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Posting for P2 Tech

Dear P2 Tech Subscribers:

 Last month I presented a paper at the annual Woods Hole P2 Conference which
addresses the issue of how we might bring more coherence into the way
environmental assistance services are delivered in this country.  Someone
suggested that I should share the paper with the broader P2 audience of P2
Tech--so here ‘tis.  A few caveats are in order, however:
 Despite the fact that this paper touches on issues that are addressed by S.
1957, it should not in any way be construed as an EPA position on this (or any
other) bill.  

 The paper does not attempt to propose solutions, so much as a way to think
about how we might bring more coherence into our environmental assistance
delivery system. 

 The current draft of the paper reflects comments that I received at Woods
and from elsewhere over the past few weeks. 
 Here at EPA, we (the Pollution Prevention Division) intend to use this paper
as the basis for an upcoming (August 5) session of the Office of Pollution
Prevention and Toxics’s periodic FOSTTA meetings  (FOSTTA being a group which
brings state and Federal toxics officials together).  Your thoughts will be

	(A Concept Paper, 2nd Draft, Prepared by 
	Ed Weiler, USEPA/OPPT, July 1998)

The Problem: Lack of a Coherent System

The lack of a coherent system for delivering environmental assistance has long been recognized as a serious problem by ?the provider community,? and thus needs no further elaboration here.  Of more recent vintage, however, is a growing awareness of the problem by Congress.  Thus, in his opening statement at an April 28, 1998 hearing of the Senate Small Business Committee on environmental compliance assistance, Chairman Kit Bond (R-MO) noted that: ?Just as the Federal government should not write laws that create multiple layers of regulation or duplicate requirements, we need the agencies to develop compliance assistance programs  in a coherent and coordinated manner.?  Commenting further on EPA?s achievements to date in this arena, Bond said in effect: Good work EPA, but you?ve got to simplify it!

The Promise: Congress is Looking for Some Vision

While a relatively low-profile event, both the tone and substance of the April hearing  appeared to reflect a genuine search by the Committee for workable models1 for compliance assistance programs. Thus, if significant new funding is to be obtained for environmental assistance services2 in the foreseeable future, the ball would seem to be squarely in the  provider community?s court.   The purpose of this paper is to stimulate thinking along these lines.

Toward a Functional Model--Looking
 to the Business World

While the provider community has yet to achieve consensus  on the design of an integrated system,  there seems to be near-unanimity on the approach--viz., inventory who is doing what ?out there,? and then see how these groups might be cobbled together.   Unfortunately, under this approach, the resulting ?design? is more reflective of the needs and aspirations of the various provider organizations than of the underlying functions required to meet the needs of the ultimate customer--viz, individual businesses.  In  the abstract, one could argue that the desire of many  (if not all) of these organizations to become vertically-integrated, full-service operations capable of reaching the end-customer promotes choice. The reality, however, has proven to be a patchwork of mostly small programs, for which the primary mission is survival.  Cobbling them together would merely serve to perpetuate the status quo.  

An alternative approach would be to design a system around the core functions that must be carried out if the ultimate customer?s needs are to be met. Perhaps this approach can be illustrated by an example from the business world: replacement windows.  In order to provide the customer (a homeowner in this instance) with improved natural lighting and heating/cooling efficiency services, the window replacement ?industry? must carry out three core functions:  (1) manufacturing, (2) installation, and (3) sales/customer service.  In most instances,  the customer has little need to interact with the manufacturer--or for that matter, even with the installer,  in the  case of standard windows.3 

An (admittedly less-than-perfect)  analogy between the window replacement and the environmental assistance provider industries can be drawn as follows: 

? Manufacturing: development of information products; training ?installers? in proper use of the information product

? Installation: assistance in diagnosing a business?s problems; interpreting and implementing the substance embodied in the information products; consulting with the information developer to obtain customized solutions 

? Sales/Customer Service: bringing customers into the service; making appropriate  referrals; distributing generalized information; and providing solutions to standard problems

Sorting Out Who Should Do What

An analogy from the business world can inform the sorting-out process as well.  Standard counsel from business assistance providers to their clients is, ?make sure YOU understand your business.?  Translation: make sure your business is based on functions that you perform well enough to attract  (within some defined time period)  enough paying customers to sustain the firm.  Apart from the prospect of one?s imminent demise, perhaps nothing else serves to focus the mind as does the need to have paying customers.

?Understanding the business? is also germane in the context of environmental assistance providers.  Thus, for example, a state P2 technical assistance program might ask itself the following questions: (1) should I develop my own technical documents, or procure them elsewhere?  (2) should I pitch my services directly to businesses? or (3) should I build my program through referrals from other, more-generalized business assistance providers?  In short, in terms of the three core functions of the ?provider industry.? where can my industry add the most value? 

Drawing upon the ?replacement window model,? and inspired by the notion that every organization needs to get in touch with its core business, this paper proposes (as a starting point for discussion) a functionally-based design for an integrated environmental assistance extension system in which the participating organizations would focus primarily on those  functions for which they have a demonstrable comparative advantage.  Within this framework, the existing provider organizations would not simply be cobbled together, but instead, be responsible for executing one (or perhaps more) of the core functions, thereby supporting the operations of other providers further up or down the environmental assistance chain.

For illustrative purposes, Figure 1 relates selected environmental assistance providers to the core function each might be expected to perform in an integrated environmental assistance extension service.  The rationale for this proposed division of labor follows below.  This discussion should not be interpreted as a description of the current  lay of the land, or as an inventory of the organizations that currently (or potentially might) provide environmental assistance, but rather as an illustrative attempt to ascribe appropriate roles to key members of the provider community, based upon considerations of efficiency and their respective abilities to access the service?s ultimate customers--individual businesses.  Thus the purpose at hand is to foster a discussion within the provider community, initially on WHAT needs to be done, and subsequently, on WHO, among many possible candidates, might have a comparative advantage in executing each of the agreed-upon core functions of the system.  

? Core Function 1:  Product Development (manufacturing): Key elements would be:  (1)  the development of information products designed primarily for (but not limited to) use by technical assistance providers;  and (2) provision for training  providers in the appropriate use of these products.   At a minimum, the key players would seem to be: 

--EPA (Program Offices and OECA):  As the source for both EPA?s regulatory and voluntary programs, these offices are uniquely positioned to develop Federal-level information products and associated training.  Working with EPA?s Program Offices, OECA?s Compliance Assistance Centers would have lead responsibility for information products and associated training relating to OECA?s priority sectors.  
--State DEPs: Since most Federal environmental laws are  implemented at the state level, states necessarily would have lead responsibility for developing state-specific information products. 

--P2Rx (a regionally-based, integrated network of P2 information centers): This network would have lead responsibility for developing P2-oriented information products,  and for training associated with their use.

? Core Function 2: Active Assistance (installation): Key elements would be: (1) providing on-site diagnostic audits/assessments;  (2) ?backstopping? Customer Service; and (3) devising customized solutions to individual businesses? environmental problems upon referral from customer service.  At a minimum, the key players would seem to be: 

--EPA?s Small Business Ombudsman (SBO)4 and Program Office Hotlines: In keeping with the principle of triage underpinning  this design, these resources would be deployed to respond to non-routine compliance questions/ issues referred through Customer Service. 

--EPA/OECA?s Compliance Assistance Centers (CACs): For OECA?s priority sectors, these centers would respond to non-routine, Federal-level compliance questions, posed either directly by businesses through the centers? help-line or fax-back service, or indirectly through Customer Service.  

--Section 507 Small Business Assistance Programs (SBAPs): These programs would respond to state-specific, non-routine compliance questions/requests-for- assistance obtained primarily through referrals from Customer Service. Their presence in the field allows them to offer on-site assistance. 

--State P2 Technical Assistance Programs (TAPs): In conducting on-site P2 assessments,  supporting other CF2 technicians, or in working directly with businesses to address the environment strategically, these programs would also derive most of their clients through referrals from Customer Service.  

? Core Function 3: Customer Service: Key elements would be: (1) demonstrating  to individual businesses the economic value of sound environmental performance; (2) diagnosing  businesses? environmental problems; and (3) providing standard solutions to routine problems, or making referrals to technical assistance providers, as warranted.  An unresolved debate within the provider community surrounds the extent to which environmental assistance services should be integrated with (or divorced from, depending upon one?s perspective) regulatory enforcement.  For those who focus on the widely-acknowledged distrust of  ?government? among small-business owners/managers,5 it is critically important that the customer service function be executed by organizations not generally perceived as having ties to the regulatory processes of government.6   A counter view holds that, were it not for regulations, businesses would have no incentive to seek out the services of environmental assistance providers.  For both views, the key word is ?access.?  The disagreement is over how this access can best be obtained.  Depending upon which view ultimately prevails, the key players would seem to be: 

--Small Business Development Centers (SBDCs): In view of their extensive on-the-ground presence (nearly 1,000 centers nationwide),  and given that they are publicly-funded yet have no ties to regulatory  agencies, SBDCs are well positioned to serve as an ?intake? for an environmental extension system.  Moreover, given their business development mission, they are also well suited to deliver EPA?s environmental message, not in the abstract, but WITHIN A BUSINESS CONTEXT.  Given that roughly two- thirds of their clients are service businesses (per a 1995 survey funded by EPA7), however, SBDCs might not offer superior  access to manufacturers.


--NIST Manufacturing Extension Partnership Centers (MEP Centers): With over 400 centers in all, the NIST Manufacturing Extension Partnership also has a national reach; and like the SBDCs, the MEP Centers  have no ties to regulatory agencies.  Whereas the primary client base for SBDCs is made up of service businesses, as noted above, the MEP Centers focus exclusively on manufacturers.  In addition to technical assistance directly relating to manufacturing,  these centers also offer a wide variety of business assistance services--many of the same services provided by SBDCs.


--Local government units (including single-purpose authorities): By dint of their legal authorities and/or their monopoly status (e.g., a local POTW), these entities collectively could offer universal access to businesses in both the service and manufacturing sectors.  Moreover, in the case of local permitting agencies, the most frequent contact occurs when the firm is expanding or in some way modifying its operations, and thus relatively more disposed toward implementing significant P2 initiatives.8   Nevertheless, these organizations are unambiguously governmental, a fact which, depending upon one?s view, might limit their utility as a deliverer of the environmental message.  

The Funding  Question

From the perspective of any given member of the provider community, the ?answer? to the funding question typically runs along the lines of, ? we could do it all if only given adequate funding,? and as such,  is antithetic to a process of coalition-building among providers.  As noted at the outset of this paper, Congress is now aware of a problem, and appears to be willing to fund a solution. While Congress might fund a coherent integrated extension service--to be administered perhaps by a joint board of Federal and state agencies with an interest in environmental protection--it is less likely to provide financial support for a group of quarreling fiefdoms. 

Summary and Conclusion

Increasing Congressional scrutiny over the manner in which EPA offers environmental  assistance, especially to small businesses,  presents the provider community with both an opportunity and a challenge.  While Congress appears to be favorably inclined toward additional funding for such activities ( the opportunity), it may be equally reluctant to act until someone offers a vision of how assistance such programs might be developed in a coherent and coordinated fashion.  In proposing a conceptual foundation upon which a coherent, integrated environmental extension system might be built, this paper seeks to help the provider community meet this challenge.

The potential benefits of an  environmental extension system along the lines proposed in this paper are both operational and political. In operational terms, an integrated system would provide a framework within which existing provider organizations could focus primarily on those functions in which they (respectively) have a demonstrated comparative advantage.  On the political level, a system comprised of interdependent ?business? units that serve readily identifiable and quantifiable customers would make intuitive sense both to lawmakers and the taxpaying public.  Finally, a service which represents a coalition of interests, embracing both aspects of environmental assistance (i.e., compliance and prevention-oriented technical assistance), as well as more broadly-based business assistance organizations, would be more likely to obtain additional Congressional support than would a ?scattershot? of narrowly-based environmental programs. 	

Core Function 1: Product Development
- Development of information products
- Training ?installers? how to use the information products
EPA (Program
Offices & OECA

Core Function 2: Active Assistance
- On-site assessments
- Customized solutions to businesses? environmental problems



State  P2


Core Function 3:Customer Service
(Sales & Customer Service)
- Bringing in new customers
- Referrals to technicians
- Standard solutions to routine problems


Local Govermental




(e.g.,trade assocs.)

- Receipt of information
- Feedback as appropriate



Figure 1.  Conceptual Framework for an Integrated Environmental Assistance Extension System
1This term was used by Senator John Kerry (D-MA) in his opening remarks.
2While the Committee Members focused on environmental compliance, pollution prevention was implicitly included in testimony that was given by representatives from the printing and metal finishing industries.  Hereafter, the term ?environmental  assistance? should be understood to include assistance for both pollution prevention and regulatory compliance.   
3On the other hand, in the case of customized windows, the customer most likely will need to interact with the installer on one or more occasions. 
4SBO?s ?small-business advocacy? role (e.g. participation in EPA rulemakings) would continue outside of the proposed extension service, as a coordinated but independent function. .
5For a variety of reasons, small businesses have been difficult for EPA to reach.
6For a discussion of this point, see: Thomas J, Bierma and Francis L. Waterstraat, ?Promoting P2 Among Small Metal Products Fabricators.? Pollution Prevention Review, August 1995, p. 34.  In view of the intense antipathy toward government among the small businesses they encountered, Bierma and Waterstraat recommended that environmental agencies work through totally private entities, such as vendors or trade associations.  
7 ?Environmental Assistance and the Small Business Development Centers: (1) Capabilities Survey; (2) Training and Program Implementation Plan.? Unpublished report prepared by the Nevada Small Business Development Center for SBA and EPA.  Reno, Nevada: August 1995.  
8Boyer, Barry, Professor of Law at Ecosystem Policy Associates, ?Creating Pollution Prevention Incentives for Small Businesses: The Erie County program.?  Unpublished report prepared for the Erie County, New York Department of Environment and Planning, Office of Pollution Prevention,  East Aurora, New York: April 1993.