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linking emission fees to mgmt improvements



Is anyone familiar with a pollution discharge fee system where the fees are reduced if the company implements management activities in support of P2, such as a P2 audit, a total cost assessment system, an EMS, a P2 program etc?  We are trying to determine if such a scheme would work here in Peru where the national environmnetal health agency now imposes a flat fee for all wastewater dischargers.  They initially wanted to link the fee reduction to specific P2 process improvements but the technical auditing details are beyond them, so we are proposing a series of relatively clear management improvements for which the fees would be successively reduced.  They want to know if anyone else has tried this approach.
Thanks for any leads.
 
Burt Hamner
Universidad del Pacifico
Lima, Peru