ERP States 

Produce 

Results

WWW.EPA.GOV/INNOVATION

Executive Summary

2007 Report

States’ Experience 

Implementing the 

Environmental 

Results Program

EPA 100-R-07-007

May 2007
The Environmental Results Program (ERP) is an innovative approach to improving the environmental performance 

of various business sectors and other groups with large numbers of small facilities. While individual facilities 

within these groups may release small amounts of pollution, their aggregate impact can be significant. The 

Massachusetts Department of Environmental Protection developed ERP 10 years ago for the dry cleaner, photo 

processor and printer sectors. Now, 18 states have developed 

or are implementing at least one ERP to address challenging 

environmental issues in 11 sectors/groups. (See box, right.) 

To date, six of those states have completed a full ERP cycle and 

generated results demonstrating the success of this approach.

As Figure 1 (below) illustrates, ERP is an integrated system of:

Plain-language compliance assistance that promotes pollution 

prevention (P2); 

Facility self-assessment and self-certification;

Agency inspections; and

Statistically based performance measurement.

Where necessary, regulators also conduct a comprehensive facility 

inventory and targeted enforcement actions. These elements work 

together to improve performance across a business sector or other 

group of pollution sources, while deploying government resources 

strategically and efficiently. 

The U.S. Environmental Protection Agency (EPA) has actively supported the diffusion of ERP across states 

since EPA’s Innovation Action Council (IAC) endorsed the approach for “scale up” in 2000. In making its 

decision, the IAC considered at least three factors: documented evidence of performance improvements in 

Massachusetts’ first years of ERP; a favorable evaluation of the 

initiative by the National Academy of Public Administration 

(NAPA); and the significance of the environmental threat that 

can be posed by large groups of small pollution sources. ERP 

shows high potential for cost-effectively achieving results with 

these small entities, which historically are under- or unregulated. 

For instance, six states to date have developed or are planning 

ERPs for auto body shops, which number more than 30,000 

nationwide and are associated with serious environmental and 

health impacts. Since the IAC endorsement, EPA has supported 

its state partners with technical assistance and grant funds. In 

addition, Massachusetts has received “resource flexibility credit” 

through EPA’s enforcement program accountability system for the 

demonstrated success of the state’s ERP for dry cleaners, allowing 

Massachusetts to focus more resources on emerging priorities for 

environmental improvement.

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Executive Summary

Figure 1. ERP: Interlocking Tools, 

Integrated System

E-1

ERP States , by Sector/Group

Animal Feedlots (Small) MN

Auto Salvage Yards IN, RI

Auto Body Shops DE, MD*, ME, NY, 

RI, WA

Auto Repair Shops FL*, MD*

Dry Cleaners MA, MI, NH, NV

Gas Stations RI, VA, VT

Oil & Gas Extraction 

Facilities 

LA

Photo Processors MA

Printers MA, NY, WI

Stormwater 

Dischargers 

ME, RI

Underground Injection 

Wells 

IL

*No longer implementing ERP. Note that MD had one ERP 

that covered both auto body and auto repair.
ERP States Produce Results

ERP has improved the environmental performance 

of businesses in each state that has applied it, and its 

measurement system has given regulators credible 

evidence of those performance enhancements. Each 

of the six states that has completed an ERP cycle 

has seen initial average improvements of 5 to 30 

percentage points for its top-priority indicators of 

performance. (See table on next page, E-3.) What 

follows below are highlights of results from these 

states.

Environmental Business Practice Indicators (EBPIs). 

ERP’s key measures are called Environmental 

Business Practice Indicators (EBPIs), because they 

typically demonstrate facility performance in terms 

of both compliance and voluntary best management 

practices. For instance, in Delaware, the proportion 

of auto body shops complying with disposal 

requirements for hazardous waste increased from 

66% to 91% in one year. In a similar time frame, 

the voluntary use of “green” solvents among Maine 

auto body shops increased from 49% to 97%. These 

examples of EBPI improvements, and slightly more 

than one third of all observed EBPI improvements, 

are statistically significant at a 95% confidence level. 

No observed decreases in EBPI performance are 

statistically significant at that level. 

The Role of Statistics. What is so “significant” 

about statistical significance? Regulators often base 

decisions upon data from only a sample of facilities, 

and usually are not sure how well the data from that 

sample represent the whole group. Using statistics, 

regulators can understand how certain they can 

be about data taken from a random, representative 

sample of facilities. For significant performance 

improvements like those discussed above, a 95% 

confidence level means we know there’s at most a 

Figure 2. A Typical ERP Cycle

Step 1: Inventory. Identify the myriad small facilities that are 

sources of pollution, many of which are often unknown to 

regulators.

Step 2: Statistical Baseline Inspections. Conduct random 

inspections to accurately measure existing environmental 

performance and focus outreach on the biggest problems.

Step 3: Compliance Assistance. Work with trade 

associations to create and provide plain-language, userfriendly assistance that improves compliance and promotes 

pollution prevention.

Step 4: Self-Certification. Facilities conduct selfassessments using a detailed checklist closely linked to 

assistance materials. Responsible officials certify to their 

facilities’ environmental performance on each item. If 

necessary, they submit plans to return to compliance.

Step 5: Targeted Follow-Up. Identify potential problem 

facilities via certification analysis, and target them for 

inspections, correspondence or phone calls. Provide 

assistance and/or initiate enforcement, as needed.

Step 6: Statistical Post-Certification Inspections. Conduct 

random inspections to accurately estimate performance 

changes and verify facility certifications.

Step 7: Informed Decision-Making. Assess performance data 

and consider whether to adjust compliance assistance or 

other strategies directed at the sector or, if sufficient progress 

has been made over time, target resources elsewhere.

How Does an Integrated ERP Work?

An ERP combines several interlocking tools in a cyclical 

process to improve overall sector performance. (See Figure 

2, below.) Compliance assistance specifies how facilities 

should assess their operations and certify compliance, 

while agency inspectors document progress against 

performance indicators that are linked to self-certification 

checklists. Performance data, in turn, inform and improve 

the next round of compliance assistance. No two ERPs are 

exactly alike, however, because states have adapted this 

approach for a wide variety of circumstances. For instance, 

many states have successfully implemented ERPs with 

voluntary submission of self-certifications, when mandatory 

certification was not feasible.

Purpose of This Report

This report updates the story of ERP, 

the implementation of which has grown 

substantially in recent years. The report 

identifies the states using ERP and the 

environmental problems they are seeking to 

address, describes the results and benefits state 

ERPs are generating, and discusses some of the 

new directions being explored within the ERP 

community. 

E-2Renew Assistance and Certification (As Deemed Necessary)
5% chance that we would be mistaken in 

saying that there was a change in performance 

for the group as a whole. Other observed 

changes may indeed point to genuine 

changes in the whole group, but we cannot 

be as certain that they occurred—oftentimes 

because states are basing their inferences upon 

small samples of the population, allowing 

only large observed changes to be deemed 

“significant.” 

Across-the-Board Performance Improvements.

Changes that are not significant can also 

be instructive. Data from ERPs have 

consistently shown a net performance gain 

across all EBPIs. Most indicators have 

risen while some have declined—but the 

overall number and size of the increases has 

substantially exceeded the number and size 

of declines. Furthermore, even where there 

are decreases, ERP provides the information 

regulators need to target their compliance assistance and enforcement efforts on that small proportion of 

lagging indicators. 

Sector Snapshots. Aside from examining 

how facilities fare on individual EBPIs, ERP 

states have also developed higher-level 

measures that concisely communicate sector 

performance. For instance, Florida inspectors 

found that the proportion of “straight-A” auto 

repair facilities—those with no violations of 

any kind—had risen 17 percentage points after 

two rounds of self-certification. Furthermore, 

Massachusetts has developed a “group 

compliance score,” a measure showing 

the extent to which a sector’s facilities are 

achieving compliance-oriented EBPIs. In 

Massachusetts, each sector’s score has risen 

from ERP’s inception through the most recent 

inspection results, with photo processors 

showing a dramatic increase from 57% 

in 1997 to 98% just five years later. (See 

Figure 3, right.) Results from the other two 

sectors suggest that ERP may not always show 

substantial improvements right away when 

performance is already at a relatively high 

level. The dry cleaners case further shows 

the potential for improvement over time, after 

which a very high performance level can be 

sustained. 

Executive Summary

Observed Average Indicator Improvement 

in First ERP Self-Certification Cycle

Sector State Avg. Improvement*

(Percentage Points)

Auto Body

DE 30

ME 10

RI 21

Auto Body/Repair MD 12

Auto Repair FL 7

Dry Cleaners MA 5

Photo Processors MA 12

Printers MA 13

*Average of performances changes for each ERP’s indicators among randomly sampled 

facilities, as observed by inspectors in the first ERP cycle. Includes all observed 

changes, regardless of significance level. Sector performance typically continues to 

improve in subsequent ERP cycles, then is sustained at high levels. For ERPs with voluntary certification (DE, MD, ME and RI), random samples were drawn from all facilities 

in the ERP inventory, not just volunteers. See full report for more detail.

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Figure 3. Long-Term Compliance 

Improvements in Massachusetts ERP Sectors

Notes: (1) “Group compliance score” is a measure of the extent to which 

facilities are achieving compliance-related EBPIs, as observed by inspectors 

during random visits to facilities. A score of 80%, for instance, would mean 

that, on average, each facility is achieving 80% of the indicators that apply to 

it. The group compliance score is distinct from traditional compliance rates, in 

that it tracks performance only on priority compliance practices and reflects 

varying degrees of compliance at individual facilities. (2) Improvements over 

time have not been evaluated for statistical significance. (3) Graph reflects 

most recent available data. Massachusetts has decreased inspection 

frequency over time for these sectors because of their trends toward sustaining 

high performance levels. The next round of random inspections is anticipated 

later in 2007, for the dry cleaner sector.
Why Are States Adopting ERP?

Aside from the across-the-board evidence of overall performance improvements, state regulators cite several 

other reasons for adopting ERP.

Most importantly, available evidence suggests that ERP achieves performance at least as good as that of 

traditional compliance assurance approaches, at substantially less cost over time.

State regulators find that rich ERP data sets can help them target resources more efficiently.

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Estimates of Environmental Outcomes. Massachusetts has experimented with developing measures that 

can demonstrate environmental outcomes that result from performance changes. The state has found that 

estimating environmental outcomes can provide valuable insights into program success. For instance, 

Massachusetts has calculated that its dry cleaners reduced annual emissions and waste of the toxic chemical 

perchloroethylene by approximately 30% in the first two years of ERP.

Baltimore Residents 

Appreciate ERP

Maryland’s ERP focused on 

informal vehicle repair facilities 

in an environmental-justice 

neighborhood in Baltimore. A 

post-ERP survey showed that 

nearby residents recognized and 

appreciated the project’s visible 

environmental improvements.

Why Do These Performance 

Improvements Happen? 

States believe that ERP’s mix of compliance 

assistance, self-certification and agency 

verification drives facilities to hold 

themselves more accountable and gives 

them the capability and incentive to improve 

performance. For instance, regulators 

are often surprised by the number of 

facilities that voluntarily report one or more 

non-compliance items on their first selfcertification form and submit plans to return 

to compliance. (See box, right.) In fact, the 

submission rate of return-to-compliance 

plans has become yet another important and 

credible measure of ERP success for many 

states.

“I’m Doing It Wrong over Here!!”

In Rhode Island, 20% of all auto body shops reported 

themselves out of compliance with at least one 

requirement, and submitted plans to return to 

compliance within a reasonable time frame. Typically, 

self-reported noncompliance decreases 

in later years of ERP, 

consistent with inspector 

findings of higher sustained 

sector performance. Over 

time, this combination of 

accountability and sustained 

performance can decrease 

the need for enforcement.

Improved facility accountability may reduce the long-term need for 

resource-intensive enforcement actions.

Statistical approaches and technology both offer substantial 

economies of scale when ERP is applied to large universes of 

facilities.

Agencies report that ERP helps them meet stakeholder demands to 

measure how well regulators’ actions achieve goals of increasing 

compliance and achieving environmental improvements.

Many businesses support ERP because it explains their obligations 

in clear terms and because it “levels the playing field” among 

facilities in a sector.

The often visible improvements and increased transparency of ERP 

provide value to the public. (See box, left.)

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Executive Summary

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ERP’s Future: Further Improvement, Experimentation and Growth Expected

In the coming years, states will report first-time results for several new ERP sectors, including underground storage 

tanks, auto salvage yards and small animal feedlots. An EPA-funded, state-led initiative to develop common ERP-type 

performance indicators for auto body shops and small quantity generators of hazardous waste is also well underway. Each 

state participating in this “Common Measures Project” will track indicators for at least one of these regulated groups using 

ERP statistical approaches. The project should allow greater comparability of environmental performance levels across 

participating states—whether or not those states are implementing an ERP for those groups. This information will help states 

choose the most effective and efficient compliance assurance strategies to meet their needs.

Further, states continue to adapt ERP to address a greater array of environmental issues. For instance, ERP states are pursuing 

new applications based on the geographic boundaries of environmental problems—such as watershed-based targeting to 

reduce polluted stormwater runoff. When appropriate, states also are implementing other promising variations on ERP, such 

as applying individual ERP tools to address problems when a full ERP may not be feasible. Massachusetts calculates that 

one application of such “ERP-like” approaches has prevented the yearly wastewater discharge of several hundred pounds of 

mercury from dentists’ offices. Another such initiative by the state has substantially improved emissions-testing compliance at 

Massachusetts gas stations, assuring the capture of thousands of tons of ozone-forming compounds annually. 

Finally, awareness of and support for ERP is expected to grow as a result of states forming the new States ERP Consortium. 

The Consortium, organized this year as a “forum” of the Environmental Council of the States (ECOS), currently represents 

more than a third of all states. (See Figure 4, below.) The Consortium includes states currently using ERP and states learning 

how to use ERP to address priority environmental problems. EPA’s National Center for Environmental Innovation (NCEI) 

is on the Consortium’s steering committee and is providing contractor support. The Consortium has four key goals: (1) 

communicating results in order to build stakeholder support; (2) sharing information among practitioners; (3) promoting ERP 

as a proven compliance strategy and expanding support within EPA; and (4) improving and disseminating tools to further 

streamline key aspects of ERP, such as automation and measurement. EPA is committed to working with the Consortium in 

the future to continue evaluating the many applications of ERP, and to communicate the results of these efforts.

AK HI

WA

OR

CA

NV

TX

NM

AZ

CO

ID

MT

WY

UT

OK

KS

NE

ND

SD

MN

AR

LA

MS AL

IA

MO

WI

IL IN

KY

TN

GA

FL*

SC

NC

MI

OH

PA

WV VA

NY

ME

VT

NH

CT

NJ

DE

MA

MD*

RI

ERP Implementers

Learning States

Consortium Members

*Not currently implementing ERP.

For a copy of the full report (available Summer 2007) and more information on ERP, visit www.epa.gov/erp.

Figure 4. Growing ERP Community Represented by a New Consortium of States