1992  NACEPT  MEMBERSHIP
Dr. John Saw-hill
Nature Conservancy

Dr. David T. Allen
Aitstiate l*nffisorof'Chemical'Engineering
University of California-Los Angeles

Jacqueline Aloisi dc Laudcrel
Industry and Environment Office
United Nations Environment Programme

Paul Arbesman
Carparate Director'forPollution Control
Allied Signal Corporation

Dr. Nicholas Ashford
/luesiate Pnfttsor ofTechnology andPolicy
Center forTcchnology, Policy and Industrial
Massachusetts Institute of Technology

Dr. R.Darrv-1 Banks
DirtilttT afTedinslogy and Environment
World Resources Institute

Waller Barber
Groundwatcr Technology, Inc.

Dr. John Boland
Prt/iuur s/Geegrapby
anil Environmental Engineering
The Johns Hopkins University

Dr, Kofi B. Bota
I'ite Pnsiileat/or Research and Sponsored
Clark Atlanta University

George Britton
Deputy City Manager
Water and Environment Services
City of Phoenix

Dr. Quincak'e Brown
Exeat titt Diretlar
Water Environment Federation

Dr. Paul Busch
Malcolm-Pintle, Inc.

William W. Carpenter
lrke President, Technology Applications
Martin Marietta Energy Systems, Inc.

Dr. Anthony Cortese
Dtmi, Center for Environment Management
Tufts University

I lonorable Larry Cole
City of Bcavcrton, Oregon

Tom Davis
Safety and Engineering Affairs
Thomas W. Devine
Corf orate Vice President, Regulatory Affairs
RMT, Inc.

Dr. Sylvia Alice Earle
Chief Scientist, NOAA
Department of Commerce

John Easton
Assistant Secretary
Domestic and International Policy
Department of Energy

Terrence Foecke
Waste Reduction Institute and
National Pollution Prevention

Dr. Robert L. Ford
Center for Energy and Environment Studies
Southern University

Scott E. Fore
Vice President
Environment, Health and Safety
Safety Kleen Corporation

J. William Futrell
Environmental Law Institute

Robert Herbst
Washington Representative
Tennessee Valley Authority
Dr. Erhard F. Joeres
Chair, Water Resources Management Program
Institute for Environmental Studies

Lillian Kawasaki
General Manager
Department of Environmental Affairs
City of Los Angeles

Dr. John Liskowitz
Executive Director
Hazardous Waste Institute

Tom Looby
Office of the Environment
Colorado Department of Health

Brigadier General James McCarthy
The Civil Engineer

R.NickOdom,Jr.   .
Vice President, Environmental Services
Springs Industries

John Palmisano
AER*X, Inc.

Nancy E.Pfund
General Partner
Hambrecht & Quist
Dr. Bruce Piasecki
Rensselaer Polytechnic Institute

Frank R. Pope
Vice President
Technology Funding, Inc.

James A. Power, Jr.
Director (Retired)
Division of Environment
Kansas Department of Health

Walter R. Quanstrom
Vice President
Environmental Affairs and Safety
Amoco Corporation

Dr. Robert Repetto
Senior Economist and Program Director
World Resources Institute

Don Richardson
Executive Director
Arkansas Association of Conservation Districts

Martin E. Rivers
Executive Vice President
Air and Waste Management Association

Dr. Lawrence Ross
Center for Waste Reduction Technologies
American Institute of Chemical Engineers

Samuel A. Schulhof
Director, Environmental Research Center
General Electric Corporate Research 8c

Margaret Seminario
Department of Occupational Safety and Health

Dr Wayne Tamarelli
Dock Resins

Eugene Tseng
E. Tseng and Associates

Perry Wallace
Professor of Law
Washington College of Law
The American University

William F.Willis
Senior Executive Officer and President Resource
Tennessee Valley Authority

Deborah L. Wince-Smith
Assistant Secretary for Technology Policy
Department of Commerce



               FOR ENVIRONMENTAL
 The National Advisor}'' Council for Environmental Policy and Technology is an independent

  advisory committee to the Administrator of the U.S. Environmental Protection Agency.

The findings and recommendations of the Council do not necessarily represent the views of the

                  Environmental Protection Agency.

                                      WASHINGTON, DC 20460
                To the Reader:
                                                                                    OFFICE OF
                                                                            THE ADMINISTRATOR
                I am pleased to provide you with the Office of Cooperative Environmental Management's
             "Progressive Environmental Management: Leveraging Regulatory and Voluntary Action."
             This document describes the highlights of the National Advisory Council for Environmental
             Policy and Technology (NACEPT) and its Committees' work during 1991 and 1992.
                We are beginning a new era in environmental protection primarily built upon successes
             grounded in traditional approaches, but we have reached limitations in many of these areas.
             We need to recognize that businesses are taking their role in environmental protection very
             seriously but that the regulatory programs provide important incentives. NACEPT's work in
             1992 looked at many of the new trends and ideas with particular focus on pollution prevention.
             It is interesting and also encouraging that the Committees, while they approached their tasks
             from very different perspectives, identified opportunities for the Agency that are very much in
             sync with many of the initiatives and directions the Agency has already endorsed. The
             Committees urge us to move even more aggressively, especially in the areas of:

                •   Enhancing EPA leadership in the new environmental era
                •   Promoting environmental literacy and workforce competence
                •   Encouraging voluntary actions to pollution prevention
                •   Integrating pollution prevention into mainstream environmental programs
                •   Promoting environmental technology
                •   Improving measurement of environmental progress
                •   Addressing trade and environment issues

                I am looking forward to continued NACEPT contributions. Given our current theme of
             ensuring environmental protection is viewed as a critical success factor in fostering economic
             growth, I think we have an exciting future.
                                                                        Abby J. Pirnie, Director
                                                 Office of Cooperative Environmental Management

                         TABLE  OF CONTENTS
NACEPT and Pollution Prevention	5

The Policy Issues Facing EPA, and NACEPT's Role	7

Summary of Recommendations	9

Enhancing EPA Leadership in the New Environmental Era	11

Promoting Environmental Literacy and Workforce Competence	13

Encouraging Voluntary Action to Prevent Pollution	15

Integrating Pollution Prevention into Mainstream Environmental Programs	17

Promoting Environmental Technology	18

Improving Measurement of Environmental Progress	19

Addressing Trade and Environment Issues	21

Future Activity	23

Appendices	25
   Photographs of national parklands appearing throughout this publication were graciously provided by the

                               United States National Park Service.



    Since the modern environmental movement began, our basic protection
strategy has been to treat and manage wastes before they enter the environment.
We have made significant progress in cleaning air, water, and land resources by
limiting the amount of releases allowed and by prescribing controls to be used in
achieving these limits. As we develop controls for the more subtle environmental
threats that remain, the regulatory system has become increasingly more complex
and encompasses literally hundreds of thousands of facilities. The approach has led
to inflexible and sometimes conflicting requirements which, may hinder innovative
solutions to environmental problems. Meanwhile, the environmental community
has learned that pollution is  not, as the "treat and manage" strategy presumes, an
inevitable byproduct of human activity. Much pollution can be avoided altogether,
and many wastes that cannot be avoided entirely can be substantially reduced.
Furthermore, the steps involved in minimizing waste can lead to more efficient and
profitable production.
    Government efforts to promote pollution prevention have existed for several
years and are growing. Typically, programs to promote pollution prevention provide
technical assistance; education and training, and other incentives to business.

                       Legally, although some waste minimization requirements have been in place since
                       1976 under the Resource Conservation and Recovery Act, it was only in 1990 that
                       the principle of pollution prevention was incorporated into Federal law with the
                       Pollution Prevention Act.
                           Pollution prevention is at the top of a hierarchy that includes: l) prevention,
                       2) recycling, 3) treatment, and 4) disposal or release. According to this hierarchy,
                       disposing of waste should be employed only as a last resort, after prevention, then
                       recycling, and then treatment have been shown infeasible. Pollution prevention is
                       defined by die EPA, in accordance with the Pollution Prevention Act, to mean
                       "source reduction": namely, any activity that reduces the amount of any hazardous
                       substance, pollutant or contaminant entering any waste stream or otherwise
                       released into the environment. This includes increasing efficiency in the use of raw
                       materials, energy, water, or other resource, and protecting natural resources by
                           One of the main attractions of the principle of pollution prevention is that it
                       benefits both the economy and the environment: it stimulates more efficient
                       production practices, which in turn reduce the waste that has to  be managed. As a
                       consequence, the strategy of implementing pollution prevention can gain the
                       cooperation of many new allies such as political and business leaders, and economic
                       development and financial institutions.
                           For pollution prevention to bring the benefits it promises the principle must be
                       accepted throughout society. Promoting it requires fostering a
                       cultural change, to one that allows those who generate
                       pollution to recognize the        5
                       benefits of more anticipation and
                       internalizing of real environmental
                       costs. To help effect this cultural
                       change, government needs
                       to build a new
                       relationship with its
                           So far, the majority of government-
                       sponsored prevention programs has been
                       voluntary. However, government actions can play an
                       important part in stimulating (or thwarting) voluntary action, and many States—
                       and EPA—are beginning to include pollution prevention provisions in some
                       permits and enforcement settlement agreements. Moreover, one of the most
                        'For a fuller definition see Appendix 1.
                        NACEF-T — SUMMARY OF  1 992: RECOMMENDATIONS


effective promoters of pollution prevention is a well-informed public empowered by
facility-specific environmental data. The government, at the Federal, State, and
local levels has begun to provide that information.
    A great deal more government action is possible and desirable. EPA and many
States are now seeking ways to incorporate prevention directly into the design of
regulations by, for example, including source reduction as a "best available
technology." Some local wastewater treatment agencies are promoting prevention
as a way for industrial dischargers to meet their pretreatment requirements.
Also, in addition to the more traditional regulatory mechanisms, a variety of
market-based policies—such as assessing fees based on emissions and providing tax
credits for environmental investments—are being tried. However, adapting the way
the market works so that prices reflect real costs, including those of environmental
damage, will require changes throughout the economy, from the way manufacturers
price their goods on the domestic market to how the United States conducts its
international trade policy.
    The shift in outlook implied by adopting pollution prevention is not yet
completely understood. Along with State and local governments, EPA is in
transition, shifting from the existing "command-and-control" approach to one that
includes implementing pollution prevention. The Agency has not established how
to adapt its institutions, policies, and programs so that pollution prevention
becomes the dominant strategy for environmental protection. The basic
components of the existing command-and-control system will remain, although
perhaps in a modified form. The challenge for government at all levels is to find a
way to make the shift that neither jeopardizes the environmental progress the
country has made under the existing system nor stifles the actions that could lead to
significant permanent reductions in the amount of pollution that is generated.
    The role of the National Advisory Council for Environmental Policy and
Technology (NACEPT) is at the leading edge of EPA's new environmental policy
making. Its aim has been to solicit the views of EPA's principal constituents on
policies to promote the principle of pollution prevention. It has examined the
problems and implications of the new approaches to environmental protection.
NACEPT provides the Administrator with innovative solutions to policy
questions, and acts as a sounding board for strategies the Agency is developing.


                          The National Advisory Council for Environmental Policy and Technology
                       (NACEPT) is a public advisory committee chartered (originally as the National
                       Advisory Council for Environmental Technology Transfer) on July 7,1988. The
                       Council provides information and advice to the Administrator and other officials of
                       the U.S. Environmental Protection Agency (EPA) on policies for managing the
                       environment. NACEPT has approximately 50 members, appointed by the EPA
                       Deputy Administrator for staggered terms of three years. They include senior-level
                       representatives of a wide range of EPA's constituents, including: business and
                       industry; academic, educational and training institutions; Federal, State, and local
                       government agencies and international organizations; environmental groups, and
                       non-profit entities. Dr. John Sawhill, President and CEO of the Nature
                       Conservancy, currently serves as the Chair of NACEPT.
                          EPA's Office of Cooperative Environmental Management (OCEM), headed
                       by AbbyJ. Pirnie, provides budgetary support, serves as the executive secretariat,
                       and performs staff support functions for NACEPT. Ms. Pirnie is NACEPT's
                       Designated Federal Official.

                                   COUNCIL. COMPOSITION 1 99Z
                                               Academic, Educational
                                               and Training Institutions
                                               Business and Industry
                       NACEPT — SUMMARY OF 1 992 RECOMMENDATIONS


     NACEPT is supported by five standing committees:

     e  Pollution Prevention Education Committee (PPEC)
     8  Environmental Measurements and Chemical Accident
        Prevention Committee (EM/CAP)
        State and Local Environment Committee
     *  Technology Innovation and Economics Committee (TIE)
     8  Trade and Environment Committee.
     Committees are chaired by NACEPT members. They are composed of
 NACEPT members and more than 300 additional individuals, chosen for their
 expertise or because they represent a group particularly affected by the issue at
     A plenary session of NACEPT meets at least once a year. The plenary session
 and all other meetings under the auspices of NACEPT are open to the public, in
 accordance with the Federal Advisory Committee Act (FACA)

    In the spring of 1991, William K. Reilly, Administrator of the EPA, asked
 NACEPT to help the Agency in promoting pollution prevention. He asked the
 Council to recommend steps EPA could take to overcome the policy, institutional,
 technical, and educational barriers that are impeding more widespread adoption of
 pollution prevention. Recognizing that a variety of factors will influence whether
 and how pollution prevention becomes the dominant approach to environmental
 protection, the NACEPT standing committees began exploring factors relevant to
 their particular areas of interest.
    The Environmental Measurements and Chemical Accident Prevention
 Committee has been concentrating on problems in evaluating the state of the
 environment and in monitoring the performance of activities to promote pollution
 prevention. The Committee focused on: l) reviewing plans for developing a central
 source of environmental information and statistics; 2) evaluating the methodology
 for measuring source reduction of Toxics Release Inventory chemicals and
 reviewing criteria for evaluating State Capacity Assurance Plans; and 3) measuring
progress in preventing chemical accidents.

                           The Pollution Prevention Education Committee explored ways to promote
                       pollution prevention education and training. Committee efforts focused on:
                       l) promoting pollution prevention within industry, especially through new
                       education and training initiatives; and 2) attaining a general level of pollution
                       prevention literacy in the public through broad educational efforts directed through
                       formal and informal channels.
                           The State and Local Environment Committee examined how the resources and
                       unique capabilities of Federal, State, and local governments could best be used to
                       promote pollution prevention as well as the challenges involved in making the
                       transition from traditional environmental programs to prevention-oriented
                       programs. The Committee analyzed: l) status and trends in State and local
                       pollution prevention programs, including innovative voluntary and regulatory
                       programs using public authority and cooperative partnerships with the private
                       sector; and 2) opportunities for expanding pollution prevention efforts by building a
                       broader base of support and integrating pollution prevention and other innovative
                       approaches into mainstream environmental programs.
                            The Technology Innovation and Economics Committee has been examining the
                       relationship between the nation's environmental regulatory system and the
                       development and use of environmentally beneficial advances in technology. The
                       Committee concentrated on: l) how EPA's permitting and compliance policies can
                       expand environmental progress by encouraging the development and use of
                       pollution prevention technology; and 2) the role of government technology
                       diffusion programs in the environmental management system.
                            The Trade and Environment Committee is addressing EPA's strategy with
                       respect to the intersecting areas of trade and the environment. It also aims to
                        provide the EPA Administrator, as a member of the Executive Branch, with
                        guidance in helping to develop the United States' government policy on the subject.
                        The Committee's primary activities were: l) assessing the role of international trade
                        and economic organizations and international environmental agreements with a
                        view towards reducing the conflict and advising on future areas requiring EPA
                        policy; and 2) developing consensus on fundamental principles with respect to the
                        overlap between trade and environmental policy objectives, and identifying areas
                        requiring future work by the Agency.
                         NACEFT - SUMMARY OF 1 992 RECOMMENDATIONS

    Over the last two decades, the government has promulgated requirements that
have established a solid floor of minimum standards for treating and disposing of
the worst pollutants, greatly improving the quality of the environment. However,
while these requirements undoubtedly need to be maintained and improved, they
cannot alone lead to the "cultural change" pollution prevention requires. The
Agency, therefore, needs to make the necessary institutional adjustments. From
being a primarily regulatory agency, EPA must expand its role to promote non-
traditional, voluntary approaches to environmental management as well. It must
also enlarge its ability to provide information and guidance.
    The Agency has shown early successes in this new role with its "33/50" and
"Green Lights" programs. Moreover, it has been considering such innovative
strategies as initiating Environmental Leadership Programs, encouraging industry
to adopt Total Quality Management practices that reflect environmental concerns,
and creating a system of tradable permits. However, as it goes through its
institutional adjustment, EPA will need to focus on several key issues:

    •   Existing bureaucracies, and their constituencies,  were developed to
        implement single-media, command-and-control programs and end-of-
        pipe solutions: enormous private and public investment has been made to
        construct the treatment facilities and install the control equipment that is
        now in place. In addition, there are strong constituencies vested in the
        existing system, including influential environmental activists and
        legislative committees in Washington and in the  States. Together these
        represent a serious impediment to EPA's new approaches.

    *   On the other hand, because pollution prevention has both economic and
        environmental benefits, EPA has natural allies among political leaders and
        economic development and financial institutions, many of whom have not
        previously been active in environmental protection. EPA needs these allies
        to provide essential support and resources that can be leveraged. The
        Agency must develop a cooperative relationship with business interests,
        while at the same time honoring its primary responsibility for protecting
        the environment.

    *  The potential for implementing pollution prevention has barely been
       tapped. Only some of the larger firms, and the tiny fraction of small firms
       that have been reached by a technical assistance program or education, are
        actively involved in the strategy. Huge opportunities remain, presenting a
       large organizational challenge to EPA and its  counterparts in State and
       local governments.



                                  In examining the issues facing EPA, NACEPT has focused on the following
                              major challenges the Agency's programs must meet:
                                     Enhancing ERA Leadership in the New Environmental Era. EPA's actions
                                     and decisions must send a consistent message that prevention is the
                                     strategy of choice for environmental protection.

                                     Promoting Environmental Literacy and Workforce Competence. The concept
                                     of pollution prevention needs to be understood and accepted, and the skills
                                     to implement it available, throughout the nation. For this the Agency must
                                     take the lead in fostering environmental education and workforce

                                     Encouraging Voluntary Action to Prevent Pollution. As voluntary programs
                                     will remain among the most effective ways for EPA to achieve some of its
                                     goals, the Agency must find the balance between fostering voluntary
                                     efforts and keeping the consistent regulatory pressure that motivates firms
                                     to seek pollution prevention solutions.

                                     Integrating Pollution Prevention into Mainstream Environmental
                                     Programs. For pollution prevention to be the dominant strategy for
                                     environmental protection, it must be integrated fully with mainstream
                                     environmental programs.

                                     Promoting Environmental Technology. Since implementing pollution
                                     prevention often implies adopting new technology and management
                                     practices, EPA must establish the role it needs to play in stimulating
                                     technological innovation and providing the means for its dissemination.

                                     Improving Measurement of Environmental Progress. EPA must be able to
                                      monitor its progress in promoting pollution prevention. As this implies
                                      assessing "cultural" change as well as compliance with a set of rules or
                                      standards, the Agency must adopt measurement and evaluation techniques
                                     with which it is unfamiliar.

                                     Addressing Trade and Environment Issues. EPA. must encourage the United
                                      States government to integrate the policy of pollution prevention within its
                                      role as world leader in environmental protection. It must do so both
                                      because environmental damage is not contained within national borders,
                                      and because failure to promote environmental protection abroad could
                                      affect the U.S. government's ability to foster it at home.


    For 1992, NACEPT was charged with examining opportunities for achieving more
 widespread implementation of the pollution prevention approach to environmental
 management. NACEPT was also asked to explore ways to reconcile potential conflicts
 between environmental protection and expanded international trade.
    While each of the NACEPT committees explored different aspects of the
pollution prevention question, the result of their collective efforts is a
comprehensive set of recommendations for making consideration of pollution
prevention alternatives an integral part of environmental decision-making by all
segments of society. NACEPT's recommendations are designed to build on early
successes, foster innovations in both environmental program management and
technology, establish mutually beneficial relationships among the stakeholders, and
address the policy and technical issues that hinder progress. In the international
arena, the notion of preventing pollution is inherent in NACEPT's position
favoring sustainable development.


                                 NACEPT's major focus on pollution prevention was a natural outgrowth of its
                             earlier efforts. From the beginning, NACEPT has endorsed the concept of a
                             hierarchy in environmental management, with pollution prevention/source
                             reduction as the most desirable approach. NACEPT has also been a strong
                             supporter of the use of risk-based planning and management as a means for
                             focusing resources on the most pressing environmental problems. In addition to
                             these fundamental positions, NACEPT has also:

                                 •   Urged greater attention to creating an environmentally literate public and
                                     a well-trained environmental workforce

                                 •   Promoted voluntary partnerships and collaborative efforts between
                                     government and the private sector to achieve voluntary reductions in
                                     pollution and to carry out research, technology development, and
                                      educational efforts

                                 •   Urged clarification of Federal, State, and local roles in environmental
                                      management to assure a mutually supportive, efficient, and effective

                                 •    Encouraged reform of environmental regulatory programs to allow for
                                      greater flexibility hi implementation and multi-media integration

                                 •   Advocated development of national policies and programs to foster the
                                      development and dissemination of innovative environmental technologies

                                 •    Promoted improvements in the quality and utility of environmental data

                                 •    Encouraged the use of market-based and other mechanisms as a means for
                                      achieving environmental improvements

                                 •    Advocated effective consideration of environmental concerns in
                                      international development and trade policy.

                                 Following is a summary of NACEPT's key findings and recommendations for
                              expanding pollution prevention efforts and addressing issues associated with trade
                              and the environment. Individual committee reports are available from EPA's Office
                              of Cooperative Environmental Management and contain more detailed discussion
                              and analysis on the recommendations.
                              NACEPT — SUMMARY OF  1992. RECOMMENDATIONS


    In the new environmental era, EPA
will need to find new ways to carry out its
mission that recognize the shared
responsibilities of all levels of government
and the private sector in meeting
environmental goals, fostering innovation,
and facilitating exchange of information
and expertise among all parties. Perhaps
the most daunting challenge EPA now
faces is managing the transition from
traditional command-and-control
environmental programs to more flexible
programs that seek continuous
improvement in preventing pollution and
that reflect collaboration with
stakeholders. EPA's actions and decisions
must send a consistent message that
prevention is the strategy of choice for
environmental protection and find the delicate balance between fostering voluntary
and cooperative efforts and keeping up the consistent regulatory pressure that often
motivates firms to seek pollution prevention solutions.
    To fulfill its essential leadership role in the new era in environmental protection,
EPA should:

    ^  Foster a strong environmental regulatory climate that pushes companies to
        seek prevention alternatives

    ^  Assure that its actions and decisions are consistent with its pollution
        prevention message, including all regulatory, enforcement, and program
        management decisions

                                                                                                    t t

                               Clarify roles and responsibilities of EPA, State, and local governments;
                               emphasize EPA's role in providing technical and other support to State and
                               local governments for building pollution prevention programs

                               Set an example for other Federal agencies, and State and local
                               governments, by showing how pollution prevention can be implemented
                               within its own operations

                               Seek more stable sources of finance for EPA and State pollution prevention
                               efforts, including greater flexibility to support them with routine program

                               Reward staff efforts to promote collaboration, achieve multi-media
                               integration, provide technical or management support to State and local
                               government, or foster innovations in policy or technology

                               Develop and implement a strategy for building greater consensus and
                               support for pollution prevention, addressing the concerns of those who fear
                               it could lead to weaker environmental protection or more burdensome
                               regulatory requirements; key constituencies include Congress, business
                               groups, and environmental organizations

                               Take special steps to understand the concerns and engage the support of
                               mid-level environmental agency officials in charting new courses

                               Build political support for pollution prevention efforts by educating
                               Governors, State legislators, and local officials about the economic and
                               environmental benefits of pollution prevention and how to build effective
                               prevention programs

                               Forge new alliances with economic development entities and financial
                               institutions to promote prevention through mechanisms not traditionally
                               linked to the environment

                               Encourage financial institutions and the insurance industry to incorporate
                               prevention considerations into their decision-making processes

                               Promote pollution prevention concepts in trade and international
                               development policies.
                        NACEPT - SUMMARY OF 1992. RECOMMENDATIONS



    If its promise of a more efficient and environmentally healthy world is to be
realized, the concept of pollution prevention must become an integral part of every
citizen's intellectual outlook and daily routine. This will require a broad educational
effort to be carried out in formal and informal channels of education, involving
shifts in the focus and curriculum of many academic programs. The general public
will need a basic level of environmental literacy to enable them to assess the
potential environmental consequences of their actions and make choices
accordingly. Workers from the shop floor to the executive suite will need to be able
to develop and implement practical measures for preventing pollution. The
engineers, scientists, lawyers, and policy analysts who make up the workforce of
environmental agencies at all levels of government will need new knowledge and
skills to be able to incorporate pollution prevention in their activities and foster
innovative technologies. They will also need new management skills to address
multi-media issues.

    To promote environmentalliteracy and competency in the general population and
•workforce, EPA should:

    Ijjf Develop and implement a pollution prevention education strategy to foster
        prevention both as an ethical standard and as a practical goal for all
        endeavors, including roles for vocational schools, community colleges,
        universities, business schools, and corporate training institutes, as well as
        non-traditional means for educating the population such as entertainment
        and news media

    ^ Assure that pollution prevention is emphasized in all EPA-sponsored
        environmental education activities, making it an explicit goal of all
        internal,  inter-agency, and grant programs for environmental education

    ^ Improve coordination of curriculum development and training programs
        for pollution prevention

    ^ Begin a series of new programs to train educators on pollution prevention,
        including establishing a network of regional centers or faculty and
        curriculum development

    "f|f  Support development of university curricula to increase literacy in
        environmentally beneficial technology


                                  *<$? Cooperate with communities, other government agencies, nonprofit
                                     organizations, and business firms in establishing regional programs in the
                                     growing field of ecological design

                                  ^ Expand support for cooperative education and training activities involving
                                     the United States and other Western Hemisphere countries.

                                  To train environmental agency staff 'at all'levels of 'government for responsibilities in
                              pollution prevention, fostering new technologies, and multi-media environmental
                              management, EPA should:

                                  ^ Place a much higher priority on training and staff development, and
                                     provide adequate budgets to assure implementation

                                  ^ Develop and implement a national strategy for building staff capacity at all
                                     levels of government, addressing pollution prevention and fostering
                                     development and use of innovative technology

                                  ^ Substantially expand training programs and address ongoing technical
                                     needs of government practitioners—including permit writers, inspectors,
                                     and enforcement personnel—regarding incorporation of pollution
                                     prevention into routine program activities and fostering development and
                                     use of new technologies

                                  *^ Establish a program to develop and disseminate information for
                                     government managers on topics such as innovative policies and programs,
                                     design and implementation of pollution prevention programs, and
                                     structural reorganization

                                  ^ Develop incentives to retain experienced personnel and reward staff who
                                     have been successful in promoting pollution prevention, fostering the use
                                     of innovative technologies, or providing multi-media benefits through
                                     their activities

                                  ^ Test alternative approaches to staff development, such as developing
                                     industry experts familiar with all requirements governing a particular
                                     industry category as opposed to experts in individual media programs

                                  ^ Develop training programs designed to enhance skills needed to manage
                                     multi-media enforcement or permit projects, including training in project
                                     planning, intergovernmental relations, matrix management, team building,
                                      community relations, and negotiations.
                               NACEPT — SUMMARY OF  1 992 RECOMMENDATIONS



    Thus far, most government-sponsored efforts to promote pollution prevention
have sought to spur companies to adopt pollution prevention measures voluntarily.
Many programs and policies exist at the Federal, State, and local levels to encourage
firms to make voluntary reductions of pollutants. They employ such methods as
using the power of persuasion with significant polluters, giving public recognition
to participating firms, providing technical and other forms of assistance, and
offering financial and regulatory incentives. An important benefit of voluntary

     t,   *j
efforts is that they help to build trust and working relationships among and between
industry, environmental regulators, and environmental advocates. Because they
stimulate actions that go "beyond compliance" and foster fundamental changes that
can have lasting environmental and economic benefits, such programs and policies
should be expanded to reach a larger share of polluting entities. For continued
success, however EPA and State and local governments must reconcile the
relationship between voluntary and regulatory efforts and resolve difficult issues
such as whether and how to provide regulatory flexibility when needed to allow for
implementation of prevention measures.


                                   To foster additional voluntary reductions in pollutant emissions, EPA should:

                                   ^ Generate a marketing plan for voluntary programs (such as EPA's 33/50
                                       Program) that communicates benefits, such as potential cost-savings and
                                       avoided liability, and that rewards those who participate

                                   ^ For the next generation of voluntary commitments, establish long-term,
                                       continuous improvement goals that address all pollutants and
                                       environmental media

                                   ^ Extend voluntary programs to small and medium-sized companies by
                                       providing them with technical and financial resources that can help them

                                   ^ Establish a steering committee consisting of EPA officials and outside
                                       stakeholder parties to assist in designing and overseeing implementation of
                                       voluntary programs

                                   ^ Consult with States to assure coordination of national efforts with State
                                       and local initiatives, and address problems that arise when EPA program
                                       goals differ from State goals or statutory requirements

                                   ^ Address policy concerns, such as providing for regulatory flexibility and
                                       ensuring that any future required prevention reductions acknowledge
                                       voluntary reductions made by participating firms.

                                   To strengthen pollution prevention technical assistance efforts, EPA should:

                                   ^ Foster links between pollution prevention technical assistance programs
                                       and other business technical and financial assistance programs, including
                                       the program required to be established under the Clean Air Act

                                   ^ Continue to help State and local governments build capacity for providing
                                       pollution prevention technical assistance through provision of technical
                                       and financial support

                                   ^ Establish a system to make pollution prevention training materials, audit
                                       guides, or other products developed with EPA grant funds, widely
                                       available, and ensure against duplication of effort

                                   ^ Support evaluation of technical assistance programs and products to help
                                       determine and disseminate "best practices" and "how to" materials on
                                       program design, policies, and management.

                                   To provide other incentives for voluntary action, EPA should:

                                   ^ Establish a national program to provide recognition and incentives to
                                       leaders in implementing pollution prevention; in designing the program,
                                       consult with the business community, environmental advocates, and State
                                       and local governments to identify effective incentives and fair criteria for
                                       participation that will ensure environmental progress
                                NACEPT — SUMMARY OF 1 992. RECOMMENDATIONS


     ^ Evaluate the implementation and effectiveness of State and local policies
        and programs to provide regulatory flexibility, tax benefits, expedited
        permits, financial assistance, and other incentives to companies that are
        leaders in pollution prevention; disseminate the results to government
        officials and others interested in establishing such programs.
    Debate continues about the desirability
 of regulatory approaches to pollution
 prevention, but some integration into
 regulatory programs is both necessary and
 inevitable. Unless appropriate adaptations
 are made to traditional single-media
 environmental requirements and the systems
 that have emerged to implement them, they
 will serve as a significant hindrance on
 progress. EPA policy states that pollution
 prevention should be integrated into all its
 programs, and top managers have supported
 efforts to address environmental matters on a
 multi-media basis. However,
 implementation by EPA (and States) has
 been limited to a few pilot initiatives that are
 typically outside the mainstream of program
 activities and have not been translated into
 changes in routine operations.

    To achieve greater integration of pollution
prevention and multi-media approaches in
mainstream environmental programs, EPA
    ^ Develop and implement an overall
        strategy to incorporate pollution
        prevention into its programs,
        including both multi-media and
        single media components

                                     Develop new approaches to funding and assessing State and local
                                     environmental programs; continue exploring ways to provide for greater
                                     flexibility in funding, administration, and oversight of State and local
                                     environmental programs—using strategic planning and pollution
                                     prevention as key components of new approaches

                                     Resolve policy issues associated with integrating pollution prevention into
                                     regulatory programs, giving priority to policies for:

                                     "  Providing regulatory flexibility or extended compliance deadlines in
                                        exchange for additional reductions, and

                                     *  Developing and enforcing pollution prevention permit conditions

                                     Increase the use of market-based approaches such as tradable permit
                                     systems, pollution fees, and "green taxes" to promote pollution prevention

                                     Continue and expand industry cluster approaches to regulation
                                     development to enhance identification of prevention opportunities and
                                     address multi-media issues; assure adequate State participation

                                    ' Develop criteria, policy, and procedures (based on experience from EPA
                                     and State pilots), for integrated permits so that all enforceable
                                     requirements and source reduction goals can be consolidated into a single

                                    ' Foster greater adoption of pollution prevention and demand-side
                                     management as a way for local wastewater treatment programs to carry out
                                     their pretreatment responsibilities and meet other environmental
                              PROMOTING ENVIRONMENTAL TECHNOLOGY

                                  Technology plays a critical role in solving environmental problems and
                              enhancing economic productivity. Government policies and programs have an
                              important impact on whether and how quickly valuable environmental technologies
                              are developed, made commercially available, and used. Over the years, NACEPT
                              has made a series of recommendations to foster development and use of innovative
                              technologies by providing incentives and making changes in permitting and
                              compliance systems. Diffusion is the spread and adoption of an idea after its first
                              successful commercial use and can be accomplished through such mechanisms as
                              government and private sector research, technical assistance programs,
                              publications, training, trade shows, professional conferences, and professional
                              research and licensing programs. The lack of strong and well-coordinated programs


for diffusion of environmental technology and solutions, including those which
result in preventing pollution, has hindered progress in making environmental

    To foster more effective diffusion of environmental technologies and solutions, EPA
        Make diffusion of environmental technology and solutions a major
        supporting mission for EPA

        Establish a high-level position to promote and coordinate the Agency's
        technology diffusion programs

        Build stronger partnerships with providers and users of environmental
        technology and actively promote increased use of innovative environmental
        solutions, using the full range of diffusion mechanisms

        Adopt a leadership position in environmental innovation throughout the
        research and development cycle—from research planning through
        dissemination to technology user

        Re-focus  EPA's current technology research activities to take on a major
        role in diffusion of information about environmentally beneficial

        Collect and generate credible information about environmentally beneficial
        technologies as weE as data on environmental businesses

        Emphasize diffusion of information about pollution prevention
        technologies and management practices in pollution prevention programs

        Expand efforts to diffuse environmental technologies internationally,
        working in conjunction with traditional Federal lead agencies, to help meet
        United States environmental and competitiveness objectives

        Continue and expand efforts to stimulate, test, and evaluate new
        environmental technologies through cooperative research efforts, testing at
        Federal facilities, and other mechanisms.


    Despite an investment of more than half a billion dollars annually by Federal,
State, and local governments on the collection, elaboration, and dissemination of
environmental data, the environmental statistics now available fall short of what is
needed to make responsible environmental management decisions. For several


                               years, NACEPT has supported the creation of a central entity to improve the quality
                               and utility of environmental statistics. As EPA's focus has enlarged from issuing and
                               enforcing standards to promoting environmentally sound behavior in all areas of
                               activity—whether regulated or not—information needs have also changed. Many of
                               the measurements of improvement in behavioral change are considerably more
                               difficult to make and are often ambiguous in their import. New approaches are
                               especially needed to measure progress in the largely voluntary efforts in source
                               reduction/pollution prevention and chemical accident prevention.

                                   To improve the quality and utility of environmental statistics, JER4 should:

                                   ^ Move with deliberate speed to establish a center for environmental statistics,
                                       seeking appropriate legislative authority

                                   ^ Assure that the center has the highest possible level of independence and is
                                       insulated from other regulatory and policy-making responsibility

                                   ^ Locate the center within the structure of the Agency such that it provides the
                                       greatest ease of access by decision-makers while maintaining its independence
                                       from policy-making and regulatory affairs

                                   'jg Concentrate staff efforts now on a few, high-quality environmental statistics
                                       projects aimed at serving as building blocks for the future.

                                   To measure progress in source reduction'pollution prevention, EPA should:

                                   ^ Avoid making measuring and proving reductions so burdensome as to
                                       discourage companies from trying

                                   ^ Take into account the constant changes inherent in industrial development
                                       that could give a false impression of source reduction

                                   ^ Tie data requirements closely to need to avoid draining resources away from
                                       activities that actually reduce wastes

                                   ^ Build incentives and disincentives into source reduction data collection and
                                       reporting requirements.

                                   To measure progress in chemical accident prevention, EPA should:

                                   ^ Select a simple means of demonstrating improvement or impairment in the
                                       state of chemical accident prevention; measure both implementation and

                                   ^ Use existing data to the extent possible; consider augmenting existing data
                                       with a voluntary survey of a limited sampling of chemical users and producers


     ^ Establish a benchmark standard from which improvement or impairment
        in the state of chemical accident prevention can be deduced

     ^ Recognize publicly that institutional change at facilities producing or using
        chemicals is essential to reducing the likelihood of chemical accidents; to
        encourage and guide such a change, EPA should adopt and promulgate
        principles of chemical accident prevention.


    With the expansion of global markets, nations are more interdependent than
ever before. Environmental perils like ozone depletion and global warming
demonstrate that nations are interdependent environmentally as well. The fields of
trade and the environment have been separate cultures with different objectives and
language, but die growing recognition that environmental and economic health are
inextricably linked suggests the need for greater communication and cooperation
between them. The world can achieve both expanded free trade and enhanced
environmental protection, but only if policies are developed that are sensitive to
both objectives. Because of its responsibilities and expertise, EPA should continue
to play a role in the trade and environment dialogue.

    To foster reconciliation between trade and environment objectives, EPA should
encourage the United States government to:

    ^ Adopt "sustainable development" as a guiding principle for U.S. policy
       relating to trade, international investment, and environmental protection,
       and urge the Industrialized Countries for Economic Development and
       Cooperation (OECD)  and other countries and organizations involved in
       international development to adopt this principle as well

    ijg Urge that environmental concerns be added as a major objective of the
       General Agreement on Trade and Tariffs (GATT); strengthen
       mechanisms for resolving disputes involving environmental issues

    'jg Push for greater transparency and public participation in the development
       of trade policy affecting the environment, both in the United States and in
       the procedures of GATT and OECD

                                     Identify appropriate areas for harmonization of environmental standards;
                                     where harmonization is not practicable, seek comity or mutual recognition;
                                     this effort should address substantive standards, testing protocols, risk
                                     assessment techniques, certification and conformity assessment
                                     procedures, and uniform procedural methods for public access and
                                     participation in setting standards

                                     Take a leading role in establishing criteria for evaluating the environmental
                                     implications of all future trade agreements in the Western Hemisphere,
                                     and seek agreement from all potential signatories in free trade agreements;
                                     assure there are adequate dispute resolution procedures

                                     Expand the use of debt reductions as an incentive for environmental
                                     initiatives and urge other creditor countries and international financial
                                     institutions to develop or expand such programs of their own

                                    ' Develop criteria for evaluating both the positive and negative impacts of
                                     domestic environmental requirements on the competitiveness of U.S.

                                    ' Facilitate the participation of the U.S. environmental goods and services
                                     industry in international markets

                                    ' Expand existing programs that increase the access of developing countries
                                     to environmentally friendly technologies.
                               NACEPT — SUMMARY OF 1 992. RECOMMENDATIONS

    By adopting the principle of pollution prevention, EPA has found that it must break the mold that
has shaped its policies since it was established. The changes that this implies in role and institutional
structure discussed in die introduction have only begun. NACEPT's efforts in 1992 to advise the
Administrator on applying the principle of pollution prevention are, therefore, the beginning of a
process. In 1993, the Council proposes to consider near-term policy changes in such environmentally
and economically important sectors as agriculture, energy, and transportation, as well as continuing its
work on cooperative initiatives such as the Environmental Leadership Program. In the longer term,
NACEPT aims to develop an agenda that will support the Agency's ability to address environmental
issues into the next century.


    The following is from the memorandum to EPA staff from F. Henry Habicht II, Deputy
 Administrator, dated 5/28/92.

    "Under Section 6602(0) of the Pollution Prevention Act of 1990, Congress established a
 Federal policy that:

    &   pollution should be prevented or reduced at the source whenever feasible;

        pollution that cannot be prevented should be recycled in an environmentally safe
        manner whenever feasible;

    e   pollution that cannot be prevented or recycled should be treated in an environmentally
        safe manner whenever feasible; and

    *   disposal or other release into the environment should be employed only as a last resort
        and should be conducted in an environmentally sound manner.

    Pollution Prevention means 'source reduction,' as denned under the Pollution Prevention

Act, and other practices that reduce or eliminate the creation of pollutants through:

    a   increased efficiency in the use of raw materials, energy, water, or other resource, or

    8   protection of natural resources by conservation.

    The Pollution Prevention Act defines 'source reduction' to mean any practice which:

    •  reduces the amount of any hazardous substance, pollutant, or contaminant entering any
       waste stream or otherwise released into the environment (including fugitive emissions)
       prior to recycling, treatment, or disposal; and

    8  reduces the hazards to public health and the environment associated with the release of
       such substances, pollutants, or contaminants.

    The term includes: equipment or technology modifications, process or procedure

modifications, reformulation or redesign of products, substitution of raw materials, and
improvements in housekeeping, maintenance, training or inventory control.

                      Under the Pollution Prevention Act, recycling, energy recovery, treatment, and disposal are
                  not included within the definition of pollution prevention. Some practices commonly described
                  as 'in-process recycling' may qualify as pollution prevention. Recycling that is conducted in an
                  environmentally sound manner shares many of the advantages of prevention—it can reduce the
                  need for treatment or disposal, and conserve energy and resources.
                      Pollution prevention approaches can be applied to all pollution-generating activity,
                  including those found in the energy, agriculture, Federal, consumer, as well as industrial sectors.
                  The impairment of wetlands, ground water sources and other critical resources constitutes
                  pollution,and prevention practices may be essential for preserving these resources. These
                  practices may include conservation techniques and changes in management practices to prevent
                  harm to sensitive ecosystems. Pollution prevention does not include practices that create new
                  risks of concern.
                      In the agricultural sector, pollution prevention approaches include: reducing the use of water
                  and chemical inputs; adoption of less environmentally harmful pesticides or cultivation of crop
                  strains with natural resistance to pests; and protection of sensitive areas.
                       In the energy sector, pollution prevention can reduce environmental damages from
                  extraction, processing, transport and combination of fuels. Pollution prevention approaches
                  include: increasing efficiency in energy use; substituting environmentally benign fuel sources;
                  and design changes that reduce the demand for energy."
                               NACEPT — SUMMARY OF 1 992. RECOMMENDATIONS

   The following are the NACEPT standing committee reports prepared during 1993.

   Environmental Measurements and Chemical Accident Prevention Committee

       Measuring Progress in Chemical Accident Prevention

       Report of the Pollution Prevention Measurement Subcommittee

       Establishment of a Center for Environmental Statistics at EPA: Interim

   Pollution Prevention Education Committee

       Partnership Building to Promote Pollution Prevention

       Pollution Prevention Education and Training for an Environmentally Sustainable Future

   State and Local Environment Committee
       Building State and Local Pollution Prevention Programs.
       J. Findings and Recommendations. II. Status and Trends.
   Technology Innovation and Economics Committee

       Report and Recommendations of the Technology Innovation and Economics Committee.
       Permitting and Compliance Policy: Barriers to U.S. Environmental Technology Innovation

       Improving Technology Diffusion for Environmental Protection. Export and
       Recommendations of the Technology Innovation and Economics Committee

       Transforming Environmental Permitting and Compliance Policies to Promote Pollution
       Prevention: Removing Barriers and Providing Incentives to Foster Technology Innovation,
       Economic Productivity,  and Environmental Protection. Report and Recommendations of the
       Technology Innovation and Economics Committee


                      Trade arid Environment Committee

                          The Greening of World Trade. Report and Recommendations of the Trade and Environment

                          This report includes the following supporting papers:

                             Trade Environment, and the Pursuit of Sustainable Development—Stewart Hudson

                             Frictions Between International Trade Agreements and Environmental Protections—
                             Durwood Zaelke, Robert Housman, and Gary Stanley

                             Note on Complimentarities Between Trade and Environment Policies—
                             Robert Repetto

                             Reconciling Trade and Environment: The Next Steps—Charles S. Pearson and
                             Robert Repetto

                             Changing GATT Rules—John H. Jackson

                             Dispute Resolution and Transparency—Konrad von Moltke

                             The Montreal Protocol—Christopher A. Cummings and Matthew B. Arnold

                             The Danish Bottle Case: Commission of the European Communities v. Kingdom of
                             Denmark—John Clark

                             Trade and the Environment: Press Clips—J. Michael McCloskey

                             A Matchmaker's Challenge: Marrying International Law and American
                             Environmental Law—David A. Wirth
                              NACEPT — SUMMARY OF  1992. RECOMMENDATIONS