PxEPA
          United States
          Environmental Protection
          Agency
                      Office of Enforcement and
                      CompliancesAssurance
                      (2251A)
   EPA/315/B-98/006
   November 1998
   www.inece.org
     COMMUNICATIONS STRATEGIES
     FOR ENFORCEMENT PROGRAMS

     Capacity Building Support Document
     International Training Workshop
"ty*y"^\
S^jfP
    ENVIRONMENTAL
    LAW-INSTITUTE
                                     Ministry of Housing,
                                     Spatial Planning,
                                     and the Environment
                                     (VROM)The Netherlands
                            Environment Environnement
                            Canada   Canada
         EUROPEAN
         COMMISSION
POLLUTION CONTROL DEPARTMENT

  THAILAND

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COMMUNICATION STRATEGIES FOR
ENFORCEMENT
               Capacity Building Document for Environmental
               Compliance and Enforcement Programs
                         April, 1996

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                                       PREFACE

 This document, Communication Strategies for Enforcement, was originally prepared in 1996 as one
 of five Environmental Compliance and Enforcement Technical Capacity Building and Technical
 Support documents prepared to  support the Fourth International Conference on Environmental
 Compliance and Enforcement held in Chiang Mai, Thailand,  April 22-26, 1996 and  ongoing
 international networking and capacity building under the auspices of the International Network for
 Environmental Compliance Enforcement.  It was maintained as a review draft to accommodate
 comments and additional country examples.  This final version remains unchanged and is published
 in final for use at the Fifth International Conference in Monterey, California, November 16-20, 1998
 along with several new capacity building documents.  These documents are^repared  as resource
 documents to be used by government officials and others who have responsibility for developing or
 enhancing environmental compliance and enforcement programs. The documents include:

       •      Financing Environmental Permit, Compliance and Enforcement Programs
       •      Source Self-Monitoring, Reporting, and Recordkeeping Requirements:  an
              International Comparison
       •      Multimedia Inspection Protocols: International Examples
       •      Communications Strategies for Enforcement Programs
       •      Transboundary Trade in Potentially  Hazardous (Waste, Pesticides,  and Ozone
              Depleting) Substances
       •      International Inspector Training Compendium, Course and Program Comparison
       •      Country Progress/Self Assessment Reports on  Environmental Compliance and
              Enforcement
       •      Citizen Enforcement: Tools for effective participation

 Consistent with the goals of the Executive PlanningCommittee for the Fourth and Fifth International
 Conferences and the ongoing goals of the International Network for Environmental Compliance and
 Enforcement to build capacity internationally for environmental compliance and enforcement, this
 document addresses key aspects of how and why to incorporate communications as a vital part of
 enforcement strategies to make them more effective.

 The Third International Conference on Environmental Compliance and  Enforcement  in Oaxaca,
Mexico (1994) pointed out the important role of communication in the enforcement of environmental
requirements.  This led to the inclusion of a workshop on communication and enforcement at the
Fourth International Conference in Chiang Mai, Thailand. Linking communication to enforcement
is relatively new.  There are of course examples where enforcement involves communication. But
this nearly always concerns implicit or incidental use of communication. Structured approaches which
consider the impact enforcement actions can make through use of publicity, visibility of inspections,
project-announcements etc., are scarce, to say the least.
                                          u

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The objective of the workshop and manual is to demonstrate the importance of communication in the
enforcement process and to show how to profit from the power communication has. It not only
provides theoretical background information on the various aspects of communication, but also
involves an immediate translation of this theory to the practice of environmental enforcement.  This
makes the workshop and manual of importance for everyone involved in the enforcement process,
from governmental policymakers to the individual environmental inspector.  It can help you to take
the first steps towards an effective combination of enforcement and communication.

Communication Strategies for Enforcement and the other documents listed above are available on
the International Network for Environmental Compliance and Enforcement's (INECE) Internet site:
http://www.inece.org. They also are available from the INECE Secretariat at the addresses below.
Finally, the INECE Secretariat  seeks your comments as to whether these documents serve their
intended purpose and how they might be improved.  Please send comments in writing to the INECE
Secretariat in care of Ms. Wasserman or Mr. Gerardu at the following addresses:

Ms. Cheryl Wasserman
Associate Director for Policy Analysis
Office of Federal Activities
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M Street MC 2251-A
Washington, D.C. 20460
FAX 1-202-564-0070
PHONE  1-202-564-7129
E-MAIL wasserman.cheryl@epa.gov

or
                                                              i
Mr. Jo Gerardu
Head, Strategy, Planning and Control Division
Inspectorate for the Environment
The Netherlands Ministry of Housing, Spatial Planning and the Environment
IPC 680
P.O. Box 30945
2500 GX Den Haag
The Netherlands
FAX 1-31-70-339-1300
PHONE 1-31-70-339-2536.
E-MAIL gerardu@IMH-HI.dgm.minvrom.nl
                                          11

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                               ACKNOWLEDGMENTS

This document was produced under contract of the Ministry of Housing, Spatial Planning and the
Environment, the Netherlands. Mr. Remko Herremans and Mr. Rene Schepers of Heijke Marketing
and Communicatie Consultants were the principal authors of this document, under the technical
direction of Mr. Jo Gerardu and Mr. Jan Veenman of the Ministry of Housing, Spatial Planning and
the Environment, the Netherlands. Mr. Jos Heijke was advising consultant.

A special word of appreciation to Ms. Cheryl Wasserman (Associate Director for Policy Analysis,
Office of Federal Activities) and Mr. Pete Rosenberg (Associate Director for Enforcement Capacity
and Outreach),  both of U.S. Environmental Protection Agency's Office of Enforcement and
Compliance Assurance and Mr. John Wise, Deputy Regional Administrator of U.S. Environmental
Protection Agency's Region IX Office in San Francisco, California.
                                         m

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                                                     Table of Contents
Table  of  Contents
         Introduction	
         1.1 Communication and Enforcement
         1.2 Three Propositions
         1.3 How to read this manual?
•pag.
  1
  1
  1
  3
         Enforcement.	;	
         2.1 An Instrument of Environmental Policy
         2.2 Repression and Prevention
         2.3 Enforcement: the State of the Art
         2.4 The Challenge for Environmental Enforcement
.pag.
 7
 7
 7
 10
 11
        Communication..	pag.  13
        3.1 Communication: Definition                              13
        3.2 Communication: Instrument of Environmental Policy        13
        3.3 What Communication Can Do                            14
        3.4 Enforcement Communication: the State of the Art            1 6
        3.5 The Challenge for Enforcement Communication              17
        Communication  and  Enforcement	
        4.1 Chance to Get Caught
        4.2 Communication Builds Perception
        4.3 Target Groups are the Market
        4.4 Communication Puts a Leverage on Enforcement
 .pag.  21
       21
       22
       24
       25
        The  Peeling  Model	
        5.1 The Peeling Model: Enforcement in 7 Layers
        5.2 Layers Reinforcing Eachother
        5.3 The Credebility Trap
  •pag
29
29
33
34
        Making  Things  Work	pag.  37
        6.1 The Strategic Wheel                                   37
              1. Analyses: A Never Ending Starting Point              38
              2. Target Groups and Objectives: Determine Your Results  39
              3. Product Development: Combining Enforcement and      40
                 Communication
              4. Organisation: A Crucial Element                     41
              5.  Execution: Flexebility, Creativity and Skills          41
              6.  Evaluation: A Powerfull Instrument                 42

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Table of Contents
7  Checklists	
         1. External Analyses
         2. Internal Analyses
         3. Target Groups
         4. Objectives
         5. Enforcement Action
         6. Communication Action
         7. Communication Instruments
         8. Organisation
         9. Execution
         10. Proces Evaluation
         11. Effect Evaluation
•pag.
45
46
47
48
49
50
51
53
54
55
56
57
8 Sources  of   Information	
         Documentation on Enforcement
         Documentation on Communication
         Documentation Centers
         Institutes
.pag.
61
61
62
63
63

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                                                      Introduction
          Introduction
 1.1  Communication and Enforcement
 This manual focuses on the relationship between enforcement and communication,
 both instruments in the environmental policy of the national as well as the local
 government. The objective of environmental policy is to direct companies and
 individuals  toward  more environmental-friendly behaviour through compliance
 to regulations.

 Enforcement is one of the most powerful instruments to influence behaviour of
 individuals and, consequently, of companies. The objective of enforcement is to
 achieve compliance  within the regulated  community.  Allthough this manual
 concentrates on enforcement practice, it is  absolutely vital to keep in mind that
 effective enforcement demands adequate environmental laws,  requirements and
 sanctions.

 One of the main  problems  for  environmental  enforcement is the inbalance
 between the  huge amount  of companies under regulation  and the  limited
 enforcement capacity. It is simply  impossible to enforce every environmental
 law  adequately by inspecting each company individually  on a regular bases.  A
 more sophisticated approach of enforcement  is needed.

This manual demonstrates the potential of communication  to raise the effective-
 ness of the enforcement.
1.2  Three  Propositions
In this manual three propositions are presented about the way communication can
leverage the effectiveness of your enforcement-activities. These propositions are
the guideline in this manual.
     Proposition  1:
     Communication   makes  environmental  enforcement  more
     effective    by    influencing    the   perception   of   the
     enforcement-action.
The effectiveness of enforcement  depends on the  'chance  to  get caught': the
probability to get caught if you violate the rules. The effect this 'chance to get
caught'  has on compliance  is based on two elements: the factual  chance to get
caught and the perception  of (feeling about) this chance to get caught. If the
goverment inspects 10 out of the 100 companies, the factual chance to get
inspected is  10%. But  if  the  government communicates about  the  enforce-
ment-action probably more than 10 companies feel they run the  risk to be
inspected.  This  feeling alone  can  change  their  behaviour.  This  is  what
communication can do. Chapter 4 of the manual explains in detail the chance to
get caught concept and how it can be influenced by communication.

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      Introduction
     Proposition  2:
     Communication  and enforcement should  be integrated.
Like enforcement, communication is  an instrument of environmental  policy.
These two instruments are not independent of each other: if employed in the right
combination they reTnforce each other, but if handled separately they can do more
harm than good.

For communication  to make enforcement more effective,  it's  necessary  to
integrate these two instruments of environmental policy. Succesful integration
means the implementation of Two Basic Rules:
   1.     No Enforcement without Communication!
   2.     No Communication without Enforcement!

Putting  a  lot  of effort in  enforcing  environmental  requirements  without
communicating in one way or the other that you're making these efforts, means a
chance has been missed.  Checking compliance without making this known to the
regulated community is not a very efficient way of stimulating environmentally
friendly behaviour. In other words: enforcement should be accompagnied  by
communication.

Vice versa is it in the long run not effective to constantly communicate about
enforcement and threaten with compliance-checks, while in fact there are none.
Communication by itself is not enough.

In this manual it is argued that bringing these two principles in practice demands
an  integration   of  enforcement  and  communication.  This  means planning,
development, execution and evaluation of enforcement and communication take
place simultaneously. They support one another.  How this integration can  be
accomplished is demonstrated with the Peeling Model encompassing enforcement
and the different ways to communicate: Chapter 5 of this manual.
     Proposition  3:
     A   strategic   approach    for   both    enforcement   and
     communication  is  a  prerequisite  for success.
Proposition 3 logically springs from proposition 2. Integration of enforcement
and communication demands a strategic approach. This implies the development
and formulation of a strategy: a long term approach based on a thorough analyses
of the present  situation and the environmental problem at hand,  the relevant
target groups and the means of enforcement at your disposal. Chapter 6 presents a
method for strategic  enforcement- and communication planning: The Strategic
Wheel.

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                                                        Introduction      3

1.3  How to  read this manual?
After the introduction in chapter 1, chapter 2 and three give an overview of the
most important theoretical concepts  of enforcement,  communication and their
interrelation. Chapter 4 to 6 deal with the three propositions, stated above. To
help you use the ideas and concepts  of the manual in  your day to day practice,
chapter 7 presents the checklists. In chapter 8 you  can find the information
sources used for this manual.
Below, a schematic outline of this manual is presented.

Hopefully this manual shows you  the  way to make  enforcement more  effective
through communication.

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Introduction
                   1. Introduction
                       I
-Three Propositions
                  2. Enforcement
                       1
 - General Concepts
                   3. Communication
                            - General Concepts
         4. Communication and Enforcement
                           - Perception,
                           - Objective Chance to Get Caught
                           - Subjective Chance to Get Caught
                           - Target Groups
                5. The Peeling Model
                           - The Peeling Model
                          t- Credibility
                6. Making Things Work
                           - Strategic Wheel
                   7. Checklists
                8. Information Sources

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 Background





- general concepts -

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Enforcement
                           -Three Propositions

          4. Communication and Enforcement
                            - Perception,
                            - Objective Chance to Get Caught
                            - Subjective Chance to Get Caught
                            - Target Groups
                 5. The Peeling Model
                           - The Peeling Model
                           f- Credibility
                6. Making Things Work
                           - Strategic Wheel
                   7. Checklists
               8. Information Sources

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                                                        Enforcement
 2   Enforcement
 During  the  last ten  years  more  effort  has  been  put into environmental
 enforcement. Before discussing the  role of communication, this chapter gives a
 very brief  overview  of the  development of  enforcement,  resulting  in  the
 formulation of the challenge for the next ten years.

 2.1  An  Instrument of  Environmental  Policy
 To make sure there is agreement on the meaning of environmental enforcement, it
 is useful to start with a definition:
      Enforcement is the set of actions that governments or others take to
      achieve compliance within the regulated community and to correct or
      halt  situations  that endanger the environment or public health.
      (Office  of Enforcement,  U.S.  Environmental  Protection Agency
      (1992). Principles  of Environmental Enforcement,  p.1-2.)

 Enforcement is  an  important instrument of environmental  policy. It  serves
 environmental policy on two main objectives:

 7.    Promoting Compliance
 Primary goal of the  enforcement is the promotion of compliance. Compliance is
 the full implementation of environmental requirements.

 2.    Supporting  Credibility
 Besides directly promoting compliance, enforcement serves environmental policy
 in  another  way.  It  provides  environmental  laws  and  requirements  with
 credibility. The regulated community judges laws by the way they are enforced:
 "If the law is not worth enforcing, it probably isn't worth complying either!".
2.2 Correction  and  Prevention
Discussions on enforcement always involve a distinction between corrective and
preventive enforcement. In this paragraph the strict distinction  of these  two
concepts is disputed.

In general, we speak of corrective enforcement when the enforcement action is
directed  at  behaviour that already took place. Offending a rule  triggers an
enforcement action. Figure 1 depicts this process. This philososphy of 'make the
offender pay* is illustrated by the XXX-case.

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     Enforcement
  f  behaviour^

Figure  1
corrective Enforcement
     TheXXX-case
     Violations found during a 10-month investigation, including among
     others illegal  land disposal  of hazardous  waste,  resulted in a
     settlement  between  Company XXX and  the  U.S. E.P.A. In this
     settlement XXX agrees to pay a $ 8 million penalty. Furthermore XXX
     has to repair and upgrade the facility at a cost estimated to be in the
      tens of millions of dollars.
     Source: U.S. E.P.A.
Whereas corrective enforcement is  directed  at past behaviour, preventive
enforcement aims at future behaviour. It's primary goal is to change behaviour
before offences occur. This approach is illustrated in figure 2.
   (^enforcement ")

 Figure  2
 Preventive Enforcement
Q   behaviour  ^
      Derelict  Vehicles
      A Dutch enforcement project in one of it's provinces handling the
      problem  of   derelict  vehicles aimed  at closing down the great
      majority of the car dismantles. With less competition it would be
      economically feasible for the remaining firms to take measures to
      protect the environment. A licensing system made this possible. The
      province started an intensive inspection  program. The dismantling
      firms were inspected on three occasions. The first round was meant to
      be  informative.  Violations found during the second round led to a
      formal warning. Only offenses discovered during the third inspection
      were sanctioned. During  the first round it transpired that 50 % of
      the firms complied with the rules. In 1995 the percentage has risen
      to85%.   ••• •;.••:•-  •  -,     •••'• V-'--v   ••':..   .'".'
      Source:  Environmental Law Enforcement in  practice  in the Netherlands
      (1995), p. 104-106.

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                                                         Enforcement
The 'XXX-case'  and the 'derelict-vehicles-case1 are typical for  the difference
between the corrective and preventive enforcement approach. But is it fair to say
the XXX-case is nothing more than corrective action and the derelicts-approach
is pure preventive? It  probably isn't. In fact, the difference between corrective
and preventive enforcement is based on a short term perspective on enforcement.

Of course the XXX-settlement in itself is corrective. But mark the words of the
U.S. E.P.A. Assistant Attorney general at the press conference shortly after the
settlement:

"...the penalties contained in today's settlement should sent a clear message that
business must either  comply with our environmental laws or inevitably pay a
stiff price  for avoiding their public responsibilities.	Let this send a  clear
signal, when the well-being  of future generations of Americans is at stake,  we
will never permit anyone to profit from environmental violations."

Obviously, the settlement with XXX is used to influence future behaviour. The U.S.
E.P.A.  aims for a  strong deterence-effect. In  the same way the  preventive
measures taken in the  Dutch case of derelict vehicles are supported by the threat
of corrective action. Sanctions have to be paid if, in the third inspection-round,
offences are found. These two cases show  if you apply a broader time-horizon
every good enforcement action has an element of correction and an element of
prevention.  The two figures  shown above can be  compressed in one cycle of
enforcement.
                preventive
corrective
                                   C enforcement J)
Figure  3
The Enforcement Cycle

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10     Enforcement
2.3 Enforcement: the  State of the Art
Overlooking the global map it is possible  to discern three possible situations in
which you  find the development of enforcement policy. First of all there is the
situation in which there is no environmental  enforcement what-so-ever. It is
absent.

A second situation you come across is to be characterized by an ad hoc approach of
enforcement. Enforcement activities take  place but in an unstructured way. The
enforcement  is  re-active.  Action is provoked  by  environmental  problems,
obvious offences of environmental requirements etc.  Probably most countries'
environmental enforcement policies can be labeled as being ad hoc.

The third  category  groups the cases  in which  enforcement is  approached
systematically, resulting in  a structured and planned environmental enforce-
ment policy. Enforcement is no longer just a reaction on environmental problems
and offences,  it's also proactive in the sence that it is aimed at avoiding these
problems.
     Nigeria  Moves  From  No  Enforcement   towards   Ad   Hoc
     Enforcement
     Enforcement is absent:
     After a period  of booming industrialisation, Nigerian government
     started to take  notice of the environmetnal downside of uncontroled
     industry-growth, especially the discharging of liquid efluents and
     solid wastes into open drains, stream, channels and lagoons. Although
     some laws, dating back to the colonial period,  existed, coordination
     and enforcement were almost nil.
     Enforcement is adhoc:
     In reaction of a toxic waste incidence the Government set up a Federal
     Environmental Protection  Agency, including  an  Inspectorate and
     Enforcement  Department. Industries are encouraged by In-House-
     Training to do self monitoring and industries are required to obtain
     permits. Mostly unannounced inspections check  compliance and
     ensure high-quality self-monitoring. Total annual inspections exceed
     300. In addition, supporting measures were taken, like encouraging
     public complaints and starting  a campaign  on moving  economy
     towards better  processing and less pdluting technology.  Compliance
     rates were in 1994 still low, but improving.
     Source:   Proceedings   Volume 2   Third  International  Conference on
     Environmental Enforcement (1994), p. 123-128.

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                                                       Enforcement    11
2.4 The Challenge for  Environmental Enforcement
The  last ten  years  environmental  enforcement has  become  a major issue:
governments sharpen their environmental policies and issue laws, inspectors
visit companies and execute audits to check compliance, projects are started to
save forests or to prevent illegal dumping.

But,  the task environmental enforcement faces  is immense. There is  so much
ground to cover with  the limited enforcement capacity available to governments.
There are limits to  how many inspections you  can perform.  Inspections are
costly. They demand human resources, technical equipment and education. Budgets
are,  by  definition, restricted.  This makes  it crucial  the enforcement  effort  is
more effective. The question is: how do we  get the most out of our enforcement
money? This manual shows how communication can help you.

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Communication
                 1. Introduction
                         -Three Propositions
                2. Enforcement
                          - General Concepts
                          - General Concepts
        4. Communication and Enforcement
                          - Perception,
                          - Objective Chance to Get Caught
                          - Subjective Chance to Get Caught
                          - Target Groups
               5. The Peeling Model
                         - The Peeling Model
                       %- Credibility
              6. Making Things Work
                         - Strategic Wheel
                 7. Checklists
              8. Information Sources


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                                                   Communication
13
         Communication
Communication encompasses all kinds of activities. Every day we communicate
and get information  by television, newspapers, small-talks, reports  etc. After
giving  a  general  definition of communication, we  will  focus on the role  of
communication as an instrument of environmental policy, especially  in relation
to enforcement.
3.1      Communication:   Definition
Defining 'communication' has proved to be an awkward task. For the purpose of
this manual we adhere the following definition:
Communication  is every  inforrriationflow  and informationexchange  between
organisations and/or persons, with a certain objective.

In the case of environmental enforcement the objective of communication is to
achieve environmental-friendly behaviour in general  and compliance by  the
regulated community in particular. For this manual it's important to get a clear
view on what communication can do in relation to the environmental policy  and
the enforcement in particular.
3.2     Communication:  Instrument  of  Environmental  Policy
The objective of environmental policy is to change behaviour in a more environ-
mental friendly way. Therefore the government uses all kinds of instruments:
regulations
financial  instruments, subsidies
sanctioning
enforcement
communication
education
research
facilities
convenants

Most  of  the  time the government  uses  a mixture of different instruments.
Communication is one of these instruments.

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14      Communication
      Reducing  Water Pollution  by  Discharges
      An  effective  campaign  to  reduce  waterpollution  by  discharges
      possibly includes the following measures:
    • regulation on discharges        ..     „  -      •    ,
    • enforcement of regulation: inspections to check compliance and
      sanctions on non-comliance
    • inform companies on the new regulations through brochures
    • a  branche-meeting  to promote  and  explain  possible  measures
      companies can take      .           .-.••-      '•:   :
    • research on how the regulated community thinks about regulations on
      discharging   '"" •,•••"'•,••' :';''-',;;;'. .•''• ' ^V;C-.^, :^::''!.'.*..•:.:.'"•'.*'••:  , ':L:." •. \
    • information centre to answer questions and practical advise
    • financial support, subsidization of new technologies
A combination of  different  instruments  is  most effective  because they  can
reTnforce each other. This especially applies for communication as an instrument
of environmental policy.
3.3      What Communication  Can  Do
Communication operates on different levels, aimed at influencing behaviour.
Five  levels  are  discerned:  Attention,  Knowledge,  Attitude,  Intention  and
Behaviour. Below, these levels are explained, starting with the Attention level,
then  moving closer to actual  behaviour with every next level. It is important to
understand this is not one and only sequence of communication levels. In fact, the
different levels are highly interrelated.

Furthemore it should be said, communication alone is never enough  to  change
behaviour. Something more is needed  to change  behavior, like: environmental
research, new regulations, sanctions, financial support, enforcement etc.

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                                                       Communication
                                                          15
Intention
 Behaviour
   Attention:
   At this  first level  of influence  communication  makes the
   problem  at  hand  an  issue  of concern  for the  regulated
   community.
   Examples:
 • publishing  environmental  research results
 • speeches by the Minister or other authorities on this matter
 • news items on environmental pollution

   Knowledge
   At the knowledge level communication is pure informative. It
   raises the knowledge about environmental problems,
   regulations, the enforcement etc.
   Examples:
 • informing the community about new license requirements
 • explaining the individual implications of new regulations
 • information about the sanctions on non-compliance
 • information about financial support for companies who intend to
   take adequate measures
 • announce enforcement action

   Attitude:
   To convert the  knowledge of the  environmental problem, the
   regulations and the enforcement into a positive opinion towards
   compliance, it is necessary to add communication at the attitude
   level. Explain the reasoning behind the regulation and make the
   regulated community aware of their individual  contribution to
   the environmental pollution and their responbilities.
   Examples:
 • the presentation of achieved results
 • showing  the  negative effects of   non-compliance  on  the
   environment
 • explaining the reasons for regulations

   Intention:
   Transforming a posititve attitude into  an  intention to  change
   behaviour, to comply, asks for another level of communication.
   This level creates the desire to comply, by making compliance
   more attractive (rewarding) or by making  it unattractive not
   to adjust your behaviour (punishing). Communication can make
   these positive and negative impulses  known to the  community.
   Examples:
 • example setting to deter offenders
 • communicating the sanctions on non-compliance
 • announcing inspections
 • rewards for good behaviour

  Behaviour:
  Finally a positive intention must lead to an actual change in
  behaviour. Communication  at this level facilitates compliance.
  Examples:
• supporting compliance with advice
• instructions to facilitate compliance
• information on financial support to achieve compliance

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16      Communication
3.4      Enforcement Communication: the  State of  the Art
In the same way enforcement can be divided in three categories, it is possible to
describe the use of communication. In most cases communication is not yet used
as an instrument of enforcement. Enforcement communication is absent.

Sometimes enforcement communication is used in an ad hoc manner to enforce
environmental laws. In general this is triggered by the attention the  press pays
to an environmental  problem.  Especially  major environmental  calamaties  do
very well  in attracting  the attention of press  and public, and so  will the
environmental enforcement's reaction to this calamity. It is only at this moment
enforcers take extra care of what they say and do. They realize themselves that
the media  lever the  effect of their  words and  actions. Note that the first
impression the environmental enforcement makes  in this situation is a  negative
one. After all the damage is already done.

A third  group is a very small group of cases  in which communication is used
structurally  as  a  means  of  enforcement. Environmental policy is aimed  at
creating publicity and employing other means of communication to enlarge the
effect of the enforcement activities.
      Auto  Service  Shops  in  Santa Rosa
      Auto service shops created a significant source of water and air
      pollution  for  the Municipality of Santa  Rosa.  The  service shops
      became  the target group  of a special enforcement program. Auto
      service shops that achieved full compliance based  on a multimedia
      inspection were offered to voluntarily receive a seal (sticker).  The
      pubtic was encouraged to do business with shops displaying the seal,
      through a well organized  outreach campaign, including television-
      advertizing. Materials, like  handouts with 'Best Management Practi-
      ces',  pollution   prevention  techniques  and  sources  for waste
      recycling,    were produced  to assist  the industry in achieving
      compliance.  In  addition local agencies  that  monitor and enforce
      environmental requirements at services stations joined forces.  They
      produced an inspection checklist, thereby allowing any one agency to
      perform  a  complete,  multi-media  inspection, referring serious
       violations to the appropriate agency for follow-up enforcement.
      Source:   Proceedings    Volume 2   Third  International Conference  on
      Environmental Enforcement (1994), p. 205 -206.

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                                                    Communication     17
3.5     The Challenge for Communication
To  ensure  a longterm  effectiveness  of enforcement, continuity is essential.
Needless to say this demands a systematic approach with structured enforcement,
but also with structured communication. This is  the only way to accomplish a
consistent enforcement of the environmental laws which is effective and efficient.
The challenge for communication is to support the enforcement in such a way the
effectiveness of enforcement as an instrument of environmental policy will be
strengthened. This asks for an integration of enforcement and communication. In
the end this will lead to more compliance and  a more environmental-friendly
behaviour of companies.

Reading the example above  of a compliance incentive program  in Santa Rosa
(California, U.S.) gives an idea of what an integrated approach of enforcement and
communication can look like.

Integrating  enforcement  and communication is your best guarantee for longterm
results. The following chapters elaborate on the  question why integration is so
important and how it can be accomplished.

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Communication

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                     Proposition   1:


"Communication  makes  environmental enforcement  more
     effective by influencing  the  perception of  the
                   enforcement-action."
                         -Perception-
                 - Objective Chance to Get Caught -
                 - Subjective Chance to Get Caught -
                       -Target Groups-

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2 0      Communication and Enforcement
                         1. Introduction
                            I
-Three Propositions
                        2. Enforcement
                                 - General Concepts
                        3. Communication
                                 - General Concepts
              ; 4. Cpmmunl^tidri; «iiT
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                                  Communication and Enforcement      21
4   Communication   and   Enforcement
This chapter is about how communication can make enforcement more effective.
The key word in this chapter is, as in our first proposition, 'perception'.
4.1  Chance to  Get Caught
An important concept in relation to enforcement is what we call 'the chance to get
caught'. The chance to get caught can be defined in two different ways:

1.   The  objective chance to get caught
     The  statistical probability to get caught when violating the
     rules.
     (also called: the factual/real chance to get caught)

2.   The  subjective chance to get caught
     The estimation by the regulated community of the probability
     to get caught when violating the rules.
     (also called: the perceived/ estimated chance to get caught)
What people think, believe, feel, this is what they act upon. Regulated companies
will be far more willing to comply if they feel there is a substantial chance they
get caught for offending the rules. This feeling is based on their own estimation,
their perception.

To effect future behaviour of the whole regulated community, it is not enough just
to create a substantial objective chance to get caught. It is crucial to make them
see and believe there is a good chance to get caught if they offend the rules. That's
where communication comes in;

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22
Communication and Enforcement
      Objective and Subjective chance to  gelt caught.
      For example: one truck loaded vwtft ilfegal waste tries to pass the
      boarder. If one out of every ten trucks' cargo is inspected and this
      check is 10096 waterproof the chance to get caught for a truck with
      an illegal load is 1096.  This is called the objective chance  to get
      caught The driver has to estimate the chances to pass the boarder
      without problems.  ',"•-:':,;, V'^Y'^;,^v'A\'"^;y':;v'.:': '"  '''.."	•	•

      Basically  there are two variations •possible in the estimation the
      truckdriver makes:           f    ;
   7. 7776 driver sees each and every cargo-inspection executed during the
      waitingperiod  at the  boarder. The perception of the chance to get
      caught will be high, possibly more then ten percent.
   2. The driver has passed the boarders more than twenty times now and
      has never seen any truck being inspected, because inspections are
      executed unobtrusively. The  estimated  chance to get  caught will
      probably not be as high as  1096.

      The estimate the driver makes, wittingly or unwittingly, is called the
      subjective chance to get caught. It is  is this subjective chance that
      will influence the truckdriver's  future behaviour.
4.2  Communication  Builds  Perception
How communication makes the difference between the objective and subjective
chance to get caught is shown in figure 5. This figure depicts how communication
levers  the objective chance to get caught to an even more effective subjective
chance to get caught by influencing perception.
objective
chance
       o:
communica tion
 subjective
chance
Figure4
From Objective to Subjective Chance to Get Caught
Communication can influence the perception of enforcement in a number of ways.
Actual enforcement action is the starting point, communication can make  this
action visible. It can draw attention towards  the inspections you undertake  and
towards the sanctions you issue. It can underline the specific characteristics of
your  enforcement action.  If an  inspection of one company  leads to  tough
sanctioning, this of course will  be  noticed  by  this  company. But  if  this
enforcement action is done in silence there will hardly be any effect on the other
companies.  Dependant  on  whether you choose  for  a  more preventive or
repressive policy you can draw attention to  the chance to get caught or  the
sanction.

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                                     Communication and Enforcement      2 3
 Communication puts a magnifying-glass on the value of your chance to get caught
 and  on  the  sanction  you  issue.  In  'marketing'  this  leverage-power  of
 communication has long been acknowledged. Product-value is enlarged by adding
 emotional value to the objective, rational characteristics of a product. The value
 of a sports shoe is not just it's practical use. Wearing a specific brand of sports
 shoe can make you feel good. This additional value exists in people's minds. It is a
 perception created by communication.

 Communication can make things attractive, or unattractive. It colors perception.
 The widespread use  of advertizing  campaigns  as  an  instrument  to increase
 product sales do just that, color  perception. How attractive would a  bottle of
 black liquid  be without  a flashy label  and glittering T.V. commercial. These
 communication elements have made Cola into an  attractive product, with billions
 of buyers. Parallel  to a company producing sports shoes or liquids, the enforce-
 ment department produces its own  product: the enforcement action.

 In the same way communication can be used to attract people to buy a product,
 communication  can be  used  to  deter offenders by  making  non-compliance
 unattractive. Think about example-setting by publishing offenders'names in the
 media.
      Communication  and   Perception
      A few examples of communication influencing perception of chance to
      get caught and sanctioning:
           Subjective Chance to get Caught                 :
         • making actions more  visible through  publicity,  letters  to
           companies etc.
         • announcing actions in the media
           Sanctioning
         • publishing results of enforcement actions in the media
         • publishing issued sanctions
Communication can be used to make others perceive your enforcement action and
color this perception. This will increase the subjective chance to get caught and the
perception of the sanctioning, which most probably influences future behaviour.
This is why there should be No Enforcement without Communication ; the First Basic
Rule.

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  24
Communication and Enforcement
  On the other hand it's impossible to create a subjective chance to get caught by
  communication alone. Perception can't be built on air. If you don't live up to the
  promises you communicate, communication can proove to be a boomerang and
  come  right back at you.  You loose credibility,  your communication looses
  credibility, and you will have a hard time to regain it. Wo communication without
  Enforcement, the second  Basic Rule. The  bases  of enforcement communication
  must be an objective chance to get caught combined with a sanction. Together this
  is the enforcement action. About the factual chance to get caught and the sanctions
  you can communicate. You can direct attention to the inspections you execute and
  the fines you issue. This way you amplify the impact on perception.

  Of course it's sometimes recommendable to operate  more quietly,  making the
  enforcement unpredictable and surprising. You can put it this way:  "Youhave to
  do everything you say, but you don't have to say everything you do!"
  4.3      Target  Groups are the Market
  This  paragraph continues the parallel between marketing  and enforcement.
  Marketing never works without a definition of the target group. It is essential to
  aim your  marketing efforts for  a  specific  group  with  specific needs  and
  preferences. For enforcement it  is equally important to focus on a target group.
  Concentrating your enforcement-efforts, on a well defined part of the regulated
  community, the target group, makes enforcement much more effective.

  Before you define your target groups you have to take in account a number of
  considerations:

1. Risk-potential
2. Environmental priorities (water, waste, land-use, noise etc.)
3. Compliance-reputation
4. Complaints
5. Preventive effect
        Target  Groups Priorities  in  Norway
        In Norway in the year 1993, 1500 enterprises have been granted
        discharge permits. In order get the best possible results from their
        ;"  fted inspection capacity they carefully select the enterprises they
           oect or audit. They use the following criteria:
           1. Enterprises which  contribute  to environmental problems in
             areas which   are   given   high  priority  by  environmental
             authorities.
           2. Enterprises with a great potential risk of hazardous discharges.
           3. Suspicion of violations.
           4. Geografic areas with special environmental problems.
           5. Preventive considerations.
           irce: Proceedings  Volume 2 Third International Conference on
           ironmental Enforcement (1994), p. 111-115.	

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                                    Communication and Enforcement      25
      Preventive l                                                .
      For * few yean ^                                        the
      Minister ^} of ffivi^^                              visit   to  a
      multinational based in^Jakarta, JhiswJthout exception resulted in a
      fair amount'; of publlic^-fNOtlonly^becaus^-of  the  high  ranked
      inspector, but also because of the nieflKa-attent/on for multinationals.
      In other words, the preventive effect of publicity was at least one of
      the reasons to select multinationals as target group.
      Source: I.W.A.C.6. The Netherlands   :    - :  v
 Defining target groups gives direction to your enforcement and communication.
 Keeping your target group in mind, you can choose the most effective combination
 of  action  and  communication. This  same  integrated  approach  of  action,
 communication and target groups  we find  in the world of business. The way
 enterprises produce and sell their products teaches the enforcement department a
 valuable lesson.

 In Chapter 7 you can read how to define a target group.

4.4  Communication  Puts  a  Leverage on Enforcement
Through  communication it is possible to lever the impact of your enforcement
 action. If done properly, an executed inspection will not just effect the inspected
 company, it will also have a deterrent effect on other members of the regulated
 community. Communication makes  enforcement visible. Communication spreads
 the preventive effect of your enforcement -activities out over larger parts of the
 regulated community. This way compliance  is promoted on a larger scale than
just the inspected company.

Communication comes in many forms to support the enforcement of the law. The
difficulty of using communication as an instrument of enforcement lies in finding
an equilibrium between enforcement and  communication. In marketing  it is
common knowledge  communication  produces  the  best  results if it colors
perception  in a way that  matches your  product. Communication and  product
should  create  one consistent  image.   It is safe to  say  the same goes for
communication and enforcement action. This demands an integrated approach of
communication and enforcement action. This is not all that easy, knowing there
are many ways to design your inspection-activities and at least as many ways to
communicate with  your target group. The Peeling Model in chapter  5 provides
you with a systematic approach to tackle this problem.

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26
Communication and Enforcement

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             Proposition   2:

"Communication  and  enforcement  should be
                integrated."
              - The Peeling Model-
                 -Credibility-

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28      The Peeling Model
                         1. Introduction
                                 -Three Propositions
                        2. Enforcement
                                  - General Concepts
                         3. Communication
                                  - General Concepts
               4. Communication and Enforcement
                                  - Perception,
                                  - Objective Chance to Get Caught
                                  - Subjective Chance to Get Caught
                                  - Target Groups
               ,•'£ >;;"££... 5. The Ceding Model,  * ,
                                 - The Peeling Model
                                 r- Credibility
                      6. Making Things Work
                                 - Strategic Wheel
                         7. Checklists
                      8. Information Sources

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                                                  The Peeling Mode)
5  The  Peeling   Model
To  optimize the effect on compliance  it is  necessary to attune action and
communication not only to each other but also to the regulated community.  In
this chapter we present a model for integrating communication and enforcement.
The Peeling Model provides you with a systematic guideline. The model is based on
a marketing view, looking at enforcement as a product, where communication is a
marketing-instrument to sell the product to your target groups.

 5.1 The  Peeling  Model:  Enforcement  in  7  Layers
The Peeling Model consists of six  levels of communication  laid around the
enforcement action.
             1. Enforcement action: inspection and sanction
             2. Enforcementsignals
             3. Enforcement action-communication
             4. General enforcement-communication
             5. Communication on regulation
             6. Educating-communication
             7. Topic communication
Figure  5
The Peeling Model

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  30
The Peeling Model
                  1. Enforcement  Action
                  The  heart  of  every  enforcement  project  must   be  the
                  enforcement  action. The  executed  inspections  and  issued
                  sanctions   are   the  'Bull's   Eye'   of  your  enforcement-
                  communication  strategy.  There is a range of dimensions on
                  Which enforcement actions can vary.
  Enforcement Actions:
• inspections:
       • single - multi media
       • personal - written contact
       • selfmonitoring - direct inspections
       • announced - unannounced
       • inspection of whole target group -selection
       • once - more than once
       • inspections equally spread in time - concentrated
• sanctions:.,
       • fines
       • restoring environmental damage
       • withdrawal of licence
       Illegal  Waste  Transport  I
       For the  Illegal Waste Transport across  the  boarder a  licence is
       required.  Related to  this  licence  is  a  set of  regulations and
       requirements.   To promote compliance with  these regulations  the
       Government has decided to intensify inspections at the boarders and
       along the highways.                     <     .""• '•'.''••"•
       Sanctions are dependant on  the seriousness of the offences. Besides
       fines, sanctions can include the withdrawal of the licence for  waste
       transports.
                  Z.  Enforcementsignals
                  The  most elementary  form  of  communication  is  directly
                  connected  to the physical  presence of the  inspectors. This
                  communication  on the  spot makes  the enforcement directly
                  visible.  Visibility  is  important to  raise the  awareness  and
                  attention for the enforcement effort, especially with the people
                  directly involved. It enlarges the effect on the subjective chance
                  to get caught. To keep the regulated community guessing, it is
                  necessary  to alternate  between  obtrusive  and  unobtrusive
                  inspections.
  Enforcementsianals:
• uniform
• car/ boat/ airplane
* logo/label/seal
• technical equipment

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                                                       The Peeling Model
        Illegal Waste Transport  II
        To increase the visibility of the inspections at the boarder inspectors
        drive cars that can easily be recognized by a logo. Moreover signs,
        stating 'waste transport inspection' are used to direct drivers to the
        place  where  the  inspections  take  place. For inspections on  the
        highway  a helicopter will  sometimes be  used  to track  illegal
        transports. Inspectors on the ground than mostly operate undercover,
        driving in  unobtrusive cars.  Visibility in this way is varied.
                  3. Enforcement  Action-communication
                  The second  layer of communication  has specific  enforcement
                  actions as subject, but is not directly related to these actions. It
                  increases  the visibility of  the enforcement  action  with  the
                  inspected  member of the regulated community, but even more
                  important,  to  the  other  members.   Enforcement  Action
                  communication spreads the  impact of an inspection  out  over
                  broader parts of the targeted community.

  Enforcement Action-communication:
• individual announcements
• announcements of inspection in branchemagazines, newsmedia etc.
• publishing inspection-results and issued sanctions
• public disclosure of names of offenders
• publicity during the enforcement-project
• individual reports of inspection results
       Illegal  Waste  Transport  III
       Furthermore, the effect of the inspections is enlarged by the use of
       signs near the boarder.  These signs announce the inspection of waste
       transports. At the same  time posters at 'trucker-restaurants' along
       the road warn  for transport inspections. To create awareness of this
       enforcement  action  with  even larger  parts  of  the  regulated
       community a couple of press releases will create publicity on  this
       issue. On top of this, reporters of national television are invited to
       visit the'inspection scene'.
                 4.  General   Enforcement-communication
                 The regulated community is  informed  in a more general way
                 about  the  intentions  of  the  environmental  enforcement
                 department. New methods of enforcement can be introduced,
                 changing priorities, news about the enforcement capacity etc.
                 Keeping enforcement in general  under the attention  of  the
                 public supports the impact of the inspections executed.

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3 2      The Peeling Model
 General Enforcement-communication:
 publicity about the enforcement department
 individually informing companies
 publicity about the enforcement policy, priorities and methods
 publicity about new methods of enforcement
 publicity about new technical equipment
      Illegal  Waste  Transport IV
      Transportcompanies are informed on  the enforcement actions by a
      brochure.  In  this  brochure the  department  responsible for the
      enforcement of the transport-regulations is introduced. The priority
      of illegal waste transports is made clear and the intended enforcement
      methodes are explained. Besides this brochure, the same information
      is  also  presented  in  an article  in a  businessmagazine  for
      transportcompanies.  A   press  release  about  the  spectacular
      inspections with the use of the helicopter will create extra publicity.
                5.  Communication on regulation
                This layer of communication  is not directly  connected to the
                enforcement-methods. Communication on regulation  explains
                the rules of the game. This informative function is the bases of a
                good enforcement.  Without knowledge of the rules compliance
                can not be achieved.
 Communication on regulation:
 information brochures
 informative meetings/ company visits
 speeches of the minister introducing new rules
 announcing higher sanctions
      Illegal  Waste  Transport  V
      To inform the transportcompanies on the regulations attached to the
      licence for illegal waste transports a videofilm and  accompanying
      leaflet are sent to branche organisations and individual  companies.
                6.   Educating-communication
                Through use  of different  media it is  tried to  educate the
                regulated  community  to   comply  to  the  environmental
                regulations. Not because of possible sanctioning when they don't
                comply  but  out  of understanding  and  support  for  the
                environmental policy. It is aimed at achieving knowledge about
                and a positive attitude towards environmental regulations. This
                enhances the credibility of your enforcement.
 Educating communication:
 publicity campaigns with argumentation of regulations
1 brochures
 informative meetings
 conferences

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                                                     The Peeling Model
      Illegal  Waste  Transport VI
      In order not only to inform on, but aslo to build understanding of and
      support for,  the Regulations Jand it's  enforcement,   transport
      companies are invited to attend a special conference on transport and
      (environmental) regulations. At this conference the reasoning behind
      t/ie regulations  and the enforcement is explained. The press is also
      invited at this conference^    ::              "'.
                 7.  Topic  communication
                 The outer  layer  of  the peeling model  brings  a specific
                 environmental problem to the attention of the  community. It
                 makes it  an issue of concern;  puts the topic on the agenda.
                 Through this agenda-setting support for the regulations and
                 willingness   to  comply  is   stimulated.  Like   educating
                 communication it supplies the enforcement with credibility and
                 acceptance.
  Topic communication:
• publicity campaigns about environmental problems
• reports on environmental problems
• articles in magazines
• discussions on T.V. and in newspapers
       Illegal  Waste  Transport  VII
       To put  the issue of illegal waste transports and it's environmental
       dangers on the public and media-agenda, several reports on this topic
       are published. National publicity is created through interviews given
       by the responsible ministers (of the Environment,  of Justice and of
       Traffic & Transport) on television and in newspapers.
  5.2  Layers  ReTnforcing  Eachother
  In  §5.1  the different  layers are  discussed  separately. In reality they  are
  interrelated. If the relation between every layer is consistent they reTnforce each
  other.  If there is no cohesion between the separate levels, or worse,  if they
  contradict each other, the effectiveness of the enforcement will suffer from it.

  Moving from one layer to the other,  we shift gradually from the enforcement
  department as sender (layer 1-4) towards the Government as sender (5-7).

  This  manual is mainly  about layer 1-4.  In layer 5-7, with the  Government
  sending the message, the focus  lays on informing the regulated community and
  changing attitudes. Layer 1 -4,  related to the enforcement action, concentrate on
  influencing behaviour directly. How these layers can be molded in one consistent
  and effective product of enforcement and communication is the subject of the next
  chapter.

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 3 4      The Peeling Model

 5.3  The  Credibility Trap
 When using the Peeling Model it is tempting to scare the regulated community
 with announcements of inspections and a lot of publicity on planned enforcement
 projects. This seems a relatively  inexpensive way to improve the compliance
 rates, without executing too many  inspections. On the short term this can indeed
 be effective. However on the long  run this will be contra-productive. Enterprises
 start to notice you are not actually living up to the expectations you create. In the
 end the  regulated community ignores your communication. This is what we call
 the boomerang-effect  of  communication.  You've  lost  your  credibility. This
 dilutes the power of enforcement in general and communication in particular.
 Credibility  doesn't  stop at enforcement: if enforcement looses credibility  it
 tiggles down to environmental policy and vice versa.

The  credibility  trap  should  always   be  avoided.  To  accomplish   longrun
 effectiveness you should stick to the basic Rules of Enforcement:

              7. No Enforcement without Communication
             2. No Communication without Enforcement

This  chapter  presented   a  model   for  integration  of  enforcement   and
communication.  In  practice, this  demands  a  strategic approach. Chapter  6
explains what a strategy is and  helps you to develop and implement an effective
enforcement-communication strategy. It puts the Peeling Model in practice.

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                Proposition  3:

"A strategic approach  of both  enforcement and
 communication is a  prerequisite  for  succes."
               - The Strategic Wheel -

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36      Making Things Work
                         1. Introduction
                             i
-Three Propositions
                        2. Enforcement
                                  - General Concepts
                         3. Communication
                                  - General Concepts
                4. Communication and Enforcement
                       5. The Peeling Model
                                  - Perception,
                                  - Objective Chance to Get Caught
                                  - Subjective Chance to Get Caught
                                  - Target Groups
                                  - The Peeling Model
                                  - Credibility
                                  - Strategic Wheel
                         7. Checklists
                      8. Information Sources

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                                                 Making Things Work    37
 6   Making   Things   work
 A strategic approach is necessary to realize integration of enforcement and com-
 munication as described in the former part of the manual. A strategic approach
 implies developing a strategy based on good analyses. There is no such thing as
 'one best strategy'.  In this  chapter  the  Strategic Wheel  is  presented. This
 strategic processs brings along some crucial questions which should be answered.
 The checklists, presented in chapter 7 can help you with this.

 6.1  The Strategic Wheel
 A strategic approach in practice means short and especially longterm objectives
 should be formulated  related to specific target  groups. There must be  an
 enforcement plan or pattern which consists of six basic elements:

   . 1. Analyses
    2. Target group definition and objective setting
    3. Product development1
    4. Organisation
    5. Execution
    6. Evaluation
      'In the  case of enforcement, 'product development1 is combining  enforcement
      actions and communication actions.

 The strategic enforcement process  is depicted below.  We call it the Strategic
 Wheel. In this wheel it is analyses that  keeps it all together. The outer part of the
 wheel concerns the choices you have to make.
                          target groups
                          & objectives
                                                enforcement &
                                                communication
                                                    action
Figure  6
The Strategic Wheel

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38     Making Things Work
                               1.     Analyses:
                                      A  Never  Ending  Starting  Point

The foundation of strategic enforcement planning should be a continuous process
of analyses. First of all it's important to have a  clear view on your starting
position,  external  as  well  as  internal.  Every  environmental enforcement
situation is different from the other, demanding a different strategy. That's why a
good strategy development needs  an analyses of the situation. This first analysis
is the starting point on which you base the consecutive choices you have to make.

Externally this means making an inventarisation in the  gross  of the present
situation of the environment and of compliance. What positive developments, can
you  discern? What are the negative ones?  Internally you  should ask yourself
what the strong points are  of the present enforcement and where the weak spots
are.

It's important to  understand analyses  never stops. Every  other phase  in the
stragegy processs brings a need for new or more detailed information. Analyses
must be a  continuous process.  New information comes in  and old information
must be  refined.  During  the strategy  process  your analyses  evolves  to an
evermore detailed  level. At the  same time  more fundamental  changes  in the
situation can be processsed.

The analyses can be divided in an external and internal part. Both are subdivided
in problem and fieldmap, as presented in the following  matrix.

Basic  Questions:	
               problem
                              field map
 external
 What:
 * is the issue?
1 * is the environment-problem?
I*'is the environmental policy?
I * are the  regulations?
. * kind of  licensing?
1 * is the specific context?
 Who:
 * are the target groups?
 * are the organizations?
 * are the persons responsible?
 * are the intermediaires?
 * are the 'third parties'?
 internal
! What:
 * are the time conditions?
 * are the financial resources?
 * are the human resources?
 Who:
I * is directly  involved?
 * is responsible?
 * executes?
 * is indirectly involved?
See also checklists 1 & 2.

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                                                 Making Things Work    39
                          2.   Target  Groups  and  Objectives:
                                    Determine  Your  Results
Making the Strategic Wheel spin starts with the determination of objectives and
target groups. Defining objectives  and  target  groups gives  direction to your
enforcement-strategy.  It  helps  to focus  your enforcement efforts.  This  is
especially important because every enforcement department has to deal with
limited  enforcement  capacity.  Formulating  objectives  also gives you  the
opportunity to evaluate the progress you make.

Objectives and target groups are closely intertwined. An objective determines the
target  group,  the target  group  determines  the  objective,  see  figure   9.
Determining your results is always a combination of both objective and target
group.
                objective
                           target group
Figure  7
Objective and Target Group

Target groups and objectives can be discerned on three levels, see figure 10:
Level
Examples  of
Target Groups
Objectives
1. Enforcement Policy   Chemical Industry
                       Car-dismantlers
2. Enforcement
   Action
3. Communication
   Action
Five Biggest Companies
Companies in District X
Company Management
Workfloor
Public
                           Compliance
Number of Inspections
Chance to Get Caught
Issued Sanctions

Attention
Knowledge
Attitude
Intention
Behaviour
Figure  8
Three Levels of Target Groups and Objectives

Basic  Questions:
What is your target group on each level?
What objective do you formulate on each level?
See Checklist 3 & 4.

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 40     Making Things Work
                 	^    3.  Product  Development: Combining
                              Enforcement  and  Communication

 To  reach  your objectives within your  target group  you need  a product;  a
 combination of enforcement action and communication. This combination must be
 attuned to your target group and objective. To achieve this, there are a number of
 jnspectionvariaties available, together with  a wide  range of different kinds of
 communication.

 Basic  Questions:
 Enforcement
: What is the objective of the enforcement?
: What are the characteristics of the target group?
 (like: size of target group, location, level of compliance etc.)
: Which Enforcement Action best fits the target group and objective?
: How do you plan your enforcement action?
'. Who is responsible for the actions?

 Communication
: What is the objective of the communication?
: What are the characteristics of the target group (audience)?
 (like: size of target group, media-use, attitude towards regulations etc.)
: Which Communication Action best fits the target group and objective?
      - On which level do you communicate?
        (layers in peeling model: signals, enforcement action communication,
        general enforcement communication etc)
      - Which media do you use?
         (printed press/ TV/Radio, written and/or personal communication)
      - What do you communicate?
        (message, tone of voice)
      - When do you communicate?
        (before, during, after enforcement action)
      - Who's the sender?
        (government, the enforcer etc.)

 See Checklist 5, 6 & 7.

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                                                 Making Things Work    4J
                              Organisation:
                              A Crucial  Element
 An important part of the strategy is a good organisation. Organisation must bring
 mutual  adjustment  between  enforcement  and  communication  in  practice.
 Preferably this  is done by project-organisation. This brings enforcement skills
 and communication skills together in project teams. Getting organised starts with
 making a plan, which answers the basic questions.

 Basic  Questions:
'. Who are the members of the project team?
; What tasks should be executed?
i Who is responsible for which task?
; How is cooperation and coordination accomplished?
• What is the time-schedule?
 See checklist 8.
                              Execution:
                              Flexibility,  Creativity   and   Skills

 Every strategy, how well planned and organised it may be, is worthless without
 execution. Preperation won't help you, if you don't have the skills, creativity or
 time, to execute your strategy.

 Besides  skills and creativity the  execution of enforcement and communication
 demands flexibility. You must be able to make use of recent developments, react
 to changing situations etc. In times like this, where developments go ever so fast,
 you must be able and prepared to adjust. This demands continuous monitoring of
 the progress you make.

 For the  succesful execution of your communication checklist 9  presents some
 general  tips.

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42      Making Things Work
                              Evaluation:  a  powerful!  instrument

In  practice not much attention is paid to  the evaluation  of enforcement and
communication-actions. But evaluation is a powerfull instrument. First of all it
shows the results you have achieved. Secondly, these results are important input
for your communication (you can show good and bad examples). And finally and
maybe most important it gives you the opportunity to judge the effectiveness of
your strategy and make adjustments if neccessary.

Like analyses, evaluation is a continuous process. Keeping a constant eye on the
effectiveness  of  your  enforcement-communication  strategy is  necessary.
Comparing  results with the objectives you've_set puts a check on your strategy.
Results  deviating from your objectives can point to problems within one or more
of your strategic elements, like: incomplete analyses,  confusing target groups,
unrealistic  objectives,  ineffective  enforcement-communication combination,
massy organisation, lacking communication skills or badly performed evaluation.

Evaluation can be devided  in process and effect evaluation,  process evaluation
focuses on the progress the project makes. Effect evaluation compares results
with objectives.

Basic Questions:
What are you going to evaluate?
How are you going to evaluate?
Who is going to evaluate?
When are you going to evaluate?

See Checklist 10 & 11.

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Checklists

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44     Checklists
                         1. Introduction
                                 -Three Propositions
                        2. Enforcement
                                  - General Concepts
                         3. Communication
                                  - General Concepts
                4. Communication and Enforcement
                                  - Perception,
                                  - Objective Chance to Get Caught
                                  - Subjective Chance to Get Caught
                                  - Target Groups
                       5. The Peeling Model
                                 - The Peeling Model
                                 i- Credibility
                      6. Making Things Work
                                  - Strategic Wheel

                          -•'•-: ,v
                      8. Information Sources

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                                                     Checklists
45
 7   Checklists
This chapter contains 11 checklists which can help you to put the strategic wheel
in motion. The checklists are:

I.    Analyses
       1. External Analyses
       2. Internal Analyses

11.  Target  Groups and Objectives
       3. Select Target Groups
       4. Formulating Objectives

III. Enforcement and Communication  Product
       5. Dimenisons of Enforcement Actions
       6. Dimensions of Communication Actions
       7. Characteristics of Communication Instruments

IV.   Organisation
       8. Basic Elements of Organisation

V.   Execution
       9. Tips on  How to Communicate

VI.   Evaluation
       10. process evaluation
       11. Effect evaluation

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  46     Checklists

  Checklist   1

  External   Analyses

  The external analyses gives you a clear view on different aspects of the
  environmental problem and the relevant regulations. It will also help you to
  identify the members of the regulated community with whom you have to deal.

  Key  Items of External  Analyses	

  l.The  Environmental  Issue
• What is the issue?
• What is the effect on the environment?

  2. The  Environmental  Policy
• What is the policy concerning this issue?
• Is It a priority for the environmental policy?
• What are the general objectives concerning this issue?
• Which (policy) instruments and measures are available?

  3. The  Environmental  Regulations
• What are the relevant regulations?
       -international
       -national
       -regional/local
• What are the possible sanctions?

  4. The Regulated  Community
  Which companies?
  How many?
  Where are they located?
  What are their economic and organisation characteristics?
  Who is responsible concerning this issue?

  5. Concurrent  activities
  Are there  any other relevant enforcement actions concerning the same field
  during this period?
  Are there  any other relevant communication actions concerning the same field
  during this period?

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                                                       Checklists     47


  Checklist   2

  Internal    Analyses

  Internal analyses helps you to define the conditions under which you have to
  perform the enforcement and communication actions. At the same time it maps
  the people who are involved.

  Key  Items of Internal Analyses	

  I.The  Enforcement  Policy
• What are the main principles and objectives of the enforcement policy?
• What are the present priorities of the enforcement policy?
• Which enforcement instruments are being used?

  2. The Enforcement Conditions
• What is the time and budget available?
• How much inspection capacity is (when) available?
• What is the level of experience and know-how in general?
• What is the level of experience and know-how concerning this issue?

  3. The  Enforcement  Responsibilities
• Who is responsible for the enforcement in general?
• Who is responsible for the enforcement in this particular case?

  4. The Communication Policy
• What are the main principles and objectives of the enforcement-communication
  policy?
• What are the present priorities of the communication policy?
• Which enforcement instruments are being used?

  5. The Communication  Conditions
• What is the time and budget available?
• How much communication-capacity is (when) available?
• What is the level of experience and know-how in general?
• How is the relation between communicators and enforcers?

  6. The  Communication  Responsibilities
• Who is responsible for the communication in general?
• Who is responsible for the communication in this particular case?

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  48     Checklists

  Checklist  3
  Select  Target   Groups

  Target groups can be selected on three different levels:
1. Enforcement Policy
2. Enforcement Action
3. Communication Action

  Analyses and selection of each target group should include the following
  considerations:
                                                                 I
  Key Items  of  Target Group Analyses  and Selection	

  1. Structure of the  Target Group
 • How many members?
 * What are their  main, relevant characteristics?
       -individuals  / organisations,
       -economic activity
       -etc.

  2. Relation to  the  Environmental  Problem
 • What do they know about the environmental issue at hand?
 • Do they care about the environmental problem?
 • Do they take measures to protect the environment?

  3. Relation to  the  Environmental  Regulations
 * What do they know about the relevant regulations?
 • How do they feel about the regulations?
 • What are the consequences of these regulations for the target group?
 • Do they comply?

  4. Relation to  the  Enforcement Policy
 • What do they know about the enforcement policy?
 • How do they feel about the enforcement policy?
 • Are they influenced by the enforcement policy?

   5. Media  Use
 • Which media are used by your target audience?
 • How reliable and credible are these media?
 • What is the outreach of these media?

   6. Information  Need
 • Which questions does your audience have?
 * Are these questions relevant in relation to the issue at hand?
 • What information does your audience need?

   7.  Intermediaires
 • How is you target audience organised?
 • Are there institutes, organisations and/or  individuals through which you can
   reach your audience?

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                                                         Checklists      49


  Checklist  4
  Formulating   Objectives

  Objectives can be formulated at the same three levels as the target groups:
1. Enforcement Policy
2. Enforcement Action
3. Communication Action
  At each level the objective-formulation should be:

  Formulation  of  Objectives	

  1.Target Group  Related
 • With whom do you want to reach the desired effect?

  2. Measurable
 • Is it in future possible to check whether you achieved your objective?
 • How are you going to check your results?
 • Can you measure your results objectively?

  3. Specific  and  quantified
 • Can you quantify your objective?
 • Is your objective specific and easy to work with?

  4.  Time-related
 • Is it clear at what moment the objective must be achieved?
 • Have you defined any landmarks during the process?

   5.  Motivating
 • Is the objective (perceived to be) challenging but realistic?

   6. Clearly  Stated
 • Is the objective easy to communicate?
 • Is there only one interpretation of the objective possible?

   Examples  of Objectives:

   1. Level of Enforcement Policy:
   Within two years 7596 of the car-dismantlers in the Netherlands must be in full
   compliance with the regulations, stated in the Waste Substances Act. After four years
   this must be 85%.

   2. Level of Enforcement Action:
   The first year 100% of the car-dismantlers in the Netherlands must be paid an
   informative  and  first-inspection visit to register and warn non-compliars. During
   the next year 100% of all registered non-compliars should be inspected and if
   necessary sanctioned. The next two years car-dismantlers must be inspected every 6
   months. If violations are found sanctions should be issued and an inspections should
   take place within 3 months.

   3. Level of Communication Action:
   Within one year 95% of the car-dismantlers in the Netherlands must be known with
   the environmental regulations concerning their company and be aware of the intentions
   to intensify the enforcement of these regulations. After two years they must estimate
   the chance to get an inspection as being  "(reasonably )high" and 95% must state to
   have the intention to comply.

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  50     Checklists


  Checklist   5
  Enforcement   Action

  In relation to your objectives and target groups you can shape your enforcement
  action. Variations on the following dimensions are possible:

  Dimensions of  Enforcements Actions	
                                                                i
  1. Kind  of Inspection:       Single  or   Multi-media
• Is it possible to execute multi-media inspections?
• What are the advantages of multi-media inspections in this case?
• What are the disadvantages of multi-media inspections in this case?

  2.  Procedure:        Announced  or Unannounced
• Is it possible to announce the inspections?
• What are the advantages of announced inspections in this case?
• What are the disadvantages of announced inspections in this case?

  3.  Intensity:         Once or More than Once
* Do you have the resources to inspect more than once?
• What are the advantages of more than one inspection in this case?
• What are the disadvantages of more than one inspection in this case?

  4.  Equipment
• What equipment do you have and how effective is it?
• Does this equipment influence your communication possibilities? (helicopter,
  car, thermometer etc.)

  5.  Surprise:         Expected or Unexpected
• How can you make the inspections surprising?
• Does a creative unexpected approach increase your impact?
• Can you add newsvalue by a creative unexpected approach?
• Are you taken serious?

  6. Time  spread:             Concentrated or  Large  Spread
• How is your inspection-capacity spread over time?
• What do you gain by short periods of intense inspections?
• What do you loose by short periods of intense inspections?
  7.  Contact:                 Written or  Personal
 1 Can you achieve eye to eye contact?
 1 What do you gain by personal, eye to eye contact?
 1 What do you loose by personal eye to eye contact?
  8.  Sanctions
• What kind of sanctions do you issue? (ex.: fines, licence withdrawal)
• How much time goes by between detection and the sanctioning?
• Do you relate sanctions to the caused pollution? (ex.: cleaning, restore damage)
• How do you treat repetition of offences?

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                                                        Checklists      51


  Checklist   6
  Communication   action

  In relation to your objectives, target groups and enforcement action you can
  shape your communication action. Variations on the following dimensions are
  possible:

  Dimensions of  Communication  Actions	'	

  1.  Media:
a publicity
a written
a personal
  (characteristics of media see checklist 7)

  How does the target group normally get their information?
  What's the best way to attract the attention of the target group?
  Are there any specific media used by the target group?
  Which kind of media best serve this project?
  What different frequencies and deadlines best fit your planning?
  What in-house-experience in communication do you have?
  What are the financial and human resources available?

  2.  Message:
a problem
a policy
a enforcement
a regulation
a inspections
a sanctions

  What does the target group  know about the environmental problem?
  What does the target group  know about the environmental policy and regulations?
  What does the target group know about the environmental enforcement?
  What is the attitude of your audience towards those issues?
  Is the objective to influence  attention, knowledge attitude, intention and/or
  behaviour?

  3.  Timing
a before
a during
a after

• When do you get the most attention for your message?
• What timing maximizes the  newsvalue?
• Are there possibilities to  communicate before,  during and after the enforcement
  action?
• Does communication before the enforcement action increase or decrease the
  impact?
• Is it possible to prolonge the effect of enforcement action by 'follow up
  communication'?

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  52
Checklists
  4.  Sender
o Government
a politician
a enforcement
a inspector
      department
  Which sender would create newsvalue?
  Which sender has authority for the target group?
  Where is the most experienced and appropriate communicator?
  Where are (human) resources available?

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                                               Checklists
                                  53
    Checklist   7
    Communication   Instruments
    Characteristics  of  Communication Instruments
Instrument  >
Objectives
                                              jCharacteristics
attention :knowledae attitude
' publicity .
; Press release x j x i x
: i ' '
i *
i
Radio item x j : x
TV item xxx
Magazine xxx
written communication
Letter ; x x x
;
Brochure , x x
personal communication
Training/course : : x x
Personal Meeting x ; : x
j
; Group Meeting x x x
; Lobbying
! intention

i

[
x

x


X
x :
i
i
x ;
behaviour

j informative
; controlled
up to date
variable outreach
limited information
high outreach
; short
high impact
1 high outreach
short
target group directed
informative
documentation function

personal
. high attention value
: informative
individual
one-way communication
informative
controlled
documentation function

x two way communication
high involvement
. intensive information
tarqet group directed
individual
high impact
; maximum feedback
controlled
; interactive
target group
: formal
.x i informal
: interactive
personal

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 54     Checklists


 Checklist  8
 Organisation

 In order to attain a well coordinated and adjusted set of enforcement and
 communication actions special attention must be paid to the organisation of the
 project. This concerns five basic elements:

 Basic  Elements  of  Organisation	

 1. Activities
• What actions are you going to take?
* Which tasks have to be furfilled?

 2.  Responsibilities
• Who are the projectmembers?
• Who is the projectleader?
• Who is involved in the execution?
• Who is  executing which task?

 3. Structure
• In what structure do you operate?
• Do you create a projectteam?

 4. Internal Communication
• How do you accomplish cooperation and coordination?
• Who should be informed within the enforcement and environmenal department?
• How do you inform them?
• Which other parties do you work and communicate with?

 5. Planning
• When do you plan to take action?
• What asks for preperation, how long in advance?
• Is it a temporary project or a permanent activity?
• Have you planned your follow-up?
• Did you plan your evaluation?

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                                                        Checklists
55
Checklist   9
Execution

Organisation must be followed by execution. The quality of the execution makes
the difference between succes and failure. In order to assure a good quality of
communication the following tips can be helpful.
Tips on  How to Communicate
1.   Press/Publicity
 Speak with one voice; assign one individual to coordinate and communicate
 Build and maintain good relations with the press
 Create newsvalue, by planning unexpected and conspicuous actions
 Prepare your press presentations
What is your point?
What does the press want to know?
Which questions can you expect?
Provide  yourself with correct back-up documentation
Keep it  simple
Know the deadlines of your audience.
Pick your medium carefully
Make your message attractive, media-genie

2.  Written media
Attune content  and style of writing to your audience
Structure your  text
Extensive texts  should include a 'contents/index', an 'abstract1 and a 'readers
guideline'
Formulate clear and concise
Use simple words and short sentences (15 words on average)
Balance text and illustrations
Pay ample attention to a good lay-out
Keep in  mind the time needed for development and production of the material
Ask yourself, beforehand how you distribute your material:
on request
as direct mail
as additional information to other reports
stocking material at 'hot' locations
hand-out personally

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 56     Checklists


 Checklist   10

 process   Evaluation

 The value of process evaluation lies in the insight it can give you in the way the
 project is progressing. Furthermore process evaluation learns you  how every
 part of the strategic wheel is functioning. Are there any bottle necks in the
 analyses, target group and objective formulation, seleceted enforcement and
 communication actions organisation, execution or evaluation?

 process evaluation of the Enforcement and  Communication Project
D How did preperation, execution and follow-up work out?
D What can we learn from this for future activities?

 Key  Questions of process Evaluation:	

 1. What do you want  to know?
• costs compared to budget
• execution compared to planning
• efficiency of human resources
• media- outreach
• efficiency of technical equipment/logistics
• opinion of employees on  cooperation, internal communication etc.

 2. How are you going to know this?
• surveys
• desk research and administration
• (informal) talks  with employees
• measurement

  3. Who evaluates?
• internal  or external agency

  4. When do  you  evaluate?
• Determine in advance at what moment you evaluate

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                                                         Checklists
57
  Checklist   11
  Effect   evaluation
  Effect evaluation makes it possible to compare the results of your activities with
  the objectives you've formulated. Because objectives can and should be
  formulated at different leves, you should also evaluate on these different levels.

  Effect Evaluation  of the Enforcement  and Communication  Project
D What effect did you sort with your enforcement and communication activities?
q What can we learn from this for future activities?

  Key  Questions of  Effect Evaluation:	

  1. What do you  want to  know?
  effect on attention
  effect on knowledge
  effect on attitude change
  effect on intended  behaviour
  effect on behaviour/ compliance

  2. How are you  going to know this?
• quantitative and/or qualitative research
• desk research and administration
• surveys
• measurement

  3. Who evaluates?
• internal or external  agency
  4. When do you  evaluate?
 1 Determine in advance at what moment you evaluate.
  Tips on  the  evaluation  in  general

   Make sure your evaluation matches the objectives you've set.
   Integrate the evaluation of communication and enforcement.
   Choose an evaluationmethod which fits the size of your project.
   Your evaluation should conclude with tips for the future.
   Elaborated research should be done by a specialised agency.
   Evaluation costs time and money.
   Make sure your evaluation is objective
   Don't evaluate for the sake of evaluation but to do better in the future.
   Take someone objective and not responsible for (parts of) the project.

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58
Checklists

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 Information   Sources
- Documentation on Enforcement-
-Documentation on Communication-
    -Documentation Centers-
         -Institutes-

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60     Information Sources
                         1. Introduction
                                 -Three Propositions
                        2. Enforcement
                             1
- General Concepts
                         3. Communication
                                  - General Concepts
                4. Communication and Enforcement
                                  - Perception,
                                  - Objective Chance to Get Caught
                                  - Subjective Chance to Get Caught
                                  - Target Groups
                       5. The Peeling Model
                                  - The Peeling Model
                                 r- Credibility
                      6. Making Things Work
                                  - Strategic Wheel
                         7. Checklists

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                                               Information Sources    61
8   Information   Sources
All sources marked with an '*' are in the English language.

Documentation on  Enforcement	

Baaijens, I. (1995). Kwaliteit van Handhaving: meer dan /outer controleren. Noord-
Holland: Dienst  Milieu en Water.

*Enforcement and Compliance Assurance Accomplishments Report FY1994 (1995).
Washington, DC: Environmental Protection Agency, United States.

* Environmental Law Enforcement in practice in the Netherlands: an integral approach
(1995). Capelle a/d Ussel: Inspectorate-General International Affairs, The
Netherlands.

Handhaving milieuwetten: Landelijk Handhavingsproject Industrie 1992, Deelrapport:
Grafische bedrijven en verpakkingsdrukkerijen (1993).  Ministry of Housing,
Spatial Planning  and the Environment, Inspectorate for the Environment: The Hague,
the Netherlands.

Handhaving milieuwetten: Landelijk Handhavingsproject Industrie 1992, Deelrapport:
grote emittenten (1993).  Ministry  of Housing, Spatial Planning and the Environment,
Inspectorate for the Environment: The Hague, the Netherlands.

Handhaving milieuwetten: Landelijk Handhavingsproject Industrie 1992, Deelrapport:
gemeentelijk  milieubeleid (1993).  Ministry of Housing, Spatial Planning and the
Environment,  Inspectorate for the Environment: The Hague, the Netherlands.

*International Enforcement  Workshop (1990). Proceedings Vol. 1. May Utrecht:
Environmental Protection Agency, United States, Ministry of Housing, Spatial Planning
and the Environment, the Netherlands.

International Enforcement  Workshop (1990). Proceedings Vol. 2. May Utrecht:
Environmental Protection Agency, United States., Ministry of Housing, Spatial
Planning and the Environment, the Netherlands.

*International Conference on Environmental Enforcement (1992). Proceedings Vol. 1.
Sept. Budapest:  Environmental Protection Agency, United States, European Economic
Community, Ministry of Housing, Spatial  Planning and the Environment, the
Netherlands.

*lntemational Conference on Environmental Enforcement (1992). Proceedings Vol. 2.
Sept. Budapest:  Environmental Protection Agency, United States, European Economic
Community, Ministry of Housing, Spatial  Planning and the Environment, the
Netherlands.

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62      Information Sources

 *Landfill Methane Outreach Program: Voluntary Pollution Prevention at a Profit.
 Environmental Protection Agency, United States Atmospheric Pollution Prevention
 Division.

 LeidraadHandhaving('\993'). Provincie Noord-Brabant, Nederland

 Milj0-og Energiministeriet Miljostyrelsen.  Milj0tilsyn  1993.

 ^Principles of Environmental Enforcement (1992). Washington, DC: Environmental
 Protection Agency, United States.

 Publikatiereeks Stoffen, Veiligheid, Straling. De perceptie, acceptatie en communicatie
 van milieurisico's. nr.  1993/6, Ministry of Housing, Spatial Planning and the
 Environment, the Netherlands.

 Samen werken aan een duurzame stadC\ 995).(Horeca-case)  Tilburg: Gemeente
 Tilburg.
                                                                i
 *Strock, J.M. (1990). E.P-A.'s Environemental Enforcement in the 1990s. In:
 Environmental Law Reporter, aug., 10327-10332.
                                                                i
 *Third International Conference on Environmental Enforcement (1994). Proceedings
 Vol. 1. Apr. Oaxaca: Environmental Protection Agency, United States, World Wildlife
 Fund, UNEP, Sedesol, Ministry of Housing, Spatial Planning and the Environment, the
 Netherlands.

 *Third International Conference on Environmental Enforcement (1994). Proceedings
 Vol. 2. Apr. Oaxaca: Environmental Protection Agency, United States, World Wildlife
 Fund, UNEP, Sedesol, Ministry of Housing, Spatial Planning and the Environment, the
 Netherlands.

 Tijdschrift Handhaving,  Magazine for Enforcers, Ministry of Housing, Spatial Planning
 and the Environment, the Netherlands.
Documentation  on  Communication	

*A Primer on Health Risk Communication:  Principles and Practices. U.S.Department
of Health and Human Services.

*Environmental Commication Strategies in Europe: Workshop for Communication
Officers of National Environmental Services (1995). Sept., International Academy of
the Environment.

Floor, K. & Van  Raaij, F. (1989).  Marketing Communicatiestrategie. Antwerpen:
Stenferd-Kroese.

*Fortner, R.W. c.s. (1994). Handbook for Environmental Communication in
Development. Ohio.

*Garn,  J. (1993). Sonoma Green Business First Year Evaluation. U.S.: Environmental
Learning Systems.

Handboek Milieucommunicatie (1995). Alphen aan de Rijn Samsom
Bedrijfsinformatie bv.

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                                               Information Sources    63

Handleiding Communicatie Milieu. Provincie Utrecht, The Netherlands.

Klandermans, B. & Seydel, E. (1987). Overtuigen en Activeren. Assen: Van Gorkum.

*McFadden, D. (1994). Take it from a groundhog...PR works. Software Publisher
Magazine. May/June.                                   .   ;

Meegeren, van, P. (1995). Milieuvoorlichting: model voor een planmatige
voorbereiding. Amsterdam: Boom

* National Enforcement Training  Institute (1995). Don't Die With The Secret: Ways of
Communicating Enforcement and Compliance Assurance Succes. '(training course by
Environmental Protection Agency, United States).            i

Preventie door communicatie: Communicatieplan voor de preventieve handhaving van
de WVO door Rijkswaterstaat (1994). Amersfoort: Damming, Dorreboom & Partners.

*Severin, WJ. & Tankard. J.W. (1987). Communication Theories. New York: Longman

*Schultz, D.E., c.s. (1993). Integrated Marketing Communications
Chicago: NTC Business Books.                              j
                                                        j
*Veenman, J.C.M. (1994). The Role of Communication for Implementing Enforcement
Policy. In: Third International Conference on  Environmental Compliance and
Enforcement, p. 293-300.                                |
Documentation  Centers         ,                       '

American Documentation Center, Embassy of the U.S., The Hague, The Netherlands
Library of the University of Wageningen, The Netherlands
Library of the University of Amsterdam, The Netherlands
Library of the MilieuContact Eastern Europe, Amsterdam, The Netherlands
Library  of Ministry of Housing, Spatial Planning and the Environment, The Hague, The
Netherlands
Library of Milieudefensie/ Friends of the Earth , Amsterdam, The Netherlands
Centre for Environmental Studies, Rotterdam, The Netherlands
National Environmental Centre, Amsterdam, The Netherlands
Library of Congress, Washington, United States
Institutions

Impel, European Network for the Implementation and Enforcement of Environment^
Law, Brussels, Belgium
VROM, Dutch -Ministry of Housing, Spatial Planning and the Environment, The Hague,
The Netherlands                   ;
RIZA , Institute for Inland Water Management and Waste Water Treatment, Lelystad,
The Netherlands
I.W.A.C.O., International Consultancy for Water and the Environment, Rotterdam, The
Netherlands
Greenpeace, Amsterdam, The Netherlands
European Commission, Brussels, Belgium
U.N.E.P. United Nations Environment Program,
Environmental Law Institute, United States

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