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Summary of Meeting with Performance Track Members and EPA's Office of Water

September 15, 2004

Rich McKeown, Chief of Staff, Office of the Administrator, EPA David Gunnarson, Lockheed Martin Sara Ethier, 3M Geoff Grubbs, Director, Office of Science and Technology, EPA Linda Boornazian, Director, Water Permits Division, EPA (right), and Diane Regas, Director, Office of Wetlands, Oceans, and Watersheds, EPA (left)

Overall Summary

• "Less process; More progress."
• EPA's Office of Water appreciates water-related environmental improvements from Performance Track facilities.
• Performance Track program needs to identify short- and long-term tangible incentives to build the program and achieve greater environmental improvements; short-term incentive successes need to be highlighted.
• Performance Track members appreciate these opportunities to meet directly with EPA program officials and would like to meet again in smaller groups to focus on specific incentives and work on details.
• Performance Track members would also like to meet with Air and Waste programs to brainstorm on issues and incentives; for multi-media issues, members would like to meet with the main programs.
• Performance Track members would like to discuss pretreatment issues. Further discussions with EPA should include Office of Enforcement and Compliance Assurance (OECA) and States, as well as local authorities for pretreatment issues.
• Need to consider applying best practices from other programs - e.g., whether flexible air permitting concepts could be transferred to water permits to expedite process changes and avoid permit modifications, business practices such as lean manufacturing, voice of customer.
• Performance Track members can help EPA test ideas that will solve problems. EPA may need to work with couple of States to work on solutions and develop models that can be replicated.

Follow-up Actions

Priority permits:

EPA will allow incentives for permits that are modified or re-issued for a Performance Track facility that is under competitive pressure. Performance Track facilities should contact Richard Kashmanian or Pravin Rana to identify candidates for priority permits.

Low priority for routine inspections:

EPA needs to further implement low priority for routine inspections on Regional and State level; EPA needs to consider how to reflect this in Performance partnership agreement (PPAs) or guidance supporting this instrument. Office of Policy, Economics, and Innovation (OPEI) managers will meet with OECA to discuss how to prioritize facilities for inspections, including developing risk scale.

Monitoring and reporting:

There is already existing guidance for performance-based reductions for monitoring. EPA will provide this information to OPEI to make Performance Track facilities aware of the elements of this guidance.

Electronic reporting:

EPA will learn from Performance Track members about how to implement electronic signatures. Performance Track members are willing to design and test electronic filing (applications, monitoring reports).

Ambient water quality data:

Performance Track facilities will work with EPA to determine how to share ambient water quality data with water officials. Office of Water (OW) and OECA have supported trading off effluent monitoring data for ambient monitoring data. Where Performance Track facilities are asking for this trading off and not receiving it, Performance Track coordinators in EPA Regions should be contacted to facilitate working on this for EPA or State permits. OW will work with States to encourage their support.

Credit for voluntary pollutant reductions:

The Office of Water considers a sector's voluntary efforts to reduce water pollution, such as through goals in programs like Performance Track, as part of its analysis for determining whether to develop or revise effluent guidelines for various industry sectors. EPA will seek input from Performance Track members as it develops criteria that will be used to assess voluntary actions by facilities and companies.

For a more detailed summary of the meeting, click here (PDF, 15 pp., 17KB, about PDF).

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