United States Science Advisory Board EPA-SAB-EEC-95-016
Environmental 1400 August 1991
Protection Agency Washington. DC
&EPA AN SAB REPORT:
VERIFICATION STRATEGIES
FOR EnTICE
j
RECOMMENDATIONS FOR
VERIFICATION STRATEGIES FOR THE
ENVIRONMENTAL TECHNOLOGY
INNOVATION AND
COMMERCIALIZATION ENHANCEMENT
PROGRAM (EnTICE) v.
A REPORT OF THE INNOVATIVE
TECHNOLOGY SUBCOMMITTEE OF
THE ENVIRONMENTAL ENGINEERING
COMMITTEE
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August 21, 1995
EPA-SAB-EEC-95-016
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401M Street, S.W.
Washington, D.C. 20460
Re: EPA's Environmental Technology Innovation and Commercialization Enhancement
Program (EnTICE)
Dear Ms. Browner:
At the request of the Office of Environmental Engineering and Technology Demonstration
(OEETD) in the EPA Office of Research and Development (ORD), the Innovative Technology
Subcommittee of the Science Advisory Board's (SAB) Environmental Engineering Committee
(EEC) reviewed the Environmental Technology Innovation and Commercialization Enhancement
Program (EnTICE). EnTICE is intended to verify the cost and performance of environmental
technologies and thereby bolster their credibility and potential entrance into the national and
international marketplace.
Overall, the Subcommittee found that EPA's mission protecting the environment requires
the use of effective technologies that are based on sound scientific principles. Hence, it is in
EPA's interest to foster initiatives that can potentially lead to the identification of more effective
environmental technologies. However, in providing this review, the SAB is not making any
recommendations as to whether or not EnTICE should be implemented.
The Subcommittee's charge was to review and comment on the strategy of establishing
third-party centers, temporarily supported by EPA, to generate credible data and information for
the marketplace and permitting arenas that would help decision makers promote the use of
innovative technologies in a more informed and confident manner. Both primary and secondary
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issues were included in the charge. The Subcommittee addressed each issue through discussion,
opinions and recommendations. Of necessity, the review participants based their
contributions on their experiences and expertise on technical issues and on related policy
implications. The attached report presents the Subcommittee's major findings which briefly are
summarized as follows:
a) EPA has an opportunity to play a leadership role in addressing technology devel-
opment and U.S. competitiveness in the national and international environmental
marketplace. A successful program of
verification of environmental technology performance could enhance this role.
b) The existence of a good, third-party center verification program likely will not be
sufficient in and of itself to substantially accelerate commercial acceptance of new
technologies, and likelihood of success will be low without complementary
targeted emphasis on credible performance and cost data and parallel programs
addressing critical issues that act as barriers to infusion of alternative technologies
into specific market sectors.
c) The use of third-party verifications centers for EnTICE is a preferred implementa-
tion model, but it is impractical to expect that every verification center will be self-
supporting in three years.
d) The customer is not likely to bear the cost of verification without incentives or
tangible benefits; the possibility of imposing long-term financial obligations on
EPA if the centers fail to become fiscally independent should be avoided.
e) If the verification process is to succeed, the EPA imprimatur is considered essential
as an official indicator of fair and impartial evaluation, especially in international
markets, provided it is not misrepresented as EPA giving approval or certification
of a technology.
f) Verification protocols should be developed to assure there is no technology bias,
and must be based upon detailed examination by all stakeholders of issues specific
to each class of technology for each market sector, coupled with strong EPA
oversight and audit to assure fairness and consistency in the application of the
verification process.
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g) A middle management committee linking verification activities and EPA efforts to
remove other barriers to acceptance of new technologies is considered critical not
only to the appropriate selection of pilot projects, but to the potential success of
EnTICE.
h) EPA needs to reassess its potential pilot program based on those areas where
verification is expected to make a difference to acceptance of a particular technol-
ogy in a particular market sector when all existing impediments are considered.
i) EPA's recognition of stakeholders as technology users and purchasers, technology
enablers (permit writers and consulting engineers), and technology developers and
vendors should be broadened to include EPA as an important customer, and
particularly the rule and regulation writers, who are engaged in the process that
leads to specification of new technologies on the basis of verification data used in
regulatory impact and cost-to-benefit performance analyses.
j) If structured to optimize opportunities for confidence building with broad stake-
holder representation, and credibility established by carefully selected pilot project
testing, verification could facilitate permitting of new technologies by states, with
reciprocal use of data and information.
In summary, a successful program of verification of environmental technology perfor-
mance also could enhance EPA's role. Yet, the likelihood of success of EnTICE is low unless
EPA is willing to set into motion parallel and complementary programs to address other critical
issues that act as barriers to infusion of alternative technologies into specific market sectors. The
existence of a good, third-party center verification program likely will not be sufficient in and of
itself to substantially accelerate commercial acceptance of new technologies.
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The SAB appreciates the opportunity to provide this review of the EnTICE initiative, an
initiative that could help promote the development and use of environmental technologies. We
look forward to a written response to our recommendations.
Sincerely,
Dr. Genevieve M. Matanoski, Chair
Executive Committee
Science Advisory Board
Dr. IshwarP. Murarka, Chair
Environmental Engineering Committee
Science Advisory Board
Dr. Frederick G. Pohland, Chair
Innovative Technology Subcommittee
Environmental Engineering Committee
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NOTICE
This report has been written as part of the activities of the Science Advisory Board, a
public advisory group providing extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency. The Board is structured to provide
balanced, expert assessment of scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency and, hence, the contents of this report
do not necessarily represent the views and policies of the Environmental Protection Agency, nor
of other agencies in the Executive Branch of the Federal government, nor does mention of trade
names or commercial products constitute a recommendation for use.
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ABSTRACT
The Innovative Technology Subcommittee of the EPA Science Advisory Board's (SAB)
Environmental Engineering Committee (EEC) reviewed the Environmental Technology Innova-
tion and Commercialization Enhancement Program. Overall, the Subcommittee found that
EPA's mission protecting the environment requires the use of effective technologies that are
based on sound scientific principles. Hence, it is in EPA's interest to foster initiatives that can
potentially lead to the identification of more effective environmental technologies. In addition,
because of the growing worldwide interest in applying environmental technologies, EPA now has
the opportunity to participate with other public and private entities in enhancing U.S. competi-
tiveness in the national and international environmental marketplace. However, in providing this
review, the SAB is not making any recommendations as to whether or not EnTICE should be
implemented. A successful program of verification of environmental technology performance
also could enhance EPA's role. Yet, the likelihood of success of EnTICE is low unless EPA is
willing to set into motion parallel and complementary programs to address other critical issues
that act as barriers to infusion of alternative technologies into specific market sectors. The
existence of a good, third-party center verification program likely will not be sufficient in and of
itself to substantially accelerate commercial acceptance of new technologies. The Subcommittee
provided thirteen findings and recommendations addressing: EPA's role, goals, enabling
strategies, imprimatur, verification protocols, barriers and incentives, stakeholders and pilot
programs.
Keywords: environmental technology, innovation, commercialization, third-party centers,
verification, demonstration, pollution prevention, permitting
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U.S. Environmental Protection Agency
Science Advisory Board
Environmental Engineering Committee
Innovative Technology Subcommittee
CHAIR
Dr. Frederick G. Pohland, Weidlein Chair of Environmental Engineering,
Department of Civil and Environmental Engineering, University of Pittsburgh, Pittsburgh, PA
MEMBERS
Dr. Robert B. Pojasek, Senior Project Director, Cambridge Environmental, Inc., Cambridge, MA
Dr. Wm. Randall Seeker, Senior Vice President, Energy & Environmental Research Corp.,
Irvine, CA
CONSULTANTS
Dr. Edgar Berkey, President, Center for Hazardous Materials Research and The National
Environmental Technology Applications Center, University of Pittsburgh Applied Research
Center, Pittsburgh, PA
Dr. Brendlyn D. Faison, Research Microbiologist, Chemical Technology Division, Oak Ridge
National Laboratory, Martin Marietta Energy Systems, Inc., Oak Ridge, TN
Dr. C. Herb Ward, Foyt Family Chair of Engineering and Director, Energy &
Environmental Systems Institute, Rice University, Houston, TX
SCIENCE ADVISORY BOARD STAFF
Mrs. Kathleen W. Conway, Designated Federal Official, U.S. EPA,
Science Advisory Board, 401 M Street, SW., Washington, DC
Mrs. Dorothy M. Clark, Staff Secretary, U.S. EPA,
Science Advisory Board, 401 M Street, SW., Washington, D.C.
m
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U.S. Environmental Protection Agency
Science Advisory Board
Environmental Engineering Committee
CHAIR
Dr. Ishwar P. Murarka, Target Manager, Environmental and Health Sciences Business Unit,
Electric Power Research Institute, Palo Alto, CA
MEMBERS
Dr. Linda M. Abriola, Associate Professor, Department of Civil and
Environmental Engineering, University of Michigan, Ann Arbor, MI
Dr. Calvin C. Chi en, Environmental Fellow, Corporate Remediation,
E.I DuPont Company, Wilmington, DE
Dr. Hilary I. Inyang, Associate Professor, Department of Civil Engineering,
University of Massachusetts, Lowell, MA
Dr. James H. Johnson, Jr., Acting Dean, School of Engineering,
Howard University, Washington, DC
Dr. Wayne M. Kachel, Technical Director, Lockheed Martin Corporation,
Oak Ridge, TN
Dr. Jo Ann Lighty, Associate Professor, Department of Chemical and Fuels Engineering,
University of Utah, Salt Lake City, UT
Dr. James W. Mercer, President, GeoTrans, Inc., Sterling, VA
Dr. Frederick G. Pohland, Weidlein Chair of Environmental Engineering,
Department of Civil and Environmental Engineering, University of Pittsburgh, Pittsburgh, PA
IV
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Dr. Robert B. Pojasek, Senior Project Director, Cambridge Environmental, Inc.
Cambridge, MA
Dr. Wm. Randall Seeker, Senior Vice President, Energy & Environmental
Research Corp., Irvine, CA
SCIENCE ADVISORY BOARD STAFF
Mrs. Kathleen W. Conway, Designated Federal Official, U.S. EPA,
Science Advisory Board, 401 M Street, SW., Washington, DC
Mrs. Dorothy M. Clark, Staff Secretary, U.S. EPA,
Science Advisory Board, 401 M Street, SW., Washington, D.C.
v
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 5
2.1 Background 5
2.2 Charge 5
2.2.1 Primary Issues 5
2.2.2 Secondary Issues 6
3. FINDINGS AND RECOMMENDATIONS 8
3.1 General Comments 8
3.2 Response to Primary Issues 9
3.2.1 Self-Sufficiency and Costs of Verification Centers 9
3.2.2 EPA Imprimatur and Oversight 11
3.2.3 Accountability and Measures of Success 13
3.3 Response to Secondary Issues 14
3.3.1 Technology Classes/Markets, Barriers/Incentives, Stakeholders 14
3.3.2 Verification vs. Certification 15
3.3.3 Pollution Prevention 15
3.3.4 Technology Categories and Prioritization 17
3.3.5 State Permits and Reciprocity 17
GLOSSARY
APPENDIX A: Documents Received from the Agency
VI
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1. EXECUTIVE SUMMARY
At the request of the Office of Environmental Engineering and Technology Demonstra-
tion (OEETD) in the EPA Office of Research and Development (ORD), the Innovative Technol-
ogy Subcommittee of the EPA Science Advisory Board's (SAB) Environmental Engineering
Committee (EEC) conducted a review of the Environmental Technology Innovation and
Commercialization Enhancement Program (EnTICE). EPA has initiated EnTICE with the intent
to verify the cost and performance of environmental technologies, and thereby bolster their
credibility and potential for entrance into the national and international marketplace. In providing
this review, the Subcommittee is not making any recommendations as to whether or not EnTICE
should be implemented.
The proposed strategy is to establish third-party centers, temporarily supported by EPA,
to generate credible data and information for the marketplace and permitting arenas, that would
help decision-makers promote the use of innovative technologies in a more informed and
confident manner. The Subcommittee's charge was to review this strategy and both primary and
secondary issues. The responses to primary issues focused on costs and early self-sufficiency of
verification centers, EPA imprimatur and oversight, accountability, and measures of success.
Responses to secondary issues focused on the stakeholders, barriers and incentives, verification
protocols, pollution prevention, technology categories and priorities, and state permitting and
reciprocity. To address the charge and breadth of issues, the discussions, opinions and recom-
mendations sometimes verged on or were related to policy matters as well as the technical
assessments reflecting the experiences and expertise of the review participants.
The Subcommittee's major findings and recommendations are summarized as follows:
a) EPA has an opportunity to play a leadership role in addressing technology
development and U.S. competitiveness in the environmental marketplace. A
successful program of verification of environmental technology performance could
enhance this leadership role.
b) The goal statement for EnTICE is too broad to guide the selection of pilot
programs on a priority basis. To enhance the potential for EnTICE to successfully
accomplish its goals in a timely fashion, a modified goals statement is proposed,
i.e., "To produce credible performance and cost data on new environmental
technologies so that the entrance of new technologies into the domestic and
international marketplace can be encouraged."
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c) The existence of a good, third-party center verification program likely will not be
sufficient in and of itself to substantially accelerate commercial acceptance of new
technologies. The likelihood for success of EnTICE is low unless EPA sets into
motion parallel and complementary programs to address other critical issues that
act as barriers to infusion of alternative technologies into specific market sectors.
Therefore, EnTICE should be initially focused on those market and technology
areas where the existence of a verification program is likely to make a difference
to market acceptance.
d) The establishment of third-party verification centers is a preferred implementing
model, but it is impractical to expect that every verification center will be self-
supporting in three years, and that the customer will bear the cost of testing
without incentives or tangible benefits. This is a significant problem for small
businesses, where verification may be seen as an additional barrier for technology
developers to overcome. Moreover, full endorsement of the verification center
program is not warranted if EPA incurs long-term obligations should the centers
fail to become fiscally independent.
e) The EPA imprimatur is considered essential to verification, especially in interna-
tional markets. However, it is important that the imprimatur not be misrepre-
sented as EPA giving approval or certification of a technology, and that EPA
provide strong oversight and audit programs to assure fairness and consistency in
the application of the verification process. Only data generated in a prospective
manner according to EPA-approved protocols and audit procedures should be
considered proof of verification if an EPA "seal" is to be provided.
f) An EPA "seal" should be conferred only on the verification protocol, with
accountability and measures of success established up front. Effective use of
advisory panels representing all stakeholders would help establish these elements,
consonant with the goal of EnTICE and its verification protocols.
g) The development of a generic protocol for the various environmental technology
classes is not recommended. Rather, a detailed examination of issues surrounding
various verification protocols specific to each class of technology designated for a
specific market is advocated. All impediments need to be comprehensively
reviewed with broad stakeholder involvement early in the execution of the
verification process for each technology class for each market sector.
h) The EPA has recognized many of the stakeholders, i.e., technology users and
purchasers, technology enablers (permit writers and consulting engineers), and
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technology developers and vendors. In addition, one of the most important
customers is EPA itself, particularly those engaged in writing rules and regulations
who can better specify new technologies on the basis of verification data used in
regulatory impact and cost-to-benefit performance analysis. Therefore, the
regulation writer for each specific market sector should be involved early in the
process of defining market impediments and the proper role of verification.
i) The EPA distinction between verification and certification, and the intent to verify
and not certify innovative environmental technologies, is endorsed. The concern
is not so much with the definition to establish or prove the validity of performance
of a technology under specific, predetermined criteria or protocols, and post-data
collection quality assurance procedures, but the issue of whether verification can
make a difference in meeting EnTICE goals in the final analysis.
j) It is not appropriate to characterize pollution prevention as a potential environ-
mental technology class. Rather, pollution prevention should be considered an
integral part of sound environmental management strategies involving a hierarchy
of choices, i.e, treatment, recycling and treatment avoidance. The role of pollu-
tion prevention in the EnTICE program should be explored within this context.
k) The EPA should select initial priority technology categories for verification on the
basis of those areas where verification is expected to make a significant difference
to market acceptance. Therefore, EPA should reassess its potential pilot program
with this criterion preeminently in mind, and make choices with the explicit use of
this criterion in testing the fundamental premises of EnTICE, i.e., that verification
will bolster the credibility of technology and thereby
accelerate entrance into the marketplace.
1) The formulation of a middle management committee to make the vital link
between the verification activities and EPA efforts to remove other barriers to
acceptance of new technologies is considered critical to success of EnTICE. Each
pilot project should engage all stakeholders to help define barriers to implementa-
tion and the proper role of the verification process in addressing these barriers.
m) Verification has the potential to facilitate permitting by the states, because it is
likely to give permit writers more confidence in accepting the performance of new
technologies with which they are not personally familiar. Reciprocal use of data
between the states in permitting technologies is also a potentially desirable feature
of the verification program. Establishing and using an informational network on
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EnTICE technologies between states would further enhance the process and
likelihood of success.
Details of each of these findings and recommendations, along with fortifying commentary,
are presented herein.
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2. INTRODUCTION
2.1 Background
At the request of the Office of Environmental Engineering and Technology Demonstra-
tion (OEETD) in the EPA Office of Research and Development (ORD), the Innovative Technol-
ogy Subcommittee of the EPA Science Advisory Board's (SAB) Environmental Engineering
Committee (EEC) conducted a review of the Environmental Technology Innovation and
Commercialization Enhancement Program (EnTICE). The EPA has initiated EnTICE with the
intent to verify the cost and performance of environmental technologies and thereby bolster their
credibility and potential for entrance into the marketplace. The proposed strategy is to establish
third-party centers with initial EPA support. These centers would generate credible data and
information for the marketplace and permitting arenas, where decision-makers then can promote
the use of innovative technologies in a more informed and confident manner.
The Subcommittee received an OEETD white paper describing EnTICE and options for
structuring, as well as a written charge for review and comment. EPA personnel briefed the
Subcommittee at its May 2-3, 1994 public meeting.
The charge to the Subcommittee was more directed toward economic and policy issues
than is usually the case with SAB reviews which, in general, focus on more technical questions.
The SAB believes that it is appropriate to respond to this charge in this case because a) the
Agency made the request, and b) the scientific and engineering disciplines includes a sensitivity
toward applying technologies within a social context. To address this latter concern, the
Subcommittee membership was augmented with individuals having considerable experience
dealing with such issues. For these reasons, this report contains management- and policy-
oriented recommendations.
The written charge included a request for the views and advice of the EEC on the
following primary and secondary issues. (These issues are presented from the charge verbatim.)
2.2 Charge
2.2.1 Primary Issues
a) Is it practical to target each center to be self-supporting in 3 years (±)? Can
industry bear the expense?
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b) How important is it that the verifications carry EPA's imprimatur? Would
verifications that don't carry EPA's seal but just that of a 3rd party center have
sufficient credibility to open doors in the marketplace and the permitting arena?
How important is EPA's oversight in ensuring consistency and rigor across 3rd
party centers?
2.2.2 Secondary Issues
a) Roles within the Alternative Approach to Verification
i) What is the appropriate mix of federal, state, 3rd party, and vendor roles
and responsibilities?
ii) Are there incentives that are necessary for any or all of the parties to
ensure success?
iii) Will verification contribute to more rapid, broader acceptance of new
technologies and accelerate reciprocal use of data among states?
b) Verification vs. Certification — Related to the value of verification is the distinc-
tion between verification and certification. Verify: To establish or prove the truth
of the performance of a technology under specific, predetermined criteria or
protocols and post-data collections quality assurance procedures. Synonyms are
confirm, corroborate, substantiate, and validate. Certify: To guarantee a technol-
ogy as meeting a standard or performance criteria into the future. Synonyms are
ensure, warrant, and guarantee. EPA has designed the EnTICE program to
verify, not certify.
c) Is there value in verifying pollution prevention technology? Are the customers
different?
d) Are there particular technology categories such as small drinking water systems
for which verification would be particularly useful? How should initial priority
technologies be selected?
e) Will verification facilitate permitting done by states? Will it lead to reciprocal use
of data in permitting between states?
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f) Verification process credibility is clearly a central value. How can accountability
and credibility best be assured in designing the program? Must the data be
independently generated or will vendor data be adequate?
g) What are the measures of success for a verification program? Number of technol-
ogies verified? Sales records? Increased number of permits? Faster processing of
permits? Some measure of environmental improvement? Reciprocal permitting
agreements among the states? Breadth (or depth) of coverage of the verification
process in terms of types of technologies, processes, and products covered?
Reduction of time to market or of time for permit decisions?
For the benefit of the Agency and the public, the Subcommittee summarized its prelimi-
nary findings at the end of the meeting on May 3, 1995. This information exchange resulted in
some realignment of the primary and secondary issues of the charge, i.e., accountability and
measures of success were considered primary issues by the Subcommittee and were, therefore,
moved to that category in the following presentation of findings and recommendations.
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3. FINDINGS AND RECOMMENDATIONS
3.1 General Comments
EPA's mission of protecting the environment requires the use of effective technologies
that are based on sound scientific principles. Hence, it is in EPA's interest to foster initiatives like
EnTICE that can potentially lead to the identification of more effective environmental technolo-
gies. In addition, because of the growing worldwide interest in applying environmental technolo-
gies, EPA now has the opportunity to participate with other public and private entities in
enhancing U.S. competitiveness in the national and international environmental marketplace. A
successful program of verification of environmental technology performance likely will enhance
EPA's role.
After reviewing the various documents provided by the Agency, receiving the EPA
briefing, and holding discussions on the relative merits and potential directions of the EnTICE
initiative, the Subcommittee concluded that the stated goal of substantially accelerating the
entrance of new environmental technology into the domestic and international marketplace is too
broad to be attained as currently constructed and scheduled. The Subcommittee also concludes
that the existence of a good verification program will not be sufficient in and of itself to
substantially accelerate commercial acceptance of new technologies. In addition, the goal
statement, i.e., "to accelerate the development and use of environmentally beneficial technology
by systematically evaluating, verifying, and broadly disseminating information on the performance
of technology innovation," was considered too broad to be useful in selecting or supporting pilot
programs on a priority basis. Therefore, to enhance the potential for EnTICE to successfully
accomplish its goal in a timely fashion, the Subcommittee suggests the goal statement for
EnTICE be modified to read:
To produce credible performance and cost data on new environ-
mental technologies so that their entrance into the domestic and
international marketplace can be encouraged.
While an appropriate level of verification of a technology may be desirable and neces-
sary, it will not be sufficient to guarantee market acceptance for a new technology, because there
are so many other controlling factors, e.g., economic, social, and political barriers. Verification
may be more desirable in certain market sectors or technology categories than in others, with the
possibility that simple verification might not make any difference at all, i.e., if barriers are
significant, some resolution may need to precede verification for EnTICE to succeed. Therefore,
the efforts of EnTICE should be primarily focused on those market and technology areas where
the existence of a verification program is likely to make a difference to market acceptance.
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In developing the framework for EnTICE, EPA needs to address both how verification
can succeed and how barriers can be diminished. Otherwise, such barriers may adversely affect
market entry and impede the potential success of new technologies. It is not clear to the
Subcommittee how EnTICE, with centers operated on a third-party franchise basis within the
context of the Environmental Technology Initiative (ETI), will or should address the variety of
regulatory, market, financial, and technology barriers which are usually far more critical to
determining market acceptance. The issue appears to be a systems problem, which cannot be
resolved by addressing only one element, such as technology verification. Expectations for
EnTICE as currently structured should not be set so high that, without attending to all crucial
elements, success will be limited. Hence, based upon the evidence presented, the likelihood for
success of EnTICE is low unless EPA sets into motion parallel and complementary programs to
address other critical issues, especially impacts of regulations on acceptance of alternative
technologies in specific market sectors.
There is some concern whether the premise that verification will increase market
acceptance of a new technology is always valid. Hence, this premise needs to be tested early,
preferably by the selection of appropriate pilot programs. Yet, it does not appear that the pilot
programs presented for consideration were developed with this purpose in mind. If this
assessment is correct, such a premise may constitute a fatal flaw in the program, and lead to
needless expenditure of resources without achieving the success so urgently sought.
3.2 Response to Primary Issues
The primary issues are addressed herein in the order of their listing in the charge, with the
exception that the original secondary issues on accountability and measures of success (issues
2.2.2.f) and 2.2.2g)), as noted previously, were considered of primary concern.
3.2.1 Self-Sufficiency and Costs of Verification Centers
It is not practical to expect that every verification center will be self-supporting within
three years. This finding partially is based on the fact that there are no existing center models in
the environmental field that indicate such financial performance is probable. Therefore, verifica-
tion centers will represent a concept whose tangible benefits to industry will take time to develop
and demonstrate. The goal of self-sufficiency is a particularly significant problem for small
businesses that can least bear the cost.
If a customer stands to benefit from the verification process, the customer should share
at least some part of the cost of testing. On this basis, some centers supporting certain technol-
ogy areas can be expected to do better financially than others. However, it is very unlikely that
all centers will be self-sufficient within three years—or, in fact, within five-to-seven years—and
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some centers may never become self-supporting. Such temporal dimensions reflect some of the
current barriers that exist regarding market introduction of new environmental technologies.
The Subcommittee's views on the difficulties that verification centers will face in
becoming self-sufficient are based on the following:
a) The benefits of verification in the marketplace are not likely to be immediately
recognized by the private sector in terms of increased sales. It will take verifica-
tion centers several years to develop widely accepted protocols, build credibility
among all stakeholders, and demonstrate the value of their testing results. These
activities must occur before a significant market response is likely. Based on other
experiences, e.g., the findings of the National Environmental Technology Applica-
tions Corporation (NETAC),1 a three-year time frame. Environmental technology
innovation, development, demonstration and commercialization typically takes ten
years or longer.
b) Overcoming the verification barrier for innovative technologies will not necessarily
remove the host of other barriers impeding the introduction and acceptance of
new technologies, whether engendered in the public or private sectors. Thus, the
intensity of any positive impact that verification centers can have will be reduced
in the short term and delay their ultimate benefit beyond a three-year time frame.
c) Verification centers cannot be expected to be self-supporting until such time as
the benefits provided by their programs clearly outweigh the costs to the users. It
may take many years for this to happen, based on the approval and technology
selection cycles operating in the environmental field at the time. For some
technology sectors, it may never happen without major systemic changes.
d) Because the majority of the technology developers are small businesses without
substantial resources, their ability to participate in verification is likely to be low.
They will have a difficult time absorbing an added development cost in an uncer-
tain marketplace. Therefore, the verification centers will likely have to subsidize
small business participation on an ongoing basis, which will further affect their
ability to become financially self-sustaining.
1 National Environmental Technology Applications Center (NETAC), April 1994. Barriers to
Environmental Technology Commercialization, 400-5408-00, Pittsburgh, PA.
10
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The Subcommittee has great concern that operation of the verification centers will come
to be seen as an additional barrier for technology developers to overcome. This concern would
be especially true if the protocols eventually developed for use by the centers are costly to
implement. Under this circumstance, the use of the centers by the customer (especially small
business) will be limited, and their likelihood of becoming self-sufficient will be decreased.
The ability of industry and other private enterprise to bear the expense of the verification
center program is unclear at this time. Industry will bear it if they receive a benefit directly
related to what the centers provide. They will not bear it if they do not sense a clear benefit. At
the present time, a compelling benefit to be provided by the centers is not clear, again because
verification is only one of the many barriers that must be overcome. Industry will recognize this
and expect a more systematic approach to the removal of other barriers if they are to pay for
verification.
Finally, the Agency should recognize that the verification center program could impose
long-term obligations on EPA, should the centers fail to become fiscally independent. This, again
emphasizes the need for EPA to undertake a series of integrated actions to overcome or
dramatically reduce all barriers to infusion of new technologies into the marketplace.
3.2.2 EPA Imprimatur and Oversight
EPA's imprimatur is essential to verification, especially for international markets.
However, it is important that the imprimatur not be misrepresented as EPA giving approval or
certification of a technology. A process of third-party verification is considered better than
nothing, but is unlikely to open doors in the marketplace until it becomes recognized as essential.
Moreover, the reputation of the third-party center will determine the degree of impact in the
permitting arena. Yet, the Subcommittee concludes that to derive the expected benefits from
verification, the verifier's "seal" must be linked directly with EPA. Therefore, strong EPA
oversight is absolutely essential and will require a correspondingly strong audit program to assure
fairness, consistency and accuracy of applications of the verification process.
Environmental technology performance verifications must be accomplished through a
cost-effective, timely, and efficient process that is organized in a holistic manner and audited by
the Agency with an EPA imprimatur recognized worldwide. However, the process must not be
self-defeating, bureaucratic, or burdensome. Hence, for EnTICE to be a successful endeavor, the
development and careful design and operation of the proposed third-party franchise model of
focused verification centers is the approach preferred by the Subcommittee in lieu of the other
potential options, i.e., EPA SITE Model, the Institute Model, and the Independent Centers
Model. The system could take several forms, but must result in verifications that are clearly
consonant with the goal of the program and then carry EPA's "seal". Where possible, EPA
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should supervise and approve preparation of verification procedures and protocols for sectors as
well as protocols for verification of specific technologies. Moreover, verification procedures
should be developed to be consistent with those followed by other countries, thereby facilitating
international competitiveness and data compatibility, e.g., performance-based specifications have
been published by the International Organization for Standards (ISO). In addition, EPA
verification should include both system and performance audits of individual technologies,
independent of the verification process. Performance audits must be conducted with "open door"
access to minimize the potential for fraudulent practices.
The Subcommittee also recommends consideration of another technology verification
approach which could serve as a valuable adjunct to the third-party center concept. This
approach would be prospective rather than retrospective, and would engage the assistance of
technology developers in generating the test data needed for verification. Only data generated
with EPA-approved protocols and audit procedures would be considered for proof of verifica-
tion. Historical data, regardless of its origin or quality, would not be used for verification. Such
a prospective approach is considered advantageous to ensure and sustain the credibility of the
EPA "seal".
3.2.3 Accountability and Measures of Success
To establish accountability and credibility for the verification process envisioned by
EnTICE, the program must be designed to embrace standard and/or EPA-approved methods.
Effective use of an advisory panel representing the stakeholders, as well as internal and external
specialists and possible third-party auditors, would provide quality assurance with responsibility
for verification assigned accordingly. Hence, those responsible for the verification protocol and
its use would share accountability for the efficacy of a particular technology. In such a manner,
accountability protocols could also stipulate levels of liability shared by all stakeholders from
technology conception to implementation.
Key to accountability will be the sufficiency of the verification protocols, which should
include such elements as sample acquisition, storage, testing/analysis and evaluation, developed in
a manner that each integral element can also be verified by a third-party entity. If developed to
include quality assurance/quality control procedures, with an opportunity to track costs, such
data could encourage more efficient and cost-effective technology development and use.
Formalized verification reports, including performance data, would reveal the capacity of a
particular technology to achieve a defined target, e.g., cleanup standards, pollution prevention
goals, resource conservation goals, or any number of other goals, all of which would need to be
stipulated in advance by EPA in conjunction with the stakeholders. Such a prospective proce-
dure essentially would establish relative measures of success that would be both tangible and
quantifiable, and would facilitate the final decision on assigning EPA's imprimatur. Moreover, it
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would allow technology comparisons, thereby promoting further development and refinement.
These comparisons could be both quantitative and qualitative, i.e., better, cheaper, faster and
safer, with the latter based on quantitative information, e.g., meeting standards, lower costs,
speed of permitting/actual cleanup, and public/worker protection, respectively.
The EPA "seal" should be conferred only on the verification protocol, and not on the
various entities engaged in its implementation. The Agency should not "bless without intent" by
endorsing a verification process that allows extension beyond establishing or providing perfor-
mance of a technology under specific, predetermined criteria or protocols and quality assurance
procedures. Hence, measures of success need to be established up front, and although in the final
analysis, responsibility for verification within the EnTICE initiative rests with EPA through
oversight and audit, third-party entities play a role and could be engaged by an appropriate
permitting system. Early involvement of the stakeholder groups would help formulate the
elements of a verification protocol leading to EPA validation of a particular technology in
whatever manner is deemed appropriate by consensus.
3.3 Response to Secondary Issues
3.3.1 Technology Classes/Markets, Barriers/Incentives, Stakeholders
The Agency has defined a number of potential environmental technology classes that
represent a broad range of industry sectors, technologies, regulatory structures, and media.
Based on the collective experiences of its members, the Subcommittee concludes that the
development of generic protocol for such a broad range of technology classes would be
technically infeasible, and thus advocates a more detailed examination of the issues surrounding
the various verification protocols specific to each class of technologies designated for the specific
markets. Moreover, the verification process cannot be separated from addressing the other
barriers or impediments to entrance of new environmental technology in a particular technology
class for a particular market segment. The basic premise of the EnTICE initiative as currently
proposed is that the lack of properly structured verification protocols for innovative technology is
the critical barrier to market entry and success of new technologies. However, the Subcommittee
suggests that the lack of an adequate verification protocol is most likely only one of the barriers
to the commercialization of innovative technologies and often is not the most critical. Econom-
ics, liability, and regulatory uncertainty are examples of other often more critical barriers to
commercialization. Thus, the impediments need to be comprehensively reviewed with broad
stakeholder involvement early in the execution of the initiative for each technology class for each
market sector.
Barriers to the acceptance of new technologies can be broadly classified into the
following categories; regulatory, market, technology, financial and management. At the present
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time, there are few incentives which encourage regulators and technology purchasers and users to
introduce new technologies. Clear benefits must be established for all stakeholders to increase
their acceptance of new technologies. Therefore, the Agency should first determine all of the
barriers for the particular market sector and innovative technology class, and then address them
in a systematic and integrated manner. An understanding of what drives the development of new
technology is key to this determination. Even the most effective verification process will be
unsuccessful if there are not adequate markets to warrant the efforts of technology suppliers.
After reviewing the issues with the stakeholders, the Agency can then consider where the
verification process fits into the process of developing a new innovative technology for the
particular market sector. The goal of the verification process is then to generate credible data for
a particular technology class for a particular market segment that can then be appropriately
integrated with the results of other efforts to minimize impediments to commercialization. Thus,
specific stakeholders must be engaged early in the process for each market segment and each
technology class.
The EPA has recognized many of the customers who should be included as stakeholders,
i.e., technology users and purchasers, technology enablers (permit writers and consulting
engineers), and technology developers and vendors. In addition, one of the most important
customers is EPA itself and, in particular, regulation writers who are responsible for establishing
new compliance standards. Therefore, these rule or regulation writers are engaged in the process
that leads to specification of new technology markets through standards such as Reasonably
Achievable Control Technology (RACT), Best Available Control Technology, (BACT) and
Maximum Achievable Control Technology (MACT), and they are clear consumers of verification
data on innovative technologies. Without this process and the response to performance-based
standards, many of the markets for environmental technologies will not be developed. These
regulation writers can use the verification data on new technologies in their regulatory impact
and technology cost-to-benefit performance analysis. Without the data, the regulation writer has
little tangible basis to embrace new technologies and thereby encourage implementation.
Therefore, the regulation writer for each specific market sector should be engaged along with
others early in the process of defining market impediments and the proper role of verification
processes.
3.3.2 Verification vs. Certification
The Subcommittee agrees with the EPA distinction between verification and certification,
and the intent to verify and not certify innovative environmental technologies. The Subcommit-
tee's concern is not so much with the definition to establish or prove the validity of performance
of a technology under specific, predetermined criteria or protocols and post-data collection
quality assurance procedures, but whether such verification can make a difference in meeting
EnTICE goals in the final analysis.
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3.3.3 Pollution Prevention
Pollution prevention has been characterized in the EnTICE materials as a potential
environmental technology class. In actuality, pollution prevention is an integral part of a sound
environmental management strategy. It involves choices being made in a hierarchy as follows:
a) using treatment technology (end-of-pipe);
b) reducing need for treatment technology by utilizing recycling; and,
c) avoiding the need for treatment technology by using pollution prevention practices
and technology (i.e., often referred to as cleaner production).
Environmental and regulatory goals often can be obtained using any of these approaches.
However, the treatment technology often shifts the contaminants from one medium to another if
destruction, degradation and/or isolation are not achieved.
As described below, there clearly is value in verifying pollution technologies, because
application of the hierarchy leads to discrete decision-making on technologies. Viewed in the
way described, the customers of verification are not really any different in this area.
Using the proposed "Coatings/Pollution Prevention" verification pilot as an example, a
company could utilize the following options within the hierarchy:
a) install a fume incinerator to destroy volatile organic compounds (VOCs) and
combustible hazardous air pollutants (HAPs);
b) recycle solvents and paints; and,
c) use low-VOC or no-VOC coatings and hardware that allow for the more efficient
transfer of paint to the surface.
Each of these choices could benefit from a verification activity as proposed by EnTICE.
For the treatment technology, the most efficient destruction of pollutants without transferring
them to other media should receive independent verification. This information is often difficult to
evaluate from vendor claims. The extent to which recycling technology does not shift contami-
nants between media and leads to resource conservation should also be verified. Finally, vendor
claims for the hardware and substitute coating material are often misleading. Independent,
objective and credible verification would lead to more informed decision-making on the part of
the user.
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The Subcommittee encourages the EPA to explore the proper role of pollution prevention
in EnTICE and within the context of what has been stated above. Other fruitful areas of such
exploration include that of cleaning technologies as another potential pilot demonstration.
3.3.4 Technology Categories and Prioritization
EPA should select initial priority technology categories for verification solely on the basis
of those areas where verification is expected to really make a difference to market acceptance.
This is the key criterion with respect to piloting the verification center concept. Unfortunately,
not all currently identified pilot program areas necessarily satisfy this criterion. From the
Subcommittee's cursory review of these programs, it is not at all clear that verification will make
a real difference in most of the areas being considered in EnTICE. However, there may be key
issues or circumstances with which the Subcommittee is not aware. Therefore, the Subcommit-
tee recommends that EPA reassess the potential pilot programs with this criterion preeminently in
mind, and make choices with the explicit use of this criterion. This will make evaluation of the
pilot program more effective as a way to test the premise of EnTICE.
The verification action plan indicates that the EPA "is considering the formulation of a
middle manager committee to make the vital link between the Agency's verification activities and
its efforts to remove" other barriers. The Subcommittee concludes that this link is critical and
should not be an afterthought, but rather the verification process should be integrated fully with
the other efforts. From initiation, each pilot project should work to define the other barriers to
implementation and the proper role of verification with stakeholders, and then the verification
process should be fully integrated with other efforts to address these barriers.
3.3.5 State Permits and Reciprocity
Based on the collective experiences of its members, the Subcommittee believes that
verification has the potential to facilitate permitting done by the states, because it is likely to give
permit writers more confidence in accepting the performance of new technologies with which
they are not personally familiar. In the same vein, reciprocal use of data in permitting between
the states is also likely to increase through such a verification program.
Potentially beneficial results from verification accrue because they address the current
reluctance of permit writers and regulators to accept new technology. Permit writers at the state
level are often unwilling to take risks on newer technologies with which they have little experi-
ence or personal knowledge. Independent verification will provide some level of technical
confidence to them, especially if the protocols on which the results are based are well conceived
and implemented. However, verification may have no impact if the proposed use of a new
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technology is different from its verified application. In addition, the other key barriers must also
be addressed by the Agency in a holistic fashion.
States must be important participants in the verification center process, in order to
improve the likelihood that ultimate permitting and reciprocity will be facilitated. EnTICE should
also keep a database of state permit writers who have allowed the use of innovative technologies.
The language they utilized may be of interest to their colleagues in other states as they prepare
similar permits. As in the case of the rule writers, permit writers must be actively involved in the
stakeholder group for each segment of the program. In addition, because consulting engineers
often assume the lead role in permit negotiations and the specification of technologies, they
should also be actively involved with their clients and the ultimate users of the EnTICE program
in the stakeholder groups.
With all groups actively involved in the EnTICE program development, there is an
increased likelihood that there would be reciprocal use of data in permitting and rule-making
between the states. An extensive, but informal, informational network already exists in this area.
Providing timely verification information on EnTICE technologies to this network will be critical
to the success of the program. Previous EPA efforts have neither effectively utilized this
network nor provided timely information to these constituencies.
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GLOSSARY
BACT
Certify
CFR
EEC
EnTICE
EPA "seal"
ETI
HAPs
Imprimatur
Independent Centers Model
Institute Model
ISO
MACT
NETAC
OEETD
ORD
RACT
SAB
SITE Model
Third-Party Franchise Model
Verify
Best Available Control Technology
To guarantee a technology as meeting a standard or perfor-
mance criteria into the future.
Code of Federal Regulations
Environmental Engineering Committee of the Science
Advisory Board, U.S. EPA
Environmental Technology Innovation and Commercializa-
tion Enhancement
an official indicator of fair and impartial evaluation, not
certification or verification
Environmental Technology Initiative
Hazardous Air Pollutants
a sign or mark of approval
as described in the EPA document, "Verification Program:
Independent Centers Model"
as described in the EPA document, "Verification Program:
Institute Model"
International Organization for Standards
Maximum Achievable Control Technology
National Environmental Technology Applications Center
Office of Environmental Engineering and Technology Dem-
onstration
Office of Research and Development
Reasonably Achievable Control Technology
Science Advisory Board
as described in the EPA document, "Verification Program:
EPA SITE Model"
as described in the EPA document, "Verification Program:
3rd Party Franchise Model"
To establish or prove the truth of the performance of a
technology under specific, predetermined criteria or proto-
cols and post-data collections quality assurance procedures.
VOCs
Volatile Organic Compounds
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APPENDIX A: Documents Received from the Agency
1. Memorandum, "EnTICE Review" from Mr. Alfred Lindsey, March 13, 1995 (with
attachments named below)
2. "SAB Engineering Committee Review, EnTICE, Environmental Technology Innovation
and Commercialization Enhancement Program" (undated)
3. "Draft Verification Action Plan," Environmental Technology Innovation, Commercializa-
tion and Enhancement Program, January 18, 1995
4. "Verification Program: EPA SITE Model", (undated)
5. "Verification Program: 3rd Party Franchise Model", (undated)
6. "Verification Program: Institute Model", (undated)
7. "Verification Program: "Independent Centers Model", (undated)
8. EnTICE brochure, February 1995
9. EnTICE: EPAs Technology Verification Program, distributed at May 2-3, 1995,
Environmental Engineering Committee meeting.
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DISTRIBUTION LIST
The Administrator
Deputy Administrator
Regional Administrators, Regions 1-10
Assistant Administrators
Director, Office of Air and Radiation
Director, Office of Atmospheric and Indoor Air Programs
Director, Office of Policy Analysis and Review
Director, Office of Environmental Processes and Effects Research
Director, Office of Policy Analysis
Director, Climate Change Division
EPA Headquarters Library
EPA Regional Libraries
EPA Research Laboratory Directors
National Technical Information Service
Congressional Research Service
Library of Congress
Office of Technology Assessment
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