For those of us who live and work in states that have Risk Management Plan enforcement delegation (like Ohio), Risk Management Plan “fees” are nothing new. But now, Federal EPA is considering charging a “Fee” for those facilities that submit an RMP AND are under federal EPA RMP enforcement. There is no mention if this will be a “double fee” for those states already charging or if this new fee will only apply to those states under Federal RMP enforcement. In their FY 2019 document “EPA Budget in Brief”, EPA states the following regarding fees related to facilities under the RMP and SPCC rules:
NOTE: this information is FREE from EPA and can found in their FY 2019 budget proposal. The content below, the notations, highlights, and explanations, are for SAFTENG members.
Establishing New Fees
EPA is proposing several new fees in FY 2019 to better align appropriated resources to the Agency’s core mission, provide dedicated funding sources for specific activities and to better align program costs with beneficiaries. To increase compliance in industry, EPA proposes establishing two new voluntary user fees. These fees will enable EPA to provide compliance assistance services to both Risk Management Plan facilities, and Facility Response Plan and Spill Prevention Control and Countermeasure facilities. EPA also is proposing to establish Energy Star as a fee-funded program in FY 2019 to ensure the important work of the program continues. In addition, EPA will continue to work with OMB and other Agencies to review potential areas where fee-funding may be an appropriate mechanism to reduce the burden on taxpayers. Source: page 6 of https://www.epa.gov/sites/production/files/2018-02/documents/fy-2019-epa-bib.pdf
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Chemical Facility Safety
The FY 2019, EPA requests $10.0 million for the State and Local Prevention and Preparedness program. EPA plays a valuable role in working with states and communities to build the capacity to prevent, prepare for, and respond to emergencies at chemical facilities. The program establishes a structure composed of federal, state, local, and tribal partners who work together with industry to protect emergency responders, local communities, and property from chemical risks through advanced technologies, community, and facility engagement, and improved safety systems. In FY 2019, the program will inspect Risk Management Plan facilities to ensure compliance with accident prevention and preparedness activities.
State and Local Prevention and Preparedness Fee Proposal
The budget includes a new fee proposal in the State and Local Prevention and Preparedness program to better support compliance assistance work for RMP facilities. The new voluntary fee and service will provide support for facilities in complying with EPA regulations via an on-site walk-through and assistance. Authorizing language for the new fee collection accompanies the budget submission. Source: pages 23-24 https://www.epa.gov/sites/production/files/2018-02/documents/fy-2019-epa-bib.pdf