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Environmental "Enhancement" Initiative
In response to the Envrionmental Enhancement Proposals posted earlier on
the P2 tech listserve by Kebin Dick:
In my position as the head of the New Mexico Pollution Prevention
Program, I have some concerns and questions regarding this proposal to
Congress to earmark funds to establish this demonstration initiative for
I am frustrated that once again there appears to be a move underfoot to
establish YET ANOTHER pollution prevention/ compliance assistance
network nationally. There is an existing network of state and local
pollution prevention assistance providers (referenced in the proposal)
that has a LONG track record of developing materials and delivering
technical assistance to businesses and organizations to their
customers. These programs can demonstrate dramatic results and are both
credible and well established.
I know from my experience in both Wyoming and in New Mexico, we have
worked hard in partnership with both the SBDC's and with the MEPs to
promote pollution prevention. My experience with the SBDC's in both
state are that they have small offices (one-three staff person offices)
that work on small business financing and start up issues. They are not
interested in delivering environmental technical assistance (unless
there is a significant amount of money offered to them to establish NEW
(and for most states) duplicative environmental assistance programs).
The success I have had with the SBDC's is to cosponsor training (we
conduct the training) which helps them round out some of their offerings
to their businesses. This is the partnership aspect...they can leverage
us to deliver additional services without expanding their staff or
I have also worked with the MEPs. In Wyoming, they were very concerned
about liability issues surrounding the delivery of environmental
assistance...mostly what their liability would be if they gave advice on
waste management issues and the enforcement agency disagreed with the
suggestion, resulting in some sort of enforcement action. I think the
MEPs make great partners and we are working on training development and
outreach with them in NM (and we had a great relationship with them in
Wyoming). However, there are limitations to the MEP program: they
conduct outreach only to manufacturers, leaving out a huge customer base
in the small business commercial sector and they have to charge
consulting fees (beyond the financial ability of many small
The existing state and local P2 programs have already conducted these
"demonstration initiatives" with the local MEPS and SBDCs for years!
This demonstration initiative will have dubious value...why not just
poll the states that are already working with these agencies if you want
to see how they work? I think most states can document their own
experiences in developing these partnerships.
My questions are:
Is this initiative compliance-focused or P2 focused?
Where is the $6 million for the 11 states, P2RX etc. going to come
Will it replace PPIS which gets distributed across the entire country? I
read in the introduction that the $6 million would be "new" monies.
how difficult it is to advocate for the full $8 million authorization
PPIS (the additional $2 million) it seems implausible that the money
just appear. It would either come from PPIS or from the media programs.
Which one is it? Or is it from some program that is closing shop?
it is all from SBA. This is an important considerations for the existing
state and local programs.
P2RX will be assisting with the national administration of this endeavor
well as the EPA funded compliance assistance centers. I am confused. Is
P2RX an organization? I thought it is an EPA funded and managed project
comprised of states and non-profit groups like NEWMOA and PPRC. They
receive federal funding and provide some matching funds. Are the
compliance centers centralized into an organization?
What office is this proposal being submitted to? Is it a media office,
it the P2 office? I am assuming it is EPA.
I see from Christine's comments that Iowa was not apprised of the
proposal. It is also my understanding that other states in the proposal
were not fully informed. I was not contacted about interest in this
proposal in my program in New Mexico and we have a good working
relationship with both the MEP and the SBDCs.
Are there other partners that were not part of the development of the
These are just some questions that were raised in this office. Thanks to
whomever can shed some light on this. This is an issue that should be
of concern to most state and local programs, as it might potentially
affect their funding sources. As well, NPPR is not a partner in this
effort and many other states are not partners in this program , but it
is important to us since it concerns a considerable number
Here's a new demonstration initiative that should be considered: Why
not adequately support the existing state and local P2 programs that are
working well? THAT is worth an earmark from Congress!
Pat Gallagher, New Mexico Environment Department and Chair, National
Pollution Prevention Roundtable