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RE: Industry environmental initiative waning?

Karen notes that participation in voluntary programs has been disappointing.
Voluntarily programs typically appeal to large corporations seeking
recognition.  However, most business are small businesses (about 96% in
Nevada).  Government environmental agencies are viewed negatively by the
business community as imposing additional operating costs on their
businesses.  Voluntary programs require businesses to expend additional
resources to monitor their performance and report it to these agencies
(small businesses already spend much more money per employee for compliance
than large businesses).  Most businesses believe that any information they
provide (particularly to USEPA) can and will be used against them.  Most
incentives for volunteering do not seem to offset the downside of additional
monitoring/reporting and the perceived greater exposure of negative
consequences from providing this information to the environmental agencies.

Our experience in Nevada has been that most businesses want to comply and be
good members of the community and will implement P2 projects that make good
business sense and/or reduce their regulatory exposure.  They need
information and assistance to do this, and they want that assistance
provided with "no strings attached."   They do not want to be the guy that
raises his hand and steps forward out of the line.  After implementing a
successful project they want to move on and do something else.  They don't
want to spend the rest of their careers measuring and reporting how
successful it was.

One anomaly may be the energy star program.  However, this program has two
advantages.  It relies on a competitive advantage for product manufacturers
that manufacture energy star equipment and the brand development of energy
star as an industry standard.  The other advantage is that EPA does not play
the role of the Energy Police, and they do not already impose additional
regulatory requirements for how a facility uses, monitors, and reports their
energy consumption.

Kevin Dick
Business Environmental Program
Nevada Small Business Development Center
University of Nevada, Reno
(775) 689-6677
(775) 689-6689 fax

-----Original Message-----
From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net]On
Behalf Of Karen Shapiro
Sent: Tuesday, December 17, 2002 1:28 PM
To: P2Tech@great-lakes.net; NPPR@great-lakes.net
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

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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