with 25 or fewer employees are eligible for the loans. The loans are up to $50,000 with a maximum term of 15 years, and the interest rate is tied to the state bond rate. The loan program will begin in 2000. Massachusetts The prospect of enforcement motivates use of assistance services better than anything else. Small companies often tell us they have not been visited by an inspector in many years. Michigan SBO - None. SBAP - SBAP trained more than 1,758 business, industry, regulatory, and consulting personnel during FY98-99 at 14 statewide workshops. The SBAP also provided a number of presentations to business, industry, and government personnel during the same period, attracting an audience of over 1,213 at 30 engagements. The technical service provided or customer service displayed is reflected in 3 letters of appreciation that were written by either industry or other state government agencies commending SBAP staff on the excellent level of technical assistance that was provided. Minnesota SBAP received the "Hassle-Free Government Award" for its participation with the MN Business Assistance Network (MnBAN) and the Government on Display (GOD) event. SBAP received the "Small Business Environmental Assistance Partnership Award" for its coordinated efforts with the MN Technical Assistance Program and MN's SBDCs. SBAP was reformatted by management from an air quality program that provided some multimedia assistance to an officially recognized, full multimedia program within the agency. This change also included the development of an agency-wide memorandum of understanding that authorizes SBAP to provide confidential compliance assistance within all environmental media. MN was one of 10 states to receive a Section 507 grant from EPA. The grant will be used to conduct and measure the effectiveness of a sector- based, nonregulatory compliance assistance initiative within MN's fiber reinforced plastics industry. SBAP created and published the "Environmental Guide for Small Businesses in Minnesota." This document was developed to provide businesses with a user-friendly means of accessing information regarding environmental and health and safety regulations , and as a resource for financial assistance. In addition to the hard-copy version, the guide also was posted on the MPCA's Internet site with hyperlinks to pertinent regulations, statutes, and other online resource sites. Mississippi Multimedia continues to work well with our program. Customers are confident that they can contact us to get answers in all areas of environmental issues. N/A Not applicable N/R No response F-2-5 ------- PROGRAM ACCOMPLISHMENTS Missouri The Pollution Prevention/Compliance Guides have been well received by industry. The guides are written in an easy to understand format providing the information necessary for the facility to comply with the regulations, but also providing P2 opportunities and ideas. The On-site Assessment Team is visiting many facilities across the state, and their services have been well received. Facilities visited by the on-site team receive a comprehensive, yet easy to understand, report illustrating the areas that need improvement and the areas where they are in compliance. The report also includes P2 tips and opportunities. The regulatory programs have commented that when a facility submits an application for a permit or other required documentation that the Technical Assistance Program has helped to complete, the application or document takes much less time to review and process. The evaluation surveys indicate that the technical assistance provided is very helpful and that many facilities achieve compliance partly due to the information provided through these efforts. Montana We are hosting the National SBO/SBAP conference in Missoula in June 2000 and have been doing a lot or work in preparation for that event. We have initiated a small (10%) funding change to help facilitate a move to multimedia. We won a competitive Section 507 grant from EPA and are in the process of implementing that project. Nebraska NE's program has progressed over the past seven years and will continue to grow. The number of site visits and assistance provided continues to stay at a high level. Current efforts are being addressed that will allow compliance assistance to be reported by all sections of the agency. This will provide a better picture of all assistance that is produced by sections other than SBAP. Nevada N/R New Hampshire The program continues to be warmly received by the business community. We continue to reach into new business sectors as new regulations are promulgated and affect increasing numbers and types of businesses. We still see an increase in the number of referrals from other media programs to provide holistic assistance to small businesses. NH was also one of 3 states awarded grants to implement the PrintSTEP program at the state level. This grant will allow us to accelerate a multimedia outreach and compliance assistance effort to this important sector. This will be the third major industry sector to benefit from our goal of providing multimedia assistance to businesses. New Jersey SBO/SBAP received one of 10 national Section 507 grants from EPA to publicize the state program. New Mexico N/R N/A Not applicable N/R No response F-2-6 ------- PROGRAM ACCOMPLISHMENTS New York Considering its small staff size, the SBAP provided a significant volume of technical assistance to small businesses in New York State once again in 1999. The SBAP provided off-site assistance via the hotline to nearly 1,200 small businesses and their support groups (nearly 100 calls per month, on average), conducted 15 on-site air audits, and completed 89 state facility permits and registrations (up from 66 in 1998). SBAP generated several technical outreach materials in 1999 that were well received by businesses: two guidebooks (Choosing an Environmental Consultant: Guidance for Small Businesses and Ventilation and Vapor Barrier Systems for Perc Drycleaning Operations), two brochures (Accomplishments of the Small Business Assistance Program: 1994-1998 and On-Site Technical Assistance for Clean Air Act Compliance), and two issues of the program newsletter, Clean Air News, mailed to over 5,000 per edition. Two of these publications, Choosing an Environmental Consultant: Guidance for Small Businesses and On-Site Technical Assistance for Clean Air Act Compliance, received awards from the Mohawk Chapter of the Society for Technical Communication during their annual publications competition. SBAP was pleased to be awarded a cooperative agreement with EPA to conduct outreach and technical assistance to gasoline stations with Stage II vapor recovery equipment. This multi-year effort is designed to quantify the benefits of compliance assistance by bringing affected stations into compliance with a state regulation requiring them to test their equipment every five years. Present compliance rates are extremely low, so the SBAP is undertaking a multi-pronged effort to inform and assist affected stations. SBEO received letters of appreciation from the New York/New Jersey Masters' Association of Metal Finishers and the New York City Auto Body Craftsmen's Guild for informative presentations made to their members on air quality regulations and environmental compliance. SBEO services are increasingly in demand. Regulations and policies have been adopted that will increase SBEO activities significantly. New federal standards and state implementation of the regulations have changed permitting requirements and procedures causing many businesses to reevaluate their emissions and compliance methods. The SBEO will continue providing outreach and compliance assistance to the small business community, including assisting businesses to locate environmental compliance financing options. Increased outreach will result in increased business use of the hotline and SBEO services. North Carolina NC's environmental department established a new Customer Service Center (CSC) to permanently replace our former Environmental Permit Information Center (EPIC). The CSC maintains a hotline to answer or direct any question involving matters handled by the Department. The small business hotline was rolled in with the CSC hotline. Overall, approximately 2,500 calls were handled. CSC's role is to provide accurate, timely information on all of the Department of Environmental and Natural Resource programs. Making environmental information more accessible and understandable to the public is a major goal. CSC developed more integrated information on all environmental programs. This is extremely valuable to small businesses with environmental requirements, which in the past have been too complex and segmented. This provides greater multimedia assistance opportunities. Over the next year, a primary focus will be to develop an improved small business and permit information web site. SBO/SBAP was called upon during the national emergency last fall after Hurricane Fran. Our staff manned a hotline and disseminated information to answer all environmental questions related to the hurricane and cleanup activities. North Dakota None. N/A Not applicable N/R No response F-2-7 ------- PROGRAM ACCOMPLISHMENTS Ohio SBAP - 99% of our site visit customers said they would contact us again for help. In 1999, the SBAP staff traveled 29,073 miles in providing on-site assistance to 144 companies located in 44 of 88 OH counties. Agency field staff often have expressed their thanks for helping small businesses rectify violations. SBO - We believe that local elected officials have better and more trusted access to small businesses in their communities. Accordingly, we have placed a heavy emphasis on outreach to state legislators, and county and city/town officials. The outreach provides them with information about how CAA requirements impact small businesses and where help can be found. This is critically important in a state where most media coverage focuses on legal battles against proposed US EPA standards. Oklahoma Our most prominent work has been representing the small business community in the rulemaking process. Through our CAP and SBAP staff, we have provided needed representation to ensure that new or revised rules are not unfairly burdensome to small businesses. Oregon N/R Pennsylvania The Pollution Prevention Assistance Account was developed. This low-interest loan program is available to small businesses that want to undertake P2 and energy efficiency projects. The Pollution Prevention/Energy Efficiency Site Assessment Grant Program was begun. This program provides up to $5,000 to small businesses that want to hire a private consultant to conduct a P2/E2 assessment. Puerto Rico The SBO office was established. The SBO has taken a more active role in the SBTCP. A cooperation agreement was signed between the Environmental Quality Board and the Commerce Development Administration last December. The agreement combines funds to operate the SBAP and SBO, increasing the participation of the Commerce Development Administration and its contacts in the small business community to enhance awareness of environmental regulations. The results of this agreement will be in place by the next reporting period. We developed promotional material that describes our office and services. Rhode Island MOU for autobody shops, emphasizing P2 and occupational health. Policy created for using evaporators in electroplating and metal finishing operations. South Carolina N/R South Dakota N/R Tennessee 60% of the dry cleaners taking the certified environmental dry cleaner test had attended our program's test preparation workshop. SBAP dry cleaner workshop had an attendance of 25, while other regulatory assistance providers offering workshops had a 0-1 person attendance. Popularity of the 112(r) workshops resulted in scheduling additional workshops. N/A Not applicable N/R No response F-2-8 ------- PROGRAM ACCOMPLISHMENTS Texas To provide better service to small businesses and leverage our resources to gain the maximum effort for our dollar, the SBLGA operates the site visit program. We offer free, confidential site visits to small businesses by contracting with a private environmental consultant. 228 site visits were conducted in 1999 for 171 businesses (includes follow-up visits). Compliance increased by an average of 10% for all industries combined. Placed 20 compliance assistance staff in regional offices. Field staff are able to provide personal, individual contact with the local regulated community, which is key to increasing environmental awareness and compliance. Conducted workshops for surface coaters (4 workshops for 115 attendees) and metal finishers (2 workshops for 105 attendees) throughout TX in cooperation with local governmental and industry organizations. Increased industries' awareness of and compliance with environmental requirements and forged partnerships between SBLGA and these industries. Conducted 42 site visits for small businesses along the TX/Mexico border region with EPA grant funds. Developed Small Quantity Generator Guide and have distributed over 7,000 copies to date. Submitted "FYI" articles with timely topics of interest to small businesses and local governments to over 650 newspapers throughout the state, and submitted over 800 press releases announcing the placement of compliance assistance staff in the field. Revised site visit checklists to include greater emphasis on wastewater, stormwater, and P2. Called businesses and local governments that had been issued default orders to help them through the enforcement process. Called businesses and local governments with expiring wastewater permits to remind them to renew before the deadline passed. Instituted Compliance Commitment Partnership program through which businesses that agree to implement all recommendations made by the contractor during a site visit and are accepted into the program receive a one year reprieve from routine inspections. Eleven businesses have been accepted into the program to date. Offered a week-long waste reduction training to 26 SBLGA central office and field staff, sponsored by the Tennessee Valley Authority. Staff learned the philosophy of waste reduction and industry-specific P2 technologies through lectures and site visits. Participated in the Small Business Summits sponsored by Lt. Governor, Rick Perry. The Texas City project helped this city receive an EPA grant to provide assistance to small businesses. Utah N/R Vermont One person program with no advertisement. Virginia In August, the SBAP, through a partnership with the State Advisory Board on Air Pollution (an ad hoc group appointed by the VA State Air Pollution Control Board), launched the VA EnviroMENTOR Program on a pilot basis. This program, which was created as a result of this partnership, will provide volunteer mentors to assist small businesses achieve compliance or institute P2 activities. We are extremely grateful for the guidance and assistance of the great state of TX for its help in originating the TX program and providing counsel in helping us develop our program. N/A Not applicable N/R No response F-2-9 ------- PROGRAM ACCOMPLISHMENTS Virgin Islands We are almost complete in our inspection of automobile repair and refinishing shops on St. Thomas and St. John. There is no personnel on St. Croix, so work has not begun on that island to date. Washington SCAPCA - We initiated a Business Recognition Program to encourage compliance and timely submittal of emission-related information and fees. If three criteria have been met, the business receives a window decal and will be listed in an upcoming print ad for "doing their share for clean air." West Virginia The creation of Natural Gas Compressor Facilities and Hot Mix Asphalt Plant General Permits has simplified and streamlined permitting for these industry sectors. SBAP staff expended a large proportion of time and effort on two agency initiatives: Regulatory Revision, which included rewriting minor source permitting requirements in a stakeholder process, and Permit Benchmarking, comparing WVs permit process to other states. Both should benefit small businesses through the eventual streamlining and simplifying of agency procedures. Quantifying the improvements is impossible at this point. This is one of the problems if programs over-emphasize conventional performance measures. Wisconsin The 14,042 businesses reached by the W SBCAAP were basically handled by one person. This outreached was done in addition to the W program maintaining a great deal of involvement on national activities, including the National Steering Committee, National Conference Planning Committee, National Network Meeting in Dallas, National Pollution Prevention Roundtable participation, and NACEPT committee. Wyoming We are especially excited about progress currently being made with our Compliance Assistance Grant Project as well as the Clean Snowmobile Challenge 2000 design competition that we are actively supporting. Both projects have great potential to improve environmental performance of businesses in our state and, in turn, the quality of the environment in which we live. N/A Not applicable N/R No response F-2-10 ------- TABLE F-3 TIPS AND BARRIERS RECOGNIZED BY THE PROGRAMS PROGRAM TIPS/BARRIERS Alabama N/R Alaska N/R Arizona N/R Arkansas Tips We have had success in communicating pollution in terms of economics. When you are polluting, you often are losing chemicals or commodities that you have purchased, which simply is bad business. California Tips ARB continually updates the organization's web site so that information is readily accessible and current. In 1999, we achieved an 89.3% hit rate via search engines through creative use of meta tags. This means that out of the 4 million hits on our web site -- a remarkable number, approximately 90% of requests -- found some information related to their inquiry. South Coast Tips Our SBO and SBAP often are the first group in the agency to become aware of problems affecting small businesses. For example, in 1999, many dry cleaners who had let their permits lapse became subject to strict toxic standards that required them to either buy new machines or to retrofit their equipment with expensive controls. SBAP staff worked with the Engineering, Legal, and Compliance staff to help coordinate how these businesses would be handled to allow them time to come into compliance. SBAP staff will continue to help these businesses understand and obtain variances or orders for abatement. In 1999, SBAP staff participated in a recordkeeping simplification study that included taking proposed new forms out to about 50 small shops and getting opinions of the business owners. This information would have been difficult to obtain without the reassurance of using SBAP staff who could help the shop owner determine if he had been keeping proper records without the risk of being found in violation. In several cases, these visits resulted in the shop owners requesting an on-site consultation that led to the permitting of several pieces of equipment. Colorado N/R Connecticut Tips We continue to have success in delivering a multimedia message to sector-specific small business categories. We have concentrated our outreach efforts on new regulatory requirements, but used these opportunities to provide small businesses with a refresher on other regulatory areas that affect them. Delaware N/R District of Columbia Barriers One barrier for our program has been the inability to hire full time SBO and SBAP staff and provide funding resources to accomplish set program goals. Another barrier has been the inability to maintain an active CAP membership, which will hopefully be re-established in 2000. N/A Not applicable N/R No response F-3-1 ------- PROGRAM TIPS/BARRIERS Florida Barriers CAP appointments are legislatively mandated, but do not establish a service term. This creates a difficult situation when CAP members do not participate yet want to "stay on" the CAP. Georgia Tips In 1999, we used local dry cleaners to host our workshops. We selected dry cleaners that were prominent in their communities and members of the South Eastern Fabricare Association. This worked very well for us in some of the cities visited. The dry cleaners received a call from their local hosts inviting them to attend the workshops. We also dressed casually instead of wearing jackets and ties. We intentionally created a non-threatening, relaxed atmosphere. Hawaii Barriers Appointment/establishment of the CAP continues to be an issue in HI. The Clean Air Branch, as well as every other environmental health program, currently uses advisory boards (ad hoc and formally established) to a great extent. The formal legislative appointment process for the CAP serves as a barrier (logistical and practical) to HI ever establishing a CAP. Idaho N/A Illinois Barriers Program marketing continues to be a challenge. Although relationships have been built with the business community, program visibility is directly proportional to impacts to their industry. General program pieces or marketing often are the most difficult. Reaching businesses not involved in trade groups is a particular challenge. Indiana Tips IN's SBAP is multimedia, which enables us to better assist businesses. In our guidance documents and manuals, we include other agencies' rules and regulations when they tie into or overlap with our regulations. This helps clarify the roles of the various regulatory agencies that small businesses must work with and allows small businesses to see all of the regulations for a product or activity. Barriers IN's CAP sometimes meets on an irregular basis and provides limited guidance. A more active CAP with a full panel would provide greater guidance for the IN SBAP. Iowa Tips Effective assistance to small businesses needs to be more than "why" and "what to do." Details of "how to" should be an integral part. Generic guidance materials, workshops, and seminars are not very effective for "typical" small businesses. Targeted and detailed specific information is better received and is more useful. Barriers Resources, staff, adequate training. N/A Not applicable N/R No response F-3-2 ------- PROGRAM TIPS/BARRIERS Kansas Tips We are proud of our dry cleaner compliance calendar, because it conveniently combines all regulatory checklists the cleaners need. We anticipate using this approach with other industries. However, the dry cleaners are easy because the KS Department of Health and Environment has a very good list of who they are. (They have to register in order to buy solvent.) Also, the environmental regulations are nearly the same for each cleaner; we only had to make six different calendars. Barriers We continue having difficulty in maintaining an effective CAP. Appointing authorities have many other duties, and the CAP does not seem to be a priority, although we have tried to impress the importance of maintaining an effective panel. Kentucky N/R Jefferson County N/R Louisiana Tips Hold quarterly CAP meetings and keep them abreast of new developments in environmental affairs that may impact small businesses. SBAP staff took field trips to two small businesses to see their operations and learn about their industry. Maine Tips Since our SBTAP has only two staff, it is very important to use the skills and expertise of staff from other programs and organizations to assist in delivering services. Maryland N/R Massachusetts Tips Use the requirements for emergency planning to promote prevention, since everyone has to have emergency plans. Focusing on this also involves local officials who have to respond in emergencies. This connects them to the facility's preventive efforts and the idea of chemical use reduction. Michigan Tips (SBAP) The SBO and SBAP must work closely with the air quality regulatory program PRIOR to initiating any outreach. For example, the Ml SBAP has worked with its air quality regulatory agency along with business and industry to address various air quality compliance issues before workshop implementation. By holding a "peer review" training session before the actual statewide business and industry workshops, SBAP is able to modify its presentation materials to reflect the comments and suggestions of business, industry, and regulatory personnel to make the workshop presentation as clear, concise, and smooth-flowing as possible. N/A Not applicable N/R No response F-3-3 ------- PROGRAM TIPS/BARRIERS Minnesota Tips Maintain and market the hotline. Have it answered by a live voice. Publish a regular newsletter. Post all newsletters, case studies, and publications on the Internet. Do on-site visits. Attend trade association conferences. Network with all types of small business assistance providers (public and private). Develop and distribute compliance assistance spreadsheets. Make them available online. Survey regulatory and assistance staff to help develop outreach initiatives and fine tune workplans. Develop sector-specific compliance assistance tools. Use EPA's SBO to help interface with EPA regulatory programs. Barriers Funding, always1 Rules that don't make sense. Conflicting attitudes and philosophies regarding nonregulatory compliance assistance. Inconsistent enforcement activities. Mississippi N/R Missouri Tips The follow-up efforts used by our on-site assessment team give an indication of the compliance rates achieved through assistance activities. Montana Tips We are whole heartedly in favor of newsletters. Nebraska Barriers Education receives a great deal of praise as well as grants. Yet the SBAPs are not considered educators. The SBA programs are educators, and each site visit should get the same credit as one or two hours of classroom education. Each time a permit is required and our program assists in the application process, we should get the same credit as an inspection. For every small business that allows a site visit and does not need a permit, we should get credit for educating the business. N/A Not applicable N/R No response F-3-4 ------- PROGRAM TIPS/BARRIERS Nevada N/R New Hampshire Tips We have found that partnering with town and city code or building departments is a very valuable way to "get the word out" and to identify additional businesses. Code and building officials are quite knowledgeable about the type of businesses in their areas and are more than willing to partner with programs that can augment their knowledge. As most towns and cities require some type of permitting before construction begins, this is an excellent time to advise business operators of environmentally-related issues that usually are less expensive to address during the planning process than after construction. Barriers We continue to be challenged by the difficulty in developing accurate business listings. Although we try to maintain accurate database listings, this is not always practical given the number of businesses that enter or exit various industry sectors each year. We continually look for new and innovative ways to keep our lists reasonably accurate, but realize they never can be. New Jersey Tips SBO/SBAP work with trade and business groups to sponsor or cosponsor events to ensure member participation and to provide a greater outreach with little or no cost to the state program. New Mexico N/R New York Barriers The regulatory agency's CAP representative should come from a division other than Air to avoid any potential conflicts of interest. North Carolina Tips We established a customer service center that helps businesses of all sizes with all environmental questions. Many small businesses call this hotline because they don't have the expertise to answer the questions themselves. As small businesses are identified, they are teamed up with an SBAP engineer often to receive far more help than they ever knew to ask for. Barriers We continue to have significant problems getting timely CAP appointments. The specific requirements for minority and majority legislative appointments, the turnover of executive staff, and appointments to a purely advisory board have created problems. Since next year is an election year, we are guaranteed to have even more trouble. For this reason, we will pursue a non-appointed, broad-based collection of individuals from small business, trade associations, etc. to act as an advisory board. North Dakota Tips Mailings are useful, but on-site visits are more helpful in answering specific questions, problems, etc. N/A Not applicable N/R No response F-3-5 ------- PROGRAM TIPS/BARRIERS Ohio Tips To optimize your on-site assistance credibility, demonstrate your capabilities in a face-to-face meeting with inspectors. The SBAP staff must know how inspectors think and what they look for. Any mass mailings should be placed in an Agency letterhead envelope, because the business is more likely to open it. Barriers Getting new CAP members appointed is slow. Expanding the SBAP budget and moving to multimedia have met with resistance due to loss of control issues among top management. Oklahoma Tips Our program has benefitted from being housed in the Customer Service Division within the Agency. This has allowed us, through the years, to develop relationships with key staff members and decision-makers in the regulatory division. This is a very unique approach to regulatory agency organization -- that is, to have a group that includes SBAP that is dedicated to providing non-regulatory technical and regulatory assistance to business and industry in OK. This gives us autonomy from the regulatory groups, but still allows us to network internally. Oregon Tips The dry cleaner technical assistance outreach that we did last summer was very well received. The dry cleaners were happy to see us and get help from us. We haven't tabulated all the results from the technical assistance visits, but preliminary results indicate that compliance has increased. The only barrier to this program was that is labor intensive. Pennsylvania N/R Puerto Rico Tips Maintain records of all businesses that we have provided orientation about the program and the regulations. Strengthen alliances with the commercial and academic sectors that may be affected by the regulations. Barriers Difficulties in recruiting a new office director. Rhode Island N/R South Carolina N/R South Dakota N/R N/A Not applicable N/R No response F-3-6 ------- PROGRAM TIPS/BARRIERS Tennessee Barriers Competition for funding among assistance providers is not beneficial to businesses. EPA provides coordination support but no monetary support to states to assist in developing the national perspectives that impact states. Meetings are held to discuss issues including funding and policy, but funds are not available to provide participation in the discussions. EPA should facilitate equal partnerships. Equal funding would go a long way to foster the partnerships. Texas Tips Personal, individual contact with the regulated community is key to increasing compliance. This effort is furthered by the compliance assistance staff being placed in the 16 TNRCC regional offices. Send regular postcard regulatory updates to industries affected or in need of compliance assistance. In 1999, SBLGA mailed over 1,200 postcards to licensed dairies and over 1,500 postcards to metal finishers. Send new rules and rule changes through Rules Review Committee. In 1999, sent 10 regulatory documents to committee members for comment. Send new and modified documents through Plain Language Committee to review for clarity and ease of understanding. Partner with local organizations to facilitate environmental awareness and compliance among the regulated community. This effort will be enhanced by regional SBLGA staff. Barriers Having adequate time and staff resources for personal, non-contact site visits. Federal and state documents often are not provided to the regulated community in bilinugal format, when needed, to facilitate understanding and compliance by non-English speaking members. Utah N/R Vermont Tips Due to the crossover in requirements between RCRA and VOSHA programs, we have found it advantageous to point out these requirements to the small businesses and to always recommend the most conservative requirement so businesses can comply with both programs. Virginia Tips EPA, through the 105 Grant process, could make money available for on-site activities that could allow programs to move beyond a selective assistance approach. Barriers Resource constraints have hampered the ability to provide on-site assessments on a continuing basis. Virgin Islands Barriers Lack of personnel is prohibiting the program from moving as fast as we would like. N/A Not applicable N/R No response F-3-7 ------- PROGRAM TIPS/BARRIERS Washington Barriers Many of our sources rely on their installer/contractor/consultant to advise them or to complete any permits necessary when adding new or modifying existing equipment rather than contacting SCAPCA directly. This sometimes results in negative enforcement-related scenarios, which could have been avoided if SCAPCA had been involved in the initial efforts. "Consistency" in written permit conditions and field enforcement is important. West Virginia None. Wisconsin Barriers We still struggle with measuring compliance assistance and the effects of our efforts. Compliance assistance and P2 activities cannot be measured and counted like enforcement activities. We cannot get the "beans" counted and recognized in the same way as enforcement activities. How do you measure the effectiveness of helping a business figure out they DO NOT need an air permit? Wyoming Tips The CAP has a full complement of nine members, one of which attended the national SBO/SBAP conference in Tampa. This CAP member provided an excellent briefing on the various activities and programs being pursued by other state's programs to fellow CAP members. The CAP concurs with ongoing SBO and SBAP outreach activities through a number of channels, including mailings, on-site visits, presentations to business organizations, web site information, and association with other assistance providers. N/A Not applicable N/R No response F-3-8 ------- TABLE F-4 SUCCESS STORIES AND CASE STUDIES PROGRAM SUCCESS STORIES AND CASE STUDIES Alabama Often the Ombudsman office receives calls from businesses that are trying to track down the answer to a regulatory question or just find information on an environmental topic. Many of these callers express gratitude for the answers provided by the office. The common dialogue is, "I have talked to 6 or 8 different people before getting to your office and you are the first one that has understood what I am looking for and has shown an interest in helping me." In this position, it pays to keep abreast of the regulations and hot news at the state and federal level. When it's a free call, you never know what kind of questions you might be asked. Alaska N/R Arizona N/R Arkansas We have had a great deal of success with our aerial applicators "fly ins." Pilots fly to seminars at locations around the state. The seminars educate the pilots on pollution issues, storage tank regulations, and Department services, such as our loan program. Our foundries initiative targeted a limited industrial sector with success. Finally, our loan program has been very effective in helping small gas stations meet underground tank regulations. California One of our success stories is the concept of a "pre-permit" meeting. A permit engineer is available to meet with the applicant to help them complete application forms and to explain the applicable rules and regulations. This helps the applicant and also helps the district permit engineer to get a more "complete" permit application. (Submitted by the Ventura County Air Pollution Control District.) South Coast The Expired Permit Courtesy Call Program has been very successful in keeping customers from inadvertently losing their permits and becoming subject to penalties and costly BACT requirements. About 600 permits were reinstated as a result of this program in 1999. This improved the noncompliance rate for a wide range of small businesses without placing an additional burden on agency inspectors or attorneys, and prevented nearly 600 permit applications from being added to the workload of the agency's engineering staff. The customers appreciate having the problem brought to their attention before being found in violation by an inspector. The SCAQMD's Fee Review Committee, chaired by the Public Advisor (our SBO), is in a good position to detect situations that might warrant suggesting changes to the district's fee schedules. In 1999, the SBAP noted inconsistencies in how a certain permit fee exemption was being applied to small businesses. The exemption applied to small businesses that had no prior history with the AQMD. To solve the problem, a memo was sent to all engineering managers. In addition, whenever the SBAP staff helped complete an application that was entitled to the exemption, they included a note to the review engineer highlighting the exemption. This action saved the businesses from paying a 50% surcharge for their permits. The SBAP staff have fostered relationships with local fire departments and hazardous waste agencies to help publicize several district rules that affect solvent cleaning operations at auto repair shops and machine shops. Although these shops are not required to have air quality permits for their equipment, they must use water-based cleaning systems. Since these shops are regularly visited by the fire and hazardous waste inspectors, we rely on these agencies to inform the shop owners of the requirement and to notify us of noncompliance so we can follow up with phone calls and information. N/A Not applicable N/R No response F-4-1 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Colorado SBAP assisted various restaurants regarding opacity violations through a non-regulatory approach. The restaurants agree to install appropriate control equipment. This avenue is much quicker than an enforcement route. SBO assisted a "financial hardship" dry cleaner case. As a result, the owner will be able to obtain brand new equipment and continue to operate versus being closed down due to not complying with regulations. Connecticut N/R Delaware N/R District of Columbia An effective program change has been an increase in the allocation of time and resources for the SBO and SBAP. Florida Mailed over 1,800 calendars to dry cleaning and laundry services to improve compliance. Held statewide "Printers Protecting the Environment" workshops. Hosted National SBO/SBAP Conference and developed conference planning manual for future conferences. Mailed over 1,500 notices of program change to asbestos industries. Georgia During 1999, a dry cleaner was referred to us for assistance by one of the enforcement programs. We visited the cleaner and determined that his compliance problems centered around his lack of familiarity with the dry-to-dry machine and recordkeeping. We assisted him with the recordkeeping requirements and brought in a Union retailer to train him in the proper use of the machine. Union provided their assistance at no charge to us or the dry cleaner. The facility was reinspected several months later by the enforcement program and was found to be in compliance. Hawaii SBAP - Multimedia dry cleaning calendar. SBO - Ability to gain trust with targeted industry representatives, such that advice is sought and given in enforcement actions. Ability of SBO/SBAP to secure full or partial waiver of air fees is consistent with sentiments expressed by the regulated community. Idaho N/A Illinois Use of the enforcement schedule has been particularly successful for our program. N/A Not applicable N/R No response F-4-2 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Indiana Childcare facilities - Through free lead risk assessments, we were able to successfully locate and assist many childcare facilities that had high lead levels in their drinking water, paint, soil, or dusts. We also realized that the asbestos inspections were sometimes cost-prohibitive for these facilities, so we pursued training for our staff to become asbestos inspectors and will implement this program in 2000. Wood furniture/fiberglass/plastics - Worked as an intermediary in several instances to help write more appropriate permits for these industries. We have been able to reduce pollution through assistance in several industries. Our outreach efforts related to methylene chloride have seen considerable reductions in the air releases. We have been able to assist metal finishers by providing them a multimedia approach to their industry. We are beginning to assist schools by educating them on issues such as lead and mercury, and the use of Integrated Pest Management. We assisted IDEM's Office of Air Management with the creation and distribution of a fact sheet announcing and explaining the new environmental rules for cold-cleaning degreasing operations in IN's non-attainment counties. N/A Not applicable N/R No response F-4-3 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Iowa 1. Case Study of Company A Background Company A is a pontoon boat manufacturer located in IA. Company A employs 25 full time employees. The facility completed the Emission Inventory Questionnaire (EIQ) as required by the IA Department of Natural Resources (IDNR) in 1993. On the basis of the emission estimates, Company A was classified as a major source and paid a fee of $70 per year. After the 1994 enactment of the Title V program, Company A, being classified as a major source, was required to obtain a Title V operating permit. The IDNR notified Company A of this requirement. On-Site Assistance and Air Emissions Review Company A approached the Iowa Air Emissions Assistance Program (IAEAP) for assistance with Title V operating permit requirements. IAEAP staff visited the facility, reviewed the air emission sources, and collected the necessary information to complete a facility-wide emissions inventory for Title V applicability. During the visit, IAEAP determined that air emissions were due to welding, natural gas space heaters, and foaming operations. Foam is used in the hull of boats to provide strength and to act as a floatation material in case of accidental leakage. This foam is formed from a chemical reaction between 2 reactants supplied through two different pressurized tanks to a spray gun. Company A was classified as a major source due to emissions from foaming operations. A review of the EIQ determined that the facility had not included its welding emissions. Company A also was out of compliance with construction permit requirements for their welding operations. On-Site Assistance and Technical Assistance Audit IAEAP determined that initial calculations in the EIQ did not account for the polymerization reaction between the chemicals while calculating the potential emissions, which were estimated at over 900 tons per year. The EIQ estimate assumed the chemicals used in the polymerization reaction are volatile and toxic. However, the reaction product obtained is a non-volatile polyurethane foam. Since the reaction time between the chemicals is less than 2 minutes, very little volatilization occurs, and air emissions are less that previously thought. The potential emissions from the foaming operations were recalculated and determined to be less than 2 tons per year. This put Company A below major source thresholds, thus eliminating operating permit requirements. With IAEAP assistance, Company A's status downgraded from a major source to a minor source. This eliminated the need to undergo the extensive Title V Operating Permit procedures and the Title V fee of $70 per year. 2. Case Study of Company B Background Company B is a grain handling facility and an animal food manufacturer located in IA. The owners of this facility also operate two other facilities in the state. Company B has about 30 full time employees. The facility completed EIQ as required by IDNR in 1993. Company B was classified as a major source, required to complete a Title V permit application, and pay emission fees. On-Site Assistance and Air Emission Review At the request of John McCully, Senior, Chairman of Company B, the IAEAP visited the facility, identified air emission sources, and collected necessary information to complete a facility-wide emission inventory. The IAEAP found that the 1993 EIQ incorrectly included fugitive emissions in the Title V applicability. On-Site Assistance and Technical Assistance Company B was not subject to New Source Performance Standards (NSPS), so fugitive emissions should not have been counted towards Title V applicability. As a result, their regulatory status was downgraded to "minor." This eliminated the need to undergo extensive Title V operating permit N/A Not applicable N/R No response F-4-4 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Iowa (cont) procedures for at least two of their three facilities and the associated fees. A Title V permit would have forced the company to hire an outside consultant at considerable cost. McCully was pleased with the services provided by IAEAP and has been very supportive of its efforts to reach out to small businesses in the state. As past president of the Grain Association of Iowa, McCully says of the IAEAP, "Your (program) is one of the better run government agencies to work with." 3. Case Study of Company C Background Company C is an independent, 12-employee IA facility that produces custom aluminum and zinc castings for diverse manufacturers. On-Site Assistance and Air Emissions Review In February 1996, Company C requested assistance from IAEAP to determine air permitting regulatory requirements. After a review of its operations and air emission sources, IAEAP identified the sources and collected necessary information to complete a facility-wide air emissions inventory. Company C needed air quality construction permits for two existing casting emission sources (Emission Point #1 Zinc Casting Unit and Emission Point #2 Aluminum Casting Unit). Company C also would need construction permits for two additional (new) casting sources that it planned to install in the near future (Emission Point #3 Zinc Casting Unit and Emission Point #4 Aluminum Casting Unit). Necessary information was collected to complete a facility-wide emissions estimate for the construction permit applications. On-Site Assistance and Technical Assistance After completing the initial air emission review, the IAEAP assisted Company C in completing construction permit applications for the existing and new zinc and aluminum casting units. There were four separate permit applications. These applications subsequently were approved by IDNR, and construction permits were issued for the four sources. IAEAP and Company C identified a concern about the approved permits. Particulate matter (PM10) stack testing and opacity testing were required for Emission Points #1 and #2. PM10 testing for two stacks costs approximately $8,000, while opacity testing costs $600. IAEAP worked with Company C to propose an alternative stack testing regime to IDNR. We proposed to test one stack and do additional testing only if the first test results showed excedence of allowable standards. IDNR agreed with our proposal with a written response. The PM10 stack test was completed April 3, 1997, and data indicated the stack has passed. Company C saved $4,600 on their stack testing requirements. IAEAP also assisted Company C in developing an emissions inventory to document their "non-major" status. Currently, Company C is in compliance with state and federal air emission requirements. IAEAP, working alongside Company C and IDNR, dealt with this situation in an efficient and cost-effective manner. 4. Case Study of Company E Background Company E is an independent trailer manufacturer and repair facility in IA that employs 60. Major production activities include metal fabrication and painting. On-Site Assistance and Air Emissions Review Company E approached IAEAP in February 1993 seeking legal assistance in determining regulatory requirements for air emissions. After reviewing emissions at their facility, IAEAP determined that Company E was out of compliance with state air quality construction permit requirements for the two spray booths. Necessary information was collected to complete a facility-wide emissions estimate to use in the construction permit applications. N/A Not applicable N/R No response F-4-5 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Iowa (cont) At the time of the initial IAEAP review, Company E was using solvent-based paint. Hazardous waste generated from painting operations was approximately 220 gallons per month, which incurred a disposal cost of about $2,000 per month. On-Site Assistance and Technical Assistance IAEAP noted that under the CAA, this would classify Company E as a major stationary source. IAEAP recommended that Company E consider switching to a powder-based coating system and explained how replacing the conventional solvent-based system would substantially decrease potential VOC emissions. Through this decrease, Company E would be reclassified as a non-major source and their regulatory burden from air emissions would significantly be reduced. The switch also would reduce hazardous waste generation and associated disposal costs. IAEAP provided Company E with a list of suppliers of alternative coating systems and assisted in evaluating and qualifying appropriate systems. Company E also received assistance in testing procedures, characterization, and disposal of solid wastes from the IWRC's On-Site Review services. Company E contacted suppliers of alternative coating systems, evaluated a number of options, and switched to powder coating in June 1994. The paint booth filters were replaced, and new coating application equipment and accessories were bought at an estimated cost of about $50,000. All outdoor paint booth exhausts were eliminated with the installation of an indoor recirculating air system. The existing bake oven continued to be operational with the new powder coating system with only an increase in the drying temperature. Company E considers their product quality to have improved from "very good" to "excellent" with the new system. VOC emissions were reduced to nearly zero with the new powder coating system. Since this reduction reclassified Company B as a non-major source, they are no longer required to meet Title V Operating Permit requirements. Wastes generated from the powder coating system were tested and shown to be non-hazardous. This eliminated hazardous waste generation from the coating operation and associated disposal costs of $2,000 per month. By removing outdoor exhausts from the paint booth and installing the recirculating system, Company E also eliminated the need for a construction permit and reduced the building heating cost in the winter. Finally, the cost of paint material per trailer was reduced. Kansas We worked cooperatively with KDHE and the American Foundryman's Society to deliver a workshop for foundries. Many of them were very surprised at the regulations to which they were subject. We were able to answer numerous questions and secure two site visits as a result of the workshop. Both site visits resulted in significant improvements in compliance. Risk management plan information was presented to several trade associations (propane dealers, fertilizer dealers, and water treatment facilities) and to local emergency planning commissions in a series of workshops. This information was very timely and generated a lot of interest. The workshops were done in conjunction with existing organizations, which leveraged the delivery. A metal finishing workshop was held with the support of the major airplane manufacturers in Wichita: Boeing, Raytheon, Lear, and Cessna. Many "job shops" attended, as they supply parts to the major manufacturers. Kentucky AQRSB prepared a second pamphlet of new success stories with help from KBEAP, the CAP, and DAQ, which will be distributed in 2000. Jefferson County N/R Louisiana Gulf Wire Corporation, located in New Orleans, received the first P2 award for a small business. The company reduced its use of trichloroethylene, a regulated hazardous chemical, by 20%. This chemical is used to clean the welding wire produced by the company. Maine N/R Maryland N/R N/A Not applicable N/R No response F-4-6 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Massachusetts The development of model integrated emergency plans was a success. We hoped that we could demonstrate that companies taking the trouble to integrate their plans also could be motivated to make those plane preventive in nature. The companies that we worked with did indeed use the emergency planning process for reducing chemical use risk, which typically focused on deciding what to do after an accident. For example, one company redesigned its process to reduce the risk of loss from pumping operations. Another reduced shipments of chemicals to its facility. Other activities included enclosing transfer operations to reduce volatization, adding secondary containment, improving training, and reviewing chemical use to reduce quantities. Michigan SBAP received a tremendous response to its emission inventory reporting workshops that took place from December 1998 to February 1999. More than 1,500 business and industry personnel received instruction on Mi's new electronic emission inventory system. SBAP also received a great response to a non-traditional type of workshop on fugitive dust in which almost 200 business, industry, and government attendees learned how to comply with federal and state regulations on particulate matter generation. Minnesota SBAP received the "Hassle-Free Government Award" for its participation with the MN Business Assistance Network (MnBAN) and the Government on Display (GOD) event. SBAP received the "Small Business Environmental Assistance Partnership Award" for its coordinated efforts with the MN Technical Assistance Program and MN's SBDCs. SBAP was reformatted by management from an air quality program that provided some multimedia assistance to an officially recognized, full multimedia program within the agency. This change also included the development of an agency-wide memorandum of understanding that authorizes SBAP to provide confidential compliance assistance within all environmental media. MN was one of 10 states to receive a Section 507 grant from EPA. The grant will be used to conduct and measure the effectiveness of a sector- based, nonregulatory compliance assistance initiative within MN's fiber reinforced plastics industry. SBAP created and published the "Environmental Guide for Small Businesses in Minnesota." This document was developed to provide businesses with a user-friendly means of accessing information regarding environmental and health and safety regulations , and as a resource for financial assistance. In addition to the hard-copy version, the guide also was posted on the MPCA's Internet site with hyperlinks to pertinent regulations, statutes, and other online resource sites. Mississippi N/R Missouri Our On-Site Assessment Team performed an assessment for an aluminum smelting facility. The facility was advised to recycle their pallets and cardboard. We located a recycling facility for the cardboard, and the smelter has saved approximately $2,000 per month in disposal costs. Montana The newsletters seems to have been a good investment on our part. We target a particular industry each month and produce a newsletter for them, which has several advantages: 1) The industry gets good information in a timely fashion and low-pressure method. 2) We build links between the SBO and other bureaus as a result of a combined effort in writing articles. 3) We have a handy reference for answering questions when a particular industry calls. 4) We learn a lot about the rules and other factors affecting that industry during preparation. 5) We do some multimedia assistance by adding non-air articles to the newsletter. 6) We get our name and message in front of potential clients in the form of something they keep, rather than throw out, thus increasing our "warm and fuzzy" factor. 7) We increase compliance. 8) We reach more businesses by mail than by driving. Nebraska Over the past year, the SBAP identified four businesses that were required to submit applications for permits and assisted the business manager in understanding the requirements under state environmental laws. In the process, other business owners were called and site visits were set up and provided. Like a sales organization, we need to ask a business owner if others that he or she knows could profit from SBAP's help. This strategy works very nicely here in NE. Nevada N/R N/A Not applicable N/R No response F-4-7 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES New Hampshire N/R New Jersey SBAP/SBO presented 7 industry-specific workshops as part of a US EPA Region 2 grant. New Mexico N/R New York 1. Printer Permitting Recently, the SBAP helped a printer to submit a State Facility Permit application (a permit for sources whose emissions are less than Title V thresholds, but greater than 50% of Title V thresholds). This permit application went smoothly, largely due to good communication among all parties: the applicant was responsive to requests from both SBAP and DEC for information, and the SBAP and DEC actively cooperated in pursuing the completion of the application. This represents one example of the critical role the SBAP plays in bringing businesses into compliance with state and federal regulations. The facility had already been registered with SBAP's assistance, but due to plans to expand, it needed the flexibility to increase its emissions to the limit provided by the State Facility Permit. With the installation of a new press scheduled for December, the SBAP and the printer began work on the permit application in March. The back-and-forth process of information-gathering went smoothly, and the application was submitted to the DEC in May. Once the application is received by DEC, any requests by DEC for further information need to be answered. Here is where the SBAP really helped to make this whole process run efficiently. Because this application was one of the first State Facility Permits to be processed under DEC's new permitting system, DEC requested that the applicable regulations be listed. With the facility's permission, SBAP called the DEC Regional Permit Administrator and the Regional Engineer. After this discussion, the request for the facility to supply the applicable requirements was dropped, because this section of the application does not have to be filled out by State Facility Permit applicants, since it is actually a Title V requirement. (For State Facility Permits, the applicable requirements are generated by the computer based on the information in the application.) The revised application was resubmitted and upon technical review, the Regional Engineer had questions about the recordkeeping procedures that would be used by the applicant to track the emission cap at the facility. However, after talking to the SBAP, the Regional Engineer was satisfied that the facility would be keeping records properly. At this point, DEC published the Notice of Complete Application, and the permit was issued shortly thereafter, in time for the facility to install the new press. 2. SBEO Advocacy The SBEO was contacted for advocacy by several businesses that own or manage residential real estate properties in New York City and that are involved in administrative enforcement proceedings with DEC. These businesses were issued an Order on Consent for failure to submit a completed Title V Facility Permit application as required under 6 NYCRR Part 201. The SBEO opposed the DEC Title V permitting violations and civil penalties assessed against these businesses in amounts ranging from $15,000 to $70,000, because failure to accept the emission cap in a timely manner did not cause a threat to health, safety, or the environment. DEC interpreted these violations as high priority under EPA's policy for what is, in essence, a paper violation. Small businesses considered the level of penalty to be unfair and excessive in light of the substantive non-impact of these facilities' late registrations. The SBEO met with DEC and EPA to discuss reduction of penalties against these minor combustion sources that had not formally capped out of Title V. As a result, DEC reduced the penalty amount for facilities whose actual emissions qualify for registration. N/A Not applicable N/R No response F-4-8 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES North Carolina Electric Motor Manufacturers - NC's air program was asked to revise the exemption for this category. We worked with Air Quality and the appropriate trade association to ensure that all but the largest burnout ovens remained exempt. Air Quality approved our language and incorporated it into the regulations. Furniture Manufacturers - The American Furniture Manufacturers Association (AFMA) is a very powerful organization in NC. The AFMA secured an exception to NC's air toxics regulations due to the overlapping of state air toxics regulations and federal MACT standards. Several small businesses were folded in with large manufacturers when they unwittingly signed up for a special order by consent (SOC) that obligated them to meet the MACT requirements even though they were not subject to them. We investigated each of the SOC signors and successfully negotiated with the AQ Director to remove all of them from the SOC and additional regulatory burden. North Dakota None. Ohio SBAP staff (Jim Carney) worked to reduce the permit fees for a customer. After many conversations, phone calls, e-mails, and meetings between the district and HQ staff, misunderstandings about the size and emission potential of the permitted sources were resolved. This resulted in the permit fee being reduced from $4,000 to $300' SBO provided financing for CAA compliant equipment for 11 small businesses and, through state tax incentives, reduced the cost of compliance. Two major vendors of dry cleaning equipment now tell their customers about us as part of their "sales pitch." Oklahoma This year, our major focus area was to attempt to ensure all dry cleaners in OK were in compliance and permitted (if needed). We held 5 workshops across the state and registered over 400 facilities and permitted over 120. We believe this has been very successful. We also continue to have great success with our site visits. We, as a program, prefer to meet with the individuals face-to-face, take a tour of their facilities and see their processes, and provide assistance from this vantage point. Oregon N/R Pennsylvania Neighbors of a woodworking facility in central PA complained about the dust from the operation, and a DEP inspector told the facility to correct the problem. ENVIROHELP staff conducted a site visit and informed the facility that the cyclone was overloading (venting too many processes for the device) and recommended installing a second device, such as a fabric filter. ENVIROHELP also provided information about financing available through DEP. The company used one of the financing options to purchase a fabric filter. A business in northeastern PA was given 3 weeks by DEP to complete 2 requests for determination forms, and the business did not understand how to calculate emissions from either the cardboard bailer or the approximately 35 different inks used for printing. ENVIROHELP conducted a site visit to understand how the bailer worked and estimate emissions. ENVIROHELP explained the information, calculations, and documentation necessary to estimate emissions from the inks and identified whether any other air pollution control requirements applied. Initially, ENVIROHELP believed the federal risk management program requirements applied to the facility; however, later revisions by the EPA changed the requirements. ENVIROHELP subsequently reviewed their request for determination forms, which were submitted to DEP on time. Puerto Rico N/R Rhode Island N/R South Carolina Working along with the Air Toxics Section of the Bureau of Air Quality, 75 small facilities were assisted in completing their Risk Management Plans for submittal to EPA by 6/21/99. Air dispersion modeling was provided by the regulatory program area. N/A Not applicable N/R No response F-4-9 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES South Dakota N/R Tennessee 60% of the dry cleaners taking the certified environmental dry cleaner test had attended our program's test preparation workshop. SBAP dry cleaner workshop had an attendance of 25 while other regulatory assistance providers offering workshops had a 0 to 1 person attendance. Popularity of 112(r) workshops resulted in scheduling of additional workshops. Staff partnered with utility district association, division of water/wastewater training center, and county/municipal technical assistance services to provide a workshop on 112(r) impact. Texas SBLGA spurred the development of the "de minimis" concept, referring to a cut-off level for air emissions below which businesses would be exempt from all air authorization requirements. The de minimis concept has been incorporated into Senate Bill 766, which will completely overhaul air pollution authorization in TX. SBLGA developed a list of more than 40 de minimis facilities and has been an integral part of building a structure of 6 de minimis categories and additional subsets of chemicals based on use rates. Developed the guide book, "Industrial and Hazardous Waste: Rules and Regulations for Small Quantity Generators" and distributed over 7,000 copies to small businesses. The guide will help small businesses understand and comply with voluminous and often complex hazardous and industrial waste regulations. Distributed over 650 "FYI" articles and over 800 press releases to newspapers throughout TX. FYls are environmental articles on timely issues of interest to small businesses and local governments, and press releases announced placement of SBLGA staff in regional offices. Placed 20 compliance staff in regional offices. Staffs ability to interact with the regulated community face-to-face and form partnerships with local organizations will greatly enhance environmental awareness and compliance throughout TX. Site visit program helped increase compliance among participants. The program focuses on opportunities for companies to reduce both the amount of pollution they create and the costs associated with proper waste handling. 229 site visits were conducted in 1999 for 171 businesses. Compliance increased for both air and waste issues for all industries. The program was enhanced by conducting follow-up visits and using compliance checklists to measure baseline and ending compliance. Implemented Compliance Commitment Partnership program, through which businesses that receive site visits and agree to implement all recommendations made by the consultant receive a one year reprieve from routine inspections. This serves as an incentive for businesses to voluntarily increase compliance and environmental awareness. Conducted over 40 site visits along the TX/Mexico border, an area where businesses historically have underutilized SBLGA's services. The site visit initiative in the border region helped increase awareness of the program and our services and forged partnerships between SBLGA and local organizations. We believe this will promote involvement of border-area businesses in our programs. Utah N/R Vermont We will host an area of our web site in 2000 that covers success stories. N/A Not applicable N/R No response F-4-10 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Virginia The CAP hosted a roundtable to identify issues of interest for future SBAP activities. The effective use of the State Advisory Board on Air Pollution to develop the VA EnviroMENTOR program is an excellent example of leveraging even part-time resources. The CAP helped to develop a tool to provide another third party approach to small business assistance that lacks the threat of regulatory compromise. Formed a partnership with our Air Compliance Chief to assist in negotiating with Region III for the delegation of the non-part 70 area source MACTs through the 105 grant process. VA had the only SBAP representation on the table. We were successful in creating compliance assistance parameters as part of the 105 grant outputs. The Internet Training Guide has proven to be a tool that is expanding the ability of small businesses to find third party assistance. Virgin Islands We are providing assistance to our automobile repair and refinishing shops, as we see them to be the ones that are in great need. We have convinced all refinishing shops of the need for spray booths. Washington OAPCA helped find an alternative to an industrial stripper product for an antique shop (project still underway). West Virginia On numerous occasions in 1999, SBAP worked with OAQ Enforcement to prevent Notices of Violation (NOV) and Cease & Desist Orders (C&D) from being issued. Consequently, the corresponding fines also were nullified. Some specific examples follow. One facility had exceeded its yearly throughput of magnetite allowed in its existing minor source permit. SBAP reviewed their process and developed an alternative potential emissions estimate for OAQ Permitting that kept the facility out of a modification permit while allowing the company to add additional yearly throughput. Another company had set up a portable crusher and was issued an NOV and C&D. If it were ultimately found that a permit was required for this process, the company would have been fined a minimum of $10,000 and had to pay an additional $1,000 for a permit. SBAP acted as the company liaison and facilitated an OAQ Permitting determination of "No Permit Needed" (without intervention, one almost certainly would have been required). SBAP also assisted OAQ Enforcement in the withdrawal of the NOV and C&D, and thereby was instrumental in avoiding an appeal, which had already been filed with the Air Quality Board. SBAP assisted a facility that converts chicken litter and ground cardboard into fertilizer. The main issue was odor complaints that had been brought to the attention of a US Senator. Using innovative emission factors, the SBAP was successful in helping this facility legitimately avoid the permit requirements pursuant to 45 CSR 13. Without our assistance, a permit would almost certainly been required. This also allowed the facility to avoid an NOV and C&D, as well as the corresponding fine. Ways of limiting odors also were suggested. In another situation where the file of record was incoherent at best, SBAP was able to assist the company in replacing a "permit by default" with an application containing more realistic emission limits. Given the state of the file and the narrow operating conditions that could be enforced from the original "permit by default," the end result was a win-win situation for both the company and OAQ. The local community benefitted from the negotiated limits of stockpile height and placement that reduced fugitive particulate matter. Based on the amount of public comments about the facility and its close proximity to the neighboring community, we believe that it was fortunate to receive a permit with a small amount of concession. This was in large part due to extra assistance from the SBAP, who with help from the SBO, also was successful in reducing the company's fine to zero. There are many other clients that avoided violations and fines or were found not to need a permit due to SBAP's assistance. In other cases, SBAP helped to negotiate outcomes that allowed small businesses to come into compliance and incorporate control devices with the least amount of difficulty and cost possible while remaining open for business during that period. N/A Not applicable N/R No response F-4-11 ------- PROGRAM SUCCESS STORIES AND CASE STUDIES Wisconsin SBAP staff provided compliance assistance to a wood frame manufacturer. The company was frustrated with the W air regulations and permitting requirements and was contemplating a move to another state. SBAP's assistance saved the business over $1,000 in consultant fees, and the company remained in the state retaining over 75 jobs. Wl SBAP staff member was appointed to EPA's National Advisory Council for Environmental Policy and Technology (NACEPT). She will work on the Compliance Assistance Advisory Committee to bring the small business and SBAP perspective to the table. Wl SBAP staff member continues to chair the National Steering Committee representing SBAP/SBO programs from around the country. SBAP brought a permitting issue to the attention of the W DNR, which resulted in the agency drafting a permitting exemption for autobody shops. The way the current Wl permitting regulations are written, very small sources of air pollution are unable to fall under a permitting exemption. Although most body shops are well below the permitting threshold, they still need to apply for an air permit. The SBCAAP brought this to the attention of the WDNR. The SBCAAP initiated a meeting and several site tours of body shops so the DNR rule writers could get a better idea of the emissions from these small sources. As a result, the agency agreed to write a variance to the permitting regulations to exempt small auto body shops. Wyoming Work continues on both the waste tire and waste wood projects reported last year. Several new technologies currently are being evaluated for applicability to the wood waste challenge. Additional work is now being done on a new opportunity, the Clean Snowmobile Challenge 2000 design competition. Sponsored by the Society of American Engineers, this project is challenging the Engineering Departments of numerous universities around the world to come up with snowmobile designs that are less damaging to the environment, both in terms of emissions and noise. The project has special importance to snowmobile use in the National Parks within our state boundaries: Teton and Yellowstone. We will continue our engagement with this activity in coming years through our P2 program. N/A Not applicable N/R No response F-4-12 ------- APPENDIX G COMPLIANCE ASSURANCE ISSUES ------- TABLE G-1 COMMON COMPLIANCE PROBLEMS SBTCPs were asked to note common compliance issues addressed in the course of providing technical assistance. Programs also were asked to indicate if certain problems were prevalent in any particular industry sector. Program Not understanding regulatory requirements Operating w/out permit Incomplete records Uncertain of permitting requirements/ need multiple permits Uncertain how to determine emission inventories/ lack of tech expertise Uncertain how to complete forms/ complicated paperwork Lack of financing for equipment Operating outside NSPS or MACT Improper storage/ disposal of hazardous waste Fear of regulatory agency/ arbitrary regulatory enforcement Failure to use right equipment to comply w/standards Other* Alabama X X X X X X X Alaska X dry cleaners X dry cleaners X X X dry cleaners Arizona X X X X X X X Arkansas X X X X X sm. facilities X sm. facilities X sm.facilities X California X X coatings X X sm. business South Coast X X dry cleaners auto body X dry cleaners auto body X X X X X X auto repair machine shop X gas stations Colorado X X X X X X X X Connecticut X X X X X MACT sources X X X X X Delaware X X dry cleaners X X X X District of Columbia X auto body X gas stations X dry cleaners X dry cleaners X dry cleaners X dry cleaners gas stations Florida X X X X X X X X Georgia X X X dry cleaners X X X X X Hawaii X X X X X X X X X N/R No response G-1-1 ------- Program Not understanding regulatory requirements Operating w/out permit Incomplete records Uncertain of permitting requirements/ need multiple permits Uncertain how to determine emission inventories/ lack of tech expertise Uncertain how to complete forms/ complicated paperwork Lack of financing for equipment Operating outside NSPS or MACT Improper storage/ disposal of hazardous waste Fear of regulatory agency/ arbitrary regulatory enforcement Failure to use right equipment to comply w/standards Other* Idaho X X X X X X X X Illinois X X X X X X X X X X X Indiana X X X X X X X fiberglass X dry cleaners wood furniture X X Iowa X X X X X X X dry cleaners chrome plating X manuf. X Kansas X X X X X X X X Kentucky X X X X X X X X Jefferson Cty X X X X X Louisiana X X X X X X X X X X X Maine X X X X X X X X X Maryland X X X X Massachusetts X X X X X X X X X X X Michigan X surface coaters X X X X X X X X Minnesota X X X X X X X dry cleaners degreasers tanks X X X X degreasers X Mississippi X X X X X X X X X Missouri X X X X X X X X X Montana X propane dealers X X X X propane & ammonia dealers X X X N/R No response G-1-2 ------- Program Not understanding regulatory requirements Operating w/out permit Incomplete records Uncertain of permitting requirements/ need multiple permits Uncertain how to determine emission inventories/ lack of tech expertise Uncertain how to complete forms/ complicated paperwork Lack of financing for equipment Operating outside NSPS or MACT Improper storage/ disposal of hazardous waste Fear of regulatory agency/ arbitrary regulatory enforcement Failure to use right equipment to comply w/standards Other* Nebraska X live stock operations X X X X Nevada X X X X X X X New Hampshire X X X X X X X New Jersey X X X X X X X X X X X New Mexico X X X X X X X New York X X NYC sources w/city permits, but no state permit X dry cleaners X X X X X X North Carolina X X X X X North Dakota X X X X X X X X Ohio X X X X X X X MACT record keeping X X Oklahoma X X X X X X X X Oregon X X furniture strippers X dry cleaners X X X X X furniture strippers X X Pennsylvania X X X X X X X X X X Puerto Rico X X X X X X X X X X X Rhode Island X X X X X X X X X X South Carolina X X X X X X X South Dakota X X X Tennessee X X X X X X X X X N/R No response G-1-3 ------- Program Not understanding regulatory requirements Operating w/out permit Incomplete records Uncertain of permitting requirements/ need multiple permits Uncertain how to determine emission inventories/ lack of tech expertise Uncertain how to complete forms/ complicated paperwork Lack of financing for equipment Operating outside NSPS or MACT Improper storage/ disposal of hazardous waste Fear of regulatory agency/ arbitrary regulatory enforcement Failure to use right equipment to comply w/standards Other* Texas X auto body auto service dry cleaners metal finishers surface coaters wood products thermoset resin printers foundries X aquaculture auto body metal finishers surface coaters wood products X auto body auto service dry cleaners metal finishers surface coaters wood products thermoset resin printers foundries X aquaculture dairies metal finishers X surface coaters X auto body dry cleaners surface coaters X sandblaster surface coaters X dry cleaners thermoset resin X auto body metal finishers surface coaters wood products thermoset resin X auto service dry cleaners metal finishers surface coaters printers X surface coaters X auto body auto service dry cleaners metal finishers surface coaters wood products thermoset resin printers Utah X X X X Vermont X X X X X X X X X Virginia X X X dry cleaners X X X X X X Virgin Islands X auto repair X X X X X X auto repair Washington X X X X X X X West Virginia X X X X X X X X Wsconsin X X auto body X dry cleaners chrome platers X metal finishers X rock crushers X X X solvent cleaners X X X Wyoming X X dry cleaners X X X X record keeping X X 'Other MN Rulemaking processes are complicated and time consuming. OH Unable to get clear answers. N/R No response G-1-4 ------- PROGRAM RESPONSES Programs were asked for any specific regulations, monitoring, or recordkeeping requirements that were particular problems. Programs also were invited to provide general comments regarding common compliance issues addressed during the course of providing technical assistance. Individual program responses are listed below. PROGRAM COMPLIANCE ISSUES Alabama N/R Alaska N/R Arizona Most NESHAPs that apply to small businesses have overly complicated reporting, recordkeeping, and operational requirements (chrome and wood, for example). Simplified small business rules should be considered in many cases, or simple operational or process changes that can get them out of requirements all together. Arkansas Stormwater regulations and air program permitting. Small businesses generally don't know they need a permit. California Since the local air districts issue the permits, compliance problems largely are inapplicable at the state level. Perhaps another reason that compliance is not a problem is that we include the regulated community in our regulation development process. Our workshops prior to rule adoption are well attended and have excellent participation. EPA recordkeeping requirements are onerous for small businesses. Because the rules are written to meet EPA criteria standards, they often are difficult to understand. South Coast Dry cleaners and auto body shops seem to have particular difficulty maintaining the required records and obtaining the necessary permits. A large percentage of these businesses are owned by people who are not proficient in English further complicates the process of improving compliance. AQMD governing board instituted a study to see how recordkeeping problems can be minimized. Colorado N/R Connecticut N/R Delaware The rationale and complexity of many environmental regulations far exceed the level of understanding found in the regulated community, especially the typical small business owner. This lack of understanding promotes fear and resentment and becomes a very real barrier to compliance efforts. District of Columbia NESHAP regulation for dry cleaners requires extensive recordkeeping of day-to-day activities. Regulated sources do not take the regulation seriously until they receive enforcement action. Small businesses do not have the manpower and financing resources to meet all these requirements. Florida None. Georgia We have found that a large percentage of businesses are not aware of the recordkeeping requirements and are very frightened of the liability surrounding hazardous waste contamination. N/R No response G-1-5 ------- PROGRAM COMPLIANCE ISSUES Hawaii Emission modeling requirements for diesel boilers for hotels in a densely populated urban area. Idaho State permitting requirements. Illinois Perc dry cleaner recordkeeping requirements seem to be a source of noncompliance for their industry. Indiana Dry cleaners - 12-month rolling total of perc purchases. Wood furniture NESHAP. Upcoming fiber reinforced plastic NESHAP. Special waste disposal. Title V permit requirements. Hazardous waste determination, measurement, and management requirements. Collision repair - VOC and HAP recordkeeping and permitting requirements. Universal waste rules. Iowa Synthetic minor sources doing a Federally Enforceable State Operating Permit (FESOP) are required to keep a set of complex and confusing records to document compliance. Small business want to do the right thing if they know what it is and shown how to do it. Kansas In KS, hazardous waste regulations are the most difficult for small businesses, since the regulations are more restrictive than the federal requirements. Also, we have state-specific rules for dry cleaners that require them to comply with 3 separate sets of regulations. The multimedia compliance calendars were designed to address this difficulty. Many small businesses continue to wait to be told what they need to do with respect to environmental regulations. They may use a hazardous waste disposal service, but they typically don't characterize their waste or evaluate their air emissions. Kentucky The chrome MACT may cause an inordinate amount of compliance issues for small businesses. Recognizing the serious nature of the pollutant, the amount of compliance information and assistance from EPA is limited when compared to other industry sectors, such as printers and dry cleaners. The regulations, in general, do not have enough flexibility to allow for changes in design, process flow, or production needs for a business starting up. The elimination of construction permits prevent businesses, especially the small ones, from having an opportunity to debug their process before having to apply for an operating permit. Jefferson Cty N/R Louisiana N/A Maine A common compliance problem across all businesses is hazardous waste violations due to lack of regulatory understanding. Maryland N/R Massachusetts Stormwater, MACTs, permits for low VOC emissions, potential to emit. Plain language guides in small chunks would be helpful. Michigan Hard and decorative chrome plating NESHAP. Surface coating for metal parts (state rules), especially recordkeeping requirements. Rock crushing and grain elevators lack good data for quantifying emissions. N/R No response G-1-6 ------- PROGRAM COMPLIANCE ISSUES Minnesota Air quality emission inventory and fee process. Hazardous air pollutant tracking. There can be a lack of incentives for a business to take the necessary steps toward compliance, particularly if others within the sector are not taking those steps. This may be because of business-specific disincentives, like the cost of time required to comply or lack of enforcement activity within the sector. Mississippi N/R Missouri N/A Montana Until the RMP exempted small propane users, it was a major problem, especially among our communities of Hutterite farmers, who do not own computers. We have a significant problem with small body shops that are exempt from MACT. MT has no spray coating regulations and we have to rely on voluntary cooperation to get these businesses to modify their operations so that their activities do not impact their neighbors. This can be time consuming and is not often successful. Nebraska A small source that emits between 2.5 and 10 tons of any single HAP is required to provide a BACT analysis. The small business does not have the time or money to research and develop a BACT analysis, nor can they afford the cost to employ a consultant to do the work. This requirement is overkill. The ability to file electronically is not available at this time and that causes some businesses to spend a lot of time filling out papers. Nevada General failure of the source to read and familiarize themselves with permit requirements. Failure to properly maintain pollution control equipment, which leads to a variety of compliance problems. New Hampshire Recordkeeping regulations tend to create much confusion. Most businesses have difficulty relating to what records must be kept as detailed by the regulations. In addition, businesses are unclear how "compliance" is determined (and maintained) and if regulations are applicable to their operations. Problems have arisen when different media regulate different aspects of one operation. For example, a spray coating operation may be subject to both air emission control and hazardous waste regulations. Unless all the media involved are addressed in a coordinated fashion, a business owners may feel he or she is in compliance with "environmental regulations" when, in reality, they have only been visited by an air division person. The common compliance problems can be addressed through the expansion of the SBTAPs into multimedia operations with close ties to the applicable regulatory agencies. With the implementation of compliance incentive policies, "separation walls" should not exist between compliance assistance and compliance assurance activities. Although each group needs to maintain their integrity to ensure effectiveness, both groups have a common purpose, which is compliance. New Jersey All are problems to small businesses. New Mexico N/R N/R No response G-1-7 ------- PROGRAM COMPLIANCE ISSUES New York Dry cleaners in New York State are subject not only to the federal NESHAP, but also to a significantly more burdensome state regulation. Compliance with the environmentally substantive, equipment-based elements of the NESHAP appears to be less difficult to achieve than compliance with the recordkeeping requirements of the NESHAP. However, the NESHAP's requirements, coupled with the complex state requirements for dry cleaners, make it difficult for cleaners to achieve total compliance. In addition, NY dry cleaners have to respond to phased state deadlines for equipment replacement and vapor barrier installation. For businesses that typically have fewer than 10 employees, only a couple of whom may actually operate the dry cleaning machine, the combined federal and state regulatory requirements are difficult to understand and follow. The various regional offices of the state's regulatory authority interpret state and federal regulations differently. This continues to be a problem for assistance providers, who encounter different responses to similar business compliance situations, depending on the location. North Carolina NC's version of Rule 66 for photochemically reactive organic compounds is an extremely difficult regulation to understand and comply with. We are working with Air Quality to revise this regulation. Many of our customers are referred to us by the compliance people in Air Quality. These businesses never realized that they needed an air permit until they were caught operating without one. North Dakota Leak detection requirements and recordkeeping can be confusing to some owner/operators of USTs. EPA needs to write regulations, especially for small businesses, that can be easily read and understood by people without environmental backgrounds. Ohio Small businesses have the most trouble with state permitting requirements, not federal regulations. Not having the required state permits is the most common violation found at small businesses. Oklahoma The largest problem continues to be operating without a permit. Oregon Monitoring and especially recordkeeping are problems for dry cleaners. The BAP revised the dry cleaner calendar that FL developed, which should greatly improve recordkeeping. The calendar was very well received by dry cleaners. Pennsylvania N/R Puerto Rico N/R Rhode Island VOC tracking could be a problem for a small business that uses many coatings. If the coating manufacturer supplies this information in a clear, unambiguous manner, this is always more helpful. MSDS formats for small businesses also can pose a problem in that there is not always consistent data listings from one form to the next. OSHA and EPA could work together to help coating/chemical manufacturers standardize product data reporting. South Carolina Labeling of hazardous waste, used oil, or other drums of raw materials does not meet regulatory requirements. South Dakota MACTs. Tennessee Ensuring all facilities affected by a new regulation are aware of the regulation. Complete understanding of the requirements of a regulation. Knowledge of potential non-compliance penalties. Small companies often don't have good environmental practices. Appropriate referral mechanisms aren't in place to meet all the small business needs. N/R No response G-1-8 ------- PROGRAM COMPLIANCE ISSUES Texas Problems and assistance needs identified from hotline calls and site visits include: 1) Understanding and complying with stormwater regulations. 2) Securing financing for removal of petroleum storage tanks. 3) Making a hazardous waste determination. 4) Complying with waste container labeling requirements. 5) Complying with waste generation and disposal recordkeeping requirements. 6) Understanding and complying with registration for air permit standard exemption. Common problems discovered during site visits included the failure to: 1) Make a hazardous waste determination. 2) Properly label waste containers. 3) Keep monthly records of hazardous waste generation. 4) Register for air permit standard exemption. 5) Meeting conditions of air standard exemption. Comments received from hotline calls and site visits emphasized the need to ensure small business input into the rulemaking process from the Small Business Compliance Advisory Panel, Small Business Advisory Committee, Rules Review and Plain Language Committees, trade associations, and small business owners. Input is important to increase small business' knowledge and awareness of new regulations and amendments to existing regulations that may affect them, as well as to ensure that regulations are in plain language and are not unduly burdensome. These actions will help ensure that compliance problems for small businesses are reduced. The greatest compliance problem SBLGA saw during this reporting period was determining which wastes are hazardous and documenting waste generation. The development of the small quantity generator guide book should greatly improve awareness of and compliance with waste determination and recordkeeping requirements for small businesses. Utah N/R Vermont RCRA manifests filed incorrectly. Poor multimedia recordkeeping. Lack of filing a RCRA notification form. General lack of knowledge that rules and regulations exist. Virginia MACT regulations continue to be highly confusing and a disincentive to businesses to employ P2 strategies for compliance, because of the trap of "once in, always in." Even if businesses eliminate all pollution, they will still have a regulatory responsibility to prove compliance. EPA could eliminate great confusion, difficulty, and inconsistencies in emissions identification, calculation, tracking, and inventories if they would develop an emissions identification and tracking program that businesses across the country could easily use. Virgin Islands Most of our small businesses are just getting to understand the program, because our on-site inspections are now in progress. Washington OAPCA: Nuisance regulations, odor in particular. OAPCA: Compliance with nuisance regulations. One staff person noted that they were having a problem with recordkeeping as it relates to monthly perc use. West Virginia No unusual problems. Wisconsin Lack of knowledge of requirements, particularly for new sources (NSR permits). Construction schedule being held up by not knowing an NSR permit was required. Lack of P2 information so businesses can avoid CAA regulations. Timing issues -- missing key deadlines and paperwork submissions. Dust/particulate emissions and violating opacity limits. Need a clearer definition of opacity requirements. NOx emissions in foundries -- closed system versus open system. Comment from our CAP: Small businesses are willing to do what they must to be in compliance. However, many of them still remain unaware of their regulatory responsibilities. N/R No response G-1-9 ------- PROGRAM COMPLIANCE ISSUES Wyoming From a number of regulatory inspections of perc dry cleaning facilities, many problems were noted with proper recordkeeping of perc purchases, temperature monitoring, and leak checks. A small number of facilities were noted with improper perc waste (sludge) storage. The Office of Outreach mailed informational packets and letters to all affected facilities identifying the requirements and the need for compliance to forego enforcement actions. While considerable progress is being made to outreach to small businesses across the state, there are remnants of anxiety in dealing with the Department. The SBAP will continue through its outreach efforts to break down such barriers to optimize its effectiveness in providing compliance assistance and advocating P2 initiatives to the business community. N/R No response G-1-10 ------- TABLE G-2 RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Alabama N/R Alaska N/R Arizona Provide funding for all SBAPs to expand and enhance their program to multimedia. Many businesses can actually do more harm to the environment if their assistance provider only looks at CAA requirements and not the potential impact that operational or process changes may have on water quality or land. Arkansas N/R California Given the diversity of the size and scope of programs in CA and its air districts, recognizing the high value that small businesses place on flexible, non- prescriptive air quality strategies is important. One idea would be to supplement the prescriptive approach with an equivalency option. This would allow states the option of fashioning an equivalent approach to achieving the federally required air pollution reduction. South Coast Clarify that cost can be a consideration in applying BACT/LAER. Clarify that BACT/LAER can be established based on when the permit application is received rather than when the permit is issued. Use actual reported emissions rather than potential to emit for determining compliance with MACT and eligibility with Title V. Colorado Continue to provide compliance assistance guides in plain English. Encourage alternatives to regulations for achieving compliance. This should be considered early during the rulemaking process. Connecticut Require EPA regulatory writers to work together on related programs to eliminate redundant requirements and unnecessary reporting, and to look for opportunities for streamlining. One example would be Emergency Response/Community Right to Know and the Accidental Release Program under the CAA. Delaware N/R District of Columbia More effective monitoring from the federal level on state programs to assure that small business programs have adequate resources to meet established SBA goals. Florida Provide specific mandate for funding to conduct outreach/awareness campaigns to increase program visibility, availability, and service. Georgia None. N/R No response G-2-1 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Hawaii SBTCP model is intended to help small businesses. Full implementation of the SBTCP in HI is needed. Without full implementation, it is premature for changes to be made in the program. Idaho None. Illinois Emphasis should be made on controlling the supplier or manufacturer of the hazardous substances or emissions. Regulating the production of coatings, solvents, or other problem emission sources at the time of production makes much more sense than regulating the universe of industries and uses for the substances. Regulating the manufacturer or supplier of the product will force them to improve environmental performance and will increase industry environmental performance overall. Recordkeeping and other requirements mandated in rules for small business should force a change in behavior or not be created at all. If recordkeeping does not provide for direct improvements in the environment, we should not mandate this activity on small business people with limited resources and time. If tracking purchases of a substance, US EPA should mandate the supplier to keep this information, not each individual small business. Indiana Reduce paperwork requirements where they are redundant or when they are no longer needed to ensure compliance. Ensure that requesting agencies really do need the information that we request from small businesses. Improve coordination between environmental regulatory departments and between regulatory agencies to combine reporting requirements. Provide more assistance to the small businesses in terms of on-site assistance with hands-on instructions. Iowa More incentives for voluntary compliance, such as clear and simple audit privilege or voluntary disclosure policies. Kansas Review the CAP structure. Locating people willing to serve is difficult, and there is little for them to accomplish. One CAP at the national level would make more sense, rather than one in each state. At the very least, the CAP should be optional at the state level. EPA needs to focus on helping businesses comply with regulations rather than trying to catch non-compliers with technicalities. (The continuous release initiative of 1998 is an example in Region 7.) Also, if EPA would let us know what industries they're targeting in advance, we could focus compliance assistance efforts on those businesses. Finding a business in compliance should be at least as important, if not MORE important, than finding one with technical or "paper" violations. Kentucky Adopt minimum gallon thresholds for MACT applicability standards for surface coating regulations like the ones for the wood finishing rule. Adopt de minimus activity levels for small businesses subject to NESHAPs by limiting potential emissions to area source limits and excluding them from Title V permitting. Jefferson Cty N/R N/R No response G-2-2 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Louisiana Conduct a national public relations program to let small businesses know that there is safe help available to them. Most small businesses want to comply with the law, but they fear bureaucracies and will remain invisible until they are contacted. A national public relations campaign would let them know that it is OK to contact the agency. Let the states participate in Small Business Advocacy Review (SBAR) panels on a local level. Organize a national CAP committee. Maine N/R Maryland N/R Massachusetts Simplify the CAA. Michigan At the federal level: EPA should work more closely with SBAPs on national compliance incentives. EPA should include the SBAP early in the process of establishing goals and criteria for compliance and enforcement and should actively solicit the SBAP's feedback on all compliance initiatives. Establish consistent requirements and expand the initial efforts begun by EPA to provide a more common sense application to the development, adoption, and execution of new rules and regulations. Provide grants or low interest loans (under SBTCP administration only) for small and medium-sized businesses for modification of current facility processes and control equipment to reduce air emissions. Provide more grant monies to state SBTCPs to develop and use innovative ways to distribute environmental programs and services to various industry sectors -- a type of "back door" approach to outreach and education for the small business workforce. For example, a federal or state grant might allow an SBTCP to work with federal and state government as well as business, industry, and state educational institutions to coordinate and package environmental compliance and P2 information that is specific to key industry sectors. The information might be introduced to students at the secondary or post-secondary level so that by the time the student enters the workforce, he or she will bring timely, relevant, and useful knowledge and experience to a specific industry or business. Minnesota Small businesses should be exempt from an NSPS if the business does not use the pollutant the NSPS intends to regulate. Provide stronger promotion of EPA's Policy on Compliance Incentives for Small Businesses. Mississippi Be proactive in providing information in the applicability and implications of regulations. Missouri N/R Montana Funding to expand our outreach would be nice. Nebraska Review the requirement, at the state level, to provide BACT for businesses that are producing less than 10 tons of a HAP. Federal requirements are set to require a BACT if the HAP PTE exceeds 10 tons. The process is time consuming and most small businesses cannot afford the expense. N/R No response G-2-3 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Nevada N/R New Hampshire Encourage or require that the SBTCP be multimedia and ensure funding is available for effective operation. In addition, EPA needs to continue to produce industry sector-based assistance tools that can be modified by each state for their specific application. There also needs to be continued work on the development of clear guidance tools and funding for effectiveness measurement without adding to the burden on assistance programs. Efforts to expand the SBTCPs to be the lead program for environmentally related assistance should be continued. New Jersey US EPA must increase its marketing and publicity campaign for both the federal and state SBO/SBAP programs. Specifically, the regulated community needs to be informed of the compliance assistance services available through the federal and state SBO/SBAPs. Additional funding levels for more staff and an increased program at the state level in specific states would greatly increase program effectiveness and outreach. New Mexico N/R New York The state environmental regulatory agency should work more closely in partnership with assistance providers on strategic planning, outreach, assistance, and follow-up enforcement to industry sectors. A coordinated approach among service providers would benefit small businesses in their quest to learn about and understand what they must do to achieve compliance. North Carolina A national outreach program is needed to advise small businesses of compliance assistance services and to do major information dissemination as new requirements are enacted or major compliance problems are identified. Recordkeeping requirements need to be examined. They often are burdensome for small businesses and have not been shown to have significant environmental benefit. They often are designed to protect regulators rather than be an environmental protection tool. North Dakota Write regulations in simple language so they are more understandable to small business. Ohio Compliance guidebooks for the dry cleaning, chrome plating, AIM costings, etc. are WAY too thick for the small business person. They are, however, good for regulatory staff. A possible improvement would be a "bottom line" style, 2-page fact sheet that omits any regulatory background information and just has bulleted requirements in short, simple sentences. Any compliance assistance literature should be designed to be read in 10 minutes or less. That is all the time a small business person often has. Oklahoma N/R N/R No response G-2-4 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Oregon The greatest obstacles to assisting small businesses in complying with the CAA regulatory requirements are the lack of financial and staffing resources. Many SBAPs are functioning at a 10 FTE level. More educational, training, financial, and support assistance are needed. Achieving compliance through educational programs emphasizing P2 should be given a higher priority at both federal and state levels. Financial -- Allocate $5 million to SBAPs. Develop a national policy that allows small businesses to invest in P2 technologies. Institute a revolving fund to finance small businesses willing to invest in MACT and BACT. Fund small business R&D projects with emphasis on P2. Regulatory -- Adopt realistic potential to emit criteria for small businesses. Adopt simple, less costly emission testing procedures for very small area NESHAP businesses. SBAP Support Projects -- Develop an easy-to-use national technical assistance tracking and reporting database. Develop a national small business mentorship program. Develop a national cross-media P2 green sticker recognition program. Develop a national simplified ISO 14000 plan for small businesses. Education -- Develop a national educatiional program at state SBDCs. Use Oregon SBAP-SBDC P2 cross-media training as a model for a national program. Employ state SBDCs to disseminate specialized training. Training -- Offer 1-2 hour teleconferences for all area source NESHAP regulations. Develop 30-minute training videos with workbooks for small business sectors. Offer teleconferences on cross-media P2 and environmental auditing. Offer a national training teleconference for environmental consultants serving small businesses. Pennsylvania N/R Puerto Rico N/R Rhode Island Assisting businesses with their other regulatory obligations, in addition to the CAA, would be more helpful. The danger of giving small businesses the false impression that they are in compliance with all their regulations could exist, when in reality, they may only be in compliance with the CAA. Therefore, emphasizing multimedia compliance assistance activities for the SBTCPs should be encouraged. Many of us are already providing such assistance to small businesses, but the emphasis is on CAA. South Carolina N/R South Dakota Develop control technologies with a clearinghouse on potential control systems for specific industries with associated costs and emission control factors. Tennessee Section 507 programs should receive federal funds to support compliance assistance and general program efforts. EPA should ensure a spirit of cooperation and not competition among the various compliance assistance providers. Federal support of programs that do not provide one-on-one assistance may be misdirected. State SBAPs need greater direct federal financial support. Much federal support and resources have been expended on the coordination of meetings. More resources are needed to provide direct one-on-one services to the programs' customers. Any effort to increase the layers of governmental assistance to small business in ineffective. Let's get back to the basics of what will work in the everyday workplace of small business. N/R No response G-2-5 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Texas Implement de minimis concept (whose development was spurred by the SBLGA), referring to a cut-off level for air emissions below which businesses would be exempt from all air authorization requirements. The de minimis concept has been incorporated into Senate Bill 766, which will completely overhaul air pollution authorization in TX. The SBLGA has successfully developed a list of more than 40 de minimis facilities and has been an integral part of building a structure of six de minimis categories and additional subsets of chemicals based on use rates. Include small business review and input in rulemaking processes. Streamline permitting processes. Expand available exemptions. Write exemptions for small businesses into all rules. Use a stairstep approach where controls increase as business size and production increase. Write rules in plain language. Make compliance conditions, such as recordkeeping and reporting, easier by using common business terms (e.g., gallons used versus pounds per hour, or gallons generated of hazardous waste). Make all small business assistance multimedia at both the state and federal level, and reinforce programs with adequate funding. Increase availability of low-cost loans and grants for small businesses and local governments, and simplify application procedures. Utah Environmental assessment training opportunities -- Industry-specific training sessions that provide a step-by-step approach to conducting on-site environmental assessments, including P2 assessments, would be of great benefit to SBAP staff. Vermont VT needs more assistance program employees. One person cannot cover the needs for all business sectors. This is why we do not actively advertise the program. N/R No response G-2-6 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Virginia At the federal level, we recommend that the Small Business Enforcement and Self-Audit Policies be reviewed and changed to provide consistency of application and interpretation by all EPA regional offices. The tools can be viable components of compliance assistance as shown by EPA Region 1. The small businesses do not now see these policies as affording any degree of safety or surety of action that might encourage them to use them as tools to assist in correcting noncompliance situations or in making compliance decisions. Many businesses will not come forward and identify themselves if there are potential penalties involved that are not clearly defined. Because the application of these policies is on a case decision basis, there continues to be differences of application and interpretation, which is not consistent within an EPA region or across EPA regions. Once the policies are uniformly accepted, understood, and implemented with consistency by the regional offices, the policies will find greater acceptance and use by small businesses. Reference the success of Region 1. More comprehensive economic impact analyses of regulations affecting small businesses. Is the gain in emission reduction worth the price that will have to be paid? Continued emphasis and increased activity by EPA in reaching full program integration with all of their rulemakings. Lay understanding of regulations should be an indispensable hallmark of all regulations and materials prior to promulgation. Provide revolving loan fund seed money from SBA for small business compliance assistance activities, such as the purchase of equipment. Expand SBAP programs to multimedia with appropriate funding provided by EPA for inclusion of the other media. Eliminate the "once in, always in" policy. Permanent Title V permit exemption for the currently deferred area sources -- dry cleaners, halogenated solvent degreasers, chromium electroplaters, ethylene-oxide sterilizers, secondary lead smelters. Virgin Islands Plain language and simple forms. Washington SCAPCA Provide more incentives for small businesses to install new air pollution control equipment. Simplify rules and requirements. Develop a directory of grants and loans available for small businesses to fund purchases or installations of air pollution control equipment. Make money available to fund personnel dedicated to business activities. West Virginia Coordinating various environmental assistance program efforts has been heavily discussed. This kind of partnering and coordination is already a way of life for most SBAPs, including WVs. However, some individuals and groups have suggested absorption or consolidation of Section 507 programs into other programs. This would not be in the small businesses' best interest if compliance with CAA requirements is the primary goal. Most of the suggested alternatives just do not possess the needed level of technical expertise or the routine contact with state permitting and enforcement staff that our SBAP personnel (and those of many other SBAP programs) do. While some states have successfully integrated the SBAP into other programs, it is the exception rather than the norm. In most cases, SBAPs will function most efficiently if operated independently and allowed to coordinate with other programs at their own discretion. N/R No response 0,-2-1 ------- PROGRAM RECOMMENDATIONS FOR CHANGES TO ASSIST SMALL BUSINESSES IN COMPLYING WITH THE CAA Wisconsin More credibility within EPA -- our CAP cited the recent illegal activities within EPA Region 5 and the tribal issues. Discretionary enforcement -- amnesty/grace periods when dealing with smaller businesses or less significant violations. Exceptions/exemptions for small businesses to the high priority violations (HPV) issue. Wyoming Provide targeted grant funding to assist small businesses that want to implement P2 practices or compliance programs but can't afford the cost. N/R No response G-2-8 ------- TABLE G-3 CONFLICT OF INTEREST/CONFIDENTIALITY ISSUES The SBTCPs provided information as to how their programs address internal or external conflicts of interest (COI) or perception that their programs may not be confidential. STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Alabama N/R Alaska N/R Arizona Existing policies, strong support from the ADEQ Director, and good working relationships with the programs have done a great deal to maintain our credibility as a source of assistance that can be used without risk of exposure. Our program does not advertise confidentiality. In fact, before we conduct a site visit, we inform the business that our report is not confidential. The simple fact is that our enforcement personnel and NGOs have better things to do than comb our files for people who are already taking steps to come into compliance voluntarily. Arkansas Confidentiality has not been an issue. California The Ombudsman's Office is part of the Air Resources Board Chairman's Office, and no COI or confidentiality issues have arisen. South Coast This issue most frequently arises in relation to our confidential on-site consultation services. Because our SBAP is part of the regulatory agency, businesses often indicate reluctance to identify themselves when they call. We explain to them that our program is separate from the Compliance Program, and that SBAP will maintain confidentiality. We also assume that the company understands that we expect them to make the necessary corrections if we identify any problems. To date, whenever we have provided an on-site consultation, the business owner has come into compliance. Our reputation, developed over the past 10 years of the program, is helping convince businesses that we can be trusted to work with them in confidence. Also, a good working relationship with trade associations and chambers of commerce has helped reassure businesses that our SBAP is separated from the Compliance Program. The SBAP and Compliance/Enforcement units have an informal process regarding maintaining confidentiality. Essentially, our Enforcement Unit does not request confidential information from SBAP. Also, companies being assisted by SBAP are provided with a business card or closing advisement to prove they are working with SBAP. Regular communication among Enforcement and SBAP and legal staff help minimize problems and uncertainties. Also, our chief Prosecutor's Office has assigned an attorney to work with SBAP on an as-needed basis. Colorado The SBO and SBAP have no conflicts regarding confidentiality. N/A Not applicable N/R No response G-3-1 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Connecticut Compliance assistance efforts have been very well defined. Assistance efforts are pursued proactively, separate from the Department's enforcement activities, but internally, efforts are coordinated to ensure roles and responsibilities between assistance and enforcement are clear and distinct. Delaware Not a problem. District of Columbia In the developmental phase of our program, a conflict of interest between the SBTCP and Compliance and Enforcement branch is inevitable. Additional staffing and resources will eliminate or resolve this aspect of the program. Florida We do not require that an inquirer identify him/herself. We do not disclose compliance issues to the enforcement section. Georgia The confidentiality issue was discussed at the workshops for dry cleaners in 1999. We explained that by statute, the information received in our office is confidential. To date, we have not had any conflicts develop as a result of the SBAP's confidentiality policy. Hawaii SBO maintains distance from regulatory programs. Files and contact lists are kept separate. Memorandum of Agreement governs relationships with regulatory programs. SBO maintains strict confidentiality in all of its individual counseling actions. Idaho This information is not available for 1999. Illinois We are outside of the regulatory agency. Indiana Communication -- explaining our program's confidentiality policy to callers, workshop participants, etc. Including our confidentiality statement in brochures, mailings, manuals, etc. IN's Compliance and Technical Assistance Program (CTAP), which is a part of the IN Department of Environmental Management (IDEM) operates under strict confidentiality, as mandated by state statute. The statute prohibits program staff from revealing confidential information to agency personnel or the public unless the client specifically waives confidentiality or there is a clear and immediate danger to the public health or environment. A non-rule policy document (published in the December 1996 Indiana Register) and written confidentiality procedures explain in detail how we implement the statute. The written procedures are revised, as needed, to reflect new information or new situations that have arisen. During 1999, the procedures were updated three times. The physical location of CTAP is in a separate building than the rest of IDEM, and access to the office is limited. Accessibility is indicated by posted signs and colored tape on the floor and doorways. Visitors must sign in, and an escort is required. Effectively working with the regulatory offices within IDEM sometimes is difficult, because our strict confidentiality policy can hinder communication or coordination of efforts. N/A Not applicable N/R No response G-3-2 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Iowa The IAEAP is funded by the IA Air Quality Bureau (AQB) of the IA DNR. Contract terms stipulate disclosure of IAEAP client information to the AQB if such information is requested. Unless specifically requested (very rarely), no client information is volunteered to the regulatory agency. The IAEAP clients are informed that confidentiality does not exist with the SBAP. Kansas This technical assistance component of the program is delegated to Kansas State University. Their contract stipulates that information is confidential, except the total numbers of assistances provided, types of businesses, and types of services provided. Management staff within the Division of Environment have unanimously agreed that information received by the ombudsman shall remain confidential. Kentucky SBAP is separate from the regulatory agency. This arrangement provides a separation and comfort level to the small business community. On occasion, SBAP advises that certain issues cannot remail confidential (such as permitting and reporting). Clients also are advised it is sometimes in their best interest to inform the regulatory agency that their business is working with the SBAP (during an inspection, for example). Compliance issues where confidentiality is impossible (permit application submission) are resolved by the Division of Air Quality, recognizing the TAP's assistance as a good faith effort to comply and thereby waiving or reducing civil penalties. This is explained to the business during the application completion process. Other issues, such as compliance issues with standard or control requirements, are handled confidentially through compliance agreements between the small business and the TAP. Jefferson Cty An amnesty program is in place to encourage honest reporting and prompt remediation of non-compliant situations. Louisiana We have had no problems regarding confidentiality with state enforcement, because LA has a Freedom of Information Act. Regional EPA inspectors come into the state, unannounced, and levy heavy fines on small businesses we have been working with, which results in the perception that our program is not confidential. Maine SBTAP has adopted the Small business Compliance Incentives Policy based on EPA guidance. Maryland N/A Massachusetts OTA is an independent office with confidentiality. We are only to report imminent threats. N/A Not applicable N/R No response G-3-3 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Michigan SBO To avoid both external and internal conflicts of interest, the SBO staff often will initiate anonymous conference calls between SBO clients and environmental regulatory staff. SBAP - External COI Confidentiality has not been an issue with the current services provided by the SBTCP. The SBAP is developing guidance publications, presenting workshops, and conducting phone consultations. At present, these activities do not warrant the collection of sensitive data. Additionally, the SBAP does not perform on-site audits, so facility-specific information is not collected. The SBTCP is in the process of developing a policy that explains how the program will respond when it becomes aware of a violation by a facility seeking assistance. The policy also will explain that information contained in the SBTCP files or databases will not be shared with the regulatory agency (Ml Air Quality Division). Currently, Mi's SBTCP cannot claim that this information is "confidential" unless a facility invokes a provision in Mi's recently enacted "Environmental Audit Privilege and immunity" law, which designates the terms of confidentiality between a facility and the regulatory agency in a "confidentiality agreement." SBAP - Internal COI The SBTCP works closely with the regulatory agency as it develops and executes all of its program objectives. SBAP staff are included in and advised of all policy developments regarding state implementation of the CAA. Mi's SBAP acts as an education, outreach, and marketing arm for the state's air quality program, and that role has assisted the SBAP in avoiding internal conflicts of interest. Minnesota SBAP negotiated with MPCA regulatory staff to develop a memorandum of understanding (MOU) that allows SBAP to provide confidential compliance assistance within all environmental media. This MOU has been very well respected by regulatory staff within MPCA and, to a somewhat lesser but still successful degree, regulatory entities outside MPCA. The SBAP is very conscientious and proactive about marketing this aspect of the program through all of its outreach tools. Mississippi SBO and SBAP are regarded by DEQ as independent, confidential, and non-regulatory. Regulatory programs see the SBO and SBAP as confidential to small businesses. On-site assistance is provided by an outside organization as authorized in EPA's Enforcement Response Policy for SBAPs, option 2; therefore, no written correspondence on the compliance status of a small business is maintained by SBO or SBAP. Missouri The regulatory programs and the Technical Assistance Program (TAP) have an understanding that regulatory programs will not look at TAP's records unless a facility is under enforcement. If TAP finds a violation that is not a substantial and immediate threat to human health or the environment, recommendations are made to get the facility into compliance, but no report is turned over to the regulatory programs. If a violation that is substantial and an immediate threat to human health or the environment is encountered, the facility is notified that TAP must report this to the appropriate regulatory program. Facilities that come to TAP for assistance are favorably looked upon when it is discovered they need a permit, and TAP assists them in attaining compliance. N/A Not applicable N/R No response G-3-4 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Montana We have not yet had to test this concept. The more sophisticated the client, the more likely they will ask about confidentiality and are less likely to believe us when we say we provide it. There is definitely a great deal of hesitation by many clients in contacting the DEQ. Clients don't like to bring attention to themselves, as they believe they will end up on a list that will eventually get them into trouble. We avoid COI by not telling Enforcement what we are doing and by not disclosing the names of businesses when asking for assistance from Permitting and Compliance staff. Nebraska The agency management and the program manager understand that if this program were to become open to regulatory inspectors, we would not have anyone asking for assistance. Confidentiality is not a problem in this state. Nevada The Bureau of Air Quality contracts with the SBDC, Business Environmental Program for technical assistance to small businesses. This third party program provides free and confidential assistance to small businesses, conducts seminars, and develops outreach materials at the direction of the BAQ based on program needs for the year and as outlined in the interagency contract for services. The SBAP, located in the regulatory agency, has a responsibility to protect public health and the environment. Discretion is applied to all cases, and businesses with non-compliance issues are encouraged to enter into audit agreements with the regulatory agency, which will waive fines and penalties for self-disclosure. In this manner, assurance is provided that no impacts to public health or the environment occur and, at the same time, brings the business into compliance. SBAP staff work closely with enforcement staff on non-compliance issues to identify and target problem areas for outreach and assistance. New Hampshire The NH SBTAP's policy continues to offer businesses the option of remaining anonymous or of taking advantage of the Compliance Incentives Policy. We continue to encourage businesses to use the Policy and have found the majority of businesses we deal with are taking advantage of it. We continue to work closely with the compliance assurance personnel to ensure these businesses are not subject to punitive enforcement actions providing that the businesses agree to rectify any deficiencies within a set time frame. In addition, there are many occasions where compliance assurance personnel will refer complaints against smaller operations to SBTAP for resolution. These referrals usually are for businesses that are in industry sectors where the SBTAP has done considerable outreach (such as auto body shops) where the complaints can be resolved through the application of "standard" actions. As a general rule, SBTAP discourages businesses from remaining "confidential," as they are not afforded the level of "protection" the Compliance Incentives Policy can offer. New Jersey SBAP has an agreement with NJDEP Enforcement that the SBAP information is confidential. SBAP publicizes this information in all collateral marketing materials as well as at meetings, seminars, and verbally on the telephone. New Mexico NM SBAP does not offer confidentiality. However, any information that is observed by or revealed to the SBAP and claimed as a trade secret by the small business will be treated as such by the Environmental Department to the extent allowable under state law. The procedure for identifying trade secrets to the Environmental Department is described in NMED's Public Records and Inspection Policy. N/A Not applicable N/R No response G-3-5 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS New York Confidentiality is key to the success of assistance programs designed to help businesses comply with environmental requirements. Recognizing this, New York State has designed its 507 program to have the SBAP and SBEO each located in non-regulatory state agencies. Further, the state assured the confidentiality of the small businesses working with the program by passing legislation that maintains under state law the confidentiality of their identify, location, and other plant information, and protects this information from access under the Freedom of Information Law. In this way, companies can be frank in describing their problems without fear of reprisals or penalties. However, confidentiality is not a shield against enforcement that is conducted independently by the regulatory agency, but is in place to encourage more companies to come forward to discuss their problems so they may achieve regulatory compliance. North Carolina We have not experienced an instance where any regulatory entity requested information about a customer we didn't feel at liberty to discuss. North Dakota The environmental programs of the Department's Environmental Health Section traditionally have been compliance assistance oriented, with enforcement reserved for recalcitrant violations or where damage to health or the environment has occurred. Even prior to establishing the SBO and SBAP, the Department's emphasis has been on educating and assisting the regulated community to achieve compliance. With the establishment of the SBO and SBAP, the fundamental approach to compliance hasn't noticeably changed; however, outreach activities have increased. We don't know if small businesses are reluctant to request assistance or confide in the SBO, since the ombudsman is housed in and employed by the Department of Health. Besides serving as SBO, the ombudsman has other duties that support the administrative functioning of the Environmental Health Section. The SBO's assistance with enforcement matters has not been requested to date. The SBO has requested the Department's Chief of the Environmental Health Section to refer cases to the SBO when a small business expresses dissatisfaction or frustration in their dealings with the Department. This is an area that should receive continued monitoring and evaluation. Dialogue between the SBO and SBAP has resulted in the understanding that small businesses may reveal certain information to the SBO that may be treated as confidential and not disclosed to or sought to be disclosed from the SBAP. Information disclosed by a small business directly to SBAP staff would not be turned over to the compliance program staff for enforcement purposes; however, a plan for correcting any violations would be developed. When needed, SBAP provides compliance assistance. Confidentiality (not disclosing violations to enforcement staff) has really been a non-issue in ND. N/A Not applicable N/R No response G-3-6 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Ohio SBAP In 1999, the OEPA consolidated its headquarters into one location, causing the SBAP to share adjacent office space with the rest of the Air Pollution Division. However, the SBAP remains separate from district office inspectors who initiate enforcement. Our computer databases, site visit reports, etc. are only accessible by SBAP staff. So far, we have not experienced any problems keeping information confidential. SBAP also visits the Agency field offices to reiterate our confidentiality policy. With prior approval of our customers, SBAP has worked directly with the district office inspectors to resolve violations. Finally, state law prohibits any information gathered by SBO or SBAP being used in an OEPA enforcement action. Oklahoma SBAP is housed in the non-regulatory Customer Service Division within our Agency, which has allowed us to effectively develop trust with many businesses. Our group is supported very strongly by our Agency management, and we are given the tools we need to provide quality confidential assistance. Oregon Information disclosed and minor violations discovered during on-site small business technical assistance visits are protected by state statute, except when there is reasonable cause to believe there is clear and immediate danger to public health or the environment. In accordance with the state statute and the confidentiality option set forth in EPA's Office of Enforcement and Compliance enforcement policy, the OR SBAP adopted a written confidentiality policy. In summary, this policy allows the SBAP to function independently of the enforcement section; restrict access to information and files of small businesses receiving technical assistance; keep business names and locations in a separate, confidential file; and perform follow-up consultations to assure resolution of violations discovered during on- site visits. This policy has prevented conflicts inside and outside the agency and allows additional flexibility to bring small businesses into environmental compliance. For example, the SBAP can assist a small business that faces enforcement through other channels by allowing staff to assist with P2, applying for permits, and mitigating penalties via supplemental environmental projects (SEPs). In such cases, OR's confidentiality policy is congruous with EPA's Policy on Compliance Incentives for Small Businesses. Pennsylvania The technical assistance program is operated by an outside contractor that keeps all of its clients confidential, thereby eliminating any potential COI. Puerto Rico N/R Rhode Island Rl DEM has been operating a non-regulatory technical assistance program since 1987. Since that time, we have worked with hundreds of companies and have gained the trust of a majority of them. COIs are avoided through close coordination with our regulatory cousins. Coordination with our state's Economic Development Corporation and URI's Center for P2 also has been helpful in stressing our Office's pledge to work with industry in a confidential manner. South Carolina As inspectors find small businesses that are out of compliance and don't appear to be intentionally trying to avoid compliance, they give the facility the opportunity to come into compliance by recommending they contact our office for assistance. Also, we appreciate the continued support of upper management in bringing our program to the table for bureau chiefs to take back to their staffs. South Dakota N/R N/A Not applicable N/R No response G-3-7 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS Tennessee TN Department of Environment and Conservation has established a state audit policy. Top Department officials have supported the confidentiality of the program. The regulatory programs understand the benefit of confidentiality. The program will partner with other assistance agencies and with regulatory programs to ensure compliance and regulatory understanding. Texas The Agency's Enforcement Division does not have any policies exclusively for small businesses. However, the majority of enforcement actions initiated in the regions that are informally resolved involve small businesses. Informal resolution means that the violations were resolved between the inspector and the regulated entity without the case going through the formal enforcement process and without the assessment of a penalty. Based on data obtained from Enforcement's FY99 Annual Report, approximately 62,000 enforcement actions involving small businesses were informally resolved. Utah We use EPA's policy as a model for compliance incentives for small business. Vermont We have not had internal (regulatory) problems as of yet. We do explain in our program flyer about the confidentiality aspects of VT's program. Our regulatory programs provided guidance as to what constitutes a significant violation with the understanding that when a significant violation is encountered, the SBAP will refer the violation to the regulatory program for resolution by that program. Small businesses are made aware of this possibility before the SBAP goes on site. Virginia The issue of confidentiality, as indicated in last year's report, is still not a major problem, but this issue will take on more importance when the SBAP is able to provide voluntary complimentary compliance audits as a part of normal operations. The ability to deliver a quality product to the customer is only as good as the credibility of the provider. The ability to correct deficiencies and non-compliance situations through the 507 Enforcement Policy provides a non-confrontational means to achieve compliance assistance and deliver a quality product. Additionally, the ability to direct inquiries to the VA EnviroMENTOR program also will provide a non-confrontational means of providing compliance assistance. Each of these avenues provide for the business's ability to fix a problem with relative ease and be kept in the category of smart business decisions. Within DEQ, the SBO/SBAP continues to maintain an excellent working relationship with the Enforcement and Compliance Office, which also helps to ensure an understanding of the needs on both sides of compliance and enforcement issues. We both recognize that compliance is the ultimate goal, and compliance assistance can become, and is, a means to that end. VA also has the additional tools of voluntary remediation and voluntary audit privilege, which are available to the business community. Virgin Islands We have not encountered this problem. Washington This has never been a problem. SCAPCA Our program is not confidential in terms of compliance and enforcement. COI or its perception is impossible to avoid. Our program does not have a dedicated, non-enforcement staff providing assistance. N/A Not applicable N/R No response G-3-8 ------- STATE OR TERRITORY COI ISSUES AND RESOLUTIONS West Virginia SBAP operates separately and independently from the enforcement group of the agency. Also, the SBAP currently is housed in a separate physical location. To better help small businesses, enforcement refers some violators to the SBAP for technical assistance to facilitate compliance. The SBO also intervenes in specific enforcement actions to ensure that small businesses are fairly treated. SBAP does not refer any cases to Enforcement, except in the case of imminent danger. However, to ensure that compliance is eventually achieved, SBAP will make on-site assessment files available to enforcement after an 18-month grace period. The business is not shielded from enforcement actions related to violations independently discovered by state (or federal) inspectors during this period. Such independent discovery may occur through routine inspection activity or complaint investigation. The DEP Director has given strong assurances that the confidentiality of all assistance programs shall be respected. Wisconsin Wl SBAP/SBO are housed in the W Department of Commerce. We are a nonregulatory agency. A memorandum of understanding has been established between Commerce and DNR that allows businesses to speak to Commerce staff on a confidential basis. We offer them complete confidentiality. However, if an inspector visits a company during the time a facility is working with the SBAP/SBO, and a violation is found, it is business as usual. A Notice of Violation (NOV) or Letter of Noncompliance (LON) may be issued. If a company would like to work with our partners at W DNR, and the DNR nonregulatory staff person finds a violation, the business has 90 days to correct the problem. No enforcement action will be taken during this 90 day period. As a rule, we let our customers know we will not share any of our information with the DNR. If we need to contact the agency with a specific question, we do not reveal the name or location of the business with which we are working. Wyoming The issue of confidentiality has been previously addressed by the CAP. The existing state statute does not provide protection from discovery in legal proceedings or from Freedom of Information Act requests. The Department is concerned about making adequate information available to the public and has no intention of pursuing a change in the law. N/A Not applicable N/R No response G-3-9 ------- TABLE G-4 EPA's POLICY ON COMPLIANCE INCENTIVES FOR SMALL BUSINESSES/SMALL COMMUNITIES SBTCPs were asked if their program used EPA's Policy on Compliance Incentives for Small Businesses or a comparable state policy for small businesses/small communities. Individual program responses are shown below. PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES Alabama N/R N/R Alaska N/R N/R Arizona ADEQ has adopted the Enforcement Waiver Policy (Small Business), which waives penalties if a business meets similar criteria as in the EPA policy. ADEQ policy does not address economic benefit. No business has aDDlied for the Dolicv as of this time. N/R Arkansas N/R N/R California N/R N/R South Coast Our Local Government & Small Business Advisory Group raised the issue of the "EPA Policy on Compliance Incentives for Small Businesses" in 1999, and the matter has not yet been fully resolved. Our Chief Prosecutor did a comparison of our existing procedures and the EPA's Small Business Policy in 1999. He recommended adoption of the EPA policy for assistance, except for the portion that allows administrative variances. He pointed out that our state law has established a variance procedure that requires petitioning a Hearing Board. This district has not yet acted on the recommendations, and there are still outstanding issues about how to implement the confidentiality Dolicv. N/A Colorado None. N/R Connecticut N/R N/R Delaware DE has a Penalty Mitigation Policy that has been used primarily by large industry. The Policy is not limited to small business and covers most regulatory programs within DNREC. The Policy has been gaining acceptance among the business community as a tool to achieve compliance and seems to lessen the fear of self-reporting when problems are discovered. N/R District of Columbia N/A N/A N/A Not applicable N/R No response G-4-1 ------- PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES Florida Inadequate staffing levels prevented activity in this area in 1999. Staffing issues have been addressed, which will allow for consideration in 2000. There is a Small Community Coordinator position in the Secretary's Office; however, it is not presently part of the SBO/SBAP office. Georgia GA has not used EPA's Policy on Compliance Incentives for Small Businesses. N/R Hawaii Department of Health's Environmental Audit Policy, gravity -based penalty: "Where violations are discovered by means other than environmental audits or due diligence efforts, but are promptly disclosed and expeditiously corrected, we would reduce gravity-based penalties...provided that all of the other conditions of the policy are first met." Economic-based penalty: "Retain our discretion to recover economic benefit gained as a result of noncompliance, so that companies will not be able to obtain an economic advantage over their competitors by delaying their investment in compliance." SBAP/Clean Air uses the Audit Policy and tiered enforcement/penalty structure in framina all enforcement action. N/A Idaho No such policy has been used at this time. DEQ currently is drafting a Self-Disclosure Policv for all facilities, includina small businesses. N/R Illinois N/R N/R Indiana N/A N/A Iowa We have not used the EPA policy with any of our clients yet. We have started implementing (used about 5 times, so far) a newly approved self- audit state law that supersedes the previous amnesty policies. We had a general amnesty policy in place, and in the last two years, aDDroximatelv 50 businesses took advantaae of that Dolicv. N/R Kansas KS has an "Audit Bill" that provides incentives for businesses to self- report. To date, five businesses have self-reported. All information is strictlv confidential, includina outcomes. N/R Kentucky Penalties have been waived or reduced when the Enforcement Branch considers the assistance effort provided bv the SBAP. N/A Jefferson Ctv N/R N/R Louisiana The Dolicv is available, but we have not had an occasion to use it. N/A Maine Seventeen companies have used the policy since its adoption in 1995. No companies used the Dolicv in 1999. None. N/A Not applicable N/R No response G-4-2 ------- PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES Maryland N/A N/A Massachusetts We recommend companies use the policy. Very few do, but it comes in handy when they need a permit and have to self-report in order to get one. N/R Michigan Ml SBAP is in the early stages of using both the Ml and EPA enforcement policies by working with companies that have both state and federal violations. N/A Minnesota N/R N/R Mississippi N/R N/R Missouri N/R N/R Montana N/R N/R Nebraska N/R N/R Nevada N/R N/R New Hampshire We continue to use the Compliance Incentives Policy as a guiding principle for program operation. As noted, we strongly encourage businesses to take advantage of the Policy as it provides "protection" against punitive actions while rewarding proactive activities. The NH SBTAP also has been active in developing an NH-specific Compliance Assurance Response Policy, which provides opportunities for businesses to receive compliance assistance from the agency if certain criteria are met. As with the federal policy, the NH policy first relies on education, outreach, and direct assistance to inform business operators of their obligations and reserves enforcement actions for those businesses that choose to ianore their responsibilities. Small communities generally are treated as small businesses in relation to a Compliance Incentives Policy. As many small communities lack the expertise to understand the applicable regulations and determine what needs to e done for compliance, it is appropriate that they are allowed access to the same protection as small businesses. New Jersev N/R N/R New Mexico N/R N/R N/A Not applicable N/R No response G-4-3 ------- PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES New York In Fall 1999, the SBEO met with EPA Region 2 and the DEC regarding the Small Business Policy. In order to refer businesses to the regulatory agencies with confidence that companies would benefit from the policy, the SBEO sought clarification of the applicability of the policy through the use of hypothetical "cases" presented to EPA and DEC. From our discussions with these agencies, the policy apparently is of little use to small businesses. The primary problem with advising businesses to come forward under the policy is the lack of any clear commitment to the policy from either EPA or DEC. A company that self-discloses is likely to be determined to be ineligible under the policy. In the SBEO staffs experience, companies that come forward voluntarily often are worse off than companies whose violations are discovered by the regulatory agency. SBEO and SBAP are reluctant to refer small businesses to either EPA's or DEC's compliance incentive policy, because there is not apparent state and federal agreement on the applicability or use of the compliance incentive policies. Thus, there is not incentive for a company to come forth voluntarily, expose its areas of non-compliance with no preliminary certainty about the categories of applicability. As a result, a company may come forth in good faith, hoping the policy is applicable. Applicability may be denied, and the company may be penalized for confessing its regulatory non-compliance instead of being rewarded for voluntarily coming forward to address the non-compliance issues and working toward achieving compliance. In the past, SBAP referred two businesses to EPA's compliance incentive policy. One business was referred to EPA's policy regarding a NESHAP issue. The business both called and wrote to the EPA contact for a copy of the policy. EPA reportedly never responded to the business. The second business was referred to EPA Region 2 to apply for consideration under the policy. EPA Region 2 allegedly said the company was ineligible, because it "had emissions." Since most businesses have emissions of one type or another, it appears that although the policy exists, the applicability is sharply limited. SBAP has found in discussions with EPA Region 2 that the Region appears to limit the federal policy's applicability to specific sectors, particularly dry cleaners, and appears not to support the policy's use for application across sectors. At the state level, the policy on voluntary compliance also has no apparent incentives for use by small businesses. In fact, DEC staff reportedly have admitted crafting a policy that they expect few small businesses will use. DEC has conducted very limited outreach to promote the policy to small businesses. Thus, small businesses do not use the policies at either the state or federal levels, because there is neither claritv nor certaintv about aDDlicabilitv. N/R North Carolina NC has a confidentiality policy, but does not apply EPA's small business Dolicv requirements specifically related to reducina penalties. N/A N/A Not applicable N/R No response G-4-4 ------- PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES North Dakota None. None. Ohio N/R N/R Oklahoma We have an internal agency policy similar to EPA's that allows us to waive civil penalties for those facilities that come forward. This policy may be invoked by a business under certain circumstances only. We do not track information on the number of businesses that use the DOliCV. N/R Oreaon N/R N/R Pennsylvania N/R N/R Puerto Rico N/R N/R Rhode Island N/R N/R South Carolina By using the Incentive Policy, the penalty assessed by Enforcement was mitigated after the facility received compliance assistance from the SBAP. N/A South Dakota N/R N/R Tennessee TN developed a self-policing and voluntary correction policy using the SBAP compliance incentives for small businesses. This provision allows a company to correct a compliance problem provided certain conditions are met. None. Texas The agency's Enforcement Division does not have any policies exclusively for small businesses. However, the majority of enforcement actions initiated in the regions that are informally resolved involve small businesses. Informal resolution means that the violations were resolved between the inspector and regulated entity without the case going through the formal enforcement process and without the assessment of a penalty. Based on data obtained from Enforcement's FY99 Annual Report, approximately 62,000 enforcement actions involving small businesses were informally resolved. The Local Government Assistance team in our section handles compliance assistance for small communities. According to information in Enforcement's FY99 Annual Report, approximately 7,300 enforcement actions involving small communities were informally resolved. Utah N/R N/R Vermont N/R N/R Virainia None. None. Virain Islands N/R N/R Washinaton N/R N/R N/A Not applicable N/R No response G-4-5 ------- PROGRAM SMALL BUSINESS POLICY ACTIVITIES SMALL COMMUNITY POLICY ACTIVITIES West Virainia None. None. Wisconsin Wl DNR Office of Enforcement has chosen not to implement the EPA Small Business Policy. Instead, the state continues to rely on its current enforcement discretion policy, which provides more flexibility for the W business communitv. N/R Wyoming The Department has a "Small Business Voluntary Disclosure Incentive Rule" in place that mirrors the EPA policy and is multimedia. The basics of this Rule have been published in our newsletter and in handout material provided to businesses during on-site visits, in public displays, and during presentations. The Rule has generated limited interest in the small business community. The Department has not developed a formal policy for small communities. However, the Department's policy is not to seek penalties when municipalities work to come into compliance. N/A Not applicable N/R No response G-4-6 ------- 1999 Application of: Small Business Policy Small Communities Policy Program # Small Entities Qualifying Under the Policy # Small Entities Attempting to Use Policy, Still Under Consideration # Small Entities Attempting to Use Policy, But Not Qualifying Total $ Amount of Penalties Reduced AL N/R AK N/R AZ N/R AR N/R CA N/R South Coast 196 on-site consultations N/A N/A N/A N/A N/A N/A N/A CO N/R CT N/R DE N/R DC N/A FL o o o o o o o o GA N/A HI o o o o o o o o ID N/R IL N/R IN N/R IA N/R KS N/R N/A Not applicable N/R No response G-4-7 ------- 1999 Application of: Small Business Policy Small Communities Policy Program # Small Entities Qualifying Under the Policy # Small Entities Attempting to Use Policy, Still Under Consideration # Small Entities Attempting to Use Policy, But Not Qualifying Total $ Amount of Penalties Reduced KY N/A Jeff Ctv N/R LA N/A ME o o o o o o N/A 0 MD N/R MA N/R Ml N/A MN N/R MS N/R MO N/R MT N/R NE N/R NV N/R NH N/A NJ N/R NM N/R NY o o o o o o N/A N/A NC N/A ND N/R N/A Not applicable N/R No response G-4-8 ------- 1999 Application of: Small Business Policy Small Communities Policy Program # Small Entities Qualifying Under the Policy # Small Entities Attempting to Use Policy, Still Under Consideration # Small Entities Attempting to Use Policy, But Not Qualifying Total $ Amount of Penalties Reduced OH N/R OK N/A OR N/R PA N/R PR N/R Rl N/R SC 1 0 o o 1 0 $2,500 0 SD N/R TN 17 N/R 17 N/R 1 N/R N/R N/R TX N/A UT N/R VT N/R VA N/R VI N/R WA N/R WV N/A Wl N/R WY o o o o o o o o N/A Not applicable N/R No response G-4-9 ------- |