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Project Title
Implementation of an Automotive Body and Automotive Repair Environmental Results Program

Project Location
State of Maine

Applicant Name
State of Maine Department of Environmental Protection (DEP), Office of Innovation and Assistance (OI&A)

Project Contact
Julie. M. Churchill, Maine DEP, Office of Innovation and Assistance; 17 State House Station, Augusta, ME 04330-0017; Phone: (207) 287-7881; Fax: (207) 287-2814; Email: julie.m.churchill@maine.gov

DEP proposes to advance an innovative environmental permitting system based on the Environmental Results Program (ERP) model for a currently non-permitted sector in Maine.

Significant Components
Hazardous Waste management and permitting under Resource Conservation and Recovery Act, Air quality standards targeting VOC reductions, and Water Regulations specifically underground injection control requirements.

Regulatory Flexibility
It is anticipated there will be no regulatory flexibility requested from the Federal government in order to implement the project. However, the project may pursue the ERP concept of assessing fees to small quantity generators who undergo the self-certification.

Project Endorsement
Senior Management of Maine DEP endorsed the project concept during a joint presentation of EPA's ERP model and our follow up explanation of the project on December 3, 2003. O fficial project endorsement letters will be provided by Senior Management representatives as well as from the following stakeholders upon final grant submission: Coastal Enterprises Incorporated, Small Business Assistance Program (SBAP) and Pollution Prevention (P2) CAP Chair, Maine Tribal Leaders, Auto Service Providers of Maine, Automotive Council of Maine, and Maine Auto Dealers Association.

2. (Section 4.2.2)
The Maine Department of Environmental Protection Office of Innovation and Assistance seeks funding through EPA's 2003/2004 Innovation Grant Program to conduct a focused Environmental Results Program including compliance and pollution prevention assistance effort targeting the auto body and auto repair Industry. Maine contains over 4,000 registered motor vehicle auto body and repair shops in accordance with 1997 U.S. Economic Census (www.census.gov). This is a significant amount of facilities and many are located in our densely populated areas that are classified in accordance with air quality non-attainment areas.

The main focus of our project is:

The vehicles we are considering to use for technical assistance purposes could include:

This Project demonstrates (section a broad innovation approach because it will reach an entire sector(s) in Maine through a new innovative self-certifying permitting program. The impact of this project will be a significant increase in compliance and a cumulative reduction in hazardous waste generated and reduction in air emissions. The goals will be to measurably reduce environmental impacts from this sector and allow the sector and DEP to jointly initiate a self sustaining ERP certification program. We will measure these outcomes by compliance numbers and volumes of air emissions and hazardous waste generated.

Project Schedule and Timeframe (Section
Time Key Activities/Tasks Products Measures Outcomes
Year 1 Develop list of ERP candidates through research and development Complete list of auto body and auto repair facilities NA Sector Contacts
Year 1 Stakeholders Meeting Commitment and development of ERP Stakeholder buy-in Sector commitment
Year 1 Development of Compliance checklist for certification Draft checklist NA Final Checklist
Year 1 Develop Environmental Business Practice Indicators (EBPIs) with Stakeholders
  • Regulatory indicators
  • Beyond Compliance Indicators
Draft EBPIs Develop Specific areas of compliance to measure Tool to measure specific areas of compliance
Year 1 Conduct Random and targeted RCRA Inspections Rate of compliance Percent of compliance measures 1. Overall compliance measures 2. Specific areas of compliance
Year 2 Tabulate Scores for EBPIs and total compliance per:
  • Facility (aggregate EBPIs)
  • Industry (aggregate EBPIs)
Rate of compliance Percent of compliance measures 1.Overall compliance measures 2.Specific areas of compliance
Year 2 Tabulate accuracy analysis scores for self certification vs. Inspections Draft Report Rate of compliance Summary Report
Year 2 Workshop Material Development Draft NA Finalized material and agenda
Year 2 Video development on HW compliance Draft NA Final Video
Year 2 Mailing 1: ERP certification notification and workshop notification Notification and awareness to sector of ERP NA NA
Year 2 Workshop I: Compliance Certification Information Explained and Distributed Education of sector Course attendees & evaluation Success of workshop
Year 2 Certification submission requests NA NA NA
Year 3 Certification Reviews % submitted % Compliance Permits issued
Year 3 Compliance Inspections Regulatory Exposure % Compliance % final compliance
Year 3 Step-Up commitment Track official agreements and sign ups Signed Step-Up agreements and commitment towards sustainability Beyond compliance % in sector Beyond compliance commitmentfrom sector participants
Year 3 Draft ERP Legislation ERP draft Legislation NA ERP Final Legislation
Year 3 Stakeholder review process Formal comments and suggestions Success of program Next steps

3. Pre-proposal Narrative
Maine DEP Office of Innovation and Assistance has educated senior management on issues related to establishing an Environmental Results Program. Funding of this program will set up an innovative yet sustainable regulatory process that can be used repeatedly throughout Maine Sectors. Working in conjunction with trade associations such as Maine Auto Dealers, will bring in sector support by involving the associations in the development in the ERP. Because there are at least 4,000 auto body/auto repair businesses in Maine, it is anticipated a large impact will be made on the aggregate reductions in hazardous waste and air emissions. The focus area of our outreach will begin with the most populated areas in Maine (southern coastal), which also includes air pollution non-attainment areas. The aggregate reduction impact in these areas will not only improve the environment but also reduce exposures to children and the mass public to air toxins from both point source and fugitive emissions.

Program Criteria
The project will build on lessons EPA and Maine Small Business Assistance Program has learned regarding innovation assistance activities including the following most recent pollution prevention and compliance outreach projects:

Target Priority Environmental Areas (Section 1.1 and 5.2.1)
This project will include the four major elements of alternatives to permitting which presents the framework as outlined in section 1.1 for environmental innovation including:

This project will target priority environmental issues as stipulated in section 5.2.1 by providing alternatives to permitting through the ERP Model, which will include multi-media compliance self-certification of water, air, hazardous waste and toxics regulations. The project will integrate innovation into permitting by implementing an ERP self certification compliance project which has been measured in other state projects as improving environmental performance. We feel this will reduce and prevent localized multi-media environmental impacts.

Likely Improvement in Results from Project Implementation (Section 5.2.2)
This ERP project differs from other approaches, as we will do extensive training, outreach and manage self-certification through Maine auto associations. Maine DEP's Office of Innovation and Assistance learned educational implementation based on the success of the Boat Building and Repair (BBR) initiative and therefore will work with the Auto associations to adopt the same approach.

Improved Efficiencies
Licensing through an ERP certification will increase administrative efficiencies by decreasing DEPs time reviewing manifest data and compliance site visits.

This also will increase efficiencies for both businesses and the department by providing a multi-media one-stop place for business to have questions answered.

Reduced Regulatory Burden
For businesses, a reduction in liability, manifest and shipping costs, switching to alternative non-hazardous parts washer will reduce potential of filing for an abbreviated license and/or filing for an air permit.

Reduced Waste and Worker Exposure
Expected measure of quantifiable environmental improvements will be reduction in hazardous waste generation, decrease in air emissions, reduction in worker exposure, increased compliance rates and overall increase in pollution prevention.

Improved Innovative Outreach
CEI and DEP will collaborate to see all business needs are met by working closely with the association members and businesses by getting their input regarding certification format, content, workshop design and implementation.

Guaranteeing Measures and Accountability (Section 5.2.3)
Baseline and final outcomes measures will include a total number of facilities, pounds of hazardous waste generated, pounds of air emissions reduced, number of workers impacted. DEP will utilize successful measuring models such as Massachusetts's ERP statistical model that will include, the following:

Development of Environmental Business Practice Indicators (EBPIs) with Stakeholders, Association members and Department Regulatory Bureaus:

We will also provide plain language guidance of our data results for stakeholders to understand the reporting and tracking of their environmental results measures. Therefore, the tracking, measuring, reporting and evaluating of the environmental results data will be readily achievable for this project. DEP's OI&A have been calculating pollution prevention in pounds and has recorded such information in benchmark studies. Since the early 1990s we have been measuring and tracking detailed outreach assistance.

We will develop environmental Business Practice Indicators including:

Regulatory Indicators

Beyond Compliance Indicators

We also will evaluate Maine DEP's Toxics and Hazardous Waste Reduction Program data in particular petroleum naptha and/or solvents in the hazardous waste generator category, review of the hazardous waste manifest data base of pounds of petroleum naptha and/or solvents and sector specific metrics.

The goals of the environmental improvement component of this project include reducing the pounds of hazardous waste generated, reducing air emissions, reducing the ozone depleting emissions, reducing worker exposures, reducing the amount of highly toxic and carcinogenic compounds being used.

The expected outcome from this project is toxics and hazardous waste reduction in the auto body/ auto repair sector, increased worker safety and health awareness, reduced worker exposures, groundwater protection, increased environmental awareness in surrounding communities, reduced worker illnesses due to exposures, reduction in fugitive emissions into communities where such businesses reside. These will be measured through existing data bases as well as through the self audit process, which will highlight and ensure identification and correction of high risk environmental activities including the use of hazardous chemicals, improper safety and health practices and release of toxic air emissions.

The long-term results of this project will be to successfully move this sector towards sustainability thorough Maine DEP's Step-Up Program. Other long-term results expected will be improved compliance, reduction in the volume of hazardous chemical use and waste generations, reduction in air emissions, reduction in worker exposure to chemicals, improved working conditions, improved environmental quality of the surrounding community.

Transferring Innovation (Section 5.2.4)
The innovation of this project, as requested under section will be transparent and readily transferred to other states and the EPA by Maine having all certification and guidance documents electronically available. We will utilize the small business assistance programs and pollution prevention list serves to notify all states of the availability of the ERP documents including our Web site link address. The specific potential for widespread application (section or use of the ERP approach as a model for next generation is high based on the feedback we have received from our stakeholders and DEP Senior Management. Promotion of compliance assistance by peers and mentors through the sector association will further guarantee this success. Our experience delivering compliance and pollution prevention assistance with the BBR industry associations has confirmed that technical information is more readily disseminated and accepted when promoted through sector's trade association(s). We will promote organization system change ( at the DEP by piloting the ERP model and instituting self-certification by auto body/auto repair businesses. This will foster an innovative environmental problem solving mechanism both internally and externally. Businesses will have a better venue to have compliance and pollution prevention information in a plain language format that they will be able to certify they meet. Plain language compliance information will also be presented through training, on-sites, mentors, compliance videotape, green shop/clean shop guide and an audit/EMS guidebook with checklist.

4. Threshold factors (Section 5.1)
Threshold factor 1
The auto body/auto repair project will utilize the ERP self-certification process which will be the use of a new innovation within Maine DEP's regulatory process. This will also apply a previously used innovative ERP model that was successfully implemented in other states such as Florida and Massachusetts. The ERP model will advance the transfer of compliance and pollution prevention information throughout the auto-body and auto-repair sector, as we will be reaching a larger audience including businesses that do not require a Department license.

Threshold factor 2
This project's overarching goal will be to prevent and control pollution by utilizing the ERP models and developing sector compliance through self-certification. This model will address multi-media pollution through compliance certification of regulations pertaining to the Clean Air Act and the Clean Water Act as well as State specific solid and hazardous waste regulations, air quality regulations and water/land usage regulations.

5. Qualitative Selection Factors
The ERP project described throughout this grant will incorporate Geographic Diversity and Project Diversity. The feasibility of this grant is high and our department is ready, as senior management will be committed to the project. This project as indicated will incorporate a high degree of collaboration with other agencies and internal department collaboration as well.


[Budgetary information withheld by U.S. EPA]


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