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State Innovation Grants

EPA 2005-2006 State Innovation Grants Competition Pre-Proposals

Primary Category: National Performance Track Program and State Performance-Based Environmental Leadership Programs

Title: Implementing Kentucky’s Environmental Leadership Program - A Vertical Start-up Model with Multi-State Applicability

Location: Frankfort, Kentucky

Applicant: The Kentucky Department for Environmental Protection

Cheryl Taylor
Office of the Commissioner
14 Reilly Road
Frankfort, Kentucky 40601
(502) 564-2150 ext. 125 phone
(502) 564-4245 fax

Statement: This project is not specifically focused on hazardous waste management or permitting under RCRA nor is it being executed with or funded by any other federal or EPA program.

Federal Regulatory Flexibility Requirements: Generally, there will be a need for the Kentucky DEP and the federal EPA to cooperate in support of potential benefits that will be offered to new environmental leadership program members. It is anticipated that a Memorandum of Agreement will be developed to assure Kentucky and the federal EPA are aligned on what benefits/incentives will be offered and honored by both regulating agencies.


The mission of Kentucky’s environmental leadership program is to promote, reward, and encourage superior environmental performance throughout the Commonwealth of Kentucky. The goal of the program is to positively impact the quality of life for Kentuckians by encouraging continual improvement in environmental performance through commitment, partnerships, systemic management, and thoughtful growth. The program members will enhance the environment and society through public and private participation and networking, the development of innovative technologies, and the application of sustainable strategies. Specific program objectives are to:

This program directly supports EPA’s Strategic Goals as well as several Cross-Goal Strategies. By improving overall compliance performance and developing the concept of environmental stewardship, the program specifically aligns with Goal 5: Compliance andEnvironmental Stewardship, and with 5.1 Improve Compliance and 5.2 ImproveEnvironmental Performance Through Pollution Prevention and Innovation. In addition, the program supports Goal 1: Clean Air and Global Climate Change, and Goal 2: Cleanand Safe Water, by encouraging pollution prevention practices and directly measuring the amount of pollution reduced to each media. The program also will enhance Goal 3: Land Preservation and Restoration, and Goal 4: Healthy Communities and Ecosystems by identifying and rewarding the completion of projects that specifically improve the community through cooperative efforts. Cross-Goal Strategies that are used in the program include developing Partnerships, sharing Information through reporting, networking, documentation, and education, and rewarding Innovation in practices and technology

Project Schedule

A project to develop Kentucky’s environmental leadership program was initiated in March, 2005. Implementation of this program has been designated as one of this year’s top three priorities for Kentucky’s Department for Environmental Protection. A design team was chartered and conceptual development began with a review of existing state programs, EPA’s National Performance Track program, and of complimentary leadership programs such as OSHA’s VPP and Energy Star to search for ideas that could be re-applied in Kentucky’s program. The fundamental goal of the program is to achieve better environmental results by enrolling and rewarding entities who are top performers and to support and offer incentives for improvement to entities whose performance is at or below compliance level. The program framework was drafted in 8 weeks and is currently in review. Input on the framework and proposed incentives will be sought from both regulated and non-regulated entities to assure a superior product. Following final approval, regulations will be promulgated as needed to support the program. The program is anticipated to be presented to the public at an environmental event in late September, 2005. With that presentation, the implementation phase of the project will begin. A number of activities will take place concurrently.

Start-up and Implementation Milestones Start

Target Completion



Public Announcement of the Program at Kick-off event 9/05


Develop MOA with EPA National Performance Track 9/05


Educate Field Office Personnel on program 9/05


Develop on-line application and Web page 9/05


Link Kentucky Program to EPA’s NPT program 9/05


Publish Promotional Materials 9/05


Publicize Program for Initial Enrollment (Educational events) 9/05


Attend Region 4 Networking Event (Initiate State Partnerships) 10/05


Redesign Staff Roles to Support the Program 10/05


Registration for Program Candidates 1/06


Provide support to candidates (complete entry requirements) 1/06


Announcement of Inaugural Membership 4/06


Review Initial Program for Improvement opportunities 6/06


Plan and Deliver Program Networking event(s) 5/06


Pre-work and Completion of First Annual Report 10/06


Review Reporting for Improvement Opportunities 3/07


Review Program for Improvement Opportunities 4/07


Plan and Deliver Program Networking event(s) 5/07


Document Program Development Process 6/07


Project Narrative
Kentucky’s newly developed voluntary recognition and incentive program will encourage members to focus on issues important to their communities, to take a creative approach in solving local and regional problems, and to employ networking and partnerships with citizens, businesses, and governments to achieve environmental goals. Members of the program will meet or exceed environmental compliance requirements and will commit to continually improving their results through systemic resource management processes. As environmental leaders, members will be encouraged to build environmental stewardship into their daily work and to emphasize greater holistic responsibility for environmental results. The program will also encourage partnerships between regulated and non-regulated organizations, business sectors, regional stakeholders, and other resources who can contribute to Kentucky’s future through educational and outreach activities. Participants who meet eligibility requirements for membership and who agree to support and deliver program results will be recognized and rewarded for their leadership.

Although Kentucky’s design has reapplied ideas from other successful state programs, this program will be innovative in several ways including: (1) Kentucky’s program will align with EPA’s National Performance Track program from the outset providing optimum membership benefits for the state’s environmental leaders; (2) Kentucky’s program will introduce an Advocate category of membership that includes a large professional resource group that can provide environmental support services to potential members at no or low cost (ex. training, auditing, etc.); (3) Kentucky’s program will work to align previously separate leadership programs, such as OSHA’s VPP, Energy Star, Green Buildings, Smartgrowth, and H2E, to encourage multi-media benefits to the environment and to human health; (4) Kentucky’s program will select and publicize annual environmental priorities/goals and will reward members that complete projects that help to meet or exceed them; (5) Kentucky will develop partnerships with other states in EPA Region 4 and with bordering states to develop membership criteria and support for business sectors that are common to the area such as mining, agriculture, and land development, to encourage regional environmental improvements, and; (6) Kentucky will develop a library of materials and guidance documents to make it easier for other states to reapply the rapid design and start-up methodology.

Conceptually, Kentucky’s program is designed to appeal to a broad range of businesses, industries, and non-governmental organizations (NGO’s). By encouraging a diverse membership, the program will provide an innovative opportunity for building networks not only within like businesses and NGO’s, but also across traditional boundaries. Applicants to the program enter as a Candidate and remain at that status until entry criteria are satisfied. Candidates enter the program through the portal of the newly established Compliance Assistance Division where they are provided some regulatory protection via Kentucky statute during the assessment process. After entry criteria are confirmed, the Candidate may chose to participate in one of three membership tiers; Master (aligns with EPA’s NPT program), Leader, or Partner. Each tier requires correspondingly higher levels of environmental performance and provides additional incentives for meeting/exceeding goals and for completing state priority projects. In addition to the three tiers, a fourth membership category will be established for Advocates. Advocates are typically non-regulated entities who have a strong interest in environmental improvement. Although some other states have a membership category primarily for environmental interest groups, Kentucky’s Advocate members will provide innovation to the program through its diversity. Many Advocate members are anticipated to provide an environmental service that offers a pool of expertise for candidates who struggle to meet entry criteria. Advocates can provide training and auditing services as well as mentoring to Candidates and members at no or low cost. By providing this outreach service, Advocates meet their annual improvement project requirement and are recognized. Without this service, many potential Candidates, particularly small businesses, would not join the program because of costs or lack of resources. Since the majority of Kentucky’s businesses are small, it is anticipated that the services of Advocate members could break barriers to membership for many and will boost participation in the program.

Master members will also be expected to offer outreach services and support for lower tier members. In addition, because of the timing of the program’s start-up, Kentucky plans to offer dual membership in EPA’s NPT to Masters and to align incentives from the outset of the program. Although other states are working to align with NPT, Kentucky has the unique opportunity to start-up a program in alignment. As a result, this will expedite anticipated environmental benefits and will increase total NPT membership.

Another innovative feature of Kentucky’s program is the anticipated partnerships with other existing leadership programs. To the regulated community, the number of voluntary leadership programs available is confusing and competitive although each has noble goals. Kentucky’s vision is to align programs from all government segments where possible and to offer recognition for accomplishments that could be non-traditional. Many entities operate a business that combines the strengths of health, safety, energy, and environment into one program because it is cost effective and synergistic to do so. By crediting accomplishments in appropriate areas, energy savings or hospital bio-waste for example, Kentucky’s environmental leadership program will recognize the holistic nature of environmental protection and will interest more potential members. Long term, leadership programs could share auditors and report data as appropriate to improve efficiencies and reduce costs for all involved.

Because Kentucky’s environmental priorities will change over time, the program will identify and publicize annual focus areas for environmental improvement. To enroll program members in support of focus area projects, those who chose to commit and complete a project in the focus area will receive additional recognition and awards from the state. In a broader context, Kentucky plans to network with Region 4 and bordering states to identify regional focus areas and project opportunities that program leaders could choose to adopt. Completion of a regional project will also be recognized and rewarded.

Nearly half of all states have some form of environmental leadership program in place. There is little consistency between the programs and although EPA NPT representatives are beginning to network with states, there is significant work remaining to be done to maximize the improvements to the environment that leadership programs can contribute. Kentucky plans to document the development process of the new leadership program and offer guidance to other states that chose to move their programs beyond command-and-control compliance.

Performance measures for implementing Kentucky’s environmental leadership program will center on start-up effectiveness and outputs during the first year and environmental outcomes in the second. In the first year, measures will include;

Output data measurement is important in the first program year so resources may be allocated in weaker program areas. Establishing a baseline for each member will also be critical for goal-setting, not only for individual members, but also to measure program effectiveness over time.

In the second year, program measures will include both quantitative and qualitative data;

Quantitative Data

Qualitative Data

Longer-term measures will be evaluated after the leadership program’s second year to determine additional program impacts such as improved public perception of environmental health, increased tourism, or increased economic opportunity for the state as a result of the enhanced environmental image the program will generate.


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