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ERP – the Environmental Results Program: An Overview. Al Innes, Minnesota Pollution Control Agency Steve DeGabriele, Massachusetts Dept. of Environmental Protection. Symposium on Innovating for Sustainable Results January 7, 2008 Chapel Hill, North Carolina. What is ERP?.

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Erp the environmental results program an overview

ERP – the EnvironmentalResults Program:An Overview

Al Innes, Minnesota Pollution Control Agency

Steve DeGabriele, Massachusetts Dept. of Environmental Protection

Symposium on Innovating for Sustainable Results

January 7, 2008

Chapel Hill, North Carolina

What is erp
What is ERP?

  • Pioneered by MA DEP in 1990s

    • Printers, dry cleaners, photo processors

  • Integrates proven tools to cost-effectively improve performance in sectors characterized by large numbers of small sources of pollution

  • To date, average initial sector improvements from 5% to 30%

    • Improvement continues in later years

    • Stabilizes at high levels

How a full erp works a typical cycle

Step 1:Inventory sources (some not previously known)

Step 2: Statistical Baseline – random, ID big issues

Step 3:Compliance Assistance – trade groups: plain language

Step 4: Self- Certification – self-assessment checklist linked to workbooks; compliance certifications; return-to-compliance plans (if necessary)

Step 7: InformedResponse - focus on common weaknesses; realign resources

Step 5: TargetedFollow-Up – inspections, assistance, enforcement

How a “Full” ERP Works: A Typical Cycle

Step 6: Statistical Post-Certification – random, verify self-assessment and perf. changes

Renew Assistance and Certification (As Deemed Necessary)

Erp usually but not always for large numbers of small pollution sources
ERP: Usually – but not always – for Large Numbers of Small Pollution Sources

  • Developed by MA in 1990s for printers, dry cleaners and photo processors

    • Hundreds of facilities per sector

    • Significant aggregate environmental footprint

    • Traditional approaches untenable

    • DEP resources shrinking

  • ERP sectors have large numbers of facilities nationally

    • e.g., over 30,000 auto body/paint shops in U. S.

    • So far, six states with auto body ERPs

  • Being examined for larger sources now


  • Voluntary vs. mandatory

  • Colorado – larger WWTPs

  • Subset of tools used

  • Transferability to new sectors and states

  • Different basis for authority

Addressing misconceptions of the role of self assessment and reporting in erp
Addressing Misconceptions of the Role of Self-Assessment and Reporting in ERP

  • Sector-wide compliance determination is based primarily on inspection data, not self-reported data

  • Based on states’ inspection data analyzed to date, group performance has improved across the board

  • Surprising numbers of facilities self-report noncompliance (83% in MN’s first cycle)

  • Inaccuracies in self-reported data allow an agency to strategically target its education and enforcement

  • States retain discretion over when to trust

    self-reported data and conduct enforcement

    – as is the case in conventional oversight programs

  • Self-assessment accuracy appears to improve

    over time

Current state of erp
Current State of ERP Reporting in ERP

  • Endorsed for "scale up" by EPA Innovation Action Council (IAC) in 2000

    • Based on MA results, NAPA evaluation and potential to address significant problems

  • Tangible EPA support since then

    • Grants, technical support, tools and resource flexibility

  • Expanding number of states and sectors

Full erp now covers 11 sectors groups
“Full” ERP Now Covers 11 Sectors/Groups Reporting in ERP

* FL and MD no longer

implementing ERP.

MD had one ERP

that covered both

auto body and

auto repair shops

Partial erp is used in other sectors
“Partial” ERP is Used in Other Sectors Reporting in ERP

“Partial” ERP means the implementing agency is not using the full set of ERP tools

Why are states adopting erp
Why Are States Adopting ERP? Reporting in ERP

  • Improved resource targeting with rich ERP data sets

  • Decreased need for enforcement over time

  • Economies of scale with statistics and automation

  • Stakeholder measurement demands

  • Businesses support a more level playing

    field, clearer obligations

  • Public supports the often visible


  • Cost effectiveness

Erp cost effectiveness
ERP Cost-Effectiveness Reporting in ERP

  • Comparisons to conventional compliance programs are difficult since those programs typically do not track sector-wide performance as ERP does

  • Also, agencies differ widely in how they track cost


  • ONE study has compared two dry cleaning programs: MA’s ERP and MI’s “census” inspection program, required by MI law

    • Those under MA ERP appear to perform as well as MI’s

    • MA’s use of ERP saves about 50% annual FTE compared to MI, allowing those staff resources to be applied elsewhere

    • MI’s approach eliminates any uncertainty about facility performance

  • Other states’ experience suggests a similar outcome, once the significant investment in ERP start-up is past

  • EPA is funding more study of this issue and the

    Consortium plans to guide its members

    in analyzing cost-effectiveness

Growing erp community forms a consortium
Growing ERP Community Forms a Consortium Reporting in ERP

  • States ERP Consortium

    • Founded 2006

    • An official "forum" of the Environmental Council of the States (ECOS)

    • 18 members (December 2007)

  • Goals:

    • Communicating successes to build stakeholder support

    • Sharing information among practitioners

    • Expanding support within EPA & promoting ERP as a proven compliance strategy

    • Improving & disseminating tools for easier

      automation & measurement

Consortium membership
Consortium Membership Reporting in ERP

May 2007

Massachusetts department of environmental protection bureau of waste prevention
Massachusetts Department of Environmental Protection - Bureau of Waste Prevention


Protect public health and the environment.

Ensure clean air, clean water and safe waste management.


Monitor air quality.

Quantifychemical use, pollution and wastes.

Regulate facilities and other sources.

Promote reuse, recycling and source reduction.

Regulated Universe

30,000+ small, 10,000 medium and 600 large sources

300 waste management facilities

4 million+ vehicles and associated transportation infrastructure

Use and disposal of consumer products by 6.3 million people

and thousands of businesses

Issues for regulators
ISSUES FOR REGULATORS Bureau of Waste Prevention

  • How do you effectively and efficiently regulate large groups of facilities or activities with limited resources?

  • How do you know that your compliance assurance efforts (permits, inspections, compliance assistance, enforcement, etc.) are yielding environmental performance improvements?

1996 level ma dep resources
1996: Level MA DEP Resources Bureau of Waste Prevention

  • With major sources generally under adequate controls and oversight, major environmental goals such as Ozone Attainment were still not achieved

  • Recognition that numerous small sources cumulatively create significant environmental impacts

  • Build on successful multi-media, pollution prevention based approaches

  • Less prescriptive, performance-based approaches

  • Finding better ways to measure regulated community and agency performance


Erp interlocking tools integrated system
ERP: Interlocking Tools, Integrated System Bureau of Waste Prevention

Current uses of full erp erp tools in massachusetts

Sector or Activity ( # ) Bureau of Waste Prevention

Compliance Assistance Workbooks


Statistical Measurement

Dry Cleaners (600)




Photo Processors (450)




Printers (1200)




Stage II Vapor Recovery at Refueling Facilities (3000)



New Small Boilers 10-40BTU

(small # / year)



New Industrial Wastewater Holding Tanks (small # / yr)


Mercury Dentists (3600)


Current Uses of Full ERP & ERP Tools in Massachusetts

Baseline universe identification

BEFORE Bureau of Waste Prevention




Percentage of facilities “in the system”



Erp measurement methodology

  • EBPI’s

  • Baseline and Year 1 Random Inspections

  • Score

    • Industry-wide

    • Indicator-specific

    • Facility-specific

  • Statistics

Ebpi s for erp printers
EBPI’s for ERP Printers Bureau of Waste Prevention

Regulatory Indicators:

* Are the fountain solutions used on offset web-fed lithographic presses alcohol-free? (air)

* Printer meeting 2ppm or hauling? (water)

* Is the facility in compliance with quantity and time limits for HW storage? (waste)

Beyond Compliance Indicators:

* Does printer have a sign prohibiting discharge of process chemicals over sinks in work areas? (P2)

* Does printer recycle aluminum printing plates? (P2)

Printer s partnership aggregate ebpi analysis

Percentage of Printers Bureau of Waste Prevention

Aggregate EBPI Score


Photoprocessors ebpi performance trends 1997 2002
Photoprocessors EBPI Performance Trends 1997-2002 Bureau of Waste Prevention





Baseline (1997) Average EBPI: 5.7


After 1998 Average EBPI: 7.1

% Photoprocessors


After 2000 Average EBPI: 9.6

After 2002 Average EBPI: 9.8 (preliminary data)

















Aggregate EBPI Score

Dry cleaners ebpi performance trends 1997 2002
Dry Cleaners EBPI Performance Trends Bureau of Waste Prevention1997-2002





Baseline (1997) Average EBPI: 8.4

After 1998 Average EBPI: 8.4


After 2000 Average EBPI: 9.7

% of Dry Cleaners


After 2002 Average EBPI: 9.8 (preliminary data)

















Aggregate EBPI Score

Dry cleaners air quality
Dry Cleaners Bureau of Waste PreventionAir Quality

(1) Perc Purchases Recorded Monthly

(12) Onsite Records of Weekly Leak Checks

% Deviation from Baseline Frequency


(20b) Cycle not ended until temp is < 45 F

1997 vs. 1998

  • statistically significant improvement or

    decline in performance

Ebpi performance results
EBPI PERFORMANCE RESULTS Bureau of Waste Prevention

EBPI: Facility Has Emergency Procedures in Place

Performance for dry cleaners increased from25% at baseline in 1997 to80% in 1998. Apply this change to the entire universe: 358 more facilities with emergency procedures in place.

EBPI: Containers in Good Cond. & Kept Closed

Performance decreased by 3% from baseline (or roughly 20 more dry cleaners have inadequate container management).

EBPI: Meeting 2ppm Silver Discharge

Performance increased from 60% at baseline to 98% in 1998. MA DEP can account for 98% of all silver generated from photoprocessors in Massachusetts.

Select environmental outcomes

  • Question: “Are you in compliance with the press cleanup solution requirement?”

    Results: Performance increased from 77% at baseline in 1998 to 85% in 1999. Apply this to entire universe, this is equivalent to 4.0 tons VOC reduction

  • Question: “Is leak detection performed weekly, following workbook protocol and using proper leak detection equipment?”

    Results:Performance increased from 33% at baseline in 1997 to 66% in 2000. Based on avg. perc use per facility, applied to entire universe, this is equivalent to 22.5 ton reduction of perc emissions.

Dry cleaner accuracy analysis self certifications vs inspections
Dry Cleaner Accuracy Analysis Bureau of Waste PreventionSelf-Certifications vs. Inspections




Facility = Y,

( 9 )

Inspector = Y


( 33 )

( 143 )


Facility = N,

Inspector = Y,

Facility = N,


Inspector = N

Facility = Y,


Inspector = N


( 580 )

( ) number of pairs


Stage ii vapor recovery goals and measures 1997 2005
Stage II Vapor Recovery Bureau of Waste PreventionGoals and Measures – 1997 - 2005

  • Compliance strategy based on ERP approach

  • Program goal: 9000 tons of VOCs controlled by 3000 fuel dispensing facilities (95% vapor capture efficiency).

  • Baseline: In 1997, only 54% had submitted required passing vapor system test results. Over 90% field non-compliance.

  • Program revisions: annual certification to system integrity (tests), weekly operator inspections, systematic reporting enforcement and field inspection presence by DEP

  • Under revised program, of the 2.7 billion gallons of motor fuel dispensed annually, facilities accounting for 2.65 billion gallons (98%) had certified to passing tests.

  • In 2005, 8820 tons of VOC demonstrated

    under control vs. 4860 tons in 1997

Voluntary erp for dental mercury facilities 2004 2006
Voluntary ERP for Dental Mercury Facilities 2004-2006 Bureau of Waste Prevention

  • Environmental Footprint: Dental practices generate waste mercury containing amalgam, 3600 dentists, 305-320 pounds of mercury total

  • Program requirements: Install an amalgam separator; maintain and operate according to manufacturer specs.; use only pH neutral cleaners and clean vacuum system lines; recycle all wastes; keep records; self-certification to DEP

  • Program incentives and goals: If dental practices certified in 1st year, would not need to upgrade system until 2010. If 50% certified in 1st year, DEP would not promulgate mandatory regulations for at least 1 year

  • Results: 1,667 dental practices covering 2661 dentists

    (74% of 3600 total dentists) self-certifiedto requirements

Minnesota dairy erp pilot phase 1
Minnesota Dairy ERP pilot – Phase 1 Bureau of Waste Prevention

  • Delegated counties

  • Third-party assesses/certifies

    • Minnesota Milk Producers Association – Environmental Quality Assurance Program (EQA)

  • Volunteers, EQA Techs, and County Feedlot Officers

  • Good results farm-wide

  • Compliance review aspect of EQA program strengthened

  • Only modest participation

  • Resources required to sustain EQA

Minnesota dairy erp pilot phase 2
Minnesota Dairy ERP pilot – Phase 2 Bureau of Waste Prevention

  • Volunteers in 4 non-delegated counties

  • Controls in 9 non-delegated counties

  • Field-test inspection & assessment

  • Self-assessment approach – Round 1 in March 07 (23 volunteers completed)

  • Benchmark inspections June-November 07

  • Round 2 self-assessments and

    inspections in 2008

Minnesota dairy erp pilot phase 21
Minnesota Dairy ERP pilot – Phase 2 Bureau of Waste Prevention

  • Multi-issue, multi-program compliance content

    • Feedlot rules

    • Septic systems

    • Wells

    • Pesticides

    • Underground storage tanks

    • Burn barrels

  • Beyond-compliance content

    • Buffers around surface water

    • Cropping practices

    • Septic systems

    • Odor and air emissions

    • Feed and feed supplements

Minnesota dairy erp pilot phase 2 status
Minnesota Dairy ERP pilot – Phase 2 status Bureau of Waste Prevention

  • 25 self-assessments returned by volunteers

  • 23 volunteers inspected; 2 rejected

  • Conducted 44 control group inspections

  • First year (Round 1) data analysis almost complete

  • Repeat the cycle March thru September 2008

  • Compare first and second year data in fall 2008

  • End game TBD

    • State-wide voluntary for smaller feedlots or just some species?

    • Mandatory as part of 4-year registration cycle

      (requires rule change)?

    • Expand into other sectors – auto body/service,

      USTs, other?

Early results 1
Early Results - #1 Bureau of Waste Prevention

Early results 2
Early Results - #2 Bureau of Waste Prevention

Minnesota dairy erp pilot phase 22
Minnesota Dairy ERP pilot – Phase 2 Bureau of Waste Prevention

  • Desired Metrics

    • Compliance status √

    • Self/Inspector assessment match rate √

    • Partial “MnFARM” (feedlot runoff model) √ soon

    • Milkhouse pollutants (# cows milking) √

    • Acres affected by manure application practices

    • Acres under sound phosphorus management

    • Septic pollutants (# residents)

    • # wells and tanks under sound management √

    • Area of buffers

    • Crop-acres under residue, rotation (√), strip

Minnesota contrasts for phase 2 self assessment
Minnesota Contrasts for Phase 2 Self-Assessment Bureau of Waste Prevention

  • Voluntary, pilot – unique seasonality to this sector

  • Uncertainty over final deployment

  • 55 of 87 counties have delegated feedlot programs

  • Natural expansion to beef cattle

  • Attrition of dairies – generational turnover

  • Shifts between milking and feeder stock depending on milk, beef, and corn prices

  • One year is very short for farm improvements ($ limits by law)

  • No EBPIs (core measures) at the beginning – Round 1 data is suggesting realistic priorities for core improvements we seek

  • Not quite a “full” ERP, since MN sought lowest cost

    and greatest accessibility from ERP

Erp states produce results
ERP States Produce Results Bureau of Waste Prevention

  • Six states have completed one or more full ERP cycles (8 ERPs)

  • Across-the-board improvement in first cycle of each ERP

  • Measured with Environmental Business Practice Indicators (EBPIs), which reflect highest priority compliance and best management practices, e.g.:

    • DE auto body shops' hazardous waste disposal compliance increased from 66% to 91% in one year

    • ME auto body shops' use of "green" solvents increased from 46% to 97% in one year

Across the board ebpi improvements
Across-the-Board EBPI Improvements Bureau of Waste Prevention

Ebpis show significant net improvement
EBPIs Show Significant Net Improvement Bureau of Waste Prevention

  • 4 EBPIs advancing for every declining EBPI

  • Size of advances greatly exceeds size of declines

Erp sector level measures show sustained compliance
ERP Sector-Level Measures Show Bureau of Waste PreventionSustained Compliance

  • FL inspectors found "straight-A" auto repair facilities rose 17 percentage points after two rounds of self-certification

    • "Straight-A" = No violations of any kind

  • MA uses a "group compliance score" as its primary measure

    • Shows the extent to which facilities are achieving EBPIs

    • Can show improvement, even when facilities are not perfect

Improvements in massachusetts group compliance scores
Improvements in Massachusetts Bureau of Waste PreventionGroup Compliance Scores

Explanatory notes for figure

available in ERP 2007 Report

and Executive Summary.

Why do these improvements happen
Why Do These Improvements Happen? Bureau of Waste Prevention

  • Mix of Compliance Assistance, Self-Certification and Agency Verification

    • Plain-language materials help facilities understand requirements

    • Facilities more capable and driven to improve performance

    • Facilities hold themselves more accountable

    • More collaborative, trusting relationship with the agency

  • Key measure: Return-to-compliance plan submission rate

    • Surprising numbers of facility self-declared violations

    • e.g., 20% of all RI auto body shops submitted at least one RTC plan

Erp s future new results new sectors
ERP's Future: New Results, New Sectors Bureau of Waste Prevention

  • Results expected for new sectors

    • e.g., USTs, salvage yards, small animal feedlots

  • New sectors being adopted

    • e.g., stormwater

  • Larger sectors being pursued

    • e.g., thousands of Louisiana oil and gas extraction facilities

Erp s future applying subsets of tools
ERP's Future: Applying Subsets of Tools Bureau of Waste Prevention

  • ERP Measurement: Multi-State Common Measures Project

    • Common indicators for a regulated group (SQGs) and auto body shops

    • Statistical performance measurement by participants

    • Allow benchmarking of different policy approaches, across participants

  • Credible Certification-Only Approaches

    • Show promise when full ERP not feasible

      • MA increased control of dental mercury discharges by hundreds of pounds

      • MA increased control of gas-station VOC emissions by thousands of tons

        • Self-certification and third-party certification

Want to learn more about erp
Want to Learn More about ERP? Bureau of Waste Prevention

  • Check out "ERP States Produce Results: 2007 Report on States' Experience Implementing the Environmental Results Program."

    • Executive Summary (May 2007)

    • 2007 Report (December 2007)

  • Purpose of Report:

    • Update the story of ERP

    • Identify ERP states and sectors

    • Describe results and other benefits of ERP

    • Discuss new directions within ERP community

  • Check out the States ERP Consortium website

Questions discussion
Questions/Discussion Bureau of Waste Prevention

Steve DeGabriele, States ERP Consortium Chair

(617) 556-1120

Al Innes, States ERP Consortium Vice Chair

(651) 296-7330