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Extraordinary Environmental Enterprise (E4)


What is an Extraordinary Environmental Enterprise?

Under the Virginia Environmental Excellence Program, an “Extraordinary Environmental Enterprise” or E4 is a facility with a fully implemented environmental management system (EMS) that has been verified by a third party. Additionally, the facility must document that it has committed to measures for continuous and sustainable environmental progress and community involvement. A strong environmental compliance record is expected of all VEEP participants. Typically, the drivers for superior environmental performance are not regulatory, but rather the demands of customers, shareholders and public opinion. Thus, there is an expectation that E4 facilities have a history of not only superior environmental performance, but also one of environmental leadership. 

The primary driver for E4 membership is the desire to be a leader in protecting and conserving Virginia's natural resources. Members are expected to display an attitude focused on protecting and preserving the environment and conduct themselves in an exemplary manner with regards to environmental leadership. E4 members are expected to:

  • Promote environmentally responsible practices, awareness and improvement to their neighbors, employees, customers, the business community, and the public;
  • Partner with DEQ in promoting regulations as minimum requirements and not goals or measures of success;
  • Openly communicate with DEQ and the public on non-proprietary results and processes; and,
  • Set and achieve goals with discernible improvements to air and water quality and increases in land conservation and restoration.     

What are the benefits of being an Extraordinary Environmental Enterprise?

Facilities achieving E4 status are eligible for all of the benefits of the E3 level, including recognition and technical assistance. In addition, as a result of legislation adopted by the 2005 General Assembly, on a case-by-case basis, E4 facilities may be eligible for "alternative compliance methods." Large E4 flags are available for purchase from a private vendor. Please contact Meghann Quinn for more information. 

What must a facility provide to DEQ to achieve Extraordinary Environmental Enterprise status?

Participation in VEEP is on a facility by facility basis. The E4 level of the program was established by legislation adopted by the 2005 General Assembly that requires a facility, in order to participate as an E4 member, to: (1) have implemented and completed at least one full cycle of an EMS as verified by an independent third party; (2) have a record of sustained compliance with environmental requirements; and (3) have committed to measures for continuous and sustainable environmental progress and community involvement. 

  • Environmental Management System Implementation: The development and implementation of effective EMS is the primary goal of VEEP. DEQ does not prescribe the model or type of EMS or the structure of a facility’s environmental programs. However, DEQ is responsible for verifying that each facility accepted into VEEP meets the program criteria. Therefore, each E4 applicant is required to address key points related to its EMS:
    • The facility’s policy statement outlining its commitment to improving environmental quality, stressing compliance with environmental requirements, pollution prevention (P2), training, communication and continuous improvement.
    • An evaluation of the actual or potential environmental impacts and aspects from current or future activities at the facility, including a comprehensive list of impacts and aspects, an explanation of the process used by the facility to determine its significant impacts and aspects, and the facility’s schedule for reviewing and reevaluating its impacts.
    • Objectives and targets for addressing significant environmental impacts, including the facility’s projects or tasks that are planned to address each of the objectives with an implementation schedule.
    • Description of the facility's pollution prevention program, including a comprehensive list of P2 projects and accomplishments, not limited to those which address its significant impacts and aspects, and any environmental results and costs savings achieved from past projects if available.
    • Identification of the facility's environmental legal requirements and a mechanism for tracking changes in environmental compliance requirements, including a system for learning about legal requirements and changes in regulations.
    • Description of how the facility defines, documents, and maintains the roles, responsibilities and authorities for its EMS, including assignments for projects, tasks or reporting responsibilities and upper management involvement or review.
    • Procedures for reporting and record keeping to document the status of EMS operations and activities, including a system for tracking EMS changes.
    • Procedures for ensuring that all employees have the necessary training, including a systematic approach ensuring all employees have role in the EMS.
    • Emergency response procedures for responding to, reporting, mitigating and reviewing incidents, including emergency management program coordinated with local emergency response efforts.
    • Monitoring, investigative, and corrective actions for noncompliance with EMS.
    • Voluntary self assessments (external or internal auditing system), which may include regular self-assessments, corrective action plans or third party audits.
    • Procedures to communicate with and inform external and internal audiences.
    • Unrelated Third Party Audit of the EMS: E4 facilities are required to submit documentation showing that they have completed at least one full cycle of an EMS which has been verified to be effective and meet or exceed Extraordinary Environmental Enterprise (E4) specified requirements by an unrelated third party. DEQ defines the term "unrelated third party" in the context of VEEP to mean that the EMS assessment team members are neither directly employed by the applying facility nor have they played a substantive role in developing the facility's EMS. In addition, DEQ requires that third party auditors be qualified for their role in assessing the EMS by meeting the requirements below:  

Qualifications for Lead Auditor:

Training: 32 to 40-hour RABQSA or Exemplar Global Accredited ISO 14001:2004 or 2015 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor Courses (must receive passing grade on course examination)

Work Experience: Five years of work experience in environmental management, environmental science and technology, environmental regulation or related field.  The lead auditor cannot be directly employed by the facility and cannot have played a substantive role in developing the EMS for the facility.

Qualifications for Audit Team Members:

Training: 32 to 40-hour RABQSA or Exemplar Global Accredited ISO 14001:2004 or 2015 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor courses (must receive passing grade on course examination)

Work Experience: Three years of work experience in environmental management, environmental science and technology, environmental regulation or a related field.

For additional information on Third Party Audits, see the guidance developed for VEEP mentors conducting third party audits.

  • Record of Sustained Compliance: Facilities applying to any level of VEEP must have a record of sustained compliance. As defined by Section 10.1-1187.1 of the Code of Virginia, record of sustained compliance means that "the person or facility (i) has no judgment or conviction entered against it, or against any key personnel of the person or facility or any person with an ownership interest in the facility for a criminal violation of the environmental protection laws of the United States, the Commonwealth, or any state in the previous five years; (ii) has been neither the cause of, nor liable for, more than two significant environmental violations in the previous three years; (iii) has no unresolved notices of violations or potential violations of environmental requirements with Department or one of the Boards; (iv) is in compliance with the terms of any order or decree, executive compliance agreement, or related enforcement measure issued by the Department, one of the Boards, or EPA; and (v) has not demonstrated in any other way an unwillingness or inability to comply with environmental protection requirements." DEQ will conduct a review of each applying facility’s compliance record, including a review of EPA records as appropriate.

  • Commitment to Continuous and Sustainable Environmental Progress and Community Involvement: E4 facilities are required to document that they have committed to continuous and sustainable environmental progress and community involvement. Each facility’s situation in terms of purpose, location and impacts may prove unique from other facilities. Therefore, meeting this requirement will vary from facility to facility.

During DEQ's site visit to review the facility EMS, the following areas related to sustainable environmental progress will be reviewed and documented:

    • Does the facility acknowledge and support the concept of environmental sustainability?
    • Does the facility actively go beyond its fence line to assist the community and peers with efforts to improve environmental quality?
    • Does the facility participate in programs that recognize environmental efforts?

Also during the E4 site visit. DEQ will document specific examples of community involvement, if applicable. Typical categories include:

    • Inform the public about their EMS and environmental goals.
    • Participate in Adopt-a-Stream, Adopt-a-Highway, or similar program
    • Participate in or support an environmental conference
    • Mentor local businesses on EMS
    • Assist peers with environmental issues
    • Host or support an event that raises environmental awareness (example: Earth Day)
    • Partner with a local group for a river or park cleanup
    • Participate in and promote environmental awareness at town or business meetings
    • Participate in regional environmental groups

        Examples from current E4 facilities include:

    • Outreach related to wildlife and renewable energy use
    • Community open house showcasing environmental efforts
    • Earth Day events
    • Site cleanup days
    • Sustainability Team
    • Collect cans for Habitat for Humanity
    • Support Forever Forest Project, which plants trees all over the world
    • Tours for local schools
    • Host sustainability conference
    • Participate on local committee boards
    • Involvement in various environmental education efforts such as Bayscapes, National Public Lands Day, etc.
    • Apply for Governor's Environmental Excellence Awards

For more information, contact Meghann Quinn.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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