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RE: Enforcement and P2



Thank you, P2 Techers, for all the great responses on P2 and enforcement.  I thought I would compile the information that I received and post it, since some of the information came from people off the list.  As a reminder, I was looking for any documents that (1) compare the effectiveness of voluntary compliance assistance and enforcement programs or (2) report that strong enforcement is an essential element to a companies decision to deploy pollution prevention strategies.  The compilation is below.

cmd

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I would try the Design for the Environment and Enforcement programs at EPA.  Their general number is (202) 260-2090.  The DfE program holds all the Office of Pollution Prevention and Toxics voluntary programs and they probably keep some of that data.  In addition, the enforcement offices are keenly interested in keeping that kind of data. 

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See "Study of Industry Motivation for P2" draft of April 23, 1997, by Manik Roy and Ohad Jehassi, USEPA.  Since neither of them is at EPA any longer, contact Lena Hahn Ferris, OPPT, PPD, USEPA, for a copy.  The document looks at the drivers for P2.  While not focusing on enforcement per se, it does point out that rule requirements were the biggest driver for P2.  One quote:
    "The survey showed that traditional environmental regulatory programs were almost unrivaled in making business decision makers aware of their environmental obligations."

A survey of printers and large companies was used to reach this conclusion.  There has not been a final report issued.

Just a personal opinion:  Since actual enforcement is so uncommon, I don't feel that it's the enforcement threat that really makes the difference.  Rather, it's the businesses' interest in "doing the right thing" to comply with rules and general feeling of obligation to do good for the community.

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I dont' have anything directly on point for you, but take a look at the world bank paper "What Improves Environmental Performance? Evidence from Mexican Industry".  http://www.worldbank.org/NIPR/work_paper/1877/index.htm.  Here's what their executive summary says:
"The implications of our results can be summarized as follows:  (1) Process is important. Plants which institute ISO 14000-type internal management procedures exhibit superior environmental performance. <SNIP>   (3) Regulatory pressure works.  Plants which have experienced regulatory inspections and enforcement are significantly cleaner than their counterparts.  <snip>"

This seems to support the idea that enforcement is an important part of environmental performance (unclear whether this study looked at P2 or just any environmental improvements)

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I have skimmed several publications that you might find useful in providing an overview of U.S. P2 policy.  
Cross, John. 1998. You say you want a P2 Revolution? P2 : Pollution Prevention Review 8:11-25.
Hirschhorn, Joel S. Why the pollution prevention revolution failed -- and why it ultimately will succeed. P2 : Pollution Prevention Review 7:11-31.
Geiser, Ken. 1998. Can the pollution prevention revolution be restarted? Pollution Prevention Review 8:71-80.

Finally, you might find the following document useful.  It discusses methods of integrating federal P2 goals with state regulatory programs.  United States. Environmental Protection Agency. Office of Pollution Prevention and Toxics.  Pollution prevention incentives for states PPIS:  Stakeholders Discussion Paper.  Washington, DC : U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics, 1998. 13 p. (Its Report ; EPA 742-R-98-004).

The publications cited above do not provide statistical comparisons, but you might find material in them that you could quote. 

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I'm not aware of anything in item (1) below because at (OR) DEQ we don't look at comparative issues like that.  For us its not an either/or  case rather its a case of both necessarily working together.  The old agency model is the enforcement model - "command and control".  The new model is to maintain the enforcement model and add a technical assistance one.  They don't operate alone so we wouldn't study the separate effectiveness.  One could determine the extent of compliance based on the base standards and then look at the effect of voluntary compliance to go beyond those base standards - which is what we are all trying to measure out here in P2.  There are some incremental measurements that one could extrapolate from but I'm not aware of a study as such.  On (2) I can think of a book I've read recently entitled "Moving Beyond Environmental Compliance" by Thomas Welch.  In his compliance-based EMS model the driving policy is compliance.  In his continuous improvement based EMS model the driving policy is compliance AND prevention continuous improvement and leadership.  His implication (and in my three years of enforcement at DEQ,  I agree) is that compliance is still the foundation of voluntary technical assistance.  

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Here are three you may or may not know about:
Cultural Barriers to Behavioral Change: General Recommendations and Resources for State Pollution Prevention Programs, July, 1993, by Center for Values and Social Policy, report for EPA under grant XB19192-01-0.  The table of contents includes methods, concepts and models and a directory of information resources that might apply to your question.

A New Market-Based Approach to Fostering P2: Policy Rationale and Progress in Indiana, produced by Indiana P2 and Safe Materials institute in June, 1995

Transforming Environmental Permitting and Compliance Policies to Promote Pollution Prevention: Removing Barriers and Providing Incentives to Foster Technology Innovation, Economic Productivity, and Environmental Protection, EPA 100-R-93-004

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Here's a citable study that sorta gets at what your after. http://www.worldbank.org/NIPR/work_paper/govern/#_Toc384547611

The variable wasn't the level of enforcement, per se.  Rather than  managment in general (not P2). 

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We are just beginning a project for the Michigan Great Lakes Protection Fund to assess the efficacy of voluntary P2 programs.  

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This area is now being looked at in Florida, and is part of their PPA. Contact Michael Phillips at 904-921-9717.