Project Summary Information Page

Applicant Information

Project Title: Auto Body Certification Project in the State of Delaware

Agency: State of Delaware Department of Natural Resources and
Environmental Control

**Project Contact: Kimberly Finch, Ombudsman**

**89 Kings Highway**

**Dover, DE 19901**

**(302) 739-6400**

**(302) 739-6242**

**[kimberly.finch]{.underline}****[\@state.de.us]{.underline}**

# Project Summary

The Delaware Department of Natural Resources and Environmental Control's
Air Quality Management (AQM) section has adopted new requirements for
auto body shops. These facilities are required to obtain permits. AQM is
in the process of developing a source category permit. We are going to
approach the development of the source category permit in a customer
friendly way changing the culture of the permitting process for the body
shop from an overly burdensome, disruptive or punitive regulatory
process to one that is less burdensome and user friendly. The
self-certification project will help develop tools we can use to ensure
compliance with the permits and provide follow-up assistance and easy
access to updates and information for the auto body sector. The
self-certification would be a more customer friendly tool for the auto
body sector which mainly consists of small businesses that do not have
the resources to devote to understanding environmental regulations. We
would also use a multi-media approach when educating the auto body
sector to ensure compliance with all applicable environmental
requirements.

**This project is not being executed in cooperation with or funded by
another federal program.**

**Initial assessments of auto body shops will be conducted to determine
a baseline compliance rate in the auto body sector. During the
compliance assessments and site visits to provide compliance assistance,
violations discovered will be considered under the DNREC Penalty
Mitigation Policy (as revised, June 7, 2000).**

**This project has the full support of the Cabinet Secretary of the
Delaware Department of Natural Resources and Environmental Control.**

# Summary of Budget Information

**[\[Financial information redacted\]]{.mark}**

#### Project Narrative

#### 

**The auto body industry in Delaware is subject to federal and state
environmental regulations pertaining to air, water pollution, solid and
hazardous waste generation. The Delaware Department of Natural Resources
and Environmental Control (DNREC) recognizes this sector as a sector
that is traditionally not aware of their environmental obligations. The
Air Quality Management (AQM) section recognizes that there is a need to
work with the auto body industry because so many of the shops may be
operating illegally and/or without a permit. The AQM section is
developing a source category permit for the auto body sector at this
time. A self-certification program with a strong outreach and education
component will enhance the regulatory programs within DNREC and move the
auto body industry closer to our goal of one hundred percent compliance.
The self-certification program will include a multi-media approach
addressing all of the environmental regulations pertaining to the auto
body sector, and will encourage a beyond compliance type approach
including pollution prevention and community involvement. The auto body
industry consists of mainly small and medium size shops that operate
with minimal resources. The self-certification tools that will be made
available to the auto body industry will address the full range of
requirements that these shops are responsible for and will allow the
shops to understand applicable requirements more easily. The project
will educate the auto body sector helping to bring them into compliance.
This could in turn reduce air and water pollution and in turn reduce the
potential for enforcement actions and fines. This may also help to
reduce expenses to the business**

**The auto body self-certification project will use Department resources
and outside partner leverage to assist with the project. DNREC will take
a multi-media approach i.e. water, waste, and air within the
organization and we plan to partner with local trade associations,
community organizations, Chambers of Commerce, Delaware Economic
Development Office, Division of Revenue and would like to pursue
contracting with the PennStar program developed in the Commonwealth of
Pennsylvania. We will also explore working with local vocational schools
to demonstrate techniques and train students who in the future are
potential auto body shop employees/owners.**

**We intend to hire a contractor to prepare fact sheets, self-assessment
check lists, a work book for guidance on how to complete the
self-assessment check lists, and compliance assistance tools for the
auto body shops on pollution prevention, solid and hazardous waste
generation, air pollution, and water pollution. We will also provide
training through site assessments, workshops, and other training
programs such as the PennStar program. The PennStar Program is a mobile
van with auto body equipment that would demonstrate techniques that are
most efficient in applying paints with spray guns.**

**This project will use concepts from the Massachusetts Environmental
Results Project and the Rhode Island Auto body Certification Program. We
will also gather information from other states who have similar projects
underway such as Maryland's Park Heights Project and Washington D.C.'s
EE-Cars project. We will continue to network with states that have
similar projects in place so that we can learn from their projects.**

**A self-assessment checklist and workbook will be provided to the auto
body shops which they in turn will complete and submit to DNREC. This
will ease the transition from an unregulated and predominately
uneducated sector to a sector which is educated and regulated making the
transition as easy as possible for all parties involved. The goals are
to gain one hundred percent compliance in an industry that is
traditionally not aware of the environmental regulations and to increase
regulatory awareness.**

**The Delaware program intends to expand on the other states' programs
to include a community involvement component. Many of the auto body
shops are located in communities which face multiple stresses including
economical, environmental and social issues. We may need to address
shops that are operating as illegal chop shops as well as shops that do
not have their community's support. By improving the shops environmental
performance we may be able to improve it's relationship with the
community as well as the shops relationship with DNREC and other
regulatory agencies.**

**We will also explore incentives to offer auto body shops to encourage
participation in this program. Incentives will include the Penalty
Mitigation Policy. It has been our agency's experience that some
businesses are afraid to ask for compliance assistance or turn down the
opportunity for compliance assistance because they fear the penalties
that may be assessed when violations are discovered. The Penalty
Mitigation Policy should help to alleviate some of those fears. We will
also consider the possibility of inspections incentives and some type of
endorsement of the program (i.e. a certificate, sticker) by the
Department, and possibly with EPA.**

**The Delaware program will also expand to include web based reporting
of the self-certification. Delaware has an Environmental Navigator
system that is a database and tracking system managed by DNREC employees
and accessible to the public for review. Information includes the
facility's address, compliance history, permits, inspection information,
ambient monitoring data, and required reporting information. We plan to
explore the possibility of tying the self-certification reports into the
Delaware Environmental Navigator system. To help expand the number of
business that will submit their reports on line, we will educate
businesses where they can go and have free access to a computer so that
they can submit their reports on line and have access to compliance
assistance materials that are available on the web. The web-based
self-certification reporting would also make reviewing the reports
easier for DNREC. We would also make as many of our compliance
assistance tools as possible available on the web for review.**

**The project will take a two year period to complete, followed by a
three month period for completion and submittal of a final report on the
project. The workplans for the project are outline below:**

**Phase I**

**Phase I will last approximately 9 months and will begin with the
development of a database for tracking the information gathered during
this project. Phase I will also include an identification period of the
auto body industry, our targeted audience. This will be done in
conjunction with the Department of Revenue, Economic Development Office,
Chambers of Commerce, Department Databases, local community groups and
trade associations as well as checking listings in the yellow pages.
Concurrently, our contractor will be developing the inspector check
list. The contractor will also begin development of the
self-certification forms and workbook, fact sheets, and other compliance
tools while we are developing training workshops to address the
environmental regulations and beyond compliance components which would
continue on in the initial part of Phase II.**

**Phase II**

**Phase II would follow phase I and would last about one year. Phase II
will include determining the number of body shops that are
representative of the entire universe of auto body shops in the State of
Delaware and visiting these shops for an initial compliance assessment.
The results of the initial compliance assessments will be used as a
baseline for compliance data at the start of the project**. **During
this phase, DNREC will clarify that the initial compliance assessment
visits are not official enforcement inspections and that penalties for
any violations discovered will be considered under** **the Delaware
Penalty Mitigation Policy** **(as revised June 7, 2000.** **Illegal chop
shops would be reported to the local police department. The
self-certification work book and forms that were started in phase I will
be completed during the early part of this period as well as other fact
sheets and workshops to provide compliance assistance. Once the
compliance assistance tools are completed, distribution of the materials
and compliance assistance activities will be conducted. Compliance
assistance activities and responses will be tracked. Follow up
inspections will be completed near the end of Phase II. During phase two
we will develop statistical methods for measuring or calculating the
environmental impact of compliance assistance solutions.**

**During phase I and phase II, the Navigator web based system will be
set up to accept the self-certification report.**

**Phase III**

**Phase III would last approximately 3 months. Phase III will be the
final implementation phase. This is when auto body shops should begin
submitting their self-certification forms and the program is implemented
in full. Once the project is implemented it should be able to support
itself with minimal resources from the Agency. The largest component of
phase III will be the staff review of submittals of the compliance
self-certification report. The regulatory staff within DNREC will be
responsible for review of the self-certification report and follow-up on
violations reported by the auto body shop.**

**Analysis and Reporting**

**Following the conclusion of Phase III, there will be a three month
period when analysis of the project is completed and a final report on
the project will be submitted.**

**We anticipate beginning this project in March of 2003 but would be
flexible based on when the grant funding was awarded.**

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# Project Budget

**[\[Financial information redacted\]]{.mark}**