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Member Responsibilities

ESP Members must maintain a standard of environmental compliance; an environmental management system (EMS); and continue implementing environmental improvement projects. IDEM requires that members submit an annual performance report (APR) by April 1. The APR report form and the instructions are available on the IDEM Forms page.

The APR report must include the following:

  • A summary of the facility's EMS assessment activities and the progress towards meeting EMS objectives and targets, including brief descriptions of any audits that have been conducted and improvements made.
  • A brief report on the progress made in meeting the facility's environmental performance goals.
  • A summary of the facility's public outreach activities.
  • A self-certification that the facility continues to meet the Environmental Stewardship Program criteria for membership.

Once an APR has been submitted to the agency, IDEM staff will review the report and contact the member facility if any problems are identified or if additional information is required. It takes IDEM approximately 30-60 days to review and accept the ESP Annual Performance Reports.

Members should not include any confidential business information in the APR, as IDEM makes current and historical APRs available to the public online.

Normalizing Data

Each member facility must “normalize” the environmental improvement initiative results data reported in Section E on the APR form. Normalizing data is a process of structuring data so as to reduce or eliminate data redundancy and properly attribute impact values to derivations.. Normalization is important because it recognizes that facilities can become more environmentally efficient, even if total production increases. Conversely, if production declines, normalization separates out the effects of declining production from any gains in environmental efficiency.

Some of the common factors that may affect the process quantities (including costs and savings) are:

  • Total hours the process operated
  • Number of batches processed
  • Input material changes
  • Total employee hours
  • Area, weight, or volume of product produced
  • Area, weight, or volume of raw material purchased
  • Profit from product

Normalization factors will be different depending on the type of process being evaluated. For instance, continuous processes can often use the product output or raw material input as factors for standardization. Some flow processes may be best measured by volume or weight, whereas others may be better normalized by area. In batch processes, production volume is usually relative to waste production, but it may not always be a linear relationship if production processes are not consistent for each product produced.

Comparing quantities is further complicated by inverse relationships that may occur between production amounts and waste generation (waste is generated at a higher rate than production volumes). Contrary correlations can occur due to things like the startup and shutdown of equipment or when purchased materials expire before they can be used in a process.

When normalizing data, it is important to determine what factors are affecting values and identify reliable indicators for accurate measurement. Facilities should choose a basis of normalization that directly demonstrates changes in the activity level or output of the facility. The basis of normalization should describe both WHAT is being produced and HOW production is measured. The basis of normalization should not change from year to year for individual processes, and in most cases the same basis of normalization should be used for all ESP goals if possible. It is best to choose a basis of normalization that is measured in physical quantities using production quantities (e.g., pounds) as opposed to dollar values. For example, for an electroplating facility, an appropriate basis of normalization could be "tons of material electroplated." For a car manufacturer, an appropriate basis of normalization could be "number of cars produced." Measuring Pollution Prevention Reductions [PDF] defines the different types and units of production, and how to calculate environmental improvement savings using normalized data.

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