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permitting, inspections, and enforcement, must reflect
our commitment to reduce pollution at the source, and
minimize the cross-media transfer of waste.
-Stateand Local Partnerships Increasingly,state and
local agencies are the "face of government" for the -
general public. We will strengthen the national network.
of state and local prevention programs, and seek to
integrate prevention into state and local regulatory,
permitting, and inspection programs supported with
federal funds.
~ Private Partnerships; We will identify and pioneer
new cooperative efforts that emphasize multi-media
prevention strategies, reinforce the mutual goals of
economic and environmental well-being, and represent
new models for government/private sector interaction.
- Federal Partnerships We must work closely with our
counterparts in other agencies to ensure that pollution
prevention guides 'our management and procurement
decisions, and to pursue opportunities for reducing waste
at the source in the non-industrial sector.
- Public Informatinn/The Right-to-Know: We will
collect and share useful information that helps identify
pollution prevention opportunities.measure progress, and
recognize success.
— Technological Innovation; We will try to meet high
priority needs for new pollution prevention technologies
that increase competitiveness and enhance environmental
stewardship, through partnerships with other federal
agencies, universities, states, and the private sector.
- New Legislation; Where justified, we must not.
hesitate to seek changes in federal environmental law that
will encourage investment in source reduction.
4. Definition
EPA has definedpollutiorrpreventionas "source
reduction" as that term is explained under the Pollution
Prevention Act, as well as protecting natural resources •
through conservation or increased efficiency in the use of
energy, water, or other materials.- EPA staff should
continue to use this definition, as elaborated in the
Agency guidance issued in May of 1992.
The guidance makes 'clear that pollution
prevention is not the only strategy for reducing risk but
is the preferred one. Environmentally sound recycling
shares many of the advantages of prevention - it can
reduce the need for treatment or disposal, and conserve
energy and natural resources. Where prevention or
recycling are not feasible, treatment followed by safe
disposal as a last resort will play an important role in
achieving environmental goals. In all cases we must be
guided by applicable statutory requirements.
5. Regulations And Compliance
Our first obligation at EPA is to fulfill the
statutory responsibilities we have been given by
Congress. That generally means developing
environmental 'standards through regulation, and
ensuring compliance through a system of permits,"
inspections, and enforcement actions. I firmly believe '
that strong environmental requirements, if designed to
encourage cost-effective compliance strategies from
industry, can promote pollution prevention and improve
the competitiveness of American industry.
We can take a number of actions to realize'this
potential. First, we must work within the law to design
and implement our regulations to provide incentives for
source reduction. That will mean better coordination of
different regulations that affect the same -industry to
reduce transaction costs, minimize cross-media transfers
of waste, and provide a clearer sense of our long-term
goals for the regulated community.
EPA's Source Reduction Review Project
(SRRP), which is exploring how best to encourage
pollution prevention in the design and implementation of
rules affecting 17 high priority industries, is a good, start
toward this goal. I also will expect programs to evaluate
opportunities for preventing pollution in each major
proposed regulation, as the Pollution Prevention Act
requires.
Second, we .must encourage pollution
prevention as a means of compliance through our
permitting, inspection, and enforcement programs,
relying on the first-hand experience of regions and states
in this area. We can learn valuable lessons from
experiments like the Massachusetts Waste Prevention
F.I.R.S.T. project, through which the state promotes,
source reduction as the principal means of correcting
violations detected through multi-media inspections.
Finally, we need to collect better data on those
cost savings that occur when regulations encourage •
investments in cleaner, more efficient manufacturing
processes. As part of .th'is effort, we must develop
credible measures of the economic value of natural
resources protected through prevention. We must also
explore non-traditional alternatives, such as life-cycle
analysis, that help shed light on the advantages
prevention can offer in meeting our objectives.
6. State and Local Partnerships
The Clinton Administrationhas called for a'full
partnership between federal, state and local governments
in defining and carrying out national policy objectives.
We delegate so many responsibilities to states and
localities under federal environmental law; we simply
cannot hope to offer effective incentives for pollution
prevention in permits or inspections without their close
cooperation. Furthermore, some states have served as
national laboratories for the incubation of exciting new
multi-media experiments in reducing waste at the source,
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and are often more in touch With industry and public
needs and how best to meet them. Several states also
have taken the lead in helping their citizens an^
businesses use energy more efficiently: r
We can explore different methods for offering
state and local governments more flexibility in the
federal grants used to support delegated activities like
permitting inspections, and enforcement actions. EPA's
new guidance, beginning in. the 1994 fiscal year,
encourages our regions to work with states to adjust •
•administrative procedures in grant work.prans to make
room for pollution prevention investments. EPA regions
and states should make maximum use of this flexibility,
working within the statutory limits that govern grant
eligibility. The guidance requires programs to report on
legal barriers to funding worthwhile state pollution
prevention projects, so that we may 'consult with
Congress to seek appropriate remedies.
We also.must trust our state partners with
greater responsibility for the Pollution Prevention
Information Clearinghouse, _which . will facilitate
prevention technology transfer and technical assistance.
Our Regional Offices also have lead responsibilities in
the allocation of State grant monies under the Pollution
Prevention Act and in the-use of Regional extramural
resources (i.e the 2% funds) allocated to pollution
prevention activities. We must make effective use of
these resources to support strong state and local pollution
prevention programs.
7. Private Partnerships
Collaborative efforts with industry or public
agencies in many cases can help us achieve results
through pollution prevention more quickly than could be
obtained through regulation alone. For example, EPA's
Green Programs to promote the voluntary energy
• efficiency will play a critical, role in helping meet our
.obligations under the U.S. Action Plan to stabilize
greenhouse gas emissions by the year 2000.
' Furthermore, regulations often do not reach the
more complicated corporate decisions needed to evaluate
design, manufacturing, packaging, distribution and
marketing practices to reduce pollution and energy
consumption. We must encourage these efforts by
entering into, partnerships with public and private
organizations where such cooperation can produce
tangible environmental results. EPA's collaborative
.efforts - like the Green Programs, 33/50 and Design for
Environment -- offer encouragement, assistance and
public recognition to those companies and groups willing
to commit the resources needed to get the job done.
Recently, these initiatives have expanded to
include WAVE, a program to encourage water
conservation with the hotel/motel industry. Earlier this
year, EPA proposed an "Environmental Leadership"
program to reward corporations willing to go beyond
compliance by making measurable commitments to
pollution prevention. EPA's FY 94 budget proposal'
requests a substantial increase-in funding for these
programs, reflecting our commitment to achieve
environmental gains by working cooperatively with
industry. These investments will supplement, but not
substitute for, regulatory approaches to pollution
prevention. -
8. Federal Partnerships
President Cinton's Earth Day speech challenged
the federal government to, "lead by example - not by
bureaucratic fiat." Our government has a tremendous
impact on the environment as the nation's largest
landlord, and its biggest consumer of goods and services.
Later this summer, we expect to complete action on an
Executive Order that commits federal facilities to
publicly report wastes and emissions under TRI,
establishes a voluntary goal of-cutting federal .TRI
releases 50% by 1999, and builds pollution prevention
into, the specifications and standards that guide federal
purchases. EPA recognizes that other federal agencies
can create major opportunities for pollution prevention
through investments in new technologies, and through
policies that shape decisions in agriculture, energy,
transportation,and the managementof natural resources.
If we want pollution prevention to expand in. these
sectors, we must form partnerships that take advantage of
the authority and expertise at other federal agencies.
9. Public Information/The Right-To-Know
• Since pollution prevention is motivated in part
by public information, one of EPA's most important tasks
is to collect and disseminate "user-friendly" data that
measures progress in reducing waste at its source. The
Toxics Release. Inventory (TRI) as amended by the
Pollution Prevention Act now-requires 28,000 industrial
facilities to publicly report on the amounts of toxic
chemicals generated as" waste or released to the
environment. These- and other environmental data have
proved vitalin helping industry to identify opportunities
to reduce waste and improve economic efficiency.
Through public disclosure, the TRI empowers local
communities, State agencies and other public interest
groups 'to become stronger advocates for pollution
prevention.
I am committed to strengthening the Toxics
Release Inventory, both by improving the.quality of the
information and .by making more effective use of EPA's
existing authority to expand the scope of reporting to
additional chemicals and major sources of pollution. We
will also make the information more accessible and
understandable to states and local communities that
depend on timely and accurate data.
EPA's public data bases are not limited to TRI.
' Preventing chemical accidents also is important, and the
Agency collects information on chemicals that can
present a hazard if released during an accident. Data
collected under laws such as the Clean Air, Clean Water
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and Resource Conservation and Recovery Acts are
important indicators of environmental risk as well as
prevention opportunities, and EPA must take steps to
integrate this information and make it more readily
accessible to the public.
We cannot stop at collecting and interpreting
data. We should encourage public education, from the
university to the grade school level, that illustrates the
importance of environmental protection and the benefits
of prevention.
10. Technological Innovation
Cooperative efforts with universities, industry,
and other Federal agencies help raise awareness of
prevention opportunitiesand attract leading scientists and
engineers to engage in demonstration, development, and
research focused on new prevention technologies.
Accordingly, we must expand work with groups like the
• Department of Energy and its National Laboratories, the
National Science Foundation, the National Institute for
Standards and Technology (NIST), states, and the private
sector to advance both the development of new pollution
prevention technology and the effective delivery of
information about such technology to companies looking
for more efficient environmental solutions.
I want to make sure that some of the funding
available through the President's Environmental
Technology Initiative is targeted to help small businesses
meet compliance requirements through pollution
prevention while remaining competitive. As part of this
effort,'! will expect our programs to work together to
identify small business needs so that we may target short
term technical assistance and.long term cooperative
research in developing cleaner, more efficient
technologies.
11. New Legislation
I am convinced that we can achieve many
important pollution prevention goals working under
existing federal environmental laws. Where these statutes
present significant barriers to reducing waste at the
source, however, we should not hesitate to share this
information- with Congress and, if needed, seek
appropriate statutory changes. I want to be sure that any
effort to seek new authority is informed by fact. That is
why it is particularly important to gather specific and
accurate information on legal barriers to source reduction
identified when developing regulations and negotiating
grants with states. -
12. Conclusion
• I expect pollution prevention to .continue to
evolve at EPA. As we learn more, no doubt we will have
to make adjustments to our programs that reflect new
knowledge. In the final analysis, what is critical in our
efforts to advance pollution prevention is a willingnessto
take chances, to question established practices and
experiment with new ideas, and above all to cooperate
with each other as we try to harmonize environmental
protection with economic growth. I hope you share my
excitement at the new possibilities for pollution
prevention in the Clinton-Gore Administration, and I
look forward to working with all of you to achieve the
ambitious goals of this policy.
Carol M. Browner
EPA Administrator
June 15,1993
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