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
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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
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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.
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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
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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
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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
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Page Intentionally Blank
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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
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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
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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.
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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.
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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
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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
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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.
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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
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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
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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.
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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
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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.
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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.
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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.
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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.
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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
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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
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• 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
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• 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
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• 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
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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
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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
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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
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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
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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
$500,000.) The primary source of funding for all programs is Title V fees (72 percent),
which are collected at the state/territory level. Other sources of funding include grant
funds, permit and other fees, and state general funds.
A program may have combined the budget for two or all SBTCP functions (i.e.,
SBO/SBAP, SBO/CAP, or SBAP/CAP). For example, a program may report a
combined SBO/CAP budget and a separate SBAP budget, which would be reflected in
the appropriate single or combined budget categories.
The range of 1999 operating budgets for the SBOs with their own budgets is shown in
Table 3-5. A comparison of SBO budgets for the past three years is not practical, as a
different number of SBOs have had their own budgets each year.
3-5
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TABLE 3-5
1999 SBO OPERATING BUDGET RANGES(42 non-combined budgets)
Budget ($)
# 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 $890,000 for New York. Title V fees again are the main funding
source (64 percent of all programs); funds from EPA grants, permit and other types of
fees, and general revenues also are used to support SBAPs.
The range of 1999 operating budgets for the SBAPs with their own budgets is shown in
Table 3-6. A comparison of SBAP budgets for the past three years is not practical, as a
different number of SBAPs have had their own budgets each year.
3-6
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TABLE 3-6
1999 SBAP OPERATING BUDGET RANGES(41 non-combined budgets)
Budget ($)
# 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
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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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.
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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
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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,
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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.
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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.
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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
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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
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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.
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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.
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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.
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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
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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
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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
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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
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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
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• 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
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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
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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
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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
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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
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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
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• 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
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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
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APPENDIX A
1999 ANNUAL REPORTING FORM
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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)
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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.
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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
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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
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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
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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
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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
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2.12 Does your program offer air-only assistance, or has your program moved into
multimedia assistance?
Air only
Multimedia
x
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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
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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
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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
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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
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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)
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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
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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).
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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
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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
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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
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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
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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
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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.).
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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
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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.
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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
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# 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
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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
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"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
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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
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• 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
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APPENDIX C
FEDERAL SMALL BUSINESS
ASSISTANCE PROGRAM
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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*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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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