I haven’t read Kathryn Harrison’s
article, but I did do a number of 33/50 data analyses in my previous life
working for an EPA contractor. EPA’s
published analyses of 33/50 data were limited, mostly comparing “participants”
to “non-participants,” and on that basis concluded that the program
was successful. I did a rather large telephone survey of TRI
reductions, both 33/50 and non-33/50 chemicals.
There were quite a few other things going on:
1) Much of the reduction was in 1,1,1-trichloroethane, which was part
of the Montreal Protocol (also true for carbon tetrachloride).
2) Companies agreed to participate in 1991 or 1992 after they already
knew what their 1989 TRI numbers would be; so it wasn’t a stretch for some
of them to make commitments to things they’d already achieved compared to
1988, and EPA wouldn’t have the information on actual data for many
months. (I actually had a couple of facilities tell me this in so many words).
3) The benzene NESHAPS were a huge factor in reducing emissions.
4) A large reduction also came because of changes in printer
technology – no more printer ribbons meant a lot less solvent got used
and released.
5) Although the program was for decreases in releases plus transfers
to disposal, there was less P2 going on than people would like to believe. Since there is no definition for reporting
on-site recycling in Section 8, facilities could report practically anything,
or nothing, with impunity. Virtually
every facility I called that had a decrease in releases with no increase in
on-site recycling was actually recycling the released material, not using less
of the chemical. Not that the decrease
in releases didn’t happen, just that the program doesn’t appear to
have fostered P2 any more than for non-program chemicals.
6) Some of the decreases in transfers to disposal were erased when
market prices for metals went down, specifically cadmium.
I don’t mean to imply that there
weren’t good things about the program.
It was a good start, but it hardly counts as an unqualified success for
a voluntary initiative.
Tom Natan, Research Director
National Environmental Trust
1200 18th Street, NW, Fifth
Floor
Washington, DC 20036
202/887-8800 (t); 202/887-8877 (f)
tnatan@environet.org
-----Original Message-----
From: Iannuzzi, Al [JJCUS]
[mailto:AIANNUZ@CORUS.JNJ.com]
Sent: Friday, December 20, 2002
3:50 PM
To: 'Melinda Dower';
NPPR@great-lakes.net; p2tech@great-lakes.net; pswp@yale.edu
Subject: RE: Industry
environmental initiative waning -- evidence from33/50?
So how much really was reduced voluntarily? The
EPA reported these savings to the public. Are the Energy Star savings
also over stated?
Al Iannuzzi
WW Environmental Affairs
732-524-6382
Fax 3296
-----Original Message-----
From: Melinda Dower [mailto:Melinda.Dower@dep.state.nj.us]
Sent: Friday, December 20, 2002
3:24 PM
To: NPPR@great-lakes.net;
p2tech@great-lakes.net; pswp@yale.edu
Subject: RE: Industry environmental
initiative waning -- evidence
from33/50?
Not only were they overstated, many of the chemicals
were banned and
therefore had to be replaced.
Melinda Dower
NJDEP
(609) 292-1122
>>> Program on Solid Waste Policy
<pswp@yale.edu> 12/20/02 03:20PM >>>
I'm a little late in responding to
this part of the thread, but I
thought
that it would be interesting
nonetheless to note that careful analysis
of
the 33/50 program suggests that
many of the reductions attributed to it
were overstated. See, the important article by
Kathryn Harrison:
Harrison, K. 1998. "Talking with the
Donkey: Cooperative Approaches
to
Environmental Protection"
Journal of Industrial Ecology 2(2):
1-22. [available at
<mitpress.mit.edu/JIE/sample_articles>]
Reid Lifset
Industrial Environmental Management
Program
Yale University
At 09:56 AM 12/17/2002 -0500, Iannuzzi, Al [JJCUS]
wrote:
>ok everyone - I work for industry and all I have
to say is 33/50
program =
>824 million pounds of toxic
chemical releases removed from the
>environment, Green Lights &
energy Star = Over 6 billion square feet
of
>building space is now more
energy efficient resulting in the
elimination
>of 10.5 billion pounds of carbon
dioxide and significant amounts of
>nitrogen oxide, sulfur dioxide,
particulates and toxic metals. All
>voluntary programs.
>
>Look at the annual
environmental reports of companies - many are
>voluntarily reducing
emissions. The question is - how can we get more
>firms to voluntarily reduce pollutants? Do
we really think that going
>through the traditional regulatory process is the
way to get more
improvement?
>
>Enforcement is necessary, but
it is only a part of the picture. You
have
>to do both to improve the
environment in today's climate.
>
>Al Iannuzzi
>WW Environmental Affairs
>732-524-6382
>Fax 3296
>
>
>-----Original Message-----
>From: Minicucci, Bob
>[<mailto:rminicucci@des.state.nh.us>mailto:rminicucci@des.state.nh.us]
>Sent: Tuesday, December 17, 2002 9:05 AM
>To: Melinda Dower;
NPPR@great-lakes.net; P2Tech@great-lakes.net;
>Todd_MacFadden@uml.edu
>Subject: RE: Industry
environmental initiative waning?
>
>What are we doing to encourage
that 10% in the 'leadership' category
to
>become 20%, 50%, 98%?
(It'll never be 100%, after all.)
>
>Bob Minicucci
>NH DES
>603-271-2941
>
>-----Original Message-----
>From: Melinda Dower
>[<mailto:Melinda.Dower@dep.state.nj.us>mailto:Melinda.Dower@dep.state.nj.us]
>Sent: Tuesday, December 17, 2002 9:00 AM
>To: NPPR@great-lakes.net;
P2Tech@great-lakes.net;
Todd_MacFadden@uml.edu
>Subject: Re: Industry
environmental initiative waning?
>
>Having been a "closet
enforcer" for many years, I am heartened to see
>everyone's conclusions about
the limited effectiveness of voluntary
>programs--I feel like I can
come out of the closet now. Even here in
NJ,
>where P2 Planning is mandatory
but implementation of P2 measures is
>
>voluntary, I have had numerous
corporate representatives comment that
>they would be implementing much
more P2 if it were mandatory.
>Regulations drive corporate
behavior far more than anything voluntary
>(with the exception of the
maybe 10% high performers who are doing
great
>P2 and have integrated P2 into
their own performance measures).
>
>It is also important to note
that government has not delivered on its
>promises to provide
flexibility.
>
>Melinda Dower
>Research Scientist
>N.J. Department of
Environmental Protection
>
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================================================================
Reid J. Lifset, Assoc.
Dir.
School of Forestry &
Env.
Studies
Industrial Environmental Mgmt.
Program Yale University
Editor, Journal of Industrial
Ecology 205
Prospect Street
203-432-6949 (tel) -5912
(fax)
New Haven, CT
06511-2189 USA
reid.lifset@yale.edu
http://mitpress.mit.edu/JIE
----------------------------------------------------------
Program on Solid Waste Policy
School of Forestry and
Environmental Studies
Yale University
205 Prospect Street
New Haven,CT 06511-2189 USA
203-432-3253 (telephone)
203-432-5912 (fax)
http://www.yale.edu/pswp
pswp@yale.edu
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