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Summary of Meeting with Performance Track Members and EPA’s Office of Solid Waste and Emergency Response
March 30, 2005
Overall Summary
-
States: It is important that EPA and
states are better aligned and further integrated to
support Performance Track, especially since
regulatory incentives are not available to most
members until adopted by the states. The following
suggestions were made that support EPA and state
integration:
- Common priorities between EPA and states should be enumerated in PPAs/PPGs.
- More outreach is necessary to educate state agencies about Performance Track.
- Further discussion is needed on possible EPA sanctioning of state-created incentives.
- EPA and states could explore new “regulatory avenues” such as petitions that request waivers from rules where equivalency determinations have been made.
- An appeal from Performance Track members could help EPA garner support from states.
- The state-EPA workgroups formed in response to the ECOS report on ensuring the success of Performance Track and state performance based programs could be the primary vehicle to promote integration and program implementation.
- Land Revitalization: Incorporating land revitalization efforts into Performance Track goals would meet the goals of OSWER and Performance Track. For example, "Adopt a Gas Station" could be a potential two-for-one Performance Track performance goal if liability issues were resolved.
- Resource Conservation Challenge (RCC): Incorporating RCC goals into the Performance Track performance goal table would serve interests of OSWER and Performance Track. For example, partnerships for community-based electronics recycling could count as a two-for-one goal.
- Definition of Solid Waste: Consider changes to definition of solid waste and beneficial reuse for Performance Track members to increase solvent recycling.
-
Permitting and Efficiency:
Permitting changes and changes to increase
operational efficiency are a valuable incentive to
Performance Track members, including:
- Decrease reporting and longer fee periods (one member stated that half of cost savings incurred would be invested in environmental improvements).
- Reduce duplication in reporting requirements; employ exception reporting.
- Apply "lean" process tools to permit programs to identify barriers.
- Combine all environmental permits (air, water, corrective action, etc.) into a single environmental permit.
- Extend the permit period from five to 10 years for Performance Track members and turn permit renewals into a notice of intent to renew.
- Waive or reduce permit fees for Performance Track members.
- Corrective Action: Apply results-based approaches and tailored oversight guidance to Performance Track members.
Follow Up Actions
- State Environmental Program Representative: Use EPA Regions as intermediaries. Regions can use PPAs/PPGs to implement Performance Track incentives.
- OPEI: Use state/EPA workgroup to raise awareness and facilitate adoption of incentives.
- State Environmental Program Representative: Develop incentives for smaller members.
- Member: Form a workgroup related to the RCC and Performance Track goals
- Member: PTPA has a state workgroup as well; we invite members to join.
- Member: Need to coordinate the various workgroups.
- OSWER: Community involvement is key.
- Member: Develop actionable items, with timelines, to pass to meeting attendees.
A more detailed summary of the meeting and list of participants (PDF, 10 pp., 84 KB) is available.