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ERP Credit Workgroup

ERP Credit Workgroup . 2005 Northeast Environmental Summit September 28, 2005 Sam Silverman – Moderator, EPA Region I Beth Termini – OPEI & Region I Steve DeGabriele – MA DEP Caroline Petti - OECA. ERP Credit Workgroup.

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ERP Credit Workgroup

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  1. ERP Credit Workgroup 2005 Northeast Environmental Summit September 28, 2005 Sam Silverman – Moderator, EPA Region I Beth Termini – OPEI & Region I Steve DeGabriele – MA DEP Caroline Petti - OECA

  2. ERP Credit Workgroup • ERP Credit Workgroup - response to isssues raised by MA DEP’s request to EPA for ERP dry cleaner credit • Group worked on this specific model and its issues to help inform future proposals • Group includes: NE States, OES, OPEI and OECA • Subgroups formed around specific issues

  3. MA ERP Credit Proposal • Credit in the PPA for addressing 600 dry cleaners through ERP: ·380 tons/yr hazardous waste (environmental footprint ≈ 30 large quantity generators) ·   250 tons/yr hazardous air pollutants ( environmental footprint ≈ 25 major air facilities) Email steven.degabriele@state.ma.us for copy of proposal

  4. Why did MA DEP propose this? • Scarce resources must yield greatest environmental benefit • MA believes its success on “majors” allows greater opportunities for environmental gains at smaller sources • EPA should continue to support innovative programs • Greater payoff if meaningful PPA credit from EPA for innovative program results • Results-driven decision-making – Trust, but verify

  5. The Essential Elements of an ERP • Valid measurement system • Self-certification and return to compliance plans • Compliance assistance • Compliance assurance and enforcement

  6. What is “credit?” • Recognition: Official EPA agreement that activities are important parts of state’s overall compliance program in an expanding universe of sectors • Offset: Substitute some ERP-like program activities and their results for some amount of core activities and results • Key issues: • Offsets: How/when to determine? Are results needed first? • Adequacy of core program: How will EPA evaluate and apply it to credit?

  7. Describing ERP Projectsin PPAs and National Data Systems • ERP Matrix will describe program in PPA & on EPA website • Includes “environmental footprint,” results, planned & actual activities • Place ERP matrix on, or linked to, one or more EPA websites • Tracking of ERP activities in EPA systems such as AIRS/AFS or RCRA Info not recommended at this time • Key: Data on ERP activities/results widely available to public and regulators

  8. ERP Model Matrix Example Key Elements Sector Specific Info.

  9. ERP Model Matrix Example Key Elements Sector Specific Info.

  10. DATA: What and how much to collect and report to get credit for ERP? • Credit continuum: based on program results and amount and specificity of data • Concern that bar not be set too high • Data depends upon stage of ERP development • Key issue: How to credit when data is limited (e.g., where only resource investments and environmental footprints are known)

  11. Proposed Role for Element 13 Work Group in Reviewing State Applications for Credit • Proposals submitted by state to region • Small group of submitting state, affected Region and OECA make preliminary determination whether to offer credit • Determination discussed with Element 13 Work Group • Element 13 Work Group then develops general guidance for the state submittal and regional review of similar state proposals for credit

  12. MassDEP ERP Credit Proposal Addendum • Completed ERP Matrix for Dry cleaners • Environmental Performance Profiles for HW Large Quantity Generators and Air “Majors” • Key issues: • Regulated group performance vs. agency oversight performance • Burden of proof

  13. Next Steps • MA to submit proposal addendum with specific data and request for offset credit • EPA response to the MA ERP proposal for recognition credit • Coordinate with Element 13 Work Group on managing and reviewing proposals • Continue offset credit discussion with ERP Credit Work Group (Region, MA, other New England states, OECA & OPEI) • Expand ERP credit dialogue beyond New England and engage states on submitting proposals for credit

  14. Discussion Topics for Today • Issue #1: What are the barriers preventing other states from seeking credit for their innovative compliance programs? • Issue #2: What assistance can EPA provide states in overcoming those barriers?

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