Recommendations from the 2009 Auto Body ERP Evaluation
Note: EPA no longer updates this information, but it may be useful as a reference or resource.
In 2009, EPA's Evaluation Support Division completed an evaluation of the experience of three states that have implemented an ERP in the auto body sector: Delaware, Maine, and Rhode Island. This effort complements EPA's 2007 examination of results from these and other ERPs, and is the first full ERP evaluation since the National Academy of Public Administration's 2000 evaluation of Massachusetts' initial ERP efforts (PDF) (84 pp, 540K). The evaluation identified several recommendations for states and/or EPA to follow in future ERPs:
- Benefit from economies of scale. ERP offers economies of scale with large populations of facilities, such as when multiple states combine forces. Why? For one, a substantial increase in the population of facilities requires only small changes in the number of random site visits that an agency must conduct at facilities. Further, an agency's per-facility costs of developing self-certification and assistance materials decrease substantially.
- Use common indicators. Common indicators, like those developed in the Common Measures Project, can support learning by allowing states and EPA to compare ERP data across states. Common indicators are also essential for achieving economies of scale in multi-state efforts, as with the Multi-State Auto Body ERP in EPA Region 5.
- Quantify environmental outcomes. Measuring key quantitative indicators (e.g., amount of hazardous waste generated) could help track environmental outcomes that are especially meaningful to many stakeholders. EPA should consider developing tools to help states use ERP data to estimate emissions reductions and similar outcomes.
- Un-package ERP. When developing their programs, states may wish to consider different ways to apply the components of ERP, alone and in combination. For instance, some states may wish to undertake statistical measurement to assess a problem before determining whether to implement ERP or other policy approaches.
- Core regulatory programs. EPA and states should develop a clearer understanding about the extent to which ERP can be used to address core regulatory programs. In circumstances where this is suitable, EPA could develop appropriate guidance and a sustainable funding mechanism.