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RE: SEPs



Of relevance is EPA's just-issued interim guidance on community involvement in SEPs, at www.epa.gov/compliance/resources/policies/civil/seps/index.html

This is also at Federal Register, Vol 68, No. 116, Tuesday, June 17, 2003, p 35884.  On page 35887 note that it says "Regions can consider setting up a SEP library to solicit community project ideas outside of the context of a particular enforcement action so that community project ideas are available to draw from in appropriate cases."  

There are two kinds of SEP lists: ideas, often referred to as SEP Idea Bank, usually available internally only, and performed SEPs.  SEP Idea Banks are probably going to be called "SEP Libraries" from now on, as seen in the new Community Involvement guidance.

Massachusetts DEP has just put an alphabetical list of over 80 performed SEPs up on the web.  Other states may have done that.  Household hazardous waste days is a popular community SEP.
 http://www.state.ma.us/dep/enf/enfpubs.htm

If you are starting an SEP Idea Bank (SEP Library), please consider funding for lead paint hazard abatement in low income schools, day care centers, housing.  There are lists of these places waiting for the funding to get done while children continue to be exposed.  A special issue is that because lead paint abatement may be ordered, it's not a SEP when it's done in a building that the violator owns, but it can be a SEP when the violator doesn't own the building.  Make sure there's "nexus" (connection) between the violation and the project - in lead paint may be defined in terms of locality. Another important issue is you must have enforceability - there has to be a contract and assurance the work will be performed, you can't usually just get SEP credit for donations.  Nor can you usually get it for public education that is just indirect in terms of benefits.  You want to couple the provision of information with direct benefit.  You also have to ensure the enforcers don't direct the expenditures or administer the funds, or that their own funding is not "augmented" by the SEP.  But these strictures are not as prohibitive as they may sound. 





-----Original Message-----
From: PRooney@ci.lincoln.ne.us [mailto:PRooney@ci.lincoln.ne.us]
Sent: Thursday, June 19, 2003 12:34 PM
To: p2tech@great-lakes.net
Subject: SEPs


The Lincoln-Lancaster County Health Department is looking for ideas for
creative, community-based Supplemental Environmental Projects. We wish to
create a list of a couple of dozen ideas, grouped by media and regulation,
to give to businesses. This list is not intended to be restrictive nor
all-inclusive but can serve as a starting point for discussion or
brainstorming when a business faces a penalty. It might also serve as a
type of guidance document.

If anyone out there has any success stories of SEPs that have been unique,
benefitted the community at large, and met the EPA criteria for an
acceptable SEP, I'd love to hear about them.

Thanks,

Phil Rooney
Lincoln-Lancaster County Health Department
3140 N Street
Lincoln, NE 68510

(402) 441-8644



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