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Wisconsin

Contact
Jon Heinrich; Bureau of Air Management; Wisconsin Department of Natural Resources; 101 S. Webster St., P.O. Box 7921; Madison, WI 53707-7921; Phone: (608) 267-7547; Fax: (608) 267-0560; Email: jon.heinrich@dnr.state.wi.us

Project Narrative

Improved Environmental Results and Increased Regulatory Flexibility in Air Permitting for the Printing Sector Using Environmental Management Systems and an Environmental Results Program

Introduction

The Wisconsin Department of Natural Resources (WDNR) Air Program has recently commenced an extensive evaluation of their air permitting program. This evaluation was undertaken as a priority of WDNR Secretary Scott Hassett who directed the Air Program to develop and implement ways to improve our efficiency in environmental regulation and program implementation while meeting the environmental protection needs of our citizens . The principal goals of this initiative are to streamline the process and find innovative air permitting alternatives. This initiative came about due to concerns over the amount of effort and time involved in air permitting as well as reservations about the value of this activity in achieving environmental improvement. Also, like many state and local environmental agencies, resources at WDNR are declining and this trend is likely to continue for the foreseeable future. There is also a strong industry interest in having WDNR adopt a more comprehensive approach to environmental regulation. All these circumstances provide a strong incentive for the development of innovative and efficient tools.

We are interested in receiving funding support from EPA for an innovative project that would apply both Environmental Management Systems (EMS) and an Environmental Results Program (ERP) across an entire industry sector with a goal of reducing the air permit burden while providing regulatory flexibility and improving the environmental stewardship of participants. A secondary goal would be to develop this proposal in such a manner that it could be applied to other industrial sectors as well as include other environmental media. By partnering with our Department of Commerce Small Business Assistance Program, we believe we can improve compliance with air, waste and water regulations through an ERP program for the small facilities. For larger printing facilities we would seek to achieve air emission reductions beyond current regulatory requirements and reduce their air permitting burden through the continuous quality improvement approach of an EMS based permit system.

Wisconsin is implementing a nationally recognized "cluster based" approach to economic development. The printing industry is one of ten targeted industry clusters in the state and a good candidate for this proposal. The printing industry in Wisconsin is diverse in size and products, vital to the state's economy and a significant source of volatile organic compound and hazardous air pollutant air emissions.

Outcome Goals and Objectives

Under current Wisconsin Law, both major (federally regulated) and minor (state only) sources of air pollution are required to obtain an air pollution control operation permit. Wisconsin Law also requires that any new printing facility that would emit more than 1,666 pounds of VOC in any month, or any change that could potentially increase emissions at a printing operation emitting more than 1,666 pounds of VOC in any month must obtain an air pollution control construction permit prior to commencing construction regardless of whether the facility is a major or a minor source. These complex permitting requirements are a significant administrative burden to both the WDNR and to the facilities that must obtain them. In this project, we are proposing an alternative approach that will provide relief of the administrative burden of issuing all types of air permits while improving the environment.

For our small printers, we are proposing to develop an ERP modeled after the work done in Florida, Massachusetts and Rhode Island. For larger printing facilities, we are proposing to replace the traditional operation and construction permitting requirements with an EMS based permit. Once an "EMS-Permit" is issued, it would cover many situations that would traditionally require construction permitting under our state program. The WDNR would take on the challenge to develop an EMS-Permit equivalent to a Title V operation permit.

Project Schedule and Time Frame

The project will begin in July of 2004 and continue for 3 years. The first year will be spent in program development including educational efforts for department personnel, the environmental community, and the business community. We need one year to get the program up and running including development of program materials and getting information and materials online. The second and third years will be spent running the program, learning how to bring new facilities in, troubleshooting and making improvements. More education will be needed for all stakeholders, internal and external. By the second half of the third year we will have an outside agency hired and they will begin program evaluation. Final evaluation will be completed by July 2007. Most measurements will be done through existing databases and through customer satisfaction surveys. Also in the third year we will begin looking at how we can extend this program to other industry sectors. We will use the results of the program evaluation to make improvements and begin bringing other sectors in who express an interest in working with us to develop an ERP or EMS-Permits for their sectors.

Program Criteria

A. Priority Environmental Issues Addressed

Our project is aimed at reducing emissions of volatile organic compounds (VOC), precursors to ozone formation, and hazardous air pollutants from the use of inks and solvents in the printing industry.

B. Improvement in Results from Project Implementation

The administrative burden for the small printers will be eased. Small businesses in particular find the permitting process arduous and confusing. An ERP tailored to small printers would be much easier to follow than a traditional permit. The amount of time a permittee must spend with a compliance inspector should be reduced and the amount of time required for annual certification should not be greater than would be currently required under traditional permitting. The ERP also has more than just administrative advantages. Massachusetts showed that the number of facilities they knew about before their ERP was less than half of the number of facilities that they are now seeing participating in their program. We also expect to find and get into compliance a substantial number of small printers that have not applied for a state operation permit as required.

An EMS-Permit for larger printing facilities should also yield significant administrative savings. Currently for WDNR, a large printing facility requires an operation permit taking at least 250 hours to issue. Because some of these facilities are subject to MACT standards, an additional 50 hours may be needed to put the correct MACT language into the permit as well. In addition, a large facility may do a new project yearly requiring the issuance of a construction permit, perhaps another 150 hours and the subsequent issuance of a revision to the operation permit, taking 25 hours. Our permit tracking system indicates that 118 printing facilities have submitted applications for a Title V permit. Compliance inspections, monitoring reports, annual certification reports, and enforcement action add more administrative hours to the total regulatory effort.

Finally, the environment will benefit from an EMS-Permit in place of traditional permitting. Currently, with the exception of actions requiring application of the best available control technology or the lowest achievable emission rate, the permit itself does not drive emission reductions. Our administrative code contains all the requirements applicable to a source regardless of whether they are contained in a permit document or not. An EMS, however, uses a plan-do-check-act strategy to drive continuous quality improvement. The printing sector in Wisconsin has already demonstrated, through their participation in the Great Printers Project, that they are committed to pollution prevention and continuous quality improvement. We will show that emission reductions are greater under an EMS-Permit than under a traditional permitting program.

How does the proposed tool or approach differ from current methods (i.e. uniqueness)?

How does the project build on "lessons learned" from prior experience (not limited to the proposing States own experience)?

The work previously performed by Florida, Massachusetts, and Rhode Island will be relied upon as a foundation for ERP development. Colorado's experience will be considered as we develop an EMS-Permit approach. We will also incorporate findings from own permit improvement initiative and the experience of the Small Business Assistance Program in our Department of Commerce who are already exploring an ERP.

What are the quantifiable improvements in environmental outcomes expected to result from implementation of this innovation?

Using our air emissions inventory we will be able to track any reductions in VOC and hazardous air pollutants that result from this project. Our inventory will also allow us to track the number of printing facilities and track the percentage of those participating in the proposed program.

What are the measurable improvements in administrative efficiency and program operational costs that may result from this program?

The ultimate goal is to reduce the overall number of permit actions necessary and to increase the operating flexibility of a facility without compromising on environmental protection. Through our compliance database we will track the hours needed for compliance, certification etc. before and after implementation. We can also use this database to show compliance rates for printing facilities.

What are the quantifiable costs and efficiency improvements for the permit holders/regulated entities resulting from implementation of this innovation?

Construction and operation permit process relief for participants and their ability to implement alternative cost-effective compliance determination techniques.

C. Measuring Improvement and Accountability

What are the goals for environmental improvement?

The main goals of our project are to use innovative regulatory strategies to relieve administrative burdens of a "cluster initiative" business. In partnership with the Department of Commerce Small Business Assistance Program we will seek to:

What are the indicators that will be used to show environmental improvement?

How and when will the baseline measurements be developed?

Surveys have been conducted in connection with the air permit program evaluation already underway that establish a baseline measurement of customer satisfaction with the current system. Information already exists on the number of personnel needed to administer the current system and the amount of time to issue a permit. Additional baseline measurements will be gleaned from our air emission inventory. This will allow us to estimate the number of the targeted business sector facilities as well as the amount of emissions. We will use our compliance data system to make an initial estimate of the rate of compliance with our rules and regulations.

What are the plan, timeline, and commitment for measuring and evaluating how well the project meets its goals and objectives?

At the end of the 3-year initial project period we are committed to hiring an outside firm to evaluate the project and prepare a report. This final report will include findings of compliance rates, number of facilities in the program, emissions, costs of program administration, and customer/internal satisfaction results. The final report will be available on our web site.

What are the expected short-term (within one to three years) results to be obtained through this innovation and how will they be measured?

We expect to show increased compliance rates, decrease in required permit actions, and increase in participant and stakeholder satisfaction. Our air emissions inventory, compliance database, administrative database and customer satisfaction surveys will be used to measure results.

What are the expected long-term results to be obtained through this innovation, how will they be measured, and what is the time span for those results?

The longer-term results of this project, 5 years, are the expectation that ERP and EMS-Permits will be extended to other cluster businesses and eventually, any other business sectors that express interest and desire to be involved. As compliance rates increase we hope to be able to maintain Wisconsin's high environmental standards at staffing levels dictated by tighter budgets. Ultimately, 10 years down the road, we expect that these innovations would lead emission reductions in substantial amounts and to all Wisconsin's counties being declared attainment for ozone and hazardous air pollutant emissions from this industry do not exceed levels that are harmful to human health and the environment.

D. Transferring Innovation

What methods will be used to document the outcomes and methods of this innovation and make information available to other jurisdictions?

As our initial project winds to a close we expect that many business sectors will be interested in using ERP or EMS-Permits to enhance their flexibility and decrease their regulatory burden. Our final report will be made available on the Internet and we will have public access to all ERP and EMS documents. Businesses will be encouraged to work with the Wisconsin Department of Commerce and the WDNR to develop more ERP and to use EMS documents from other businesses as a foundation for their own EMS-Permit.

What is the specific potential for widespread application or use of the tool/approach as a model for "next generation" environmental protection?

To make the next generation happen will require a system change. The WDNR is actively engaged in a thorough evaluation of our "system" as part of our air permit improvement initiative. This improvement initiative supports innovation and this proposal is certainly compatible with that initiative and vital to the changes in approach we need to adopt and implement.

How will the application of this innovation be used to promote organizational system change, or develop a culture of innovative environmental problem solving as a "way of doing business" within the state more broadly?

By focusing air permitting more on environmental results and by involving business and their communities as active partners in environmental protection.

What commitments can the proposing state make to provide consultation and mentoring to other states wishing to adopt similar innovations?

We are committed to meeting with any business groups or governmental agencies to share our experiences, successes and problems associated with this project.

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