Diane Saxe a very bright environmental lawayer -- I use the phrase deliberately because there are many many dumb ones!-- expressed it best: 1. use enforcement vigorously for the 15% environmental criminals 2. use incentives & recognition for the leaders and early adapters 3. use spot inspections and voluntary in-between to provide both deterrent from slippage and incentive to do better for the middle of the pack. Too often government inspectors go after the good performers who have minor slips, because those beans are easy to count, and don't chase the ones who are hard to find. Enforcement alone cannot do the job; voluntary alone is for the very few. We need both and we need to get our act together so that both sides of the equation are mutually supportive, not competing for the glory. Fred Granek -----Original Message----- From: Karen Shapiro Sent: Tue 12/17/2002 4:27 PM To: P2Tech@great-lakes.net; NPPR@great-lakes.net Cc: Subject: RE: Industry environmental initiative waning? Like many of the prior responders, I too believe that integrated approaches work best. Voluntary programs (VPs), by themselves, are not apt to lead to significant aggregate environmental gains. Thus, in my view, the best "carrot" is backed by a "stick." The size and variety of the stick can be tailored to industry/business sectors along with many other factors (e.g., is the facility a good or poor environmental actor). Another reason why voluntary programs are not always effective is that their success hinges on the participation of many facilities/companies -- it is unlikely that a small number of participating facilities will yield significant aggregate environmental improvements. To date, there have been many voluntary programs at the federal and state level. However, participation in many of these programs has been disappointing. Why don't more firms participate in VPs? A few years ago Tellus conducted a study for the Michigan Great Lakes Protection Fund entitled, "Do Voluntary Mechanisms Work? An Evaluation of Current and Future Program Performance." This study examined why firms participate in voluntary programs and what is needed to sustain their participation. In a focus group comprised of industry representatives, several people noted that the uncertainty of VPs versus the certainty of regulations is one driver for not participating. Because participation in a VP incurs costs (including time), firms want to know that the VP is not ephemeral. By comparison, focus group participants noted that regulations have greater staying power and therefore warrant greater resources. Lastly, the efficacy of VPs is typically difficult to measure and many of these programs are designed without giving prior consideration to performance measures needed for gauging success. Even the success of the 33/50 program (referred to by another responder) has been debated -- while chemical releases during the program's lifetime decreased, it is difficult to know to what extent reductions should be attributed to the program versus to pending regulations, or to what extent these reductions were in fact due to P2 activities. (For a further discussion of the efficacy of VPs see http://www.tellus.org/b&s/publications/r8-031.pdf) Thank you Todd for initiating this dialogue! Karen Shapiro Senior Scientist Tellus Institute 11 Arlington Street Boston, MA 02116-3411 phone: 617-266-5400 fax: 617-266-8303 email: kshapiro@tellus.org web: http://www.tellus.org -----Original Message----- From: Rudy Moehrbach [mailto:Rudy_Moehrbach@p2pays.org] Sent: Tuesday, December 17, 2002 1:31 PM To: 'Terry Foecke'; Katz.John@epamail.epa.gov; Minicucci, Bob Cc: NPPR@great-lakes.net; P2Tech@great-lakes.net Subject: RE: Industry environmental initiative waning? As a P2Tech member I would like to state this has been a very interesting thread. I disagree with Jim Walsh that we should not reply to all. Deleting some messages that may not interest you at this time is not that big a deal, Mr. Walsh. Many of us are being served well by this discussion. Terry Foecke, if memory serves my right, the last time I saw Bill Bilkovich was at a plating shop in Virginia and you were there also. Rudy Moehrbach Staff Engineer Waste Reduction Resource Center Phone 800-476-8686 Web http://wrrc.p2pays.org Check out DPPEA marketplace for waste material: www.ncwastetrader.org * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * p2tech is hosted by the Great Lakes Information Network: http://www.great-lakes.net To unsubscribe from this list: send mail to majordomo@great-lakes.net with the command 'unsubscribe p2tech' in the body of your message. No quotes or subject line are required. About : http://www.great-lakes.net/lists/p2tech/p2tech.info * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
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