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Summary Information

2002 Project Category for the State Innovation Pilot Grant
Re: permitting innovation

Self-audit Software Package for Personal Digital Assistants

Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84116

Renette Anderson, Small Business Ombudsman
UDEQ Planning and Public Affairs
168 North 1950 West
Salt Lake City, UT 84116
Phone: (801) 536-4478 Fax: (801) 536-4457

Marv Maxell, Air Standards Branch Manager
UDEQ Division of Air Quality
150 North 1950 West
Salt Lake City, UT 8411
Phone: (801) 536-4082 Fax: (801) 536-4099

Other Projects
Project will be developed and tested as a pilot for inclusion as a part of the state's performance track-type program. The development phase of that project is nearing completion. An EPA planning grant has been used to assist in that process. The project will also be developed to compliment the state's electronic information initiative.

Regulatory Flexibilty Needed
There may be some regulatory flexibility required to allow self-certification. It is anticipated that, if needed, it will be requested as part of the performance track package. Our performance track team includes a member of EPA Region 8's Enforcement staff. He is working with us to identify issues and possible options.

Department Support
This project will be piloted within our Air Quality Division and will be developed under the general oversight of Brent Bradford, UDEQ Deputy Director.

Budget Summary

Preposal Narrative

Doing business electronically is extremely popular. Things that seemed so innovative a few years ago - online shopping, banking, tax filing - are now taken for granted by users. Moving permitting and compliance-related functions into an electronic arena has been a natural step that we have been undertaking in phases. For our next step, the Utah Department of Environmental Quality proposes to use this grant money to develop an electronic "self-audit" package for use on a personal digital assistant (PDA) that would:

1. Allow Title V permit holders to track their own compliance status on a regular basis.

2. Provide an interactive audit process for those in the state's performance track program that include the ability to self-certify electronically.

Targeted Priority Environmental Area
The grant will be used to develop a "pilot" within our air program. Here, the ultimate goal would be to reduce smog by making it easier for industry to monitor its own progress and to prevent pollution before it occurs. For those in our performance track program, the expanded package would offer one more incentive to air emissions.

This pilot would be designed to be easily adaptable by the water and waste programs to accomplish similar goals there. Since these programs are all based, primarily, on federal regulations, the pilot should be easily adapted by other state programs.

Use of Incentives as a Tool
Over the past several years, stakeholder feedback has focused on requests to encourage electronic permitting and self-audits. UDEQ is in the process of developing an electronic permitting process. We propose to use the grant money to further work with industry and develop an electronic self-audit process that could be accessed on line or loaded into a PDA.

The tool would be designed starting with a "core" checklist currently used by compliance inspectors. It would then be customized, pulling parameters flagged in the permit and, where applicable, from the voluntary pollution reduction measures contained in the performance track agreement. The self-audit would allow the industry to monitor compliance, and flag potential issues before they emerge as actual problems. For those in performance track, it would allow for self-certification and would be coupled with the program's reduced oversight incentive.

We intend to partner with an industry association and our Small Business Compliance Advisory Panel at the development and testing stages to ensure the product improves the process for both industry and UDEQ and that it effectively reduces and prevents pollution.

Because it is our intent to use the package as part of our performance track incentives, we will use information gathered from other programs across the country and also be seeking feedback from our Performance Track workgroup.

Transferring Innovation
Many businesses meet environmental requirements only because they have to; going beyond that may not seem worth the extra effort, especially for owners pressed for time and feeling they lack the expertise. Offering an easy-to-use electronic tool will be empowering. It will give the owner a way - right at his or her fingertips - to track progress and minimize (or eliminate) surprises by flagging potential compliance concerns well before they become problems.

By thinking through the development of this package, our inspectors and permit writers will own it - reinforcing a culture of innovative problem solving as a way of doing business.

This pilot would be designed to be easily adaptable by the water and waste programs.

Results will be measured by:

1. Feedback from our industry partners and from air staff at key stages of development. Success will be determined here by the ease in which they are able to use the program and by their indicated willingness to try it outside of the pilot development.

2. Requests from performance track applicants to use the tool as part of their incentive package.

3. In the longer term, demonstrated pollution prevention and/or reduction through the use of the tools. This will be measure by annual performance track progress reports by industry and improvements noted by DEQ inspectors as part of their routine visits.

Budget and Time Line

The project will be completed in the following steps:

Phase One: (9-12 months)
1. Hold 1-2 workgroup meetings with staff and with partners to "scope out" and clarify expectations.

2. Gather existing materials. Identify components from existing tools that need to remain and opportunities for streamlining or improvements. Develop a written approach and take back to smaller group for feedback.

3. Turn work over to programmer. Once a beta type is developed, allow for testing by partners.

Phase Two: (12 months)
1. Work with designated industry sector to get several applicants for performance track who are also interested in using the tools.

2. Monitor progress by industry user and by staff. Troubleshoot any unexpected problems that arise.

Phase Three:
1. Evaluate results reported in performance track annual report. Compare with those who are in the program but not using the tool.

2. Make any adjustments to the tool and make recommendation for expanded use.



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