Through Evaluation

Promoting Environmental Results 

Evaluation of the 

Effectiveness of an 

Ethanol Compliance 

Manual 

Final Report

United States Office of Policy, November 2009 

Environmental Protection Economics and Innovation EPA-100-R-10-001 

Agency (1807T) 
Acknowledgements 

This evaluation was performed by Ross & Associates Environmental Consulting, Ltd. (Ross 

& Associates) under contract to Industrial Economics, Incorporated (IEc) for EPA’s Office of 

Policy, Economics and Innovation (OPEI) under Contract EP-W-07-028 between EPA and 

IEc. The evaluation team included Anna Williams, Tamara Power-Drutis and Amy Wheeless 

of Ross & Associates, Ashley Betts and Ward Burns of EPA Region 7 and Michelle 

Mandolia of OPEI’s Evaluation Support Division. 

This report was developed under the Program Evaluation Competition, sponsored by OPEI. 

To access copies of this or other EPA program evaluations, please go to EPA’s Evaluation 

Support Division’s website at http:www.epa.gov/evaluate. 
Table of Contents 

Executive Summary ..................................................................................................... i 

I. Introduction ..........................................................................................................1

Background .......................................................................................................1

Purpose of the Evaluation .................................................................................2

Report Organization ..........................................................................................2

II. Methodology ........................................................................................................3

Evaluation Approach .........................................................................................3

Information Collection and Analysis..................................................................4

III. Findings ...............................................................................................................8

Topic Area I: Outreach and Access ..................................................................8

Topic Area II: Effectiveness of the Manual as an Information Tool ................11

Topic Area III: Changes in Understanding and Behavior................................14

Topic Area IV: Improving the Manual..............................................................16

Topic Area V: Other Compliance Assistance..................................................19

IV. Recommendations.............................................................................................20

Appendices (Available in Separate Document) 

A. Customer Satisfaction Survey 

B. Customer Satisfaction Survey Results 

C. Interview Guide – Ethanol Facility 

D. Interview Guide – Contractor 

E. Interview Guide – State Compliance Staff 

F. Interview Guide – EPA Staff 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Executive Summary 

Background and Evaluation Process 

Between June 2005 and June 2008, approximately 100 ethanol plants in EPA Region 7 (Region 7) were 

issued new environmental permits. The increase in new ethanol facilities was especially significant given 

that, during the previous 20 years, only 30 ethanol plants had been permitted. Region 7 recognized that 

the ethanol production sector may need targeted outreach and education on the pertinent federal 

environmental rules, regulations, and programs that govern the sector’s construction and operation. 

To meet this need, in November 2007, Region 7 staff published a compliance assistance manual for new 

ethanol facilities entitled Environmental Laws Applicable to Construction and Operation of Ethanol Plants 

(hereto after referred to as “the Manual”). The Manual included information on federal environmental 

programs and the roles of state and federal authorities in overseeing ethanol facility construction and 

operation. The Manual was primarily targeted to ethanol plants, but was also likely of interest to state 

regulatory program offices, trade associations, consultants, and the public. Region 7 conducted a 

number of outreach activities to publicize the Manual to ethanol plants and other stakeholders. 

Region 7, with support from the EPA Office of Policy, Economics and Innovation (OPEI), wished to 

evaluate the success of the Manual in improving industry compliance with relevant rules and regulations 

and to gather information on the Manual’s readability, quality of information, and overall usefulness as a 

compliance assistance tool to ethanol facilities in the Region. In addition, Region 7 wanted to identify 

ways to improve facility satisfaction with the Manual as a compliance assistance tool and to determine 

what other compliance assistance tools and materials may be helpful to ethanol facilities. The results of 

this evaluation are intended primarily for Region 7 staff as they prepare revisions to the Manual and 

produce other outreach materials for the ethanol production sector. 

An EPA-contractor team led the evaluation. Two representatives from Region 7 were part of the team; 

one who had helped to develop the Manual as a member of the Region 7 Biofuels Team, and one 

representative of the Region's policy and management division. The other EPA team member was an 

evaluation specialist in EPA Headquarters’ Evaluation Support Division within OPEI. The contractor team 

Exhibit ES-1. Overarching Evaluation Questions 

Topic Area I: Outreach and Access. How effective are Region 7’s efforts to advertise the 

availability of and distribute the Manual to ethanol facilities and other intended audiences? 

Topic Area II: Effectiveness of the Manual as an Information Tool. How effective is the 

Manual as a tool for transferring compliance (and related facility technical support) information to 

ethanol facilities? 

Topic Area III: Changes in Understanding and Behavior. Has the existence and use of the 

Manual led to increased understanding and behavior change to support improved compliance? 

Topic Area IV: Improving the Manual. How could the Manual be improved to provide effective 

compliance assistance to ethanol facilities? 

Topic Area V: Other Compliance Assistance. What approaches other than the Manual would 

provide effective compliance assistance to the ethanol facilities? 

November 2009 ES-i 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

consisted of Industrial Economics (IEc) and a subcontractor, Ross & Associates Environmental 

Consulting, Ltd. (Ross & Associates). Ross & Associates implemented most of the contractor 

responsibilities and produced this report with support from the other team members. 

The evaluation focused on five overarching evaluation questions, listed on the previous page in Exhibit 

ES-1. To answer the overarching questions, the evaluators conducted 20 interviews with facility 

environmental managers, ethanol industry contractors, state compliance staff members, and EPA staff 

members. In addition, the evaluators developed a customer satisfaction survey and distributed the 

survey to ethanol facilities in Region 7 and ethanol industry contractors known to work in the Region. 

Finally, the evaluators conducted research on ethanol plant compliance to try to answer the overarching 

evaluation question on the effect the Manual had on facility compliance. 

Findings 

Those interviewed and surveyed for the evaluation found the Manual to be very useful. They appreciated 

its existence, the effort that EPA Region 7 undertook to develop it, and the “gesture” that the proactive 

assistance approach embodied in the Manual represented. Generally, comments for improvement 

focused on timelier and improved distribution and a variety of changes to make the Manual a stronger 

compliance assistance tool. Below were the major findings for each overarching evaluation topic area. 

Topic Area I: Outreach and Access 

Awareness of the Manual amongst the primary audiences—ethanol facilities and contractors—was not as 

prevalent as it could be despite outreach efforts by Region 7 staff. In addition, the timing of the Manual’s 

publication occurred after most new plants had commenced or completed construction; only a handful of 

new ethanol plants started productions since November 2007. A majority of the facilities that the 

evaluators spoke with in the summer of 2009 were not immediately aware of the Manual’s existence. 

Nonetheless, most of these facilities were receptive to reviewing the Manual as a part of this evaluation. 

Feedback also indicated that the audience for the Manual is larger than just Region 7-specific ethanol 

facilities and contractors, and that promoting the Manual nationally could be beneficial, particularly to EPA 

Regions with significant numbers of ethanol plants. 

Topic Area II: Effectiveness of the Manual as an Information Tool 

Participants in the evaluation found the Manual to be well organized, easy to navigate, and an appropriate 

tool for conveying compliance information to facilities. Having this material, including appropriate 

contacts, organized in one place provided for an easy reference for facility managers and they found the 

Manual to be readable and organized logically. Participants provided varied and inconsistent feedback 

on whether the Manual was too technical or not technical enough, but everyone interviewed and surveyed 

indicated that they found the Manual to be useful in some way. Whether the Manual has the appropriate 

level of detail likely depends on the reader’s existing level of knowledge and facility needs. 

Topic Area III: Changes in Understanding and Behavior 

All of the facilities and contractors that participated in this evaluation said the Manual was comprehensive 

and was helpful for increasing or solidifying their understanding of environmental compliance 

requirements. 

This evaluation cannot conclusively say that the Manual has led to any significant changes that would 

affect facility compliance. With only a few exceptions, respondents to this evaluation were not able to 

identify specific instances where facilities had more awareness of applicable federal regulations or had 

made compliance or management changes as a result of the Manual. Research of the EPA Enforcement 

November 2009 ES-ii 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

November 2009 ES-iii 

and Compliance History Online (ECHO) database showed that, after the Manual was published in late 

2007, there was some change in informal and formal enforcement actions at Region 7 ethanol facilities, 

but due to lagging and incomplete enforcement data and the inability to know exactly when a facility 

reviewed the Manual, the evaluators cannot say conclusively than the Manual had an effect on 

compliance. 

Topic Area IV: Improving the Manual 

Respondents to this evaluation had a number of suggestions on how future versions of the Manual could 

be improved. These suggestions centered around additional content, such as a section on cellulosic 

ethanol, or around functional content, such as checklists, case studies, and specific examples. The 

recommendations below carry forward many of the suggestions offered by those interviewed and 

surveyed. 

Topic Area V: Other Compliance Assistance 

Evaluation participants thought that, while the Manual itself was a useful tool, other venues, such as 

conferences, EPA workshops, a more interactive Web site, and one-on-one interaction with ethanol 

facilities were also valuable approaches for providing compliance assistance to ethanol facilities. 

Recommendations 

Evaluation participants clearly conveyed that the Manual was useful and valuable and that it effectively 

communicated relevant information for ethanol plants. The following recommendations focus on ways to 

improve the Manual for any potential future versions and on other ways that Region 7 could make the 

existing information available to its intended audiences. The evaluators understand that there may be 

limited resources available for updating the Manual and limited time available for staff to provide other 

kinds of compliance assistance to ethanol facilities. Further, the market for ethanol has been shifting 

dramatically and demand for new facility permits has not returned to the peak it was in when the Manual 

was first released. Demand for the Manual and feasibility of implementing any of the evaluation’s 

recommendations will likely be influenced by these and other factors. The following recommendations, 

which are expanded upon in the body of the report, are offered for Region 7’s consideration. 

1. As a first step, consider whether to tailor the Manual’s content and distribution to the national level. 

2. Consider additional outreach strategies and targeted audiences. 

3. Consider making this tool primarily Web-based, with a hard copy Manual as a supplement. 

4. Update the Manual to include new regulatory and compliance information. 

5. Create an executive summary to encapsulate the main points of the Manual. 

6. Incorporate more “at a glance” information, such as lists of resources, call-out boxes, checklists, and 

calendars. 

7. Provide more specific examples and case studies. 

8. Expand content to include regulatory information about topics of interest to ethanol plants, such as 

cellulosic ethanol production and byproduct diversion into other products. 

9. Expand information on beyond compliance efforts and best practices. 

10. Apply the lessons from this evaluation to the Region’s other compliance assistance and beyond 

compliance efforts. 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

I. Introduction 

Background 

Between June 2005 and June 2008, approximately 100 ethanol plants in EPA Region 7 (Region 7) were 

issued new environmental permits. The increase in new ethanol facilities was especially significant given 

that, during the previous 20 years, only 30 ethanol plants had been permitted. Region 7 recognized that 

the ethanol production sector may need targeted outreach and education to understand the pertinent 

federal environmental rules, regulations, and programs that govern the sector’s construction and 

operation. 

To meet this need, in November 2007, Region 7 staff published a 

compliance assistance manual for new ethanol facilities entitled 

Environmental Laws Applicable to Construction and Operation of 

Ethanol Plants (hereto after referred to as “the Manual”). The Manual 

included information on federal environmental programs and the roles 

of state and federal authorities in overseeing ethanol facility 

construction and operation.1

 

“The Manual in general was 

a huge undertaking and a 

great idea... a good public 

service...” – EPA contact 

Ethanol plants were the primary audience for the Manual, but the Manual was also likely of interest to 

state regulatory program offices, trade associations, consultants and the public. To distribute the Manual 

to the relevant stakeholders, Region 7 staff conducted a number of outreach activities: 

 Staff announced the development of the Manual at the 2007 National Association of Farm 

Broadcasting Convention and distributed ethanol materials to attendees and exhibitors. 

 Staff developed a news release about the development of the Manual and distributed it to those who 

had expressed interest and to the editors of agriculture and biofuels magazines. 

 Staff posted the Manual on the EPA Region 7 Web site. 

 The Region 7 Office of Public Affairs (OPA) shared ethanol postcards with the Chairs of the Missouri 

House Agriculture Committee, the Agribusiness Committees, and the Senate Agriculture Committee, 

along with members of these committees, as well as at relevant conferences (e.g., Commodity Class, 

the Missouri Agribusiness Association annual meeting, the Kansas Feed and Grain annual 

conference, the Nebraska Governor’s Conference on Agriculture, and the Missouri Governor’s 

Conference on Agriculture). 

 The Region 7 Regional Administrator (RA) and OPA attended the Fuel Ethanol Workshop and 

announced the development of the Manual. OPA collected contact information for those interested in 

the Manual and notified them via email when Region 7 released the Manual. 

 The RA conducted news interviews about the Manual (e.g., Missourinet, WHO-Farm radio) and 

mentioned the Manual in a number of speeches (e.g., at Commodity Classic, Bunge North America, 

Inc., CenSARA’s National Environmental Biofuels Conference). 

 OPA met with executives of ethanol plants and shared information about the Manual. 

 

1

 A copy of the Manual can be downloaded at: 

http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf

November 2009 Page 1 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

 Air program staff discussed the Manual at a number of events and meetings (e.g., Iowa State Field 

Briefing, a meeting with the head of EPA’s Office of Enforcement and Compliance Assistance, 

CenSARA Director's Meeting). 

 Staff informed a number of interested stakeholders about the Manual, including RCRA (Resource 

Conservation and Recovery Act) State programs, the U.S. Army Corps of Engineers. Staff also 

informed two ethanol facilities about the Manual during the facilities’ RCRA inspections. 

 Each Emergency Planning & Community Right-to-Know Act (EPCRA) state coordinator announced 

the availability of the Manual at his or her State Emergency Response Commission meetings. 

Purpose of the Evaluation 

Region 7, with support from the EPA Office of Policy, Economics, and Innovation (OPEI), wished to 

evaluate the success of the Manual in improving industry compliance with relevant rules and regulations 

and to gather information on the Manual’s readability, quality of information, and overall usefulness as a 

compliance assistance tool to ethanol facilities in the Region. In addition, Region 7 wanted to identify 

ways to improve facility satisfaction with the Manual as a compliance assistance tool and to determine 

what other compliance assistance tools and materials may be helpful to ethanol facilities. The results of 

this evaluation are intended primarily for Region 7 staff as they prepare revisions to the Manual and 

produce other outreach materials for the ethanol production sector. 

An EPA-contractor team led the evaluation. Two representatives from Region 7 were part of the team; 

one who had helped to develop the Manual as a member of the Region 7 Biofuels Team, and one 

representative of the Region's policy and management division. The other EPA team member was an 

evaluation specialist in EPA Headquarters’ Evaluation Support Division within OPEI. The contractor team 

consisted of Industrial Economics (IEc) and a subcontractor, Ross & Associates Environmental 

Consulting, Ltd. (Ross & Associates). Ross & Associates implemented most of the contractor 

responsibilities and produced this report with support from the other team members. 

The results of this evaluation are intended primarily for Region 7 staff as they prepare revisions to the 

Manual and produce other outreach material for the ethanol production sector. The results of this 

evaluation could also assist this and other Regions with compliance assistance materials for industry and 

manufacturing sectors. 

Report Organization 

This report consists of four sections, in addition to this Introduction (Section I). Section II provides an 

overview of the evaluation methodology. Section III describes the findings for each evaluation question. 

Section IV lists and describes the evaluation’s concluding recommendations for Region 7. Appendices, 

which include a copy of the survey, the survey results, and the interview guides, are provided in a 

separate document. 

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Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

II. Methodology 

The following section provides an overview of the evaluation methodology, including the team’s initial 

approach for planning the evaluation and information collection and analysis process. 

Evaluation Approach 

As a first step in the evaluation, the evaluation team refined the initial evaluation questions that had been 

submitted as a part of OPEI’s evaluation competition, identified the information needs to answer the 

refined questions, and updated the draft ethanol manual logic model that had been developed previously 

to help inform the evaluation. 

As a first step in the evaluation, the evaluation team refined the initial evaluation questions that had been 

submitted as a part of OPEI’s evaluation competition, identified the information needs to answer the 

refined questions, and updated the draft ethanol manual logic model that had been developed previously 

to help inform the evaluation. 

Evaluation Questions 

The evaluation team developed the overarching evaluation questions listed below to structure the 

evaluation. The overarching questions cover five topics: effectiveness of distribution of to the Manual, 

effectiveness of the Manual as an information tool, effectiveness of the Manual on understanding and 

behavior changes, possible improvements to the Manual, and other approaches for providing compliance 

tools. 

The evaluation team developed the overarching evaluation questions listed below to structure the 

evaluation. The overarching questions cover five topics: effectiveness of distribution of to the Manual, 

effectiveness of the Manual as an information tool, effectiveness of the Manual on understanding and 

behavior changes, possible improvements to the Manual, and other approaches for providing compliance 

tools. 

Exhibit 1. Overarching Evaluation Questions

Topic Area I: Outreach and Access. How effective are Region 7’s efforts to advertise the 

availability of and distribute the Manual to ethanol facilities and other intended audiences? 

Topic Area II: Effectiveness of the Manual as an Information Tool. How effective is the 

Manual as a tool for transferring compliance (and related facility technical support) information 

to ethanol facilities? 

Topic Area III: Changes in Understanding and Behavior. Has the existence and use of 

the Manual led to increased understanding and behavior change to support improved 

compliance? 

Topic Area IV: Improving the Manual. How could the Manual be improved to provide 

effective compliance assistance to ethanol facilities? 

Topic Area V: Other Compliance Assistance. What approaches other than the Manual 

would provide effective compliance assistance to the ethanol facilities? 

These overarching evaluation questions informed data collection, including development of the interview 

guides and the survey (see Appendices). This report presents findings according to each overarching 

evaluation question. 

Evaluability Assessment 

Following development of the evaluation questions, the evaluation team conducted an evaluability 

assessment to ensure that there would be enough information to assess the effectiveness of the Manual. 

This evaluability assessment identified: 

Following development of the evaluation questions, the evaluation team conducted an evaluability 

assessment to ensure that there would be enough information to assess the effectiveness of the Manual. 

This evaluability assessment identified: 

 What information would be needed to address the key evaluation questions; 

 Whether the needed information would be available; and 

 How the available information would be collected. 

November 2009 Page 3 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

November 2009 Page 4 

The conclusion of this evaluability assessment was that, with the available data and information collection 

methods, to some extent all evaluation questions would be answerable, with qualitative, yet authoritative, 

information and stakeholder feedback. The one exception was Topic Area III: the evaluability 

assessment concluded that, due to a lack of data, the evaluation would not be able to draw definitive 

conclusions about a causal relationship between the Manual and facility compliance. 

Logic Model 

In preparing for this evaluation, Region 7 developed a logic model for the Manual and its associated 

activities. The evaluation team refined the model to elaborate on potential outcomes of Manual use (see 

Exhibit 2 on the following page). The final logic model depicts the linkages between program activities 

inputs, outputs, stakeholders, and expected outcomes of Region 7’s outreach activities and compliance 

assistance tool. 

Information Collection and Analysis 

In planning for the evaluation, the evaluation team determined that interviews with relevant stakeholders, 

supplemented by a survey of facilities and contractors, would help to answer the overarching evaluation 

questions. The primary target audience for the Manual and thus the main source of feedback were 

ethanol facilities and contractors. The secondary audiences were state and EPA Region 7 compliance 

staff. While trade associations and the public were also listed in the logic model as an “audience” or 

“customers” for the Manual, they were not targeted for separate information collection in this evaluation. 

Using information provided by Region 7, the evaluators contacted the ethanol plants and a handful of 

contractors to assess interest in participating in an interview and/or a survey. During this contact, the 

evaluators also offered to send Internet links for the Manual to those facilities and contractors who were 

not previously aware of the Manual or had not received it. 

In addition to interviews and surveys, the evaluators conducted some limited research on facility 

compliance in the Region to better understand any changes in facility compliance. 

Interview Approach 

The evaluators collected data from ethanol plants, contractors, EPA staff, and state compliance staff 

through a set of telephone interviews. Facility and contractor interviews were with individuals who 

confirmed that they had received and reviewed the Manual. Region 7 staff contributed suggestions on 

who to interview at EPA and state agencies. The list of interviewees was reviewed by other members of 

the evaluation team to ensure a representative selection. The final set of interviewees consisted of: 

 Individuals at seven facilities that had responsibilities pertaining to environment compliance. 

 Three ethanol-industry environmental consultants/contractors; an additional consultant submitted 

written feedback. 

 Five state compliance staff members from three Region 7 state environmental agencies. 

 Five EPA staff members, four of whom were from Region 7 and one from EPA Headquarters. 
Evaluation of the Effectiveness of an Ethanol Compliance Manual 

Exhibit 2. Ethanol Compliance Manual Logic Model 

Goal: Improve environmental regulatory compliance among ethanol facilities in order to reduce impacts on environmental a

INPUTS OUTPUTS OUTCOMES 

ACTIVITIES PARTICIPANTS SHORT TERM MEDIUM TERM 

Improved Awareness and Knowledge of Regulatory Requirements and Attitude Change 

Changes in Ethanol Facilities Operations or Management 

OUTCOME MEASURES 

Resources from:  EPA Region 7 

Biofuels Team 

 EPA Region 7 

Ag Team 

 State 

Agencies 

 Trade Groups 

 Create 

Compliance Manual 

 Answer 

Regulatory Questions 

 Develop Other 

Outreach Materials 

 Improve and 

Revise Manual

 Ethanol 

Facilities 

 Biofuels Team 

and Regulatory Programs 

 State 

Compliance Staff 

 Ethanol 

Contractors 

 Trade Groups  Public 

# of facilities that say they better understand how to comply with regulations # of facilities that contacted someone for further compliance assistance # of Manuals accessed (print copies/ downloads) 

# of facilities that took at least one recommended action to comply with regulations # of facilities that adopted process changes # of facilities improving environmental management systems or conducting reviews

2 It was assumed that increased compliance with environmental laws would result in the long-term outcomes of improved environmenta

these long-term outcomes would be realized over the course of months or years. It was beyond the scope or ability of this evaluatiooutcomes have occurred as a direct result of the compliance assistance manual in question. Similarly, it was not feasible as part of thdata needed to develop the long-term (aspirational) performance measures listed in the logic model. 

November 2009 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Interviewees received interview guides (see Appendices C, D, E, and F) in advance of their interviews. 

Interviews were generally conducted by one Ross & Associates staff member and lasted 15 to 30 

minutes. The evaluators conducted the telephone interviews based on the interview guides; however, the 

order in which topics were discussed sometimes varied. Notes from these interviews were collected 

during the interviews and entered in an Excel workbook. These notes were considered confidential and 

not included in this report. Any specific quotes that this report uses as examples were sent to the 

relevant interviewees to ensure accurate communication of ideas, and are not attributed to the individual 

in this report. 

The evaluation team had originally considered conducting a set of follow-up interviews with the primary 

and secondary audiences after doing an initial round of information collection. However, after conducting 

the interviews, the evaluation team determined that follow-up interviews would be unlikely to yield 

additional feedback or insight. However, the evaluation team did meet with members of the EPA Region 

7 Biofuels Team to discuss the report’s draft findings and recommendations. 

Survey Approach 

There were as many as 150 ethanol facilities in Region 7, as well as a number of ethanol industry 

contractors, who may have received and read the Manual. To reach as many of them as possible and 

understand their access to and satisfaction with the Manual, the evaluation team developed and 

administered a written customer satisfaction survey to be completed by mail or on the Internet. 

The Federal Paperwork Reduction Act of 1995 requires that federal agencies receive approval from the 

Office of Management and Budget (OMB) before requesting information from more than nine non-federal 

entities, and must do so by submitting an Information Collection Request (ICR) to OMB for approval. The 

evaluation team developed a survey, submitted the survey under generic ICR 1711.05 to OMB, and 

received approval following some minor survey revisions. 

Following OMB approval of the survey, Ross & Associates emailed or mailed the survey to all Region 7 

ethanol facilities and contractors for which it had contact information. This survey (see Appendix A) 

focused on customer satisfaction with the Manual. Survey responses were anonymous unless 

respondents chose to identify themselves. 

Participants were encouraged to respond to the survey within approximately four weeks. Approximately 

three weeks after the survey was mailed, the evaluators contacted facilities and contractors with a 

reminder email or reminder postcard and extended the due date to solicit more responses. 

The evaluators mailed or emailed surveys to approximately 120 facilities and contractors. Of these, 

approximately ten were returned as having no recipient. Of the remaining, 24 facilities and contractors 

completed surveys; at least three had also participated in a telephone interview. Others may have 

participated in telephone interviews, but did not identify themselves in the survey. 

The response rate for the survey was approximately 20 percent; generally, response rates for customer 

satisfaction surveys range from 10 percent to 30 percent, so this response rate was not unexpected. 

Factors that may have contributed to this response rate include the fact that the evaluators did not 

connect with all facilities and contractors to alert a specific contact that a survey would be forthcoming; 

some facilities in Region 7 were no longer in operation; and there was no tangible and immediate 

incentive offered for completing the survey. 

Additional Information Review 

In addition to the surveys and interviews, the evaluators reviewed background material and researched 

compliance information through available data to help answer the overarching evaluation questions. The 

evaluators reviewed the Manual itself, the outreach activities that Region 7 had done to promote 

November 2009 Page 6 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

distribution of the Manual, and the plant list available at Ethanol Producer Magazine 

(http://ethanolproducer.com/plant-list.jsp), which provides status of operation, when the facility started 

production, and type of feedstock. In addition, the evaluators conducted Internet searches to see which 

organizations or companies had posted links to the Manual from their Web sites. 

Finally, the evaluators reviewed EPA’s Enforcement and Compliance History Online (ECHO) database. 

ECHO provides an overview of a facility’s environmental record under the Clean Air Act (CAA) Stationary 

Source Program, the Clean Water Act (CWA) National Pollutant Elimination Discharge System (NPDES), 

and the Resource Conservation and Recovery Act (RCRA), and associated state and federal responses. 

The evaluators queried each facility in Region 7 that had information in the database and tracked informal 

and formal violations pre-publication of the Manual and post-publication of the Manual (the Manual was 

published in November 2007). The evaluators also looked at the compliance history of specific facilities 

that were interviewed or surveyed and compared the results for a richer analysis of compliance. 

November 2009 Page 7 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

III. Findings Findings 

The following pages describe the evaluation’s key findings, organized by the overarching evaluation 

questions. Those interviewed and surveyed for the evaluation found the Manual to be very useful. They 

appreciated its existence, the effort that EPA Region 7 undertook to develop it, and the “gesture” that the 

proactive assistance approach embodied in the Manual represented. Generally, comments for 

improvement focused on timelier and improved distribution and a variety of changes to make the Manual 

a stronger compliance assistance tool. 

The following pages describe the evaluation’s key findings, organized by the overarching evaluation 

questions. Those interviewed and surveyed for the evaluation found the Manual to be very useful. They 

appreciated its existence, the effort that EPA Region 7 undertook to develop it, and the “gesture” that the 

proactive assistance approach embodied in the Manual represented. Generally, comments for 

improvement focused on timelier and improved distribution and a variety of changes to make the Manual 

a stronger compliance assistance tool. 

Topic Area I: Outreach and Access 

How effective are Region 7’s efforts to advertise the availability of and distribute the Manual to ethanol 

facilities and other intended audiences? 

Overarching Findings 

As discussed in Section I, Region 7 staff conducted a number of outreach activities to publicize the 

availability of the Manual to ethanol plants and other interested stakeholders. However, awareness of the 

Manual was not as prevalent as it could be for these audiences, and the timing of its publication was not 

coincident with the largest increase in construction of ethanol plants. Nonetheless, access to the Manual 

was sufficient for stakeholders who were aware of it, and many had additional suggestions for how to 

improve advertisement of the Manual. Feedback also indicated that the audience for the Manual was 

larger than just Region 7-specific ethanol facilities and contractors, and that promoting the Manual 

nationally could be beneficial, particularly to EPA regions with significant numbers of ethanol plants. 

 Access to Manual: Overall, for facilities and contractors aware of the Manual, access to the Manual 

was considered sufficient, with many receiving it from an EPA or state contact or at a workshop or 

conference. However, a majority of facilities (31 of 51) that the evaluators spoke to in the initial 

evaluation contact period were not immediately aware of the Manual’s existence. Nonetheless, most 

of these facilities were receptive to receiving a Web link to the Manual. Of these 51 facilities, eight 

had started production in 2008 or 2009; only one of these newer facilities indicated awareness of the 

Manual prior to the evaluation. 

 Timing: Many interviewees noted that the timing of publication of the Manual was not ideal—few 

ethanol facilities have been constructed since November 2007, after the Manual was published, and 

many have gone out of business or halted production since that time. 

 Distribution Audiences: Many facilities indicated that they use contractors and consultants to find out 

information on current or upcoming regulations and refer to 

them with questions on compliance or permitting. Facilities also 

look to other ethanol-related organizations that interact regularly 

with the ethanol sector for information. These groups were 

noted as venues for distribution if EPA were to develop future 

versions of the Manual. 

 National Relevance: Several interviewees noted that the 

information in the Manual would be well-received in other EPA 

Regions with significant numbers of ethanol plants. In addition, 

research during this evaluation found that the Manual was 

linked on the state environmental agency Web sites of states 

not in Region 7, highlighting that non-Region 7 ethanol plants 

“Ethanol is not unique to Region 

7. If a region comes out with 

something that's a good 

product, then the agency should 

consider marketing it beyond 

that region... It should be a 

national manual. The federal 

regulations are all the same, so 

they should all use the same 

manual.” – EPA contact 

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Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

may have found this information to be relevant. 

Interview Findings 

Of those that participated in the interviews, six of the seven facilities and two of the three contractors were 

aware of the Manual prior to being contacted for the evaluation. These interviewees indicated that they 

had received it from: a contact at EPA Region 7; a manager; training sessions and workshops; and an 

environmental consultant. 

Generally, the timing of the publication of the Manual was more of an issue than mode of distribution in 

getting information out to relevant stakeholders. As few ethanol plants have been placed into operation 

since the Manual was published, many of the facilities the evaluators spoke with were already aware of 

the information, having been in operation for some period of time. Region 7 noted that more than 100 

facilities have been issued environmental permits between June 2005 and June 2008. According to 

Ethanol Producer Magazine, only 11 facilities have been put into operation after November 2007, 

indicating that the largest increase in activity was prior to publication of the Manual.3

 Additionally, a 

number of plants have gone out of business or have halted production in recent months. According to 

Ethanol Producer Magazine, only seven facilities in Region 7 were not operating during the summer and 

autumn of 2009. However, during the evaluation, the evaluators encountered disconnected lines, 

returned surveys, and comments from ethanol plant staff that indicated that the number of facilities that 

had at least temporarily halted production was higher. 

Interviewees from the state agencies all work in some capacity with ethanol facilities and noted that they 

have not referred any facilities to the Manual, but indicated that they may in the future as the ethanol 

industry rebounds and new facilities are constructed. Both EPA and state staff noted that the information 

in the Manual was helpful to operators just beginning to plan construction of a facility, but those people 

are difficult to identify unless they approach regulators before beginning plant construction. 

For improving distribution of the Manual, contractors were highlighted as an important and oft-used 

resource for ethanol facilities on environmental issues. Five of the seven ethanol plants that were 

interviewed indicated that they receive assistance on environmental compliance and permitting issues 

from contractors and that these contractors alert them of new and upcoming regulations. All of the 

contractors also stated that they help many ethanol plants in Region 7 with their environmental 

compliance issues. 

In addition to contractors and consultants, facility interviewees noted that they received information about 

environmental regulations and tools from many different sources, and suggested these venues as ways 

to get information about to this audience in the future. Region 7 distributed the Manual using some of the 

below approaches (e.g., making information about the Manual available at workshops, alerting relevant 

stakeholders), but feedback suggested that wider distribution through a number of venues, including the 

following, would be useful: 

 Make Manual available at environmental workshops. 

 Provide Manual during EPA or state on-site technical assistance or inspections. 

 Make information available on a more interactive EPA Web site. 

 Distribute information on EPA and external email listservs. 

 Post Manual on state environmental agency Web sites. 

 Send hard copies of Manual to all potentially relevant organizations or facilities, including: 

 

3 Ethanol Producer Magazine, Plant List. Accessed at http://ethanolproducer.com/plant-list.jsp on August 18, 2009. 

November 2009 Page 9 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

o Directly to contractors and consultants. 

o State regulatory agencies. 

o State ethanol boards. 

o EPA program offices. 

o National and state ethanol trade associations. 

o National and state environmental consulting trade associations. 

o Air resource agencies. 

Finally, two EPA staff members and two contractors noted, unprompted, that the information in the 

Manual is not just relevant to Region 7 ethanol plants, and the Manual should be distributed and 

advertised more nationally. 

Survey Findings 

Overall, survey respondents were satisfied with their access to the Manual and had generally heard about 

it either directly from EPA, from a state contact, or during a workshop or conference. 

Four respondents, or about 17 percent of respondents, noted that they learned of the Manual specifically 

when contacted with the survey or during the initial evaluation contact period. Of the other respondents, 

they had learned about the Manual through visiting EPA’s Web site, through their state contact, at 

conferences or workshops, or from an EPA postcard. None had learned about it through an EPA 

television or radio interview, and only one due to an EPA news release (see Figure below). All but one of 

the respondents, or 95 percent, indicated that they were satisfied or very satisfied with their access to the 

Manual; the other respondent was neither satisfied nor dissatisfied. 

November 2009 Page 10 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Other Findings 

The evaluators researched where this Manual had been referenced on the Internet. Region 7 conducted 

a number of outreach activities to announce the publication of the Manual, including developing a press 

release. News aggregation and industry-focused Web sites and journals picked up this release and 

developed short news stories for their readers, including Biofuels Journal4

, Enviro Business and Legal 

Reports5

, Bulk Transporter6, and ChemAlliance7. 

In addition, the Manual can be found on the Nebraska Ethanol Board’s and Nebraska State Department 

of Environmental Quality’s Web sites8, 9

, and on the Web sites of some state departments that are not in 

Region 7, including Kentucky10 and Minnesota.11 The Minnesota Web site noted that, while the Manual 

“was not directly intended for Minnesota ethanol plants, many of the same policies and regulations apply.” 

The Manual had received 129,337 Web server requests (“hits”) from its release in November 2007 

through August 2009. 

Topic Area II: Effectiveness of the Manual as an Information Tool 

How effective is the Manual as a tool for transferring compliance (and related facility technical support) 

information to ethanol facilities? 

Overarching Findings 

Participants in the evaluation found the Manual to be well organized, easy to navigate, and an appropriate 

tool for conveying compliance information to facilities. Having this material, including appropriate 

contacts, organized in one place provided for an easy reference for facility managers. Participants 

indicated that they found the Manual to be readable and organized logically. Participants provided varied 

and inconsistent feedback on whether the Manual was too technical or not technical enough, but 

everyone interviewed and surveyed indicated that they found the Manual to be useful in some way. 

Whether the Manual has the appropriate level of detail likely depends on the reader’s existing level of 

knowledge and facility needs. 

 Readable and Organized: Overall, respondents for this evaluation found the Manual to be readable 

and well-organized. 

 

4

 “EPA Ethanol Manual: Environmental Compliance Manual for Ethanol Plants.” Biofuels Journal. May/June 08, 

page 44. Accessed on September 10, 2009: http://www.nxtbook.com/nxtbooks/GJ/BJ_56_08/index.php 5

 “EPA Region 7 Announces Rollout of Environmental Manual for Ethanol Facilities.” Enviro Business and Legal 

Reports. November 16, 2007. Accessed on August 19, 2009: http://enviro.blr.com/news.aspx?id=83282 6 “EPA develops ethanol manual for producers.” Bulk Transporter, November 19, 2007. Accessed on August 19, 

2009: http://bulktransporter.com/management/tank-truck/epa_ethanol_manual/. 7 “EPA ethanol Compliance Manual Available Online.” ChemAlliance, September 5, 2008. Accessed on August 19, 

2009: http://www.chemalliance.org/news/news_detail.asp?StoryID=2272 

8

 “Reports.” Nebraska Department of Environmental Quality. Accessed on August 19, 2009: 

http://www.deq.state.ne.us/Publica.nsf/Pages/06-192 

9

 “Resources.” Nebraska Ethanol Board. Accessed on September 10, 2009: http://www.neethanol.org/resources/resources.htm 

10 “BioFuel Considerations.” Kentucky Department for Energy Development and Independence. Accessed on August 

19, 2009: http://www.energy.ky.gov/dre3/renewable/considerations.htm 11 “Ethanol in Minnesota – information for industry.” Minnesota Pollution Control Agency. Accessed on August 19, 

2009: http://www.pca.state.mn.us/energy/fuels/ethanol-facilities.html 

November 2009 Page 11 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

 Level of Detail: Among respondents, there was disagreement over whether the document was too 

technical or not technical enough, but everyone interviewed and surveyed indicated that they found 

some use from the Manual. In addition, most respondents thought the right amount of information 

was available in the Manual, though a few indicated that too little information was available and 

provided ideas for where content could be expanded or added. 

 Reference Guide: As noted previously, almost all facilities who responded to this evaluation had 

started production prior to publication of this Manual, so they were familiar with the material; however, 

they expressed appreciation for having the information in one place to refer to when needed. 

 Contact Information: Respondents saw the value of having specific state and EPA contacts in 

Appendix A of the Manual to refer to for more information, but noted that it would be more difficult to 

keep up to date than other information in the Manual. 

Interview Findings 

All interviewees provided an overall positive assessment of the 

content and organization of the Manual, indicating that the Manual 

was organized well and was very readable. Comments included 

that it was helpful that the Manual was organized by EPA program 

areas and that the language was very straight forward. Critiques of 

the Manual from some respondents were that it may be slightly too 

technical for those new to the field of environmental compliance and 

permitting and that its length may prevent some potential users from 

perusing it. However, no interviewees indicated that they saw 

opportunities for shortening the Manual. Other interviewees, 

however, indicated the opposite—that the Manual was too general 

and needed more detail to be more useful to ethanol plants. One state interviewee noted that when a 

facility first contacts them about an environmental permit, their state agency has a multi-media group that 

provides information on the requirements for the facility; gives permit application forms and any other 

relevant handouts; and offers to have an in-person meeting for any questions. This outreach provides 

much of the same information found in the Manual, so the Manual itself was less useful in providing 

unique information to this state’s facilities. 

“If anything you’re trying to 

reach a broad audience, and 

the more broad you make it the 

less technical it becomes... so 

it doesn't necessarily have the 

right level of detail for the finer 

points in regulation for all 

intended audiences.” – EPA 

contact 

“There are differences between the 

contacts in the appendix and the 

contacts on the Iowa DNR Web site. 

 In some cases, the contact section 

in the manual lists the head of the 

department, which I probably 

wouldn’t need to contact. Before 

using the contact information in the 

manual I would check the Iowa DNR 

Web site to make sure I contact the 

appropriate person.” – Ethanol 

facility 

All but one of the facilities interviewed had started up production prior to publication of this Manual, so the 

general content of the Manual was already familiar to them. The one facility that started up after the 

Manual was published used it as a reference guide for construction and referred to it occasionally during 

operation. Other respondents noted that the Manual overall 

was very useful, in that having all the information in one place 

was in itself helpful. Another facility respondent said their 

facility had put together a calendar based on the Manual to 

help track due dates for permits and plans. 

The evaluators specifically asked all interviewees about the 

“Who to Contact” section of Appendix A and whether this 

section was useful and any ideas to improve it. Interviewees 

indicated that the contact information in Appendix A was 

helpful, though approximately half of the interviewees had not 

looked at this section until asked about it during the interview. 

A common comment on Appendix A was that it might be hard 

for EPA to keep the contact information current and that 

putting titles rather than contact names could help with this 

November 2009 Page 12 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

challenge. Others, however, preferred to keep the specific contact names in the Appendix and have EPA 

update the information frequently, perhaps on a linked Web site. One facility said that the contact 

information provided in the Appendix did not always match the contact information found on their state 

Web site or was not the appropriate level of staff person. One state interviewee said that he has received 

calls from around the United States with questions about ethanol regulations and wished to have a list of 

all state contacts for ethanol issues, rather than just those in Region 7. 

Survey Findings 

Significantly too

little (0%)

Slightly too

little

38%

Right

Amount

57%

Slightly too much

5%

Significantly too

much (0%)

No opinion (0%)

AmountofInformation in the Manual

N=21

 Survey respondents were generally positive about the Manual and its readability and organization. 

Twenty of the 21 respondents, or more than 95 percent, who answered questions on readability 

indicated that the Manual was somewhat easy or very easy to read (see Figure below). 

 Sixteen (76 percent) of respondents said it was easy or very easy to navigate to areas of interest, 

while five (24 percent) said it was neither easy nor difficult to navigate the Manual. Twelve 

respondents (almost 60 percent) thought there was the right amount of information in the Manual (see 

Figure below). 

November 2009 Page 13 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Topic Area III: Changes in Understanding and Behavior 

Has the existence and use of the Manual led to increased understanding and behavior change to support 

improved compliance? 

Overarching Findings 

This evaluation indicates that existence and use of the Manual has led to increased or enhanced 

understanding and knowledge for ethanol facilities. However, this evaluation cannot conclusively say that 

the Manual has led to any significant changes that would affect compliance on the part of facilities. 

 Understanding and Awareness: All of the facilities and contractors said the Manual was 

comprehensive and was helpful for increasing or solidifying their understanding of environmental 

compliance requirements. 

 Behavior Change: With only a few exceptions, respondents were not able to identify specific 

instances where facilities had more awareness of applicable federal regulations or had made 

compliance or management changes as a result of the Manual. 

Interview Findings 

All of the facilities and contractors said the Manual was 

comprehensive and was at least somewhat helpful for 

increasing their understanding of environmental compliance 

requirements, or solidifying what they already knew. The 

contractors interviewed were all very familiar with the 

applicable environmental rules, but all said that they thought 

the Manual would be helpful to a facility starting out in the 

construction and operation process. State interviewees 

noted that if the ethanol industry rebounds, the Manual 

would be very useful for helping new operators understand 

requirements. 

“I used it because we were brand new, 

and it was great for starting up. Now 

that we’re in production I refer back to 

the Manual. I also belong to a group of 

ethanol producers, and many times 

people will call me with questions. I 

use it as a reference tool to help 

answer them.” – Ethanol Facility 

EPA and state compliance staff were asked whether facilities seemed more aware of applicable federal 

environmental requirements as a result of the Manual. One EPA interviewee noted that there had been 

increased awareness of the Risk Management Program (Clean Air Act, Section 112 (r)); this interviewee 

said that, prior to the Manual, many plants did not realize they were covered under this regulation. Other 

compliance staff noted that there may be increased awareness among the regulated community, but that 

they could not conclusively point to the Manual as the cause of 

that knowledge. 

Facilities, in general, could not point to instances where the use 

of the Manual had influenced a compliance change. One 

exception was a facility that had started up after the Manual was 

published, who said, “Before we started up our plant, we read 

the Manual and realized that we had missed a permit,” which 

prompted the facility to secure the permit. No facilities could 

point to any environmental or health outcomes that resulted from 

the use of the Manual. One facility noted that the main impact on their management processes was that 

the information in the Manual allowed the facility to do more of their permitting work in-house rather than 

hiring outside consultants. 

“It allowed us to not ship out work 

to consultants; we did all the work 

in house. In the past we would 

have just hired a consultant, so I 

believe it saved us money and 

effort.” – Ethanol Facility 

November 2009 Page 14 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

One EPA interviewee recalled being contacted because of someone reviewing the Manual and having a 

follow-up question. 

Survey Findings 

Overall, survey respondents expressed satisfaction with the information thoroughness of the Manual. 

Sixteen respondents, or approximately 76 percent, were satisfied or very satisfied with how well the 

Manual met their needs for understanding compliance information, and five, approximately 24 percent, 

were neither satisfied nor dissatisfied; none expressed dissatisfaction. One contractor respondent was 

dissatisfied with the information thoroughness of the Manual, suggesting that the air section should be 

updated and expanded with more specific details. All other respondents were either satisfied or very 

satisfied with the information thoroughness (15 respondents, or greater than 70 percent) or were neither 

satisfied nor dissatisfied (five respondents, or 24 percent). 

Compliance Data Analysis 

Table 1. Pre- and Post-Manual Publication Ethanol Violations 

Informal Violation or 

Notice 

Pre-Nov. 2007 

Informal Violation or 

Notice 

Post-Nov. 2007 

Formal Violation 

Pre-Nov. 2007 

Formal Violation 

Post-Nov. 2007 

48.7% 34.6% 11.5% 9.0% 

 N=78 

Analysis of EPA’s Enforcement and Compliance History Online (ECHO) database provided the above 

information. ECHO provides an overview of a facility’s environmental record under the Clean Air Act 

(CAA) Stationary Source Program, the Clean Water Act (CWA) National Pollutant Elimination Discharge 

System (NPDES), and the Resource Conservation and Recovery Act (RCRA), as well as state and 

federal responses. 

This information shows that there had been a decrease in informal violations since the Manual was 

published in November 2007. Prior to November 2007, 48.7 percent of the facilities in Region 7 had 

received an informal violation, compared to 34.6 percent after publication of the Manual. For formal 

violations, 11.5 percent of Region 7 facilities received a formal violation before publication of the Manual, 

compared to 9.0 percent after publication. However, this evaluation cannot conclusively state that 

environmental compliance increased because of this Manual. The data in ECHO may have been 

incomplete or lagging and may not have completely shown the enforcement actions taken in all of 2009, 

and the evaluators did not have access to information on the rate at which inspections were conducted for 

facilities in the Region on a yearly basis. In addition, this evaluation had incomplete information about 

whether all of the plants analyzed were in full operation before November 2007 and whether they 

continue to be in operation at the date of this evaluation. Further, past enforcement actions can influence 

current compliance with regulations, as can other factors—such as learning from the mistakes of other 

facilities, a downturn or upturn in business, or changes in personnel with compliance responsibilities. 

Finally, this evaluation did not have information about whether all of these facilities received and reviewed 

the Manual and therefore what, if any, effect it may have had on their compliance behavior. 

The evaluators also looked more specifically at the facilities that were interviewed for this evaluation and 

that responded to the survey. Below are the findings of this analysis: 

 One facility had more than 15 informal violations between 2005 and 2007, but only two in 2008 and 

2009, all pertaining to air regulations. The facility interviewee did not explicitly credit the Manual with 

helping improve compliance, but did note that having the information in the Manual would have been 

November 2009 Page 15 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

helpful when the facility was trying to be in compliance when just beginning operation, because the 

Manual lays out all the regulations and needs clearly. The interviewee particularly noted that the 

section on the CAA was helpful, as CAA requirements can be very confusing to facilities. 

 Another facility that responded to the survey had received 15 informal CAA violations between 2007 

and 2009. In the survey, the respondent from this facility expressed satisfaction with the CAA 

information in both the building and operation sections of the Manual. This respondent also 

suggested that voluntary EPA inspections would be a helpful way to learn about compliance 

information. This facility indicated that they had received the Manual from a state contact, though did 

not indicate a timeframe for this interaction. 

 Another facility that responded to the survey had received a formal enforcement action under the 

CAA earlier in 2009. This respondent expressed dissatisfaction with the information thoroughness of 

the Manual and requested more specific examples and details. 

As noted above, this evaluation cannot conclusively state that there is any causal link between these 

compliance actions and use of the Manual. During discussions with the Region 7 Biofuels Team about 

the findings of this report, members of the Biofuels Team noted that more consistent tracking of 

compliance and beyond compliance behavior and targeting assistance based on more thorough 

compliance information may be a path forward for this sector. 

Topic Area IV: Improving the Manual 

How could the Manual be improved to provide effective compliance assistance to ethanol facilities? 

Overarching Findings 

Respondents to this evaluation had a number of suggestions for how future versions of Manual could be 

improved. The suggestions centered around additional content, such as a section on cellulosic ethanol, 

or around functional content, such as checklists, case studies, call-out boxes, and examples. 

Interview Findings 

Most interviewees had some general comments and suggestions for how the Manual could be improved 

to provide effective compliance assistance, as well as specific suggestions for additions. They offered the 

following suggested changes and additions to the content: 

 A few contractors requested more examples be provided in the Manual to define terms, such as what 

constitutes commencing construction and modifying a plant. 

 A contractor suggested including information on how long the permitting process takes, as well as a 

general discussion of what permits would likely be required, as many operators start the process 

without any knowledge of the expected permit timeframes. 

 A contractor suggested providing embedded hyperlinks to the Code of Federal Regulations (CFR) 

Web site so that readers can look up the referring statutes. 

 A contractor suggested moving the Renewable Identification Numbers (RINs) requirements 

discussion to a later section of the Manual, rather than up-front, since this requirement comes further 

along in the facility operation process. 

 A contractor noted that some of the permits listed in the Manual did not seem applicable, and three 

contractors noted other EPA permits and reporting plans applicable to ethanol plants that were not 

November 2009 Page 16 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

mentioned in the Manual, including: Toxic Substance Control Act (TSCA) Form U Reporting and New 

sources performance standards (Subpart VVa) (released after the Manual was initially published). 

 A contractor disagreed with the statement found in the Manual that “all ethanol plants will probably 

generate some quantities of hazardous waste” (page 2-20), and noted that some facilities were 

focusing on making use of their byproduct waste streams to make value-added products. 

 A facility suggested adding an executive summary to the front of the Manual to make the document 

more approachable to potential readers. 

In addition, the evaluators specifically asked interviewees about any suggested changes to the “Who to 

Contact” section of Appendix A. There was no clear consensus from interviewees on whether this section 

should provide direct numbers and names to contact people or to general support numbers. Interviewees 

noted the benefit of having these specific names in knowing whom to contact but noted that staff turnover 

could cause this section to be out of date sooner than other parts of the Manual. One state interviewee 

suggested expanding this section to include all applicable ethanol offices in state agencies so that those 

outside of Region 7 could use the Manual. 

Interviewees were asked whether there were other areas of information that EPA should consider 

covering in future versions of the Manual. The following were the suggestions provided for this area: 

 An EPA interviewee noted that issues have arisen in recent years around emissions from fermentors, 

biochemical oxygen demand loading and storm water ponds, and leak detection. These issues and 

others that have come to the attention of regulators may be candidates for specific discussions in 

future versions of the Manual. 

 An EPA interviewee suggested that checklists would be helpful to facilities that have been in 

operation and were familiar with much of the Manual content. 

 A state interviewee noted that the Manual was geared toward building a new plant, but that any future 

version could include information about requirements when making substantial modifications to that 

plant or process (e.g., using a new feed stock, burning fiber). Similarly, two contractors noted that 

ethanol plants were looking for ways to integrate value-added products to their production stream 

(e.g., oil extraction), and that including a discussion of requirements that plants should consider would 

be useful. Related to this discussion, a state compliance staff member suggested a section on 

byproduct handling. 

 An EPA interviewee suggested adding information about state laws to make the Manual more 

comprehensive, while noting that it would be more difficult to update that information. Facilities and 

contractors, similarly, said that ethanol plants were responsible for a number of federal requirements 

to different agencies, including the U.S. Department of Transportation, the U.S. Department of 

Homeland Security, the U.S. Army Corps of Engineers, and the Alcohol and Tobacco Tax and Trade 

Bureau. 

 EPA and state staff as well as contractors noted that future versions could include sections on 

cellulosic and other emerging types of ethanol. 

 State staff and contractors suggested that a future version of the Manual could include information on 

what should happen with federal permits when plants halt production for any length of time. In 

addition, unless there is renewed emphasis on alternative fuels, there may not be as much 

construction of facilities in the future; any future versions could focus on operation rather than 

construction of plants. 

November 2009 Page 17 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

 An EPA staff member suggested information on community and emergency response could be 

valuable for this audience and that EPA should incorporate this information or link to another 

organization that has resources in this area. 

Survey Findings 

The survey asked facilities and contractors what things EPA should consider to improve satisfaction with 

the Manual as a compliance assistance tool. The following were the suggestions provided in the survey 

for additional content or functionality: 

 More examples and specific details throughout the text 

 A list of ethanol relevant resources, such as ethanol trade associations 

 A list of contractors or consultants in particular states and the services they provide 

 Checklists and “at a glance” materials and pages 

In addition, a facility expressed dissatisfaction with the transition between the construction and operation 

sections of the Manual, but did not elaborate on this response. Another noted that the section on air 

quality regulations needs updating and improving, but also did not expand on this comment. 

The survey asked participants how frequently EPA should update the Manual to be helpful to facilities. 

Ten respondents (48 percent) suggested updating the Manual every three years. The three respondents 

who chose “Other” wrote in that Region 7 should update the Manual whenever there were regulatory 

changes (see Figure below). 

Annually

29%

Every 3 years

48%

Every five years

9%

Other timeframe

14%

I don’t intend to

refer to the

Manual again

(0%)

Which update frequency would be the most useful for the

Manual? N=21

November 2009 Page 18 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Topic Area V: Other Compliance Assistance 

What approaches other than the Manual would provide effective compliance assistance to the ethanol 

facilities? 

Overarching Findings 

As previously discussed, evaluation participants thought the Manual was a useful tool for conveying 

compliance information. However, evaluation participants also considered other venues, such as 

conferences, EPA workshops, a more interactive Web site, and one-on-one interaction with ethanol 

facilities to be additional valuable approaches for providing compliance assistance. 

Interview Findings 

During the interviews, facilities and contractors were asked about other tools and approaches that EPA 

could use to present the information that is available in the Manual. Five of the ethanol facility 

representatives noted that they had attended EPA workshops in the past and found them to be useful 

sources of information about regulations and implementing them at their facilities. In addition, a few of 

the contractors and facilities regularly attended conferences; additional or continued EPA presence would 

be welcome there to share information about new resources or requirements. In addition, interviewees of 

all categories noted that having an up-to-date Web site that is easy to navigate was a very effective way 

to convey information. One contractor suggested having an ethanol-specific Web page, either nationally 

or regionally, to provide links to resources and updates on regulations. 

Survey Findings 

The survey asked respondents about what other tools and approaches would be helpful for conveying 

compliance assistance information. Most noted that compliance assistance had so far been sufficient. 

Below were the other suggestions from the survey: 

 An email newsletter or listserv with reminders, updates, industry contacts, suggested best practices, 

and regulatory changes applicable to the industry. 

 Voluntary EPA inspections without fines. 

 Additional workshops and meetings with open discussions between regulators and ethanol plants. 

November 2009 Page 19 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

IV. Recommendations 

This evaluation assessed the effectiveness of an ethanol compliance assistance Manual developed by 

EPA Region 7. The evaluation focused on a set of overarching evaluation questions to inform this 

assessment. Evaluation participants clearly conveyed that the Manual was useful and valuable to its 

intended audiences, and that it effectively communicates relevant information for ethanol plants. The 

following recommendations focus on ways to improve the Manual for any potential future versions and 

other ways that Region 7 could make this information available to its intended audiences. 

The evaluators understand that there may be limited resources available for updating the Manual and 

limited time available for staff to provide other kinds of compliance assistance to ethanol facilities. The 

evaluators also recognize that the market for ethanol has been shifting dramatically, and that the demand 

for new facility permits has not returned to the peak it was in when Region 7 first released the Manual. 

These and other related factors will likely influence demand for the Manual and feasibility of implementing 

any of the evaluation’s recommendations. The below recommendations are organized thematically and 

not by priority. 

1. As a first step, consider whether to tailor the Manual’s content and distribution to the national 

level. 

The Manual is available to the public on the Region 7 Web site, and as such it is available nationally. 

However, the contact information in Appendix A is focused on Region 7 only, and EPA’s national offices 

have not posted the Manual on their Web sites. EPA and state compliance staff and contractors noted 

that the Manual’s content was not specific to Region 7, and would be of interest to other Regions with 

significant ethanol industries. Already, some state agencies such as the Kentucky Department for Energy 

Development and Independence and the Minnesota Pollution Control Agency have linked to the Manual 

on their Web sites, noting that it may be of interest to their states’ ethanol facilities. 

The Region 7 Biofuels Team noted that they had written the Manual in such a way that it could be easily 

adapted to other EPA Regions. The Region 7-specific contact information, for example, was included in 

an appendix to enable easy substitutions with other Regions’ contact information. Sending the Manual to 

EPA staff in other Regions for posting and distribution would be a simple first step to making this 

information more widely available, and Regional staff or Headquarters could take the lead on revising the 

contact Appendix and any other sections that needed another Region’s specific information. Staff in the 

other Regions and at state environmental agencies would likely need to be available to answer questions 

about the information provided by the Manual, which would require a commitment of staff time in other 

Regions with significant numbers of ethanol plants. 

The evaluators recognize that there may not be a clear national EPA office or program to take over 

responsibility for the current Manual, any updates to the Manual, or any coordination between or among 

Regions for the Manual. Similarly, other Regions may not have an equivalent biofuels team or group to 

coordinate the Manual’s distribution or incorporate regional contact information. For these reasons, if the 

Manual were to be used nationally or in other Regions, it may be necessary for the Biofuels Team in 

Region 7 to identify individual “champions” for the Manual’s use and updates at the national and/or 

regional levels. Some level of ongoing coordination between Regions or between Regions and 

Headquarters may be needed. 

November 2009 Page 20 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

2. Consider additional outreach strategies and targeted audiences. 

Region 7 undertook a number of activities to advertise the Manual’s existence, including a news release, 

providing postcards at conferences, emailing those who had expressed interest, and highlighting the 

Manual during media interviews. The Region could continue to advertise the Manual and any future 

versions with these mechanisms, but could also expand its outreach to consider additional audiences and 

outreach strategies. 

The evaluators recognize that Region 7 had limited resources to conduct Manual outreach and 

advertisement. Allocating at least some resources to outreach would allow the Region to conduct 

activities such as advertising in trade journals relevant to the ethanol industry. However, Region 7 could 

also undertake activities that would not require significant resource investment and would be more likely 

to reach the targeted audiences relatively quickly: 

 Region 7 could develop and maintain an ethanol-industry email listserv that regularly sends out 

updates and news to subscribers. Region 7 could allow anyone to join or have a moderated listserv 

of only ethanol plant managers. This approach would be a simple way to keep in contact with 

interested stakeholders and alert them to any future versions or updated Manual, or to remind them of 

the Manual’s existence, as well as send out other relevant information. 

 When Region 7 staff members visit ethanol plants on site visits, the staff could bring an electronic 

copy of the Manual or could provide a postcard with the Web link to the Manual. 

 If the Manual is updated with new information, Region 7 could gather a small focus group of three to 

five ethanol facility contacts by phone or in-person. This group could discuss the best ways to inform 

ethanol plants about any changes, and whether the industry needs a fully updated Manual with the 

information, or whether an email or Web site with the changes is sufficient. This approach would 

allow Region 7 to learn about any venues (e.g., upcoming conferences) that could be key distribution 

points, and would also allow Region 7 to target its resources strategically. 

While ethanol plants were the primary targeted audience for this Manual, ethanol-industry contractors 

could be an effective audience for future outreach. Many of the facilities interviewed said that they use 

contractors for much of their environmental compliance and permitting work, and rely on these contractors 

for updates and information on regulation. As there are a smaller number of contractors and consultants 

working with existing and potential ethanol facilities, making the Manual specifically available to 

contractors could more directly reach an important audience and perhaps ultimately reach a wider 

audience. In addition, having contractors review draft Manual updates may be a productive way to 

ensure that the Manual is helpful to the target audience. 

3. Consider making this tool primarily Web-based, with a hard copy Manual as a supplement. 

Nearly all evaluation participants accessed the Manual on the Internet, and many suggested that the 

Manual include more Web-based content, such as updates and additional or more current contact 

information. Transferring the Manual to a current, Web-based version would require some effort, 

particularly if user interactivity such as topic “drill downs” and links to related topics or contacts, were to 

be incorporated. Making the content Web-based, however, would make the Manual more accessible and 

useful to many users and likely easier to maintain and update by EPA. In addition, Internet search 

engines could find specific sections more easily, and Region 7 could implement Web feeds that would 

allow users to subscribe and be notified of any changes.12 A version formatted for printing could still be 

 

12 “Web feeds” are a format for providing users with frequently updated content. Content distributors (in this case, 

Region 7) develop a “feed” and allow users to subscribe to it. Users are alerted through a “feed reader” or through 

November 2009 Page 21 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

available on the Web for readers who wanted to download it for their office reference library or for EPA 

and state compliance staff or others who would want to take hard copies to facilities they visit. 

The below are some ways that Region 7 could implement this recommendation: 

 Region 7 could simply upload the content onto a series of HTML Web pages. This approach would 

allow EPA staff to make changes quickly to the content of the Manual, without republishing the 

document entirely. Examples of this approach at EPA include the EPA Lean in Government Starter 

Guide13 and the EPA Guide for Industrial Waste Management.14 

 Region 7 could upload the Manual to the Web in a wiki-format,15 which would allow EPA staff to edit 

the content even more easily than HTML pages, and could allow other non-EPA users to edit the 

content. This ease of updating can help ensure that content is up-to-date and relevant to its intended 

audiences. Region 7 could upload the content to an EPA-hosted or third-party hosted wiki and then 

designate through assigned log-ins which groups (e.g., EPA staff, state compliance staff, facility 

contacts) are allowed to contribute edits to the document and create discussions about specific pages 

or sections. This approach could allow a greater cross-section of stakeholders to contribute to 

improving the Manual, and could result in a more valuable resource for ethanol plants looking for 

compliance assistance information. If Region 7 decides to go this route to make the Manual Webbased, they can look to the lessons learned of similar efforts at EPA and other federal agencies. For 

example, EPA’s Watershed Central Wiki is a Web site based on the MediaWiki platform that is open 

to EPA employees and identified partners to provide information on watershed resource management 

best practices, organizations, and plans.16

 Region 7 could develop a Web site that displays the content of the Manual on a series of HTML or 

Wiki Web pages (discussed above), and also links to more dynamic content and resources internal 

and external to EPA, such as upcoming meetings or relevant conferences. For example, the EPA 

Office of Wastewater Management has developed a Web site on NPDES (National Pollutant 

Discharge Elimination System) permits.17 It links not only to compliance information, but also to 

relevant new publications and training materials, discussions of current issues, and links to upcoming 

meetings and conferences. While incorporating and updating this material would require more staff 

time and resources on a continuous basis, it could become a frequently used and valuable resource 

for ethanol plants and their environmental managers. 

4. Update with current information on regulations. 

If a future version of the Manual is published, it could incorporate the latest information on applicable 

federal environmental regulations, permits, plans, and approvals for ethanol plants. Alternatively, a 

stand-alone supplement to the Manual that focuses solely on recent changes and updates could be 

created. If the Manual was Web-based (see Recommendation 3), regular maintenance would ensure that 

all of these components are kept current. If the Manual continued to be hard-copy based, then having 

 

their email when new content is available. An example of this is EPA’s Office of Public Affairs news release pages, 

which alerts users whenever a new press release is issued; see http://www.epa.gov/newsroom/rssfeeds.htm. 13 See http://www.epa.gov/lean/starterkit/index.htm 14 See http://www.epa.gov/waste/nonhaz/industrial/guide/index.htm 15 A wiki is a Web site that allows easy creation and editing of content for users. Wikis are often used for 

collaborative editing of a document that has content that changes frequently and/or could benefit from multiple 

perspectives. Wikipedia (http://www.wikipedia.org) is one of the best known wikis. 16 See https://wiki.epa.gov/watershed/index.php/Main_Page; Access is limited to EPA employees and identified 

partners. 

17 See http://cfpub.epa.gov/npdes/index.cfm 

November 2009 Page 22 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

links within the Manual to an EPA Web page that provides real-time updates to the Manual content would 

keep the information current for ethanol facilities and contractors looking for updates.

5. Create an executive summary to encapsulate the main points of the Manual. 

A few participants in this evaluation noted that the length of the Manual could detract potential readers 

from reviewing the Manual; however, no participants noted opportunities for shortening the Manual.18 In 

addition, several participants thought that a short executive summary or equivalent synopsis would give 

readers an overview of the content and any potential sections of interest without taking away any of the 

content within the Manual. There is currently a front section (“What is the purpose of this manual?”) that 

provides two paragraphs on the purpose of the Manual and some disclaimers on what the Manual does 

not cover; however, this section is not an executive summary in the way that readers expect. Similarly, 

the Introduction covers three topics (requirements for renewable fuels, the renewable fuel standard 

program, and a brief overview of the ethanol production process), but does not include a list of the laws 

that apply when constructing, modifying, or operating ethanol plants or any related summary information. 

Creating a new executive summary or overview section to summarize the main topics of each of the 

chapters could be one way to meet the stated need of respondents. 

6. Incorporate more “at a glance” information. 

Expanded “at a glance” information, such as lists of resources, call-out boxes, checklists (e.g., on the 

steps to take), and calendars can be integrated throughout the Manual to highlight particularly important 

information. Respondents to this evaluation indicated that they would like more of this kind of content so 

that they can quickly refer to information of interest. The evaluators recognized that the Biofuels Team 

intentionally avoided creating new guidance with the Manual, and as such that there may be reason not to 

create action or requirements lists that could constitute guidance. If this has not been done already, it 

may be worth exploring the feasibility of drawing from existing guidances to develop “how to” checklists or 

other short reference lists either at the regulation, media, and/or cross-media levels. 

Similarly, a generic schedule that a plant could modify and download could be very useful. Such a 

schedule could, for example, indicate a starting date and include the deadlines (e.g., date + 90 days) for 

the related required procedures, submissions, and other information. It may be that plants or their 

contractors already have these tools in paper or electronic format and may be willing to share them for 

use by EPA for this purpose. As mentioned earlier in this report, one facility interviewee developed a 

calendar for this purpose after reading the Manual. 

Several participants raised the idea of listing resources beyond the contacts already included in Appendix 

A. Some said that a list of contractors would be of interest, though they also said that caution may need 

to be exercised in doing so to avoid perceived or actual conflicts of interest. Some thought that there 

were precedents for listing contractors and that there would be no problems in doing so as long as there 

were multiple contractors listed. Others thought that directing parties to external Web sites that already 

list contractors would be a relatively easy way to achieve this change, though it is not clear that there is 

such a resource. Other resources that Region 7 could consider could be lists of facilities that would be 

willing to discuss their experience with others and contacts from other regulatory agencies, such as the 

Occupational Safety and Health Administration (OSHA). 

 

18 One way to reduce the manual’s size would be to reformat it with fewer pictures (though the pictures make it a 

much more visually pleasing document), reduce the large margins, and modify the spacing. Converting the Manual 

to a Web-based format may or may not assist with length depending on how the Web site is designed. This would 

not serve as a substitute for including an executive summary but would likely help with the initial impression voiced by 

several participants that the Manual seems very long. 

November 2009 Page 23 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

In developing the Manual, the Biofuels Team has considered about whether a “flip book” of key issues 

and important points would be feasible. The evaluators think that anything along these lines, regardless 

of the format (e.g., flip book, standard paper format, electronic spreadsheet) would be useful for readers. 

7. Provide more specific examples and case studies. 

Participants commented that the information in the Manual was sometimes vague or too general and that 

specific examples would be helpful for understanding. For example, providing examples of what 

constitutes a modification to a building would be helpful to a reader wanting to understand what is 

applicable to their building. More narrative discussion or case studies, either real or hypothetical, can 

also help a reader relate their facility to the regulations discussed within the Manual. 

8. Expand content to include regulatory information about topics of interest to the target 

audience, such as cellulosic ethanol production and byproduct diversion into other products. 

There were many suggestions for specific content to add to the Manual for future versions (see the 

findings on Topic Area IV: Improving the Manual). Cellulosic ethanol production and byproduct diversion 

into other products were mentioned most often by the state compliance staff, facilities, and contractors 

who participated in the evaluation. Cellulosic ethanol production is expected to increase as producers 

look to different feedstocks to take advantage of new incentives, research findings and changing market 

conditions, and facilities are interested in the different federal environmental regulations that may be 

applicable. In addition, during this evaluation, ethanol facilities indicated that they were looking for ways 

to take the byproducts of ethanol production, make them into value-added products, increase profit 

margins, and decrease waste disposal. Facilities may find value in a discussion in the Manual of 

regulations and requirements to consider when changing operations in these ways. 

9. Expand information on beyond compliance efforts and best practices. 

Although the Manual is focused on current federal environmental regulations and rules, a section on how 

a facility could go beyond compliance and implement best practices may be of interest to some facilities. 

In particular, newer or smaller facilities may not know about best practices that could provide 

environmental, safety and/or economic benefits; having this information in one place could be useful. 

Currently, the Manual has a section in the construction chapter about the Pollution Prevention Action and 

refers to the EPA Pollution Prevention Web site.19 Region 7 could evaluate whether this is sufficient 

information or whether expanding this section with additional best practices could be a way to incorporate 

more beyond compliance information for the audience. The evaluators recognize, however, that 

providing beyond compliance information is a secondary priority following the Manual’s focus on 

compliance assistance. 

10. Apply the lessons from this evaluation to the Region’s other compliance assistance and 

beyond compliance efforts. 

The evaluators understand that Region 7’s compliance assistance activities are largely integrated into its 

broader compliance-enforcement program. The Region has a compliance assistance coordinator who 

serves the regional media program staff as a policy disseminator and a data quality control check for 

measuring activities. The technical and enforcement staff in the other regional programs incorporate the 

actual compliance assistance activities into their other routine actions. More broadly, the Region focuses 

on conducting inspections, following up on potential violations, and, in general, working within the 

traditional compliance-enforcement framework that has been the hallmark of EPA’s compliance approach 

for over 30 years. Region 7, like other Regions, also oversees the compliance enforcement work of the 

 

19 See http://www.epa.gov/p2/

November 2009 Page 24 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

Region 7 states and reports back to EPA Headquarters Office of Enforcement and Compliance 

Assurance (OECA) and on its activities and progress through routine reporting channels. Compliance 

assistance is, in other words, primarily an “add on” to more “core” programmatic activities and 

responsibilities. 

Within this broader construct, the Region conducts both ad-hoc and routine periodic compliance 

assistance work. The Manual is an ad-hoc example that the Region took on after a dramatic shift in the 

number of new permit requests for ethanol facilities as explained in this report. In another instance, 

Region 7 is focusing on improving compliance with a new lead (Pb) rule, which was promulgated in April 

2008. This rule requires workers to follow lead-safe work practice standards to reduce potential exposure 

to dangerous levels of lead during renovation and repair activities.20 The Region has been conducting 

outreach with thousands of contractors and citizens who renovate, repair, or repaint older buildings that 

may have lead-based paint to support compliance with the new rule. The Region also discusses 

compliance assistance activities each quarter with the Region 7 states. At these meetings, the state and 

regional staff take turns sharing their compliance assistance activities among discussions of other 

activities for collaboration. 

Within this context, the evaluators, in consultation with Region 7 staff, have identified some options for 

applying the lessons learned from the evaluation of the ethanol compliance assistance manual to the 

Region’s broader compliance assistance activities. These options, which can serve as the basis for 

further discussion within the Region, are as follows: 

i. Determine whether the Region would like to initiate more compliance assistance activities like the 

ethanol compliance assistance manual that are proactive in nature and intended to help raise 

awareness amongst a targeted regulated community that has been identified as needed additional 

support. Doing so would require additional planning and coordination and therefore the “blessing” of 

senior managers who would deploy staff resources for this purpose. In addition, there may need to 

be further exploration of the relationship between the compliance assistance work and the more 

customary interactions that compliance inspectors have with the regulated community to clarify 

respective roles and responsibilities. 

ii. Consider options for cross-media compliance assistance integration like the Biofuels’ Team effort on 

the ethanol manual. Evaluation participants expressed their appreciation for having all major 

regulations described in one place instead of media-by-media and program-by-program. 

iii. Consider additional opportunities for coordinating with, as well as learning from, the Region 7 state 

compliance programs. Although Region 7 already works hand-in-hand with the state compliance 

enforcement programs, there are likely opportunities to be more proactive in terms of identifying 

potential compliance gaps or assistance opportunities, learning about planned or ongoing compliance 

activities that the states are conducting and coordinating on compliance assistance implementation. 

There are likely efficiencies and economies of scale for doing so; for instance, in providing regional 

compliance assistance materials (such as the Manual) to state compliance staff and vice versa, or in 

having strategic planning meetings intended to design and coordinate Region-wide compliance 

activities for the upcoming years (this would be materially different from the current update-oriented 

quarterly meetings). 

iv. Take advantage of Internet-based tools and options. Tools such as Webinars, interactive guides, 

Wikis, and topical drill-down Web sites (such as the one discussed in the context of the ethanol 

 

20 See: http://www.epa.gov/region7/citizens/lead.htm

November 2009 Page 25 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Final Report 

November 2009 Page 26 

compliance assistance manual) provide opportunities for getting compliance information out to a wide 

range of people quickly. 

In general, these ideas and options will depend on whether Region 7 wishes to invest in more targeted 

compliance assistance on top of the current compliance-enforcement activities. There are likely to be 

needs related to existing or new rules where additional compliance assistance focus would help to raise 

awareness and support compliance before any inspectors contact regulated entities. Perhaps Region 7 

is already exploring such options in relation to other sector outreach, or perhaps this is an area that is 

worth exploring. 

As a first step, Region 7 may wish to identify a point person or small group of individuals to further explore 

the options for either following up on recommendations related to the ethanol compliance assistance 

manual itself, or on taking a next step on additional targeted compliance assistance that can benefit from 

the lessons gained from the Manual evaluation. It is likely that a targeted scoping exercise could result in 

a short set of viable options and recommendations for future “value added” compliance assistance that 

Region 7, its states, and the Regional regulated community could all utilize to support improved 

understanding of and compliance with the law. 
United States Office of Policy, November 2009 

Environmental Protection Economics and Innovation EPA-100-R-10-001 

Agency (1807T) 

Evaluation of the 

Effectiveness of an 

Ethanol Compliance 

Manual 

Report Appendices
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Table of Contents 

Appendix A. Customer Satisfaction Survey.............................................................1

Appendix B. Customer Satisfaction Survey Results..............................................10

Appendix C. Interview Guide for Ethanol Facilities................................................19

Appendix D. Interview Guide for Ethanol Contractors...........................................22

Appendix E. Interview Guide for State Compliance Staff......................................24

Appendix F. Interview Guide for EPA Staff ...........................................................26
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

EPA ICR No. 1711.05 

OMB Control No. 2090-0019 

EXPIRATION DATE: 8/31/2009

Appendix A. Customer Satisfaction Survey 

COMPLIANCE ASSISTANCE MANUAL

FOR ETHANOL FACILITIES

Survey of Customer Satisfaction

Thank you for participating in this survey so that EPA can serve you more effectively.

Assuming you have already read the compliance assistance manual, Environmental Laws Applicable to 

Construction and Operation of Ethanol Plants, we anticipate that the main part of this survey will take 

approximately 10-20 minutes and the optional questions at the end will take approximately an additional 

10 minutes. Your participation will help EPA improve ethanol facilities’ satisfaction with this manual. 

You may also take this survey on-line at the following website: 

http://www.surveymonkey.com/s.aspx?sm=2uWpdtMi8JSWjH_2bkMbQ35g_3d_3d. 

Submitting your responses online will take the same amount of time and will help us to analyze the 

results and provide feedback to EPA more quickly. 

If you choose to fill out the paper survey instead, please return 

your responses by July 10, 2009 in the enclosed self-addressed 

stamped envelope. 

Note about respondent confidentiality: The contractors evaluating 

the ethanol facilities’ and contractors’ satisfaction with the compliance 

assistance manual, Environmental Laws Applicable to Construction and 

Operation of Ethanol Plants, are gathering basic information to better 

understand how useful different types of customers have found the 

Manual to be. Informational responses will be generalized and made 

anonymous for the final results and no facility or contractor names or 

other identifiers will be provided to EPA as part of the results, unless a 

facility or contractor explicitly indicates at the end of this survey that 

they would like their responses to be identified. 

Industrial Economics, Incorporated (http://www.indecon.com/) and Ross & Associates Environmental Consulting, 

Ltd. (http://www.ross-assoc.com) are the contractor team. For more information, please contact Anna Williams 

(anna.williams@ross-assoc.com) or Amy Wheeless (amy.wheeless@ross-assoc.com) by email or at (206) 447-

1805.

November 2009 Page 1 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

I. PART 1: INFORMATION ABOUT YOU AS OUR CUSTOMER

1. Prior to receiving this questionnaire, were you aware that EPA developed the Compliance

Assistance Manual for Ethanol Facilities (Manual) and that the Manual was publically available?

{    {   

Yes    No   

2. Have you received (or downloaded) the Compliance Assistance Manual for Ethanol Facilities,

published by EPA in November 2007?  If No, please skip to Question 17.

{    {   

Yes    No   

3. Please check the method below that indicates how you learned about the Manual

{ { { { {

Postcard

distributed from

EPA

EPA news release EPA radio or TV

interview

EPA Web site State contact

{ { { {

Meetings /

conferences (e.g.,  

FEW workshop,

CenSARA's National

Environmental

Biofuels

Conference)

Other

correspondence

from EPA

Other method

(please specify)

Don’t know/don’t

remember

If other:  

4. Why were you interested in receiving the Manual?  (check all that apply)

{ { { {

Wanted to learn more

about applicable Federal

laws for construction of

facilities

Wanted to learn about

applicable Federal laws for

operation of facilities  

General reference Other

If other:

November 2009 Page 2 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Optional response:  {  I received the Manual without asking for it (check here if applicable)

II. PART 2: ACCESSING THE MANUAL

5. Please check the method below that indicates how you accessed the Manual.

{ { { { {

Downloaded the

Manual from the

EPA Web site

Received a

Compact Disc (CD)

from EPA

Received a CD

from a state

contact

Received a CD

from another

contact outside of

my facility

Received a hard

copy from EPA

{ { {

Received a hard

copy from a state

contact

Received a hard

copy from a

different (not

state/EPA) contact

outside of my

facility

Other method

(please specify)

If other:  

6. Please rate how satisfied you were with the ease of accessing the Manual.  

{ { { { { {

Very

Dissatisfied

Dissatisfied Neither

Dissatisfied nor

Satisfied  

Satisfied Very Satisfied No Opinion

  

Please describe any ways you think EPA could improve access to the Manual (optional):

7. Have you read any part of the Manual?  If No, please skip to Question 17. If Yes, please continue

to Part 3 of the survey.

{    {   

Yes    No   

November 2009 Page 3 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

III. PART 3: STRUCTURE AND READABILITY OF THE MANUAL

8. Please rate your satisfaction with the Manual’s readability.    

{ { { { { {

Very difficult to

read  

Difficult to read Neither easy

nor difficult to

read

Somewhat easy

to read

Very easy to  

read

No opinion  

9. Please rate the ease of navigating through the Manual to get to areas of interest.    

{ { { { { {

Very difficult to

navigate to

areas of interest

Difficult to

navigate to

areas of

interest

Not easy, but

not difficult to

navigate to

areas of

interest

Easy to

navigate to

areas of

interest  

Very easy to

navigate to

areas of

interest

No opinion  

10. How would characterize the amount of information presented in the Manual?  

{ { { { { {

Significantly too

little

Slightly too

little

Right Amount Slightly too

much

Significantly

too much

No opinion  

We welcome any comments on your response:

IV. PART 4: YOUR OVERALL SATISFACTION WITH THE MANUAL

11. a. Please rate your satisfaction with how well the Manual met your needs for understanding

compliance information.

Very Dissatisfied Dissatisfied

Neither

Dissatisfied nor

Satisfied   Satisfied

Very  

Satisfied No Opinion  

{ { { { { {

November 2009 Page 4 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

b. Please rate your satisfaction with how clear the information provided in the Manual was on

where to go for more information.

Very Dissatisfied Dissatisfied

Neither

Dissatisfied nor

Satisfied   Satisfied

Very  

Satisfied No Opinion  

{ { { { { {

c. Please rate your satisfaction with the information thoroughness of the Manual.

Very Dissatisfied Dissatisfied

Neither

Dissatisfied nor

Satisfied   Satisfied

Very  

Satisfied No Opinion  

{ { { { { {

We welcome any comments on your response:

Were there any sections of or chapters of the Manual you were particularly dissatisfied with?  If so,

we welcome any explanation and suggestions for improving your satisfaction with that section or

chapter below.

{Yes {No

12. What else should EPA consider to improve your satisfaction with the Manual as a compliance

assistance tool?

November 2009 Page 5 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

13. Please rate your overall satisfaction with the Manual as a compliance assistance tool.

Very Dissatisfied Dissatisfied

Neither

Dissatisfied nor

Satisfied   Satisfied

Very  

Satisfied No Opinion  

{ { { { { {

V. PART 5: OTHER SUGGESTIONS FOR FUTURE COMPLIANCE ASSISTANCE

14. If EPA were to update the Manual, which update frequency would be the most useful?  

{ { { { {

Annually Every 3 years Every five years Other timeframe

(please specify)

I don’t intend to

refer to the

Manual again

If other:

15. What other tools and approaches would you prefer for sharing compliance assistance

information concerning ethanol facilities?

VI. FINAL QUESTIONS!

16. What category best describes your position?

{ { { {

Facility manager Facility compliance officer   Other facility role

(please specify)

Contractor

If other:

17. Can we identify your facility or company (by name) as having participated in this survey?

{Yes {No

November 2009 Page 6 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Facility or Company Name (optional)  

PRIMARY POINT PERSON (OPTIONAL)

If you are willing to provide the name of a primary point person who could be contacted by the

contractors with any follow up questions or correspondence, please list that person here.   

Name:

Phone Number:

E‐mail Address:

Thank you for participating in this survey!

Please return your responses using the enclosed self‐addressed stamped envelope by  

July 10, 2009.

November 2009 Page 7 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Optional Section: if you would like to provide more specific feedback on each Section of the

Introduction, Chapter 1, Chapter 2, and the Appendices that you have reviewed, please answer

the following questions.   

1. Please rank your overall satisfaction with the ease of understanding, information thoroughness,

and overall usability of each of the Manual’s sections:

Very

Dissatisfied Dissatisfied

Neither

Dissatisfied

nor

Satisfied   Satisfied

Very

Satisfied

No

Opinion

Introduction

Section I.1: Requirement

for Renewable Fuels { { { { { {

Section I.2: Renewable

Fuel Standard Program { { { { { {

Section I.3: Brief

Overview of Ethanol

Production Process

{ { { { { {

Chapter 1: What Laws Apply When I’m Constructing or Modifying a Plant

Section 1.1: National

Environmental Policy Act { { { { { {

Section 1.2: Clean Air Act { { { { { {

Section 1.3: Clean Water

Act { { { { { {

Section 1.4: Safe

Drinking Water Act { { { { { {

Section 1.5: Pollution

Prevention Act { { { { { {

Chapter 2: What Laws Apply to Operating an Ethanol Plant?

Section 2.1: Clean Air Act { { { { { {

Section 2.2: Emergency

Planning and Community

Right to Know Act

{ { { { { {

Section 2.3: Clean Water

Act { { { { { {

Section 2.4: Safe

Drinking Water Act { { { { { {

November 2009 Page 8 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

November 2009 Page 9 

Very

Dissatisfied Dissatisfied

Neither

Dissatisfied

nor

Satisfied   Satisfied

Very

Satisfied

No

Opinion

Section 2.5: Resource

Conservation and

Recovery Act –

Hazardous Waste

{ { { { { {

Appendices

Appendix A (First Half):

Summary of Laws Pertaining

to Ethanol Production and

Contacts

{ { { { { {

Appendix A (Second Half):

Contact Information { { { { { {

Appendix B: Emergency

Planning    { { { { { {

Appendix C: Clean Air Act

Section 112‐R Requirements { { { { { {

Appendix D: Definitions Of

Acronyms    { { { { { {

Appendix E: The NEPA Process   { { { { { {

Do you have any specific suggestions for improving the usefulness of any of the Manual sections?

(optional)

If you have not done so already, please remember to fill out the final section of the main part of the

survey starting with “Part 4: Your Overall Satisfaction with the Manual” on page 3. Thank you!

Burden Statement: Public reporting burden for this collection of information is estimated to average fifteen (15)

minutes per response, including the time for reviewing instructions, gathering information, and completing and

reviewing the collection of information, with a possible ten (10) additional minutes for the optional section at the

end. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates,

and any suggestions for reducing the burden, including the use of automated collection techniques to the Director,

OEI Collection Strategies Division, United States Environmental Protection Agency (Mail Code 2822T), 1200

Pennsylvania Avenue, Washington, DC 20460; and to the Office of Information and Regulatory Affairs, Office of

Management and Budget, 725 17th Street NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the

EPA ICR number (1711.04) and the OMB control number (2090‐0019) in any correspondence.
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Appendix B. Customer Satisfaction Survey Results 

Note: Questions that asked for optional contact information are not listed here, nor are any participant 

comments that indicated which surveys responded to the survey. 

I. PART 1: INFORMATION ABOUT YOU AS OUR CUSTOMER

1. Prior to receiving this questionnaire, were you aware that EPA developed the Compliance

Assistance Manual for Ethanol Facilities (Manual) and that the Manual was publically available?

Response 

Percent 

Response 

Count 

Yes 72.7% 16 

No 27.3% 6 

answered question 22

skipped question 2

2. Have you received (or downloaded) the Compliance Assistance Manual for Ethanol Facilities,

published by EPA in November 2007?  If No, please skip to Question 17.

Response 

Percent 

Response 

Count 

Yes 100.0% 22 

No 0.0% 0 

answered question 22

skipped question 2

3. Please check the method below that indicates how you learned about the Manual

Response 

Percent 

Response 

Count 

Postcard distributed from EPA 13.0% 3 

EPA news release 4.3% 1 

EPA radio or TV interview 0.0% 0 

EPA Web site 21.7% 5 

State contact 17.4% 4 

Meetings / conferences (e.g., FEW workshop, 

CenSARA's National Environmental Biofuels 

Conference) 

13.0% 3 

Other correspondence from EPA 8.7% 2 

Other method (please specify) 17.4% 4 

Don’t know/don’t remember 4.3% 1 

Other (please specify) 

• From corporate office 

• From this survey and this consulting firm 

• This questionnaire 

• From Ross & Associates 

4 

November 2009 Page 10 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

answered question 23

skipped question 1

4. Why were you interested in receiving the Manual?  (check all that apply)

Response 

Percent 

Response 

Count 

Wanted to learn more about applicable Federal laws 

for construction of facilities 22.7% 5 

Wanted to learn about applicable Federal laws for 

operation of facilities 63.6% 14 

General reference 54.5% 12 

Other (please specify) 4.5% 1 

I received the Manual without asking for it 3 

answered question 22

skipped question 2

II. PART 2: ACCESSING THE MANUAL

5. Please check the method below that indicates how you accessed the Manual.

Response 

Percent 

Response 

Count 

Downloaded the Manual from the EPA Web site 73.7% 14 

Received a Compact Disc (CD) from EPA 0.0% 0 

Received a CD from a state contact 0.0% 0 

Received a CD from another contact outside of my 

facility 0.0% 0 

Received a hard copy from EPA 15.8% 3 

Received a hard copy from a state contact 5.3% 1 

Received a hard copy from a different (not 

state/EPA) contact outside of my facility 5.3% 1 

Other method (please specify:) 

• Received electronic copy from corporate office 

• Electronic copy from state contact 

• Received link from Ross & Associates 

• Emailed to me by EPA contact 

4 

answered question 19

skipped question 5

6. Please rate how satisfied you were with the ease of accessing the Manual.  

Response 

Percent 

Response 

Count 

Very Dissatisfied 0.0% 0 

Dissatisfied 0.0% 0 

Neither Dissatisfied nor Satisfied 4.3% 1 

Satisfied 43.5% 10 

Very Satisfied 39.1% 9 

November 2009 Page 11 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

No Opinion 13.0% 3 

answered question 23

skipped question 1

Please describe any ways you think EPA could improve access to the Manual (optional):

No Answers

7. Have you read any part of the Manual?  If No, please skip to Question 17. If Yes, please continue

to Part 3 of the survey.

Response 

Percent 

Response 

Count 

Yes 91.3% 21 

No 8.7% 2 

answered question 23

skipped question 1

III. PART 3: STRUCTURE AND READABILITY OF THE MANUAL

8. Please rate your satisfaction with the Manual’s readability.    

Response 

Percent 

Response 

Count 

Very difficult to read 0.0% 0 

Difficult to read 0.0% 0 

Neither easy nor difficult to read 4.8% 1 

Somewhat easy to read 47.6% 10 

Very easy to read 47.6% 10 

No opinion 0.0% 0 

answered question 21

skipped question 3

9. Please rate the ease of navigating through the Manual to get to areas of interest.    

Response 

Percent 

Response 

Count 

Very difficult to navigate to areas of interest 0.0% 0 

Difficult to navigate to areas of interest 0.0% 0 

Not easy, but not difficult to navigate to areas of 

interest 23.8% 5 

Easy to navigate to areas of interest 57.1% 12 

Very easy to navigate to areas of interest 19.0% 4 

No opinion 0.0% 0 

answered question 21

skipped question 3

November 2009 Page 12 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

10. How would characterize the amount of information presented in the Manual?  

Response 

Percent 

Response 

Count 

Significantly too little 0.0% 0 

Slightly too little 38.1% 8 

Right Amount 57.1% 12 

Slightly too much 4.8% 1 

Significantly too much 0.0% 0 

No opinion 0.0% 0 

answered question 21

skipped question 3

We welcome any comments on your response:

No Answers

IV. PART 4: YOUR OVERALL SATISFACTION WITH THE MANUAL

11. a. Please rate your satisfaction with the following:

Very 

Dissatisfied Dissatisfied

Neither 

Dissatisfied 

nor 

Satisfied 

Satisfied Very 

Satisfied 

No 

Opinion 

How well the Manual 

met your needs for 

understanding 

compliance information 

0 (0%) 0 (0%) 5 (23.8%) 13 

(61.9%) 

3 

(14.3%) 0 (0%) 

How clear the 

information provided in 

the Manual was on 

where to go for more 

information 

0 (0%) 0 (0%) 6 (28.6%) 11 

(52.4%) 

4 

(19.0%) 0 (0%) 

The information 

thoroughness of the 

Manual 

0 (0%) 1 (4.8%) 5 (23.8%) 13 

(61.9%) 2 (9.5%) 0 (0%) 

answered question 21

skipped question 3

We welcome any comments on your response

• Should have provided some more details.

November 2009 Page 13 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Were there any sections of or chapters of the Manual you were particularly dissatisfied with?  If

so, we welcome any explanation and suggestions for improving your satisfaction with that

section or chapter below.

Response 

Percent 

Response 

Count 

Yes 9.5% 2 

No 90.5% 19 

answered question 21

skipped question 3

We welcome any comments on your response:

• The section on air quality regulations needs improvement and updating.

• Construction to operations transition

What else should EPA consider to improve your satisfaction with the Manual as a compliance

assistance tool?

• A section targeted to the regulators (EPA/states) where the ethanol plants can provide

input on details of plant operations and the importance of operational flexibility.

• Good overviews. Wish it was more thorough or provided examples. Is there a list of

resources or contractors/consultants that could be provided for each state and what

services they provide?

• I really can't think of anything, this was a very comprehensive manual.

• Include checklists, one‐page "at‐a‐glance" tables, etc.

• The more specific and less vague it is, the more valuable a resource it will be.

• No suggestions at this time.

• Nothing  

12. Please rate your overall satisfaction with the Manual as a compliance assistance tool.

Answer Options Response 

Percent 

Response 

Count 

Very Dissatisfied 0.0% 0 

Dissatisfied 0.0% 0 

Neither Dissatisfied nor Satisfied 14.3% 3 

Satisfied 76.2% 16 

Very Satisfied 9.5% 2 

No Opinion 0.0% 0 

answered question 21

skipped question 3

November 2009 Page 14 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

V. PART 5: OTHER SUGGESTIONS FOR FUTURE COMPLIANCE ASSISTANCE

13. If EPA were to update the Manual, which update frequency would be the most useful?  

Answer Options Response 

Percent 

Response 

Count 

Annually 28.6% 6 

Every 3 years 47.6% 10 

Every five years 9.5% 2 

Other timeframe (please specify) 14.3% 3 

I don’t intend to refer to the Manual again 0.0% 0 

Other (please specify) 

• When regulations change 

• Any time there has been a major regulatory change 

• As often as changes are made 

3 

answered question 21

skipped question 3

14. What other tools and approaches would you prefer for sharing compliance assistance

information concerning ethanol facilities?

• Yearly EPA meetings with industry ‐ compliance/update seminars

• Think it has been good so far.

• Workshops/meetings with open, unbiased, and frank discussions between regulators

and ethanol plants.

• Email listserv for ethanol industry contacts that sends regulatory/policy changes

applicable to the industry or NAICS code. Send industry compliance advisories that give

helpful info on what are some compliance concerns along with any compliance

assistance info or best practices.

• An associated question and answer document to is mainted so you could access it to see

if there are any changes to the manual.

• EPA inspection without fines (voluntary)

• Email updates/newsletters

• An email newsletter with reminders, updates and new information would be helpful.

• new regulations and laws that come up every year

• No suggestions. Website and manual are both sufficient in my opinion.

VI. FINAL QUESTIONS!

15. What category best describes your position?

Answer Options Response 

Percent 

Response 

Count 

Facility manager 19.0% 4 

Facility compliance officer 61.9% 13 

Other facility role (please specify) 14.3% 3 

Contractor 4.8% 1 

November 2009 Page 15 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

If other: 

• EH&S Manager (2) 

• Consultant 

• Environmental engineer/EHS manager 

• Environmental, Health and Safety Coordinator 

5 

answered question 21

skipped question 3

16. Can we identify your facility or company (by name) as having participated in this survey?

Answer Options Response 

Percent 

Response 

Count 

Yes 52.2% 12 

No 47.8% 11 

answered question 23

skipped question 1

Optional Section: if you would like to provide more specific feedback on each Section of the

Introduction, Chapter 1, Chapter 2, and the Appendices that you have reviewed, please answer

the following questions.   

1. Please rank your overall satisfaction with the ease of understanding, information thoroughness,

and overall usability of each of the Manual’s sections:

Answer Options Very 

Dissatisfied Dissatisfied 

Neither 

Dissatisfied 

nor 

Satisfied 

Satisfied Very 

Satisfied 

No 

Opinion 

Section I.1: 

Requirement for 

Renewable Fuels 

0 (0%) 0 (0%) 1 (14.3%) 2 

(28.6%) 1 (14.3%) 3 (42.9%) 

Section I.2: 

Renewable Fuel 

Standard Program 

0 (0%) 0 (0%) 1 (14.3%) 4 

(57.1%) 0 (0%) 2 (28.6%) 

Section I.3: Brief 

Overview of Ethanol 

Production Process 

0 (0%) 2 (28.6%) 2 (28.6%) 1 

(14.3%) 0 (0%) 2 (28.6%) 

answered question 7

skipped question 17

Answer Options Very 

Dissatisfied Dissatisfied 

Neither 

Dissatisfied 

nor 

Satisfied 

Satisfied Very 

Satisfied 

No 

Opinion 

Section 1.1: National 

Environmental Policy 

Act 

0 (0%) 0 (0%) 0 (0%) 5 

(71.4%) 0 (0%) 2 (28.6%) 

Section 1.2: Clean 0 (0%) 0 (0%) 1 (14.3%) 3 1 2 

November 2009 Page 16 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Air Act (42.9%) (14.3%) (28.6%) 

Section 1.3: Clean 

Water Act 0 (0%) 0 (0%) 1 (14.3%) 2 (28.6%) 

2 

(28.6%) 

2 

(28.6%) 

Section 1.4: Safe 

Drinking Water Act 0 (0%) 0 (0%) 3 (42.9%) 2 (28.6%) 0 (0%) 2 (28.6%) 

Section 1.5: 

Pollution Prevention 

Act 

0 (0%) 0 (0%) 1 (14.3%) 4 

(57.1%) 0 (0%) 2 (28.6%) 

answered question 7

skipped question 17

Answer Options Very 

Dissatisfied Dissatisfied

Neither 

Dissatisfied 

nor 

Satisfied 

Satisfied Very 

Satisfied 

No 

Opinion 

Section 2.1: Clean Air 

Act 0 (0%) 0 (0%) 1 (14.3%) 6 (85.7%) 0 (0%) 0 (0%) 

Section 2.2: 

Emergency Planning 

and Community Right 

to Know Act 

0 (0%) 0 (0%) 1 (14.3%) 6 

(85.7%) 0 (0%) 0 (0%) 

Section 2.3: Clean 

Water Act 0 (0%) 0 (0%) 1 (14.3%) 5 (71.4%) 

1 

(14.3%) 0 (0%) 

Section 2.4: Safe 

Drinking Water Act 0 (0%) 0 (0%) 1 (14.3%) 5 (71.4%) 0 (0%) 1 (14.3%) 

Section 2.5: Resource 

Conservation and 

Recovery Act – 

Hazardous Waste 

0 (0%) 0 (0%) 1 (14.3%) 5 

(71.4%) 

1 

(14.3%) 0 (0%) 

answered question 7

skipped question 17

Answer Options Very 

Dissatisfied Dissatisfied

Neither 

Dissatisfied 

nor 

Satisfied 

Satisfied Very 

Satisfied 

No 

Opinion 

Appendix A (First 

half): Summary of 

Laws Pertaining to 

Ethanol Production 

and Contacts 

0 (0%) 1 (14.3%) 1 (14.3%) 2 (28.6%) 3 

(42.9%) 0 (0%) 

Appendix A (Second 

half): Contact 

Information 

0 (0%) 0 (0%) 2 (25.0%) 2 (25.0%) 4 

(50.0%) 0 (0%) 

Appendix B: 

Emergency Planning 0 (0%) 1 (14.3%) 2 (28.6%) 4 (57.1%) 0 (0%) 0 (0%) 

Appendix C: Clean Air 

Act Section 112-r 

requirements 

0 (0%) 0 (0%) 3 (42.9%) 4 (57.1%) 0 (0%) 0 (0%) 

Appendix D: 

Definitions of 0 (0%) 0 (0%) 1 (14.3%) 5 (71.4%) 1 (14.3%) 0 (0%) 

November 2009 Page 17 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

November 2009 Page 18 

Acronyms 

Appendix E: The NEPA 

Process 0 (0%) 0 (0%) 4 (57.1%) 3 (42.9%) 0 (0%) 0 (0%) 

answered question 8

skipped question 16

Do you have any specific suggestions for improving the usefulness of any of the Manual sections?

(optional)

Answer Options Response 

Percent 

Response 

Count 

Yes 0.0% 0 

No 100.0% 8 

If yes, please provide: 0 

answered question 8

skipped question 16
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Appendix C. Interview Guide for Ethanol Facilities 

A NOTE TO INTERVIEWEES

A Ross & Associates evaluator will ask the questions in this guide during your telephone interview. The 

interview is not intended to be a test of your knowledge of the compliance manual Environmental Laws 

Applicable to the Construction and Operation for Ethanol Plans. Rather, the evaluation is designed to 

collect feedback on your thoughts about the Manual’s effectiveness in relaying compliance information to 

ethanol facilities. For the interview, it is not expected that you will have carefully read the entire Manual, 

but please at a minimum review those parts of the manual that pertain to your area of work. The manual 

can be accessed at: http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf

If you have an questions, please contact Anna Williams or Amy Wheeless, Ross & Associates by phone 

at 206-447-1805 or by email at anna.williams@ross-assoc.com or amy.wheeless@ross-assoc.com. 

TOPIC AREA I: OUTREACH AND ACCESS TO MANUAL

Overarching Question: How effective are Region 7’s efforts to advertise the availability of and distribute the

Manual to ethanol facilities and other intended audiences?

1. Where did you obtain the Manual? 

2. How could distribution of or access to the Manual be improved? 

TOPIC AREA II: EFFECTIVENESS OF THE MANUAL

Overarching Question: How effective is the Manual as a tool for transferring compliance (and related facility

technical support) information to ethanol facilities?

1. How readable and comprehendible is the Manual? 

2. How comprehensive is the Manual in its scope? 

3. What was most/least useful or informative to you in the Manual? 

4. Is the contact information provided in the Appendices helpful? How could it be improved? 

5. How has your facility used the Manual? If your facility has not used the Manual, why not? 

6. What regulatory actions did your facility take, or intend to take, as a result of reviewing the 

Manual? 

November 2009 Page 19 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

7. What process or management changes did your facility make or intend to make as a result of 

reviewing the Manual? 

8. Did your facility make any changes in constructing or establishing the plant as a result of 

reviewing the Manual? 

TOPIC AREA III: UNDERSTANDING AND BEHAVIOR CHANGE

Overarching Question: Has the existence and use of the Manual led to increased understanding and behavior

change to support improved compliance?

1. After reviewing the Manual, do you feel more aware of the applicable Federal regulations? 

2. Are there still federal laws or regulations that you do not understand after reading the Manual? 

3. Have there been any changes in your compliance results since reviewing the Manual? 

4. What “beyond compliance” measures has your facility made as a result of using the manual? 

5. Are there specific environmental health outcomes (e.g. amount of waste generated) that have 

resulted from use of the Manual? 

6. Have you noticed any human health outcomes (e.g. reductions in the number of accidents) that 

have resulted from this Manual, or are you aware of any potential effects on human health? 

TOPIC AREA IV: IMPROVING THE MANUAL

Overarching Question: How could the Manual be improved to provide effective compliance assistance to ethanol

facilities?

1. What changes would you recommend to the Manual to improve its readability and navigation? 

2. What could be changed about the Manual to make it more thorough and comprehensive and to 

make it more effective as a compliance tool? 

3. Are there topics you would like more or new information about in a future Manual? 

4. What are possible ways that EPA Region 7 could distribute an updated Manual to its audiences, 

or make facilities and other stakeholders aware that an updated Manual is available? 

5. Do you have any other suggestions for improving the Manual? 

TOPIC AREA V: OTHER COMPLIANCE ASSISTANCE

Overarching Question: What approaches other than the Manual would provide effective compliance assistance

to the ethanol facilities?

November 2009 Page 20 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

1. What are other ways you find information about regulations and applicable laws? 

2. What are other ways EPA could present the information in the Manual to its targeted audiences? 

(e.g. workshops, interactive Web site) 

FINAL QUESTION

1. Do you have any final “closing thoughts” or recommendations regarding the overarching 

questions, sub questions or the compliance assistance Manual in general? 

Thank you for participating! 

November 2009 Page 21 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Appendix D. Interview Guide for Ethanol Contractors 

A NOTE TO INTERVIEWEES

A Ross & Associates evaluator will ask the questions in this guide during your telephone interview.  The

interview is not intended to be a test of your knowledge of the compliance manual Environmental Laws

Applicable to the Construction and Operation for Ethanol Plans.  Rather, the evaluation is designed to collect

feedback on your thoughts about the Manual’s effectiveness in relaying compliance information to ethanol

facilities.  For the interview, it is not expected that you will have carefully read the entire Manual, but please at

a minimum review those parts of the manual that pertain to your area of work.  The manual can be accessed at:

http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf

If you have an questions, please contact Anna Williams or Amy Wheeless, Ross & Associates by phone at 206‐

447‐1805 or by email at anna.williams@ross‐assoc.com or amy.wheeless@ross‐assoc.com.   

TOPIC AREA I: OUTREACH AND ACCESS TO MANUAL

Overarching Question: How effective are Region 7’s efforts to advertise the availability of and distribute the

Manual to ethanol facilities and other intended audiences?

1. Where did you obtain the Manual? 

2. How could distribution of or access to the Manual be improved? 

TOPIC AREA II: EFFECTIVENESS OF THE MANUAL

Overarching Question: How effective is the Manual as a tool for transferring compliance (and related facility

technical support) information to ethanol facilities?

1. How readable and comprehendible is the Manual? 

2. How comprehensive is the Manual in its scope? 

3. What was most/least useful or informative to you in the Manual? 

4. Is the contact information provided in the Appendices helpful? How could it be improved? 

TOPIC AREA III: UNDERSTANDING AND BEHAVIOR CHANGE

Overarching Question: Has the existence and use of the Manual led to increased understanding and behavior

change to support improved compliance?

1. After reviewing the Manual, do you feel more aware of the applicable Federal regulations? 

November 2009 Page 22 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

2. Are there still federal laws or regulations that you do not understand after reading the Manual? 

3. Are there specific environmental health outcomes (e.g. amount of waste generated) that have 

resulted from use of the Manual? 

4. Have you noticed any human health outcomes (e.g. reductions in the number of accidents) that 

have resulted from this Manual, or are you aware of any potential effects on human health? 

TOPIC AREA IV: IMPROVING THE MANUAL

Overarching Question: How could the Manual be improved to provide effective compliance assistance to ethanol

facilities?

1. What changes would you recommend to the Manual to improve its readability and navigation? 

2. What could be changed about the Manual to make it more thorough and comprehensive and to 

make it more effective as a compliance tool? 

3. Are there topics you would like more or new information about in a future Manual? 

4. What are possible ways that EPA Region 7 could distribute an updated Manual to its audiences, 

or make facilities and other stakeholders aware that an updated Manual is available? 

5. Do you have any other suggestions for improving the Manual? 

TOPIC AREA V: OTHER COMPLIANCE ASSISTANCE

Overarching Question: What approaches other than the Manual would provide effective compliance assistance

to the ethanol facilities?

1. What are other ways you find information about regulations and applicable laws? 

2. What are other ways EPA could present the information in the Manual to its targeted audiences? 

(e.g. workshops, interactive Web site) 

FINAL QUESTION

1. Do you have any final “closing thoughts” or recommendations regarding the overarching 

questions, sub questions or the compliance assistance Manual in general? 

Thank you for participating! 

November 2009 Page 23 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Appendix E. Interview Guide for State Compliance Staff 

A NOTE TO INTERVIEWEES

A Ross & Associates evaluator will ask the questions in this guide during your telephone interview.  The

interview is not intended to be a test of your knowledge of the compliance manual Environmental Laws

Applicable to the Construction and Operation for Ethanol Plans.  Rather, the evaluation is designed to collect

feedback on your thoughts about the Manual’s effectiveness in relaying compliance information to ethanol

facilities.  For the interview, it is not expected that you will have carefully read the entire Manual, but please at

a minimum review those parts of the manual that pertain to your area of work.  The manual can be accessed at:

http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf

If you have any questions, please contact Anna Williams or Amy Wheeless, Ross & Associates by phone at 206‐

447‐1805 or by email at anna.williams@ross‐assoc.com or amy.wheeless@ross‐assoc.com.   

TOPIC AREA I: OUTREACH AND ACCESS TO MANUAL

Overarching Question: How effective are Region 7’s efforts to advertise the availability of and distribute the

Manual to ethanol facilities and other intended audiences?

1. Where did you obtain the Manual? 

2. Does your agency refer ethanol facilities and contractors to the Manual? 

3. How could distribution of or access to the Manual be improved? 

TOPIC AREA II: EFFECTIVENESS OF THE MANUAL

Overarching Question: How effective is the Manual as a tool for transferring compliance (and related facility

technical support) information to ethanol facilities?

1. How readable and comprehendible is the Manual? 

2. How comprehensive is the Manual in its scope? 

3. Is the contact information provided in the Appendices helpful? How could it be improved? 

4. Have you been contacted by an ethanol facility or contractor as a result of the Manual? 

TOPIC AREA III: UNDERSTANDING AND BEHAVIOR CHANGE

Overarching Question: Has the existence and use of the Manual led to increased understanding and behavior

change to support improved compliance?

November 2009 Page 24 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

1. Could compliance with state laws and rules be enhanced using the Manual? How? 

2. In your interactions, do facilities seem aware of the applicable Federal regulations? 

3. Have you noticed any changes in facility compliance with regulations since the Manual was 

released? 

TOPIC AREA IV: IMPROVING THE MANUAL

Overarching Question: How could the Manual be improved to provide effective compliance assistance to ethanol

facilities?

1. What changes would you recommend to the Manual to improve its readability and navigation? 

2. What could be changed about the Manual to make it more thorough and comprehensive and to 

make it more effective as a compliance tool? 

3. Are there topics you would like more or new information about in a future Manual? 

4. What are possible ways that EPA Region 7 could distribute an updated Manual to its audiences, 

or make facilities and other stakeholders aware that an updated Manual is available? 

5. Do you have any other suggestions for improving the Manual? 

TOPIC AREA V: OTHER COMPLIANCE ASSISTANCE

Overarching Question: What approaches other than the Manual would provide effective compliance assistance

to the ethanol facilities?

1. What are other ways EPA could present the information in the Manual to its targeted audiences? 

(e.g. workshops, interactive Web site) 

FINAL QUESTION

1. Do you have any final “closing thoughts” or recommendations regarding the overarching 

questions, sub questions or the compliance assistance Manual in general? 

Thank you for participating! 

November 2009 Page 25 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

Appendix F. Interview Guide for EPA Staff 

A NOTE TO INTERVIEWEES

A Ross & Associates evaluator will ask the questions in this guide during your telephone interview.  The

interview is not intended to be a test of your knowledge of the compliance manual Environmental Laws

Applicable to the Construction and Operation for Ethanol Plans.  Rather, the evaluation is designed to collect

feedback on your thoughts about the Manual’s effectiveness in relaying compliance information to ethanol

facilities.  For the interview, it is not expected that you will have carefully read the entire Manual, but please at

a minimum review those parts of the manual that pertain to your area of work.  The manual can be accessed at:

http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf

If you have any questions, please contact Anna Williams or Amy Wheeless, Ross & Associates by phone at 206‐

447‐1805 or by email at anna.williams@ross‐assoc.com or amy.wheeless@ross‐assoc.com.   

TOPIC AREA I: OUTREACH AND ACCESS TO MANUAL

Overarching Question: How effective are Region 7’s efforts to advertise the availability of and distribute the

Manual to ethanol facilities and other intended audiences?

1. Does your agency refer ethanol facilities and contractors to the Manual? 

2. How could distribution of or access to the Manual be improved? 

TOPIC AREA II: EFFECTIVENESS OF THE MANUAL

Overarching Question: How effective is the Manual as a tool for transferring compliance (and related facility

technical support) information to ethanol facilities?

1. How readable and comprehendible is the Manual? 

2. How comprehensive is the Manual in its scope? 

3. Is the contact information provided in the Appendices helpful? How could it be improved? 

4. Have you been contacted by an ethanol facility or contractor as a result of the Manual? 

TOPIC AREA III: UNDERSTANDING AND BEHAVIOR CHANGE

Overarching Question: Has the existence and use of the Manual led to increased understanding and behavior

change to support improved compliance?

1. In your interactions, do facilities seem aware of the applicable Federal regulations? 

November 2009 Page 26 
Evaluation of the Effectiveness of an Ethanol Compliance Manual Report Appendices 

November 2009 Page 27 

2. Have you noticed any changes in facility compliance with regulations since the Manual was 

released? 

TOPIC AREA IV: IMPROVING THE MANUAL

Overarching Question: How could the Manual be improved to provide effective compliance assistance to ethanol

facilities?

1. What changes would you recommend to the Manual to improve its readability and navigation? 

2. What could be changed about the Manual to make it more thorough and comprehensive and to 

make it more effective as a compliance tool? 

3. What are possible ways that EPA Region 7 could distribute an updated Manual to its audiences, 

or make facilities and other stakeholders aware that an updated Manual is available? 

4. Do you have any other suggestions for improving the Manual? 

TOPIC AREA V: OTHER COMPLIANCE ASSISTANCE

Overarching Question: What approaches other than the Manual would provide effective compliance assistance

to the ethanol facilities?

1. What are other ways EPA could present the information in the Manual to its targeted audiences? 

(e.g. workshops, interactive Web site) 

FINAL QUESTION

1. Do you have any final “closing thoughts” or recommendations regarding the overarching 

questions, sub questions or the compliance assistance Manual in general? 

Thank you for participating!