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Underground Storage Tank Program
Environmental Results Program - Introduction

Self-Certification On-Line - Login Here

Click here for printable versions of the Self-Certification Workbook and Checklist

Click here for the electronic Return to Compliance (RTC) Form

Results!

In 2005, we randomly selected 100 facilities for inspection to determine our Baseline Compliance Rate. The compliance rate was 68% (95% degree of confidence). After the first round of self-inspection and certification in 2007, we randomly selected another 100 facilities to determine the compliance rate. We were very happy to see the compliance rate rose to 84%!


In 2009, we conducted another round of compliance inspection and found the compliance rate to be 81%. For a more detailed look at the compliance data, click here.

About the Environmental Results Program (ERP)

Protecting the Environment and Helping Small Businesses

ERP is a unique environmental performance initiative first developed by the Massachusetts Department of Environmental Protection. The VT Department of Environmental Conservation (DEC) is targeting Underground Storage Tank (UST) facilities for our first ERP. ERP features a multimedia, sector-based regulatory approach that features annual certifications of compliance by facility owners/operators. ERP applies three innovative tools to enhance and measure environmental performance:

  • Annual self-certification of compliance by companies to increase self evaluation and accountability;
  • Compliance assistance from the agency through outreach and workbooks;
  • Performance measurement methodology to track results, determine priorities and strategically target inspections and compliance assistance efforts.
    ERP Tools
    Self-certification. ERP requires that a senior company official annually certifies that the facility is and will continue to be in compliance with all applicable state UST, Air, Underground Injection Control (floor drains) and hazardous waste management performance standards. DEC provides compliance assistance (see below) for facility managers so they can better understand the information that is the basis for their certification. Facilities that are not in compliance must file a "Return to Compliance" plan, which describes the corrective actions that the facility will take and a schedule to achieve full compliance.
    Compliance Assistance. DEC assists the self-certification process by providing compliance assistance for all ERP facilities. Compliance assistance includes sector-specific workbooks and workshops that clearly explain facilities' environmental obligations as well as sound environmental practices that go "beyond compliance".
    Performance Measurement. DEC is utilizing an evaluation methodology that uses random sampling and statistical analysis to measure the performance of ERP facilities. This methodology validates the performance of the program itself, and is used to target facilities for inspections and compliance assistance. The evaluation tracks environmental business practice indicators (EPBIs), which are industry-specific performance measures that provide snapshots of facilities' environmental performance before and after certification and on a long-term basis.
    DEC hopes to be able to expand the program into other sectors, as an innovative approach to regulating facilities.


Why is the Environmental Results Program Unique?
The ERP approach is unique in several ways:

• The compliance certification process involves industry proactively in ensuring its environmental compliance. Yearly facility reviews and annual certifications of compliance lead to more comprehensive environmental performance than short-term compliance resulting from infrequent inspections.
• Making information about industry's environmental performance and the effectiveness of ERP readily available to the public makes both industry and government more publicly accountable for their performance. Periodic reports provide the public with meaningful information about industrial environmental performance.
• DEC oversees the program by reviewing certifications and conducting random and targeted compliance inspections, to make sure that the program is working. DEC can focus its limited resources on companies and facilities that are not performing adequately by targeting inspections and assistance efforts to facilities with specific compliance problems (including failure to file their certifications), and to demonstrated sector-wide problem areas.

What is an EBPI?
An Environmental Business Practice Indicator (EBPI) is one of the tools developed by the Environmental Results Program. EBPIs are industry-specific performance measures that provide a snapshot of a facility's environmental performance.

The EBPIs include both traditional program compliance measures (e.g. level of compliance with labeling, record keeping) as well as measures that go beyond program compliance.

DEC conducts statistical analysis of the EBPIs along with random inspections and review of self-certifications to evaluate the performance of individual facilities, sectors and ERP as a whole. We use its evaluation to:

1. Determine industry-wide compliance rates and actual environmental performance;
2. Make more informed and strategic resource allocation decisions for inspections and compliance assistance efforts; and
3. Evaluate ERP's programmatic effectiveness.


What Problems Is ERP Designed To Solve?
DEC undertook ERP to address several concerns, in its view, about the effectiveness of the existing regulatory system for small business and the agency's limited resources. DEC believes that the traditional regulatory approach:

• Does not efficiently cover all facilities regulated by the state; we were only inspecting approximately 100 UST facilities per year, meaning it might be 10 years between inspections at some facilities.
• Does not sufficiently encourage multimedia compliance;
• Needs to encourage more pollution prevention;
• Could benefit from more compliance assistance to inform small businesses of their environmental requirements.
• Does not achieve a desired level of environmental performance.
• Does not promote lasting change and improvement in environmental performance at facilities because of: the sporadic nature of inspections; facilities' staff's limited understanding of regulatory requirements and beyond-compliance possibilities; and the frequent turnover of facilities within the regulated sectors.

Benefits of ERP Approach and Tools

Environmental Benefits: ERP can achieve measurable reductions in environmental impact of covered facilities. ERP prompts industry to increase its focus on complying with environmental laws, and on overall environmental performance. For example, in the dry cleaning sector in MA, 77 percent of the indicators showed either high performance or a statistically significant increase in performance in a comparison between the baseline and first year ERP results. High performance includes such practices as not discharging to septic systems and installing appropriate pollution control equipment.

Industry: ERP can assist facilities in understanding their environmental regulatory requirements and in monitoring their environmental performance. It also engenders high-level management commitment to environmental performance by requiring company owners to certify their compliance, and allows facilities to project a positive environmental image to the public.

Public: ERP holds industry accountable for its environmental performance and increases public awareness of industry's environmental impacts. Stakeholders participate in the development of the ERP compliance workbooks and program design. The public also benefits from ERP through improved environmental results for limited government resources. In addition, ERP documents environmental achievement in a manner that can be more easily understood by the public.

Agency: DEC hopes to benefit from ERP through its improved ability to track environmental performance trends and specific environmental practices of whole industry groups and individual facilities. ERP increases government's cost effectiveness by allowing DEC to dedicate its limited resources to the areas of greatest concern. ERP results in a multimedia, incentive-based regulatory system that is designed to produce lasting improvements in industry's environmental performance.

 

VT DEC Waste Management & Prevention Division 1 National Life Drive - Davis 1  Montpelier, VT  05620-3704  Tele: 802-828-1138   Fax: 802-xxx-xxxx

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