Overview of State Incentive Programs

1
Overview of State Incentive Programs

• Sara Ethier,
• Director, Environmental Operations
• 3M
• Telephone [phone]
• e-mail sjethier_at_mmm.com

2
Introduction - The Gap

• Current regulatory approach is not sufficient for
  all environmental issues (non-point pollution,
  global climate change, biodiversity loss, cross
  media issues, etc.)
• Regulations are complicated, very prescriptive
  (what to control, how much to control and type of
  control equipment to use) and sometimes
  overlapping
• Interest by all parties to improve environmental
  performance beyond that currently required, in
  the most efficient manner

3
Introduction The Role of Incentives in
Voluntary Programs

• From the EPA Performance Track web site
• Incentives are being designed and implemented to
• Recognize and reward environmental
  accomplishments
• Encourage facilities to perform beyond basic
  compliance
• Allow members to operate more efficiently, and
• Demonstrate that innovation is integral to EPAs
  evolving framework

4
Introduction Desirable Features of Good
Incentives

• Apply to a broad range of industry or really
  attractive to one segment
• Easy to understand, implement and verify
• Will save time for both industry and government
• Result in measurable environmental improvements
  (preferably at lower costs)
• Are attractive enough to encourage participation
  by average performers plus small to medium size
  business
• Improve the environment faster than otherwise
  expected
• Significantly increase the number of participants
  so the environment will show measurable
  improvement

5
Introduction Current Constraints to Useful
Incentives

• Regulations are not always easy to understand,
  may not allow for alternatives, or only with
  great difficulty plus some delegated states
  vary from federal regulations (equal or more
  restrictive)
• Confusion regarding federal vs. state beyond
  compliance programs
• Perception by non-governmental organizations that
  industry is trying to avoid the law
• Can be costly to try alternatives (staff time for
  both industry, agency plus legal costs)

6
Introduction Possible Non-Regulatory Solutions

• Time
• Top of the pile for new construction permits
• Reduced inspection priority
• Longer permit periods (send in only changes?)
• Faster permitting for emission control projects
• Financial
• Preferred buying list for the government
• Tax benefits
• Revolving loans
• Insurance benefits

7
Introduction Possible Non Regulatory
Solutions(continued)

• Flexibility
• Cap/flexible permits changes made quickly,
  improves speed to market
• Access
• Someone to talk to for new permits, concerns
• Publicity
• Recognition for beyond compliance
• Benefit of doubt if compliance issue occurs
• Socially responsible investment organizations
  give credit for membership

8
Performance Track Participants Association
Incentives

• Incentives Committee formed February 21,
  2001during first meeting of Association
• A list of incentives was developed over the next
  eight months through a series of meetings and
  committee conference calls
• 72 ideas were listed and divided into permits,
  air, water, waste, CERLA/EPCRA, product reviews,
  tax incentives, capital incentives, other
  incentives and general comments

9
Performance Track Participants Association
Incentives

• 8/06/02 the list was narrowed down to the top 5
  in each of three categories
• Non-regulatory
• Regulatory, and
• Statutory

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Top 5 in each of three categories
11
PTPA Incentives

• On 11/7/01 the list was further reviewed at the
  membership meeting with a request to vote for the
  top two.
• It ended up being the top six.

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Top Six

• Air Emission PAL (plant-wide applicability limit)
  or cap
• Expedited permitting
• Reduced or no water monitoring for non detect
  parameters

• Extend hazardous waste storage from 90 to 270
  days
• Exclude definition of recycled materials from
  solid waste
• Reduce TRI reporting frequency

13
PTPA Incentives

• On 2/11/02 the committee had a conference call
  and developed a list of ideas that might be used
  most easily by the EPA without extensive
  regulatory changes.
• Reduced inspection frequency.
• Expedited permitting.
• Reduce TRI reporting frequency (regulatory but
  not delegated).
• Modify Title 5 annual compliance certifications.
• Reduced or no water monitoring for non detect
  parameters.
• EPA to allow self audits and corrections without
  penalty.
• Fast permit approval if project reduces emissions
  or for control device.

14
Developed Combined Incentive Grid in November 2003

• Purpose of Project
• Determine which states are working in the
  incentives area
• Determine which incentive ideas are in common
• Look for unique ideas
• Share ideas with key agency decision makers
• Compare state programs to EPA and PTPA ideas

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Grid is in Process of Verification but Available
for Review at this Time

• States with incentive ideas listed on web site
  are Colorado, Idaho, Illinois, Louisiana,
  Maine, Mass., Michigan, New Mexico, North
  Carolina, Oregon, South Carolina, Tenn., Texas,
  Utah, Vermont, Virginia, Wisconsin
• The abbreviation of the state is also a direct
  link to the incentives page (for e-mail version)

States with a Memorandum of Agreement with the
EPA
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Incentives are Grouped into Categories as Follows

• Administrative Requirements
• Air
• Audits
• CERCLA/EPCRA/TSCA
• Compliance
• Database
• Env. Mgmt System
• Fees/Loans/Grants/ Credits

• General Comments
• Individual Company Incentives
• Inspections
• Insurance
• Memberships
• Monitoring
• Municipalities
• Networking

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Incentives are Grouped into Categories as Follows
(continued)

• NSPS
• Open to discuss other incentives
• Penalties
• Permits
• Point of Contact
• POTWs
• Recognition
• Reporting Recordkeeping

• Tax Incentives
• Technical Program Assistance
• Title V
• Training
• Vendor/Supplier
• Waste

18
Common Incentive Ideas

• Administrative Details
• Inspections
• Networking
• Permitting
• Point of Contact
• Recognition
• Reporting Recordkeeping

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Detail of Permitting(to show variety of ideas)

• Submit permit applications and renewals
  electronically
• Performance-based permitting
• Automatic extension for companies meeting
  specified criteria
• Expedited permitting
• Increased permitting flexibility
• All qualifying facilities to replace existing
  media-specific permits with single multi-media
  permit
• High priority for air permitting
• Self-reporting policies
• Established time frame for permit decisions
• Permit enhancements
• Faster permit modifications under NSR

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Detail of Recognition(to show variety of ideas)

• Logo use
• Inclusion on website
• Inclusion in promotional material related to
  partnership programs
• Featured in articles, newsletters, case studies
• Media activities/press releases
• Plaque, window emblem, certificate
• Automatic participation in state award program or
  ceremony

21
Detail of Point of Contact(to show variety of
ideas)

• Single point of contact for all permitting issues
• High priority to responding to questions and
  providing expertise
• Facilitator appointed by Secretary of the
  Department to help resolve local, state and
  federal barriers

22
Some Unique Ideas

• Dual Membership (join EPA Ptrack, belong to state
  program)
  CO, NC, TX, VA
• Preferred purchasing list (for government/ joint
  members)
• WI, PTPA, TX
• Shorter permit turn around processing time IL,
  MI, OR, WI, EPA

23
Copies of Grid Available

• CD
• Floppy Disc
• Via e-mail by contacting Sara Ethier at
  sjethier_at_mmm.com