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RE: Industry environmental initiative waning?



Diane Saxe a very bright environmental lawayer -- I use the phrase
deliberately because there are many many dumb ones!-- expressed it best:

1. use enforcement vigorously for the 15% environmental criminals
2. use incentives & recognition for the leaders and early adapters
3. use spot inspections and voluntary in-between to provide both
deterrent from slippage and incentive to do better for the middle of the
pack.

Too often government inspectors go after the good performers who have
minor slips, because those beans are easy to count, and don't chase the
ones who are hard to find.

Enforcement alone cannot do the job; voluntary alone is for the very
few. We need both and we need to get our act together so that both sides
of the equation are mutually supportive, not competing for the glory.

Fred Granek


-----Original Message-----
From:	Karen Shapiro
Sent:	Tue 12/17/2002 4:27 PM
To:	P2Tech@great-lakes.net; NPPR@great-lakes.net
Cc:	
Subject:	RE: Industry environmental initiative waning?

Like many of the prior responders, I too believe that integrated
approaches
work best.  Voluntary programs (VPs), by themselves, are not apt to lead
to
significant aggregate environmental gains.  Thus, in my view, the best
"carrot" is backed by a "stick." The size and variety of the stick can
be
tailored to industry/business sectors along with many other factors
(e.g.,
is the facility a good or poor environmental actor).  

Another reason why voluntary programs are not always effective is that
their
success hinges on the participation of many facilities/companies -- it
is
unlikely that a small number of participating facilities will yield
significant aggregate environmental improvements.  To date, there have
been
many voluntary programs at the federal and state level.  However,
participation in many of these programs has been disappointing.  

Why don't more firms participate in VPs?  A few years ago Tellus
conducted a
study for the Michigan Great Lakes Protection Fund entitled, "Do
Voluntary
Mechanisms Work? An Evaluation of Current and Future Program
Performance."
This study examined why firms participate in voluntary programs and what
is
needed to sustain their participation.  In a focus group comprised of
industry representatives, several people noted that the uncertainty of
VPs
versus the certainty of regulations is one driver for not participating.
Because participation in a VP incurs costs (including time), firms want
to
know that the VP is not ephemeral.  By comparison, focus group
participants
noted that regulations have greater staying power and therefore warrant
greater resources.  

Lastly, the efficacy of VPs is typically difficult to measure and many
of
these programs are  designed without giving prior consideration to
performance measures needed for gauging success.  Even the success of
the
33/50 program (referred to by another responder) has been debated --
while
chemical releases during the program's lifetime decreased, it is
difficult
to know to what extent reductions should be attributed to the program
versus
to pending regulations, or to what extent these reductions were in fact
due
to P2 activities.  (For a further discussion of the efficacy of VPs see
http://www.tellus.org/b&s/publications/r8-031.pdf) 

Thank you Todd for initiating this dialogue!

Karen Shapiro			
Senior Scientist	
Tellus Institute	
11 Arlington Street	
Boston, MA 02116-3411	

phone: 617-266-5400   fax: 617-266-8303
email: kshapiro@tellus.org
web: http://www.tellus.org




-----Original Message-----
From: Rudy Moehrbach [mailto:Rudy_Moehrbach@p2pays.org]
Sent: Tuesday, December 17, 2002 1:31 PM
To: 'Terry Foecke'; Katz.John@epamail.epa.gov; Minicucci, Bob
Cc: NPPR@great-lakes.net; P2Tech@great-lakes.net
Subject: RE: Industry environmental initiative waning?


As a P2Tech member I would like to state this has been a very
interesting
thread. I disagree with Jim Walsh that we should not reply to all.
Deleting
some messages that may not interest you at this time is not that big a
deal,
Mr. Walsh. Many of us are being served well by this discussion.

Terry Foecke, if memory serves my right, the last time I saw Bill
Bilkovich
was at a plating shop in Virginia and you were there also. 

Rudy Moehrbach
Staff Engineer
Waste Reduction Resource Center
Phone 800-476-8686
Web http://wrrc.p2pays.org
Check out DPPEA marketplace for waste material: www.ncwastetrader.org 


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