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TABLE OF CONTENTS
Acronyms and Abbreviations ii
Executive Summary 1
Introduction 8
Methodology 10
Part I: Context and Rationale for Partnership Programs 12
Part II: Profile of EPA's Partnership Programs 18
Definition 18
History 19
Current Models of Partnership Programs: The 1,000 Flowers 20
Part III: Research Findings 23
The Partnership Program Approach and EPA's Mission 24
Current Management of Partnership Programs 32
Part IV: Recommendations ' 39
EPA-Wide Actions: Integrate Partnerships as a Core Element
of EPA's Mission 40
Office of Policy and Reinvention: As Coordinator and Champion 45
The Next Steps 50
Appendices
Appendix A: Detailed Recommendations
Appendix B: Survey Text
Appendix C: Selected Survey Results
Appendix D: EPA Staff Interviewed
Appendix E: Literature Review
Appendix F: Analysis of Non-EPA Partnership Programs
Appendix G: Bibliography
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ACRONYMS AND ABBREVIATIONS
CBEP Community-Based Environmental Protection
CSI Common Sense Initiative
DfE Design for Environment
EPA Environmental Protection Agency
GPRA Government Performance and Results Act
LMOP Landfill Methane Outreach Program
NGO Non-Governmental Organization
OAR Office of Air and Radiation
OPPTS Office of Pollution Prevention and Toxic Substances
OPR Office of Policy and Reinvention
OSHA Occupational Safety and Health Administration
P2 Pollution Prevention
PPCC Partnership Programs Coordinating Committee
TRI Toxics Release Inventory
XL (Project) Excellence and Leadership
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EXECUTIVE SUMMARY
In slightly less than a decade, partnership programs at EPA have evolved from two experimental
projects into a varied array of over 40 programs addressing diverse EPA priorities. This process
of development has been highly decentralized, drawing its energy from the initiative and
entrepreneurship of individuals in EPA's programs and policy offices at headquarters and in the
regions. Outside of EPA, many individual states and other federal agencies have also adopted the
partnership model of voluntary, mutually beneficial cooperative programs with partner
organizations.
This study investigates how partnership programs as a whole are organized and managed at
EPA—how the partnership approach1 now stands after a decade of decentralized development.
The Office of Policy and Reinvention (OPR), which supported the study, stipulated two central
goals:
• To develop more information about how EPA's partnership programs are currently
structured from an organizational standpoint.
• To make recommendations on what management steps the Agency could take to make
partnership programs more effective.
To gather the data for this study, we relied heavily on interviews with headquarters and regional
EPA staff (both inside and outside of partnership programs) and a survey sent to managers and
implementers of partnership programs. We also reviewed existing literature on EPA and non-EPA
partnership programs and contacted several current industry partners.
'Partnership programs are the most obvious, but not the only, example of using the partnership approach- a
strategy by which the Agency forms a partnership with an external entity to resolve an issue of shared importance. CBEP
(Community Based Environmental Protection) and NEPPS (National Environmental Performance Partnership System)
are both partnership approaches, but are not part of the Partnership Programs Coordinating Committee (PPCC).
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The findings of our research and our recommendations to OPR and EPA for improving the
Agency's use and management of partnership programs are best understood in light of ongoing
changes in the structure of the nation's economy. Before discussing the results of our
investigation, we turn briefly to these changes and related trends.
Partnerships in the Changing Context of Environmental Management
Partnership programs have developed rapidly and will have an increasingly important role in
EPA's ability to accomplish its mission in the future. They are flexible enough to address complex
environmental problems in the context of a rapidly changing economy—where increased
productivity comes less from manufacturing advances and more from knowledge-based services.
The following trends, closely related to the shifting structure of the economy, will make
partnerships a core element of EPA's approach to environmental protection:
The emergence of new environmental issues. Urban sprawl, non-point source pollution,
and increased greenhouse gas emissions are examples of emerging environmental issues of
critical importance that are related closely to new patterns of economic development.
Issues like these are difficult to address in a regulatory framework, but are amenable to the
partnership approach.
A better informed public. Advances in computer programming and Internet technology
place environmental data only a click away from citizens and advocacy groups.
Meanwhile, scientists continue to improve our understanding of the environmental and
public health impacts of pollution and environmental degradation. Partnership programs
can work through a variety of stakeholders to channel relevant information to the public,
highlight new and promising practices, and provide recognition for the environmental
commitment of outstanding partners.
The increasing importance of non-regulatory, market-oriented forces for improving
corporate environmental performance. Driven by market and stakeholder forces,
companies are undertaking initiatives that go beyond regulatory requirements to improve
customer and community relations and to become more efficient. Many EPA partnership
programs offer a combination of non-regulatory incentives that allow partners to realize
business benefits by improving some aspect of their environmental performance.
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The best partnerships take advantage of these trends to create powerful, effective environmental
programs in which the goals of partners and of the Agency can both be advanced. Partnership
programs should not supplant regulations, however. They work best as a complement to existing
regulatory programs.
EPA Management of Partnership Programs: The 1,000 Flowers
In surveying Agency staff and reviewing literature on partnership programs, we developed a
comprehensive picture of how the Agency views the partnership model and manages existing
programs. We did not evaluate the effectiveness of individual programs, but focused instead on
how the partnership programs fit into the Agency's management structure. The following are our
major findings:
There exists enormous variation among existing EPA partnership programs.
Programs vary across many axes, including type of environmental issue addressed, type of
partner sought, incentives offered, amount of EPA funding, and program location within
EPA, to name a few. To use a metaphor we encountered during our interviews, the
programs are like "1,000 flowers blooming": individually, partnership programs have been
remarkably successful in meeting their goals and in attracting a dynamic and
entrepreneurial staff; there has been to date, however, little organized planning to
determine where the 1,000 flowers should spring up.
There is a lack of consensus within the Agency concerning the role and value of
partnership programs in EPA's mission. While there exists a rigorous theoretical basis
for regulatory programs, neither the theoretical nor the practical case for partnership
programs has been well articulated across the Agency (though some programs have
developed program-specific cases). Program proponents, including partnership program
staff and their advocates, see partnerships as incubators of reinvention and a critical part of
EPA's future. Skeptics, on the other hand, consider the partnership approach inappropriate
for a regulatory government agency. If partnerships yield such beneficial results, skeptics
ask, why do the partners not develop the programs themselves?
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This debate is not just theoretical: it has practical, negative consequences for the
partnership programs. Because of this lack of consensus, EPA senior management has
shown inconsistent support for existing programs. In the survey and during interviews,
program mangers and staff referred consistently to two damaging manifestations of
inconsistent senior management support:
— The partnership program approach is not integrated with traditional Agency
approaches to environmental protection. There is little communication between
partnership programs and non-partnership staff, and multimedia partnership
programs have difficulty receiving support from qualified divisional staff in the
regions.
— Partnership programs generally receive inconsistent funding. In addition, staff
of many of the programs believe the funding they receive is not sufficient to exploit
the full potential of their programs.
In general, individual programs are well managed. Most programs have a mission
statement, have defined objectives, gather environmental performance data, conduct
evaluations, and attain their objectives cost-effectively. Thus, the Agency does not need to
oversee or centralize management of individual programs.
Partnership programs are designed more to address the needs and priorities of
individual program offices than those of the industry partners. Although individual
programs are generally well managed, there is little evidence of consolidation or
coordination among partnership programs to serve the needs of particular "customers"
(generally industry partners).
Partnership programs attract talented, entrepreneurial staff to the Agency.
Generally, partnership staff think differently about industry-government relations than
EPA traditionally has. Their perspective adds value to the Agency beyond supporting the
partnership approach.
Recommendations: Capturing the Potential of the Partnership Approach
As our study results suggest, partnership programs can be better supported and managed at EPA.
Fortunately, there exists today a 10-year base of experience from which to build. Although we
have not rigorously evaluated the results of the partnership programs to date, we strongly believe,
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based on evidence provided by the programs themselves and by industry partners, that the
partnership approach is vital to addressing effectively the environmental protection challenges of
today and tomorrow. Our starting point in making the recommendations that follow is that the
Agency could firmly commit to improving the application and effectiveness of partnership
programs.
To this end, we make recommendations at two levels: EPA-wide recommendations and
recommendations for OPR. For the partnership approach to reach its true potential, EPA must
make the partnership approach an integral part of the Agency's strategy for accomplishing its
environmental mission—something the Occupational Safety and Health Administration (OSHA)
has done effectively to improve occupational safety and health. Partnership programs have
blossomed at the grassroots level to date; now is the time to make them more powerful by
supporting the approach on a broader level within the Agency. This change will not happen
overnight, nor will it happen without a champion. OPR should take the role of champion, leading
the process through which the Agency integrates the partnership approach into its core strategy.
We expand upon these recommendations below.
EPA-Wide Recommendations: Partnerships as a Core Strategic Approach
In interviews and surveys, partnership program staff consistently referred to the lack of Agency
consensus on the partnership approach (or its direct consequences) as a central limitation to their
program's success. There are three key steps that the Agency as a whole must take to overcome
this limitation, thus ensuring that partnership programs realize their full potential as an integral
part of EPA's strategy:
Define and articulate the role of partnership programs in accomplishing EPA's
mission. Most importantly, the Agency needs to build consensus across both partnership
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program staff and non-program staff concerning the value—and limitations—of
partnership programs. The concerns of partnership skeptics must be addressed, and the
claims of proponents must be validated.
Building consensus involves developing and articulating the case for partnership programs,
defining priority goals for their application, and integrating the partnership approach into
strategic Agency initiatives, as well as establishing standards of quality and performance
expected of partnerships. The very nature of partnership programs makes it challenging to
accomplish these tasks: in a true partnership program, EPA's should not be the only voice
in defining program objectives and establishing performance standards.
Develop performance indicators relevant to partnership programs. The Government
Performance and Results Act (GPRA) has caused the Agency to focus on environmental
results measures. While commendable in itself, this emphasis has the unfortunate
consequence of devaluing significant potential contributions of partnership programs to
innovation and learning across the Agency and to improvements in the working
relationship between EPA and industry. EPA should develop performance indicators that
measure partnership programs in a more balanced way. In particular, we recommend that
EPA use a "balanced scorecard" to measure programs in terms of internal management,
customer satisfaction, and innovation and learning, as well as actual environmental results.
Provide adequate, consistent financial support to partnership programs. Widely
fluctuating budgets are demoralizing to staff, exasperating to industry partners and
stakeholders, and affect the credibility of the partnership approach. The Agency should
collect supporting data and make a strong case for partnership programs during budget
negotiations. In addition, we recommend that EPA develop a mechanism for providing
consistent incubator funding for selected new programs.
Recommendations for OPR: The Role of Champion
In addition to managing partnership programs such as Project XL and Common Sense Initiative,
OPR has recently played the role of coordinating programs housed throughout the Agency. OPR
has developed a website with links to the partnership programs and to the regions and has brought
representatives from different programs together for networking and seminars. While important,
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the role of coordinator is not sufficient. OPR should expand its focus to being the champion of the
partnership approach within the Agency. In particular, OPR should:
Serve as the champion for partnership programs Agency-wide. The EPA-wide
recommendations we outlined above will not be implemented unless an internal champion
pushes the Agency to do so. OPR should not lead or manage the programs themselves
(this would actually lead to greater marginalization). Rather, OPR should be the advocate
and supporter of the partnership approach within the Agency.
Being champion involves advocacy in the Office of the Administrator, "in-reach" to non-
program offices at EPA, and collaboration with the media and program offices and with
the regions. These efforts should initially focus on building Agency consensus concerning
the role and value of partnership programs.
Provide services that meet the needs of partnership programs. OPR has begun to
provide some of these services in the role of coordinator; examples include compiling
environmental results data across the partnership programs and arranging expert guidance
on program evaluation. OPR should continue to develop tools needed by the partnership
programs and help the programs learn from each other through targeted networking.
Ensure that partnership programs meet a high standard of quality. If particular
partnership programs are poorly designed and implemented, the other programs suffer by
association. As champion, OPR needs to protect the "brand identity" of partnership
programs by acting as gatekeeper, ensuring that new partnerships meet clearly defined
criteria before they are formally designated as partnership programs, and by helping
established programs improve their quality based on internal evaluations. Playing the role
of gatekeeper will be challenging, but it is one that OPR should undertake. Being a
partnership program should convey an image of creativity and dedication to cost-effective
environmental management both inside and outside of EPA.
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INTRODUCTION
This study investigates how partnership programs are organized and managed at EPA. In
February of 1998, the Reinvention Action Council directed the Partnership Programs
Coordinating Committee (PPCC), which operates out of the Office of Policy and Reinvention
(OPR), to develop a characterization and analysis of partnership programs. The research and
organizational analysis presented in this report complement recent work that characterizes
individual partnership programs.2 This study was not meant to characterize each EPA partnership
program comprehensively or to evaluate the effectiveness of the partnership programs, either
individually or as a group. OPR stipulated two central goals for this study:
• To develop more information about how EPA's partnership programs are currently
structured from an organizational standpoint.
• To make recommendations on what management steps the Agency could take to make
partnership programs more effective.
Our report is structured in the following way:
Methodology describes the research tools and key audiences for our study.
Part I: Context and Rationale for Partnership Programs analyzes current trends in
environmental management and provides the rationale for partnership programs' role in
EPA's approach to environmental protection.
Part II: Profile of EPA's Partnership Programs provides a brief definition, history and
current characterization of EPA's partnership programs as a group.
Part III: Research Findings summarizes our key findings with, regards to the
organization and management of partnership programs at EPA.
See The Cadmus Group. 1999. Characterization of Selected EPA Partnership Programs. Final report
prepared for U.S. EPA, OAR.
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Part IV: Recommendations presents our recommendations on how, from a management
standpoint, to make the partnership programs as effective as possible. Appendix A
contains more detailed action items for several recommendations.
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METHODOLOGY
We concentrated our data collection efforts on the Agency itself in order to focus our report on
how EPA manages partnership programs. We gathered data directly from EPA staff both in
Headquarters and in the Regions through interviews and surveys. We also contacted a limited
number of industry partners and other stakeholders and reviewed available information about EPA
and non-EPA partnership programs inside and outside the U.S. Our data-gathering efforts are
described in more detail below:
Survey of EPA partnership staff. Because we believed that personal contact would
generate the most candid results, we distributed surveys to targeted EPA staff and
interviewed staff from Headquarters and four regions. We distributed two surveys by e-
mail, one to managers of national or regional partnership programs (the "manager's
survey") and the other to regional implementers of national programs (the "implementer's
survey"). These surveys asked quantitative and qualitative questions about how
partnership programs were managed, from budget to stakeholder involvement to intra-
Agency organization.
We sent 82 implementer's surveys and received 23 responses; of the 56 manager's surveys
that we sent, we received 24 responses. (Because not every respondent answered each
question, the total number of respondents may vary from question to question). Copies of
the surveys and a printout of collated responses to selected questions are given in
Appendix B and C respectively. Respondents' names are kept confidential.
Interviews with EPA staff (partnership and non-partnership). We also interviewed
approximately 60 EPA staff members, including senior policy makers, non-partnership
program3 staff, and individuals who manage or are involved in partnership programs at the
headquarters or regional level. We chose Regions 1, 3, 6, and 7 to conduct the regional
interviews because they represent a cross-section of approaches to partnership programs.
We also relied on data gathered from related interviews conducted by an OPR staff
member. Where the interviewees represented a partnership program, our questions
generally reflected the categories of survey questions, although we did not follow a strict
A non-partnership program is an EPA-sponsored program that is not a partnership program, including,
enforcement, regulatory, or grants programs.
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protocol. A list of people interviewed is given in Appendix D. We have kept our notes
confidential.
• Interviews with partner and stakeholder sources. We contacted six partner
representatives and one non-governmental organization by telephone to discuss their
perspective on EPA's partnership programs. In particular, we wanted to learn whether the
programs caused partners to take actions they otherwise would not have taken and
whether they were confused by the variety of partnership programs available. We
conducted these interviews to stimulate our thinking rather than to generate extensive
data; many more partners would have to be contacted to understand comprehensively how
partners view the programs. We have kept the names of the partners we contacted
confidential.
• Review of existing literature on EPA's partnership programs. Because EPA's
partnership efforts are relatively new, there is not much literature describing these
programs. EPA has compiled several documents that characterize the partnership
programs, and several limited external studies of their effectiveness have been conducted.
We reviewed these documents, concentrating on concerns raised in the studies relating to
partnership program organization and management. Our report on these studies is in
Appendix E.
• Review of available information on non-EPA partnership programs. To place EPA's
management of partnership programs in perspective, we gathered data on several non-
EPA partnership programs and voluntary efforts. In the U.S. public sector, we focused on
OSHA and DOE efforts. We also researched several private initiatives, including the
Responsible Care program, and reviewed several broader studies on initiatives in other
countries. We gathered our information through a literature review and through telephone
interviews. Our report on non-EPA partnership programs is in Appendix F.
We have drawn from all of the sources listed above in writing this final report. A comprehensive
bibliography is provided in Appendix G.
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PART I: CONTEXT AND RATIONALE FOR PARTNERSHIP
PROGRAMS
Beginning in the early 1980s, but principally in the past decade, the context of environmental
management in the United States and internationally has shifted substantially. In the 1970s, EPA
primarily focused its efforts on point sources of pollutants through an adversarial regulatory
process. Today, EPA faces environmental challenges that extend beyond its original statutory
mandate and has the opportunity for a less adversarial relationship with industry.
Many of these complex environmental issues and opportunities arise in the context of a rapidly
changing economy—where increased productivity comes less from manufacturing advances and
more from knowledge-based services. In 1947, for example, the service sector of the economy
accounted for 8 percent of Gross Domestic Product (GDP) and manufacturing accounted for 27
percent. In 1997, the service sector accounted for 20 percent and manufacturing accounted for
about 16 percent (see Figure 1). Most service operations use relatively little capital and resources:
their environmental impacts stem not from their manufacturing process, but from their impact on
the economy, their use of products and energy, and their suppliers.
Several significant and related trends indicate that partnership programs will have an increasingly
important role in EPA's ability to accomplish its mission in the future. The partnership approach is
a powerful mechanism for EPA to address the shifting structure of the economy and the changing
context of environmental management, complementing but not replacing its regulatory programs.
This part of the report highlights four significant trends related to environmental management and
the opportunities they create for partnership programs.
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Figure 1: Manufacturing and Services Shares of GDP, 1947 to 1997
Source: Bureau of Economic Analysis, Gross Product by Industry
35%
5 2
Year
-Manufacturing —•—Services
Trend: The Increasing Importance of Knowledge in Industry. At the 1999 Harvard
commencement, Alan Greenspan told graduates that "knowledge is far more important as a
source of economic growth than physical capital." Improved information reduces the need for
inventories and redundant capacity and increases operating efficiency. It has also led to new
business development, as shown by the emergence of so-called "knowledge" industries, such as
software design, financial services, and consulting. Even in 1980 (the most recent date from which
data are available), "knowledge" accounted for 36.5 percent of U.S. GDP.4 That fraction must be
much higher today. Thomas Stewart illustrates this change in Intellectual Capital: "...four out of
five dollars Levi Strauss spends to make a pair of blue jeans go to information, not to make, dye,
cut, and sew denim."5
4 Stewart, T. 1997. Intellectual Capital. New York: Doubleday/Currency Publishers, Inc.
5Ibid.
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In the environmental arena, innovative techniques such as environmental management systems,
pollution prevention, and design for environment represent a shift towards the increasing
knowledge content of environmental management. The infusion of billions of dollars in product
and process research and development has led to a significant reduction of material and energy
use in the manufacturing sector. A beer can that weighed 1.25 ounces in 1957 weighs 0.48 ounces
today; and recycling the can will save 95 percent of the energy it takes to make a new can from
virgin aluminum. In 1979, a manufacturer might have hired a consulting engineering firm to build
a treatment plant to handle its wastewater. Today, the same company might redesign its processes
to reduce the quantity of waste generated. As investment in capital, labor, and resources gradually
decreases, the need for a sophisticated understanding of process and product is greater.
Partnership Opportunity: Partnership programs develop and communicate environmental
management knowledge and provide industry the flexibility to use the best existing
practices. Programs such as Design for the Environment, Natural Gas STAR, and the
Environmental Accounting Project generate knowledge that helps industry tackle environmental
problems more efficiently. These programs also provide technical assistance and disseminate
knowledge to a wider industry audience. Without these programs, industry might not develop,
organize, or share this information as efficiently or quickly.
Partnership programs allow the Agency the flexibility to address both new impacts and new
industries generated by the service economy. The major performance-oriented partnership
programs establish (jointly with industry) performance goals without specifying how these goals
are to be met. Industry can find the most efficient way of meeting these goals, in contrast to being
mandated (dejure or de facto) to use a particular technology.
Trend: Widespread public access to information. Since the initial publication of the Toxics
Release Inventory (TRI) data in 1988, the amount of corporate environmental performance data
available has increased dramatically. TRI currently covers nearly twice as many industries and
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chemicals as it did in 1988, and provides time series data to evaluate long-term change. Several
environmental groups accumulate, interpret, and disseminate environmental data, such as the
Environmental Defense Fund's "Scorecard" and the Council on Economic Priorities' "Corporate
Ratings." Increasing numbers of corporations publish environmental data in their annual reports
and investment analysts, such as Innovest, rate corporate environmental risks. Corporate and
environmental organizations are also developing tools that specify common environmental
reporting elements. The challenge facing EPA today is not how to acquire environmental data but
how to select and interpret these data most effectively.
Partnership Opportunity: By providing environmental performance information to the
public, partnership programs can promote market-based solutions to potential
environmental problems. Reporting environmental performance information is an important
component of many partnership programs. The first concrete project that members of the
Common Sense Initiative's (CSI's) Petroleum Refining workgroup agreed upon, for example,
involved trying a more efficient and more easily understood mechanism for environmental
reporting. As clear, relevant, standardized environmental information becomes more available to
the public, market pressures will drive facilities to improve their environmental performance.
Trend: The emergence of new environmental issues. One of the greatest challenges facing EPA
is the emergence of critical environmental issues that it has neither the regulatory authority nor the
capability to address through its traditional structure. Some issues—such as point source
greenhouse gas emissions—are beyond EPA's regulatory mandate but could be managed through
an existing approach (emissions trading). Other issues—urban sprawl, congestion, area source
pollution, habitat protection—cross media boundaries and affect a diverse group of stakeholders.
Effective environmental management of these complex issues will require much more than better
coordination among media offices: it will require affecting societal behavior. It is unlikely that
new legislation will give EPA the authority to address these issues in a regulatory framework and,
even so, traditional regulatory instruments alone will not be adequate to address these issues.
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Partnership Opportunity: Partnership programs address issues beyond the reach of
traditional regulatory programs. Partnership programs allow EPA to address both impacts
(such as greenhouse gas emissions and urban sprawl) and industries (such as retail, agriculture,
and services) that are difficult to regulate or are beyond the reach of traditional regulatory
programs. Regulatory approaches are not well-suited to these purposes because they require
legislation that does not exist and because they are less capable of adapting to changing
circumstances.
Trend: The emergence of non-regulatory forces for improving environmental performance. In
the OECD countries, environmental regulations are only one, albeit the major, factor promoting
industry environmental performance improvements. Since the early 1990's—when a group of US
companies established the Global Environmental Management Initiative (GEMI), the International
Chamber of Commerce published its "Principles for Sustainable Development," and the World
Business Council on Sustainable Development was formed—companies have undertaken
environmental initiatives that go beyond regulatory requirements. They have taken these initiatives
for reasons of corporate image, market advantage, cost savings, or community relations6. Once an
"externality" addressed through regulation, the environment is now increasingly internalized in
corporate and market decision-making.
Partnership Opportunity: Partnership programs leverage industry's recognition of
voluntary environmental initiatives. Leveraging the brainpower, energy, and perspectives of
industry partners, stakeholders, and the public is perhaps the greatest strength of the partnership
programs. During one interview, a CSI staff member related an anecdote about two participants in
the petroleum refining sector. At the beginning of a project, the participants, one a director of an
environmental group and the other a corporate VP for the environment, would have nothing to do
6 A recent survey of major US and non-US companies found that the leading reasons for corporate "beyond
compliance" activities were corporate image, operational efficiency, and economic benefit. See The Lexington Group
and the Conference Board. 1999. Corporate Environmental Management: A State-qf-the-Art Survey.
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with each other. Now, several years into the process, they have agreed on a pilot project to
improve environmental reporting; moreover, they even feel comfortable enough to call each other
directly to ask for information or discuss an issue. This sort of cooperation is evidence of the
growing power of partnerships to improve environmental performance.
Partnership programs offer the Agency an important mode for operating in the changing climate
of environmental management. Partnerships focus more on the knowledge content of
environmental management than on the "bricks and mortar." They provide greater flexibility to
address environmental management in an economy that is increasingly service-oriented and in
which several critical environmental issues are beyond EPA's regulatory mandate. Finally,
partnerships provide a mechanism to work with positive forces in industry and the environmental
community and provide an opportunity for more collaborative "win-win" management methods.
For these reasons, the ways in which EPA manages and learns from its partnerships programs
transcend the programs in place today; they will form a significant part of the foundation for
environmental protection tomorrow.
In your own words, what benefits does your program provide to your
partners?
• "Disposal costs of PCB equipment and mercury-containing wastes are reduced."
• "Cost savings, new ideas/approaches."
• "A cleaner, healthier Chesapeake Bay."
• "The ability to participate with regulators and business having similar interests and
commitments."
• "Consensus-based decision-making process for addressing complex environmental
issues."
• "Protect public health, increase compliance."
Source: Surveys of National Managers and Regional and National Implementers
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PART II: PROFILE OF EPA PARTNERSHIP PROGRAMS
In this part of the report, we discuss the definition of partnership programs at EPA, the history of
partnership programs within the Agency, and the existing models for partnership programs.
Definition
An "operating" definition of an EPA partnership program is a program that involves voluntary
cooperation with an outside entity (such as other governmental agencies, business and industry,
environmental and public interest groups, and communities and private citizens) to improve
performance.
EPA conducts many activities complementary to the regulatory sphere, including research,
outreach and information dissemination, technical assistance, and grant-making. These activities
are not partnership programs in and of themselves, but they are often components of partnership
programs. This makes the line between partnership programs and, for example, grant programs
hard to define. Partnership programs usually involve elements of pollution prevention or
reinvention, but not all pollution prevention or reinvention programs are partnerships. Some
distinguishing characteristics of partnership programs are that they are:
Non-regulatory;
Mutually beneficial to all parties;
Based on shared goals and joint responsibility;
Interactive and reciprocal, not one-way streams of technical or financial assistance; and
Non-prescriptive, tailored to meet the specific needs of partners.
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History
The 33/50 and the Green Lights programs were the first partnership programs, established in the
early 1990s. The 33/50 program challenged industry partners to reduce their emission of selected
chemicals by 33 and 50 percent over a 7-year period, while the Green Lights program provided
technical assistance and other tools to businesses and organizations seeking to use energy more
efficiently in their buildings.
These programs were not established by statutory mandate. Rather, entrepreneurial EPA staff
recognized that important environmental results could be achieved by providing the right
incentives and information to voluntary industry partners. Partnership programs have
subsequently blossomed throughout the agency, most importantly in the two offices that first used
them—the Office of Pesticides, Pollution Prevention and Toxic Substances (OPPTS) and the
Office of Air and Radiation (OAR). Today, in fact, a commonly used phrase to describe
partnership programs is "a thousand flowers blooming." At the time of this writing, there are
approximately 25 partnership programs run from EPA Headquarters and 40 from the regions.7
There still is no specific statutory mandate for most of the partnership programs8. Instead, the
flowers have bloomed where entrepreneurial EPA staff have seen an opportunity and management
has supported their efforts at the divisional, office, or regional level. There is also no centralized
control exercised by the Agency over partnership programs. However, in 1998 OPR assumed the
role of coordinating an exchange of information and lessons learned between representatives of
different partnership programs. The Partnership Programs Coordinating Committee (PPCC),
hosted by OPR and composed of representatives from headquarters partnership programs and the
A current listing of partnership programs exists at h ttp://www.epa.gov/partners/partnerships.htm 1.
B10 respondents to the manager's survey identified a specific statutory basis for their program, and 11 said
there was none. Hie statutes identified included parts of the Pollution Prevention Act and the Clean Air Act, as well as
the Climate Change Action Plan.
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regions, currently undertakes these efforts. Several members of the Reinvention Action Council
(RAC), which is composed of senior managers from the regions and offices and is also hosted by
OPR, act as liaisons between the PPCC and EPA's reinvention planning. OR has also assumed
leadership of high-profile, cross-cutting partnership programs such as Project XL.
Current Models of Partnership Programs: The 1,000 Flowers
To continue the metaphor, none of the 1,000 flowers are alike. Because they were developed at
different times and places in the Agency and in response to different environmental issues, each
program is different. There is not even a small group of models that represents all of the
programs. EPA has already sponsored several studies that help to characterize the partnership
programs9. Although the purpose of this study is to complement, not rqpeat, these prior efforts, it
is useful to describe some of the most significant axes of variation:
Environmental Problem Addressed. The partnership programs address a wide variety of
environmental problems, from greenhouse gas emissions to solid waste generation and
water consumption. Several programs, such as the Design for the Environment Program
(DfE) address multiple environmental problems on a sector-specific basis.
Partner Profile. Although industry is the primary group targeted by the partnership
programs, some target state and local governments, industry organizations, and other non-
governmental organizations (NGOs) as well. Many programs, such as the Landfill
Methane Outreach Program (LMOP), target several partner types, or at least attempt to
include mem as stakeholders (variously called "Allies" or "Endorsers").
Level of Decision-Making. Some programs address facility or product-specific issues
(WasteWiSe, Energy Star), some operate at the corporate level (formerly 33/50), the
industry level (CSI), or the trade association level (DfE, the U.S. Auto P2 Project), and
others address community-level concerns (Transportation and Environmental Network
See The Cadmus Group. 1999. Characterization of Selected EPA Partnership Programs. Final report
prepared for U.S. EPA, OAR.
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and State and Local Outreach Program). Finally, some programs address economy-wide issues
(environmental accounting).
• Incentives for/Benefits of Participation. The partnership programs offer several types
of incentives to industry and other potential partners. These include regulatory flexibility,
cost savings, market transformation, recognition for environmental commitment, and
development and transfer of technical information. Many programs employ multiple
incentives to attract partners. For example, the Natural Gas STAR Program recognizes
participants and facilitates cost savings by providing partner companies with information
on best management practices to reduce methane emissions.
• Program Location Within EPA. As mentioned above, approximately 25 partnership
programs are run from various Headquarters offices. In many cases, some or all of the
regions are actively involved in supporting, administering, or developing these programs.
When managers of national programs were asked how many regions were actively
involved, the answers ranged from 1 and 2 to 10. This variation is due in large part to the
autonomy regions have in how they will dedicate staff resources.
Most of the regional partnership programs are unique to one region, although some
programs, such as the Chlor-AUcali Industry Mercury Reduction Project (coordinated in
Region 5) involve multiple regions. Many regions, for example, have developed their
own compliance assistance/recognition programs such as the Small Business Assistance
Center in Region 3 and the Bay Area Green Business Program in Region 9.
• Amount and Source of EPA Funding. As would be expected from a group of programs
so dispersed throughout the Agency, the amount and source of funding varies greatly
from program to program (see Figure 2, which shows the number of partnership programs
within set budget categories, and the sum of the budgets of each program for each
category). The FY '99 budgets reported by program managers responding to the survey
ranged from $3,000 to more than $10 million, and full time equivalent (FTE) allocation
ranged from 0.05 to 20. For programs run from Headquarters with assistance from the
Regions, Headquarters generally provides only limited (or no) budgetary resources
earmarked for the program. This is one explanation for the range in regional involvement
in Headquarters programs.
• Degree of flexibility/adaptation to individual circumstances. Some programs have a
standard "product" that is provided to partners and usually have a standard Memorandum
of Understanding (MOU) that all partners sign. Other programs involve the partners in
deciding what issues will be addressed and what levels of performance will be attained.
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Figure 2: Diversity of Funding for Partnership Programs
Less than $100,000 $100,000 to $999,999 $1,000,000 to $4,999,999 $5,000.000 or more
Program Budget Categories
Based on Responses from 15 Partnership Programs Total Budget for 15 Rograms - $24.606,365
The above list is not meant to be comprehensive—there are other variables that distinguish one
partnership program from another. As stated previously, other efforts have characterized the
partnership programs much more comprehensively than this study was intended to do. We have
discussed these axes of variation to point out the diversity of the 1,000 flowers and because these
axes are directly related to our key findings on EPA's management of partnership programs.
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PART III: RESEARCH FINDINGS
These findings reflect our analysis of the interview and survey data, referring to specific data
where appropriate. Our findings are organized into two major areas:
The Partnership Program Approach and EPA's Mission
Lack of Framework and Inconsistent Agency Support for Partnership Programs
Limited Integration into the Agency's Traditional Areas
Resources and Budget
Different Implementation Approaches
Human Resources Benefits
Current Management of Partnership Programs
Current Status of Coordination
Good Internal Program Management
Retail Operations
A View from the Partners and Stakeholders
The first part of this section focuses on the overall relationship of partnership programs to EPA's
mission. We identify a lack of a framework within the Agency concerning the role of partnership
programs and examine the resulting challenges for these programs, including inconsistent support
from upper management, lack of integration with other EPA programs, inconsistent funding,
human resource challenges, and varying implementation approaches.
The second set of results examines EPA's current management of partnership programs. We
examine an internal debate among EPA staff over the question of increased coordination of
partnership programs. After reviewing internal management practices for the programs, we identify
opportunities for coordinated marketing. Finally, we conclude by summarizing interviews with
partners and stakeholders.
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The Partnership Program Approach and EPA's Mission
Lack of Framework and Inconsistent Agency Support for Partnership Programs
While EPA has a rigorous theoretical basis for regulatory programs, the role of partnership
programs in EPA's mission is not well defined either theoretically or operationally. In theoretical
terms, there exists no coherent framework for the role of partnership programs in a market
economy as there exists for regulatory programs. In operational terms, the role of partnership
programs as a whole, their goals, and their relationship to EPA's regulatory programs are not well-
defined. This lack of a theoretical or practical framework for partnership programs has created a
fault line within the Agency concerning the value of partnership programs in accomplishing EPA's
mission.
Some proponents of partnership programs maintain that they are the harbinger of the new
EPA—more flexible, more entrepreneurial, less confrontational, and better able to address critical
current and future issues that are not covered by environmental regulation and legislation. Others
argue that partnership programs have (at least in some cases) a special status because they have
substantial indirect and internal culture change benefits. For example, it :is difficult to point to
specific environmental improvements that have resulted directly from the Environmental
Accounting Project, but the program has been instrumental in introducing a better way for
industry to manage its environmental costs and make better environmental decisions. Others are
less enthusiastic, but recognize that partnerships are a useful tool to achieve certain environmental
ends. They argue, however, that partnership programs must justify themselves in cost-
effectiveness terms, just as EPA regulatory initiatives must be subject to economic analyses. (Note
that the established partnerships such as Energy Star and WasteWiSe easily meet this criteria).
Skeptics argue that partnerships are another form of "corporate welfare." They mostly benefit
larger companies (through recognition, technical assistance, and funding support, or in limited
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cases, regulatory relief) for taking actions that are in their own interest. Survey results reinforce
this criticism: managers report that, on average, only 25 percent of their partners are small
businesses, whereas small businesses make up a much greater percentage of the total number of
businesses. Other critics stress that these programs divert Agency resources from the "true"
regulatory function of EPA. There are no consistent Agency responses to these arguments, or
framework that acknowledges and directly addresses them.
This debate is not just theoretical: it has practical, negative consequences for the partnership
programs. Because of this lack of consensus, EPA senior management has shown inconsistent
support for existing programs.
Our data indicate that senior EPA management support for the partnership programs is
inconsistent. Seven of 19 partnership program managers (37 percent) rated lack of recognition
within EPA as "quite important" or the "most important" internal barrier to their program (see
Figure 3). Sixteen of the 23 managers (70 percent) responding to the question on internal
supports rated support and recognition from EPA management as an important support for their
program (see Figure 4). However, this figure is elevated because several respondents answered
this question based, as one manager explains, "on what I think a program should have to be
successful, not what we've actually experienced."10
In several of the regions we visited, the general sentiment of the partnership program staff was
that EPA senior management emphasized the importance of the partnership approach in public
appearances but, with the exception of a few well-endowed programs, did not provide the
necessary resources or recognition for the partnership approach to take hold in the Agency.
This respondent rated Agency support as most important to have but noted that the lack thereof, in her
particular case, was a very important barrier.
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Figure 3: Internal Barriers to Partnership Programs
'What do you consider the major organizational
barriers?"
Excessive nd tape
Poor coordination among programs
Lack of clear measures
Too many staff commitments
Lack of recognition from EPA
Insufficient resources
0% 20% 40% 60% 80% 100%
Percent of Survey Respondents
B Regional rmptementers • National and regional managers
Figure 4: Internal Supports for Partnership Programs
"What do you consider the major organizational
supports?"
Flexibility and ability to Innovate
Dedication and commitment of staff
Support and recognition from my management
Support and recognition from EPA management
Clearly defined goals
Effective coordination among programs
Support from other programs
»»«*:..«... .JJJT
atstj
0%
20% 40% 60%
Percent of Survey Respondents
D Regional imptementers pj National and regional managers
100%
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Limited Integration into the Agency's Traditional Areas
Another negative result from the lack of a framework and inconsistent agency support for
partnership programs is their lack of integration into EPA. Our data show that at EPA
headquarters, and especially within the Regions, the partnership programs are viewed as separate
from the main Agency business of regulation and enforcement. This lack of integration is evident
in several ways:
Partnership programs, especially multimedia programs, have difficulty getting
support from qualified divisional staff in the regions. In several of the regions we
visited, EPA staff who managed or coordinated the Project XL program stated that it was
very difficult to get qualified technical assistance from regional divisions. These two
programs in particular have a small staff of coordinators and rely on assistance from
experts in the appropriate media to develop and appraise specific projects.
Employee incentive structures, particularly at the regional level, often make it
extremely difficult to achieve integration. The quantitative incentives for divisional
heads are based on indicators such as number of permits, inspections, civil referrals,
administrative orders, etc. As one EPA regional staffer writes, these types of incentives do
not support involvement in partnership programs:
"If EPA had a system set up where managers were evaluated based on the
emission/pollution reductions they achieve, there would be more support for many
partnership programs that achieve reductions in pollution. However, as long as the
system continues to recognize only paper actions and penalty totals, there is not going to
be broad support from management for diverting staff to work on activities for which no
bean counts are generated."
Although many participants in partnership programs shared this sentiment, in several
cases, partnership program objectives were included in a division's incentive structure.
One respondent, for example, reported that her division director was asking for the
numbers of companies that reported undertaking P2 activities.
There is not a great deal of interaction between the partnership programs and other
EPA (non-partnership) programs. Nine respondents to the manager's survey said that
they coordinated objectives with non-partnership programs. Additionally, only five
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percent of respondents rated other EPA programs (partnership and non-partnership) as an
important source of client leads. Of respondents to the implementer's survey, 9 of 18
reported working with another EPA program—due in part, no doubt, to the versatility of
regional implementers, most of whom wear several hats.
Many partnership program staff interviewed expressed frustration that others in the
building had no idea of their program's existence. They believe that many of their
colleagues view them with suspicion for working too closely with industry. Although we
can not verify this perception, it indicates that the partnership approach has not yet
become a part of EPA culture. Several of the survey respondents specifically
recommended that partnership programs interact more with other programs in the Agency
in order to become more integrated with the general EPA culture.
Resources and Budget
Lack of consistent support leads to fluctuating funding. Our data reveal that partnership
programs undergo major year to year changes in funding levels. One program, for example, saw
its budget drop from $225,000 to $150,000 to $80,000 from fiscal year 1997 to 1999. Allocations
for regional participation in several national partnership programs have been reduced as well.
While budgetary changes are inherent to any government program, uncertainty and insufficient
resources plague the partnership programs, especially the smaller, less established ones. (As
mentioned previously, the larger, more established headquarters programs are generally better and
more consistently funded). One senior manager explained that mandated programs are more
level-funded; therefore, discretionary programs such as partnerships absorb budgetary fluctuation.
Managers of regional or national partnership programs rated insufficient number of staff and
insufficient resources as the two major internal barriers of their programs (11 of 20 (55 percent)
and 11 of 19 (58 percent) managers rated these two issues, respectively, as most important or
quite important barriers). Regional implementers of national programs selected overcommitment
of regional staff" to a variety of projects as the major barrier (15 of 21 regional implementers (71
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percent) rated it as most important or quite important), reflecting the fact that regional staff who
work on headquarters programs usually have multiple responsibilities.
As will be noted later, budget fluctuations can have a significant negative effect on partners. When
a partner invests time and resources into a partnership program only to see the program greatly
curtailed because of funding cuts, that partner will be much less inclined to participate in future
joint initiatives.
Different Implementation Approaches
Partnership programs in regional and headquarters offices have developed different
implementation approaches. While the headquarters' partnership programs vary significantly in
how they involve regions and define responsibilities, the organizational structure of programs in
the EPA regional offices reflects each office's priorities.
Several headquarters' programs rely extensively on contractors and little on the regions. This
relationship is viewed both positively and negatively by the regions. One regional staff person
explained that she appreciated this lack of responsibility because, "I'm not a marketer and I don't
want to do marketing; this lets me focus on technical assistance." However, in other regions, staff
resented the fact that headquarters did not coordinate a program with the region. Other programs
involve the regions in identifying leads, promoting outreach activities, and conducting follow-up
visits. Still other headquarters programs solicit much stronger regional input, including the region
as a full member of a project planning and implementation team. These latter models were viewed
positively by the regions.
The differences among headquarters' programs in their approaches to the regions are due at least
in part to differences in the "products" they provide to their partners. Large programs with
. • • : • ' ' '" ;' V',-'
• " '
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established "products," such as Energy Star, have less need to involve the regions (or even their
partners) in a significant way in the design of their products than do programs such as XL that are
highly tailored to individual partners. For example, the Energy Star label is found on many
popular brands of office equipment, home electronics, and appliances that are certified as products
that operate at exceptional levels of energy efficiency. Programs such as CSI and XL, by
contrast, develop new products that are tailored to the specific needs of individual industries,
facilities, or communities. For example, CSI targets environmental management practices by
industrial sector. There were six industries that served as CSI pilots: automobile manufacturing,
computers and electronics, iron and steel, metal finishing, petroleum refining, and printing.
The implementation of partnership programs by the EPA regions reflects each office's priorities
and organizational structure. Some regions, such as Region 1, placed all partnership-related
activities in a single office. This structure counterbalances the "stovepipe" structure of the
partnerships at headquarters and links the federal partnerships to regional partnerships (which are
also contained within the same office). Region 1's organizational structure reflects how
partnerships are a priority aspect of its mission.
Other regions essentially mirror the headquarters' organizational structure. One region, for
example, housed the partnership programs in their corresponding media program offices. In this
region, the PPCC representative did not know several of the people who implemented partnership
programs outside of his division. There was little region-level activity promoting either national or
regional partnership programs. In another model, dictated primarily by size, one relatively small
region assigns responsibility for many national and regional partnership programs to a single
individual.
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Human Resources Benefits
As pointed out to us by a senior official in EPA, partnership programs have allowed EPA offices
to attract entrepreneurial staff with an interest in "running their own show" and working
collaboratively with industry. Our survey and subsequent interviews confirmed this impression: In
response to a survey question asking managers to rate organizational supports, 21 of 23 managers
(91 percent) rated dedication and commitment of program staff a& "quite important" or "most
important."
Although many of the individuals we interviewed displayed a strong commitment to their
programs and an evident pride in their success, they sensed that they were overcommited and that
their programs were not central to EPA's mission. While this sense of dissatisfaction is difficult to
define and measure, it may be the source of what some observe to be a high turnover rate in
partnership program staff.
The partnership program staff are probably responding to the mixed message they receive from
the Agency. On the one hand they are recognized and promoted as dedicated, innovative
entrepreneurial individuals on the cutting edge of the "new" EPA (and this message is clearly
communicated and creates a strong "esprit de corps" among program staff). On the other hand,
they see their programs as understaffed and underemphasized relative to EPA's regulatory and
enforcement activities and, in the regions, feel by-passed by headquarters-based programs.
Without a consistent message of the importance of their contribution to the agency's mission,
EPA runs the risk of losing these talented staff.
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What motivates you personally ?
• "The partnership emphasis is a motivation."
• "The opportunity to work collaboratively with other government and private sector folks
who place a high value on environmental excellence/leadership."
• "Challenge of reaching out to industry generally hostile to EPA."
• "Ability to experiment with new approaches."
• "The opportunity to be on the cutting edge."
• "Energy efficiency is the key to the survival of the planet."
Source: Surveys of National Managers and Regional and National Implemented
Current Management of Partnership Programs
Current Status of Coordination
Interviews with EPA staff revealed an internal debate about the question of coordination among
partnership programs. This debate raises a critical management question for EPA partnership
programs: Should the 1,000 flowers be allowed to bloom separately, or should they be arranged
in vases?
Proponents of independence for individual partnership programs point out that centralized
coordination would deprive them of the flexibility and opportunities that lead to their success.
Partnership programs have succeeded because they have been able to adapt to changing
environmental and industry needs with a minimum of bureaucracy. Partnership programs have
been EPA's incubators, where entrepreneurial staff test innovative approaches outside of
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adversarial processes dominated by legal and regulatory structures. Excessive coordination or
centralization of the partnership programs could also lead to the loss of a highly motivated,
creative group of professionals in the Agency.
Others, however, argue that coordination is necessary for the programs to survive internally. They
believe that partnership programs are being marginalized in internal budget and priority decisions
because they do not have a common voice. In order to make the case for themselves internally,
partnership programs must act like mature programs, measuring and reporting performance and
accepting some degree of central coordination. Externally, the failure of coordination among
partnership programs has created confusion as potential partners wonder how the programs are
different and which one they should join.
Another argument for coordination comes from smaller programs. While some partnerships
constitute entire EPA divisions with substantial FTEs and budgets, several programs are two- or
three-person operations with very limited budgets. The smaller programs tend to be more
interested in some degree of coordination because they have more to gain from strength in
numbers.
Good Internal Program Management
Although the question remains whether partnership programs as a whole need further
coordination, our data reveals that individually, the partnership programs are generally well
managed. And more importantly, internal program management is improving.
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As indicators for program management, we chose to use existence of a mission statement,
connection to GPRA objectives, collection and verification of environmental results data, and
existence of an evaluation process. Results from the managers' survey revealed that:
• 16 of 21 of the responding partnership programs have a defined nu'ssion statement.
• 11 of the respondents were able to identify the GPRA objectives that their program
addresses, 3 could not, and 8 were unsure.
• 19 of 23 of the responding programs collect environmental performance data from their
partners, and more than half of these programs employ some means of verifying these
data.
• 10 program managers reported that their programs have conducted an internal evaluation,
and 7 are in the process of (or soon will) do so.
These data are encouraging although not exceptional11. Yet based on our interviews, we believe
that the trend is clearly toward more mission-driven, results-oriented program management.
Because of the entrepreneurial and innovative nature of the partnership programs, and the
complex nature of the problems that they address, it can be difficult to define goals clearly,
develop performance measurements, and evaluate progress. Measuring reductions in
environmental and public health risks, for example, is extremely difficult. Nevertheless, managers
of several programs that have risk-related goals (including PESP and DfB) have initiatives
underway to improve measurement and program evaluation.
11 One discouraging result from the imptementer's survey, discussed more under "Retail Operations," is the
disproportionate amount of time regional implementers of national programs appear to spend on overhead functions
(i.e., pushing paper) instead meeting with partners.
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Retail Operations
Just as a corporation interacts with its customers at a retail level, EPA interacts with its customers
(industry partners) through contractors, regional offices, or directly from headquarters. To
continue this analogy, individual partnerships might be considered EPA's "brands"—the name,
logo, reputation, and promise of future service that customers associate with particular programs.
In retail operations, "brands" must be very carefully managed. They should not compete with each
other (just as two shampoos from the same company should not compete in the same segment of
the market) and ideally they should reinforce each other (a low cost "starter" automobile brand
that allows customers to graduate to a higher priced brand as they accumulate wealth).
We have little evidence that EPA's partnership programs have focused on this type of "brand
management." The survey results indicated that only 5 percent of program managers considered
other programs an important source of client leads (see Figure 5) and anecdotal evidence in
regional interviews suggests that the partnership programs actually compete with each other for
partners. In addition, the EPA partnerships "compete" with other federal and state partnerships,
for example those sponsored by the Department of Energy. The problem of "brand identity" needs
further study to determine whether they are competing by selling essentially the same product to
the same customers, selling different products to the same customers, or different products to
different customers.
EPA partnership programs are missing opportunities that could benefit all the partnership
programs and misallocating resources. No strategy exists for cross-selling of partnerships or for
"graduating" partners from relatively straightforward "starter" programs to much more
comprehensive programs. Programs expended substantial effort to identify new partners, while
little effort is made to capitalize on existing partners, who may be receptive to EPA requests to
join another partnership. As noted above, only 5 percent of headquarters program managers said
they considered other programs an important source of client leads. By contrast, both
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implementers and managers indicated that word of mouth and outreach are important sources of
leads (see Figure 5). Program managers reported spending an average of between 20 and 25
percent of their budget on marketing, and regional implementers reported spending an average of
26 percent of their time on marketing. A very substantial amount of time is spent on program
management and coordination with national programs (43 percent) and only 13 percent of time is
spent on providing technical assistance to partners.
Figure 5: Contacting Potential Partners
"How important is
in contacting potential
partners?"
Word of mouth
Outreach
Trade association
Cold calls
Leads from states
Leads from EPA programs
20%
80%
40% 60%
Percent of Survey Respondents
• Regional Imptomenteis • National and regional managers
100%
The problem of coordinated marketing is complicated by the lack of central coordination at
headquarters, the stovepipe structure of the Agency, and by the role of contractors in partner
interaction.12 Nevertheless, it is difficult to see how coordination can be improved given the
current structure of EPA's partnership programs. Programs are funded independently and
12 ,
The large programs' contractors work directly with partners, not with other programs in client interaction.
Although regional staff often work on two or more programs, the major headquarters use contractors who to a greater or
lesser degree bypass the regions.
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promoted independently both internally and externally. There are few incentives for sharing client
leads and EPA's current atmosphere (in order to measure and demonstrate performance it is
important for programs to win for themselves rather than for all the Agency's programs), in fact,
offers disincentives for cooperation.
The View from the Partners and Stakeholders
We contacted six industry representatives and one NGO to get an impression of how industry and
stakeholders perceive partnerships. Because of the small sample of companies contacted in our
study, the findings described in this section are not comprehensive, yet instructive. The following
are the major findings from these interviews:
All of the companies contacted indicated that partnership programs are useful because
they can affect the companies' internal decision-making. Being associated with a
partnership gives a company's environmental initiative greater internal priority and makes
it more likely that initiative will receive resources, time, and attention.
There was general consensus (but not unanimity) that the technical assistance provided by
partnerships is useful. Small companies without other sources of data appreciate the
technical assistance and large companies find it useful to have information documented
and available in one place.
The companies felt they could "handle" the large number of partnership programs. The six
industry representatives interviewed understood that EPA needs to have a wide range of
partnership programs and is not confused by them.13
There is distrust of EPA because it is a regulatory agency. One representative of a large
environmentally progressive company said that one particular partnership program is rigid
13 This finding differs from other studies of industry attitude and needs to be verified by further research before
it can be accepted. In fact, the views of the one NGO interviewed were much more negative than those of the industry
staff. The NGO (with considerable partnership program experience) generally concurred with previous industry
critiques that partnership programs are too numerous and confusing. This organization also expressed a concern that the
requirements of some partnership programs present a moving target to industry.
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and bureaucratic in its response to suggestions for improvement and that its consultants
are "arrogant" and uninformed "just like with regulatory programs." Another said that as a
matter of company policy, they participate only in partnerships that are not associated with
any regulatory issues because they are concerned about letting EPA's regulatory
enforcement staff "get the camel's nose in the tent."
EPA's inconsistent support of partnership programs causes confusion and frustration. A
strong trade association supporter of partnership programs based on one very positive
experience promoted another program only to find out that the program was cut back by
EPA. The cancellation was a source of considerable embarrassment.
Has any of your programs been more/less successful? What contributed
to success/failure?
SUCCESSES
• "Brought EPA HQ and regional staff, state staff, and industry reps together as team
members in a way that had never been tried before.."
• "The partnership aspect...very successful in building better relationships across state,
federal, industrial, and environmental institutions."
FAILURES
• "(In)ability to reach internal consensus on the role of voluntary programs and
appropriate benefits."
• "Small business participation."
• "Attempts to team up with DOE."
• "Lack of commitment from team members."
• "HQ staff didn't share...visions and goals...did not communicate with regions."
Source: Surveys of National Managers and Regional and National Implemented
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PART IV: RECOMMENDATIONS
In slightly less than a decade, partnership programs at EPA have evolved from two experimental
programs (33/50 and Green Lights) into a richly varied (and sometimes bewildering) array of over
40 programs addressing diverse headquarters and regional office priorities. In addition, individual
states have in many instances adopted the partnership model. As a result, EPA has a base of
experience with partnerships that did not exist a decade ago. Given this experience and the
Agency's current review of its reinvention activities, this is a particularly appropriate time to
examine how EPA can utilize and manage partnership programs more effectively.
Although we have not rigorously evaluated the results of the partnership programs to date, we
strongly believe, based on evidence provided by the programs themselves and by industry
partners, that the partnership approach is vital to addressing effectively the environmental
protection challenges of today and tomorrow. As the summary of our findings suggests, we also
believe that partnership programs can be better supported and managed at EPA. Our starting
point in making the recommendations that follow is that the Agency could firmly commit to
improving the application and effectiveness of partnership programs. We have developed six
recommendations based on this fundamental premise. These recommendations are outlined below
and expanded upon in the rest of the report.
First, we recommend three critical steps for EPA to take to integrate partnerships as a core
strategic element for accomplishing its mission:
• Better define and articulate the role of partnerships in the Agency's mission.
* Develop and use performance indicators relevant to partnerships.
• Provide adequate, consistent financial support to partnership programs.
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Second, we identify three actions for the OPR to take in broadening their role of coordinator to
include that of champion of the Agency's partnership programs:
• Serve as the champion for partnership programs Agency-wide.
• Provide services that respond to the needs of the partnership programs and make them
more effective.
• Ensure that partnership programs meet a high and consistent level of quality, convey an
image of creativity, show dedication to cost-effective environmental management, both
inside and outside EPA.
I. EPA-WIDE ACTIONS: INTEGRATE PARTNERSHIPS AS A CORE ELEMENT
OF EPA'S MISSION
As noted in Part I, "The Context of Environmental Management," in a more knowledge- and
service-based economy, non-regulatory approaches will be an increasingly important management
mechanism for EPA. Partnerships are one of EPA's potentially most effective non-regulatory
mechanisms, but, as we noted in our "findings" section, there is disagreement within the Agency
over the appropriateness and role of partnership programs and the support that they should
receive. We discuss below the following three key actions for EPA to take to ensure that
partnerships realize their full potential:
• Better define and articulate the role of partnerships in EPA's mission.
• Develop and use performance indicators relevant to partnerships.
• Provide adequate, consistent financial support to partnership programs.
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4]
Define and Articulate the Role and Value of Partnerships in EPA's Mission
Most importantly, the Agency needs to build consensus across both partnership program staff and
non-program staff concerning the role of partnership programs in a structure that is primarily
regulatory. Consensus in some areas is reasonably well established—for example, the use of
partnership programs to reduce greenhouse gas emissions where the Agency lacks regulatory
authority (although even in this area Agency skeptics argue that "if it's such a good idea, industry
would be doing it on its own"). There is much less agreement concerning the role and value of
smaller, innovative programs, particularly regarding what value they have in changing the internal
culture of EPA and in the way EPA interacts with industry.
In fact, there are few guidelines for what the "new" relationship between EPA and industry should
look like, and both partnership and non-partnership staff struggle to create this vision. Should
recognition be given to industry for taking actions that are in its own interest? Should regulatory
compliance be a prerequisite for recognition? Should partnerships benefit large, well-established
companies or should benefits go to smaller companies? What should be the role of communities
and stakeholders in defining program objectives? Should partnership programs receive special
consideration because they have cultural change and reinvention benefits beyond their direct
environmental benefits, or should they be subject to the same cost-effectiveness tests as traditional
programs? Will partnership programs lose credibility if they are oversold and overused? How
should partnership programs be protected from budgetary whipsaws caused by fluctuating
budgets and constant budget allocations for mandatory programs?
In interviews we identified substantial confusion concerning the definition, role, and value of
partnership programs to EPA. This confusion is a fault line running through the Agency's
attitudes toward partnership programs: proponents extol their virtues as the incubators of the new
EPA; skeptics suggest that partnership programs are oversold and provide services that industry
should provide for itself. The process of defining the role of partnership programs should:
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Partnership Program Management Review
42
Articulate the case for partnerships in theoretical and practical terms. As we have noted in
this report, while there exists a coherent, generally accepted theoretical framework for the role of
regulation in a market economy, the same is not the case for partnership programs. Both the
theoretical and the practical case for partnerships need to be made and articulated. In particular,
the Agency must answer internal and external skeptics by developing a rationale for EPA's
involvement in programs that are, in theory, in industry's own best interest.
Define priority goals for the application of partnerships. With the exception of a few regions
and offices that have defined a role for partnerships in their mission, mere has been little
systematic thinking about the current and emerging environmental issues that partnership
programs can most effectively address, in what circumstances and how partnerships can be
combined with regulatory programs, under what circumstances partnerships are likely to prove
effective, and what their limitations are. A first step is to define, based on experience, what types
of issues lend themselves to a partnership approach and to identify current and emerging
environmental issues that can most effectively be addressed through partnerships.
Build consensus around the role of partnerships in accomplishing EPA's mission. The
partnership approach will flourish most effectively if all Agency staff understand its value and
priority applications. At present, partnership programs and staff have relatively little day-to-day
contact with non-partnership programs and staff. Although cultural change will not happen
overnight, we believe there exists an interest in (but little understanding of) partnership
approaches throughout EPA. We recommend that EPA act to ensure that the role of partnership
programs is understood throughout the Agency.
Specific, detailed steps toward accomplishing these three goals are discussed in Appendix A.
Develop Performance Indicators Relevant to Partnerships
Under GPRA, the Agency has focused very strongly on outcome-based environmental results
measures. While this emphasis is commendable in itself, it has had the unfortunate consequence of
ignoring other dimensions of performance. In a seminal article in Harvard Business Review,
Norton and Kaplan have argued that a single-minded focus on one aspect of performance (in the
case of corporations, financial performance) is similar to a pilot flying an airplane with only an
altimeter: he or she may know how high the airplane is flying but have no idea how much fuel the
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Partnership Program Management Review
43
airplane has left. To provide the other gauges, Norton and Kaplan propose the "Balanced
Scorecard," now in common use among corporations.14
In an adaptation of the balanced scorecard to partnership programs, environmental results are
analogous to financial results for companies. Accordingly, partnerships can be measured across
four dimensions, one of which is environmental results:
Environmental Results. "Is the environment improving?" Results measures are clearly the key
measures of performance. Programs such as Energy Star and WasteWiSe have developed
effective results measures that demonstrate that they are attaining their goals in a cost-effective
manner. Defining results measures for programs that are more removed from direct environmental
results, such as the Environmental Accounting Program or Environmental Technology
Verification, is more complex and may not reflect the full contribution of these programs.
Internal Management "Are programs being managed effectively? Are we doing the right
things?" The survey of partnership program managers and implementers revealed significant
problems in inter-program management (intra-program management was more effective). Internal
management measures may include:
— "Cost of sales" or "overhead" time per partner.
— Employee satisfaction.
— Lead sharing (number of partner contacts provided to other partnerships, number
received from other partnerships).
— Integration with regulatory and/or non-regulatory programs.
Not all measures necessarily apply to all programs, but all programs would benefit from internal
management tracking (some programs may already have such measures in place).
Customer Satisfaction. "Are our partners and stakeholders happy?" Clearly, a key dimension of
success for partnership programs concerns the extent to which their "customers," i.e., partners
and stakeholders, are satisfied. Currently, EPA is conducting customer satisfaction surveys of four
Norton, D. and R. Kaplan. January-February 1996. Using the balanced scorecard as a strategic management
system. Harvard Business Review.
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Partnership Program Management Review
44
partnership programs. Ideally, such data would be developed for all programs. The programs can
take advantage of OMB's quick turnaround period (two weeks) for customer satisfaction surveys,
and the process could be expedited by getting blanket approval for a common template of
questions appropriate to most or all of the programs. Other surrogate measures of customer
satisfaction can, however, be used. These might include 800-line responses, referrals to other
partners, or comment cards filled out at seminar or outreach sessions.
Innovation and Learning. "Are we improving?" Given the importance of partnership programs
to EPA's Reinvention, the innovation and learning they generate are important aspects of their
performance. Performance measures may include "lessons learned," adoption of the model by
other regulatory or non-regulatory programs, and information-sharing through coaching and
mentoring. These measures may be quantitative (number of programs adopting a given model) or
qualitative (description of lessons learned). As one regional staffer told us, "We emphasize that
partnership programs are part of developing a new way to manage the environment, but then we
measure their performance exclusively in terms of environmental results."
Provide Adequate, Consistent Financial Support to the Partnership Programs
The funding available for EPA partnership programs is seen by program staff as inadequate and
inconsistent. We are not able in this report to determine whether, relative to EPA's other
priorities, the funding for partnership programs is "inadequate." This judgment depends on how
important EPA considers partnerships and how EPA fares in the Congressional budget allocation
process.
We can say, however, that the inconsistent "whipsaw" nature of the partnership program
budgets—one of our findings noted previously—is demoralizing and exasperating to program
staff and, of great importance, to industry and stakeholder partners. Highly dedicated program
staff receive a clear message that EPA does not consider their role important when budgets are
cut year to year, and long- or even short-term planning is also extremely difficult. Budgetary
uncertainty exacts a toll on industry partners as well: they are much more reluctant to participate
in partnership programs if they have invested substantial resources in a given program that is
subsequently cut back or eliminated. We recommend two actions in particular for EPA to take in
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Partnership Program Management Review
45
reducing budgetary uncertainty and ensuring that worthy partnership programs receive
appropriate support:
Make the Case for Partnerships in Budget Negotiations. For partnerships to argue their case
effectively at budget negotiations, EPA needs to build a foundation of knowledge about
partnership programs' budgets. This involves tracking program budgets, tracking budget
fluctuations, and evaluating the cost-effectiveness of resources expended on partnership
programs.
Secure Consistent Incubator Funding. We recommend that EPA ensure that deserving projects
are underwritten by establishing an internal "start-up" fund to match office or regional resources
expended during the early phases of implementing new partnership programs.
These two actions are discussed in greater detail in Appendix A.
II. OFFICE OF POLICY AND REINVENTION: AS COORDINATOR AND
CHAMPION
OPR has been given a somewhat vague mandate to coordinate the activities of the partnership
programs. The reason why this mandate is unclear is readily apparent: partnership programs and
their staff do not lend themselves readily to centralized management. First, the programs
themselves are highly diverse in terms of subject matter, approach, and tools. Second, the very
characteristics of entrepreneurship, creativity and flexibility that make programs and staff effective
make centralized management inappropriate.
Although the partnership programs do not need centralized management, they do need a
champion within EPA to advocate for the partnership approach and to ensure that the Agency
takes the necessary steps to support promising programs. We believe that OPR, as the EPA office
with the broadest responsibilities for changing the Agency's approach to environmental
protection, should undertake this role of champion. This role involves three key functions:
Serve as the champion for partnership programs Agency-wide.
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Partnership Program Management Review
46
Provide services that respond to the needs of the partnership programs and make them
more effective.
Ensure that partnership programs meet a high and consistent level of quality.
Serve as the Champion for Partnership Programs Agency-wide
Individual program offices have been highly effective in some cases as champions for their
particular partnership programs, but there has been little advocacy for partnership programs per
se within EPA or to external constituencies (Congress, industry, stakeholders). No internal group
has taken the initiative to articulate the case for partnership programs and to build consensus
within the Agency on their most effective applications. Serving as the internal champion for
partnership programs involves pushing the Agency to implement the three Agency-wide
recommendations given previously: defining the role and value of the partnership approach;
ensuring that the programs receive adequate and consistent funding; and developing relevant
indicators of performance.
In particular, OPR will have to work closely with the following constituencies within EPA to
drive implementation of the Agency-wide recommendations:
The Office of the Administrator and the Reinvention Action Council. There exists a
perception among both program and non-program staff that senior EPA management support for
partnership programs is variable and inconsistent. Whether this perception is correct or not, OPR
should ensure that, to the extent possible, support and funding for partnerships is visible,
consistent, and predictable.
Non-Program Offices at EPA. There are important functions in non-program offices at
EPA—strategic planning, budgeting, outreach, Congressional relations, policy analysis—that can
influence how partnership programs are perceived and supported internally and externally. The
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Partnership Program Management Review 47
recent consolidation of the Offices of Reinvention and Policy in particular creates an important
opportunity for partnership programs.
Media and Program Offices. Partnership programs are well established in specific areas of
particular program offices. Outside of those offices they are not well known. In addition, OPR
could help promote the smaller partnership programs.
Regions. Some EPA regions have adopted partnership programs as a core element of their
activities while others have minimal programs. OPR could help promote partnerships among
regions where they are relatively underutilized.
Similarly, OPR could help to convey a consistent, positive message concerning partnerships to
external audiences, including industry, stakeholders, and Congress. This activity goes beyond
promoting individual programs to promoting the concept of partnerships as a legitimate and
important mechanism for EPA to accomplish its mission in the context of ongoing structural
changes in the American economy.
Provide Services That Respond to the Needs of Partnership Programs
Because partnership programs share certain characteristics, they will benefit from services
developed for their particular needs. For example, both StarTrack (Region 1) and WasteWi$e
attempt to encourage companies to undertake cost-effective pollution prevention activities
voluntarily. Although they reside in very different places organizationally speaking, both programs
share the challenges of marketing an "environment in your own best interest" philosophy to
potential partners and of gathering and reporting environmental results.
As a champion of the partnership programs, OPR is well positioned to know and address their
particular needs. Although there are opportunities for all programs to benefit, needs may be
greatest in the cases of the smaller, cross-media programs which may not have strong, consistent
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Partnership Program Management Review
48
internal support from their respective offices. Services that OPR could provide to these programs
include:
Networking, communications, and knowledge exchange. The PPCC is a useful mechanism but
it suffers from a lack of participation of program staff. PPCC subcommittees have been poorly
attended, in part because the PPCC has not focused on service provision. In addition to focusing
the PPCC (or a group within the PPCC, as is currently being considered) more directly on service
provision, a more proactive OPR role would be to make specific "matches" between programs
that share common interests or needs. For example, OPR might link up two programs facing a
similar partner or substantive issue based on its knowledge of the programs. In this sense, OPR's
expertise would be knowing where opportunities for mentoring or knowledge exchange exist.
Recognition. Most partnership program staff are highly dedicated and serve the program as a
labor of love, with little recognition or reward. The Agency could set up a recognition program
for partnership staff, administered by OPR, to recognize individual staff members or programs for
their contributions-(nominations could come from partners or stakeholders). Award recipients
would be publicly recognized Agency-wide. Like incubator program participants, recipients of
recognition could be asked to develop lessons learned to improve future programs. This
recognition program could also be carried out on a broader scale, where entire programs are
recognized for their results and achievements.
Specific tools. Recently OPR brought in experts in program evaluation to describe evaluation
techniques to partnership programs so that they could evaluate their own programs. OPR could
provide similar tools based on best practices within the programs or using outside expertise. For
example, OPR could develop performance measurement tools or partner contact tools that would
be useful across programs.
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What services could OR/PPCC usefully provide?
• "Critically evaluate the programs...and tell management the truth..."
• "Seek cross-platform opportunities."
• "More importance attached to the program by management."
• "Gatekeeper...integrator...lessons learned."
• "Clearinghouse."
• "Information gathering and sharing only."
Source: Surveys of National Managers and Regional and National Implemented
Ensure That Partnership Programs Meet a High and Consistent Standard of Quality
The traditional role of a champion is to advocate on behalf of its constituency and to ensure that
its constituency receives the most appropriate level of support. As champion of the partnership
programs, OPR should pursue one additional priority: ensuring that all partnership programs meet
high standards for quality. If partnership programs were poorly designed or implemented, all the
programs would suffer by association, and OPR's role as champion would be undermined.
Programs should be proud to call themselves partnership programs and careful to save the
benefits of being a partnership program for deserving, innovative programs.
Playing the role of gatekeeper will be challenging for OPR because programs may question its
authority to take this role. If legitimate partnership programs truly perceive the benefit of OPR as
champion, however, they will understand the need for the gatekeeper role. The advocacy and
valuable services that OPR has to offer should be reserved for programs that meet high standards.
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50
At a minimum, OPR should develop and apply guidelines to new programs that want access to its
services and advocacy and should assist existing programs in improving based on internal
evaluations.
III. THE NEXT STEPS
A process of change must start somewhere. As champion of the partnership approach, OPR can
capitalize on ongoing and planned activities in the coming year as platforms for defining the role
and priority applications of partnership programs, building consensus within the Agency, and
advocating for sufficient funding. These activities may include:
• The revision of EPA's strategic plan
• The activities of the Reinvention Action Council
• The development of sector-based action plans
• The review of program activities by EPA's Planning and Budget Office
At these venues, OPR should develop and present a coherent theoretical and practical case for the
partnership approach. As this case becomes better defined, it may be appropriate for OPR to
organize a high-profile retreat to further develop the case for partnership programs and to begin
the process of articulating the case and building consensus within the Agency. Representatives of
the program and regional offices, partnership program representatives, and key partners and
stakeholders could be invited. A structured two-day retreat of this nature would be an excellent
vehicle for beginning to involve key personnel across EPA in the process of making partnerships a
cornerstone of EPA's approach to environmental protection.
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APPENDIX A
DETAILED RECOMMENDATIONS
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APPENDIX A—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 2
Appendix A
Detailed Recommendations
In this appendix we present detailed, specific steps for implementing the first two of our EPA-
wide recommendations from Part IV of the report: articulating the role of partnership programs in
accomplishing the Agency's mission and providing adequate and consistent funding for the
programs.
Define and Articulate the Role and Value of Partnerships in EPA's Mission
In Part IV, we discussed three facets of this recommendation. We present detailed implementation
steps related to each facet below.
Articulate the Case for Partnerships in Theoretical and Practical Terms
As we have noted in this report, while there exists a coherent, generally accepted theoretical
framework for the role of regulation in a market economy, the same is not the case for partnership
programs. Both the theoretical and the practical case for partnerships need to be made and
articulated. In particular, the Agency should:
— Define what a partnership is. At present, partnerships are self-defined. If a
program considers itself a partnership, it is a partnership. There is a need for a
clear, readily communicated definition of partnerships for the benefit of both the
EPA staff and the public.
— Establish criteria for designating partnerships. From both a quality control and
an identity viewpoint, there should exist criteria for designating new partnerships.
These criteria should be derived directly from the definition. One principle to keep
in mind: being designated a partnership should convey status and benefits to the
partnership, not merely require attendance at PPCC meetings.
— Set expectations. While not all partnerships need necessarily lead to specific direct
environmental benefits, their objectives should be clearly set and measurable and
partnership staff should be accountable for performance (see below for
performance measures).
Define Priority Goals for the Application of Partnerships
With the exception of a few regions and offices that have defined a role for partnerships in their
mission, there has been little systematic thinking about the current and emerging environmental
issues that partnership programs can most effectively address, in what circumstances and how
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APPENDIX A—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 3
partnerships can be combined with regulatory programs, under what circumstances partnerships
are likely to prove effective, and what their limitations are. In particular, the Agency should:
— Work with its strategic planning staff to identify emerging environmental issues
("environmental futures") and to determine how partnership programs can be used
to address these issues.
— Review the regulatory agenda to identify upcoming regulations or initiatives that
may lend themselves to a partnership approach.
— Work with regional office staff io identify issues and approaches where
partnership programs have been particularly effective.
— Work with industry and stakeholder groups to identify their environmental
priorities over a 5-year timeframe to identify how these priorities can be addressed
using a partnership approach.
— Identify "gaps " in partnerships. Partnerships are heavily concentrated in a few
areas—energy, solid waste, and toxics—and by and large focus on large company
partners. Partnerships likely lend themselves well to use by other media and cross
media programs and would be a useful tool to address small enterprise issues.
— Build strategic links among partnerships. A well-conceived partnership program
may have "entry level" partnerships to introduce partners to the benefits of
partnerships and a system of graduating partners to more advanced programs.
— Develop partner-oriented programs. At present, partnership program structures
are dictated by the needs of different organizations within EPA (i.e., individual
offices and the regions). Partnerships might be less costly to implement and more
effective if they focused on the needs of the partners. For example, there could
exist an umbrella partnership program for building owners and operators that
covered energy, solid waste, and water issues.
Build Consensus Around the Role of Partnerships in £PA 's Mission
The partnership approach will flourish most effectively if all Agency staff understand its value and
priority applications. At present, partnership programs and staff have relatively little day-to-day
contact with non-partnership programs and staff. Although cultural change will not happen
overnight, we believe there exists an interest in (but little understanding of) partnership
approaches throughout EPA. The following are specific steps to begin the process of cultural
change:
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APPENDIX A—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 4
— Integrate partnerships in office-specific and EPA-wide planning processes.
Only 9 of 24 partnership programs responding to the managers' survey said they
coordinate objectives with other partnerships; a more important statistic (which we
did not research) would be how many EPA non-partnership programs have
considered a partnership approach. There may be a useful lesson learned in the
experience over the past decade of integrating pollution prevention in EPA's
planning processes. This integration was accomplished through a mix of specific
requirements to account for pollution prevention in the regulation development
process, the availability of assistance from the Office of Pollution Prevention, and
Agency-wide publicity. The experience of pollution prevention could be used as a
model for partnerships.
— Distribute a "primer" on the partnership approach to staff involved in the
development of regulatory and non-regulatory programs describing the theoretical
case for partnerships and their practical benefits, the role of partnerships in EPA's
mission, the conditions under which they are likely to prove successful, limitations
on their use, and case studies of their application. The primer should be
theoretically rigorous but written in a down-to-earth, user-friendly style.
— Integrate partnerships in incentive structures for senior staff. Performance
appraisals and incentives may, for example, include specific recognition for
environmental results obtained using a partnership program approach.
Provide Adequate, Consistent Financial Support to the Partnership Programs
In Part IV of the report, we discussed two components of this recommendation. We elaborate on
these components, making the case for partnerships in budget negotiations and securing consistent
incubator funding, below.
Make the Case for Partnerships in Budget Negotiations
With a few exceptions, partnership program budgets appear to be what is left over after
"essential" programs have been taken care of or they are pieced together from funds available for
other programs. If they are an important element of EPA's mission, they should be considered
explicitly in budget appropriations.
— Track partnership program budgets. At present, no one at EPA can answer the
question, "How much does EPA spend on partnership programs?" let alone more in-
depth questions such as, "How much do partnerships spend on outreach, technical
assistance, and program management?" Without this information, it is difficult for EPA
to determine whether the resources spent on partnerships are adequate and whether
they are well spent. In addition, this information could be compared to similar
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APPENDIX A—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 5
information for non-partnership programs as a benchmark of the relative severity of
fluctuation in overall spending on partnership programs.
— Track budget fluctuations. Partnership programs' budget fluctuations have serious
repercussions because they diminish the credibility of the Agency with its external
partners and its own staff. As part of the budget tracking described above, there
should be a mechanism to highlight specific programs that are undergoing particularly
severe and abrupt funding changes. If these changes are inevitable, specific actions
should be taken to limit their damage to EPA's relationship with its staff and partners.
— Evaluate the cost-effectiveness of resources expended on partnership programs. It
is probably impossible to develop a means to link all partnership expenditures to
environmental results measures and to use this information as a single indicator of cost
effectiveness. It should, however, be possible to link partnership program expenditures
to the "balanced scorecard" measures described in Part IV of the main report. While
individual partnerships may not show results in all dimensions of the balanced
scorecard, they should show cost-effective results in some of the measures.
Secure consistent incubator funding
EPA should develop a discretionary budget to support deserving projects as defined by
predetermined criteria (for example, small business benefit, multimedia impact, highly important
innovative or learning opportunities, long-term sustainability). It could match regional or
partnership funds to ensure that a new program has sufficient funding over, say, a 3-year period,
enough time to become well-established. Incubator programs could also receive coaching and
mentorship from established programs. A condition of participation in an incubator program
might be that the recipient be available as a training case study of partnership program
implementation (much as Federal Quality and Malcolm Baldrige award recipients are).
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APPENDIX B
SURVEY TEXT
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
Appendix B
Survey Text
This appendix contains the full text of the managers' survey (sent to managers of national and
regional partnership programs) and the implemented' survey (sent to regional implementers of
national programs).
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
General Program Information
1. What is the name of the partnership program for which this survey is being completed?
2. Is this a national or regional partnership program? (check the one that best applies)
National Regional (please indicate the Region):
3. What is your role in the program? (check the one that best applies)
Partnership Program Manager
Partnership Program Staff
4. Is there a specific statutory basis for your program? (markyes or no with an "x ")
_ Y N Don't know
If so, what is it?
5. Do you have a defined mission statement? (markyes or no with an "x ")
_Y _N
If yes, please e-mai! or fax a copy along with the completed survey, or give the URL where it can be
found on the Internet:
6. In your own words, what benefits does your program provide to your partners?
7. Why is a partnership program appropriate to provide these benefits? Were any alternative approaches
analyzed when the program was being established?
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
Organization Within EPA
8. Which of the following best describes how your program is structured within EPA? (mark the option
that best applies with an "x ")
Run entirely from EPA Headquarters
Run from Headquarters with support from some or all of regions
Run from the Regions, with Headquarters playing a coordinating role
Run entirely from one Region
Other (please specify):
9. If your program is run from Headquarters with support from the Regions, please indicate how many
Regions are actively involved.
Number of regions actively involved in supporting the program
10. What outside support does your program rely on? (mark each option that applies with an "x ")
Consultants and contractors
Trade associations
_ State staff
Universities
Other (please specify):
11. What is the title of the person to whom the head of your program reports, and where is he or she located
in the organization?
Title (of person to whom program head reports):
EPA Program or Office:
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
10
Managers9 Survey (Sent to Managers of National and Regional Partnership Programs)
12. What, if any, do you find to be the major organizational/internal barriers to the implementation of the
program? (please rate each from 1 to 5 using the following scale: 1 = not important; 2 - minimal
importance; 3 = somewhat important; 4 = quite important; 5 = most important)
Poor communication/coordination between Headquarters and the regions (if your program is a
national program)
Poor coordination and communication among partnership programs
__ Lack of clarity as to program definition and/or objectives
Lack of clear, quantitative performance measures
Excessive red tape
Lack of recognition as important within EPA
Insufficient resources (excluding number of staff)
Insufficient number of staff
High turnover of program staff
Lack of staff skills in managing collaborative programs
Staff working on program implementation have too many other commitments
Other (please specify):
13. What do you consider the major organizational supports in the implementation of the program? (please
rate each from 1 to 5 using the following scale: 1 = not important; 2 = minimal importance; 3 =
somewhat important; 4 - quite, important; 5 = most important)
Flexibility and ability to innovate
Effective coordination among programs
Access to support from other partnership programs
Support and recognition from my management
Support and recognition from EPA management
Dedication and commitment of program staff
Clearly defined, measurable goals
Other (please specify):
14. Has any of your projects been more/less successful than you anticipated? If so, what was the project and
to what do you attribute its success/failure?
Success:
Failure:
15. What motivates you personally to participate in the program?
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
11
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
Budget
16. What is the total FY99 budget for your program?
' $
17. How many FTEs do you have assigned for FY99?
FTEs
18. What is your contractor budget for FY99?
$
19. What were your FY97 and 98 budgets?
FY97: $
FY98: $
20. What EPA Programs, Offices, or Regional Divisions determine your budget?
21. If your program is run from Headquarters with assistance from regions, please indicate what role
Headquarters plays in funding regional assistance, (mark the option that best applies with an "x "; leave
blank if your program is not run from HQ with assistance from regions)
The Headquarters program provides participating regions with budgetary resources ($ and/or FTEs)
for assisting with program implementation. These resources cover most or all of the costs incurred by
the regions.
The Headquarters program provides participating regions with limited budgetary resources ($ and/or
FTEs) for assisting with program implementation. The regions, however, pick up most of the cost of
implementation assistance.
The Headquarters program does not provide participating regions with any sort of budgetary
resources. The regions pick up the full cost of implementation assistance.
This varies greatly from region to region.
Don't know
Other (please specify):
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
12
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
22, If states assist in the implementation of your program, please indicate how their assistance is funded.
(mark the option that best applies with an "x "; leave blank if states are not involved in
implementation of your program)
States do not assist in program implementation.
Participating states are given grants for assisting with program implementation. These resources
cover most or all of the costs incurred by the states.
Participating states are given small grants for assisting with program implementation. The states
themselves, however, pick up most of the cost of their assistance.
Participating states do not receive any grants for assisting with program implementation. They pick
up the full cost of implementation assistance.
This varies greatly from state to state.
Don't know
Other (please specify):
Partner Involvement
23. How is your partnership program structured? (please mark the option that best applies with an "x ")
Partners sign a formal Memorandum of Understanding (or equivalent) to join
Agreements between EPA and participants are created on an ad-hoc basis
We maintain a network of interested parties but do not have any formal partners
Other (please specify):
24. How important is each of the following in contacting potential partners? (please rate each from 1 to 5
using the following scale: 1 -we don't use this method; 2 = minimal importance; 3 = somewhat
important; 4 = quite important; J = most important)
Advertising
Word of mouth
Compliance actions
Cold calls and networking
Outreach, e.g. seminars or Public Service Announcements (PSAs)
Leads from other partnership programs
Leads from other EPA programs
__ Leads from states
Trade associations
Other (please specify)'.
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
13
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
25. Roughly speaking, what percentage of your budget is used for marketing and outreach?
percent
26. Does your program have a system (or exit strategy) for "graduating" partners who have demonstrated
superior performance and/or achieved the goals of the program? (mark the option that best applies with
an "x")
Yes, we do have this sort of exit strategy
No, we do not have this sort of exit strategy, but we could potentially develop one
No; this sort of exit strategy does not make sense given our program structure
If you answered "Yes" above, please describe your exit strategy.
27. Does your program itself have an exit strategy? In other words, does your program have a definitive end-
point or set of goals that, when achieved, would imply the closing of the program? (mark the option that
best applies with an "x ")
Yes, we do have this sort of exit strategy
No, we do not have this sort of exit strategy, but we could potentially develop one
No; this sort of exit strategy does not make sense given our program structure
If you answered "Yes" above, please describe your exit strategy.
28. How is contact maintained with Partners? (please mark all that apply with an "x ")
Designated EPA personnel maintain contact with groups of partners
Designated contractor employees maintain contact with groups of partners
As new developments occur, partners are informed by e-mail or other communications
Contact proceeds with partners on an ad-hoc basis
Partners submit periodic reports
Other (please specify):
-------
APPENDIX ^-PARTNERSHIP PROGRAM MANAGEMENT REVIEW
14
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
29. How many partners do you have, and how many other supporters, allies, and endorsers (organizations
that support or endorse the program but are not partners) do you have? (please indicate in the matrix the
approximate number of partners and supporters in each category and the total numbers)
Category
Private-sector companies
Public agencies or organizations
Trade associations
Other non-governmental organizations
Universities
Foreign partners
Other (please specify):
TOTAL
Number of
Partners
Number of Supporters,
Allies, or Endorsers
30. Of your partners in the private sector, approximately what percentage are small businesses? (please
indicate the approximate percentage; leave it blank if you can't make an approximation)
31. Does your program target a specific geographic area such as a particular state, a water- or airshed, or a
border area? (please mark yes or no with an "x")
_Yes _No
If you marked'Tes", what geographical area?
-------
APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
15
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
Stakeholder Involvement
32. What sorts of stakeholders do you involve in your program? (mark all that apply with an "x ")
Other government agencies
Industry associations
_ States
National and regional environmental organizations
Communities
Suppliers to target partners
Customers to target partners
Educational or research organizations
Supporters, Allies, or Endorsers (please define):
Other (please specify):
33. How helpful have you found participation from stakeholders to be in supporting and improving your
program? (mark the option that best applies with an "x ")
Extremely helpful
Very helpful
Somewhat helpful
_ Unhelpful
Very unhelpful; a hindrance
Our experience varies so much that it is impossible to generalize
-------
APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
16
Managers'Survey (Sent to Managers of National and Regional Partnership Programs)
Interactions Witb Other Programs
34. Please fill in the following matrix regarding the types of interaction between your program and other
EPA, federal, and state programs and non-governmental organizations (NGOs): (mark an "x" where
appropriate for the first four rows; specify any other types of interaction you have in the fifth row;
and list the programs you interact with in the sixth row)
Types of Interaction
1 . Coordinate objectives
2. Share client leads
3. Coordinate client
participation (one-stop
shopping)
4. Ideas for program design
5. Other (please specify)
6. With what programs?
Other EPA
Partnership
Programs
Other EPA
Programs (non-
partnersbip)
Programs in
Other Federal
Agencies
State
Programs
NGOs
35. What opportunities do you see for increased interaction with EPA partnership programs, other EPA
programs, programs in other Federal agencies, states and/or NGOs?
36. The Office of Reinvention (OR) has recently been assigned the role of coordinating the efforts of
partnership programs. How have OR's efforts been useful to you? (mark all that apply with an "x ")
Our program has benefitted from OR's internal coordination and networking efforts
Our program has received potential partner leads through OR's efforts
Our program has benefitted from OR's overall outreach activities (e.g. web site)
Other (please specify):
None of the above options apply
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
17
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
37. Please describe the nature of your interaction with the Partnership Program Coordinating Committee run
out of OR and of your interaction with your Region or Office's PPCC representative. Do you have any
suggestions for improvement?
38. What other services do you think OR could usefully provide in its role as coordinator for partnership
programs?
Evaluation and Measurement
39. Who is responsible for evaluating the success of your program? (please mark all that apply)
We have conducted an internal program evaluation
We are or will soon conduct an internal program evaluation
An EPA group outside of our program has, is, or will soon conduct an evaluation of our program.
(please indicate which EPA organization):
Other (please specify):
40. What criteria were, are, or will be used to evaluate your program?
41. If both your program and an external EPA group have, are, or will soon conduct an evaluation of your
program, are different criteria being used for these two evaluations?
Yes
No
If so, how are they different?
42. Do you gather environmental and/or economic performance data from your partners? (markyes or no
with an "x ")
Environmental:
Economic:
Y
Y
N
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APPENDIX R—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
18
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
43. If you collect these data, please indicate how. (mark the option that best describes how you collect these
data with an "x")
Partners submit an annual report. They do this by using a template file we send them.
Partners submit an annual report. They can do this using our Internet site.
__ Data are periodically collected by interviewing, written communication, or site visits
__ Other (please specify):
44. If you collect environmental and economic performance data, please list the EPA programs or offices to
which you report these data.
45. If you collect environmental performance data, do you have a process for verifying these data? (mark yes
or no with an "x ")
_Y _N
If so, what is your process?
46. Does your program address Government Performance and Results Act (GPRA) objectives and sub-
objectives? (mark yes, no, or don't know with an "x ")
_Y _N _ Don't Know
If yes, please indicate below which objectives and sub-objectives it addresses.
Objectives:
Sub-objectives:
47. Do you gather customer satisfaction data from your partners and stakeholders? (markyes or no with an
"x")
Partners:
Stakeholders:
.Y
Y
N
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
19
Managers' Survey (Sent to Managers of National and Regional Partnership Programs)
48. If you collect these data, please indicate how. (mark the option that best describes how you collect these
data with an "x ")
A survey is periodically sent to partners and/or stakeholders
800 number
Comment cards
Direct feedback
Other (please specify):
49. Roughly speaking, what percentage of your budget is used for conducting evaluation and soliciting
feedback from partners and other stakeholders?
percent
Additional Information
(Please give the following additional information. The Lexington Group may contact you for additional information
or to conduct an interview. Note that individual respondents will not be identified in our report to EPA, although we
will occasionally ascribe particular comments to the programs from which they come.)
Your name:
Your title:
Your phone number:
Your fax number:
THANK YOU!!
Please e-mail the completed survey as a WordPerfect attachment to survey@lexgrp.com or, if necessary,
fax it to 781-674-2851, attn: Richard Wells.
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
20
Implementers' Survey (Sent to Regional Implementers of National Partnership Programs)
1.
General Program Information
Which EPA Region are you from? (mark one option with an "x ")
Region 1
Region 5
Region 9
_ Region 2
Region 6
Region J 0
Region 3
Region 7
Region 4
Region 8
2. What is the number of national partnership programs that you personally help to implement in your
region?
Number of national partnership programs you help to implement
What are the names of these programs?
3. What percentage of your time do you spend on these partnership programs?
% of time
For purposes of this survey, please select the national partnership program you are most involved with out of
the ones you listed above (or, if you are just involved with one such program, choose that one). You will fill
out tbe rest of this survey from the perspective of this program only. If you wish, we encourage you to
fill out additional surveys, one per program.
4. Name of national partnership program chosen for this survey:
5. What is your role in this program?
Manager for regional implementation of a national partnership program
Staff for regional implementation of a national partnership program
Other (please specify):
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
21
Implemented' Survey (Sent to Regional Implemented of National Partnership Programs)
6. Do you have a set of goals or an operating plan that describes your partnership program activities?
(mark yes or no with an "x")
_Y _N
If yes, please e-mail or fax a copy along with the completed survey, or give the URL where it can be
found on the Internet:
7. In your own words, what benefits does this program provide to its partners?
Organization Within EPA
8. Where are you located in the Regional office?
Office (please name):
Division (please name):
Branch (please name):
9, What is the title of the person to whom you report for partnership program activities? Is he or she in
EPA Headquarters or in the region? (mark "Headquarters " or "Region " with an "x " and fill in
title)
Headquarters
Region
Title:
10. How many staff in your region, other than yourself, are involved in implementing this program?
Number of regional staff involved (not counting yourself)
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
22
Implementers' Survey (Sent to Regional Implemented of National Partnership Programs)
11.
12.
What, if any, do you find to be the major organizational/internal barriers to the implementation of the
program? (please rate each from 1 to 5 using the following scale: 1 = not important; 2 = minimal
importance; 3 = somewhat important; 4 = quite important; 5 = most important)
Poor communication/coordination between Headquarters and the region
Poor coordination and communication among partnership programs
Lack of clarity as to program definition and/or objectives
Lack of clear, quantitative performance measures
Excessive red tape
Lack of recognition as important within EPA
Insufficient resources (excluding number of staff)
Insufficient number of staff
High turnover of program staff
Lack of staff skills in managing collaborative programs
Staff working on program implementation have too many other commitments
Other (please specify):
_ lementation of the program?
important; 2 = minimal
most important)
Flexibility and ability to innovate
Effective coordination among programs
Access to support from other partnership programs
Support and recognition from my management
Support and recognition from EPA management
Dedication and commitment of program staff
Clearly defined, measurable goals
Other (please specify):
13. Has any of your projects been more/less successful than you anticipated? If so, what was the project
and to what do you attribute its success/failure?
Success:
Failure:
14. What motivates you personally to participate in the program?
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
23
Implementers' Survey (Sent to Regional Implementers of National Partnership Programs)
15. The Office of Reinvention (OR) has recently been assigned the role of coordinating the efforts of
partnership programs. How have OR's efforts been useful to you? (mark all that apply with an "x ")
We have benefited from OR's internal coordination and networking efforts
We have benefitted from OR's overall outreach activities (e.g. Web site)
Other (please specify):
I know very little about OR's efforts
None of the above options apply
16. What services do you think OR could usefully provide in its role as coordinator for partnership
programs?
17. Please describe the nature of your interaction with the Partnership Program Coordinating Committee
(PPCC) run out of OR and of your interaction with your Regional PPCC representative. Do you
have any suggestions for improvement?
18. Please give any suggestions you have for improving the way your program is managed (either at the
regional or national level).
Program Implementation
19. Please fill in the matrix below regarding whether other EPA programs, other federal agencies, state
or local agencies, or non-governmental organizations are involved in conducting the program, (please
mark YorNin the "Involved" column and name specific entities involved in the right column)
Entity
Other EPA Programs
Other Federal
Agencies
State Agencies
Local Agencies
Non-governmental
Organizations
Involved
(YorN)
.
Specific programs, agencies, organizations
-------
APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
24
Implemented' Survey (Sent to Regional Implementers of National Partnership Programs)
20.
21.
What opportunities do you see for increased interaction with EPA partnership programs, other EPA
programs, programs in other Federal agencies, states and/or non-governmental organizations?
How would you characterize where you spend your program time? (Provide the approximate
percentage of time you spend on each activity below as a percentage of the total amount of time
you spend on the program.)
% Promoting and marketing
% Technical assistance to partners
% Coordination with national program
% Program management
% Other; please specify:
22. What outside support do you rely on for program implementation assistance? (mark each option that
applies with an "x ")
Consultants and contractors
Trade associations
State staff
Universities
Other (please specify):
Budget
23. Do you receive resources from the national program to conduct your regional program activities?
(mark the option that best applies with an "x ")
Yes, we receive resources from the national program
No, we do not receive resources from the national program
I am not sure
-------
APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
25
Implementers' Survey (Sent to Regional Implementers of National Partnership Programs)
24. If you marked "Yes" above, please indicate the nature and extent of the resources provided by the
national program for FY99 by filling in the matrix below. (Indicate whether they are involved by
marking Yor N; then use Y, N, or U (for unsure) to indicate the type of resources provided; fill in
the amount of the resource where you can estimate it. Use the example in the shaded area as
guidance.)
Resources Provided by National Program for FY 99
FTEs
Y.N.U
(ex.) Y
Amount
2 FTEs
Grant Funds
Y,N,U
N
Amount
Contract Funds
Y,N,U
U
Amount
Other
Y,N,U
Y
Specify
computers
25. Are you receiving resources for implementation assistance in FY99 from sources other than the
national program?
Yes No Unsure
If "Yes", please name these sources.
26. Please fill in the matrix below regarding assistance you provide to state governments, local
governments, and non-profit organizations involved in implementing your program for FY99.
(Indicate -whether they receive assistance from you by marking Y, N, or U (for Unsure); then use Y,
N, or U to indicate the type of resources provided; fill in the amount of the resource where you
can estimate it. Use the example as guidance.)
Entity
EXAMPLE
State Agencies
Local Agencies
Non-profit organizations
Receive Your
Assistance?
(Y,N,U)
Y
Resources You Provide, FY99
FTEs
Y.N.U
N
Amount
Grant Funds
Y.N.U
Y
Amount
$50,000
Other
Y.N.U
Y
Specify
Training
Materials
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APPENDIX B—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
26
Implementers' Survey (Sent to Regional Implementers of National Partnership Programs)
Partner Interactions
27. How important is each of the following in contacting potential partners? (Please rate each from 1 to
5 using the following scale: 1 = we don'(use this method; 2 = minimal importance; 3 = somewhat
important; 4 = quite important; 5 = most important. Leave blank if the region is not involved in
contacting potential partners.)
Advertising
Word of mouth
Compliance actions
Cold calls and networking
Outreach, e.g. seminars or Public Service Announcements (PSAs)
Leads from other partnership programs
Leads from other EPA programs
Leads from states
Trade associations
Other (please specify):
Additional Information
(Please give the following additional information. The Lexington Group may contact you for additional information
or to conduct an interview. Note that individual respondents will not be identified in our report to EPA. although we
will occasionally ascribe particular comments to the programs from which they come.)
Your name:
Your title:
Your phone number:
Your fax number:
THANK YOU!!
Please e-mail the completed survey as a Word Perfect attachment to survey@lexgrp.com or, if necessary,
fax it to 781-674-2851, attn: Richard Wells.
-------
-------
APPENDIX C
SELECTED SURVEY RESULTS
-------
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
28
Appendix C
Selected Survey Results
This appendix contains results to selected questions from the managers' survey (sent to managers
of national and regional partnership programs) and the implementers' survey (sent to regional
implementers of national programs). To protect the confidentiality of EPA staff, some questions
and responses were omitted from this compilation. For example, narrative responses may directly
or indirectly identify the respondent and have therefore been omitted. The full text of both surveys
is contained in the previous appendix.
-------
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
29
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
2. Is this a national or regional partnership program?
Count Percent
13 54.2% National
11 45.8% Regional
3. What is your role In the program?
Count Percent
14 58 3% Partnership Program Manager
8 33.3% Partnership Program Staff
4. Is there a specific statutory basis for your program?
bunt
10
11
1
2
Percent
41.7%
45.8%
4.2%
8.3%
Yes
No
Don't know
Blank
5. Do you have a defined mission statement?
Count Percent
16 66.7% Yes
5 20.8%
3 12.5%
No
Blank
8. Which of the following best describes how your program is structured within EPA?
Count Percent
5 20.8% Run entirely from EPA Headquarters
8 33.3% Run from Headquarters with support from some or all of regions
0 0.0% Run from the Regions, with Headquarters playing a coordinating role
6 25.0% Run entirely from one Region
6 25.0% Other
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
30
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
10. What outside support does your program rely on?
Count Percent
17 70.8% Consultants and contractors
12 50.0% Trade associations
11 45.8% State staff
9 37.5% Universities
15 62.5% Other
12. What, if any, do you find to be the major organizational/internal barriers to the Implementation of the program? (please
rate each from 1 to S using the following scale: 1 • not Important; 2 * minimal
importance; 3 • somewhat Important; 4 • quite important; S • most important)
Avg. Mode Count by Response
4-5 3 1-2
2.0
1Q
.8
I**
.1
2.1
2.6
3.8
3.8
1.7
1.4
2.8
1
*
1
4
1
2
4
5
5
1
1
3
2
2
7
11
11
2
0
3
7
/
3
3
6
5
2
2
10
A A
14
4C
13
m
IU
14
9
2
4
15
17
Poor communication/coordination between Headquarters
and the region
Poor coordination and communication among partnership
programs
1 iu li jtrnluvilu uji IJL fujuvrniiL »l»lb«!lMm AIM|/M» rtlkinrtii «!••
LBCK or clarity as to program oermrDon ano/or oojecoves
Excessive red tape
Lack of recognition as important within EPA
Insufficient resources (excluding number of staff)
Insufficient number of staff -The issue here is that it demands more
time than my dufes aHow
High turnover of program staff
Lack of staff skills in managing collaborative programs
Staff working on program iiiplementalion have too many other
I inniiiitih*^ •*•>!•
Total Count
15
18
19
19
19
19
19
20
19
19
20
4.0
Other
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
31
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
13. What do you consider the major organizational supports in the implementation of the program?
(please rate each from 1 to 5 using the following scale: 1 * not important; 2 « minimal importance; 3 «
somewhat important; 4 • quite important; 5 * most important)
Avg. Mode Count by Response
4-5 3 1-2
4.6
3.2
2.1
4.0
3.7
4.6
4.0
3.0
5
0
0
4
4
5
4
0
21
10
2
17
16
21
17
1
2
5
6
5
3
2
5
1
0
8
14
1
4
0
1
1
Flexibility and ability to innovate
Effective coordination among programs
Access to support from other partnership programs
Support and recognition from my management
Support and recognition from EPA management
Dedication and commitment of program staff
Clearly defined, measurable goals
Other
Total Count
23
23
22
23
23
23
23
3
16. What is the total FY99 budget for your program?
17. How many FTEs do you have assigned for FY99?
18. What is your contractor budget for FY99?
19. What were your FY97 and 98 budgets?
FY97:
FY96:
94 If vouf nraflmn is run ftmti MAadnuartAfft with ftssistai
fci« ii jvw |*iu]jifliii 19 IMM iiuvii i iMe»m^mimft» wiiii OTVWMI
Headquarters plays In funding regional assistance.
Count Percent
2 8.3% The Headquarters program provide!
Average
$1,025,266
2.8
$665,000
$826,697
Minimum
$3,000
0.05
$20.000
$3,000
Maximum
$13.400.000
20.0
$7.900.000
$10,200,000
$865,192 $3,000 $10,400,000
ice from regions, please indicate what role
5 participating regior
is with budgetary
resources ($
Count
15
20
10
15
16
0
0
0
and/or FTEs) for assisting with program implementation. These resources cover most or all
of the costs incurred by the regions.
8.3% The Headquarters program provides participating regions with limited budgetary resources ($
and/or FTEs) for assisting with program implementation. The regions, however, pick up most
of the cost of implementation assistance.
12.5% The Headquarters program does not provide participating regions with any sort of budgetary
resources. The regions pick up the full cost of implementation assistance.
0.0% This varies greatly from region to region.
0.0% Dontknow
0.0% Other \ v .-
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
32
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
22. if states assist in the implementation of your program, please Indicate how their assistance Is
funded.
Count Percent
6 25.0% States do not assist in program implementation.
1 4.2% Participating states are given grants lor assisting with program implementation. These
resources cover most or all of the costs incurred by the states.
2 8.3% Participating states are given small grants for assisting with program implementation. The
states themselves, however, picK up most of the cost of their assistance.
4 16.7% Participating states do not receive any grants for assisting with program implementation. They
pick up the full cost of implementation assistance.
1 4.2% This varies greatly from state to state.
0 0.0% Don't know
5 20.8% Other
23. How is your partnership program structured?
Count Percent
12 50.0% Partr«rssignafonTialMemorarxlumofUno^rstano1ng(oreqiiivalent)tojoin
1 4.2% Agreements between EPA and participants are created on an ad-hoc basis
4 16.7% We maintain a network of interested parties but do not have any formal partners
7 29.2% Other
24. How important Is each of the following in contacting potential partners? (please rate each from 1 to
S using the following scale: 1 - we dont use this method; 2 • minimal importance; 3 - somewhat
Important; 4 » quite important; 5 * most Important)
Avg. Mode Count fay Response
4-5 3 1-2
2.4
3.6
1.3
3.0
3.3
2.1
2.0
2.6
3.3
3.6
1
4
1
4
4
2
1
0
4
5
4
13
1
10
11
1
1
7
12
3
6
6
1
3
4
6
6
4
4
1
11
3
17
8
6
13
14
11
5
1
Advertising
Word of mouth
Compliance actions
Cold calls and networking
Outreach, e.g. seminars or Public Service Announcements
Leads from other partnership programs
14 Leads from other EPA programs
Leads from states
Trade associations
Other •
Total Count
21
22
19
21
21
20
21
22
21
5
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
33
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
25. Roughly speaking, what percentage of your budget is used for marketing and outreach?
Average: 20.4% Count by 16 Less than 25%
Response:
0% 3 Between 25% and 50%
Minimum:
Maximum:
100%
More than 50%
26. Does your program have a system (orextt strategy) for "graduating" partners who have
demonstrated superior performance and/or achieved the goals of the program?
Count
4
6
14
Percent
16.7%
25.0%
58.3%
Yes, we do have this sort of exit strategy
No, we do not have this sort of exit strategy, but we could potentially develop one
No; this sort of exit strategy does not make sense given our program structure
27. Does your program itself have an exit strategy? In other words, does your program have a
definitive end-point or set of goals that, when achieved, would Imply the closing of the program?
Count Percent
7 29.2% Yes, we do have this sort of exit strategy
5 20.8% No, we do not have this sort of exit strategy, but we could potentially develop one
11 45.8% No; this sort of exit strategy does not make sense given our program structure
28. How is contact maintained with Partners?
Count Percent
15 62.5% Designated EPA personnel maintain contact with groups of partners
10 41.7% Designated contractor employees maintain contact with groups of partners
19 79.2% As new developments occur, partners are infonmed by e-mail or other communications
10 41.7% Contact proceeds with partners on an ad-hoc basis
12 50.0% Partners submit periodic reports
8 33.3% Other
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
34
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
29. How many partners do you have, and how many other supporters, allies, and endorsers
(organizations that support or endorse the program but are not partners) do you have?
Category
a. Private
etc
npi
Average No. of
Partners
b. Public agencies or organizations
c Trade associations
d. Other non-governmental organizations
e. Universities
f. Foreign partners
g Other (please specify):
30. Of your partners In the private sector, approximately what percentage are small businesses?
176
18
5
8
4
1
0
Average No. of
Supporters, Allies,
or Endorsers
40
2
3
4
1
0
1
Average: 24.2%
Minimum: 0%
Maximum: 100%
Count by
Response:
15 Less than 25%
3 Between 25% and 50%
6 More than 50%
31. Does your program target a specific geographic area such as a particular state, a water- or airshed,
or a border area?
Count Percent
10 41.7% Yes
14 58.3% No
32. What sorts of stakeholders do you involve in your program?
Other government agencies
Industry associations
States
National and regional environmental organizations
Communities
Suppliers to target partners
Customers to target partners
Educational or research organizations
Supporters, Allies, or Endorsers
Other
k)unt
20
22
20
16
12
12
11
18
11
2
Percent
83.3%
91.7%
83.3%
66.7%
50.0%
50.0%
45.8%
75.0%
45.8%
8.3%
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
35
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
33. How helpful have you found participation from stakeholders to be in supporting and improving your
program?
Count
16
3
2
1
0
1
Percent
66.7%
12.5%
8.3%
4.2%
0.0%
4.2%
Extremely helpful
Very helpful
Somewhat helpful
Unhelpful
Very unhelpful; a hindrance
Our experience varies so much that it is impossible to generalize
34. Please fill in the following matrix regarding the types of interaction between your program and
other EPA, federal, and state programs and non-governmental organizations (NGOs):
Interaction and a.Other EPA
Number of Partnership
Responses: Programs
b.Other EPA
Programs
(non-partners
hip)
c.Programs
in Other
Federal
Agencies
d.State
Programs
e.NGOs
1. Coordinate
objectives
2.Share client
leads
10
^Coordinate
dient
participation
4, Ideas for
program design
12
36. The Office of Reinvention (OR) has recently been assigned the role of coordinating the efforts of
partnership programs. How have OR's efforts been useful to you?
Count Percent
6 25.0% Our program has benefited from OR's internal coordination and networking efforts
3 12.5% Our program has received potential partner leads through OR's efforts
2 8.3% Our program has benefited from OR's overall outreach activities (e.g. web site)
1 4.2% Other
15 62.5% None of the above options apply
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
36
Selected Results of Managers'Survey (Sent to Managers of National and Regional
Partnership Programs)
39. Who is responsible for evaluating the success of your program?
Count Percent
10 41.7% We have conducted an internal program evaluation
7 29.2% We are or will soon conduct an internal program evaluation
2 8.3% An EPA group outside of our program has, is, or will soon conduct an evaluation
of our program.
10 41.7% Other
41. if both your program and an external EPA group have, are, or win soon conduct an evaluation of your
program, are different criteria being used for these two evaluations?
Count Percent
2 8.3% Yes
5 20.6% No
17 70.8% Blank
42. Do you gather environmental and/or economic performance data from your partners?
Environmental:
Count Percent
19 79.2% Yes
4 16.7% NO
1 4.2% Blank
Economic:
Count Percent
12 50.0% Yes
11 45.8% No
1 4.2% Blank
43. If you collect these data, please Indicate how.
Count Percent
7 29.2% Partners submit an annual report They do this by using a template file we send them.
2 8.3% Partners submit an annual report They can do this using our Internet site.
8 33.3% Data are periodically collected by interviewing, written communication, or site visits
8 33.3% Other
45. If you collect environmental performance date, do you have a process for verifying these date?
Count Percent
11 45.8%
7 29.2%
6 25.0%
Yes
No
Blank
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
37
Selected Results of Managers' Survey (Sent to Managers of National and Regional
Partnership Programs)
46. Does your program address Government Performance and Results Act (GPRA) objectives and
sub-objectives?
Count Percent
11 45.8% Yes
3 12.5% No
8 33.3% Dontknow
2 8.3% Hank
47. Do you gather customer satisfaction data from your partners and stakeholders?
Partners:
Count Percent
12 50.0% Yes
12 50.0% No
Stakeholders
Count Percent
8 33.3% Yes
14 58.3% No
48. If you collect these data, please indicate how.
Count Percent
6 25.0% A survey is periodically sent to partners and/or stakeholders
0 0.0% BOO number
1 4.2% Comment cards
11 45.8% Direct feedback
4 16.7% Other
49. Roughly speaking, what percentage of your budget is used for conducting evaluation and soliciting
feedback from partners and other stakeholders?
Average:
Minimum:
Maximum:
5.5%
0.0%
75.0%
Count by
Response:
23 Less than 25%
0 Between 25% and 50%
1 More than 50%
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
38
Selected Results of Implementers' Survey (Sent, to Regional Implementers of National
Partnership Programs)
2. What is the number of national partnership programs that you personally help to implement in your
region?
Average:
Minimum:
Maximum:
1.7
0
5
Count by Response:
One program: 13
Two or more programs: 9
3. What percentage of your time do you spend on these partnership programs?
Average: 21.9%
Count by
Response:
11 Less than 25%
3 Between 25% and 50%
9 More than 50%
5. What is your role in this program?
Count Percent
13 54.2% Manager for regional implementation of a national partnership program
9 37.5% Staff for regional implementation of a national partnership program
2 6.3% Other
6. Do you nave a set of goals or an operating plan that describes your partnership program activities?
Count Percent
11 47.8% Yes
11 47.8% No
1 4.3% Blank
9. What is the title of the person to whom you report for partnership program activities? Is he or
she in EPA Headquarters or in the region?
Count Percent
•
8 34.8% Headquarters
13 56.5% Region
2 8.7% Blank
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
39
Selected Results of Implementers' Survey (Sent to Regional Implementers of National
Partnership Programs)
10. How many staff in your region, other than yourself, are Involved in implementing this program?
Average:
Minimum:
Maximum:
2.2
0
11
11. What, if any, do you find to be the major organizational/internal barriers to the Implementation of
the program? (please rate each from 1 to 5 using the following scale: 1» not important; 2 « minimal
importance; 3 * somewhat important; 4 - quite important; 6 • most important)
Avg.
2.4
2.2
2.0
2.5
2.5
2.9
3.6
3,1
1.8
2.0
4.2
Mode
1
1
1
1
2
2
4
2
1
1
4
Count by Response Total Co
4-5
4
5
3
7
4
7
14
8
2
2
15
3
7
2
4
3
4
5
5
3
2
5
3
1-2
11
14
15
12
12
10
3
8
17
13
3
Poor oommuntcation/coordinatjon between Headquarters and the
region
Poor coordination and communication among partnership programs
Lack of darity as to program definition and/or objectives
Lack of dear, quantitative performance measures
Excessive red tape
Lack of recognition as important within EPA
Insufficient resources (excluding number of staff)
Insufficient number of staff - The issue here is that it demands more
time than my duties allow
High turnover of program staff
Lack of staff skills in managing collaborative programs
Staff working on program implementation have too many other
22
21
22
22
20
22
22
19
21
20
21
4.2
commitments
Other
-------
APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
40
Selected Results of Implementers' Survey (Sent to Regional Implementers of National
Partnership Programs)
12. What do you consider the major organizational supports in the Implementation of the program?
(please rate each from 1 to 5 using the following scale: 1 * not important; 2 = minimal Importance; 3 >
somewhat important; 4 » quite important; 5 « most important)
Avg.
4.2
3.2
2.8
3.7
3.6
3.8
3.0
0.5
Mode
5
4
4
4
4
4
3
0
Count by Response
4-5
13
11
7
13
13
13
8
2
3
4
2
4
4
3
6
8
0
1-2
3
7
9
3
4
1
4
0
Flexibility and ability to innovate
Effective coordination among programs
Access to support from other partnership programs
Support and recognition from my management
Support and recognition from EPA management
Dedication and commitment of program staff
dearly defined, measurable goals
Other
Total Count
20
20
20
20
20
20
22
20
1$. The Office of Reinvention (OR) has recently been assigned the rote of coordinating the efforts of
partnership programs. How have OR's efforts been useful to you?
Count
4
5
1
14
4
Percent
17.4%
21.7%
4.3%
60.9%
17.4%
We have benefited from OR's internal coordination and networking efforts
We have benefitted from OR's overall outreach activities (e.g. Web site)
Other
I know very Irttte about OR's efforts
None of the above options apply
19. Please fill in the matrix below regarding whether other EPA programs, other federal agencies, state
or local agencies, or non-governmental organizations are involved in conducting the program.
Count by Response
Other EPA Programs
Other Federal Agencies
State Agencies
Local Agencies
Non-governmental Organizations
Yes
9
9
17
13
13
No
12
10
6
7
e
Blank
2
4
0
3
2
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
41
Selected Results of Implemented Survey (Sent to Regional Implementers of National
Partnership Programs)
21. How would you characterize where you spend your program time?
Count by Response
Average
26.3%
13.3%
21.5%
20.9%
10.0%
Less than 25%
13
17
13
14
20
Between 25%
and 50%
4
4
5
7
1
More than 50%
6
2
5
2
2
Promoting and marketing
Technical assistance to partners
Coordination with national program
Program management
Other
22. What outside support do you rely on for program implementation assistance?
Count Percent
9
6
10
7
3
39.1%
26.1%
43.5%
30.4%
13.0%
Consultants
Trade assoc
State staff
Universities
Other
23. Do you receive resources from the national program to conduct your regional program activities?
Count Percent
8 34.8% Yes, we receive resources from the national program
10 43.5% No, we do not receive resources from the national program
4 17.4% I am not sure
24. If you marked "Yes" above, please indicate the nature and extent of the resources provided by the
national program for FY99 by filling in the matrix below.
Resources Provided by National Program for FY 99
FTEs
Grant Funds
Contract Funds
Other
Yes
6
3
0
3
No
0
6
6
3'
Unsure
2
0
1
0
Blank
15
14
16
17
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
42
Selected Results of Implementers' Survey (Sent to Regional Implementers of National
Partnership Programs)
25. Are you receiving resources for implementation assistance in FY99 from sources other than the
national program?
Count
4
13
3
3
Percent
17.4%
56.5%
13.0%
13.0%
Yes
No
Unsure
Blank
26. Please fill in the matrix below regarding assistance you provide to <
i, local
governments, and non-profit organizations involved in implementing your program for FY99.
State Agencies
Receive Your Assistance?
FTEs
Grant Funds
Other
Local Agencies
Receive Your
FTEs
Grant Funds
Other
Non-profit organizations
Receive Your
FTEs
Grant Funds
Other
Yes No Unsure
Count Percent Count Percent Count Percent
10
0
4
s
Count
6
0
0
3
Count
6
0
1
3
76.9%
0.0%
44.4%
71.4%
Yes
Percent
46.2%
0.0%
0.0%
50.0%
Yes
Percent
46.2%
0.0%
11.1%
42.9%
3
10
4
2
Count
7
7
6
16.66
Count
7
7
5
1
23.1%
100.0%
44.4%
28.6%
No
Poroont
53.8%
100.0%
100.0%
16.7%
No
Pcrcsnt
53.8%
70.0%
55.6%
14.3%
0
0
1
0
0.0%
0.0%
11.1%
0.0%
Unsure
Count
0
0
0
0
Percent
0.0%
0.0%
0.0%
0.0%
Unsure
Count
0
0
0
0
Percent
0.0%
0.0%
0.0%
0.0%
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APPENDIX C—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 43
Selected Results of Implementers' Survey (Sent to Regional Implementers of National
Partnership Programs)
27. How important is each of the following in contacting potential partners? (Please rate each from 1 to 5
using the following scale: 1 • we dont use this method; 2 = minimal Importance; 3 = somewhat
important; 4 * quite important; 5 = most important Leave blank if the region is not involved In contacting
potential partners.)
Avg.
2.1
4.3
1.5
2.9
4.1
2.7
2.9
3.0
3.1
5.0
Mode
1
5
1
0
0
0
0
2
3
5
Count by Response
4-5
3
9
0
6
10
5
5
5
5
2
3
2
3
2
1
4
2
3
3
5
0
1-2
9
2
11
7
0
7
6
6
4
0
Advertising
Word of mouth
Compliance actions
Cold calls and networking
Outreach, e.g. seminars or Public Service
Announcements (PSAs)
Leads from other partnership programs
Leads from other EPA programs
Leads from states
Trade associations
Other
Total Count
14
14
13
14
14
14
14
14
14
2
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-------
APPENDIX D
EPA STAFF INTERVIEWED
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APPENDIX D—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
45
Appendix D
EPA Staff Interviewed
Headquarters
Shannon Alford and John Thomas,
Transportation Partners
Mark Badalamente, OA
Jay Benforado, OP
Rob Brenner, OAR
Karyn Finkle, Climate Wise
John Flowers, Water Alliances for Voluntary
Efficiency
Terry Grogan, WasteWi$e
Penny Hansen, Environmental Technology
Verification
Kathleen Hogan, OAR
David Kling, OPPTS
Robert Lee, OPPTS
Jean Lupinacci, Energy Star Buildings/Green
Lights Program
Mark Luttner, Budget Office
Ellie McCann, OPPTS
Susan McLaughlin, Environmental
Accounting
Rebecca Nachtrieb, OPR
Judy Nelson, OPPTS
David Sarokin, OPPTS/Chemical Right to
Know
Deborah Thomas, Environmental Leadership
Program
Harry Wells, Mike Farrar, and Jim Boland,
Pesticide Environmental Stewardship
Program
Headquarters, at PPCC Meeting
Mary Dominiak, Green Chemistry
Jerry Filbin, CBEP
Dan Fiorino, OP
Kathy Hart, DfE
Kathleen Hogan, Energy Star
Region 1
Tom d'Avanzo
Christine Bonica
George Frantz
Cynthia Green
Norm Williard
Region 3
Jeff Burke, PPCC Representative
Richard Daly, Business Assistance Center
Lisa Donahue, Pesticide Environmental
Stewardship Program
Fran Dougherty, Indoor Air
Ray George, Southwestern PA Voluntary
Initiative for Pollution Prevention
Kelly Mecum, Business for the Bay
Tad Radzinski, Waste Min & Strategic Goals
for Metal Finishers
Bruce Smith, Global Warming (Energy Star
Buildings)
Tom Stolle, Brownfields
Beth Termini, Project XL
Paul Wentworth, Transportation Partners
Region 6
David Bond, Project XL coordinator and
PPCC participant
Adele Cardenas, Project XL
Bill Gallagher, Streamlined Delisting
Program
Brad Lamb
Rick McMillin, Region 6 Lab
Tom Reich, Environmental Excellence
Awards Program
Craig Weeks, CSI
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APPENDIX D—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
46
Cindy Wolf and William Rhea, Community-
Based Environmental Protection Program
Region 7
Mary Carter, Branch Chief, P2 and Solid
Waste Branch
Bob Dye, OAR
David Flora, WasteWiSe
Marc Matthews, P2 and Solid Waste Branch
Chet McLaughlin, Energy STAR Programs;
PPCC Representative
Bill Rice, RAC member; RAC advisor to
PPCC; Deputy RA
Richard Sumpter, NEPPs
Glen Yager and Jamie Green, Pesticide
Environmental Stewardship Program
-------
APPENDIX E
LITERATURE REVIEW
-------
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
48
Appendix E
Literature Review
I. INTRODUCTION
This document is a review of selected studies on the management of the U.S. EPA's partnership
programs. Most of the documents reviewed are the product of research efforts that entailed
extensive interviews of both EPA staff and program partners. Through these interviews,
researchers gained valuable insight as to what management issues hinder, and what enables,
program success. On an individual basis, the findings from each of these studies are hardly
conclusive, given the limited range of programs, issues, and constituencies any given study can
evaluate. However, the findings in aggregate provide a sound basis for beginning to review the
way partnership programs are managed at EPA.
We want to emphasize that this review does not investigate program success. Several of the
sources reviewed include the authors' viewpoint on the effectiveness of voluntary programs, but
none of them provide any sort of comprehensive evaluation. We are approaching this review from
the spirit of most of these authors: that EPA's partnership programs represent an exciting new
complement to traditional approaches to environmental protection, and that opportunities for
improvement exist.
In conducting this review, we attempted to analyze research findings from industry, government,
and academia to provide the most comprehensive analysis possible. Specifically, we reviewed:
• Two industry studies including a Global Environmental Management Initiative report
(by Terry Davies and Jan Mazurek of Resources for the Future) and a Conference
Board Townley Global Management Center for the Environment, Health and Safety
special report (by Meredith Whiting and John D. Whiting).
• A government study completed by the U.S. General Accounting Office.
• Two student academic studies including research projects conducted by Deborah Boger
and Christine Stackpole from Harvard's John F. Kennedy School of Government and
Suganthi Simon from the Yale School of Forestry and Environmental Studies.
• An EPA catalogue, an older Global Environmental Management Initiative (GEMI)
catalogue, and an EPA-commissioned characterization of partnership programs.
An annotated bibliography that contains exact citations for these documents is attached to this
report. We did not review any documents from the non-governmental organization sector, as our
literature search suggested that nothing has been written on EPA partnership programs by NGOs.
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
49
We found that most of the research on partnership programs analyzes program results with little
or no focus on opportunities for the Office of Policy and Reinvention (OPR) to help improve
EPA's management of them. Consequently, this review complements the limited research on
opportunities for coordination with research findings on specific programs.
Our review contains the following elements:
• A generalized characterization of different management components of EPA partnership
programs (Section II);
• Discussion of management issues of concern identified by the studies (Section HI);
• Identification of opportunities suggested for addressing those concerns (Section IV);
and
• A potential framework for analyzing management issues (Section V).
II. GENERAL MANAGEMENT CHARACTERISTICS OF PARTNERSHIP PROGRAMS
Perhaps the most notable characteristic among all of EPA's Partnership programs is their
diversity. To date, between 26 and 28 partnership programs (depending on how you define
"partnership" program) are housed in various offices a|t the EPA headquarters. An additional 20
or more programs are administered out of regional offices, sometimes in conjunction with state
environmental protection offices. Partnership programs vary in their history, goals and objectives,
budgets, level of commitment by EPA staff, type and number of partners, and stakeholder
constituencies.
Nevertheless, there is uniformity in this diversity. Most EPA partnership programs require
stakeholder participation in reaching agreements, seek to achieve multiple goals, support a variety
of EPA strategic objectives, and provide multiple incentives to participants. Boger and Stackpole
(199S) highlight additional similarities among headquarters-based programs and among region-
based programs as follows:
Similarities Among Headquarters-Based Partnership Programs
• All of the programs (with the exception of Water Alliances for Voluntary Efficiency
(WAVE)) state pollution prevention as a main objective.
• A main objective of 15 of the 28 headquarters-based programs is the reduction of
greenhouse gas emissions.
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
50
• Nearly all of the programs offer public recognition, economic benefits, and technical
assistance as incentives.
• Companies and trade associations are most commonly targeted as partners.
Similarities Among Region-Based Partnership Programs
• A major incentive to participate in many regional-level programs, for example the Bay
Area Green Business Program, is industry's desire for compliance assistance.
• A variety of constituencies (i.e., beyond just the business community) are targeted
somewhat equally to participate in programs.
HI. MANAGEMENT ISSUES OF INTEREST
The reports identified a number of successes achieved by the partnership programs analyzed and
also pointed to some concerns with how many of the programs are organized and managed.
Evaluating the successes achieved is outside the scope of this project, but the management issues
of concern identified are central to it. We therefore concentrate on these issues, most of which fall
into one or more of the following seven broad categories.
* Definition and Goals of Partnership Programs- Studies identified problems associated
with confusion over the definition of both the general categorization of "partnership
program" and specific program goals.
• Program Incentives- Studies raised concerns over the ineffectiveness of some program
incentives.
• Procedural Burden- Studies noted that partnership programs can be unnecessarily
burdensome due to excessive information requirements, failure to facilitate information
sharing, and inflexibility.
• Stakeholder Participation- Studies noted that partnership program stakeholders have
great appreciation for EPA's dedication to facilitating better communication between
traditionally adversarial parties. Nevertheless, some of the studies cited mistrust
between stakeholders and ineffective or ill-defined procedures for coordinating
stakeholder participation as potential impairments to program success, particularly with
respect to reaching consensus. This concern was noted specifically for XL and CSI
(which were reviewed more frequently than other partnership programs).
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
5!
• Performance Measurement- The lack of or incomplete nature of performance
measures, as well as the lack of procedural mechanisms for evaluating performance,
were identified as major barriers to program advancement. In addition, some studies
pointed to past inappropriate performance evaluations of specific partnership programs,
such as 33/50.
• EPA Internal Management and Organizational Culture- According to the studies,
obstacles to program success caused by EPA's management of the partnership
programs include poor coordination and outreach of programs, high turnover of and ill-
qualified partnership program staff, and poor systems for managing problems as they
arise. Studies also noted a general cultural preference for regulatory programs among
EPA staff accompanied by a lack of agency staff "buy-in" to the programs. The lack of
statutory base for voluntary initiatives, lack of management support for programs,
inadequate provision of staff and financial resources, and failure to include partnership
program performance in staff performance evaluations were identified as systematically
maintaining cultural barriers.
• Statutory Restrictions- Studies noted that incentives to participate in partnership
programs are often inadequate in comparison to the burden of the existing, rigid
regulatory structure. In addition, because the partnership programs offer little or no
reprieve from the existing statutes, the programmatic opportunities for achieving
environmental benefits at lower cost may be limited.
Of these seven categories, concerns over statutory restrictions, EPA's internal management and
culture, and performance measurement were most commonly mentioned and vigorously
emphasized. Specific issues within the remaining four general categories also persisted throughout
the literature. The following matrix highlights the categories of management issues and provides
more detailed information about specific concerns within each of these categories. It is important
to note that while some of the issues presented have been identified in only one or two of the
reviewed documents, given minimal overlap in the scope of research among the documents
reviewed, this information may be quite valuable.
Ill.i. Matrix of Partnership Program Management Issues
Table 1 shows which studies raise each of the management issues, as described above. Studies
that describe the partnership programs but do not offer any analysis are not included in this
matrix.
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
52
Table 1 - Management Issues Raised By Studies
MANAGEMENT ISSUE
Definition and Number of Programs
Ill-defined programs lead to confusion among EPA staff
ill-defined programs lead to confusion for external
constituencies
Too many programs "with overlapping and ill-defined
objectives make program selection confusing and
burdensome for potential partners
Program goals are poorly defined
Program Incentives
The significance of public recognition (a common program
incentive) is unclear to customers (program participants)
Programs rarely result in cost savings
Incentives are generally unsubstantial
Incentives are not tailored to target participant needs
Procedural Burden
Failure to provide support of partnership networks working
on similar issues to partners
Programs are inflexible and complex
Information requirements from partners are burdensome
Stakeholder Participation (note focus on XL, CSI)
Mistrust and competing interests between EPA, industry,
and environmental organizations hinders the stakeholder
participation process
Lack of or ineffective procedures for addressing stakeholder
concerns
Standard for consensus is excessive, leading to progress
impairment and frequent impasse
NGOs lack resources to effectively participate in process of
reaching consensus
Lack of uniform definition (across programs) of consensus
leads to confusion
REFERENCE
Whiting &
Whiting
X
Simon
Boger&
Stackpole
X
X
X
X
X
Davies &
Mazurek
U.S.
GAO
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
53
MANAGEMENT ISSUE
Performance Measurement
Few criteria developed for assessing program performance
Failure to measure customer (participant) and employee
satisfaction
Incorrect program evaluation
No systematic process for evaluation by either EPA or
partners
EPA Culture and Internal Management
Cultural barriers within EPA inhibit communication,
prioritization of programs, and agency "buy-in"
Failure to hold EPA employees accountable for their
performance in partnership programs limits employee
dedication
Lack of management support for lower level staff and
program advancement
Poor program coordination and outreach leads to confusion
and overlap
Limited financial and staff resources to coordinate
programs among constituencies and to administer them at
the regional level
Varied approaches to management across programs and
offices implementing the same programs
Undervaluation of partnership programs by non-partnership
program staff
High turnover rate, inadequate knowledge of, and shortage
of program staff
Lack of management structure and formalized
administrative procedures for approval of project proposals
and problem resolution
Statutory Restrictions
Lack of statutory basis for programs
Rigidity and demands of existing regulatory structure limits
program success
Failure to provide legal shelters to partners diminishes
incentive to participate
REFERENCE
Wbiting &
Whiting
X
X
Simon
X
X
X
X
X
X
X
X
X
Boger &
SUickpole
X
Davits &
Mazurek
X
X
U.S.
GAO
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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APPENDIX E—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
54
IV. RECOMMENDATIONS FOR ADDRESSING ISSUES OF CONCERN
This section summarizes the recommendations made in the studies reviewed for addressing each
of the seven management issues of concern presented in Section III.
IV.i. Recommendations for Clarifying Program Definition
The issue of program definition has three main concerns, according to the studies that address the
issue. First, there are no established criteria for what makes a "partnership" program. Second,
some of the partnership programs are ill-defined, with program goals and priorities not having
been set in some cases. In other instances, while goals and priorities have been set, they are not
effectively conveyed to EPA staffer program partners. The studies note that confusion over
program definition has sometimes frustrated staff and outside participants and led to difficulties in
determining program success. Third, some programs have overlapping objectives, which can leave
potential partners feeling confused by multiple program options and overburdened by multiple
requests for program participation.
Davies and Mazurek (1996) suggest that advanced planning, which defines (among other things)
program goals, is paramount to the future survival of EPA's partnership programs. Once program
goals have been identified, additional key steps include determining what actors will govern the
accomplishment of those goals and what incentives will be most enticing to those actors (as
discussed in Section IV.ii).
In general, researchers suggested that clearly defining partnership programs is a solid first step
toward alleviating confusion both internally and externally, identifying redundancies, and better
conveying responsibilities to partnering organizations. (Boger and Stackpole (1998) actually detail
what the definition of "partnership" should be). In so doing, initiatives that may not currently be
considered partnership programs may be classified as such and others that are considered
partnership programs and should not be would be reclassified.
Once the definition of a partnership program is clear, U.S. GAO (1994) argues, priority objectives
and programs should be identified, in order to ensure cost-effectiveness in administering
partnership programs. This will also help to alleviate the problem of limited resources for
operating programs as identified in Section TV.vi. A cost-benefit analysis tool of some sort would
be instructive in helping to measure and compare cost-efficiencies of different programs (Ibid and
Boger and Stackpole, 1998).
IV.ii. Opportunities for Providing Greater Incentives
Several of the authors scrutinized closely the incentives offered by partnership programs to their
targeted customers. Selecting and marketing incentives is a management action of highest concern
to EPA program managers because it determines what rewards a participant can expect.
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While most of EPA's partnership programs claim to provide multiple incentives, there is
speculation over the importance of the incentives. The Davies and Mazurek study focuses largely
on the issue of incentives. The authors found that programs rarely result in cost savings and that
other benefits are relatively unsubstantial. There is sdme evidence to suggest that the common
utilization of the public recognition incentive is less effective than it could be due to lack of clarity
in customers' minds regarding the significance of EPA recognition (Boger and Stackpole, 1998).
Boger and Stackpole also suggest that the development of uniform standards for public
recognition would better inform customers.
Davies and Mazurek (1996) are less optimistic about concrete opportunities to remedy
shortcomings in partnership program incentives for programs that target business communities,
largely due to the statutory limitations on partnership; programs and the huge diversity among
businesses targeted for the same programs. Within the limitations of the current regulatory
structure, the authors view changes that address diversity among businesses as providing some of
the most significant opportunities for program improvement. They argue that because of the
diversity of businesses, no single incentive appeals to all. Public recognition, for instance, is a
much stronger driver for firms that sell directly to the public. Davies and Mazurek believe that
incentive structures tailored to better meet the diversity of business needs are likely to achieve
greater success.
The authors argue that in determining the degree to which the incentive is likely to be effective,
EPA must answer the question "how much" of the incentive is required for firms to want to
participate. The likelihood that the answer to this question will change over time in response to
changes in political and economic climates, competing investment options, and firm leadership is
significant, making this task particularly daunting, but nevertheless crucial (Ibid).
IV.iii. Opportunities for Alleviating Procedural Burden
The studies suggest that many of the procedural burdens to program success boil down to
program inflexibility and complexity. While some of the complexities are linked to statutory
requirements, other complexities arise when programs are administered and must be approved
through multiple offices or by diverse constituencies. Another major concern among partners is
that information requirements are extremely burdensome, sometimes to the extent that potential
participants choose not to engage in the program.
Davies and Mazurek argue that relatively simple programs that have few requirements and mirror
existing EH&S programs have been more effective than more complex program models. Whether
or not to rely on this information in guiding future program developments will of course depend
on a number of additional management factors, particularly OPR's approach to statutory
limitations and stakeholder participation. However, there are opportunities for answering a call
for more flexibility and simplicity with better program management, independent of larger
management considerations. Several such opportunities are touched on in Section IV.vi.
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IV.iv. Recommendations for Facilitating Effective Stakeholder Participation
Perhaps the most consistent finding with respect to the issue of stakeholder participation is that
many of the partnership program participants have great appreciation for EPA's dedication to
facilitating better communication between traditionally adversarial parties. For many, an
opportunity to contribute to the alleviation of the traditional mistrust and sense of competing
interests between constituencies is the most attractive incentive for participation. Whiting and
Whiting (1998), for example, quote Northrop Grumman's corporate environmental director as
justifying his company's investment in the Region IX MERIT partnership program on the grounds
that "Open relationships [between Northrop Grumman and the regulatory community and public]
have been formed."
That said, some of the flagship partnership programs — especially Project XL and CSI, which the
studies analyze most heavily — have experienced great difficulties in achieving stakeholder
consensus because of the following factors:
• The lack of a clear definition of what is required to meet a consensus;
• General mistrust between industry, EPA, and environmental groups; and
• A lack of or ineffective procedures for meeting stakeholder needs.
There have also been claims by NGOs that they are unable to actively participate in the
consensus-reaching process due to inadequate resources to analyze technical information.
Project XL, while still experiencing some difficulties with stakeholder issues, has effectively
addressed many of those mentioned above. For example, XL does not require 100 percent
agreement in achieving consensus, as several other partnership programs do (Simon and U.S.
GAO). XL has also effectively addressed the problem of limited technical resources of NGOs by
providing technical assistance grants to enhance their level of participation (Ibid). In addition,
some regional offices have, by reorganizing their staff around multi-media issue management,
provided more institutionalized opportunities for reaching consensus (Boger and Stackpole,
1998).
Despite general optimism over Agency success in identifying and addressing some of the concerns
associated with the stakeholder participation process, Davies and Mazurek (1996) found that
programs relying on cooperation and voluntary actions for their success do not fare well due to
mistrust and paranoia among parties. They hold that there is a fundamental conflict between
industry desire for flexibility and the environmental community's desire for certainty and
enforceability, which is not easily overcome. The authors go on to argue that problems in reaching
consensus and other factors inhibiting program success are largely symptoms of a need for
statutory overhaul (to be discussed Section IV.vii). Within the current regulatory system, they
suggest that the inhibitory nature of the Federal Advisory Committee Act process used at the
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Federal level in managing stakeholder involvement renders partnership programs better conducted
at the state or regional level. Whiting and Whiting (1998) provide some evidence to suggest that,
in fact, region- and state-level programs are more effective. However, they suggest that the force
behind this success is the greater ease of collaborating when partners are in closer geographic
proximity.
IV.v. Opportunities for Improving Performance Measurement
Performance measurement was commonly cited as one of the weakest areas of partnership
program management. In most cases, few or no criteria have been developed for measuring
program performance and programs often lack systematic processes for evaluation. While both
the U.S. GAO (1997) and Davies and Mazurek (1996) acknowledge that in many cases it is too
early to do full program evaluations given the newness of most partnership programs, they also
note the importance of developing metrics and tracking systems early on in the program
development process.
Despite EPA's recent advances in developing uniform standards for performance measurement,
the weaknesses in this area continue to be highlighted as an area in crucial need of management
attention. Boger and Stackpole (1998) note that employee and customer satisfaction is an
important metric that has been omitted from the new EPA performance measurement standards;
Whiting and Whiting (1998) highlight the need for EPA to have a clear idea of what to measure
and why before institutionalizing performance evaluation; and Davies and Mazurek (1996)
emphasize the need to avoid stating evaluative measures in end-of-pipe terms in order to promote
the development of innovative proposals and to attract participants. EPA's 33/50 program
provides one example of where evaluation (although ultimately controversial) was built into
program design and linked directly to clear program goals (Davies and Mazurek, 1996).
rv.vi. Recommendations for Addressing EPA Cultural Barriers and Internal Management
Issues
Concerns over EPA cultural barriers and the internal management of partnership programs are the
most frequently noted of all the management issues. Some research suggests that EPA staff and
external parties are excited about the opportunity for addressing these issues through centralized
coordination by OPR (Boger and Stackpole, 1998 and U.S. GAO, 1997). In addition, several
parties point to recent success in overcoming organizational barriers at the regional level.
Many of the organizational barriers to partnership program success are viewed as stemming from
the culture of EPA. The media-specific focus of EPA's statutory authority and its tendency to act
on this authority through a command-and-control style of regulation have led to ingrained
tendencies to place secondary emphasis on voluntary approaches to environmental protection.
Another oft-cited barrier is the failure in most offices to hold EPA staff accountable for their
performance on partnership program projects (Simon, 1998 and U.S. GAO, 1997). These two
factors have led to a sense among partnership program staff of undervaluation by their colleagues,
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creating low morale. An additional cultural issue that is seen as inhibiting Agency "buy-in" is the
non-traditional interdivisional and interoffice communication required to operate multi-media
voluntary programs. This cultural barrier to communication has led to poor Agency coordination
of and outreach for partnership programs, as previously discussed in Section IV.i.
Concerns with respect to a lack of management support for lower level staff, limited financial and
staffing resources, and the lack of management structures that define at what level problems
should be resolved are likely products of the aforementioned cultural barriers, as well as the
newness of the programs. High turnover rate, inadequate knowledge of, and shortage of program
staff may also be products of these cultural inhibitions.
Both Whiting and Whiting (1998) and Simon (1998) suggest that a remedy to many of these
problems is to provide a champion within each partnership office to carry the program vision,
secure resources and long-term commitment, and provide management support for better
integration. The U.S. GAO (1997) points to success achieved by specific regional initiatives that
have established agency champions. The U.S. GAO report also highlights regional initiatives that
have achieved greater participant and staff satisfaction through the establishment of review and
reward systems for evaluating employee performance on partnership projects, dedicating a
comparatively greater percent of resources to partnership initiatives, and developing cross-
divisional and cross-media project teams.
On the national level, the Agency has assigned senior program managers to the Reinvention
Action Council to expedite the problem solving process. While this move has proven effective in
providing more timely responses to partner concerns, the U.S. GAO (1997) suggests that the
permanent assignment of senior management to trouble-shooting duty is not a sustainable solution
to the larger problem of a lack of an effective management structure.
In summary, the reports reviewed suggest that OPR and specific program offices face a major
task in overcoming the institutional barriers to progress. Yet, regional success stories suggest that
with some structural reorganization and program championship, real progress can be made.
Finally, it is important to note that cultural change in any environment is rarely a speedy process
and requires a large degree of patience.
IV.vii. Relationship of Partnership Programs to EPA's Statutory Structure
Boger and Stackpole (1998) suggest that EPA staff and external partnership constituents'
perceptions of the relationship between partnership programs and the statutory structure are
varied and unclear. This issue largely stems from the problem of program definition discussed in
Section IV.i. Much of the research reviewed here suggests, however, that regardless of how this
relationship is defined, the success of partnership programs will always be severely limited by the
current statutory framework. In fact, several researchers find that the current statutory framework
is the most significant limiting factor in determining the achievement frontier of EPA's partnership
programs.
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This sense of restriction stems from the rigidity of regulations that have been developed to
implement EPA statutes, a cultural bias toward regulatory programs, arid competition for scarce
resources between partnership and command-and-control programs (U.S. GAO, 1997). Given this
framework for operation, there is a sense among many stakeholders that partnership programs
will always struggle to survive. Davies and Mazurek (1996) say that partnership programs are and
will always be "peripheral" to society and industry (in the sense that they make no significant
contribution to the improvement of environmental conditions or cost reductions) because of the
limited support provided by the current statutory framework.
Given the limited control EPA exercises over the nature of its statutory mandates, Davies and
Mazurek (1996), in their report prepared for GEMI, assert that "[significant regulatory relief and
consequential financial incentives may only be able to come from Congress or from the state
governments." They go on to suggest that voluntary programs are simply a band-aid to a larger
problem of statutory ineffectiveness and that there is no "short-cut" around legislative overhaul in
achieving superior environmental performance at a reduced cost.
Many staff within EPA believe that mechanisms within the current statutory framework can
provide the necessary flexibility to achieve greater efficiency through voluntary efforts (U.S.
GAO, 1997 and Boger and Stackpole, 1996). Specifically, the EPA claims to be able to
effectively deal with potential regulatory constraints through "site-specific rulemaldngs" (U.S.
GAO, 1997). The U.S. GAO (1997) responds negatively to such a claim because site-specific
rule-makings must go through a rule-making process. Given that the rule-making process
commonly takes years to complete, this mechanism can hardly be viewed as increasing the
efficiency of partnership programs (Ibid).
V. Framework for Analyzing Management Issues
Boger and Stackpole (1998) provide a comprehensive characterization of current partnership
programs based on four main features including: goals, partners, incentives, and partnership
requirements. They also discuss suggestions for other means of characterization and comparison
made by EPA staff including: market transforming and non-market transforming programs;
multimedia and single media programs; regulated industry as partner and non-regulated entity as
partner programs; heavily interactive and less interactive programs; and programs with well-
defined and less-defined goals.
These parameters provide an exceedingly useful basis for comparing different partnership
programs. Boger and Stackpole (1998) and Cadmus's draft characterization report (1998)
provide tables and matrices that compare the programs based on these and other parameters.
Their characterization work serves as one foundation for our management review because it
provides a comprehensive snapshot of EPA's current partnership programs. The studies reviewed
most extensively in this report go one step further and identify a range of issues that impact how
well these programs perform (Section III) - and, in some cases, suggest: improvements EPA can
make in addressing these issues.
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All of the issues we identified in Section III are "management" issues, but their scope varies. For
example, it is important that the procedural burden on partners be reduced as much as possible for
a given program. This is a management issue that can be addressed at the program level. But it is
equally important that different partnership programs complement each other rather than compete
and that partnership programs as a whole have an effective and recognized role within EPA's
overall, statute-driven approach to environmental management. These are management issues that
must be addressed at higher levels than that of the individual program.
Instead of focusing primarily on a strategy for comparing one partnership program to another, we
instead want to propose that our future analyses be based in part on the following three levels of
management issues:
• Program-specific issues, such as procedural burden and performance measurement. All
management issues that are ultimately the responsibility of the program manager fall
into this category.
• Issues of coordination among the programs, which include the potential for
overlapping goals (which can lead to confusion or even competing programs) and the
opportunity to consolidate or standardize certain support functions. OPR is already
strengthening its role at this level.
• Role of partnership programs as a group within EPA's portfolio. Issues of
statutory restriction and the overall definition of and support for partnership programs
fall into this category. These are issues that are critical to the partnership programs but
cannot be resolved by them or even by OPR (though OPR can certainly play a role).
Of course, these levels are related. It is important to have evaluations of specific programs
support the larger role of partnership programs, for example. Nevertheless, we believe that these
three levels provide a clear framework for understanding most of the management issues raised in
the studies reviewed for this report and for focusing our upcoming data collection activities and
analysis.
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Annotated Bibliography
Boger, Deborah and Christine Stackpole. 1998. Opportunities to Strategically Manage the
U.S. Environmental Protection Agency's Partnership^ Programs. Report prepared for U.S.
EPA, OR
This report evaluates and seeks to identify opportunities for the Office of Reinvention to utilize
their new coordination role to more effectively and strategically manage the U.S. EPA's
partnership programs. The authors liken the management of these voluntary initiatives to
managing a portfolio of financial investments, with a focus on program performance,
characteristics, and opportunities for improvement. The report identifies four dimensions for
characterizing and comparing EPA's 28 partnership programs including goals, partners,
incentives, and partnership requirements. Three options for management improvement of both
service and control functions are presented, followed by an endorsement of one of the three
approaches. The recommended approach entails the U.S. EPA's Office of Reinvention take a
"limited control" approach to coordinating partnership programs across offices, with an emphasis
on providing control, rather than service functions.
The Cadmus Group. 1998. Characterization of Selected EPA Partnership Programs. Draft
report prepared for U.S. EPA, OAR
As part of the initial efforts by the U.S. EPA's Office of Reinvention (OR) and the Partnership
Programs Coordinating Committee (PPCC) to examine the Agency's partnership programs, this
report seeks to identify the different design characteristics of 28 such programs. The report
categorizes programs by objectives, sector relationships, EPA strategic goals, and incentives.
Davies, Terry and Jan Mazurek. 1996. Industry Incentives for Environmental Improvement:
Evaluation of U.S. Federal Initiatives. Report prepared for Global Environmental
Management Initiative. Washington, DC: GEMI.
This report is the product of one of a series of three studies commissioned by the Global
Environmental Management Initiative (GEMI) to investigate areas of interest for environment,
health, and safety managers. An executive summary of all three documents prefaces the body of
this document that identifies the importance of accounting for stakeholder needs, performance
objectives, procedural requirements, and effective incentives in future program development.
Specifically, the report evaluates five federal programs seeking to achieve environmental results
through alternative initiatives including: 33/50, OSHA Star, Common Sense Initiative (CSI),
Project XL, and SO2 emissions trading under the Clean Air Act (CAA). The authors find that four
of the five programs (S02 trading being the exception) are "peripheral" to business and society,
noting that XL and CSI are likely too new to evaluate. The report further documents the need to
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take into account the significant diversity of characteristics in the business community, limits of
the current statutory structure, pervasive mistrust among stakeholders, and problems with EPA
management in further developing these programs.
Global Environmental Management Initiative. 1994. GEMI Reference to EPA Voluntary
Programs. Washington, DC: GEMI.
An early attempt to catalog partnership efforts by the U.S. EPA, this report identifies key
characteristics of 14 programs (the totality of partnership programs in 1994). GEMI identifies
statutory barriers to participation in partnership programs and examines the importance of
designing partnership initiatives in a manner that is easily integrated with existing management
systems. The report broadly identifies benefits of partnership programs to include cost savings,
public recognition, and rewards over the long-term from innovation efforts.
Simon, Suganthi. February 18,1999. Personal communication.
A master's degree student at the Yale School of Forestry and Environmental Studies, Ms. Simon
recently conducted a management study for the U.S. EPA's Project XL with the HADCO
Corporation-Project XL partnership as the centerpiece of her investigation. This conversation
highlighted many of her findings.
U.S. Environmental Protection Agency, OA. 1998. A Catalogue of the Agency's Partnership
Programs. Report EPA100-B-97-003.
An agency guide to its voluntary partnership programs, this document provides information on the
history, goals, participants, benefits of participation, and results of all headquarters, regional, and
state-level initiatives. The most comprehensive cataloging of the EPA's partnership programs to
date, this document provides one stop information shopping for potential partners and other
interested parties.
U.S. General Accounting Office. 1997. Environmental Protection. Challenges Facing EPA *s
Efforts to Reinvent Environmental Regulation. Report to Congressional Requesters
GAO/RCED-97-155. Washington, DC: U.S. GAO.
By request of several congressional committees, this report examines the U.S. EPA's reinvention
initiatives, highlighting key management issues for the Office of Reinvention (OR) in moving
towards greater program success. The report evaluates how the EPA, specifically OPR might
better manage its reinvention efforts to provide flexible, cost-effective environmental protection.
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A great deal of emphasis is placed on the issues of performance measurement, stakeholder
participation, and organizational barriers to success in achieving these management objectives.
Whiting, Meredith and John D. Whiting. 199& Innovative Public-Private Partnerships:
Environmental Initiatives. The Conference Board Townley Global Management Center for
Environment, Health and Safety Special Report 1208-98-RR. New York: The Conference
Board.
Acknowledging that while it is too early to determine the degree of success achieved by the
growing number of environmentally oriented public-private collaborations, this report examines
the experiences of participants from both the pubb'c and private sectors in some of these
programs. The authors discuss lessons learned from a variety of federal, state, and regional level
initiatives to move beyond command-and-control regulation toward a more cooperative and
efficient system of environmental oversight. Specifically, the accomplishments and participant
reaction to efforts by the President's Council for Sustainability, the National Environmental
Performance Partnership System (NEPPS), the U.S. EPA's Project XL and Common Sense
Initiative, and several state and regional programs are reviewed. The report closes with
recommendations for developing more successful partnership programs given participant
experience.
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APPENDIX F
ANALYSIS OF NON-EPA PARTNERSHIP PROGRAMS
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Appendix F
Analysis of Non-EPA Partnership Programs
I. INTRODUCTION
This document is an analysis of select voluntary and partnership programs initiated by U.S. federal
agencies, the private sector, state departments of environmental protection, and in foreign nations
around the world. Four U.S. federal agency initiatives and two private sector initiatives are
examined in significant detail, while the analysis of state government programs and a number of
international efforts is limited to review of aggregated evaluations. We place special emphasis on
analyzing climate change initiatives to complement the large number of EPA partnership programs
with this environmental focus. Specifically, we reviewed:
Federal Agency Initiatives
• The Occupational Safety and Health Administration's (OSHA) three primary voluntary
and partnership programs: the Voluntary Partnership Program (VPP), the Consultation
Program (CP), and the Strategic Partnership Program (SPP). Our analysis is principally
derived from personal communication with VPP Director, Cathy Oliver and former
OSHA consultant, Carol Vira, with additional information obtained from multiple
occupational health periodicals.
• The Department of Energy's (DOE) Climate Challenge and Clean Cities programs. With
respect to the Clean Cities programs, we draw almost exclusively from personal
communication with Assistant Director, Marcy Rood, and staff person, Christy Picker,
because the literature on this relatively new program is quite limited. The Climate
Challenge and Voluntary Reporting programs are well documented and commonly
compared to other initiatives around the world. Information for program analysis is
derived from documents published by the DOE, program partners and advocates
Environmental Defense Fund and Edison Electric Institute, and numerous comparative
analyses of the Climate Challenge program with similar programs in Canada, Australia,
Japan, and throughout the European Union.
The Private Sector
• The Alliance for Environmental Innovation's (AEI's) comprehensive experience with
building industry partnerships. We draw primarily from a report sponsored by the J.M.
Kaplan Fund that reflects AEI's experience over the past decade in managing effective
partnerships.
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• The chemical industry's Responsible Care® (RC) program. In addition, peripheral
analysis of: sub-sector spin-offs of RC is provided. The analysis of these programs rests
largely on findings from research publications by the Organization for Economic
Co-operation and Development (OECD) and the International Labour Organization
(ILO).
State Government and International Efforts
• Multiple government-initiated voluntary environmental programs in Minnesota, New
Jersey, and Massachusetts. We draw solejy from a study conducted by Daniel P.
Beardsley and written up for the Global Environmental Management Initiative for this
analysis.
• An array of non-U. S. voluntary environmental initiatives from around the world.
Analysis of these efforts is aggregate in nature due to the large number of programs.
While multiple documents are reviewed, key documents are published by the European
Environment Agency, United Nations, Global Environmental Management Initiative,
The New Directions Group, and the Institute of Local Government Studies-Denmark.
An annotated bibliography that contains exact citations for all references is attached to this report.
The degree of diversity in the programs reviewed is significant. To some degree, this diversity
reflects the lack of overriding consensus on the distinction between key terms. While some
organizations are currently struggling to communicate discrete definitions for the terms
"voluntary" and "partnership", the majority of actors participating and analyzing these programs
use the terms interchangeably, with a greater emphasis on the term 'Voluntary."
There is greater consensus in the literature about the distinction between the terms "initiatives"
and "agreements," particularly on the international front. The general consensus is that
agreements must involve at least two parties, demand a significantly larger degree of commitment,
and usually involve a degree of negotiation.1 In contrast, initiatives can involve some or all of
these components, be limited to codes of conduct, or simply involve an exchange of information.2
For the purposes of this abstract, this distinction is of greatest import, and one that we make when
drawing from "lessons learned" in either case.
'International Labour Organization (ILO). 1999. Voluntary Initiatives Affecting Training and Education on
Safety, Health, and Environment in the Chemical Industries. Geneva: ILO, 39. See also European Environment Agency
(EEA). 1997. Environmental Agreements: Environmental Effectiveness. Environmental Issues Series, No. 3, Vol. 2.
Copenhagen: EEA, 5.
'Ibid.
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As indicated in the work plan, this abstract seeks to answer five key questions in our analyses of
the aforementioned initiatives:
How are the programs structured?
How are the programs managed?
How is performance measured?
What "lessons learned" can be transferred to EPA's programs?
Where is there potential for overlap and coordination between EPA and voluntary
programs in Federal agencies?
It should be noted that information on program structure and management was less forthcoming
in programs for which there was no personal communication. This is particularly the case with
most of the international and state-led programs.
Our review proceeds as follows:
• A discussion of Key Findings (Section II)
• Program Abstracts and Summaries of Relevant Points (Section HI)
• Summary of Relevant Findings and Proposed Management Guidelines from
Comprehensive Studies (Section IV)
• Lessons Learned Relevant to EPA Partnership Programs
Recommendations for improved management and coordination of EPA's partnership programs
will be included in our final project report and will account for the findings discussed here.
II.
KEY FINDINGS
In the process of analyzing programs for this task, we identified a number of common themes and
recommendations for effective management of voluntary and partnership initiatives. These
findings are organized into four main management areas including: stakeholder involvement,
program incentives, program evaluation, and general guidelines/keys to success.
Stakeholder Involvement
• Opinions regarding the appropriate nature and degree of stakeholder involvement in the
development and monitoring of voluntary initiatives are polarized. There exists a
significant contingent that claims participation by the general public and environmental
groups is detrimental to the process of developing effective programs, and an equally
strong contingent that argues for the necessity of their involvement.
• There is a general sense that where industry is a program partner, the participation of
industry representatives in the program development process is crucial.
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Program Incentives
• In identifying incentives for voluntary program participation, partners most commonly
cite qualitative benefits such as improved relationships with regulators and impacts on
public image. In addition, these benefits are often viewed by industry partners as
relatively significant.
• Another commonly cited incentive for participation is to prevent the establishment of
potential new regulations. Proof of this tendency is the existence of and degree of
participation in a relatively large number of climate change initiatives in countries,
including the U.S. In most cases, signatory countries are responding to industry
requests to test the effectiveness of voluntary pledges in meeting Kyoto Protocol
commitments before digging into the policy toolbox for regulatory options.
Program Evaluation
• There is an almost across-the-board lack of systematic measurement and subsequent
evaluation of programs by program partners; Most evaluation is completed by outside
parties seeking to analyze the public policy potential of voluntary initiatives. As a result,
all but qualitative benefits are extremely difficult to assess.
• While the qualitative benefits of partnership programs for both the regulating agencies
and partners are frequently noted in program evaluations, these benefits are often
referred to as amorphous.
• Where systematic program evaluation does exist, it is often limited to the evaluation of
project outcomes. Consistency with program and larger agency objectives and program
cost efficiency are rarely assessed.
• Despite this lack of measurement, there is a pervading sense that programs are cost
effective for both industry and regulatory agencies.
• Even with careful measurement and evaluation, the complexity of factors influencing
program outcomes renders the isolation of program effects extremely difficult.
General Guidelines/Keys to Success
• There is a pervasive consensus across industry, non-profit groups, and government
agencies that voluntary and partnership programs are best utilized as a complement to
other regulatory tools.
• There is a degree of commonality in the recommendations made by multiple reports
with respect to the key elements of program success (see Section IV). Acknowledgment
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that the determination of program success should be contingent upon the ability of the
program to satisfy program goals and objectives is much less common.
There is limited evidence to suggest that successful agency programs have some
statutory basis.
Federal Agency Initiatives
U.S. Occupational Safety and Health Administration (OSHA)
The Occupational Safety and Health Administration started experimenting with voluntary
approaches to regulation in 1982 with the establishment of the Voluntary Protection Programs
(VPP).3 The program has since grown from 11 to 292 sites," and the Agency has developed two
additional cooperative programs: the Consultation Program (CP) and the Strategic Partnership
Program (SPP). While the SPP is too new to evaluate its success, the CP has been praised in a
number of arenas for its success in improving work-place safety in a cooperative manner.
There is a widespread sense within OSHA of the importance of partnership initiatives to the
success of the larger organization. OSHA employees tend to be very proud of the program
accomplishments and extremely committed to their objectives;5 organizational leaders, including
assistant labor secretary for occupational safety and health, Charles Jeffress,6 and former OSHA
Chief, Joseph Dear,7 are known for their commitment to cooperative efforts; and Congress, in
recent amendments to the OSHA Act, has placed a premium on the value of industry partnerships
by mandating the dedication of 15 percent of the Agency's budget to cooperative efforts and in
placing the highest priority on achieving results through the systematic management of health and
safety, including the use of voluntary policy tools.8
Outside of OSHA, there is appreciation among industry health and safety officers for the specific
OSHA partnership programs, and more generally for the agency's reinvention as a friendly,
cooperative partner.9 Employers comment that they see benefits, rather than detrimental impacts
'Oliver, Cathy. May 3, 1999. Personal communication.
'Hanson, D. March 31, 1997. OSHA marks gains with voluntary plans. Chemical and Engineering News, Vol.
75, 22.
sVira, Carol. April 27, 1999. Personal communication.
*Brostoff, S. December 1,1997. OSHA creates cooperative program for safety testing. National Underwriter,
Vol. 101,1.
7Figura, S. March, 1997. Is OSHA reform on target? Occupational Hazards, Vol. 59,23.
'Oliver.
'Figura. See also Hofmann, M. 1998. Employer groups divided on OSHA auditor idea. Business Insurance,
No. 32, Vol. 3+, F9.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 70
in working cooperatively with OSHA, both on the compliance end of operations and in the realm
of setting standards.10 Further, the insurance industry praises the CP and VPP for significantly
reducing occupational risk and calls for the expansion of both programs.11
Beyond the benefits of specific partnership programs, VPP Program Director Cathy Oliver
emphasizes that OSHA's systems approach to health and safety management is the "heartbeat" of
the organization, which enables effective interplay between programs and with customers to meet
the specific needs of different employers.12
The structure of cooperative programs within OSHA reflects this systems approach. Each
program has a distinct target audience, with little overlap between them, and communication
structures have been established to ensure cooperation between the programs when appropriate.13
To aid in facilitating this approach, a distinction has been made between partnership and voluntary
programs with respect to the regulatory components of the programs. The partnership programs
(which are overseen by SPP) can have regulatory enforcement components to them, whereas the
voluntary programs (CP and VPP) are set up either to ensure there will be no enforcement
consequences to participating or to offer regulatory reprieve as an incentive to participants.14
Assistant Secretary Charles Jeffress points out that another key aspect of this systems approach is
to unify the measures of success for employers and the organization.15 By assisting employers
through a variety of programs to model OSHA's systems approach, the organization is
accomplishing this goal. In an interview with Ms. Oliver, she cited the fact that workplace injuries
and illnesses are 40 to 80 percent less in environments where the employer takes a systems
approach to health and safety (H&S) management,16 driving home the point that this strategy is
working. The numbers are indicators of success for both partners.
While voluntary initiatives have been a part of OSHA's approach to achieving policy objectives for
nearly two decades and the concept of Reinvention is nearly a decade old, the organizational
culture is still adapting to these changes. For example, at the regional level all emergency response
personnel are just as of this year being trained to provide strategic, innovative consultations to
'"ibid
"Hofinann, Employer. See also Brostoff, OSHA creates I.
"Oliver.
13Ibid.
"Ibid. See also Vira.
"Fleming, S. Fall/Winter 1998. Assistant secretary Charles Jeffress discusses plans for OSHA. Job Safety and
Health Quarterly, No. 9, Vol. 20, 18.
"Ibid.
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employers after site visits.17 Another area of cultural resistance identified at the regional office
level is in accepting the validity and need for inviting and facilitating stakeholder participation.18
OSHA officials are quick to note that there is a need for a spectrum of policy tools,19 within a
larger philosophical approach.20 Among these tools, partnership programs are seen as
complementary to regulatory enforcement, and neither approach is seen as effective independent
of the other.21 Of particular note, this outlook is supported by industry H&S officers familiar with
the Agency's health and safety objectives.22 They note that the regulatory enforcement process
seems more valid, less "nitpicky" since the implementation of the cooperative efforts within
OSHA.23
Strategic Partnership Program (SPP)
The SPP is a newly instituted effort to set standards for a number of Reinvention initiatives that
have been established under the general heading of "Partnership Programs" over the last decade.24
Previously, the management approach to these programs was to treat them as regional or
industry-specific laboratory efforts designed to explore options for H&S performance
improvement through cooperative measures.25
As the number of programs grew to between 30 and 40, the Agency decided that while these
programs are still best managed at the project level there needed to be some coordination among
them.26 The realization that each program houses valuable information that may be useful in other
settings and that some broad policy guidelines needed to be set in order to avoid regulatory and
other problems associated with ill- management guided the establishment of the SPP.27 The SPP is
currently housed in the same office with the VPP.28 Due to the relative newness of this program,
little evaluation has been done or made available.
The Voluntary Protection Programs (VPP)
"Oliver.
"Ibid.
"Vira.
ZQOliver. See also Fleming, Assistant 19-20.
''Oliver.
"Figure, Is OSHA reform...?
"Ibid.
"Oliver.
"Ibid
26Ibid.
"Ibid.
"Ibid.
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The Voluntary Protection Program (VPP) is designed to "recognize and promote excellence in
worksite-based safety and health program management.29 As mentioned, the VPP started in 1982
with 11 test sites and has since grown to encompass ^92 sites (1997 figure). The pre-requisites to
participation are that the employer must be in compliance with all OSHA regulations and have
developed and implemented its own health and safety program.30 Incentives to participate include
public recognition and exemption from OSHA's routine inspection list for two years.31 The
program offers different levels of leadership recognition, depending on the employer's ability to
meet a variety of requirements upon OSHA inspection.32 At all levels, VPP qualification is
regarded as a true mark of excellence.33
VPP-recognized employers are credited with injury arid illness rates at 50% below industry
norms.34 As the reduction of workplace deaths, injuries, and illnesses are primary goals of both the
program and the organization, the program's performance is very impressive. Kenneth Brock, a
safety consultant, commented during an interview for Susannah Figura's article that OSHA has in
essence become a "victim of its own success."33 OSHA doesn't have enough resources to conduct
evaluations of all the employers wishing to participate in the program! While this can be seen as
problematic, it appears that OSHA has discovered a pareto optimal means of responding to this
demand, the VPPPA Volunteers Program.
The Voluntary Protection Programs Participant Association (WPPA) Volunteers Program (VP)
has burgeoned from the VPP program in the past couple of years. The VPPPA Volunteers
Program was initiated by H&S officers from VPP-cernfied organizations that wanted to share
their experience with other employers in the capacity of VPP on-site review team members.36
Volunteers must meet rigorous requirements in order to be accepted into the program, at which
time they are sworn in for 3-year renewable terms as ^Special Government Employees."37 As of
last year, OSHA had effectively recruited 80 volunteers.
The benefits of this program are numerous. Participants are not shy about sharing their
contentment: Industry representatives comment on the refreshing sense of cooperation among
businesses; volunteers comment on how they learn a great deal from interacting with employees at
29SherilI, L. and J. Weinberg. Summer 1998. OSHA's VPP gets a littJe help from its friends. Job Safety and
Health Quarterly, No. 4, Vol. 9,29.
'"Hanson, OSHA marks.
"Ibid.
"Sherrill and Weinberg, OSHA's VPP 29.
"Ibid.
MHanson, OSHA marks.
"Figure, Is OSHA reform... ? 25.
"Sherrill and Weinberg, OSHA's VPP 29.
"Ibid.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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the sites they audit; OSHA on-site review team members have found the volunteers to be
invaluable in maintaining program quality; and the Agency is saving significant economic
resources.38 A recently debated issue is whether OSHA should certify third parties to do site
evaluations (at the employers' expense) in order to meet the ever owing demand for VPP
participation.39 In this instance, industry is, in general, for the option of third party authorization
capabilities, but there are many issues that will have to be resolved before OSHA makes a
decision either way to proceed with this option. Acknowledging that there are some concerns
with this type of program, one must credit OSHA for again charting new ground in providing
their customers with flexibility in a manner that is cost efficient for the agency.
In any case, it is noteworthy that OSHA has invited significant stakeholder participation in the
development of the VPP program, as demonstrated through the establishment of the volunteers
program and the Agency's willingness to consider a third party certification option.
The Consultation Program (CP)
The Consultation Program (CP) was established in 1997 to support small business (100 or fewer
employees) in improving health and safety programs and compliance records.40 It is based on a
successful prototype that originated in Maine, which analyzes accident data and targets companies
with the worst records.41 The CP program targets 14,500 employers with lost workday injury
rates more than double the national average.42 Employer incentives for participation include: free
technical assistance, an assurance that any findings of non-compliance during consultation
sessions will not be reported, a reduction in chances of being inspected from 3/10 to 1/10, lower
worker's compensation costs, and lower insurance costs. The Agency headquarters monitors this
program, but program management and implementation largely take place at the regional level.43
Aside from anecdotal approval of the program,44 and a sense of improved cost efficiency among
Agency staff, this one-year old program is yet too young for evaluation. However, initial reactions
are highly positive, and there is a general sense that the program will continue to grow.
Summary of Relevant Points
• Unification of performance measures for both partners.
"Ibid.
"Hoftnann, Employer groups.
'"Brostoff, OSHA creates 1.
"Ibid.
"Ibid.
43Vira.
"Hofinann, Employer 5.
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Overarching philosophy that enables inter-program coordination and efficiency.
Both OSHA and industry view partnership programs as an essential tool among
many-one that is only complementary to effective regulatory programs.
Cultural change takes time.
Emphasis on Agency cost efficiency.
17.5". Department of Energy
Clean Cities
The objective of the Clean Cities program is to encourage the use of alternative fuel vehicles
(AFVs) and the development of a supporting infrastructure toward the end of achieving energy
security and the reduction of urban pollution.45 The first Clean City was designated in 1993, and
the program has grown significantly since that time.46 DOE Clean Cities staff provide partner
cities with technical support and relay relevant information between stakeholders47. This is of
particular interest to fuel providers that are required by law to make AFV acquisitions or
conversions in the near future.48 In addition, participants are motivated by the increased likelihood
that through voluntary participation, they can avoid future regulation.49
There is minimal marketing of the program, so the program relies on cities interested in
participating to contact the Clean Cities offices.50 While there is no component of regulatory
reprieve in the program51, cities must be in compliance with the Energy Policy Act (EPAct) State
Government Fuel Provider Rule in order to participate.52 The Clean Cities program is grounded in
the EPAct mandate for the development of voluntary programs to complement regulatory
enforcement.53
The Clean Cities program is centrally managed, but administered at the regional level.54 Assistant
Program Director, Marcy Rood commented that the headquarters office staff communicate
<5U.S. Department of Energy (DOE). 1999. http://www.ccities.doe.pov/what is.html.
46Ficker, Christy. April 29, 1999. Personal communication.
47DOE.
"'Ibid.
"Ibid.
MFicker.
"There is a provision for establishing voluntary alternatives to state fleet mandates, but no state has submitted
an application for this alternative.
"Ibid.
"Ibid.
"Rood, Marcy. May 3,1999. Personal communication.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
75
regularly and effectively with regional staff.55 In addition, the program tends to attract and retain
very high quality staff.56 Ms. Rood feels that this is largely a product of a general sense of
enthusiasm for and importance of voluntary initiatives within the agency that is supported by
upper management.57 Despite this fact, she noted that the program is resource scarce and would
be more effective if it were able to support full-time coordinators at the regional level. In addition,
Ms. Rood commented that there is some tension within the Agency over the relationship between
the program and the larger DOE mission.58
With respect to coordination of the Clean Cities program with other voluntary or partnership
initiatives, the Assistant Secretary of DOE has recently expressed concern over the need for a
more community-based approach to marketing programs.59 A model where DOE would present a
city or potential customer with all of the partnership program options and provide assistance in
identifying what programs best suit their needs is being considered.60 DOE has also recently
published a brochure entitled "Communities of the Future" that lists all of the partnership
programs.61 Despite the Agency's lack of focus heretofore on program coordination and a failure
to strictly define the components of a "voluntary" or "partnership" program, there is little overlap
in program focus and confusion over program structure doesn't appear to be a problem.62
Another area of coordination that needs to be improved is program referral at the regional level.63
The program monitors the number of AFVs on the road, fleet conversions, and other more
qualitative indices to measure program performance.64 This information is reported to Congress
and compiled in a report on an annual basis.65 There is no cost efficiency component or measure
of contribution of the program to the larger goals of the agency as part of this review.66 A
relatively new program, it is difficult to evaluate its success. Most of the information on the
program is available through DOE and it tends to be educational, rather than evaluative in nature.
There has been some criticism that the program has not been successful in getting enough AFVs
on the road.57
"Ibid.
"Ibid.
"Ibid.
5!lbid.
59Ibid.
60lbid.
6llbid.
"Ibid.
"Ibid.
"Ibid.
"Ibid.
"Ibid.
67Ibid.
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Summary of Relevant Points
• Importance of upper level management support for programs in attracting and retaining
high quality program staff.
• Current lack of coordination between DOE partnership programs. Emphasis is being
placed on improving program communication and collaboration.
• Program is based in EPAct statute.
• Program provides technical assistance to customers in meeting regulatory requirements.
• Avoidance of future regulation is an incentive for participation.
• Lack of performance evaluation.
Climate Challenge and the Voluntary Reporting Program
The DOE's Climate Challenge program is a voluntary, performance-based program whereby
energy utilities enter into formal agreements with DOE detailing their greenhouse gas emission
reduction commitments.68 In exchange for voluntary reduction commitments, DOE provides
technical information and support; a periodic, public report on the progress of the program; and
public recognition to utility participants.69
The impetus for the establishment of the program came largely from the U.S. signing of the Kyoto
Protocol.70 The Electric Utility Industry responded strongly to this development by lobbying the
U.S. government with an argument that voluntary reductions would come at a significantly
smaller cost to both agencies and business than regulatory measures. The Administration and
DOE recognized the cost and time efficiency advantage of a voluntary initiative and created
Climate Challenge, among other partnership programs.
From the program's inception, DOE has worked cooperatively with the Edison Electric Institute
and other electric utility associations at developing the program.71 The Environmental Defense
Fund (EDF) has also taken an active role in advocating for the Climate Challenge program by
publicly praising the approach and partnering with one utility, Public Service Electric and Gas
"U.S. Department of Energy (DOE). Voluntary Reporting of Greenhouse Gases 1995.
http://ww w .eia. doe, go v/oiaf/\rgg05/chap3. h tml.
"Newman, J. 1997. Policies and Measures for Common Action: Electricity Sector: Utility Voluntary
Agreements to Reduce Greenhouse Gas Emissions. Working Paper 17, Annex I Expert Group on the UN Framework
Convention on Climate Change.
'"Kinsman, J.D., M. McGrath, R. McMahon, M. Ricker, R. Shiflett, and R. Tempchin. June 23-28, 1996. A
Status Report on Climate Challenge Program's Voluntary Initiatives to Manage U.S. Electric Utility Greenhouse
Gases. Presented at 89th Annual Meeting & Exhibition Air & Waste Management Association, Nashville, TN.
http://www.eej'.org/industry/enviro/manus.htm.
"Edison Electric Institute (EEI). Global Climate. http://w3vw.eei.org/Industrv/enviro/global.htm.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
77
(PSE&G) of New Jersey.72 EDF is collaborating with PSE&G in developing a plan to assure that
emissions reduction commitments come to fruition.73
Climate Challenge participants are required to report "annually on activities and achievements
under the Climate Challenge Program in a clear and understandable manner."74 In developing
standards for reporting, it was realized that a reporting tool developed for the Voluntary
Reporting Program (VRP) would serve this purpose well. (The Voluntary Reporting Program is
an EPAct mandated, EPA and DOE collaborative, voluntary greenhouse gas emissions reporting
program).75 Climate Challenge participants signed an MOU with DOE stating that they will record
project efforts on one of two versions (short and long) of VRP Reporting Form EIA 1605(b) to
facilitate the reporting process.76
The EIA forms are based on guidelines developed during a series of DOE and EPA-conducted
workshops and in response to public review.77 In developing the guidelines, there was a fair
amount of debate over the degree of flexibility that should be afforded participants in defining
baseline emissions and ownership of emissions reduction.78 Those arguing that a more rigid format
would discourage voluntary participation won out, and the final guidelines emerged affording
partners more flexibility in defining these parameters.79 In addition, the guidelines entail several
themes including:80
The encouragement of broad participation in reporting.
Participants are to be granted nearly complete flexibility in crafting their reports.
Participants are permitted to report activities both in the U.S. and abroad.
Participants are encouraged to report emissions and emissions reductions as broadly as
possible.
Participants are encouraged to report for a broad range of greenhouse gases.
Participants are permitted to report on "achieved" reductions after 1990.
"Environmental Defense Fund. (EDF). EDF, PSE&IG Ink Pact to Turn CO3 Cut Promise into Performance.
hrtp://www .edf.org/pubs/newsrelea5es/199S/feb/djmpseg/htrnl.
See also Environmental Defense Fund. April 20, 1994. EDF Unveils Pact with PSE&G Creating Environmental
"Backstop. " http://www.edf.org/pubs/newsreleases/1994/apr/d%5Fpseg.html.
73Ibid.
"Kinsman et ai, A status.
75DOE, Voluntary.
"Kinsman, et al, A status.
"DOE, Voluntary.
Ibid.
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Pursuant to these guidelines, the forms are designed to track a broad range of emissions
sequestration, avoidance, and reduction activities.
The electric utility industry contributes one-third of thfc total U.S. carbon dioxide emissions- it is
also the largest contributor to Climate Challenge and Voluntary Reporting Program emissions
reductions.*1 The electric utility DOE Climate Challenge participants make up the majority, 560
out of 645 reported projects, of VRP participation, with 37 of the remaining 85 reported projects
being associated with other voluntary programs.'2 As is obvious from the numbers, there is a great
deal of collaboration between the Climate Challenge and Voluntary Reporting Programs, and
between VRP and other climate change programs within EPA.
As of 1996,600 participants, representing 60 percent of the electric power generation in the
nation, had signed 113 Climate Challenge agreements with DOE.83 In most cases, partners have
chosen to participate in the program to establish a public record of their contribution toward
meeting a national environmental policy goal that may create standing in a possible future
regulatory scheme and to enable others to learn from their experience.84 Some examples of
projects undertaken to meet program commitments include:*5
• American Electric Power has established a program of carbon offsets from aforestation.
The company has planted over 41 million trees since 1945 on company lands.
• Texas Utilities Company has begun commercial operation of two nuclear power units as
substitutes for slated coal-fired plants.
• Allegheny power has established a demand-side program that educates customers on
energy conservation measures, including load management.
All of these programs have tracked past and estimated future impact on greenhouse gas emissions.
DOE estimates that Climate Challenge covenants will lead to reduced emissions of 43 million
metric tons of carbon equivalent by the year 2000.86 EEI provides a reduction number four times
as large (170 million metric tons) and claims that the program is the most successful in the
world.87 The discrepancy in numbers comes from a difference in the types of activities recorded.
"DQESoluntary.
"Ibid.
"Edison Electric Institute (EEI). Climate Challenge Report: Voluntary Programs Work.
http://www.eei.org/Industrv/enviro/programs.hpn.
"DOE, Voluntary.
"EEI, Climate.
"Ibid.
"EEI, Global.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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DOE excludes reduction commitments not yet quantified and utility-wide educational initiatives
aimed at transforming key markets.88
The Climate Challenge and Voluntary Reporting programs are yet too young to be
comprehensively evaluated. It is interesting to note, however, that it would be difficult to conduct
an evaluation given the nebulous nature of program objectives. The Climate Challenge program
seeks as its main objective to encourage electric utilities to identify means of and commit to
reductions of greenhouse gas emissions. The Voluntary Reporting program simply aspires to
broad participation in reporting activities that will effect the stock of greenhouse gases in the
atmosphere. If there are specific targets set for the degree of participation in either program, that
information is not readily available. Assuming that 100 percent participation would be ideal, one
could give the Climate Challenge program a very positive rating given the 60 percent rate of
participation by the electric utility industry. With respect to VRP, only 23 percent of total
emissions are currently being accounted for. The DOE also sets as a program goal the provision
of technical information for participants, which it has achieved on one level through the recent
publication of the Climate Challenge Options Workbook.89
Given that it is a goal of both programs to reduce greenhouse gas emissions, a likely measure of
effectiveness in the future will be to quantify reductions and compare total emissions with
projected emissions absent any voluntary commitments. However, this would be difficult given
the non-uniform, unverified form in which emissions reductions are being reported.
It is instructive to review findings from other voluntary climate change programs around the
world that have been more extensively evaluated against program goals. Canada, for example, has
implemented a program quite similar to the Climate Challenge program. Canada's Voluntary
Challenge and Registry (VCR) is also a performance-based initiative, with similar program
objectives and offering identical benefits to both industry and the government. However, the
Canadian program is grounded in a set reductions target, whereas the Climate Challenge program
is a "no regrets" initiative.90 Like in the U.S., industry in Canada has been an active advocate for
voluntary initiatives, fearing strict legislation as the alternative.91
While the VCR program has been successful in meeting its goal of a high degree of participation
(the majority of utilities have registered), only half of those registered have submitted action plans,
and a small fraction have quantified reductions.92 In addition, there is no evidence to suggest that
the program is getting Canada any closer to meeting its signatory commitments. Another program
"Kinsman, et a!., A status.
"EEI, Climate.
'"O'Brien, R. 1997. Global Warming and Voluntary Initiatives: The Role of the Voluntary Challenge and
Registry in Canada, http://www.web.net/~robrien/papers/vcrpaper.html.
"Ibid.
"Ibid.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
80
goal, similar to the Climate Challenge program, is to provide information to participants on the
latest developments in emissions reductions achievements.93 The VCR has established a web site
from which it was to serve as an information clearinghouse, however, the site has not been
updated in over a year due to an inadequate level of support for the program.94
On a broader level, the program has been evaluated as unsuccessful with respect to helping to
meet the goal of reducing emissions back to 1990 levels.95 Projections suggest that the Canada
will likely be emitting greenhouse gases at a 9 percent increase from 1990 levels by the year
2000.% Likely contributors to program failure include the minute nature of program incentives, an
increase in overall production due to consumer demand, poor program design, and a lack of
government support for the program.97 This lack of success in reaching reductions targets has
prompted a "turn to a regime of legislated economic, instruments in the form of global tradable
emissions permits."98 Whether or not the results of the highly similar Canadian VCR program can
be assumed to reflect the likelihood of Climate Challenge outcomes remains to be seen. However,
the similarity between the programs and the economic and social contexts in which they operate
suggests that this is not an unlikely possibility.
Summary of Relevant Points
The United Nations Framework Convention on Climate Change conducted an evaluative study on
climate change initiatives in the U.S. (Climate Challenge), the Netherlands, Canada, and
Australia.99 In attempting to make some broad generalizations about the use of voluntary
initiatives to meet global greenhouse gas emission reduction goals, the author makes the following
assertions:100
• Due to the young nature of most of the programs reviewed, it is difficult to assess results.
• Voluntary climate change programs rarely operate in isolation. Financial incentives or
regulations often accompany them, making it difficult to isolate effects.
• The effectiveness of different types of voluntary initiatives is difficult to assess due to the
range of political and economic factors influencing each context.
"Ibid.
"Ibid.
"Ibid,
"Ibid.
"Ibid.
"Ibid.
"Newman, Electricity.
I00lbid.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
81
• There is no evidence to suggest that one type of voluntary program is better than another,
rather the effectiveness of each program depends on the economic and competitive
conditions that exist.
In summary, it appears that largely due to the lack of generally accepted accounting principles, the
newness of programs, and the wide diversity of economic and social contexts in which the climate
change initiatives are operating, it is nearly impossible to establish general guidelines for effective
management. However, it is perhaps of interest that the Institute for Local Government Studies
(AKF) in the Netherlands has been successful in conducting comprehensive, quantitative studies
on the cost-efficiency and effectiveness of the voluntary component of the National
Environmental Policy Plan.101 This evaluation suggests that the voluntary Dutch climate change
program has been both effective and cost-efficient at meeting program goals.102
With specific respect to the Climate Challenge and Voluntary Registry Programs, the following
findings are of particular relevance to this paper:
• There appear to be significant opportunities for collaboration between EPA and DOE
voluntary climate change programs, with the VRP serving as the nexus between programs.
• DOE programs have been marked by significant stakeholder involvement in program
development.
• Program effectiveness is difficult to evaluate due to the apparent lack of clear objectives,
the newness of the program, and the non-uniformity of project emissions reports.
• Questions remain as to how and if emission reduction achievements will be validated.
Private Sector Initiatives
Multiple private sector voluntary initiatives have burgeoned in recent decades. The Environmental
Defense Fund (EDF) has emerged as a leader of industry partnerships in the environmental
non-profit community. Starting in 1991 with a McDonald's alliance, EDF has in recent years
proven effective at assisting private companies in adding value through the adoption of
environmentally sound practices and in eroding the adversarial nature that traditionally
characterizes relationships between industry and advocacy groups.103
""Rietbergen, M., J. Farla, and K. Blok. June 11-12,1998. Quantitative Evaluation of Voluntary Agreements
On Energy Efficiency In: Proceedings of the International Workshop on Industrial Energy Efficiency Policies:
Understanding Success and Failure. Utrecht: AKF. http://www.akf.dk/vaie/papers.htm.
102Ibid.
""Fastiggi, E. 1999. Catalyzing Environmental Results. Lessons in Advocacy Organization-Business
Partnerships. The Alliance for Environmental Innovation (AEI), 3.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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In 1994, the EDF formalized its commitment to revolutionizing the business world's approach to
environmental issues in a partnership with The Pew Charitable Trusts (which also has an
impressive record in establishing industry partnerships) called the Alliance for Environmental
innovation (AEI).'04 Given EDF's and AEI's reputation for success and longevity in pursuing
such endeavors, we have chosen to showcase their efforts. We draw primarily from a report
sponsored by the J.M. Kaplan Fund that reflects AEI's experience over the past decade in
managing effective partnerships.105
With respect to industry-led initiatives, we focus here an initiatives within the chemical industry
due to the large number, relatively long history, and pervasiveness of these efforts. Particular
emphasis is placed on the Responsible Care® program as it is the most mature, extensively
evaluated, and expensive of its kind.
In particular, we have reviewed lessons learned from:
• The Alliance for Environmental Innovation,
• Responsible Care® (RC),
• Subsector spin-offs of RC (chemical distributors, traders, and industry associations have
developed their own programs, which commonly employ the RC logo),
• The industry-led voluntary cessation of manufacture of benzidine dyes in Switzerland and
the United Kingdom, and
• An industry-sponsored nickel/cadmium battery collection and recycling program in the
United States
Our analysis of the industry-led programs is based on research publications by the Organization
for Economic Co-operation and Development (OECD) and the International Labour Organization
(ILO). Additional references are cited as appropriate.
The Alliance for Environmental Innovation
The Alliance for Environmental Innovation's primary mission is to create and execute
environmentally beneficial partnerships that generate economic benefits.106 The economic and
environmental components of this goal are viewed as equally essential as the Alliance believes that
"environmental initiatives will only sustain themselves and grow within a company when they
deliver specific, measurable business benefits."107 At the same time, AEI emphasizes the
importance of both partners investing significant time and resources in the project at the time of
104Ibid
1Mibid.
lo*Fastiggi, Catalyzing 3.
""Fastiggi, Catalyzing 22.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
83
inception, despite the fact that the requisite benefits will likely not materialize until the future. This
is of premier import given the traditionally adversarial nature of the two partner communities.
Beyond these guiding principles, AEI documents the steps in establishing successful
NGO-industry partnership projects. The majority of these recommendations are inapplicable to
EPA's partnership programs given their fundamentally different structure. For example, one of the
central components of the guidelines is the negotiation and signing of a memorandum of
agreement (MOA) between the two partners. The guidelines for negotiating an effective MOA,
among other recommendations, would primarily be applicable in the Project XL program (other
partnership programs contain MOUs, but they are generally pre-set and non-negotiable).10* One
component of AEI's recommendations, which includes means to effective performance
measurement, provides highly applicable guidelines for EPA programs.
The Alliance has been diligent in measuring and evaluating the performance of its partnerships
based on the organization's central goals of achieving superior environmental performance and
economic benefits for its partner companies. In essence, both partners must identify the specific,
measurable indicators that determine if the project is meeting both their project goals and the
larger organizational missions. With respect to AEI, this means that they will always need to
select performance indicators that track both economic and environmental results.109 The Alliance
emphasizes that after identifying measures appropriate to the specific project goals, it is "essential
to establish a baseline"110 from which progress can be evaluated, and to evaluate progress
throughout the project. Given the common failure by both government agencies and industry
participants to measure quantitative results of voluntary initiatives and the almost ubiquitous
failure by regulatory agencies to evaluate program performance in relation to the organization's
larger mission, AEI's approach to performance measurement is particularly noteworthy.
Summary of Relevant Points
• Criticality of economic benefits in environmental initiatives in order for them to be
sustainable
• Performance measurement based on baseline measurements of appropriate indicators to
both project and organizational objectives
Responsible Care®
l08For additional recommendations that may be useful in improving the management of Project XL, see
Fastiggi, Catalyzing 7-22.
109 A table of metrics for tracking both qualitative and quantitative benefits to business categorized by risk
reduction, costs, costs of capital, and revenues is provided. Fastiggi, Catalyzing 24-26.
1 !0Fastiggi, Catalyzing 23.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW 84
Introduction and History
Responsible Care® (RC) is an international chemical industry effort to continually improve in all
aspects of environment, health, and safety (EHS) performance, with particular emphasis on
communication of EHS performance to the public.1'1 The international effort is modeled after a
program developed by the Canadian Chemical Producers Association's (CCPA), with significant
components drawn from the U.S. Chemical Manufacturers' Association's (CMA) Community
Awareness and Emergency Response (CAER) program.112
RC started in 1985, largely in response to three major chemical release disasters around the world
and a realization that "if the public's expectations of improved performance [were] not realized,
the chemical industry [would] face greater regulation, sanctions, protests, or even closure.""3 It
has since spread to 41 countries in companies accounting for 88 percent of world chemical
production"4 - an unprecedented degree of voluntary participation within a given industry on a
global basis. The degree and scope of RC program implementation varies greatly from country to
country, but all program sponsors commit to the same set of eight fundamental features.115
Beyond these features, the program entails the adoption often guiding principles and six
management codes of practice.116 For example, there is a code of management practices for
product stewardship which, among other commitments, requires the company to maintain health,
safety, and environmental information on its products. A complete list of principles and
management practices is available from the CMA website at
http://www.cmahq.com/cmawebsite.nsfypages/responsiblecare.
Program Structure
Program commitment is often conditional upon membership with national chemical
manufacturers' associations,117 which ensures significant degrees of participation and avoids free
rider problems. In addition the International Council of Chemical Associations (ICCA) has
established an RC Leadership Group (RCLG) to oversee international coordination of RC
'"International Labour Organization (ILO). 1998. Voluntary Initiatives Affecting Training and Education on
Safety, Health and Environment in the Chemical Industries. Report for Discussion at the Tripartite Meeting on
Voluntary Initiatives Affecting Training and Education on Safety, Health and Environment in the Chemical Industries.
Geneva.
"2ILO, Voluntary 30.
"3Inter-Organization Programme for the Sound Management of Chemicals. 1997. Proceedings of the OECD
Workshop on Non-regulatory Initiatives for Chemical Risk Management, OECD Environmental Health and Safety
Publications Series on Risk Management, No. 7. Paris: OECD, 16.
"4IOMC, Proceedings 15.
II5ILO, Voluntary 29.
"6Ibid.
U7ILO, Voluntary 30.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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efforts.118 CEO level commitment has been instrumental in assuring sustained commitment to the
initiative.119 Complete implementation is self-verified in most countries, but recently heated debate
has ensued in the U.S. and Canada over the need for third-party verification and public disclosure
of third-party findings.120
The methodology by which RC's guiding principles and management codes of practice are
implemented in a given company varies depending on the company's previous commitments and
management systems. RC is flexible enough that its commitments can be adapted to other
management systems.121 With respect to effectively managing what can be highly complex issues,
this approach appears logical. It allows individual companies to determine what is the best way of
injecting RC's principles into an existing corporate culture without confusing the work force by
adding new terminology or giving the impression of not following through on existing
programs.
122
One result of this approach is that there is little "brand recognition" of RC below the management
level within member companies.123 In response to the RC's challenge, "don't trust us, track us,"
the Public Research Interest Groups (PIRGS) conducted a series of two surveys in 1992 and 1998
of U.S. RC members (with the worst TRI reports) during which they asked between seven (1998)
and nine (1992) basic questions relating to RC.124 The PIRGs found the results very
"disturbing."125 To the point, only 17 percent of respondents in 1992 and 22 percent of
respondents in 1998 provided responses to all nine questions - to say nothing of the quality of the
responses.126 Studies done by the ILO and the International Federation of Chemical, Energy,
Mining, and General Workers' Unions (ICEM) determined the level of worker awareness and
involvement in RC to be very minimal as well.127
Logically, it can be and is argued that given the "cocktail" approach, the absence of brand
recognition implies very little about the degree and effectiveness of program implementation.128 In
fact, a survey of member companies conducted by the CMA "repeatedly referred to the value that
"*ILO, Voluntary 32.
'"IOMC, Proceedings 13.
120ILO, Voluntary 1\.
I2llLO, Voluntary 34.
l"ILO, Voluntary 35.
'"Ibid.
I24ILO, Voluntary 36.
'"Ibid.
'"Ibid.
'"ILO, Voluntary 37.
I2'ILO, Voluntary IS.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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RC had brought to creating an integrated management system."129 However, this has led to some
significant problems in evaluating the effectiveness of RC. Consistent with worker recognition
findings, the degree of public recognition of RC is very low.130 The results of surveys assessing
changes in public image of the chemical industry in general are mixed, but there is some evidence
to suggest that RC has contributed to stopping a "25-year decline in the general public's
opinion"131 of the industry. While the degree of "brand recognition" of RC within member
companies and among the public is very low, in many respects, performance measures suggest
that the initiative may be accomplishing its primary goals. However, one cannot be sure, given the
near impossibility of isolating the effects of this effort132
Incentives for Participation
The RC program provides multiple incentives for participation. Perhaps the greatest of these is the
increased likelihood of staying in business.133 Other key incentives include: a positive impact on
companies' bottom tine through reduced EH&S costs and improved efficiency; avoidance of
environmental liability suits; improved relations with stakeholders; and the improved likelihood of
avoiding stricter government regulation.134
Stakeholder Involvement
Consistent with the RC articulation that public accountability is a key tenet of the program,135 the
nature of stakeholder involvement in RC is highly inclusive. While the RC rules at both the
national and international level call for specific industry association coordination, the remainder of
the stakeholders mentioned in Table 1 participate either because they have been invited to
participate or in response to the RC challenge of "don't trust us, track us." As the program has
grown, RC leaders and administrators have sustained and expanded their initial commitment to
public involvement and approval and the number of stakeholders actively participating in its
development has increased.136
I2'ILO, Voluntary 36.
I30!LO, Voluntary 34.
I31ILO, Voluntary 10.
mILO, Voluntary 72.
'"IOMC, Proceedings 14-16.
134!OMC, Proceedings 14-16.
'"ILO, Voluntary 15-16.
IJ6ILO, Voluntary \6-\l.
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Table 1 - RC Stakeholders and Functions
Stakeholder
Function
National chemical industry associations
• responsible for implementation of RC in their countries
• i.e., the United States Chemical Manufacturers' Association
(CMA) membership is conditional on RC implementation
Regional chemical industry associations
some overlap with National Chemical Industry Associations
i.e., European Chemical Industry Council (ECIC)
membership is conditional on RC implementation
Trade unions
program monitoring
driving force behind call for third-party auditing
i.e., International Federation of Chemical Energy, Mining and
general Workers' Unions (CEM)
Local communities
dialoging over local concerns about chemical production and
distribution through plant visits, panel meetings, and written
communication
verification of program implementation
i.e., the Community Advisory Panels in the U.S.
International industry associations
program monitoring
provide leadership
i.e., the International Council of Chemical Associations
(ICCA), International Council of Chemical Trade
Associations (ICCTA)
Intergovernment Forum on Chemical Safety ("a
body set up to give effect to UNCED's Agenda
21'"")
monitors worldwide progress
Non-profit and advocacy organizations
• monitoring
• i.e., the Public Research Interest Group (PIRGs) in response
to RC's challenge of "don't trust us, track us"
Program Results
"Positive [environmental] trends are beginning to emerge wherever RC is being implemented."13*
Specific performance data are reported to and by the National Chemical Associations as a
prerequisite to international participation. Some examples of documented improvements
include:139
I37ILO, Voluntary 29.
IJSIOMC, Proceedings 17.
1MIbid.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
88
• The level of vinyl chloride monomer emissions has been reduced! by approximately 50
percent between 1990 and 1993 in Japan.
• In the UK, member companies have reduced emissions of Red L 1st substances by 89
percent since 1990.
• Member companies of RC in Canada have reduced emissions of all substances (excluding
CO2) by 50 percent since 1992.
More generally, the industry, as a whole has "reduced emissions to the environment, improved
emergency response, reduced transportation mishapsj improved outreach and communication,
safer working conditions, and overall reduced risk."140 Yet, the ILO makes the point that these
indicators are indirect. The RC program does not mandate the use of performance indicators to
measure progress in implementing the RC codes a part of company self-assessment and/or third
party verification.141 As a result, while there is speculation, perhaps valid, that RC has been
tremendously successful, it is impossible to isolate the impact of RC on performance
improvements from other factors.
As a side note, the Chemical industry has received a great deal of recognition for taking a
leadership role in a number of other voluntary initiatives, as well. For example, chemical plants
account for one third of the participants in OSHA's Voluntary Protection Programs (VPP)'42 and
for 60 percent of the documented energy savings in me Netherlands in 1995.143 Again, while there
is no isolated evidence to suggest that the participation in RC led to the industry taking these
leadership positions, the possibility is interesting to note.
Summary of Relevant Findings of the ILO Study on RC and Sub-sector Spin-offs of RC
Chemical distributors, traders, and industry associations have developed their own programs that
commonly employ the RC logo. In all cases, these programs are less pervasive and well
established as RC, but are believed to have contributed significantly to the EHS performance of
their industries. The programs are not presented in detail here, but we provide the following
summary of relevant points.
• Isolating the effects of RC-based voluntary initiatives on EHS performance is highly
difficult.144
1<0ibid.
141IOMC, Proceedings 38. See also IOMC, Proceedings 33.
|42Hanson, OSHA marks 22.
'°RJetbergen, Proceedings..
144ILO, Voluntary 72,80-81.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
89
IV.
Due to the lack of direct performance measurement and the newness of many of the
RC-based voluntary initiative, evaluation is difficult.145
SUMMARY OF RELEVANT FINDINGS and PROPOSED MANAGEMENT
GUIDELINES FROM COMPREHENSIVE INTERNATIONAL and STATE
LEVEL STUDIES
We have been able to draw our own conclusions in separately reviewing the initiatives discussed
above. In addition, we feel that it would be valuable to review the findings of other research
studies that have evaluated voluntary measures on a more comprehensive, aggregate basis. Below
we review three such studies that discuss voluntary initiatives and/or alternatives to "command
and control" at a multi-national level.
Environmental agreements: Environmental effectiveness
by the European Environment Agency
The European Environment Agency (EEA) published this document to assist the European
Parliament's debate on environmental agreements. The report examines six negotiated agreements
(out of more than 300 across the European Union) currently being administered in France,
Germany, Sweden, the Netherlands (two agreements), and Portugal. The authors emphasize that
quantitative evaluations are hampered by lack of available data in all but one case (the
Netherlands), but qualitative evidence suggests that valuable benefits result from the agreements.
The report identifies common difficulties with the agreements, and provides some guidelines for
effective management of voluntary negotiated agreements including:
Set clear targets
Ensure transparency during negotiation of the terms of the agreement
Negotiate reliable monitoring and reporting agreements
Systematically evaluate the results of the agreement against the targets
Make provisions for access to information regarding the agreement
Use negotiated agreements as a complement to other policy measures
Use negotiated agreements in situations where regulatory or fiscal instruments would be
difficult to administer
"ILO, Voluntary %\.
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Additional key findings include:
• Negotiated environmental agreements are useful in creating greater awareness of a
subject, facilitating information exchange, in the creation of a consensus, and in facilitating
technical change.
• Strong incentives for participation are important.
* Lack of program monitoring is pervasive.
• It was impossible to prove that negotiated environmental agreements lead to
environmental effectiveness in this case due to a lack of monitoring by all but one project.
Negotiated environmental agreements are most functional under the following conditions:
Pro-active industries or businesses are involved.
A small number of partners or high organization level of signatory partners are involved.
Industry sectors that have matured and face little competition are involved.
Environmental problems are of limited scale.
There are a limited number of sources of pollution.
Long-term targets (early signal) have already been established.
Voluntary environmental measures: What are they? What makes them work?
Prepared by John Moffet and Francois Bregha of Resource Futures International for The New
Directions Group
This paper was prepared for the New Directions Group to provide an overview of issues and
trends in the realm of voluntary environmental measures, with particular emphasis on
opportunities for improvement of voluntary initiatives within Canada. Voluntary initiatives taking
place in the U.S., Canada, and Europe are discussed, with emphasis on incentives for participation
for both industry and government, critical success factors, key design and process features,
appropriate measurements of achievements, and effective public participation in voluntary
initiatives.
Given that most voluntary initiatives challenge industry to alter some basic aspect of how they do
business, rather than just to implement quick technical fixes, the following barriers to success
often exist:
Uncertainty about future regulatory requirements
"Concerns about potential adverse effects of disclosing environmental shortcomings"
"Concerns about free riders"
Short-term cost issues with respect to capita] investments and long-term pay back
"Inconsistent consumer behavior"
Lack of expertise
"Inadequate indicators to measure progress"
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In order to overcome these barriers, the following managerial guidelines must be followed:
• Establish and monitor clear, measurable objectives from a measured baseline throughout
the life of the project.
Relate the initiative to the organization's core values to ensure cultural transformation.
Secure the continuous, explicit commitment of senior managers to the project.
Ensure a steady and adequate commitment of resources to the project.
Develop capacity to communicate across traditional organizational barriers, i.e., through
cross-functional teams.
Provide consistent signals to project participants to maintain project momentum.
Build the institutional capacity of the partners to act as leaders on the issue at hand.
Provide useful information and the analytical tools necessary to process it.
Effectively communicate and market the project such that program proponents are clearly
recognized to differentiate them from their competitors.
• In industry-wide initiatives, provide both positive incentives for participation and negative
incentives for not participating.
• Exchange "pre-competitive information" to ensure that all partners, who may also be
competitors, are aware of the available techniques for addressing environmental problems.
• Ensure credibility of program claims by subjecting them to third party verification.
Empowering the community: Information strategies for pollution control
By Tom Tietenberg and David Wheeler
This paper compiles and identifies what is known about the effectiveness of information disclosui
strategies as a "third wave" of pollution control policy. The authors discuss multiple government
and industry information disclosure strategies, including a number of voluntary initiatives such as
the 33/50 program, and present a series of research study findings on this topic. They conclude
with a discussion of overall effectiveness of information strategies and the key determinants of
successful strategies. Their recommendations include:
• Provide easily understandable, accessible, and moderate amounts of information so as to
avoid information overload.
• The relay of information through direct means is much more effective than through mass
communication channels.
• Pay attention to incentives created by complementary aspects of disclosure programs.
Incentives for environmental improvement: An assessment of selected innovative programs in the
States and Europe
By Daniel P. Beardsley. Prepared for the Global Environmental Management Initiative (GEMI).
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EMI
92
This report, one of three published by GEMI on the subject of "Industry Incentives for
Environmental Improvement," reviews a number of programs in the states of Minnesota,
Massachusetts, and New Jersey and international efforts in the Netherlands, Sweden, and the
United Kingdom. Beardsley finds that among many innovative efforts throughout the U.S. and
Europe to improve the effectiveness and efficiency of environmental protection, there are certain
identifiable characteristics among the successful programs.
Key Findings:
• Economic incentives associated with participating in most voluntary programs are
considered marginal. However, there is little doubt that they Eire more cost-effective than
traditional command-and-control methods.
• Successful voluntary programs are supported by some legal context.
• Systematic evaluation is very weak, and it is therefore difficult to assess program
effectiveness.
• The cultural expectations of the general population in which potential partners operate is a
significant factor in determining whether or not to participate in voluntary initiatives. For
example, the general populous in both Minnesota and the Netherlands tend to value
environmental protection more than in other geographic areas;, and industry responds to
those values by participating in voluntary programs.
• Industry participants appreciate the cooperative nature of voluntary programs.
Recommendations:
Establish and communicate simple, clear objectives.
Offer bold economic incentives in order to ensure a large degree of participation.
Enable participants to have a major voice ill establishing program goals.
Grant flexibility to industry in implementing features that will meet partnership objectives.
Seek to establish trust among stakeholders and participants.
Minimize transaction costs of participation.
V. LESSONS LEARNED RELEVANT TO EPA'S PARTNERSHIP PROGRAMS
In the sections above, we have comprehensively reviewed a number of non-EPA partnership
programs and related reports. The structure and evolution of these programs provide many
opportunities for contrast with EPA's management of partnership programs. Rather than doing an
extensive comparison, however, we have decided to single out and condense the lessons learned
from these programs that are most relevant to partnership program management at EPA. Key
lessons learned include:
• Participation of industry in the development of industry-focused partnership programs is
crucial to their success (as partnership programs). In particular, it is important for partners
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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to agree on program success indicators. The Alliance for Environmental Innovation
provides excellent guidelines for designing performance measures.
Especially for industry partners, the potential for economic benefit is an incentive of
critical importance.
Opportunities to improve relations with regulators and to enhance corporate image are
also important incentives for companies to participate in partnership programs.
Partnership programs work best when they complement regulations (or previously
established, long-term goals, as in the case of the Dutch covenants). Nevertheless, because
the opportunity to prevent new regulations can also be an important incentive to
participation, partnership programs can also work to address unregulated issues.
The success of OSHA's programs is reflected in the extent of integration of the
partnership philosophy throughout the organization. Achieving this integration has taken
time and effort focused on cultural change, however.
OSHA has chosen to exercise some central coordination and control over partnership
programs by establishing an initiative known as the Strategic Partnership Program (SPP).
It is still too early to know how well the SPP has worked; it would be worthwhile to
revisit this question in a year.
DOE and EPA both have partnership programs that address climate change. There appear
to be significant opportunities for collaboration through the joint EPA-DOE Voluntary
Registry Program.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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Annotated Bibliography
Beardsley, D.P. 1996. Incentives for Environment^ Improvement: An Assessment of Selected
Innovative Programs in the States and Europe. For the Global Environmental Management
Initiative (GEMI). Washington, DC: GEMI.
This report, one of three published by GEMI on the subject of "Industry Incentives for
Environmental Improvement", finds that among many innovative efforts to improve the
effectiveness and efficiency of environmental protection, a select few at the state level (in the
U.S.) and in Europe have spurred improvements in environmental quality. In addition, benefits of
improved relationships between the private sector and regulators found at the federal level in the
U.S. are present in this context, and to a greater degree. The European and state-level initiatives
are viewed, contrary to federal programs, to be wellJ-planned and administered. The author bases
these conclusions on analyses of four state-level programs and selected programs in the
Netherlands, Sweden, and the UK.
Bergman, P., R. Kane, and J. Kildow. 1997. United States policy for mitigating global climate
change. Waste Management, No. 5-6, Vol. 17, 309-,314.
This paper delineates the U.S. Department of Energy's efforts to implement the U.S. policy on
climate change. In addition to a discussion of the recent U.S. policy shift in response to the
realization that the FCCC targets are not being met and a brief presentation on the potential for
the ocean storage of carbon, the effectiveness of the DOE Climate Challenge Program is analyzed.
Brostoff, S. December 1,1997. OSHA creates cooperative program for safety testing. National
Underwriter, Vol. 101, 1+.
This brief article announces the establishment of OSiHA's Consultation Program. The history,
program structure, incentives, and regulatory implications are discussed.
Edison EieCtrk Institute (EEI). 1999. http://www.eej.org/lndiistrv/enviro/global.htm.
This web site describes EEI's position on effective management of global climate change issues
and their role in assisting electric utilities to voluntarily reduce, avoid, or sequester greenhouse
gas emissions as part of the US Department of Energy's Climate Challenge program. Available on
the web site is the Climate Challenge Report: Voluntary Programs Work, which documents the
EEI's instrumental role in developing Climate Challenge initiatives and each initiative's potential
for greenhouse gas reduction.
Environmental Defense Fund (EDF). January 26,1999. Environmental Defense Fund Praises
Clinton Climate Proposal. http://www.edf.org/pubs/new^releases/l999/ian/b climate.html.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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Environmental Defense Fund. February 7, 1995. EDF, PSE&G Ink Pact To Turn CO2 Cut
Promise Into Performance, http://vyww.edf.org/pubs/newsreleases/1995/feb/dunpsep/html.
Environmental Defense Fund. April 20,1994. EDF Unveils Pact With PSE&G Creating
Environmental "Backstop." http://www.edf.org/pubs/newsreleases/1994/apr/d%5Fpseg.html.
European Environment Agency (EEA). 1997. Environmental agreements: environmental
effectiveness, Environmental Issues Series No. 3, Vol 2. Copenhagen: EEA.
This evaluation of European negotiated environmental agreements is targeted at policy makers
and the public and timed to assist the European Parliament's debate on environmental agreements.
The report examines six agreements in various countries and managing various issues for
environmental effectiveness. The authors emphasize that quantitative evaluations are hampered by
lack of available data in all but one case (the Netherlands), but qualitative evidence suggests that
valuable benefits result from the agreements. The report identifies common difficulties with the
agreements, and provides some guidelines for effective management of voluntary initiatives.
Fastiggi, E. 1999. Catalyzing Environmental Results. Lessons in Advocacy Organization-
Business Partnerships. Boston: The Alliance for Environmental Innovation.
The Alliance for Environmental Innovation (AEI) produced this document as a means of
disseminating lessons learned from a decade of experience in establishing cooperative partnerships
with companies. AEI has pursued such partnerships toward the end of creating environmentally
aggressive initiatives that generate business benefits. The report highlights successful strategies
and program models for similar alliances and proposes guidelines that have emerged as reliable
rules of conduct in AEI's advocacy-business partnerships.
Picker, Christy. April 29,1999. Personal communication.
Figura, S. March, 1997. Is OSHA reform on target? Occupational Hazards, Vol. 59, 23-25.
This article reviews OSHA chief Joseph Dear's progress toward his original mission of bringing a
more cooperative regulatory approach to the agency when he accepted his position as chief in
1993. Particular note is given to the Consultation Program and the Voluntary Protection Program.
Fleming, S. Fall/Winter 1998. Assistant secretary Charles Jeffress discusses plans for OSHA. Job
Safety and Health Quarterly, No. 9, Vol. 20,16-20.
Jeffress discusses his prior experience at the state level in North Carolina and his goals for the
federal position. He stresses cooperative efforts with employers, though conceding that these
efforts are only effective with a regulatory enforcement mechanism backing them.
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APPENDIX F—PARTNERSHIP PROGRAM MANAGEMENT REVIEW
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Gnee Library. Thematic references. Voluntary approaches, http://www.feem.it/gnee/direc/ref2.html.
i
Hanson, D. March 31, 1997. OSHA marks gains with voluntary plans. Chemical and Engineering
News, Vol. 75,22.
This article documents the growth of OSHA's VPPs since their inception in 1992.
Hennicke, P. and S. Ramesohl (project coordinators). 1998. Interdisciplinary Analysis of
Successful Implementation of Energy Efficiency in the Industrial, Commercial and Service
Sector. Final Report. Volume II. Documentation of Policy Case Studies. Chapter 1. The Danish
CO2 Tax On Trade and Industry, httpr/Avww.psvchologi^uni-kiel.de/nordlicht/sme/bl.htm.
This paper analyzes the Danish CO2 tax on trade and industry, with some focus on the role that
alternative policy tools such as agreements play in nieeting CO2 reduction goals. Preliminary
analysis of the effectiveness of agreements indicates that they have, in conjunction with investment
grants, contributed to reductions.
Hoffman, M. 1998. Employer groups divided on OSHA auditor idea. Business Insurance, No.
32, Vol. 3+, F9.
This article presents opposing views on the most repent controversial issue at OSHA, the
proposal to give third party auditors the authority to exempt workplaces from federal fines for 2
years under the VPP.
International Labour Organization (ILO). 1999. Voluntary Initiatives Affecting Training and
Education on Safety, Health and Environment in the Chemical Industries. Geneva: ILO.
This document is a report developed for discussion at the Tripartite Meeting on Voluntary
Initiatives Affecting Training and Education on Safety, Health and Environment in the Chemical
Industries in Geneva, 22-26 February 1999. The report surveys voluntary initiatives within the
arenas of health, safety, and the environment, with particular emphasis on chemical industry
initiatives. The benefits of voluntary initiatives are qualitatively documented, and the difficulty in
isolating and measuring quantitative benefits is discussed.
Inter-Organization Programme for the Sound Management of Chemicals. 1997.
Proceedings of the OECD Workshop on Non-Regulatory Initiatives for Chemical Risk
Management. An OECD Environmental Health and 'Safety Publications Series on Risk
Management No. 7., OECD/GD(97)97. Paris: OECD.
This publication contains papers presented and the consensus of findings from the OECD
Workshop on Non-Regulatory Initiatives for Chemical Risk Management held in the U.S. at
Crystal City, Virginia on 10-12 September, 1996. Voluntary programs from around the world
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were presented either extensively in panels or marginally in poster format. Panel presentations
covered four general program types including: Industry Initiatives, Challenge Programmes,
Bilateral/Multilateral Agreements, and Other Agreements. The document describes the history,
participants, political setting, and progress of each of these initiatives and concludes with a
statement of workshop findings.
Kinsman, J.D., M. McGrath, R. McMahon, M. Ricker, R. Shiflett, and R. Tempchin. June
23-28, 1996. A Status Report on Climate Challenge Program's Voluntary Initiatives to Manage
US Electric Utility Greenhouse Gases. Presented at the 89th Annual Meeting & Exhibition, Air &
Waste Management Association, Nashville, TN. http://www.eei.orp/lndustrv/enviro/manus.htin.
This report discusses incentives for government to develop and industry to participate in
voluntary programs such as Climate Challenge in reaching climate protection goals. Achieved
reductions in emissions are documented and predictions for quantities of further reductions
through the Climate Challenge program are presented for the year 2000. Finally, the five specific
Climate Challenge initiatives led or supported by the Edison Electric Institute (EEI) are discussed
in detail.
Krarup, S. and A. Larsen. 1998. Energy Efficiency through Voluntary Agreements. AKF.
http://www.akf.dk/eng/98/energierT.htm.
This paper compares the different approaches to environmental voluntary agreements in five EU
nations including Great Britain, Denmark, Finland, the Netherlands, and Sweden. The approaches
reviewed for contrasts and similarities in policy formulation and the design, implementation, and
effects of the agreements.
Kristof, K. and S. Ramesohl. June 9-14,1997. Can Industry Do Better Alone?: A Critical
Discussion of the Voluntary Agreements on Climate Protection of the German Industry. In:
Sustainable Energy Opportunities for a Greater Europe, The Energy Efficiency Challenge for
Europe: Proceedings of the 1997 European Council for an Energy Efficient Economy (ECEEE)
Summer Study, Panel 3 - ID 123, Part 2. Czech Republic.
This critique of the German government's voluntary approach to climate protection, the
"Declaration of German Industry for Climate Protection" (DCP), finds the program to be an
ineffective instrument for meeting climate protection goals. The authors provide a number of
suggestions for improvement.
Larsen, A., S. Krarup, and T.P. Kramer. August 23-28, 1998. A Policy Analysis of Voluntary
Agreements for Energy Efficiency in Industry. In: Proceedings of The 1999 ACEEE Summer
Study on Energy Efficiency in Buildings. Pacific Grove, CA: Asilomare Conference Center.
http://www.akf.dk/vaie/paDers.htm.
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This paper investigates the design, effects, and implications of voluntary agreements on energy
efficiency in Great Britain, Denmark, Finland, Sweden, and the Netherlands. Of particular interest,
the paper highlights sanctions imposed by select countries in the event of ill-participation or
failure to participate in the voluntary programs.
Moffet, J. and F. Bregha. September 24,1996. Voluntary Environmental Measures: What Are
They? What Makes Them Work? For The New Directions Group, Ottawa, Ontario.
•
This paper was prepared for the New Directions Group to provide an overview of issues and
trends in the realm of voluntary environmental measures, with particular emphasis on
opportunities for improvement of voluntary initiatives within Canada. The paper discusses
incentives for participation for both industry and government, critical success factors, key design
and process features, appropriate measurements of achievements, and effective public
participation in voluntary initiatives.
Newman, J. 1997. Policies and Measures for Common Action Electricity Sector: Utility
Voluntary Agreements to Reduce Greenhouse Gas Emissions. Working Paper 17, Annex I Expert
Group on the UN Framework Convention on Climate Change.
This paper reviews current voluntary agreements (VAs) in the electric utility sector in Canada, the
United States, and the Netherlands in seeking to determine the potential for the development of an
international, voluntary, greenhouse gas reduction program. Specifically, the author reviews the
Climate Challenge Program (U.S.), the Voluntary Challenge and Registry (Canada), and
Environmental Action Plan (the Netherlands). The fundamental difference between target-based
and "no-regrets" program models is emphasized as an important determinant of program
outcomes.
O'Brien, R. 1997. Global Warming and Voluntary Initiatives: The Role of the Voluntary
Challenge and Registry in Canada. http://www.web.npt/~robrien/papers/vcroaper.htmL
This paper suggests that Canada's reliance on voluntary instruments, specifically the development
of the Voluntary Challenge and Registry (VCR), as the primary means of meeting its
responsibilities for reductions in greenhouse gas emissions is largely a response to industry and
union pressure. The author documents that the VCR is falling far short of its targeted reductions
and analyzes reasons for the performance failure. He concludes that as a result of this
ineffectiveness and the legally binding nature of the Kyoto agreement, the Canadian legislature is
looking to move away from voluntary methods and toward economic instruments backed by
regulatory oversight to meet its commitments for 2010.
Oliver, Cathy. May 3, 1999. Personal communication.
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Rietbergen, M., J. Farla, and K. Blok. June 11-12, 1998. Quantitative Evaluation of Voluntary
Agreements On Energy Efficiency, In: Proceedings of the International Workshop on Industrial
Energy Efficiency Policies: Understanding Success and Failure. Utrecht: AKF.
http://www.akf.dk/vaie/papers.htm.
This paper evaluates the effectiveness (based on three independent assessments) and efficiency of
voluntary agreements on energy efficiency in the Netherlands. The authors find that a significant
portion of the energy efficiency improvement of participating organizations are a result of
voluntary agreements and further conclude that voluntary agreements are more cost-efficient in
meeting energy efficiency objectives than strictly subsidy-based schemes.
Rood, Marcy. May 3,1999. Personal communication.
Sherrill, L. And J. Weinberg. Summer 1998. OSHA's VPP gets a little help from its friends.
Job Safety and Health Quarterly, No. 4, Vol. 9, 29-34.
This article discusses the development of the VPP Volunteer Program. Motivations for
volunteering are discussed, and OSHA describes what it sees as the program's successes.
Tietenberg, T., and D. Wheeler. October 23-25, 1998. Empowering the Community:
Information Strategies for Pollution Control, Presented at Frontiers of Environmental Economics
Conference, Airlie House, VA. http://www.worldbank.org/nipr/wprk_papers/ecoenv/index.htm.
This paper attempts to compile and identify what is known about the effectiveness of information
disclosure strategies as a "third wave" of pollution control policy. The paper sets the stage for the
discussion by acknowledging a growing need for broader use of diverse and resource-efficient
policy tools, the declining costs of information dissemination, and growing demand for
information to influence market forces. After reviewing the three types of situations influenced by
information dissemination, the authors discuss multiple government and industry information
disclosure strategies and research study findings on this topic. They conclude with a discussion of
overall effectiveness of information strategies and the key determinants of successful strategies.
Tyson, P. November, 1995. OSHA has some friends in high places. Safety and Health, Vol. 152,
29-30+.
This article discusses an uncharacteristic alliance between member corporations of the VPPPA
and organized labor in testifying against proposed changes to the OSHA reform bill.
U.S. Department of Energy. 1999. http://www.ccities.doe.pov/what is.shtml.
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This web site provides a description of the U.S. Department of Energy's (DOE) Clean Cities
program and chronicles each Clean Cities initiative. Of particular interest, the 1999 version of the
"Road Map" to Clean Cities document is available in PDF format.
U.S. Department of Energy. 1996. Voluntary Reporting of Greenhouse Gases 1995.
http://www.eia.doe.gov/oiafyvrggQ5/chap3.htmI and http://wwW.eia.doe.gov/oiaf/vrggQ5/chapl .html.
This report describes the development of the Voluntary Reporting Program, which was
established pursuant to the enactment of the Energy Policy Act of 1992, through which entities
can report actions taken to reduce greenhouse gas emissions to the Energy Information
Administration (EIA). The report evaluates, among many different issues, project level reports of
greenhouse gas emissions reduction and carbon sequestration to the DOE under Schedule n of
Form EIA-1605 and EIA-1605EZ. The document asserts that despite the difficulty in evaluating
the effects of project-level activities due to their relatively small size, such evaluations enable the
process of identifying activities that would not have occurred absent project momentum. The role
that 16 different DOE and EPA based voluntary programs have played in promoting the 645
evaluated projects is highlighted, with particular emphasis on the electric utilities Climate
Challenge program.
Vira, Carol. April 27, 1999. Personal communication.
Weinberg, J. Summer 1997. OSHA cooperative efforts: a good deal for workers and employers.
Job Safety and Health Quarterly, Vol. 8, 11-15.
This article documents the effectiveness of OSHA's voluntary CP and VPP, and surveys new
initiatives within OSHA to improve performance even further.
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APPENDIX G
BIBLIOGRAPHY
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Appendix G
Bibliography
Beardsley, D.P. 1996. Incentives for Environmental Improvement: An Assessment of Selected
Innovative Programs in the States and Europe. For the Global Environmental Management
Initiative (GEMI). Washington, DC: GEMI.
Bergman, P., R. Kane, and J. Kildow. 1997. United States policy for mitigating global climate
change. Waste Management, No. 5-6, Vol. 17, 309-314.
Boger, D. and C. Stackpole. 1998. Opportunities to Strategically Manage the U.S.
Environmental Protection Agency's Partnership Programs. Report prepared for U.S. EPA, OR.
Brostoff, S. December 1,1997. OSHA creates cooperative program for safety testing. National
Underwriter, Vol. 101,1+.
The Cadmus Group. 1999. Characterization of Selected EPA Partnership Programs. Final report
prepared for U.S. EPA, OAR.
Davies, T. and J. Mazurek. 1996. Industry Incentives for Environmental Improvement:
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Edison Electric Institute (EEI). 1999. http://www.Ki.org/IndusWenviro/global.htm.
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Fastiggi, E. 1999. Catalyzing Environmental Results. Lessons in Advocacy Organization-
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Figura, S. March, 1997. Is OSHA reform on target? Occupational Hazards, Vol. 59,23-25.
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Fleming, S.I998. Assistant secretary Charles Jeffress discusses plans for OSHA. Job Safety and
Health Quarterly, No. 9, Vol. 20, 16-20.
Global Environmental Management Initiative. 1994. GEMI Reference to EPA Voluntary
Programs. Washington, DC: GEMI.
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Hanson, D. 1997. OSHA marks gains with voluntary plans. Chemical and Engineering News, Vol.
75,22.
Hennicke, P. and S. Ramesohl (project coordinators). 1998. Interdisciplinary Analysis of
Successful Implementation of Energy Efficiency in the Industrial, Commercial and Service
Sector. Final Report. Volume II. Documentation of Policy Case Studies. Chapter 1. The Danish
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Hoffman, M. 1998. Employer groups divided on OSHA auditor idea. Business Insurance, No. 32,
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International Labour Organization (ILO). 1999. Voluntary Initiatives Affecting Training and
Education on Safety, Health and Environment in the Chemical Industries. Geneva: ILO.
Inter-Organization Programme for the Sound Management of Chemicals. 1997. Proceedings of
the OECD Workshop on Non-Regulatory Initiatives for Chemical Risk Management. An OECD
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OECD/GD(97). Paris: OECD.
Kinsman, J.D., M. McGrath., R. McMahon, M. Riqker, R. Shiflett., and R. Tempchin. June 23-
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Krarup, S. and A. Larsen. 1998. Energy Efficiency through Voluntary Agreements. AKF.
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Kristof, K. and S. Ramesohl. June 9-14,1997. Can Industry Do Better Alone?: A Critical
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Europe: Proceedings of the 1997 European Council for an Energy Efficient Economy (ECEEE)
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Larsen, A., S. Krarup, and T.P. Kramer. August 23-28, 1998. A Policy Analysis of Voluntary
Agreements for Energy Efficiency in Industry. In: Proceedings of The 1999 ACEEE Summer
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http://www.akf.dk/vaie/papers.htm.
The Lexington Group and the Conference Board. 1999. Corporate Environmental Management:
A State-of-the-Art Survey.
Moffet, J. and F. Bregha. September 24, 1996. Voluntary Environmental Measures: What Are
They? What Makes Them Work? For The New Directions Group, Ottawa, Ontario.
Newman, J. 1997. Policies and Measures for Common Action Electricity Sector: Utility
Voluntary Agreements to Reduce Greenhouse Gas Emissions. Working Paper 17, Annex I Expert
Group on the UN Framework Convention on Climate Change.
Norton, D. and R. Kaplan. January-February 1996. Using the balanced scorecard as a strategic
management system. Harvard Business Review.
O'Brien, R. 1997. Global Warming and Voluntary Initiatives: The Role of the Voluntary
Challenge and Registry in Canada, http://www.web.net/~robrien/papers/vcrpaper.html.
Rietbergen, M., J. Farla, and K. Blok. June 11-12,1998. Quantitative Evaluation of Voluntary
Agreements On Energy Efficiency. In: Proceedings of the International Workshop on Industrial
Energy Efficiency Policies: Understanding Success and Failure. Utrecht: AKF.
http://www.akf.dk/vaie/papers.htm.
Sherrill, L. and J. Weinberg. 1998. OSHA's VPP gets a little help from its friends. Job Safety and
Health Quarterly, No. 4, Vol. 9, 29-34.
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Tietenberg, T., and D. Wheeler. October 23-25, 1998. Empowering the Community: Information
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Tyson, P. November, 1995. OSHA has some friends in high places. Safety and Health, Vol. 152,
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U.S. Department of Energy. 1999. http://www.ccitie5.doe.gov/whatjs.shtnil.
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htrp://www.eia.doe.gov/oiaf/vrggQS/chap3.html and http://www.eia.doe.eov/oiaf/vrggQ5/chap 1 .html
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U.S. Environmental Protection Agency, OA. 1998. A Catalogue of the Agency's Partnership
Programs. Report EPA100-B-97-003.
U.S. General Accounting Office. 1997. Environmental Protection. Challenges Facing EPA's
Efforts to Reinvent Environmental Regulation. Repprt to Congressional Requesters GAO/RCED-
97-155. Washington, DC: U.S. GAO.
Weinberg, J. 1997. OSHA cooperative efforts: a good deal for workers and employers. Job Safety
and Health Quarterly, Vol. 8,11-15.
Whiting, M. and J.D. Whiting. 1998. Innovative Public-Private Partnerships: Environmental
Initiatives. The Conference Board Townley Global Management Center for Environment, Health
and Safety Special Report 1208-98-RR. New York: The Conference Board.
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