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My Submission for P2 Tech

Here goes again.á Thanks for your help. 

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
with the broader
P2 audience of P2 Techso here Štis.  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)

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

     The current draft of the paper reflects comments that I received at Woods
Hole 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
together).  Your thoughts will be welcomed. 


                      A FUNCTIONAL APPROACH 
TO THE DESIGN                 OF AN 
                        EXTENSION SYSTEM 
            (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 models for compliance
assistance programs. Thus, if significant new funding is to be obtained for environmental
assistance services 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. 

     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

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

     --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) 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
     --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, 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.   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 EPA),
     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.   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

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 of information
- Training "installers" how to use the
information products

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

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





- Receipt of information
- Feedback as appropriate


               Figure 1.  Conceptual Framework for an Integrated Environmental Assistance Extension System