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APPENDIX F STATE PROGRAM APPROVAL HANDBOOK OSWER Directive 9650.11 May 11, 1992

APPENDIX F

Capabilities Matrices

OSWER DIRECTIVE 9650.11

UPGRADING:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF UPGRADING REQUIREMENTS	VALIDATING PROPER UPGRADING	TAKING ACTION AGAINST VIOLATORS OF UPGRADING REQUIREMENTS
State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Musts for USTs," State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the upgrading requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State requires jobbers to distribute information on upgrading requirements. State publicizes violations of requirements in local newspapers or trade publications. State includes information on upgrading requirements as "statement stuffers" in tank fee invoices State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the upgrading requirements State holds press conferences on regulatory requirements	State conducts preventative inspections to validate upgrading. State requires owners and operators to notify agency of upgrade or repair. State agency or fire marshal's office requires permits for upgrade or repair. Local fire departments inspect facilities. State conducts targeted inspections of facilities in areas of greater sensitivity. State provides owners or operators with self-audit forms for self-inspection.	State bars non-upgraded tanks from receiving state funds for cleanup. State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets"). State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State has the ability to remove tanks when the owner or operator is recalcitrant. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

OSWER DIRECTIVE 9650.11

NEW UST SYSTEMS AND NOTIFICATION:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF NEW UST SYSTEMS AND NOTIFICATION REQUIREMENTS	VALIDATING PROPER DESIGN, CONSTRUCTION, INSTALLATION OF NEW UST SYSTEMS	VALIDATING COMPLIANCE WITH NOTIFICATION REQUIREMENTS	TAKING ACTION AGAINST VIOLATORS OF NEW UST SYSTEMS AND NOTIFICATION REQUIREMENTS
State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Musts for USTs", State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State requires tank vendors to distribute information on notification requirements. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the new UST system requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television State requires jobbers to distribute information on new UST system and notification requirements. State publicizes violations of requirements in local newspapers or trade publications. State includes information on new UST system and notification requirements as "statement stuffers" in tank fee invoices. State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the new UST system and notification requirements State holds press conferences on regulatory requirements.	State certifies installers of new UST systems to ensure proper installation procedures. Certification requirements may include: secured course work written tests review of applicants qualifications by independent board State issues installation permits for new UST systems based on UST and facility characteristics descriptions or on-site UST system inspections. State requires all companies offering UST services to register with environmental agency before commencing work. State requires prospective owners and operators to submit plot plans and specifications to fire marshal's office and receive installation approval before commencing work. State provides tank installation videos to tank installers. State distributes information on latest tank installation techniques to tank installers. State sends inspectors to all installations State sends inspectors to a selected number of installations based on facility criteria (e.g., proximity to aquifers, compliance history, previous experience of contractor). State requires owner or operator to submit daily inventory results for a specified period immediately following tank installation.	State issues registration sticker or certificate after notification or existence of new UST systems. State requires that this tab be placed on or near UST system to enable fuel distributors to verify registration status of UST system before making a delivery. If tags are missing then distributor must notify the state agency. State develops and maintains UST data base which tracks: permit and closure deadlines and upgrading dates. State fire authority has local engine companies drive through their districts looking for visible vent pipes to identify unknown/unregistered tanks. State conducts phone surveys of potential UST facilities to determine if notification requirements have been met. State reviews building code/permit files to potential UST facilities. State requires distributor to submit lists of customers to verify compliance with notification requirements. State requires UST vendors to submit lists of customers.	State requirements prohibit fuel distributors from delivering to UST systems that do not display registration stickers or tags. If tags are missing, then distributor must notify the state agency. State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., traffic tickets") State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or fails to reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State has the ability to remove tanks when the owner or operator is recalcitrant. State levies penalties or takes other enforcement actions against manufacturers that sell USTs not authorized under new UST standards. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State require violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

OSWER DIRECTIVE 9650.11

GENERAL OPERATING REQUIREMENTS:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF GENERAL OPERATING REGULATIONS	VALIDATING COMPLIANCE WITH GENERAL OPERATING REGULATIONS	TAKING ACTION AGAINST VIOLATORS OF GENERAL OPERATING REGULATIONS
State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Musts for USTs", and copies of the regulations). State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the general operating requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information on oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences State sponsors public service announcements on radio and television. State requires jobbers to distribute information on general operating requirements. State publicizes violations of requirements in local newspapers or trade publications. State includes information on general operating requirements as "statement stuffers" in tank fee invoices State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the general operating requirements State holds press conferences on regulatory requirements.	State requires labeling of tanks and fill pipes to identify tank material and proper regulated substance for tank. State requires special compatibility labeling of fiberglass-reinforced plastic tanks. State tests and licenses product transporters in spill and overfill prevention. State certifies tank installers, closers, testers, and supervisors according to nationally recognized codes. State requires owners or operators to obtain permit before beginning repairs. State requires that tanks have attached label indicating volume to prevent overfills. State develops standardized format for recordkeeping to aid owners and operators and inspectors. State requires owners and operators to submit documentation on tank tests. State requires that records be kept on-site for out-of-service tanks. State requires tank testers to submit documentation on tank tests. State requires records of daily inventory tests.	State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets"). State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities or recalcitrant violators. State has the ability on remove tanks when the owner or operator is recalcitrant. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

OSWER DIRECTIVE 9650.11

RELEASE DETECTION:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF THE RELEASE DETECTION REQUIREMENTS	VALIDATING COMPLIANCE WITH RELEASE DETECTION REQUIREMENTS	TAKING ACTION AGAINST VIOLATORS OF RELEASE DETECTION REQUIREMENTS
State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Musts for USTs," "Leak Lookout," State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State publishes articles or announcements in newspaper and oil industry and trade association publications. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the release detection requirements. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State requires jobbers to distribute information on release detection requirements. State publicizes violations of requirements in local newspapers or trade publications. State includes information on release detection requirements as "statement stuffers" in tank fee invoices State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the release detection requirements. State holds press conferences on regulatory requirements.	State or local agency conducts inspections, or "spot checks" at facilities to determine compliance status. State requires evidence of release detection compliance at various times, including: prior to issuing operating permits; on notification forms; or prior to delivering product. State or local agency staff monitor leak detection compliance by reviewing written results or tank tightness tests, and requiring owners or operators to submit automatic tank gauging records. State requires owners or operators to self-certify that they have proper leak detection at various times (e.g. during permit renewal process). State approves leak detection methods to ensure that owners and operators are using effective leak detection methods. State requires submittal of site plans and reviews them with respect to leak detection installation. State establishes training program for local agencies on recognizing noncompliance with release detection requirements.	State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets"). State holds face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State has the ability to remove tanks when the owner or operator is recalcitrant. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

OSWER DIRECTIVE 9650.11

RELEASE REPORTING, INVESTIGATION, AND CONFIRMATION:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF THE RELEASE REPORTING REQUIREMENTS	ENCOURAGING PROMPT RELEASE REPORTING, INVESTIGATION, AND CONFIRMATION	TAKING ACTION AGAINST VIOLATORS OF THE RELEASE REPORTING REQUIREMENTS
State distributes stickers that may be placed on owner or operator's telephone with release reporting number. State produces signs for jobber's trucks that advertise the release reporting phone number. State requires commercial gas station owners or operators to post sign on or around gas pumps informing customers on how to detect a release and report a release. State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Oh No!," State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the release reporting requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State requires jobbers to distribute information on release reporting requirements. State publishes articles or announcements in newspaper and oil industry and trade association publications. State publicizes violations of requirements in local newspapers or trade publications. State includes information on release reporting requirements as "statement stuffers" in tank fee invoices. State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the release reporting requirements. State holds press conferences on regulatory requirements.	State requires disclosure of releases during property transfer. violators may be fined for false statements. State staffs a 24-hour toll-free hot line for reporting releases. Owners and operators may be ineligible for reimbursement of cleanup costs from a state fund if they fail to report the release promptly to the state. State provides information to jobbers on detecting releases and encourages jobbers to bring them to the owner or operators attention when discovered. State, when a leak is suspected, can "loan" product to tank owners who are financially unable to fill tank completely, thereby enabling tightness test to be completed. State provides incentive to closures contractor to report releases during closure.	State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets") State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State has the ability to remove tanks when the owner or operator is recalcitrant. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense. State orders the tank to be emptied pending further investigation when an owner or operator has not reported a suspected release.

OSWER DIRECTIVE 9650.11

RELEASE RESPONSE AND CORRECTIVE ACTION:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF CORRECTIVE ACTION REQUIREMENTS	ENSURING ADEQUATE RELEASE RESPONSE AND OVERSEEING CORRECTIVE ACTIONS	TAKING ACTION AGAINST VIOLATORS OF THE CORRECTIVE ACTION REQUIREMENTS
State has written guidance for RPs concerning their responsibilities for responding to a release and penalties for inaction. State staff delivers presentations at oil industry and trade association meetings. State sponsors public service announcements on radio and television. State works with local agency staff to distribute information to owners and operators. State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Oh No!," State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the corrective action requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State requires jobbers to distribute information on corrective action requirements. State publishes articles or announcements in newspaper and oil industry and trade association publications. State publicizes violations of requirements in local newspapers or trade publications. State includes information on release reporting requirements as "statement stuffers" in tank fee invoices. State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the release detection requirements. State holds press conferences on regulatory requirements.	State conducts a "contractor day" where cleanup consultants, engineers, tank manufacturers, etc. receive information on proper release response and corrective action. State develops satellite broadcasts that owners and operators may watch for information on proper release response and corrective action. State has a field manual that contains guidelines for site assessments and cleanup activities. State has developed a workload tracking system to follow site progress. State co-sponsors corrective action training workshops with a local university or training center. Workshops cover environmental assessment methodologies and corrective action procedures. State provides financial incentives for proper cleanup (e.g., tax breaks to encourage compliance, and a fund to provide RPs reimbursement for cleanup expenses when the RP demonstrates cooperation during the initial assessment. State has an emergency spills hot line with a recorded message that provides information 24-hours a day. The message informs owners and operators how to get personal assistance if necessary. State certifies contractors through required training and certification tests. State distributes a list of certified corrective action contractors. To be eligible for state fund reimbursement, an approved contractor must be used. State has written guidance for contractors on preparing corrective action plans. State sponsors training to inform contractors of state cleanup requirements and expectations. State requires contractors to meet with state staff and demonstrate that they are capable of conducting corrective actions appropriately before being placed on a list that is given to owners and operators who request a referral State conducts on-site inspections at cleanup sites. State has developed expedited procedures to issue air or water permits required for corrective action. State promotes a positive environment for private insurers so that they will be willing to offer coverage in the state and funds for cleanup will be available in a timely manner.	State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets") State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State has established a system for tracking state-lead cleanup costs and recovering costs from RPs. State publicizes cost recovery cases to inform owners and operators that RP-lead cleanups are less costly to the owner or operator than state-lead cleanups. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State has the ability to remove tanks when the owner or operator is recalcitrant. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense. State has procedures whereby penalties can be waived or negotiated provided the RP signs and complies with the terms or a settlement agreement. State places a lien on RPs property if state or federal funds have been used for a cleanup and not repaid.

OSWER DIRECTIVE 9650.11

CLOSURE:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF THE CLOSURE REQUIREMENTS	VALIDATING PROPER CLOSURE	TAKING ACTION AGAINST VIOLATORS OF THE CLOSURE REQUIREMENTS
State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Musts for USTs," State-developed materials, and copies of the regulations). State publicizes violations of requirements in local newspapers. State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the closure requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State requires jobbers to distribute information on closure requirements. State publishes articles or announcements in newspaper and oil industry and trade association publications. State publicizes violations of requirements in local newspapers or trade publications. State includes information on closure requirements as "statement stuffers" in tank fee invoices. State holds an annual conference/trade show with owners and operators to share information. State provides a telephone number to owners and operators to call for additional information on the closure requirements. State holds press conferences on regulatory requirements.	State establishes policy for prioritizing inspection of closure activities, based on such factors as proximity to vulnerable ground water and previous experience with closure contractors. State inspectors oversee all closure activities. Local agency staff (e.g., fire or health department) monitor closure activities. State institutes certification program for tank closure contractors. Closure permit is required for all closures. Owners and operators must place a notice on property deed, describing the location of abandonment, method of closure, and proof of closure certification. Retired engineers are hired to conduct closure inspections on a case-by-case basis. State implements computerized system for maintaining closure records (e.g., results of closure inspection, enforcement, and certification). State responds to public reports of nuisance, odors, unusual activity, etc. State reviews tax records to identify recent tank closures. State requires a certificate of closure before any transfer of property can occur.	State established training program for fire and police departments on recognizing illegal closure activities. State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets") State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State issues administrative or judicial orders with penalties. State revokes permit or does not reissue permit of recalcitrant violators. State locks delivery pipe of facilities not in compliance. State shuts down facilities of recalcitrant violators. State conducts hearings concerning the violations before a citizen board. The hearings are advertised in local newspapers. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

OSWER DIRECTIVE 9650.11

FINANCIAL RESPONSIBILITY:
STATE UST PROGRAM IMPLEMENTATION ACTIVITIES

INFORMING OWNERS AND OPERATORS OF FINANCIAL RESPONSIBILITY REGULATIONS	STATE COMPLIANCE ASSISTANCE PROGRAMS	PROMOTING AVAILABILITY AND AFFORDABILITY OF INSURANCE OR OTHER MECHANISMS	COMPLIANCE MONITORING AND ENFORCEMENT
State publishes monthly newsletter with periodic reminders of compliance deadlines and updates on availability of private or state-run financial responsibility mechanisms. State employs mass mailings of information concerning the requirements to the regulated community (e.g., "Dollars and Sense," State-developed materials, and copies of the regulations). State inspectors distribute outreach materials on-site. State has local agencies (e.g., local fire departments) distribute information to owners and operators concerning the financial responsibility requirements. State forms committee (including members from local government, industry, community groups) that relays regulatory requirements and information to oil industry and trade associations and other interested parties. State staff deliver presentations at oil industry and trade association meetings and at seminars and conferences. State sponsors public service announcements on radio and television. State provides a telephone number to owners and operators to call for additional information on the financial responsibility requirements. State holds press conferences on regulatory requirements.	Some states have developed financial assurance funds which help owners and operators pay for cleanups and/or third-party damages. State provides grants or low interest loans to rural and small business tank owners to upgrade tanks (because tanks that have been upgraded are more likely to be covered by private insurers).	State promotes development of risk retention group that provide UST coverage to municipal or other large groups of UST owners and operators. State promotes communication with private insurers to maximize their participation in providing financial responsibility. State supplies insurance companies with a list of tank owners and operators and tank characteristics so that insurers can determine whether they will provide coverage. State reinsures private insurance carriers who agree to provide coverage to owners and operators (i.e., the state protects carriers from large claims). State has developed a co-payment program where it pays a portion of fund claims and a private insurer pays the rest. The proportions change over time until the private insurer takes over the program.	State requires owners and operators to certify that they have financial assurance on tank notification forms. State checks for demonstration of financial assurance during routine inspections. State requires owners and operators to produce copies of financial assurance documents during installation inspections. State requires UST manufacturers or retailers to ensure owners have financial responsibility before selling new USTs. State requires installers to verify financial responsibility prior to installation. State requires jobbers to verify financial responsibility before filling tanks. State conducts informal activities (e.g., letters, phone calls) to inform owners and operators of non-compliance and encourage compliance. State issues warning letters and notices of violation to facilities not in compliance. State issues on-site expedited administrative orders (e.g., "traffic tickets") State hold face-to-face compliance meetings (e.g., a "show-cause" meeting) with the violator in which the violator must demonstrate why an administrative order should not be issued. State publishes newspaper and journal articles on violators and associated enforcement actions. State requires violators to publish a public statement in a local newspaper explaining the violation and pledging not to repeat the offense.

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