Environmental Results Program
The Environmental Results Program or "ERP" is an innovative program, readily adoptable by regulatory agencies, that can improve performance and address environmental problems.
In ERP, regulating agencies educate facilities about their environmental impacts and obligations, require them to certify as to their compliance, and track them to evaluate their environmental performance. After several years of implementation in Massachusetts, ERP has a record of improving environmental performance that could produce similar results for other state programs. The Office of Enforcement and Compliance Assurance is working with other EPA offices, states, and associations to further develop the Massachusetts program and transfer it to other states and sectors.
In a Environmental Results Program, facility owners or managers have to certify that they are in compliance at the time of the certification, and that they have systems in place to remain in compliance over the coming year. If a facility is not in compliance, facility owners or managers must complete a Return to Compliance Plan. ERP gives owners or managers the tools to do this through workbooks, written in easily accessible language, that walk the owner or manager through the facility process, showing environmental requirements, pollution prevent techniques, and worker health and safety requirements at each step of the process.
For more information, see the Executive Summary of ERP The self-certifications, which cover air, water, and waste performance standards, are signed by a senior official at the facility, usually the owner or senior manager. This creates a powerful incentive for the owners or managers of these businesses to take personal responsibility for environmental results.
Closely linked to the self-certification process and the compliance assistance tools is ERP's performance measurement methodology. In ERP, the regulatory agency, using its subject matter experts, develops a set of environmental business practice indicators (EBPIs) for each of the three industry sectors that provide a snapshot of a facility's environmental performance and enable the state to track progress and target resources. Random and targeted inspections, and enforcement, are integrated into the ERP program and are used to verify, measure, and appropriately respond to results.
Benefits of the Environmental Results Program (ERP)
- ERP can produce improved environmental business practices in business sectors and overall improved environmental performance. In addition to sector-wide improvement, compliance with particular measures can increase significantly.
In Massachusetts, in 1997 only 33 percent of dry cleaners were performing routine leak checks, but this increased to 66 percent in 2000 after implementation of the program in 1998.
- ERP can expand the universe of small businesses on record with the regulatory agency.
Massachusetts found that the number of facilities it knows about in the 3 sectors increased from about 380 to 2,200.
- With ERP, an agency can better quantify the cumulative impact of these diffuse sources.
For more information on Massachusetts Department of Environmental Protection's (DEP) ERP projects, please see their web site at www.state.ma.us/dep/erp/erphome.htm .
The Massachusetts Department of Environmental Protection (DEP) estimates that based on average facility purchases of perchloroethylene in the state, the current dry cleaner universe of regulated facilities is equivalent to about 60 hazardous air pollutant major sources; and for printers, based on the potential to emit for all printers under the ERP emission threshold in the state, the printer universe of regulated facilities is equivalent to about 17 VOC major air emission sources.
- ERP also has helped those businesses that have wanted to comply, but did not know how to do so.
- ERP has provided pollution prevention techniques that save money, as well as fee consolidation and cost reductions compared to case-by- case permitting.
- Prior to ERP, in Massachusetts, a mid-size printer found that it cost more than $2000 in permit fees, compared with the annual $200 ERP fee.
EPA's Office of Policy, Economics& Innovation (OPEI) has a web site on ERP that can be accessed at www.epa.gov/permits/masserp.htm . The Office of Planning, Policy Analysis & Communications (OPPAC) in the Office of Enforcement and Compliance Assurance is working with other EPA offices and the state of Massachusetts on further developing the Massachusetts program and transferring ERP to other states and sectors. In particular, OPE) and EPA New England have worked with OECA to create opportunities for other states to learn about the ERP approach and its tools, in facilitating information sharing among states, and in supporting use of the ERP to solve environmental problems.
OPPAC has been working with, and encouraging collaboration between, several states planning on developing ERP programs for auto repair sectors in their states. Florida, Maryland, the District of Columbia and Rhode Island are develop programs for various aspects of their auto repair/auto body industries. We are currently providing financial, technical and legal assistance to Massachusetts, Florida, and the District of Columbia.
EPA has an Information Sheet on how ERP might apply to Underground Storage Tanks. The State of Tennessee has decided to adopt an UST ERP and will be working with EPA to develop the program.
If you are interested in exploring how you might develop a program, refer to the User's Guide that EPA developed with Massachusetts' assistance. You may also contact Patricia Mott at (202) 564-5133, email@example.com or Lynda Goodgame at (202) 564-7376, firstname.lastname@example.org.