United States
          Environmental Protection
          Agency
Office of
Air and Radiation
430-S-93-002
December 1993
v>EPA    Conference Proceedings
          The Clean Air Marketplace
          Conference and Exhibition
Trie
Clean Air
Marketplace!] 993
New Business Opportunities Created by the Clean Air Act Amendments
September 8-9,1993 • Sheraton Washington Hotel • Washington, D.C.
                               Recycled/Recyclable
                               Printed with Soy/Canola Ink on paper that
                               contains at least 50% recycled fiber

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  This document is a summary of presentations made at an EPA-sponsored
conference.  The views expressed by individual authors are their own and do
  not necessarily reflect those of the U.S. Environmental Protection Agency.

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                               Table of Contents

                                                                           Page
September 8, 1993
Keynote Address — Carol M. Browner	1

Session 1 — Competitiveness, Jobs, and Exports	9
Session 2 — Pollution Prevention and the Clean Air Act  	19

Keynote Address — Professor Michael E. Porter	31

Session 3 — Control Technologies and Services - I
       Session 3A — Electric Power Technologies 	49
       Session 3B — Stationary Source VOCs/Air Toxics Control  	57
       Session 3C — Vehicular Emissions Control Technologies	71
       Session 3D — Alternative Vehicle Technologies	81

Session 4 — Control Technologies and Services - II
       Session 4A — Electric Power Services  	93
       Session 4B — Stationary Source NOX Control Approaches	107
       Session 4C — Vehicular Emission Control Services	117
       Session 4D — Alternative Fuels	123

September 9, 1993
Keynote Address — The Honorable Senator  Max Baucus	139

Session 5 — Role of the Government in Supporting the Clean Air Marketplace
       Session 5A — Federal, State, and Local Regulatory Programs  	147
       Session 5B — Technology Development and Diffusion  	159
       Session 5C — Export Promotion  	177

Keynote Address — Donald A. Deieso	189


Table of Contents                                                          Page i

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                              Table of Contents
                                 (continued)

Session 6 — Connections Among Clean Air Act/ISTE A/Energy Policy Act .     . 197

Session 7 — The Global Clean Air Marketplace - Export Opportunities  .        .211

Session 8 — Looking to the Future - New Directions for
      Environmental Technology      ...             	223

Session 9 — Public/Private Partnerships in Cleaning the Air   		231

Session 10 —  Financing the Clean Air Marketplace
      Session IDA — Financing Companies and Projects	241
      Session 10B — Financing Exports and Investments  .  .  .  .     	249

Appendices
      Appendix A — Conference Program	A-l
      Appendix B — Exhibitors    	  B-l
      Appendix C — Participants .       	    	C-l
Page ii                                                       Table of Contents

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Clean Air Marketplace 1993                                             Page 1
                            Keynote Address by
                            Carol M.  Browner
                            Administrator,  U.S. EPA
                            Introduction by Michael H. Shapiro,  Acting Assistant
                            Administrator, Office of Air and Radiation, U.S. EPA

                            Septembers, 1993
       Thank you very much Steve, and it is a pleasure to welcome all you to the Clean
Air Marketplace.  We are delighted that so many of you chose to attend and share our
vision of  clean air  and a healthy economy.  I would  also  like to acknowledge the
outstanding work that Steve Harper has done in putting together this  conference.
Although  he was very gracious in giving Rob Brenner and I some credit, really Steve has
put this conference together — together with a dedicated  team that he led. He has done
an incredible job of overcoming the many obstacles that the Federal government puts in
the way of organizing successful conferences. I think missing the coffee was a minor
omission and will not effect your performance appraisal  at all, Steve. The performance
reviews take care  of that problem; we well be in good shape for next year's conference.

       It is my pleasure today to be able to introduce my boss, Carol Browner, who will
be giving the welcoming remarks for this conference. Carol was sworn-in in January 1993
as the Administrator of the U.S. Environmental Protection Agency (EPA).  She brings to
the Agency a career of experience in the environmental protection arena, including a blend
of experience in the State and Federal arenas, that gives her important perspectives on the
implementation of environmental programs, and in particular, implementation of the Clean
Air Act.

       Prior to coming to EPA, Carol served as Secretary of the  Department of
Environmental Regulation for the State of Florida from 1991-1993, where among her many
accomplishments was the early implementation of a permit fee program that  would fund
programs  anticipated under the Clean Air Act. That is something that many states have
still not yet completed, but which we are trying hard to get underway.  Before that
position, Carol served as the Legislative Director for Senator Al Gore where, among her
other responsibilities, she assisted in drafting the provisions  of the Clean  Air Act
Amendments of 1990. In introducing Carol Browner, President Clinton cited her record
in building innovative partnerships to protect the environment while promoting economic
growth.  I think the oft-cited example of aDowing Walt Disney World to develop in
exchange for setting aside a significant amount of wetlands for wildlife protection is just
one example of the way in which Carol brings  to the environmental arena a new
perspective on how  we can build partnerships among  the  regulated community, the
environmental community, and state, local, and Federal governments to productively work
                                           Keynote Address — Carol M. Browner

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Page 2	Clean Air Marketplace 1993


towards  important, aggressive  environmental goals, while  at  the  same  time  being
cognizant of the importance of economic development and prosperity. Since coming to
EPA, Carol has initiated numerous activities, including a policy to protect children from
harmful pesticide residues on food, tightened controls over hazardous waste incinerators,
and a major expansion of the important toxics release inventory. She has played a leading
role within the Federal government as an advocate for  pollution prevention programs
within the Federal community. She has also initiated a major reorganization of her Office
of Enforcement, which is  among the recommendations of  the National  Performance
Review.  We are therefore delighted that Carol has been willing to take time from her very
demanding schedule to introduce this conference.  Please join me  in welcoming Carol
Browner.
Address by Administrator Carol M. Browner

       Good morning and thank you.  I want to begin by thanking all of you who have
joined with the Environmental  Protection Agency to co-sponsor these two days.  I think
it is going to be a very productive use of your time.

       What we have in the room are the people at the forefront of air pollution control
in this country. Everyone here has something to do with air pollution control — from my
colleagues at the Environmental Protection  Agency, to the  people who are buying the
technologies, to the people who are inventing the technologies.  It is a group of friends —
people who understand that environmental protection and economic growth go hand-in-
hand.

       As I go around the country and talk to people about my job of promoting public
health by protecting our air, our water, and our land, I run into a lot of people who do not
really understand what it  is  we are all trying  to do.  And the most common, but  false,
debate that I hear is that people believe we must make a choice between environmental
protection on the one hand, and economic growth on the other hand.  I think  too many
people still believe that  the world is divided  into those who  make a living off of our
environment on the one hand, and those who care about it on the other hand. I hear this
when I talk about food safety by regulating pesticide use.  I hear it when we talk about
improving the Superfund program to speed up the revitalization of our cities, and even
when we talk  about improving water quality by strengthening the Clean Water Act and
the Safe  Drinking Water Act.

       But I think you all in this room are living proof that environmental protection can
protect public  health, improve our environment, and at  the same time create new
businesses, new profit, new export opportunities, and new jobs.

       There are many who say that environmental regulations cost a  lot of money: they
are  not  wrong.  The Clean  Air Act Amendments have been projected to reduce air
 Keynote Address — Carol M. Browner

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Clean Air Marketplace 1993	Page 3


pollution by 56 billion pounds per year at a cost of $20-$25 billion. It is a lot of pounds
but it is also a lot of dollars. Many believe the conventional wisdom that the money is just
going down the drain and  represents a net loss of economic resources. I believe they are
absolutely wrong, that the  people who say this do not really understand what we are all
doing, and that if we can inform them, they would come to appreciate the investments and
the return that we get on those investments. The resources, the money, the energy that
is spent on environmental  protection just do not disappear.  Very often, they go to  firms
like the ones represented in this room. Already, environmental protection is a $100 billion
industry.  By  the year 2000, a conservative estimate  says that revenues in just the air
pollution control industry  will rise by $50-$70 billion. These are very, very significant
amounts of money.

       A recent report by the Environmental Protection Agency shows  that stringent
pollution regulations have  put the U.S. air pollution control industry at the very top.  Our
exports of pollution control equipment outstrip all other nations, including Germany and
Japan. And our lead is growing. It is not diminishing.  We are getting even further ahead.
As a direct result of the Clean Air Act, U.S. companies are at the forefront of clean diesel
engine technologies, clean fuel development, improved monitoring technologies, alternate
fuel vehicles, and cleaner paints and solvents.  Our pollution control industry is ready to
help the rest of the world improve air quality.

       Later this month, we will release a report on the domestic environmental protection
industry. I expect that this report will supply us with further evidence of what we already
know: that environmental technology creates jobs  and substantial business growth.
Nowhere is that fact more evident than in the area of air  pollution control.

       Three  years ago,  Congress amended the Clean  Air Act  to  reflect  a  new
understanding of how to reduce pollution and promote growth. I had an opportunity to
participate when the Senate was drafting amendments  to the Clean Air Act, and I will tell
you that if I  knew  then  what  I  know  now,  I might  have written  a  few of those
amendments a little bit differently.  It is quite a challenge to have been on the one side
writing and now be on the other side, helping to implement. Everyone should have this
experience of going back and forth.

       In the Clean Air Act Amendments of 1990, we tried to move toward performance
standards  instead of always specifying exactly what technology has to be used.  We
wanted to be uncompromising about our goal of providing the protection that is important
to  the public, but be flexible in how we  achieved those goals. We set a strict standard of
pollution control, but we  increased the flexibility allowed to states and industries.   I
certainly saw that in my work at the state level in Florida.  Economic incentive approaches
are woven throughout the Act, which also makes the Clean Air Act Amendments of 1990
very different from almost any other major piece of environmental legislation to have been
passed by the  Congress.  The Act sets  up a system of trading air pollution allowances
which will provide economic rewards to companies that cut their sulfur dioxide emissions
                                            Keynote Address — Carol M. Browner

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Page 4	Clean Air Marketplace 1993


below the legal requirement. This trading system will cut acid-rain-causing emissions by
electric utilities by one half in a way that is already saving utilities and their customers
hundreds of millions of dollars a year.

       I think many of you are aware that the first public trading took place earlier this
year and it is now ongoing. I also want to announce today that I will very shortly propose
a new rule called the Opt-In Rule, which will allow other companies, in addition to the
utilities, to opt into this credit emissions trading program and join utilities in trading sulfur
dioxide emission allowances.  This new  phase of our acid rain program will create new
market opportunities for companies in a variety of industries, not just the utilities who
heretofore have participated in the program. I would think that for many of you here, that
is good news. It expands the number of companies looking for the technologies that so
many of you offer. We are also developing rules to encourage states to adopt  the same
kind of  economic incentive programs.  These programs create new markets for new
technology.

       President Clinton believes very, very strongly in market-based incentives. In fact,
in the National Performance Review report, there is a whole section on increasing the use
of market-based incentives not just  in  the Clean Air  Act, but in a  number of  other
environmental laws.  The President has also recently set up the President's Council  on
Sustainable Development, of which EPA  is a member. When we were discussing with the
White House the establishment of such a Council, I strongly encouraged the President to
include all of those who have an interest in the environment in this country. The President
agreed  that  it was important  to have everyone  at  the  table.   So  on  this  Council,
government — state,  local, and Federal  — industry representatives, and environmental
group representatives are all working together to look at how we can change, how we can
do a better job of protecting our environment and allowing for economic growth.

       I have encouraged the Council to  work with the Environmental Protection Agency
to  conduct  a  series  of demonstration  projects  to  identify how  we  can  achieve
environmental results as cheaply as possible.  Some of you may have read about the work
that we did with Amoco in Yorktown, Virginia. Several newspapers have reported on it.
The Wall Street Journal did a lengthy piece on it.  That project demonstrated the potential
to  get equivalent  environmental  results more cheaply.  We worked in a cooperative
manner with Amoco. We looked at the entire facility to see where we could get reductions
and found that in some instances, they could achieve them in places where the regulations
did not  necessarily require reductions.  In instances where the regulations did require
reductions, those reductions would be more costly.  But the effect in terms of air quality
would be the same, one being more expensive than the other. We want to do more of
these joint projects in the future.   I think  ail of you will benefit from the technological
opportunities that will be created  as we  examine alternative ways of achieving  better  air
quality.
 Keynote Address — Carol M. Browner

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Clean Air Marketplace 1993                                              Page 5
       The President has also set aside $36 million  for the Environmental Technology
Initiative at the Agency and will, I  think, make available larger amounts of money in
future years.  This project is expected to provide significant impetus to the environmental
goods and service industry by spurring the development and marketing of Innovative
technologies for pollution prevention and  control.  This is essentially new money to the
Agency.  We have not had this level of funding before in this area and are very excited
about the work that we'll be able to  do in conjunction with you all.

       We are also working with the Small Business Administration.  We are going to be
training people at the Small Business Administration development centers across the U.S.
to provide assistance to small businesses to help them comply with the Clean Air Act. We
are also going to help small businesses that are making, or want to make, environmental
technology, by linking them to businesses that need the technology.  One of the things  I
was able to do in Florida was to set up a  state trust fund to provide financial assistance
to small businesses to comply with the Clean Air Act. Large numbers of small businesses
across this country will be affected by the  Clean Air Act.  Environmental regulations are
new for  them; we want to work with them,  to help them understand what the rules
require, learn what technologies are  available,  and avoid future enforcement actions.

       I  think what distinguishes this Administration from prior administrations is the
recognition that a healthy environment and a healthy  economy go hand-in-hand. You
really can't have one without the other. As we come into the second year of this Congress,
there  are several opportunities for  us — in  the  reauthorizations and legislation that
Congress will be considering — to  use what we've  learned from the Clean Air Act to
promote economic growth along with environmental protection. I want to briefly mention
those.  We will be working to propose legislation  to Congress dealing with food safety
issues, Superfund, water quality, both in terms of the Clean Water Act and the Safe
Drinking Water Act, and the North American Free Trade Agreement.

       I  feel an obligation to explain that while lawyers may be making a lot of money in
the Superfund program, it is not taxpayers' money. It is not money that comes out of the
trust fund that we manage.  Nonetheless,  I think we  would all agree that the Superfund
cleanups are not moving quickly enough. In November of this year, we will propose
legislation to amend the law to spur economic growth rather than  stifle it.  Every one of
us can probably point to a Superfund site in our home towns — a contaminated urban site
that is just lying idle — that the developers and the bankers do not want to touch.  They
are afraid of becoming liable under the law. As a result, the developers go out into the
farmlands and the woodlands and destroy those areas, rather than using the areas that
already have all of the urban services like water and electricity.  We want to address these
problems in the Superfund  law.  We want to provide incentives for people to purchase
these vacant sites, to clean them up,  and return them to productive community use. The
result would be  a revitalization  of  our urban areas, a preservation  of the green  areas
outside of our cities, and a bigger market for remediation technologies.  We want to look
at all of the technologies that exist, we want to be creative, we want to allow more people
                                            Keynote Address — Carol M. Browner

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Page 6                                              Clean Air Marketplace 1993
to use all that great technology and innovation that exists in this country to get these sites
cleaned up and put back into productive use for the citizens of those towns and cities.

       This same principle  of encouraging innovation is also  guiding our proposed
amendments to the Clean  Water Act.  The  Senate is currently working on revising the
Clean Water Act, one of the original environmental laws passed by the Congress.  What
we'd like to do in the Clean Water Act is require communities in a given watershed region
to identify the sources  of water pollution in their area and then come  up  with the best
solutions.  Again,  I believe  that this will spur creativity  and promote innovation and
economic growth.  Rather  than suggesting that one solution works for every watershed,
let us look at each individual watershed, figure out what works best, what  is causing the
biggest problem, and let us put our resources into solving that problem.

       Later today, I will announce the work that we will be doing on reauthorization of
the Safe Drinking Water Act, which protects the water that you drink out of your tap
every day.  As the technologies have grown, and as our ability to measure what is in the
drinking water supplies has grown, so have costs of compliance grown for the cities. The
President has called for the creation of a $600 million fund in  the first year, going to $1
billion in the outyears.  We would give this money to the states and they would loan it to
communities so that they could put in place the technologies to make sure that their water
supply is safe. We also are asking that for the very small systems, for which the costs can
sometimes be rather prohibitive, we give greater flexibility in choosing technologies.

       What is important  in all of these areas is the environmental  goal — we cannot
compromise the standards.   We cannot set standards that do  not  provide levels of
protection to those  people most affected in this country, whether it be people who live
around a particular Superfund site or who live in an urban area, whether it be the elderly
or the children. But at  the same time, we must provide flexibility in how we reach those
goals.   We have to work  with the industries, work with the  companies such  as those
represented here who  are developing the technology, work with our cities  and  our
communities to give them the flexibility to meet the standards that protect the health of
the people. A lot of people talk about how  harsh environmental standards are and how
stringent they have become.  But when I can actually have a frank and open discussion
with people, whether they be mayors or industry representatives, I always find  that it is
not the standard per se  that is causing the problem; it is the methods by which they have
to achieve the standards.  I want to make sure that we give people the  tools to find the
very, very best and the most cost-effective way of achieving those standards.

       Let me say something briefly about  the North American  Free Trade Agreement.
1 would presume that everybody in this room is aware of what NAFTA is. It has certainly
been in the newspapers enough recently.  Someone said  to me  that they  thought most
people thought NAFTA was a place where you buy automobile parts.  Not true. But let
me explain to you why  NAFTA is important to you, and maybe that is something that you
have not had an opportunity on which to reflect. The most  important thing about NAFTA
 Keynote Address — Carol M. Browner

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Clean Air Marketplace 1993                                             Page 7
for the people here today is that it will expand the market for environmental technology,
perhaps on a scale we have never seen before.

       NAFTA was negotiated in the last administration. When President Clinton came
into office, he said we need to look at the environmental issues associated with opening
up trade  between the United States, Mexico,  and Canada.   We have just completed
negotiating a side agreement to NAFTA, focusing specifically on the environment. This
side  agreement will  make it  harder  to pollute in all three  countries —  United  States,
Mexico, and Canada. It will also increase the incentive for Mexico in particular to enforce
its environmental laws, thereby creating a demand for technologies so that they can bring
down the emissions and achieve compliance with their laws.

       NAFTA will create  jobs all  over  this country,  particularly  in  the  field of
environmental technology.  I would ask each and every one of you to look at NAFTA to
understand the opportunities created by the side agreement for the work you do, including
the opportunity to export technologies to Mexico and perhaps Canada.

       Over the next two days, you are going to be able to participate in many interesting
debates and  discussions, which is only fitting in a field that is  so vital, vibrant, and
growing as this one. I would imagine that if we had had this conference  10 or 15 years
ago, we would not have  had  20 co-sponsors, nor quite the number of people attending.
We have had several conferences similar to this one in other areas across the United States
and they have all been very, very well attended. Over the next couple of years we  would
expect to see the numbers grow, and hopefully double.  One of the opportunities  in you
all coming here is not just to hear about what we are going to be doing, but also to hear
about what each other  is  going to be  doing.  It is an opportunity for those of you  on the
sell side to discover markets for your products and an opportunity for companies  on the
buy side to learn about the  latest ways to comply with the law more cost-effectively.

       In the environmental debates that lie ahead, we need your help. You all benefit in
many instances from the way the laws are written.  You can also be hurt by how the laws
are written.  We really need you to help us. Together, we can get the flexibility that we
believe is so important in  protecting the environment and that I know you all need  if your
businesses are to grow and expand. In all of these areas — air, water, Superfund — there
will be opportunity to work together.  We encourage you to  get involved.

       When I tell audiences about the huge opportunities that exist in this industry and
the environmental technology industry, they are astounded. They have no  idea about the
opportunities that exist for this country, both domestically and internationally — the jobs
that can be created, the return on investment that can be made. We need to do a better
job of telling the public that environmental technology is something in which this country
can be an international star and an  international leader. It  is true.   It  is happening.  I
encourage you to talk to the people in your communities, your members of Congress, and
your colleagues in the business community.
                                            Keynote Address — Carol M. Browner

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Page 8                                        Clean Air Marketplace 1993
 Keynote Address — Carol M. Browner

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Clean Air Marketplace 1993
                                  Page 9
                          Session 1
                          Competitiveness, Jobs, and Exports
                          September 8, 1993
                           9:30 a.m. - 71:30 a.m.
                          Moderator:
                          Panelists:
Jeffrey C. Smith
Robert Brenner
John Quarles
Professor Paul Templet
Dr. Richard Klimisch
Daniel Noble
Introduction
       Jeffrey C. Smith, Executive Director  of the Institute of Clean Air Companies,
summarized the issues of this session into three brief questions:

       •      What impact do the Clean Air Act Amendments (CAAA) have on business
             profits?

       •      Are there new business opportunities, or potential opportunities, created by
             the CAAA?

       •      How do we quantify these impacts?

       Although  it is difficult to measure the exact  size of the  air pollution control
industry, this market has the potential to be one of the fastest growing sectors of the U.S.
economy. Full  implementation of the CAAA will create tens of thousands of high-tech,
highly paid jobs a year.  Moreover, by forcing U.S. businesses to take the lead  in
developing innovative pollution control technology, the CAAA will create important new
export opportunities as other nations implement tougher environmental regulations. As
an example, there is an increase in demand for U.S. pollution control technology in Asia.
To date, however, the U.S. air pollution industry- while generating a trade surplus- has not
experienced the growth predicted when the CAAA were enacted in 1990.
                                 Session 1 — Competitiveness, Jobs, and Exports

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Page 10                                             Clean Air Marketplace 1993
Presentations

           Robert Brenner, Acting Deputy Assistant Administrator, U.S. EPA Office of
           Air and Radiation, reminded the audience that more regulations on business
           cannot be expected to necessarily result in more business opportunities. While
           keeping this in mind, it is clear that  sound environmental  regulation, by
           maximizing  the  flexibility  allowed  to business,  potentially  can be  very
           compatible with fostering new market opportunities.  There are  numerous
specific examples of companies taking advantage of opportunities created by the CAAA
to increase their profits or expand their work force:

             Strict U.S. regulations encouraged a producer of diesel engines to invest
             heavily in the development of cleaner technology.  This investment has
             allowed the firm to compete very favorably in nations that are beginning
             to implement tougher standards.

       •     Numerous  substitutes,  either  new  compounds  or new  uses of  old
             compounds, have been discovered for toxic chemicals in the production of
             many  goods.  The  aerospace industry, for example, has developed new
             techniques to strip paint from planes. These techniques emit less air toxics
             and save $15,000 per plane.  AT&T also has greatly reduced its emissions
             of  toxic  chemicals  while reducing  costs through the  use of a natural
             substitute.  The 3M Corporation is saving $3-$7 million a year through a
             program that substitutes cleaner solvents.

       •     The CAAA have also greatly encouraged the development of whole new
             sets of innovative technologies to combat nitrogen oxide (NOX)  emissions,
             which will help  reduce urban ozone levels.   Bechtel  Corporation, for
             example,  has developed scrubbing  technologies  that will reduce  NOX
             emissions by 90 percent, and will reduce sulfur oxide (SOX) pollution as
             well. The corporation expects demand for this product to rise  as a result
             of the CAAA.

       •     The CAAA regulations  on SO2  have also  created significant business
             opportunities for firms producing scrubber technology and cleaner burning
             fuels.  For instance, Custom Coals has recently developed a line of self-
             scrubbing coal, in which SO2 is removed as it is  burned.  This coal should
             be  in high demand  from electric utilities.

       •     The costs of reducing CO2 emissions have also  been reduced by the fact
             that some  new powerplant  technologies and  processes have  reduced
             utilities' consumption of electricity as well as SO2.  These processes also
             often result in the production of gypsum, a marketable product.
 Session 1 — Competitiveness, Jobs, and Exports

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Clean Air Marketplace 1993                                             Page 11
       •      Argonne National Labs has invested heavily in developing a potentially
             profitable system to convert solid waste to fuel, while separating out metal,
             glass, and plastic.

       •      The restrictions on using chlorofluorocarbons (CFCs) in air conditioners has
             spurred investment in a number of companies as they race  to develop
             competitive alternatives.  For instance, some firms have been  developing
             potentially  profitable  citrus-based  substitutes  for  CFCs.   Some  CFC
             alternatives developed also help reduce the energy consumption of air
             conditioners.

       •      In the auto industry,  regulations have created new  opportunities  for the
             producers of new and improved catalysts and engine parts that help reduce
             emissions.  In the longer run, the need to switch to alternative fuels will
             help create whole new markets and opportunities. Increased  reliance on
             alternative fuels will also draw the domestic demand for energy away from
             imported oil to domestically produced forms of energy such as solar power,
             electricity, and natural gas.

       These examples of companies benefitting from the CAAA represent just the tip of
the iceberg; EPA is still in the early stages of implementing the Amendments, and business
opportunities will increase  greatly  as EPA strives to attain even tougher emissions
reduction standards in the future.

       The compatibility of environmental regulation and economic growth should not be
so much  of a surprise. The efforts to reduce pollution and maximize profits in a business
share many of  the same basic principles, including using energy more efficiently, and
recycling or reusing resources as much as possible.
           John Quarles, Esq., Partner at Morgan, Lewis and Bockius, helped develop the
           Clean Air Act when he was at EPA in the 1970s.

           It is  obvious that there are going to be significant business opportunities
           created by the CAAA. A great deal of money is being spent — clearly going
           in someone's pocket — and jobs will therefore be created. This, however, is
not the issue on which  we should be focusing.  We should focus on whether the jobs
created by environmental regulation will be canceled out by the fact that  the regulations
create impediments to U.S. firms' ability to compete in a global market.  There are two
effects that regulation  has on  firms' competitiveness:   (1)  it increases  U.S.  firms'
                                  Session 1 — Competitiveness, Jobs, and Exports

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Page 12	Clean Air Marketplace 1993


expenditures relative to foreign competitors; and (2) it imposes the additional burden of
a cumbersome regulatory process. Both effects represent a drag on competitiveness, but
the latter is more dangerous.

       The following are a few examples of how increased costs and regulatory red tape
have hindered competitiveness:

       •     Environmental  regulations may have been a big factor in encouraging a
             number of industries to relocate overseas in the late 1980s and early 1990s.
             This represents a change from the 1970s, when studies indicated firms did
             not make relocation decisions  on the basis of environmental  laws.  This
             effect will increase as regulations become  more cumbersome.

       •     A major petroleum corporation recently decided that a proposed expansion
             project was not economical due to EPA's required paperwork and red tape.
             The project would have increased  revenue and jobs and, ironically, would
             have reduced the corporation's overall emissions.

       •     The  permitting system  under Title V of the CAAA also represents a
             potentially significant drag  on  industry  and  its ability to  compete.
             According to the permitting rules, any change or expansion that a company
             undergoes, no  matter how little the potential effect on air quality,  will
             require them to extensively revise their permit. Firms may be held back
             from  expanding as a result of this regulatory morass, to which foreign
             competitors are immune.  The permitting system is just one example of the
             complex and burdensome requirements of the CAAA.

       The crux of the CAAA program is that the public clearly mandates that clean air
 is important, and this program will help a great deal in providing it. However, along with
 these benefits comes a process that inherently hinders our ability to compete in a global
 economy. Moreover, many of the controls and requirements that are the most burdensome
 to industry provide very  little marginal benefit.   It is difficult to see much benefit from
 many of the expenditures of the Superfund program.

       Why, then have the CAAA and other regulations developed into such a burden on
 competition? Due to the sheer size  and bureaucratic nature of EPA, the agency suffers
 from numerous inherent management problems:

       •     There are layers upon layers of supervisors, and the people who actually
             make decisions are isolated from the specifics of the situations.

       •     The Agency is not forced to confront the real implications of the costs that
             it is imposing.
Session 1 — Competitiveness, Jobs, and Exports

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Clean Air Marketplace 1993	Page 13


       •      The  system  is  risk  averse, which discourages experimentation and
             innovative ideas.

       •      There are many battles over "turf".

       EPA is heading in some positive directions, such as the move toward marketable
permits and other economic incentives. The effort that the Agency  has made in recent
years to work better with other governmental bodies is also a positive step.  This does not
change the overall problem, however, that certain aspects of EPA  itself contribute to
significant burdens on U.S. industry and its competitiveness.
           Professor Paul Templet of Louisiana State University, who was in charge of
           environmental protection in Louisiana Governor Roemer's administration,
           began his presentation by stressing that economic growth and environmental
           protection  should  no  longer  be  seen  as  inconsistent  but  rather  as
           complementary.  Despite the traditional conceptions, the economy must be
           seen as functioning within a larger environmental context. The economy, for
instance, is dependent on the environment as a source of materials and resources and as
a place to dispose of waste. Because of this relationship, economic development must be
consistent in the long run with the maintenance of the region's ecosystem.

       Having provided this theoretical underpinning for the complementary relationship
between the economy and the environment, Professor Templet unveiled a series of graphs
demonstrating how this has been reflected in U.S. economic data:

       •     The first series  of  graphs  showed  how  the top ten states in terms of
             disposable income,  per capita education spending, and growth rates  also
             have the highest levels of environmental protection.  Although Professor
             Templet  admitted this does not necessarily indicate causation, and  that
             there are probably some other factors intruding into the data, he contended
             this does help refute the perceived incompatibility of the environment and
             the economy.

       •     A study by the Bank of America shows a  similar  correlation between
             regions with  healthy economies  and  strong environmental  standards.
             According to the study,  "strong" environmental states grew an average of
             2.6 percent and  "weak" states an average of 2.1 percent  over a  14-year
             period,  and an estimated  3.5  million jobs  have  been  created  by
             environmental   regulation.    The  study  identified  some  theoretical
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Page 14	Clean Air Marketplace 1993


             connections between a strong economy and healthy environment, including
             the fact that better management of resources and minimization of waste is
             integral to both, and that  long run economic growth depends on a
             sustainable ecosystem.

       •      The next series of graphs displayed how environmental regulations, and the
             funding to enforce them, multiplied greatly in Louisiana from 1988-92.  As
             a result of these measures, Louisiana reduced toxics more than any other
             state in the country (50 percent by 1991, 75 percent by 1995). During this
             period, investment  increased dramatically, from $1  billion to around  $3
             billion, and unemployment dropped from 12 percent to 6 percent.

       •      According to the next graph, employment in the chemical industry began
             to stagnate in Louisiana by 1988, only to surge again during the next four
             years.  This  surge  was a direct result of the  aggressive environmental
             regulations  that were being developed, and  helped contribute  to  the
             plummeting unemployment rate in the period.  For every $1 million spent
             in Louisiana on pollution control in the period, 25 jobs were created, which
             is close to the national ratio of 23 jobs created per $1 million spent.

       •      Professor  Templet introduced the concept of the emissions/job ratio, that
             identifies  which states and industries are polluting the most per worker.
             Regression analyses of the fifty states  reveal that states with  higher
             emissions/jobs ratios uniformly have higher poverty rates and employment
             rates,  worse  income disparity, slower  growth, and  lower levels  of
             investment. On  the other hand, as the emissions/job ratio declines  among
             the states, the economic indicators consistently rise.  Therefore, in states
             where business is allowed to pollute more and industries have less regard
             for natural resources, the economy is also suffering.

       To conclude, Professor Templet reiterated the conclusions of an OECD study that
there is no connection between environmental standards and a loss of competitiveness.
Session 1 — Competitiveness, Jobs, and Exports

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Clean Air Marketplace 1993                                             Page 15
           Dr. Richard Klimisch, Vice President of the Engineering Affairs Division of the
           American  Automobile Manufacturers Association (AAMA), focused on the
           regulations on the vehicle painting industry and how its competitiveness has
           been affected.  Painting is one of the most complex aspects of the automotive
           industry; there are a number of different stages including primer, base coats,
           clear coats,  repair,  and a  number of  different techniques, which  are  all
regulated separately for Volatile Organic Compound (VOC) emissions.

       Japanese VOC regulations are very simple, flexible, and are generally a compromise
between business interests and the government. U.S. regulations, on the other hand, are
exceedingly complex and burdensome.  The complexities of U.S. policy lead to delays,
inflexibility, and competitiveness decay. Dr. Klimisch emphasized that the complexity of
U.S. regulations has scared many operations away from areas of ozone non-compliance,
typically cities — this has contributed to urban economic decay.

       Over the last decade, U.S. automobile manufacturers have made a great deal of
progress reducing VOC emissions, which are now at about half the level of Japanese firms.
Achieving further cuts will require higher and higher costs to industry; moving on to the
next level of pollution control will result in a rise in cost from $500,000 per ton to $800,000
per ton.  This level of control  is not cost effective, so there will be little international
demand for the technology and few jobs created.

       Therefore, there are a number of direct costs, capital costs, and indirect costs, such
as a loss of time, that the vehicle painting industry suffers under as a result of regulations.
Although the laws add only about $100 to the cost of production for each car, this is added
to other regulatory  differences between the U.S. and Japan.  For instance, Super fund and
water pollution regulations impose significant costs on domestic manufacturers that are
not shared by foreign competitors.

       The AAMA  has developed a series of recommendations designed to push EPA to
acknowledge  the impacts the CAAA have on international competition and develop a
strategy for dealing with them.  These ideas include:

       •      A continued dedication to achieving  the  lowest  costs by providing
              maximum flexibility

       •      Enlarging bubbles

       •      Streamlining state procedures

       •      Expediting reviews

       •      Developing a system  which does constrain  industries unnecessarily by
              forcing specific technologies on them.
                                  Session 7 — Competitiveness, Jobs, and Exports

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Page 16	Clean Air Marketplace 1993


           Daniel Noble, Vice President, Director of Research, Environmental Business
           International, Inc., presented an overview of the environmental industry and
           some of the changes that it is currently undergoing.  The movement in the U.S.
           from a "linear" to a "circular" economy, among other factors, has driven the
           environmental industry to a state of transition  and  uncertainty.  A linear
           economy, which has characterized our society up until the last decade, can be
described as one in which we take  out resources, put them to some productive capacity,
and then throw them  away.  A circular economy, on the other hand, exists side  by side
with  the  marketplace of the environmental  industry  and  puts more  emphasis on
sustainable development.

       The movement towards a circular economy has been driven by a number of factors.
Rising prices for raw materials and  waste disposal, for instance, have encouraged society
to manage and preserve its resources better than under a linear economy. The trend in
the environmental movement to discuss sustainable development and pollution prevention,
as opposed to remediation, has also helped drive the development of a circular economy.
This development, along with factors such as increasing globalization, will mold the future
of the environmental industry.

       Mr. Noble  provided  an overview of the industry as it  stands today and the
possibilities for the future.

       •     The environmental industry currently has a $134 billion market.   In the
             latter half of the 1980s, the industry  grew at a very fast pace, and has
             recently begun to slow down. The market will level off around the year
             2000 at  $200 billion.

       •     The environmental industry  is divided into  three areas —  equipment,
             services, and resources.  The services area, a $61 billion market, is the
             largest of the three. The equipment and resources areas are $31 billion and
             $40 billion markets, respectively.  The growth rate for each of these sectors
             varies.

       •     Air  pollution control comprises 17 percent of the  equipment end of the
             environmental market, or $5.4 billion.  The growth of this market has been
             relatively  slow in  recent years, although  sales will rise as EPA  further
             develops rules under the CAAA.

       •     In the air pollution control market, the major product types  in demand
             include   electrostatic  precipitators,  and  baghouse   and   flue  gas
             desulfurization equipment.  ABB Environmental and Research Cottrell are
             two  of the major suppliers of these products; 47 percent of the customers
             are electric utilities.
Session 1 — Competitiveness, Jobs, and Exports

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Clean Air Marketplace 1993                                            Page 17
       •     Another emerging part of the air pollution market has been consulting.
             Charts Indicate that three companies — Radian, ENSER, and TRC — have
             reaped the lions' share of the assessment design business so far.

       Mr. Noble provided his view of how the air pollution control market might grow
as a result of the CAAA:

       •     Many analysts predict the market to reach $15  billion by the end of the
             century, but the actual slope of the growth curve will depend on a number
             of uncertain  factors.  For example, the degree to which the  emphasis in
             environmental policy shifts from control to prevention and the pace of the
             development of alternative fuel technology will greatly impact the demand
             for air pollution control equipment.

       •     Currently, the air pollution control industry employs about 35,000^40,000
             people. An expansion to a $15 billion market would result in an additional
             40,000-50,000 jobs.

       •     Growth  markets,  in addition  to  air  pollution control, include  water
             reclamation, the shift from solid waste to resource recovery, and particularly
             the development of alternative energy technology.

       The environmental industry as a whole is facing transition and a great deal of
uncertainty,  but  significant  opportunities will  nevertheless exist  in the  clean  air
marketplace.
Questions and Answers
         How could EPA encourage moving to performance-based standards and further
         innovation?

         Mr. Brenner responded that EPA is trying to move one step beyond performance
based standards.  The first step in environmental regulation is "command and control,"
which  is based on requiring  facilities to use specific technologies.  Performance-based
standards, which require facilities to meet a certain level of pollution cuts using whatever
means  they choose, represents the next step in the maturation of environmental policy.
EPA is trying to move to this step, which relies more on economic incentives and gives
more flexibility to facilities. Firms will not be required to achieve 60 percent reductions at
each individual plant, for example, but will be allowed to choose how they wish to achieve
60 percent reductions on average among all their plants.
                                  Session 1 — Competitiveness, Jobs, and Exports

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Page 18                                             Clean Air Marketplace 1993
         Are there any studies concerning the quality of jobs, not just the numbers, that
         will be gained as a result of the CAAA?

         Mr. Brenner answered that  EPA has been involved in surveying companies to
determine the kinds  of jobs that will be gained and lost as a result of regulations.  The
results so far indicate that the jobs created by the CAAA will be more highly skilled and
paid than those that  are lost.
         What steps has EPA taken to grant more flexibility to businesses?

         Mr. Brenner responded that as EPA develops each rule, it tries to implement
         economic incentives.   It gets difficult,  however, to  grant  flexibility in many
instances. To foster economic incentives, without sacrificing environmental goals, EPA is
trying to set up cooperatives with businesses and pilot programs. This effort will help the
agency  gain experience and  enable it to institute programs that are more sound
economically and environmentally.
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Wliat can  EPA  do to use its leadership position in global environmental
standards to help open up opportunities for U.S. firms abroad?
         Mr. Brenner replied that EPA has been aggressively promoting U.S. pollution
control standards and techniques abroad. This is the best way to expand the market for
the services and technology that U.S. firms offer. EPA has also developed an Innovative
Technology Council to help advocate the development of new technology in every field
of environmental policy.
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Have there been any attempts to solicit the input of business at the level of
writing statutes, not just at the regulatory level?
         Mr. Quarles explained that involving more parties at the level of developing the
laws would not be practical. Businesses already have influence at that level, through the
lobbying process.
Session 1 — Competitiveness, Jobs, and Exports

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Clean Air Marketplace 1993
                                 Page 19
                          Session 2
                          Pollution Prevention and the Clean Air Act
                          Septembers, 1993
                           9:30 a.m. - 11:30 a.m.
                          Moderator:
                          Panelists:
John Seitz
Dr. Thomas Mauser
Amy Laspia
Howard Klee, Jr.
Dr. Dhiren C. Mehta
Eric Shaeffer
Introduction
       John Seitz, Director of the Office of Air Quality Planning and Standards, U.S. EPA,
introduced pollution prevention as the  panel's topic, commenting that the regulated
community  is at a critical  point, particularly  in  terms  of  the  history of EPA and
implementation of the Clean Air Act. Mr. Seitz stressed that if environmental change
continues to be approached in a command-and-control sense, the costs of meeting future
goals will become increasingly higher. Focusing on pollution prevention, and not as much
on remediation, is the most cost effective solution to our environmental problems.

Presentations

           Dr. Thomas Hauser, Executive Director of the American Institute of Pollution
           Prevention, spoke on the historical and cultural barriers to pollution prevention
           and what can be done to overcome them.  Dr. Hauser described himself as an
           old "command-and-control" type turned academic, who retired after 32 years
           at EPA.  According to  Dr. Hauser, we need to break the cycle of addressing
           pollution problems  only after they occur, and  focus instead  on simply
preventing them outright.  Many significant decisions have been made in past years that
have caused environmental disasters because of a lack of foresight (e.g., DDT, automobiles,
and CFCs).  We have to be able to think in advance or we will find ourselves in a costly
pollution remediation situation.

       Since its formation in  1970, EPA has spent over 90 percent of its resources on end-
of-pipe solutions. This is because the nation generally ignores or tolerates pollution until
there is some drastic environmental event.  When there is such an emergency, correction
is often  chosen  in response to public concern, whether the concern is either real or
perceived.  Driven  by  this public concern, environmental laws emphasize the use of
pollution control equipment to reduce health and environmental risks.  Government
                           Session 2 — Pollution Prevention and the Clean Air Act

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Page 20	Clean Air Marketplace 1993


reliance on end-of-pipe solutions therefore results from the short-sightedness of the general
public and the policy making process.

       Academia is also shortsighted, often driven by the necessity to bring in research
dollars for survival.  Instead of solving long-term problems, academics tend to focus on
short-term, regulation-driven research projects. The evolution of the Clean Air Act from
1955-1990 with new source performance standards, mobile source performance standards,
new source review, and prevention of significant deterioration simply represents continued
reliance on remediation solutions. It is necessary  to change from remedying present-day
problems to solving problems before they occur.

       Pollution reduction activities should be distinguished  from pollution prevention
activities.

       •      Pollution reduction activities.  Pollution prevention  has become a part of
              major environmental  concerns, such  as  ozone  depletion  and  global
              warming.    Although  in  general  these  activities are  good for the
              environment, they are pollution reduction activities rather than pollution
              prevention activities.

       •      Pollution  prevention activities.   An  alternative approach  is to treat
              pollution prevention as an entity unto itself, rather than as an afterthought.
              As environmental laws are passed, the pollution prevention concept is
              added to regulations first, before end-of-pipe control is generated.

       A culture seems to have developed in which everyone — from those  writing
regulations, to those in industry implementing the regulations — has a  command-and-
control emphasis. Perhaps the best way of changing this approach is to focus on pollution
prevention activities. Environmental problems can often be avoided through the adoption
of a "rigorous and vigorous" pollution prevention program.
           Amy Laspia, President, Environmental Management Consulting, described the
           results of a one-year study on the application of pollution prevention to
           industry.  The one-year study involved 317 companies that ranged from a
           seven-employee company with one plant and one source, to a 22,000-employee
           firm with 36 plants and 42 sources per plant.  The businesses included food
           processing, window and door manufacturing, flour milling, and hospitals.
Session 2 — Pollution Prevention and the Clean Air Act

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Clean Air Marketplace 1993                                            Page 21
       Environmental Management Consulting, based in  Minneapolis, Minnesota, was
asked by EPA to conduct a survey of businesses studying what incentives are available for
industry to engage in pollution prevention activities.  It conducted one-on-one interviews
with individuals in all phases of business, and found the following pollution prevention
activities taking place:

       •     Housekeeping management, which relies heavily on plant maintenance, is
             being conducted by all of the companies  surveyed because of  its cost
             effectiveness. The study recommended that EPA should not discount these
             activities, which are a major improvement for many plants and are low-tech
             methods for running a cleaner plant with  less waste.  In addition, the best
             pollution prevention ideas often come from  maintenance personnel.

       •     Process modification is being achieved, but takes a  much longer  time to
             implement than other pollution prevention activities and is very dependent
             on  available  funds for R&D.  Most  companies felt that some incentive
             should be  given by EPA and states to increase R&D dollars for  process
             modification.  It is very difficult for middle managers to convince upper
             management of  the  need for R  &  D  dollars  dedicated  to  pollution
             prevention activities.

       •     Material  substitution  is  also  heavily  dependent  on  R&D  dollars.
             Management is not likely  to spend R&D  money for  material substitution
             when a process is operating successfully.  The study recommended that
             there needs to be some joint  EPA, academic, and industry standards for
             when material substitution might benefit  the plant.  These standards can
             then be used by managers seeking R&D  dollars to justify and implement
             material  substitutions.

       •     Employee  training is being conducted by  many  of the firms  surveyed.
             However, most firms noted that they had a difficult time finding useful
             training  resources.  Although EPA has excellent training programs and
             ideas, the  current distribution  effort  is lacking  in getting  them out to
             businesses. This issue was mainly of concern to small- and medium-sized
             companies.  EPA recognizes its problem with distribution of its  resources,
             and will  work to improve  this area.

       •     Pretreatment is an option  that is largely dependent on the industry. If a
             company  can   modify a process  to  accommodate  or  incorporate
             pretreatment, pretreatment will increase in use.  However, this is one of the
             least practiced pollution prevention technologies because of time, the R&D
             dollars, and the aversion  to unproven innovative technology,  especially
             when regulatory compliance is not assured.
                           Session 2 — Pollution Prevention and the Clean Air Act

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       Environmental Management Consulting presented EPA with five key findings on
what encourages or discourages pollution prevention throughout industry. These findings
were:  (1) Effective Communication;  (2) Flexibility; (3) Major Impediments to Pollution
Prevention; (4) Cross-Media Solutions; and (5) Involvement Level.

Effective Communication

             Uniform permit forms. Businesses would like to see a uniform  form  for
             permits, at  least  for  smaller businesses with simple processes.  While
             business realizes that this is a huge undertaking, many suggested that EPA
             begin with small business, possibly in  a single media (e.g., air).

       •     Clear and definitive  regulations.  EPA should communicate clear and
             definitive regulations.   Most permit  applications are written for the
             environmental  professional.   However,  the   person  responsible   for
             implementing permits does not necessarily have an environmental/scientific
             background. An understanding of clearly defined regulations allows the
             environmental  manager more  understanding  (and time)  to  seek  out
             pollution prevention options.

       •     Meaningful and  consistent data.  Data should  be meaningful and  be
             generated consistently. Businesses would like to work with EPA to develop
             hybrid measures or units commonly used in manufacturing  for reporting
             requirements and measurements.  This would allow businesses to use data
             already being generated in a plant environment, thereby cutting the time
             required to convert manufacturing data for reporting, thereby allowing time
             for more innovative technology development.
Flexibility
             Performance standards.  Industry believes that the only  way to develop
             pollution prevention technologies and emissions reductions rapidly is for
             industry to work with EPA  to  develop industry-specific  performance
             standards.  Industry considers themselves to be the best  ones to do this,
             because they know the processes better than anyone else.

             Individual Plant measurement.   Apart from  reporting  requirements,
             manufacturers believe that  they  can assist EPA  and state agencies in
             determining an accurate method for measuring their facilities. A great deal
             of trust is involved in this area, and industry is looking for a way to work
             together with EPA.

             Technical flexibility.  Businesses of all sizes feel  strongly that the EPA
             should avoid prescribing technologies. Being told what type of technology
Session 2 — Pollution Prevention and the Clean Air Act

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Clean Air Marketplace 1993                                             Page 23
             to  use  to achieve  compliance can  tie  the  hands  of creativity  and
             improvement. Given parameters, a company would rather be challenged
             to look for a solution within a reasonable time frame.

       •      Inspection and enforcement. Small- and medium-sized businesses need a
             "level playing field" in inspection and enforcement. They are concerned
             that inconsistencies hurt   their  ability  to  compete.    Firms  ignore
             environmental compliance, believing that they will never be inspected. As
             a result, one  firm makes an investment in prevention/ control, while the
             other goes free and can afford to offer lower priced goods.

Major Impediments to Pollution Prevention

       •      Permitting time.  Permitting time is the single  largest impediment to
             companies trying  to implement pollution prevention technologies.  The
             length of the permitting process forces them to be conservative about trying
             new pollution prevention technologies, particularly when EPA  does not
             provide some condition that, for trying the technology, they will achieve
             some level of compliance.

       •      Cost. When pollution prevention is viewed as an extra program rather than
             a needed program, cost is an issue.  When pollution prevention is integrated
             with the regulation, cost is viewed as less of an issue, or as no issue at all.

       •      R&D resources. Companies are under pressure to commit R&D resources
             to reliable, end-of-the-pipe technologies.  They maintain that there is no
             incentive  to  use R&D resources on an  unproven pollution  prevention
             technology, because  EPA will not provide some  level of compliance if the
             technology should fail.

       •      Regulatory uncertainty.  Companies are less  willing to take  risks on
             investments in pollution prevention technologies when they are unsure of
             how the regulations  may change.

       •      Process complexity. In some complex processes, there is no technology
             available for material substitutions. Significant improvements can be made
             in the process, but companies feel that they should not be penalized if those
             improvements are not necessarily in the "source reduction" category.

       •      Business risk.  For some companies, trying new  technologies puts them at
             a potential competitive disadvantage. If a company is in a competitive bid
             process (especially for government projects), it must bid with the "proven"
             technology.
                           Session 2 — Pollution Prevention and the Clean Air Act

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       •      Cost accounting.  Businesses are trying to find a way to demonstrate to
             their management the cost of not preventing pollution that is acceptable to
             accounting and financial managers.  Figures on such costs, however, are
             currently unreliable, and inconsistent. Businesses would like to work with
             accounting organizations to develop standards (e.g. quantifying cost of
             waste and reporting).

       •      Fee structure.  Businesses believe that the fee structure should be adjusted
             or flexible if they invest in additional equipment or new technology to reach
             emissions reductions below the current  required level.

Cross-Media Solutions

       •      Cross-media  permitting.    Plants  often  deal with  more  than   one
             environmental medium.  In such cases, facilities are interested in cross-
             media permitting, and would welcome  a joint EPA-industry pilot effort.

Involvement Level

       •      Motivation.  Companies that motivated more  employees had the most
             success in preventing pollution. The pollution prevention effort should not
             be  limited to  people  responsible  for source reduction and material
             substitution. The entire process benefits  from downstream ideas, which are
             often the best catalyst to upstream changes.

       Based  on  these conclusions about  the  encouragements  and  impediments to
pollution prevention,  Environmental Management Consulting provided the following
recommendations to EPA:

       •      Improve EPA's distribution of information;

       •      Provide additional on-site technical assistance;

       •      Provide incentives such as matching grants and low-interest loans;

       •      Ensure regulatory consistency;

       •      Establish interagency cooperation to allow companies to use alternative
             materials to meet the standards;

       •      Conduct consistent inspections and integrate pollution prevention. EPA
             and the states need to use the inspector as an agent of change;

       •      Inspect regularly to provide a level playing field; and
Session 2 — Pollution Prevention and the Clean Air Act

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Clean Air Marketplace 1993                                             Page 25
             Integrate pollution prevention options into enforcement actions using a
             flexible approach.
           Howard Klee, Jr., Director, Regulatory Affairs, Amoco Corporation, discussed
           the Amoco/EPA project in Yorktown, Virginia, designed to study pollution
           prevention  opportunities, and  barriers to innovation.   Frustration with
           inabilities to implement innovative solutions to environmental problems within
           the regulatory framework led Amoco to  initiate the joint pollution prevention
           initiative in Yorktown.

       An example of such frustration involved the rebuilding of a Texas facility to comply
with the lead phase-down rules.  Amoco had an opportunity to improve the efficiency of
a certain furnace in this facility  that would reduce the amount of fuel burned,  reduce
emissions, and save energy.  Amoco was ready to make the necessary modifications when
they discovered  that changing the piece of  equipment required a change in the permit.
Although EPA agreed that  Amoco's plans would  reduce emissions and save energy,
Amoco was told that it would be  at least nine months before the Agency could look at the
permit, and even then, there was no  guarantee that it would be approved.  At the same
time, Amoco had a construction deadline to meet in  order to comply with the lead phase-
down rule, and could not afford  to wait.  Hence, the old, inefficient equipment is still in
place.

       In another example,  Mr. Klee discussed Amoco's production  of terphthalic acid,
which is used to make polyester.  One of the outputs is a wastewater stream that is very
difficult to treat.  Over the years, Amoco has developed a wastewater treatment technology
that consumes less energy, generates natural gas, produces less solid waste, and takes up
less land.  Although the multi-media benefits of this process reportedly far outweigh the
EPA-approved process, it does not quite meet the existing water quality standards, and
cannot be constructed in this country.

       These examples illustrate  the types of issues that come up at facilities attempting
to use innovative technologies. In the Yorktown project, EPA and Amoco conducted an
inventory of  the  facility, identified sources, identified ways to reduce  them, and then
ranked and identified priority alternatives according to the uniqueness of the facility. The
"rule-book" was "set aside"  for the entire process.

       The site chosen was a small, 35-year  old refinery in Yorktown, Virginia.  The
refinery is in an environmentally sensitive area on the York River, about one-half mile
from where the River empties into the Chesapeake Bay. Emissions samples were collected
                           Session 2 — Pollution Prevention and the Clean Air Act

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over the course of one year at a cost of approximately $1 million.  Almost 90 percent of
the releases were found to be going into the air.  Some of the pollution prevention projects
that Amoco and EPA looked into were inexpensive and effective, such as a leak detection
and repair program.  In this program, an employee uses an electronic detector to identify
hydrocarbon leaks around valves, flanges, and  pumps, and then repairs them.  Over 90
percent of the leaks  were repaired immediately by the person who conducted the initial
check.

       Interestingly, Amoco discovered that emissions from a barge loading operation (80
percent of the product is shipped out by marine barge) were  the single largest source of
the emissions that were having an impact (or potential impact) on the surrounding area.
However, there are  currently no controls required on  those emissions, since the refinery
in question is located in an ozone attainment area.

       EPA and Amoco  then looked  at the eight  things that  they thought would be
required under statutory requirements and calculated that they could capture about 7,300
tons a year of hydrocarbon emissions from multiple sources at an average cost of $2,400
per ton. They then looked at alternative technologies, such as those that are not currently
regulated, as well as other sources of releases and multimedia effects. The net effect was
a different series of projects, which, once implemented, could capture about 7,500 tons of
emissions at a cost of $500 per ton. This was a slightly different set of emissions, including
some hazardous solid waste that the plant was generating. However, by reducing solid
waste generation, the facility was able to increase their processing capacity, and reduce the
amount of waste that was sent off-site to a landfill.

Lessons Learned

       •      Government  and  industry can  work together.    However,  current
             institutional practices discourage innovative solutions to  environmental
             problems.  The biggest concern is not the goals,  but rather the means to
             achieve the goals.

       •      Improved data can improve environmental management decisions.  Too
             many  decisions are made  without  enough accurate data.   Although
             obtaining data is expensive now, it is cost effective in the long run.

       •      Risk-based decisions, while complex, offer the ability to focus resources
             on  significant problems  and  more  effective  solutions.   Risk-based
             decisions allow industry to determine the benefits of different choices in
             terms of impact on human health and environmental quality.

       Many opportunities exist for EPA to be flexible and to promote innovation under
current Federal  statutes, including:
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             Reliance  on performance standards instead  of  technological design
             standards. The people who have to work with facilities should determine
             the best way to meet standards.

             A safety  net to encourage people to try new things must be created.
             Currently, if a company tries something new and comes up with 95 percent
             success instead of 100 percent, they are essentially back to ground zero and
             have to start over. This is an expensive proposition.

             If a facility shows an overall net reduction of emissions for sources at a
             particular site, EPA should consider the reduction to be valid. This is
             cost-effective because it allows facilities to over-control some sources and
             under-control others.
           Dr.  Dhiren  C.  Mehta,  Manager,  Technology   Applications,  Hughes
           Environmental Systems, discussed pollution prevention opportunities in the
           electronic sector.  Hughes is an aerospace/electronics company that does a
           substantial amount of work for the defense industry. The job of Dr. Mehta's
           division, Environmental Systems, is to develop new technologies that are used
           internally and marketed to other companies. Dr. Mehta discussed the way in
which Hughes  is responding  to  Title I  (Ambient  Air  Quality Standards), Title III
(Hazardous Air Pollutants), and Title VI (Ozone Depleting Chemicals) of the Clean Air Act
Amendments.

Title I — Ambient Air Quality  Standards

       Hughes is currently working on a project that will  allow different manufacturers
to come up with the most cost effective technology for a given facility.  This project will
not only reward innovation, but will also allow companies to bank their reductions so that
they can use them for other sources or sell them.

       Hughes is trying to  better understand the problem of air emissions  from mobile
sources.  It is developing technologies to  better identify  high  polluting  cars, and it is
working with  the city of Los Angeles. The project will use Hughes Smog Dog, a device
that can  remotely and accurately determine which  vehicles  are the high polluters.  It
consists of  an infrared source, a remote sensor, and a computer  that gives percentages of
CO, HC, and CO2 emitted.  At  the same time, a video camera captures the  license plate
of the moving vehicle.  All of this is done within the  fraction of  a second that it takes for
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a car to pass.  This information would allow states to identify high emission vehicles, and
take appropriate corrective actions.

Title III — Hazardous Air Pollutants

      One  of the first MACTs (maximum  achievable control  technologies) being
developed by EPA is for the electronics industry.  Hughes is working with the EPA to
assess the technological options and  choose the right ones.  Some market opportunities,
however, should come out of the new standards.

Title VI — Ozone Depleting Chemicals

       Because Hughes uses ozone depleting chemicals very heavily, the ozone depleting
chemical (ODC) phase-out by 1995 will impact  them the most of any of the regulations.
Hughes has pledged to delete all ODCs from manufacturing processes by 1994, although
it faces several problems in finding alternatives to ODCs.

       Hughes has been assessing new technologies since 1988. Ideally, Hughes would
prefer to develop pollution prevention techniques because they are a long-term solution.
Hughes does not want to create hazardous waste, or transfer pollution from one medium
to another. However, solutions also have to be cost effective.  In recent years Hughes has
developed  different cleaning systems, some of which  have been  licensed  to  outside
companies that are now marketing them to other customers.

       In summary, the CAAA have significant impacts on the electronics and aerospace
industries.  Hughes is attempting to develop cost-effective solutions that they can use and
also market to other companies.
           Eric Shaeffer, Director, Pollution Prevention Policy Staff, U.S. EPA, spoke of
           EPA's opportunities to promote pollution prevention and source reduction.
Several of EPA's options in this area are:
             Invest in research. This option, however, is constrained by EPA's limited
             research budget.
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       •      Provide people companies with information and technical assistance. To
             do this EPA would have to rely heavily on states and their  technical
             assistance programs.

       •      Encourage voluntary programs such as Green Lights.

       EPA's role in designing and implementing rules through permits and enforcement
actions should create a positive investment climate for prevention. In the end, EPA is a
regulatory agency with a mission to carry out environmental statutes that they are given
by Congress.

       Technology-based standards and deadlines are two of the main components of the
rulemaking process that EPA faces once legislation has been mandated by Congress.  EPA
attempts to  identify the best performing  technologies and  then  convert them into a
performance standard.  Ideally, companies should have the option of selecting the optimal
way of complying with that standard.  The pressure of deadlines also greatly impacts the
rulemaking process.  If EPA misses a deadline,  the courts will write the regulations.

       Industry  has very limited opportunities  to provide input into a rule. By the time
a proposed rule gets to the Federal Register, many basic decisions have already been made.
EPA does its best to provide companies with options, but the  analytical process for
pollution prevention is intense. There is a lot of information that has to be sifted through,
analyzed and understood.  By the time a proposed rule reaches the Federal Register, there
is a fairly short time period between proposal and when the rule is supposed to take effect.
This makes it hard for EPA to fully respond to  comments.

Source Reduction Review Project

       EPA  is currently working on a project that focuses on key industries and trying to
put some of the questions concerning pollution prevention  to the public arena.   EPA
identified 17 industrial categories that included fairly large industries such as pulp and
paper, small manufacturers like printers, and high-tech industries like pharmaceuticals.

       All  17 industries face deadlines and  are  all generally  facing multiple  rules
converging on the same issues. To make this project possible, EPA only picked industries
with a regulatory proposal date far enough away that sufficient time  is available to have
an impact on the industrial process. The goals  of the project include:

       •      Designing and implementing rules in which source reduction is the optimal
             method of compliance;

       •      Eliminating cross-media transfers of pollution by eliminating single medium
             decisionmaking; and
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       •      Providing, through a public dialogue, as much predictability and certainty
              with regard to all the compliance requirements.

       Although EPA is compelled to adopt with deadlines [can we clarify?], there is some
flexibility.  For example, EPA recently adjusted the timing of the air rule for the pulp and
paper industry so that it will coincide with the rule for water. This will allow the industry
to see the dual impact of the rules and plan its investment appropriately.

       Technological advance often occurs so rapidly that it is impossible for every Agency
to reflect the latest technological developments in each of its rulemaking processes.  It is
therefore  important  to  build flexibility into  implementation.  Although  EPA  offers
flexibility in theory, in practice,  permit writers  have proven  to be  conservative.   If a
company attempts to use a new  technology, they  are often discouraged by the permit
process.

       For smaller manufacturers, information is critical. Because small manufacturers are
not going to read  the Federal Register, it is important  to convey quickly and simply the
necessary information.

       No matter how much cooperation is achieved, there is always going to be a debate
over the amount of pollution prevention that is necessary.   In order to accomplish some
of the above goals, EPA needs participation from industry before the rules are published
in the Federal Register.  Industry also needs to be patient as  EPA attempts to move  from
"end-of-the-pipe" control to the complicated world of  pollution prevention.
Session 2 — Pollution Prevention and the Clean Air Act

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                             Keynote Address by
                             Professor Michael E. Porter
                             Harvard Business School
                             Introduction by Michael  P.  Vandenbergh, Associate
                             Deputy Administrator, U.S. EPA

                             Septembers, 1993
       It is always a challenge speaking immediately after lunch.  I had a friend who had
gone out to a big business lunch and returned to his law firm after the big lunch and put
his head down on his desk... just for a moment.  Luckily, he popped his head up just
before a partner walked into his office to give him an assignment. After a long discussion,
the partner turned around and walked out. The guy felt like relaxing when a paper clip
fell off his forehead and hit the desk. I always thought about the dangers of that. I do not
know what that  means — either do not sleep after lunch or, if you do, sleep on the side
of your head.

       I am very honored to introduce our keynote speaker today.  As we consider the
Clean Air Act and its far-reaching impacts on the U.S. economy, we are contributing to the
critical debate that is very important to this Agency and is taking place across the country
on the relationship among environmental protection, economic growth, and environmental
technology. Few have advanced that debate more than Professor Porter. Professor Porter
is an international leader in the field of competitive strategy.  His work on the interface
between the environmental regulation, business innovation, and the competitiveness  of
industries provides a perfect context for discussions here today.

       Professor Porter received his undergraduate degree from Princeton University, and
a Ph.D. in Business Economics from Harvard, which he received in 1973.  He then went
on to become the C. Roland Christensen Professor of Business  Administration at the
Harvard Business School — one of youngest tenured professors in its history.

       Professor Porter's work at Harvard has been exceptional.  His ideas are the basis
for one of the school's required courses and he  is rumored to  be — and we will find out
sometime during his lecture — one of the school's absolute best teachers.  In addition, his
independent contributions are equally  impressive. Professor  Porter is the author of  14
books and  over 45 articles.  His recent works, including, Competitive Advantage: Creating
and Sustaining Superior Performance, and the well-known Competitive Advantage of Nations
form the basis  for competitive strategy in  both government  and the private  sector.
Professor Porter's April 1991 Scientific American article entitled "America's Green Strategy"
is particularly related to this conference.  One of his most important conclusions in that
article —  that  environmental  regulation,  under the  right circumstances,  can  spur
innovation and  increase competitiveness — is reenforced by your presence here today.

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       Professor Porter also serves as a consultant to many leading companies and  has
shared his thoughts throughout the government, including with Administrator Browner
and the top management at EPA.  His contributions to EPA are greatly appreciated. 1 can
think of no better expert to address this group on the issue of business competitiveness
and environmental technology. Please join me in welcoming Professor Michael Porter.
Address by Professor Michael E. Porter — Towards a New Conception of the
Environment-Competitiveness Relationship

       This conference is probably the single biggest manifestation that some of the ideas
I am going to talk about today can really work, and can really make a difference.  So I
could not resist the opportunity to come here this afternoon and talk to you about some
of my ideas about  competitiveness in general,  and about the  role of  environmental
regulation in impacting competitiveness.

       As you know, there still remains a raging debate in our nation about environmental
policy — about how fast we should go, about how we should approach this issue. The
private sector is still deeply  divided on how to think about environmental issues — new
issues that face  the agenda of virtually every corporation.  What I would like to do this
afternoon is to contribute to that  discussion from the perspective of one  who has spent
approximately 20 years deeply concerned with the problems of international competition
in industry

       I would  like to cover three subjects.  First, I would like to talk about  what it takes
to be internationally competitive. The question that many have asked is, "Is environmental
regulation diminishing the ability of U.S. industry to be internationally competitive?"  In
approaching this, one  must  examine the  prior  question of  what it  takes to  be
internationally competitive.  Second, if we understand what makes an industry or firm
internationally competitive, what is the link between this and the environment?  How  do
we think about that relationship?  How do we  frame that relationship?  How do we
understand  whether the  environment or environmental regulations  contribute  to
competitiveness, or erode competitiveness, or perhaps both? I would like  to draw on my
joint research with Dr. Claas van der Linde to explore these questions. And  finally, if we
can reach a clear understanding of the link between the environment and competitiveness,
what  does that imply for the strategies of companies, the EPA, and of environmentalists
(all of whom have a keen interest and large stake in addressing this issue)?

       What I would like to argue is that we  have been framing the environment-
competitiveness debate  using the wrong perspective. There is another way to frame the
issue  that is much more constructive,  both  for the environment  and for companies.  I
would like to persuade  you this afternoon that the  directions in which many of you are
already moving — because you are here — are the right directions and that  the notion of
the world community must find ways of speeding up this transition to a new perspective.
Keynote Address — Professor Michael E. Porter

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What Creates International Competitiveness

       Let  us  begin, however,  with  the  prior question of what creates international
competitiveness in industry? There has been a long-standing interest in the question of
international competitiveness.   There are some old paradigms that have shaped  our
thinking about competitiveness historically, but they are rapidly fading and, indeed, are
becoming counterproductive ways of thinking about the issue.

Comparative Advantage

       The most established of the old paradigms is comparative advantage. This says
that competition is fundamentally based on cost, and the company notion the companies
with the lowest cost will win. Costs are principally determined by the cost of inputs:  the
cost of energy, labor, raw materials, other cost of doing business, and so on. According
to the paradigm of comparative advantage, the nation that is competitive is the one that
enjoys the most favorable endowment of what economists call "factors of production" (i.e.,
the lowest  cost inputs).  The nations  that will win  in labor-intensive industries will be
those that have low labor costs. Similarly, the companies and countries that will win in
industries that rely on raw materials will be those that enjoy favorable local supplies of
their materials.

       The comparative advantage paradigm  has defined much of  our thinking about
competitiveness.  However, it has been superseded.  Why?

       •     Globalization. In a world of global competition, companies no longer need
             to have low cost  inputs at home to get access to them.  They can source
             raw materials cheaply on global markets, thus not needing them at home.
             The global firm can locate selected activities in other countries to tap into
             those low cost inputs, wherever they  might be.  For example, a company
             could be based in Germany, but the labor intensive parts of its process can
             be  located in  a  low-wage country such as Mexico.   This company  can
             remain vibrantly competitive despite the fact that it  has  high wages at
             home.

       •     Role  of  Technology.   Even  more  importantly,  the old paradigm of
             competitiveness  has been superseded by the power  of technology.   In
             industry after industry, we find that the companies/nations that win are not
             those that have access to inexpensive, abundant  inputs but those that are
             able to use technology  to use the inputs productively. For example, if a
             company has high labor costs at home, it can simply  automate away the
             need to use unskilled labor. If a company has a shortage of a raw material
             at home, it can find an alternative raw material or a  synthetic one.  If a
             company faces high costs of space (e.g., as companies do in Japan) this does
             not make  it uncompetitive. Instead,  Japanese companies have pioneered
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             dozens of space-saving innovations that have allowed them to be more
             productive than foreign rivals even accounting for the high cost of space.
             That is what just in time production is.

             Just in time production, for example, is an invention that avoids the need to
             store inventory on the factory floor and  consume space.  Why did the
             Japanese come up with just in time production?  Because they were forced
             to deal with the high cost of space.

             In this illustration, as in  hundreds of industries  we have examined, the
             concept of comparative advantage has been superseded. But it is more than
             this. Today, if all a company has for its comparative advantage is  low
             input costs, it  is in a very  precarious  position.   It  is likely to  lose
             competitiveness to rivals with even cheaper inputs or those who are more
             innovative in using them.

Economies of Scale

       Another paradigm of competitiveness that is becoming obsolete is the paradigm of
scale. In this paradigm, the principal source of comparative advantage is being big — big
enough to amortize  R&D costs, big enough to reap scale economies in production.
Europeans, I find are particularly enamored with scale.  Unfortunately, just when many
European companies are merging because they want to be bigger, the paradigm of scale
has been made obsolete by the same forces that have undermined comparative advantage.

       There is growing evidence that being big does not necessarily make a company
more competitive. Why? Firms that are more innovative, and that have better technology
can make scale economies obsolete.  A large company may be very efficient  in making its
traditional products, or producing them in the traditional ways. But today's winner is the
company that can come up with new products or new means of producing them.  The
world industrial landscape is heaped with piles of big companies that had  economies of
scale but have been superseded by smaller ones.

The Paradigm of Innovation

       A new paradigm is driving international competitiveness, one based on innovation.
What we have verified from looking at hundreds of industries, based in dozens of different
countries, is that, the competitive industry is not the one with the cheapest  inputs or the
largest  scale but the one  with the capacity  to  continually   improve and  innovate.
Innovation is defined broadly, to include the product itself, how the product is serviced,
how the product is marketed, how the product is designed, and how the product  is
produced.
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       In industries, and segments of industries, that support high wages, relying on cheap
inputs will fail.  Today, innovation can no longer be inward looking.  It can no longer
merely reflect local or domestic needs. The internationally competitive companies in every
industry are those whose innovations anticipate international needs at the same time as
they serve local  needs.  If an American company can come up with a new product or
service that is a little bit ahead of where the world market is going, it can emerge as an
international  leader.  On the other hand, if a company is innovating in ways that are
peculiar to U.S. circumstances, it will ultimately lose — international competitors who are
innovating in more globally useful and relevant ways will come out ahead.

       In global competition, early movers often win.  Companies that can see new market
segments and discover new process technologies do not have direct opposition. They can
enter new segments of the market without any opposition.

Underpinnings of International Success

       Why do that nation's companies innovate? Why is it that competitiveness emerges
in a particular nation, in particular fields?  My research, first published in the Comparative
Advantage of Nations  found four elements of  the national (and often regional and local)
environment  underpin the capacity to be internationally  successful in an industry: (1)
access to specialized inputs; (2) demanding and trend setting home customers; (3) a critical
mass of local suppliers and related industries; and (4) a context of local competition.

       Access to the Right Kind of Inputs

             General purpose inputs, such as unskilled labor or basic infrastructure are
       no longer a competitive advantage. Many nations and states have those, and firms
       can readily access them.  Today, competitiveness comes from  having  highly
       specialized inputs tailored to the needs of a particular business and having these
       inputs nearby. One of the reasons America is the world leader in software and
       why Japan is uncompetitive, for example, is because of the shortage of software
       engineers in Japan.  Software engineers  are scarce in Japan because Japanese
       universities are so bureaucratic and centralized that it takes years to change the
       curriculum. Japanese universities are good at training electrical engineers, but not
       very good at training software engineers.

             My favorite illustration of  the role of specialized inputs  in international
       competition is the Dutch flower industry.  The Dutch are responsible for 65 percent
       of  all the world exports  of live and cut flowers.  (I will use this example again
       when I talk about the environment  because it is quite an interesting example.) The
       two most important inputs to the flower business are land and climate. Anyone
       who has been to  Holland knows that  it fails on both counts. The Dutch literally
       have to reclaim land from the ocean, and the weather is dreadful. Yet the Dutch
       are the world's leaders in the industry. How could that be?
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             The answer is that they have created unique pools of highly specialized
       inputs for that particular business.  They have major research centers dedicated to
       flower technology: growing, shipping, handling, packaging. That is an advantage.
       Having a good university, strong in basic research is great for the world's scientific
       community, but does not create competitive advantage. Basic scientific knowledge
       flows  freely around  the  world.  Having specific expertise in how  to apply
       technology to growing flowers is an advantage.  The only way to gain such an
       advantage is to actually be there, in Holland.

             Holland also has five auction houses tailored to handling, selling, shipping,
       and processing flowers.  In those auction houses, one can see carts of flowers being
       towed around  by computer-guided  vehicles, passing through a Dutch auction
       room. The buying process occurs in about 3 seconds. There are buyers sitting with
       buttons and  the auction clock goes down  (Dutch  auctions start at the high price
       which falls until someone pushes the button).  The first person to push the button
       buys the flowers. That person's code is attached to the cart, which is routed to that
       buyer's shipping and handling facility.  Within 20 minutes, those flowers are at
       Schipol Airport in a  container bound to  the United States.  It is  an awesome,
       specialized  infrastructure, and it represents a  competitive advantage.   Simply
       having highly developed airports, water ports, and roads, however, is not.

             Paradoxically, having a shortage can sometimes be an advantage. One of the
       reasons that  the Dutch are so good in the flower business is that they do not have
       good weather.  If the weather was good, the Dutch would plant  flowers outside
       and pray for good weather.  Not having good weather forced the Dutch to come
       up with a different way to grow flowers.  Their solution was to cultivate flowers
       in greenhouses all year round.  Adopting such a strategy  would  pose a tough
       tradeoff for a nation with a good climate (i.e., why build a greenhouse that you are
       only going to use three months a year?).  For the Dutch, it was easy.  Once the
       Dutch committed to greenhouses, however, they could control every single thing
       about the environment of the  flowers.  Going into a Dutch flower greenhouse is
       kind of like being in a spaceship — high technology, sensors, automatic shutters
       to control the sunlight, and the sprinklers to regulate humidity. Competitiveness
       comes from the ability to create unique, specialized technology and keep advancing
       that technology over time.

             When a nation has an abundance of labor, an abundance  of land, and an
       abundance of natural resources, conversely, it does not  normally create unique,
       specialized technology.  Abundance leads  firms to use the input inefficiently and
       unproductively.  Competing on cheap inputs alone used to work when we had an
       insular, closed economy.  Now, when the U.S. competes with many other  countries
       with even cheaper labor and even cheaper raw materials, this strategy fails.  The
       only way to succeed is through innovation.  And to innovate, one needs specialized
       inputs.
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       Demanding and Trend Setting Home Customers

             If home customers will accept whatever you already provide, and if they
       do not push  you, your firm will never be internationally successful.  To be
       internationally  successful,  companies need  home  customers that are  very
       demanding.  You need home customers who  have problems early — before
       customers elsewhere in the world.  This way, firms can understand those problems
       better and you can keep adapting  your products and services to address them.

       A Critical Mass of Local Suppliers and Related Industries

             Internationally competitiveness depends on a critical mass of local suppliers
       with which to work.  While machines, components  and services can be bought
       from around the world, a company needs a critical mass of suppliers that are based
       nearby to work with interactively, on a continuous basis, and in the same language.
       Otherwise  firms  will have a hard  time  being innovative  enough  to  be truly
       competitive.  Firms  hold  on in  the  price-sensitive  segments, and  in  the  less
       sophisticated parts of the market, but without local suppliers firms will have a hard
       time being truly competitive.

       A Context of Vigorous Local Competition

             Finally, competitiveness is crucially affected by local competition. We found
       very few internationally successful industries where there is only one company
       based in a particularly successful country. Much more typical is an example such
       as the German auto industry, in which we find companies such as Mercedes, BMW,
       Audi, and Porsche, all located within a relatively small geographic area.

             Why is local rivalry necessary? In a static view of "low cost", having a
       number of rivals  divides up the home market and causes duplication — a word
       heard often in Washington these  days.  But in a  world where innovation puts
       pressure on local rivals, there is much more rapid improvement. The best analogy
       I have been able to come up with  was given to me by a  German CEO:

             // you are trying to become a really good runner, one way to improve  is  to run
             against a dock. Your coach  is there with a stop  watch.  Ready,  set,  go.   Run
             around the track. Click... look at your time.  Tell yourself you can do better.  But,
             if you really want to be a world class runner, you need somebody breathing in the
             next lane.  You need  someone there who is sort of like you, that  is in similar
             circumstances,  that is showing you that it  can be done  and is forcing you to
             improve.

             Particularly in sports, science,  and the arts, the power of local rivalry is
       pervasive all  forms of human endeavor.  Good sprinters, for example,  occur in
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       clumps.  There are three or four of them at the same time at UCLA, or some other
       location, they all become Olympic  medalists — because they push each other,
       because they challenge each other. We find the same thing to be true in business
       competition.

Competitiveness and the Environment

       Now what does all this mean for  the environment?  This perspective about
competitiveness  has  a  profound  implications   for  how  we  must think about  the
environment. It also suggests that we have been framing the environment-competitiveness
issue in a way that is not advancing either company or environmental goals as rapidly as
they could be.

       The tendency in thinking about the environment has been to view it as a tradeoff.
On  one side of  the  tradeoff are some social  benefits through  strict environmental
standards. There is a debate about how big  the social benefits are: about how much
improvement in life expectancy results, and how  big the health risks are, etc.  I will put
this issue aside.   Let us assume we  know what the social benefits are.  Sustainable
development concepts are giving us a broader perspective on the social benefits of a clean
environment might be. On the other side of the tradeoff is industry competitiveness. The
idea here is that obtaining environmental benefits will involve private costs.  Industries
must bear costs in order to improve environmental outcomes.  The prevailing view is that
there is an inherent tradeoff.  To get the social benefits, a nation or  state inherently and
inevitably must bear private costs.

       There are numerous  problem with framing the  issue this way. First, it means that
the  process of environmental improvement  becomes a power struggle.   Using  this
perspective, there are two sides with diametrically opposed  objectives.  Progress on the
environment becomes a kind of an arm wrestling match. The struggle goes a little bit one
way when Republicans are in power, and the other way when the Democrats are in power.
The problem is that the wrestling match itself consumes enormous amounts of energy and
resources.  If we had the data, I would submit  that it would show that a substantial
fraction of the revenues from environmental products  and services industry  is consumed
in the struggle, not in cleaning up the environment.

Struggle Metaphor

       The struggle metaphor (i.e., "we must push harder to get tougher standards", "we
must beat standards back", also creates a lot of uncertainty in the minds of industry.  This
is the  true enemy of progress.  If companies are uncertain about what environmental
regulations are going to be, and think they can be delayed or modified, they will hold back
investment.  They will not push forward on programs to really deal with environmental
issues.  The arm wrestling match guarantees that progress will be quite slow. Both sides
will battle over  one inch of  territory, not unlike World War I.
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Clean Air Marketplace 1993                                             Page 39
       Now as you have probably already guessed, I  do not believe that the struggle
perspective is the right way to frame the issue.  The focus should not assume a fixed
inherent tradeoff, but on how we can relax that tradeoff as much as possible, and perhaps
even  eliminate it.  This  framing  of the  problem provides  an  opportunity  for  what
economists call a "positive-sum game"  Making the environment-competitiveness nexus
into a positive-sum game, however, will require  some profound changes in just about
every aspect of the way in which we think about environmental issues, craft regulations
as well as in the way companies, EPA and environmentalists behave.

       The Static View of Environmental Regulations

              The struggle metaphor  grows out  of what I would call a static view of
       environmental regulation.   A  static view  is one  in  which  everything  is held
       constant, but environmental regulations are imposed. Technology, products, and
       customer needs are held constant.  In this static  world, environmental regulation
       raises costs and, with a downward sloping demand curve, reduces profits in the
       private sector.  In a static  world, environmental regulation inevitably reduces
       competitiveness.   Assuming that the U.S. is  more regulated, and more strictly
       regulated than a  variety of other countries,  compliance  in a  static world will
       inevitably inflict higher costs on U.S. industry that will lower domestic profitability,
       and/or lost sales if competition is international.

              Regulation will  create  some demand for  environmental products and
       services;  so although regulation will inflict costs on the affected industries,
       environmental products and services suppliers will benefit. That will provide a
       partial private offset against the cost, assuming that there are  capable domestic
       suppliers of pollution control  services and equipment.  But  the two  will not
       balance, and  the economy  will be worse off.  The nation may  gain  a cleaner
       environment, but at the expense of private costs that can be substantial.

       The Dynamic View

              My previous discussion should suggest to  you  that we are not in a static
       world. And indeed, the static mentality represents the old view of competition
       which we must shed. What we are in, instead, is a dynamic world. We are in a
       world  where everything does not stay  constant.   Just because we  impose
       environmental regulation does not mean we have to hold everything else the same.
       In a dynamic world, of course, things can look very, very different. In a dynamic
       world, firms can respond to environmental regulation or even anticipate it with
       innovation. This innovation can take one of two broad forms.  One form consists
       of new technologies and approaches that minimize the  costs of compliance.  Here,
       we get smarter and smarter  on how to  deal with toxic  materials, or  process
       emissions.  But there is another form of innovation that is even more interesting
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       and more exciting. These are innovations that address environmental regulation
       which simultaneously leads to improved products and processes.

       Think of it as a bonus,  In innovating a deal with an environmental regulation, a
firm may also benefit the core product  or process itself.  This produces what we call an
innovation offset, which can partially offset the net cost of compliance.  In some situations,
the innovation offset may be greater than the cost of compliance. We have documented
quite a number of cases where the compliance with the environmental regulations had a
net profitable impact on the company.  Not only was there zero cost, but there actually
was a negative cost in dealing with  environmental regulation.

       If environmental problems can be addressed through innovation, we also  get
another bonus. Innovative solutions will not only help the affected industries be more
competitive, but also help U.S. suppliers of environmental products and services industry
be more competitive.  To  the extent that firms are innovating to deal with environmental
problems, local suppliers will gain a competitive advantage in selling those environmental
products and services in foreign markets where the demand for innovative technologies
is exploding.

Answering the Critics

       I originally put forward the  argument that strict regulation  was not inconsistent
with competitiveness in a short Scientific American essay.  This essay has received a good
deal of scrutiny, far beyond what I could have predicted.  It has been warmly received by
many, especially in the business community.  But I have  also had my share of critics,
especially among economists.

       One criticism of my argument is easily dealt with.  Some have read my Scientific
American essay to  say that I  believe that I  believe that strict environmental regulation
inevitably leads to  innovation and competitiveness. This is not what my argument is,  nor
what the essay actually says. My argument is that innovation to minimize and even offset
the cost of compliance is possible in  many circumstances, provided that regulations were
properly crafted. We must focus, then, on relaxing the trade-off between the environment
and competitiveness rather than accepting its as given. Any innovation offset is a plus for
both the environment and industry.

       Yet there are more legitimate criticisms that must be dealt with. One is that the
opportunity for innovation offsets is exceedingly rare, even though theoretically possible.
Here, our argument is that the most  important reason we would expect innovation offsets
in many circumstances is the nature of  pollution itself.  Pollution is the emission or
discharge of a harmful substance into the environment.  If you think about it, pollution if
fundamentally  a  manifestation of economic waste.  It involves incompletely using a
resource, throwing a resource away,  or burning something.  The opportunity to lower  cost
by eliminating pollution,  then, seems anything but rare.
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Clean Air Marketplace 1993                                             Page 41
       Think of the analogy of quality. Companies used to think about quality in terms
of reducing the number of defects. To do so, the prevailing practice was to have many
inspections.  Then the idea was to have a really good service organization in order to
correct the product quality problems that turned up in the field.  As we have rethought
the quality issue, however, this approach has proven to be the wrong one.  The best way
to think about quality is to figure out how  to build in quality  at the source, which is
usually in the design, the purchased components, the process technology, the shipping and
handling  techniques, and so forth.   Inspections and  the  need  for a  large  service
organization can be dramatically reduced. This leads to the off-quoted phrase, "quality
is free." Given the nature of pollution, I think the analogy with quality is a good one.
There is every reason to believe that we could have substantial innovation offsets in many
circumstances.

       Another  observation  is  that  estimates  of regulatory  compliance  costs  are
systematically biased upward. Estimates  prior to regulation are  usually higher than the
actual costs, because early estimates assume no innovation. In coatings, for example, early
estimates involved  holding everything else constant and  added a hood  to capture the
fumes  from the paint line. Yet, it has proved possible to remove  the volatile compounds
from the paint, and eliminate the need for the hood altogether. Moreover, the new solvent
could be water rather than an expensive chemical. The compliance cost estimates used by
most studies are those self reported  by industry,  and no one every goes back and
compares them with actual practice.

       Net compliance costs are biased upward in  every single study that shows that
environmental regulations raise costs and harm competitiveness. All such studies measure
is cost.  The  models literally assume away any innovation benefits.  How, then, could
econometric studies reach any  other  conclusion than they  do?  Moreover, traditional
approaches to regulation have not fostered innovation and thus imposed unnecessarily
high costs of compliance on industry.

       My joint research with Dr. Claas van der Linde of St. Gallen University, work by
the Management Institute  for Environment and Business, and other research has  started
to assemble a body of case shady evidence  that provides  quite  striking examples of
innovation to respond to environmental regulation. These innovations sometimes created
offsets that exceed the cost of compliance. Let me return to the Dutch flower industry.
The industry has a serious  environmental problem.  Cultivating flowers intensely in small
areas creates pesticide and fertilizer  contamination  of the soil and groundwater.  The
Dutch have understood that they only way to really address this problem is to innovate
by moving to a closed-loop  system.  In advanced Dutch greenhouses, flowers grow in
water and are not in contact with the soil. The water circulates and contains the fertilizers
and pesticides.  Water is reused, and  the need for fertilizers and pesticides is reduced,
because of the absence of soil and a lower risk of infestation. By designing the cultivation
platforms correctly, it is  also possible to reduce  handling cost.   In eliminating the
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environmental problem, then, the Dutch have  simultaneously  lowered cost and even
improved product quality.

       Stringent regulation can actually enhance competitiveness because it pressures
greater innovation offsets.  Relatively lax regulation can be dealt with easily without
innovation, and often with "end-of-pipe" solutions. More stringent regulation, however,
requires more innovation.  While the cost of compliance may rise, so also does the offset
to these costs because of the innovation.  Thus, the net cost of compliance often seems to
fall with stringency and may turn  negative!  This is before adding in the innovation
benefits for supplier industries.

       There are many such examples, and the numbers will proliferate as companies (and
regulators) become more sophisticated and shed old mindsets.  And I am taking  into
account  any benefits  from  so-called  "green  demand"   (consumers wanting more
environmentally friendly products).  Instead, the static mindset has created a self-fulfilling
prophecy of ever more costly environmental regulation. It has also spawned an entire
industry of litigators and consultants fighting  over  regulation, driving up  costs,  and
draining resources from real  solutions.

The Need for Regulation

       One of the most common criticisms of my argument is that if there is money to be
made innovating to deal with environmental regulation (i.e., if you can actually offset the
cost of compliance), why is regulation necessary?  If such profitable opportunities existed,
companies would already be pursuing them. The first answer to this criticism is that some
companies do, especially in European companies such as Germany and Scandinavia where
both companies and consumers are very sensitive to environmental issues. While this may
be more true in  the United States  in future  decades,  we  are now in a phase  of our
industrial history where  companies are  inexperienced  in dealing  creatively with
environmental issues.   The environment has not been a principal area of technological
emphasis.

       Regulation is needed  for five major reasons:

             Regulation signals and provides information to companies about potential
             payoffs.   A typical company  has  numerous avenues  for technological
             improvement  and  limited  attention  and  resources.   Companies  are
             inexperienced  in measuring environmental impacts, understanding the full
             costs of toxicity and discharges, and conceiving of new approaches  that
             reduce discharges or eliminate  hazardous substances.  Regulation rivets
             attention to this area of potential innovation, just as total quality programs
             have in the 1980s and early 1990s.
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       •      Regulation reduces uncertainty about the demand for solutions to
             environmental impacts.  Regulation reduces uncertainty that investments
             to address the environment will be valuable.

       •      Pressure  from  regulations  acts  as  a  motivator.    My  work  on
             competitiveness highlights an important role of pressure in the innovation
             process, to overcome inertia and foster creative thinking. Strict regulation,
             if it structured  to allow innovative solutions, fosters progress.

       •      Regulation addresses  the case of incomplete  offset.  It is not always
             possible to completely offset the  cost of compliance  through innovation.
             There will still be a net cost of compliance, but nearly as large a cost as
             dealing with environmental problems without innovating (e.g., by adding
             a hood  to capture the fumes versus changing the paint).

       •      Leveling the transitional playing field.  During the transition period to
             innovation-based solutions, regulation  ensures that one company cannot
             opportunistically gain position by avoiding environmental investments.  It
             provides a buffer until new technologies become acceptable.

Barriers to Innovation

       My central message is that there is great potential to limit or relax the tradeoff
between environmental regulation and competitiveness via innovation. To the extent that
we can relax the tradeoff or even eliminate it, the nation will enhance the competitiveness
of its companies and suppliers at the same time as it makes progress on environmental
quality.

       Yet considerable barriers are  present in  our current system.  Perhaps the most
important single  barrier is mindset.   As long as the constituencies see environmental
regulation as a  fundamentally adversarial, win-or-lose process, innovative solutions will
often not even be considered.  Other  barriers  to innovation  can be divided into two
categories:

       The Content of Regulatory Standards

       One of our problems in the United States is that we have gone about regulation in
a way that actually makes it difficult, if not impossible, to introduce innovative solutions
versus "put-the-hood-over-the-paint-line"  solutions.    What  we should be  doing  is
regulating outcomes, not technologies.  Instead, the  phrase "best available technology" is
deeply rooted in  American thinking, which  almost guarantees that innovation will not
happen.  It raises the perceived  risk and thereby creates major disincentives  for any
company that attempts to deal with an environmental problem in an innovative manner.
Our regulations must encourage product and process changes rather than treating discharges.
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       We must make sure that our environmental regulations are in synch (but slightly
ahead) with the rest of the world.  We must avoid adopting philosophy A when every
other country in the world is pursuing philosophy B, or the competitiveness of  U.S.
companies and U.S. suppliers of environmental products and services will be undermined.

       We need significant phase-in periods for regulations. We need to give companies
as much flexibility as possible to address environmental problems in fundamental ways.
WE need to understand how unrelated regulations regard innovation.  To eliminate CFCs
and HCFCs from refrigerators, for example, one solution involves a mix of small amounts
of propane and butane. But safety regulations in the United States seem to have impeded
a shift to the new technology, while  European companies are already marketing  new
products. We need to do more of what the Clean Air Act has finally started to do, which
is to build market incentives for innovation into regulations.

       Finally, we need  to rethink some of the liability issues.  Liability exposure in the
United States works against new innovative approaches, and leads companies to take  safe,
"best available technology," "what everybody else does" approaches.  We must provide
adequate safeguards against companies recklessly harming  citizens,  but  recognize the
health and safety benefits of innovation.

       The Regulatory Process

       I suspect that even more important than the content of regulatory standards as a
barrier to innovation is the process in place in the United States for setting, implementing,
and enforcing the standards. It is hard to imagine a regulatory process that is more  anti-
innovation than the one we have in this country.

       What kind of a  regulatory process do we need?  We want to process  where
industry accepts standards as a given and starts doing something to  meet them, rather
than spending years dodging and feinting trying to water down standards and learning
what they will actually be.  In our current system, once standards are  finally settled, it is
often too late to address them fundamentally. We need more certainty and predictability,
so that it pays to innovate rather than adopt a short-term expedient.  We need to evolve
toward a regulatory regime in which the EPA makes commitments that standards will be
in place for, say, five years, so that industry can lock in and innovate around them instead
of hedge against the next twist or turn in direction.

       We need substantial industry  participation in setting standards right from the
beginning — not industry participation in the  arm-wrestling mode.  The industry must
develop the  trust to provide genuine information reactions, and regulators must develop
the trust to take it seriously.

       We need a much more efficient process that minimizes the resources expended on
the process versus cleaning up the environment.  A crucial priority is new forums which
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Clean Air Marketplace 1993                                             Page 45
minimize litigations.   In  Massachusetts, there is  actually a money (filing fee) back
guarantee if a company does not get an answer on the permitting process within 60 days.
While this may seem trivial, the Department of Environmental Protection has not missed
it once. These sorts of approaches must proliferate.

       We need  the  different  parts  of  government  to  organize  themselves  so that
companies can understand again what the requirements really are.  We need  strong
technical capabilities among regulators so that regulation and enforcement can understand
and accept novel solutions. Finally, we need to build innovation incentives into not only
standards but  the regulatory process.  In Massachusetts, for example, the Commissioner
is able to waive permits in some circumstances or promise an immediate permit if it will
take a zero-discharge approach, versus a "careful review"  if the company wants  to
continue discharges. This creates strong incentives for innovation rather than end-of-pipe
solutions.

Imperatives for Companies

       If we adopt this new perspective, what are the implications for the constituencies
now engaged  in the environmental area?  Companies, first and foremost, must start to
recognize environmental regulation and environmental issues as a strategic opportunity
— not as an annoying cost, not as a threat.  The early movers, the companies that can seize
the opportunity first, that embrace innovation-based solutions, will reap major competitive
benefits. We are already seeing the competitive advantage of environmental innovation
in a widening array or cases.

       Companies must start by deeply understanding and measuring what it is that they
are doing that impacts the environment. One of the reasons that companies are not very
innovative about  the environment is ignorance.  Companies have not analyzed the true
cost of toxicity, waste, and discharges.  Relatively few companies look not only at the out-
of-pocket costs of these things but also the opportunity cost. How much money is going
up the smoke stack? What portion of inputs are being wasted? What are the second-order
impacts of waste and discharges on other activities?

       Once environmental impacts are understood, companies must make innovation-
based solutions the expectation. In order to find such solutions, environmental strategies
must be embedded in overall competitive strategies.  They must be a general management
issue if the sorts of process and product redesign needed for innovation is to  occur. The
more environmental issues are delegated to individuals without profit responsibility, the
more a company will tend to get incremental solutions.

       Finally, companies are clearly  going to have to start  investing in new kinds of
innovation and 'new technologies that  have not been seen as relevant to their businesses.
These sorts of capabilities are necessary to really address environmental  issues.
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Imperatives for EPA

       Given this perspective, what is an appropriate mission statement for the EPA? I
want  to  emphasize that what  follows  is not officially sanctioned, but I  offer  it as
illustrative.  A central goal  of the EPA should be to promote innovation  to  enhance
environmental quality, including innovation in compliance technologies and innovation
in ways to offset compliance costs via more efficient processes or better products. EPA's
central mission would be to foster innovation because it lessens the tradeoff  between
environmental benefits and private  costs and will lead to the fastest rate of true progress
in environmental quality.

       The EPA's regulatory standards would be to set to maximize innovation potential.
Every single standard  that was issued would be scrutinized deeply from this perspective,
to encourage innovation-based  as  opposed to status quo  solutions.  Some important
principles for standard setting have been outlined earlier.

       Similarly, the regulatory process would be fundamentally reexamined to minimize
cost and to foster innovation. Legislative changes may well be required.  There  is also a
need to change the way the EPA deals with the states. Right now, the EPA measures state
performance  in  terms of  how many inspections  are  conducted,  not how much
improvement  in  environmental  quality  they  achieve  or cost/benefit  rations  of
improvements in various areas.

       The EPA must move  beyond the medium (air, water, etc.) as the principal way of
thinking about the environment.  It  would reorganize around affected industries  to better
understand industry processes and technology and its total set of problems. This will
foster innovative rather than piecemeal solutions.  We also need to eliminate the practice
of hiring multiple inspectors of the same plant who do not talk to one another, and
consume time and resources unnecessarily.

       To play its modified role, the EPA would not only worry about affected industries
but also about the nation's environmental products and services suppliers. The health of
this sector  is crucial to the pace of innovation.  There would be an explicit strategy for
upgrading  this  sector, not  only because  it will  be crucial in addressing  America's
environmental problems but because it is a major potential area of competitiveness in our
economy.

       The EPA would employ a lot of demonstration projects to stimulate and seed new
technologies.  I would  caution against heavy reliance on government laboratories  for  these
projects because this will slow diffusion.  Instead, the EPA should be encouraging private
sector entities such as universities and industry associations to pursue such efforts.

       A major point  of leverage for the EPA is to  harness the role of government as a
buyer. The EPA would coordinate  procurement of environmental products and services
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throughout government.  The aim would be that government act as a sophisticated and
demanding buyer that demands innovative solutions to environmental problems. There
is going to be a lot of money spent by the Federal government on environmental issues
in the next decade.  This spending should be pro-innovation, where the government
provides a market for innovative solutions rather than old solutions. Finally, EPA would
play a major role in creating information on the economics of compliance, innovation, best
practice, trade in environmental equipment and services, and other topics which will speed
innovation and sharpen our understanding of these issues.

The Role of Environmentalists

      This  way  of thinking also  casts new light on  the  appropriate  role  of
environmentalists.  While the "progress at any cost" stage was probably necessary, it is
time  to move beyond it.  It would submit that the best way to further the goal of
environmental quality today is to foster an innovation mentality.  Environmentalist groups
should be speaking out for regulatory standards that  are pro-innovation.  They should
devote substantial resources to educate the public to create a demand  for environmental
solutions, which will motivate companies to supply them, rather than only addressing the
supply side. They should also be thinking differently about  their role in the  regulatory
process.  Rather than prolonging uncertainty, environmental groups must work to reduce
the uncertainty about acceptable  and appropriate standards.  Rather than consuming
resources in filings and litigation, the focus should be on maximizing the  proportion of
resources devoted to actual solutions.

       Environmental organizations need to develop  deeper interaction with industry.
Our environmental organizations could become sources of information and best practice
about how to innovate your way around environmental problems.  Some of the resources
of environmental organizations could also be used to fund research on minimizing the cost
of addressing environmental problems, especially as it applies  to fragmented industries
composed of many small  companies.

Closing Remarks

       In summary, we need  a  whole new way of  thinking about  the  environment-
competitiveness nexus — a way that is closer to the reality of modern competition.  We
need  to focus on relaxing the tradeoff rather than heightening it. We  need an approach
that minimizes, and ideally eliminates, the energy, time, and resources  spent not on
improving the environment but on the struggle over regulation.  It is not at all surprising
that the environment-competitiveness debate has emerged the way it has.  But now is the
time for a paradigm shift to carry us for the next several decades. The real winners among
environmentalists, regulatory agencies, companies, and suppliers will be those that can
adopt innovation-based solutions rather than accepting current technologies or established
approaches to compliance.
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Clean Air Marketplace 1993
                                Page 49
                         Session 3 — Panel A
                         Electric Power Technologies
                         Septembers, 1993
                           2:00 p.m. - 4:00 p.m.
                         Moderator:
                         Panelists:
Paul Stolpman
Eugene Crossland
William Elliott
Steven Feeney
John Huffman
Presentations

          Eugene Crossland, Pure Air, introduced his remarks by explaining the role of
          Pure Air.

          Pure Air is a partnership between two Fortune 200 companies — Mitsubishi
          Heavy Industries America (MHIA), an SO2 scrubber technology company, and
          Air Products and  Chemicals, a company which provides long-term clean air
services.  Pure Air is involved with a Department of Energy (DOE)-sponsored Clean Coal
Demonstration project at the Bailly Station.  This powerplant is owned and operated by
Northern Indiana Public Services Company (NIPSCO).  Pure Air has constructed an SO2
scrubber  at the Bailly Station and through a project  company  owns and operates  the
scrubber under a 20 year contract with NIPSCO.

       The Clean Air Act Amendments create a  large market for SO2 removal. As a result
of this legislation,  there was a  shift  from "command and  control" to "least-cost
compliance" where each utility must select the compliance option that provides the least
cost option for the utility. The Bailly Station project couples advanced technology and the
unique Own-and-Operate commercial arrangement to provide  a least-cost compliance
package.

       DOE has been awarding money for jointly-funded demonstration projects under
the Clean Coal Program. The Bailly Station was awarded funding under the Clean Coal
Round II program. DOE provides up to 50 percent funding for design, construction, and
operation of projects  to demonstrate new clean air technologies.  The goal of the Bailly
project is to include all viable, advanced technology developments and commercial features
to provide a low-cost air pollution control system. The Bailly Station project between Pure
Air and Northern Indiana Public Service Company (NIPSCO) was given $63 million by
DOE and came on-line in June 1992.  Under this project, a large single-module scrubber
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Clean Air Marketplace 1993
system was built to service two boilers at the facility, a concept which is unique in the field
of clean air technology.

       The following table illustrates some features of the NIPSCO/Pure Air project:
High SO2 Removal
Single 600 MW Module
Multiple Boilers
Maximum Fuel Flexibility
High Efficiency Oxidation System
Commercial-Grade Gypsum
Dry Injection of Powdered Limestone
SO2 Allowances
Over 95 percent
99.9 percent availability
99.9 percent availability
2 percent to 4.5 percent sulfur testing
Complete FGD system requires less than 1.5
of total station capacity
100 percent sold to the a wallboard facility in
percent
the area
Reduced capital cost
Pure Air and NIPSCO shared credits
       The Bailly Station project is a co-current wet limestone flue gas desulfurization
(FGD) system.  In this system, the SO2 is converted to calcium sulfite, then is oxidized to
form calcium sulfate (gypsum).  A centrifuge is used to dewater the Gypsum.  Gypsum,
a commercial by-product as opposed to waste, is made into wallboard. The chemistry is
simple; but what is unique is the  order of magnitude  of the system and its efficiency.
Efficiency is a key to this system; this is accomplished by a large single module which is
unique in the industry.

       What is also unique about the Bailly Station is the partnership which was formed
between Pure Air and NIPSCO. Pure  Air owns and operates this scrubber and is under
a 20-year contract with NIPSCO.  Once the three-year demonstration project is over, Pure
Air will  continue to operate at the facility for 17 additional years.   Therefore,  Pure  Air
provides a scrubber service to NIPSCO.
           William  Elliott, Vice  President  and  General Manager, Electric Supply,
           Northern  Indiana  Public  Service  Company  (NIPSCO),  gave  explanatory
           remarks about NIPSCO.

           NIPSCO  Industries, Inc. is an energy-based holding company.  Its  largest
           subsidiary, Northern Indiana Public Service Company, is a regulated natural
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gas and electric public utility company serving a 12,000 square-mile area with a population
of 2.2 million people.

       The Bailly Station  project, a partnership between NIPSCO and  Pure Air, is a
demonstration project for the DOE Innovative Clean Coal  Technology Program.  The
program and the partnership provided Bailly Station with superior technology, experience
in chemical processes and, due to DOE's program, a 20-year contract. The partial funding
from  DOE  provided a  benefit  to  NIPSCO's  customers  by  reducing the  cost  of
environmental controls needed to comply with Clean Air Guidelines, and allowed NIPSCO
to continue to burn high-sulfur coals found in their State.  This, over time, benefits the
Indiana Coal Industry and provides NIPSCO customers with low-cost fuel flexibility.  As
the project advanced, the Indiana Utility Regulatory Commission, United States Gypsum,
and numerous suppliers and trade unions joined the partnership.

       Start-up at Bailly Station occurred  on June 2, 1992,  and commercial operations
commenced on June 15, 1992.   Between start-up  and  June  1995,  six  one-month
demonstration tests will  be performed to assess scrubber operations with a variety of coals.
All will be bituminous coals with sulfur contents ranging from 2.0 percent to 4.5 percent.

       The partnership  presented a  new concept for NIPSCO.  In the  past, we have
entered into many  partnerships, especially  in  generating  stations; however, these
partnerships have been  "maintenance" related.  Leasing space  to an outside company to
build, own, operate, and maintain a plant attached to NIPSCO equipment presented an
uncertain  and an unsettling concept.  However, further analysis of the concept indicated
that the ultimate benefit of this partnership would rest with NIPSCO and our customers,
resulting from Pure Air's years of design, engineering, and chemical operating expertise.
The result would be a plant with minimized operating costs and guaranteed  maximum
efficiency  over the contract period.

       The operating characteristics of Pure Air have been outstanding. During the past
twelve months, the Pure Air facility:

             Scrubbed  3,123,314 MWH;

       •      Had a facility availability of 99.93 percent (in hours) and 99.97 percent (in
              MWH);

       •      Removed  79,248 tons of SO2; and

       •     Shipped 216,344 tons of by-product gypsum to U.S. Gypsum.
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       Our teamwork allows us the opportunity to think about what NIPSCO does best
— generate electricity.   Therefore,  there  has been  an improved  station  operating
performance perspective since the Pure Air facility came on line.  The statistics for the year
to date demonstrate significant improvement in forced  outage rate and availability:

       •      Forced Outage Rate:
             >  0.74 percent Actual
             •>  7.62 percent Goal (or 6.68 percent under plan)

       •      Availability:
             >  90.12 percent Actual
             ••  82.96 percent Goal (or 7.16  percent over plan)

             Heat Rate:
             >  10,174 BTU/kWh Actual
             -  10,059 BTU/kWh Goal (or  1.1 percent over plan)

       In closing, NIPSCO has made  a long term commitment to the Northwest Indiana
Region's clean air standards with the  emphasis on keeping costs competitive. There will
continue to be a commitment to our partnerships with  Pure Air, U.S. Gypsum, the State
of Indiana, the Department  of Energy, and many others. The last twelve months of
operations prove that this blending of people and machine technology are worth using
elsewhere to meet clean air standards.
           John Huffman, Project Development Manager, Kenetech/U.S. Wind Power Inc.

           On the surface, the resource planning challenge seems straightforward. Most
           utilities enjoy a  favorable position with low energy costs, new base load
           capacity needs after 2000,  and combustion  turbines in the near term for
           peaking power. However, recent events have created uncertainties. The Clean
 Air Act Amendments of 1990 (CAAA) created uncertainty surrounding SO2 allowance
 prices, ultimate NOX compliance requirements (Title I), and possible air toxic emissions
 caps (Title IE). In addition, there are potential for energy taxes, CO2 reductions, and an
 uncertainty about future prices and availabilities of fuels. All of these uncertainties must
 be reconciled with increasing pressures to keep costs low.

       In the  past, utilities  did not consider wind  power because early turbines  had
 unproven technical reliability and poor economics.   However, ENETECH/U.S. Wind
 Power Inc.'s (the world's largest wind power company with over 750 employees) recent
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Clean Air Marketplace 1993                                             Page 53
introduction of the 33M-VS Wind Turbine dramatically changes wind power's potential.
Wind power can now help utilities deal with resource planning uncertainties and wind
may be the least cost CAAA compliance option while hedging against fuel price risks and
additional environmental regulations.

      Wind power evolved in the 1980's into  a mature generating technology with a
proven  1,600 MW installed in California, with  current  availability  rates exceeding  95
percent.  Wind has also proven to be a predictable source of power with seasonal and
time-of-day patterns.  But  despite rapid gains, the economics of wind power were not
competitive with conventional power plants until U.S. Wind Power developed the 33M-VS
Utility-Grade Advanced Wind Turbine with key utility partners:  Pacific Gas  & Electric,
Niagara Mohawk Power Corporation, and Electric Power Research Institute. Development
was completed one and one-half years  ago and the technology breakthrough of the
product is its variable speed operation. The 33M-VS wind turbine delivers power at 5
cents/kWh power, making it competitive with  conventional plants.   In addition, wind
power provides a  wide range of environmental benefits compared to conventional power
plants because it has zero emissions.

      The Energy Policy  Act  of 1992 included  a production tax credit  for wind, thus
making  wind power more advantageous  than conventional power plants.  The Energy
Policy Act provided wind  power with a 1.5 cents/kWh  tax credit which escalates with
inflation for projects placed in service between 1994 and  1999. Thus, on a real levelized
basis, and  with lower-cost  utility financing, the cost  of  wind  is  approximately 3.6
cents/kWh.

      U.S. utilities have committed to over 430 MW so  far with 165 MW  windplant
purchases, 20 MW power plant purchases and 250 MW in joint development agreements.
Utilities using the  33M-VS Wind Turbine include: New England Power, Iowa-Illinois Gas
& Electric, PacifiCorp and Bonneville Power, Portland General, SMUD, and Puget Sound.
Some near-term, publicly-known opportunities for the wind industry include 100 MW of
wind power to Northern States Power, 50 MW (AVG) of renewables to Portland  General,
and 700 MW of renewables to California utilities.

      Wind Power can add near-term economic value as a least-cost CAA compliance
option by displacing marginal (SO2 emitting) energy. Wind's source of value comes from:
capacity value, energy savings, SO2 savings, and production tax credits. The value created
offsets wind's capital cost,  creating a negative cost of compliance (a savings).  Wind can
create savings  for every ton of  SO2 removed making it the least-cost compliance option,
regardless of where the market price for  SO2 allowances settles.  The sources  of value
described in detail are:

      •     Capacity Value:  Wind's capacity value is the highest when there  is a high
             correlation between the wind resource and utility peak load.
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Page 54                            	  Clean Air Marketplace 1993


             Energy Savings: Wind has zero fuel costs and stable O&M costs, making
             it valuable as a fuel displacer, even when coal is on the margin.  Also, wind
             acts as a hedge against uncertain future fuel prices.

       •     SO2 Savings: By displacing marginal energy, wind frees up SO2 allowances
             which can then be used or sold for profit.

       •     Production Tax Credits:  1.5 cents/kWh escalating.

       Wind creates value as a CO2 mitigation option  making wind  preferable to tree
planting as a compliance option while providing an excellent hedge against carbon taxes.

       In conclusion, wind  power  is a proven  technology  and is feasible in today's
economy. It is an excellent hedge against future energy taxes, additional regulations on
emissions of CO2, NOX/ and toxic air pollutants, and future prices and availability of other
fuels.  It also offers other advantages such as short development and  construction lead-
times.
           Steven Feeney, Manager of Upgrade  Projects and Services,  Environmental
           Equipment Division, Babcock & Wilcox, Inc.  Babcock and Wilcox is part of
           McDermott International, a company with $3.1 billion per year in revenues,
           traded on the New York Stock Exchange.

           The following are engineered products  of the Environmental Equipment
 Division of Babcock & Wilcox.

        •      Wet Flue Gas Desulfurization  (Wet FGD) is a staple of the environmental
              equipment division. As a result of Phase I of Title IV of the Clean Air Act
              Amendments of 1990, Babcock & Wilcox led the market with five contracts
              for Wet FGD's.   Of these five,  two have been delayed and three are
              currently under construction.  There were a total of 18,425 MW contracted
              for in the U.S. as a result of Phase I. Of this, 4,350 MW have been delayed
              and 14,075 have been confirmed.  The three leaders supplying equipment
              are Babcock & Wilcox, ABB, and General Electric. Some of the companies
              which have delayed construction in Phase I are Commonwealth Edison,
              CEI, Illinois Power, Niagara Mohawk, and Tampa Electric.

        •      Selective  Catalytic Reduction (SCR) is a  technology utilizing a  catalyst
              located downstream of the economizer on a utility boiler and upstream of
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Clean Air Marketplace 1993                                             Page 55
             the air heater.  In the process ammonia is injected in front of the catalyst
             and NOX is reduced to nitrogen and water. Throughout the world, 100,000
             MW have been installed, 23 percent of these by Babcock & Wilcox or its
             licensor, Babcock-Hitachi.

       •     Electrostatic precipitators  are a participate removal device.  Babcock  &
             Wilcox  has 30,000 MW  of electrostatic precipitations installed worldwide
             with our German Licensee, Rothemuhle.

       •     Dry Flue Gas Desulfurization (Dry FGD), of which approximately 6,000 MW
             of utility systems are in operation in the U.S., generally with low-sulfur
             Western coals.  Typically, Dry FGD is considered appropriate for low-sulfur
             Western coals.  However, this perception is changing.  Dry FGD has not
             been a popular compliance option as a result of Phase I; no projects have
             been sold.

       •     Clean Coal Technologies involve advanced technologies for the reduction
             in emissions of SO2, NOX, and particulates.

       •     Condenser Heat  Exchange (CHx) is a heat recovery system.  CHx  is a
             technology  which hopefully will  reduce air  toxics in  the future.   The
             technology involves teflon coated tubing which can operate below the acid
             dew-point without affecting the tubes. It has found widespread use in heat
             recovery, but it will prove to be an air toxics control device.

       There is also an international focus  to Babcock & Wilcox.  Currently Babcock  &
Wilcox has joint ventures in Mexico, Turkey, China, India, and Indonesia.

       Market trends  for the  future include:

       •     Fuel switching  — 60,000-65,000 MW of fuel switching resulted from Phase
             I.  Many times,  fuel switching requires boiler and accessories modifications.

       •     NOX — called the awakening giant — represents a very large market in the
             future.  Non-attainment requirements may make  NOX a bigger capital
             investment than SO2 in the future;

       •     Phase II of CAA  Amendments of 1990, starts in the year 2000 — Delayed
             by a few  years, the decision of customers and as a result, there is little
             activity;

       •     Allowance market — This could be big in the future. There is a way for
             existing FGD systems to inexpensively upgrade  their  units and remove
             more SO2.  If a company could upgrade its units for greater SO2 removal
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Page 56                       	Clean Air Marketplace 1993


             and receive credit in Phase I through a "substitution plan," in many cases
             it would be an extremely low-cost option.  Recently, however, EPA sent a
             proposal to OMB to change the substitution rules and EPA is not taking any
             more permits or plans for substitution. This could be a fatal blow for a low
             cost option.  EPA should  revisit the policy of substitution for those units
             which actually reduce their SO2 emissions below where they otherwise
             would have  been without the planned substitution.


Questions and Answers
         Wliat is the difference between the utility building a scrubber and Pure Air
         building the scrubber?

         Since utility companies are a regulated community, they can not push the edge
of technology. The scrubber system that the utility would choose may  be different than
the one Pure Air chose to build since Pure Air is a non-regulated company.  For example,
it is unheard of for a utility to tie together two boilers to one scrubber.  Also, the operating
philosophy is different because Pure Air sees a scrubber as a chemical plant, and not a
power plant.  Even if they built the same product, the operating mind-set would probably
be different and this would  make a difference in how the scrubber is run.
If wind power technology is so great, why isn't everyone doing it?
      L
  *>
   •  I  The variable  speed technology that  makes  wind  power  competitive  with
"^"^•"  conventional power plants has just arrived and a lot of education is Involved.
The economics are extremely compelling, and you will see many more utilities (in addition
to the ones mentioned) sign up for wind power.
         How much power does wind power produce and what is the minimum wind
         needed?

         Mr. Huffman answered that the windmill needs 15-16  miles per hour average
annual wind speed to make the economics win.  The 33M-VS is  a 400 kW machine and
provides power at an installation cost of $750-$800/kW.
Session 3A — Electric Power Technologies

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Clean Air Marketplace 1993
                                 Page 57
                          Session 3 — Panel B
                          Stationary Source VOCs/Air Toxics Control
                          Septembers, 1993
                           2:00 p.m. - 4:00 p.m.
                          Moderator:
                          Panelists:
Bruce C. Jordan, Jr.
C. Shepard Burton
Dr. Orman A. Simpson
David A. Doles
Paul D. White
Introduction

       Bruce C. Jordan, Jr., Director of the Emission Standards Division, Office of Air
Quality Planning and Standards, U.S. EPA, is responsible for implementing major portions
of the Clean Air Act Amendments, including the Air Toxics Program.  The discussion
focused on stationary source controls and VOCs, and specifically concentrated on how
market forces might affect the Air Toxics Program and the way regulations are structured.

       EPA has traditionally used a "command-and-control" approach to regulate.  This
approach is a hard barrier to  overcome, not only for the  regulators, but also for the
industries responsible for adhering to  the regulation.  Regulations  become constrained
because of the way they are structured and this hampers the development or use of market
forces in regulatory programs.  This hindrance occurs in two ways:

       •      The way that regulations are actually written  forces the use of preexisting
             technology, and inhibits innovative technology. Oftentimes, the regulation
             focuses on proven technology, either in setting the performance standards
             or in identifying the type of control technology that  would satisfy the
             requirement. This actually may prohibit the development of innovative
             approaches that achieve reductions in a more economical and efficient way.

       •      The emphasis that regulators have  put on creating enforceable programs
             has also hindered the development of  market forces  and flexibility. The
             interests of simplicity and enforceability have led regulators to focus  on
             controlling pollution from individual emissions points.  It would be much
             more flexible, however  to allow each  facility to decide for itself which
             individual points to control and which  means to  use.
                         Session 3B — Stationary Source VOCs/Air Toxics Control

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Page 58                                             Clean Air Marketplace 1993
Presentations

          C. Shepard Burton, Senior Vice President at ICF Kaiser Engineers Environment
          Group, is responsible for the air consulting and air compliance business unit.
          Mr. Burton focused his talk on fugitive emissions, particularly in the refinery
          and chemical manufacturing industries.  According to Mr. Burton, the rules
          governing fugitive emissions are complex; there  is a sizable opportunity for
          companies like  ICF  Kaiser, and  there is a sizeable expense  involved for
companies that have to comply.

       •      Complexity.  There are numerous Federal, state and local rules governing
             VOCs and volatile hazardous air pollutants (VHAPs) that facilities must
             deal with.  For VOCs, the requirements mostly stem from  Title I of the
             Clean Air Act.  Some states, however, have their own rules and/or  local
             rules with which to comply as well. Volatile hazardous air pollutants are
             dealt  with under  the NESHAPs,  RCRA, and  HON  (Hazardous Organic
             NESHAPs) rules.  A facility located in the Bay Area, for instance, may have
             to  comply with NSPC, NESHAPS, RCRA, HON, CAA RACT rules, and
             rules specific to the Bay Area Air Quality Management District.  Each of the
             rules  differ according to leak  definition, monitoring frequency, repair
             requirements  and  reporting/recordkeeping requirements.

       •      Costs. $70-$140 million is spent each year by the chemical manufacturing
             and refining industry to  comply with the VOC regulations and fugitive
             emission rules. After the MACT implementation, this number will increase
             to  approximately $400-$800 million. The increase in cost figures is due to
             the increasing number of facilities that will be regulated, the additional
             components that must be monitored, the increased monitoring frequency,
             and lower leak definition.  All major chemical plants and petrochemical
             facilities will be affected, not just those located in non-attainment areas.

       •      Business Opportunities.   The  dynamics of the situation present some
             interesting business decisions, as well as compliance questions.  When all
             of  the rules for equipment leaks take effect, there will be a rapid rise in
             monitoring, system installation, and the number of system components to
             monitor.  The estimated cost to comply, $400-$800 million, is substantially
             higher than what EPA estimated because it takes into account both chemical
             manufacturing and petroleum refining, and more realistically  reflects the
             increase in monitoring.   Currently, the bulk  of this work  is performed
             within the plant by plant personnel.  The rest is handled by  about 5-10
             competitors, including ICF Kaiser.
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Clean Air Marketplace 1993                                             Page 59
       There are six elements needed for compliance, and these are included in  ICF
Kaiser's approach to addressing the challenges facing industry brought on by the fugitive
emissions rules.

       •     Sources. Accurately identify all of the leaking components, starting
             with pipe and instrument drawings for the plant.

       •     Data.   Automation is  necessary to manage the huge volume of data
             involved.  Most states  require quarterly monitoring, and  some require
             monthly monitoring.

       •     Training.  Being able to reliably identify and repair leaking components
             quickly and safely requires specialized training for personnel.

       •     Credibility. One of the  problems with leak detection and repair programs
             is that they have not been credible in the past — it is difficult to find out
             what someone did, when they did  it, and what they have found.

       •     Self-audits.  To ensure compliance, it is important to conduct internal
             review of monitoring activities. New software can help do this effectively.

       •     Continuous improvement.  Change is continuous in  the  chemical  and
             petroleum refining business; as fugitive emissions monitoring systems must
             interface smoothly with that change.

       ICF Kaiser has developed  a plan to manage all of these elements for facilities.  ICF
Kaiser has concentrated on making the system as rugged and cost effective as possible, so
that it will last.  The system is called  the Fugitive Emissions  Management System
(FUGEMS) and it consists of:

       •     Training for field operators, in the  form of a users guide, with a big focus
             on safety, productivity and quality.

       •     Improved hardware for measuring  and checking for leaks.  ICF Kaiser uses
             a punch-hole card  system. The system has a tag reader, a data logger and
             a signal conditioner that interfaces with the sniffer.  The system works in
             the following way:

             *•       The field operator has a list of all  the components that must be
                     monitored that day and their locations.

             >•       At the specified  location, the tag is inserted into  the tag reader and
                     the  system asks if the reading is  on the list  of measurements
                          Session 3B — Stationary Source VOCs/Air Toxics Control

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Page 60                                             Clean Air Marketplace 1993
                     required that day. The operator proceeds if it is and may move on
                     if not.

             >       A leak check is conducted, using the time clock in the data logger
                     that makes sure the operator follows the regulatory method.  If the
                     equipment fails a leak check, the system prompts the operator to
                     repair the problem.  If the operator chooses not to repair it at that
                     time, the system sends a message to maintenance the following day.
                     Operators can conduct hundreds of these checks in a day  to meet
                     the  requirements.  Daily productivity is governed by the  leak
                     detection method and the time to find the components.

       •      Improved  software  that standardizes the  operating procedure,  and
             schedules and prioritizes  the work. It also develops a synthetic regulation
             that integrates all of the applicable rules for that facility in order to better
             identify what the facility  needs to do in order to comply.

       •      A guarantee that the system will help a facility reach compliance.  ICF
             Kaiser pledges to pay any fines incurred if a violation occurs.

       According to Mr. Burton, the system has been a success.  It has been installed at
six facilities and has had no violations. The system has resulted in a 90 percent reduction
in emissions, and a 50 percent reduction in the  inplant labor required  for the tasks.  The
time of supervisory and clerical personnel required for compliance tasks has been reduced
by 50 percent.

       There is an issue concerning the slowness in the uptake of these new systems. ICF
Kaiser expected to install more than six systems.  Clearly, economic uncertainty in these
times is driving industry to be cautious.  According to the Wall Street journal, refinery
margins  and chemical margins are  really down;  firms are not making money from
operations, but rather through restructuring and downsizing.

       Regulatory complexity and gridlock between Federal, state, and local agencies is
in part responsible  for the slow growth in demand  for the fugitive emissions  control
system. Rule development and promulgation is slow, and the variation in EPA's monetary
commitment to enforcement also contributes to enforcement delays. There are some good
cost incentives within the regulations, however, specifically in the HON rule; if you have
a good program, costs will dramatically decrease. A key factor driving cost incentives to
work and fugitive emissions to drop is enforcement — reasonable, reliable, and sufficiently
frequent.
Session 3B — Stationary Source VOCs/Air Toxics Control

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Clean Air Marketplace 1993                                             Page 61
           Dr.   Orman A. Simpson, Director of Remote Sensing Technology, MDA
           Scientific Inc., produces optical remote sensing equipment.  His presentation
           examined  optical  remote  sensing  technology, how  it  contributes  to
           manufacturing in the U.S., and the advantages and disadvantages of applying
           this technology to stationary source monitoring.

       When the HON and the NESHAPS rules are implemented, everyone needs to
understand the costs and the total impact.  Every average or medium-sized plant has
thousands of valves, pump seals, and flanges that they must monitor on a monthly basis
under  the  national standards  for  equipment leaks.  The average cost is $1.50 per
measurement, so facilities are spending hundreds of thousands of dollars every month to
be in compliance. Thus, chemical plant managers and environmental engineers are always
looking for innovations.  One such innovation is optical sensing technology.

       An optical sensor generally includes some sort of an optical source, an instrument
that projects a beam of light out — ultra violet or infrared. This beam hits an optical
target  that returns it to the  transmitter.   This provides an analytical technique for
measuring  and identifying compounds in gas clouds emitted by  sources.

       One example of this technology is Open Path  FTIR (Fourier Transform Infrared),
built by MDA  Scientific, Inc.   It  can take continuous measurements for multiple
compounds at a site where measurements are required. This technology was introduced
in 1988, under the Superfund Region 2 field screening program. It has matured since then,
with funding support from several EPA programs. Emission rates for upwind remediation
activity can be  obtained by  the  system.   The system is  also effective  in  fenceline
monitoring. For example, Dupont is now using this  technology to monitor 24 different
compounds every 2 minutes across 1060 meters of their fenceline.  SAFER, a subsidiary of
Dupont, is  inputing the data into emergency response models to get emissions rates.

       Optical  sensors  are  systems technologies — they are  not  core  component
technologies. They are made up of many advanced component technologies.  As such,
when you obtain an advanced optical system, you impact many component manufacturers
in this  county. When you introduce innovation of this kind in industry, rather than being
a burden on industry, you are actually loosening the ties of the  industry, and favorably
impacting other manufacturers. To illustrate this point three technologies that are making
headway in this market are described below.

       •     Ultra  Violet  DOAS (Differential  Optical  Absorption Spectrometer)  —
             Manufactured by Optsis of Sweden, this system combines an infrared open
             path FTIR system and monitors most of the air toxics with an ultraviolet
             system that detects SO2, NO2, ozone, and benzene  better than the infrared.
             It uses an ultraviolet lamp source, specifically mercury arc lamps.  Arotech
             and Datal produces  precision  motorized  scanners that are computer
             controlled. Other manufacturers produce detectors, photomultiplier tubes,
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Page 62                                              Clean Air Marketplace 1993


             transmitter and/or receiver optical systems  (i.e. mirrors and windowed
             materials), and products that have to be coated for the ultraviolet.

       •      LIDAR (Light  Detection and Ranging) — This  laser-based  system uses
             various types of pulse lasers (carbon dioxide lasers, optically pumped lasers,
             etc.), each from a different manufacturer.  Other technologies used in this
             system include: motorized precision scanners, optical transmitting receiver
             systems that have optic and window materials dependant on the spectral
             region  in which  the system  operates, and  advanced  signal processing
             electronics.  These contain various LIDAR technologies that can  look at
             gases for gas concentration and actually create television images from gas
             specific clouds or particulate.  The diode laser based in-situ stack monitor,
             developed by SAAB Industrial Systems of Sweden, will be introduced into
             the US market this year to monitor SO2 and NO2-

       •      FTIR (Fourier  Transform Infrared) — This system uses the Michealson
             Interferedometor  that can be  found in an analytical chemistry unit, or a
             process analysis type of instrument; this system  simply opens a box and
             transmits a beam  into space.  This technology has produced a $110 million
             market, and  requires parts from  other manufacturers, such as motorized
             precision scanners, cool market liquid  detectors, transmitter and receiver
             optics, beam return optics, and infrared sources.

       Performance specifications (listed in the appendices of 40 CFR Parts 50, 51, 53, 60,
and 61) can be adapted to remote monitors, codified reference methods, test methods, and
measurement principles. However, the calibration test procedures require major revisions.

       Although the initial capital costs are higher for remote instruments than for point
samplers, the operational costs are less because  of mobility. The current estimate is that
for some remote monitoring applications the operational costs are decreased by a factor
of ten. One disadvantage to  using monitors is  that there has not been an adaptation of
existing  performance  specifications  of  continuous  monitors to  remote monitoring
application,  or  an initiation  to  formulate additional test  procedures required in the
application of remote monitors.

       Remote monitoring can play a major role  in EPA's enforcement and R&D activities.
There are innovative technologies that produce  better results and are more cost effective
if regulations can be structured  to incorporate innovation.
Session 3B — Stationary Source VOCs/Air Toxics Control

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Clean Air Marketplace 1993                                              Page 63
           David A. Doles, Sales Engineer of Stationary Source Catalysts with Engelhard
           Corporation, which supplies pollution control equipment, focused primarily on
           catalytic and  thermal oxidation systems.  His presentation highlighted the
           issues and complications affecting industry due to the Clean Air Act Title I and
           Title III. He discussed aftertreatment technologies available today, as well as
           past successes and future challenges with these technologies.

       Mr. Doles began his presentation by sketching out some differences between Title
I and Title ID of the Clean Air Act Amendments. Title I, according to Mr.  Doles, focuses
on state  regulation.  It allows  states, with Federal approval to draw up and enforce
regulations. Title  III, on the other hand, is essentially Federal regulation.  In  terms of
pollutants addressed, Title I covers all VOCs and does not distinguish between hazardous
and  non-hazardous emissions.  Title III covers only hazardous VOCs.  Since there is
overlap, some facilities may be regulated by both. Control requirements in Title  I depend
on whether the area of the facility is in attainment.  Such area distinctions do not apply
in Title III; all sources have the same control requirements. Timing is also a big difference
between  these two titles.  Facilities may have to meet standards under both acts which
come into play  over different time periods. This complicates firms' decisions about what
technologies to use.

       Various control options that are available today are:

       •      Process modifications — This includes raw material changes, processing
             conditions, etc.  The end user is often able  to both reduce emissions, and
             realize other economic benefits such as producing a better product or
             reducing its cost of production.  These opportunities, however, are not as
             common as we would like; such changes are expensive and oftentimes not
             technologically feasible.

       •      Recovery/Recycling — If VOC streams are concentrated enough, and if they
             cannot be avoided through process modifications, it is often economically
             attractive  to  recapture the  VOCs  through  a  number  of  different
             technologies.  The VOCs can then be reused in the process or sold  on a
             secondary  market.

       •      Aftertreatment technologies — If it is not feasible to prevent or recover the
             pollution,  there are a number of  aftertreatment technologies  that are
             applicable  and currently being used.

             *     Catalytic oxidation — A  catalyst,  typically  a precious metal
                    catalyst, is used to oxidize VOCs. This can be carried out at much
                    reduced temperatures, and the resonance time can be much shorter.
                    There  is heat recovery with this system as well.
                          Session 3B — Stationary Source VOCs/Air Toxics Control

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Page 64                                             Clean Air Marketplace 1993


             >      Thermal oxidation — This process takes the VOC stream and heats
                    it to an elevated temperature, 1500°F-2000°F.   The  two main
                    technologies involved are regenerative and recuperative. For both
                    of these technologies, the goal is to recover the heat that you put
                    into the system in order to  oxidize the VOCs.

                    °      Recuperative  systems  take  the exhaust  stream  from  the
                           combustion process and use it to preheat  the incoming
                           stream, with  heat recoveries commonly at about 60 percent.

                    0      Regenerative  systems consists of  multiple regenerative
                           chambers and an oxidation chamber. The contaminated air
                           enters one chamber  of the RTO and the air passes upward
                           through the heat sink material, which serves as a preheat for
                           the gas because  this chamber is hot from  being the  exit
                           chamber in the previous cycle.  The gas then  enters the
                           oxidation  chamber, which  is   operating  at  elevated
                           temperature,  to  complete  the  oxidation   of  the VOC
                           compounds.

       •     Incineration — Depending  on the nature of the VOC stream, it  is possible
             to use incineration as a fuel for existing combustion sources and thereby
             produce some economic benefits. However, this system is not specifically
             engineered for high VOC destruction, so for areas with very strict emission
             standards, incineration may not be  appropriate.

       •     Adsorption — This is a recovery system in which VOCs are adsorbed into
             a carbon bed or perhaps  zeolite.  There are two drawbacks:   the  bed
             eventually has to be discarded, disposed of or destroyed.

       •     High Tech  Technologies — These include  cryogens, UV,
             ozonation,  and biofiltration.  By and large,  these are  new
             technologies that  have  not been widely  commercially
             applied.

Mr. Doles focused  specifically on two of the above technologies, catalytic  oxidation and
regenerative thermal oxidation to illustrate past successes in innovation.

       •     Catalytic oxidation — There have been a number of advances in the use of
             catalysts  for oxidation. This is one of the primary advantages of a catalytic
             system —  it  can  be operated at low temperatures  and  achieve high
             efficiency.  This advantage has been enhanced  over the years with new
             catalyst and system designs.  The major drawback to catalytic  systems  is
             that  because they use precious metal catalysts, they can be  susceptible to
Session 3B — Stationary Source VOCs/'Air Toxics Control

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Clean Air Marketplace 1993                                             Page 65
             poisons. Many catalyst compositions can be poisoned by things like sulfur,
             heavy metals, chlorinated compounds, etc. To address this, poison resistant
             catalysts have been developed. Mechanical design and equipment can often
             be the overall factor that determines the destruction efficiency of the  system.
             With special attention to ensuring the equipment is air tight, destruction
             efficiencies of 99% can be guaranteed. This technology also reduces capital
             and operating  costs.  As the market has grown and more players have
             entered, there have been innovations to reduce the up  front and ongoing
             costs to operate these systems. This has made the systems readily available
             and more practical in many applications.

       •     Regenerative thermal oxidation — Technologies in other industries use the
             concept  of a reciprocating flow stream with the ceramic bed, but only
             recently has it been applied to VOC oxidation. Thermal efficiency through
             this method has reached  95 percent.   Regenerative  thermal oxidation
             systems are particularly attractive for larger flow rate streams, because they
             recover a significant portion of the heat  from the gas. One of the problems
             had been that as the stream  cycles back and forth, there  was a residual
             unoxidized component emitted.  New developments in valve design and
             purge systems, however, eliminate this  problem.

       The future for  technological innovation may see the following:

       •     The efficiency and cost of existing technologies will continue to improve.

       •     New technologies will continue  to come  on the market.  Here are a few
             examples:

             >       Catalytic filtration — A  ceramic honeycomb filtration  device
                     applied to a catalytic media creates both a  catalytic oxidation
                     reaction and particle filtration in the same unit.  Two activities can
                     be carried out in one  system.

             >       Regenerative catalytic oxidation — Adding  a  catalyst  to the
                     regenerative thermal oxidation  system  can  reduce operating
                     temperature. Operating and total system costs  will decrease.

       •     The future for technological innovation is in a dilemma.  End users  require
             technologies  that are proven so that the after treatment unit does not
             adversely affect their process and the regulators must accept the technology
             as meeting their requirements. In writing regulations, regulators must base
             the  rules  on  results  that are  achievable with  commercially  proven
             technologies.  The missing element in this  scenario is a mechanism for
             proving and accepting new technology, which may have the benefit of
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             better destruction efficiencies and more cost effective operations.  If there
             is a perception that it will take too long for equipment to be accepted, or it
             looks like it might not be accepted, equipment suppliers' already limited
             R&D funds will dry up very quickly.

             New regulations have  created a large dynamic market for  aftertreatment
             technology, resulting in jobs and export opportunities.

       To continue this market innovation and growth, the regulators need to promote the
development and acceptance of new technology.
           Paul D. White, Business Director of the Environmental Projects Division at
           Johnson Matthey Corporation, supplies stationary  source  environmental
           controls.  His presentation described state of the art catalytic oxidation and
           some developments in meeting the requirements of the Clean Air Act.

           The main  motivation  to control VOCs are the  requirements  in  Title I.
Facilities not meeting attainment VOC and NOX  standards create smog and contribute to
the ozone non-attainment areas. The upcoming rules and regulations are impacted by Title
III, which regulates carcinogens and mutagens.  Many are  standard VOCs, but  some
present some interesting challenges, particularly the halogenated materials.  In addition,
nuisance conditions of odor and smoke will be addressed.

       There are a variety of VOC control technologies:

       •     Carbon absorption

       •     Solvent recovery

       •     Incineration
             *•     Recuperative
             ••     Regenerative
             >     Catalytic

        Catalytic  oxidation is currently  the  preferred  technology — it is  merely  an
enhanced thermal oxidation process.  The catalyst allows the reaction to take place at a
lower temperature, the main advantage of catalytic over thermal oxidation. Much less fuel
is needed to heat the incinerator and  a catalyst allows the reaction to take place in  a in a
much shorter period of time.  The resonance time is important because it allows the device


Session 3B — Stationary Source VOCs/Air Toxics Control

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Clean Air Marketplace 1993	Page 67


to be  smaller.   Unsaturated materials  are  more difficult  to  destroy  than  saturated.
Benzene, acetone, and  methanol are relatively easy VOCs to destroy at relatively low
temperatures.  Methane and short-chained saturated compounds tend to be more difficult
to oxidize.  Most of the VOCs and air toxics fall into the range of 450°F-850°F.

       Typical catalytic applications include:

       •     Can coating

       •     Painting of any kind

       •     Converting (printing on anything other than paper)

       Title ID presents some interesting challenges. In the past, catalysts were thought
to be  inefficient in streams that contained halogens.   Much research  has  gone into
developing catalysts that can effectively destroy halogenated hydrocarbons.  This is an
example of the kind of innovation that needs to be done to meet Title ID.

       There is no advantage to destroying one compound and creating one that is even
more hazardous; if there is no moisture in  the stream, phosgene is  created  as  the
compound is destroyed. The destruction of halogenated VOCs then becomes more than
simply designing a catalyst — it focuses on system design to make sure that the water
levels are proper.  Along with the necessity of injecting water is the heat requirement. Not
only must the heat be sufficient to destroy the compound, it must also be  sufficient to not
create  another compound.

       One solution to  this problem is to use PGM catalysts that are less volatile than base
metal catalysts, and operate at higher temperatures.  Basically, because  they  operate at
higher temperatures, unwanted byproducts do  not form.  However, laboratory trials still
should be backed up by field trials.

       PGM catalysts are effective for the complete destruction of halogenated VOCs.  To
deal with regulations, one cannot simply develop a catalyst.   A complete system  should
be developed to account for all the different parameters involved.


Questions and Answers
         How can regulators convince industry that there is technology that may even be
         more economically feasible than the techniques we use now?

         Mr. White responded that the producers, users, and government officials must
be understanding so that we know the limits of all the different VOC  technology and
where it can be applied.- There are a host of different VOC technologies available.  People
                          Session 3B — Stationary Source VOCs/'Air Toxics Control

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Page 68                                    	Clean Air Marketplace 1993
must take  the time to evaluate the different technologies.  Government officials must
understand the  limits of what the different technologies can  and cannot  do.   Most
importantly, vendors have to make sure that people do not misapply the technologies.

A member of the audience added that one of the things catalyst manufacturers should
consider is the liability question. Warranties and guarantees are quite limited. As part of
the innovative process, manufacturers should stand behind the product and offer  longer
warranties.
         To what extent is pollution prevention control technology being developed?

         Mr. Dole  responded that  Englehard only has abatement  and  aftertreatment
         technology as of now. The pollution prevention technologies available today are
 very industry- and pollution-specific. Some new pollution prevention technologies could
 include a coating type application, and a progression from solvent to water-based systems.
 Perhaps there are no capitol costs for this modification, just a change in the product. There
 is improved equipment available that can prevent leakage.
         Winch industries arc being proactive in terms of market size and growth?
  O
   •   I Mr. White replied that, regarding market size and growth of this technology,
 ^™^^" VOC control is about a $200 million market.  The major industry that is now
 undergoing VOC  control is  the chemical process industry, particularly the synthetic
 chemical manufacturers. Many of these industries have had nuisance problems long before
 now. For example, the printing and converting industry is a known user of solvents, and
 they really do not  have any substitutes — they are stuck with post-treatment.

 Mr.  Jordan added that we are  actually developing  MACT  standards for 174 major
 industries under Title III.  Practically all will be affected by VOC regulation. They cover
 everything from wood furniture manufacturing to coating operations.
Session 3B — Stationary Source VOCs/Air Toxics Control

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Clean Air Marketplace 1993                                             Page 69
        Each panel member was asked to make a one sentence suggestion to regulators.

        Mr.  Burton.commented that business and government must trust each other.
        There is a lot of room for improvement.

Mr. Simpson added that flexibility should be built into the regulations.

Mr. Doles suggested that  regulators incorporate flexibility into  their regulations and
enforcement.  Many innovations have a lot of promise, but there is risk involved. EPA can
go a long way to help alleviate the risk that the end user perceives.

Mr. White recommended that Federal agencies give the states guidance.  They need to
decide where the  most VOCs are  coming from and what is the most  appropriate
technology.
                         Session 3B — Stationary Source VOCs/Air Toxics Control

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Page 70                                         Clean Air Marketplace 1993
Session 3B — Stationary Source VOCs/Air Toxics Control

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Clean Air Marketplace 1993
Page 71
                          Session 3 — Panel C
                          Vehicular Emissions Control Technologies
                          Septembers, 1993
                           2:00 p.m. - 4:00 p.m.

                          Moderator:    Bruce Bertelson
                          Panelists:     John S.  Howitt
                                       John Mooney
                                       Reginald Modlin
                                       Dr. George M. Sverdrup
Introduction

       Bruce Bertelsen, Executive Director of the Manufacturers of Emission Controls
Association, was the moderator for this session. He began his remarks by stating that the
motor vehicle emission control program began approximately 25 years ago with the Clean
Air Act Amendments of 1970.  The program is an example of an environmental success
story for this country and the world. During the 1960s the air quality in a number of cities
in the U.S. was as bad as Mexico City's air quality is today.  The motor vehicle emission
control program has helped turn this around and has spurred the development of a multi-
billion dollar industry.

       Although the program has experienced success in the past, there are still air quality
challenges to be addressed today. Specifically, there are two goals: (1) to look back at the
program's successes  and failures and  learn from them, and (2) to look forward to the
future of the program. The discussion will focus on new emission control technology, the
impacts of that technology, changes in the program, and the impacts of fuel selection.
Presentations
           John S. Howitt,  Manager  of  New Technical  Ventures at Allied  Signal
           Corporation, has 23 years experience in auto emissions control, and his current
           responsibilities include developing new business opportunities in the catalyst
           area. His remarks focused on advancements in catalyst technology.
           In the next few years, the market for catalytic converters will see some growth.
In North America the need for catalytic converters will increase modestly, while Japan's
market will remain constant. However, there will be tremendous growth in Western
Europe, and potential for growth in Eastern Europe, South America, and Asia.
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       The driving  force behind technological  advancements has  been  California's
forthcoming regulation on LEV standards, to be employed in various phases in the 90's.
Preliminary figures from these regulations show that the hydrocarbon limit will fall from
today's .41 to a midlevel of .125 and finally to an even lower level.  The planned ULEV
standard will be .04.

       The focus of catalyst technology is the control of hydrocarbons.  The following list
summarizes some of the most remarkable advances in catalyst technology today:

       •      electrically heated catalysts;

       •      palladium catalysts;

       •      lean NOX catalysts;

       •      hydrocarbon traps;

       •      substrates;

       •      compressed natural gas catalysts;

       •      utility engines, mainly for lawn and garden controls;

       •      diesel  catalysts; and

       •      motorcycle catalysts.

Electrically Heated Catalysts

       A  catalyst usually  does not become active until it has reached several hundred
degrees,  and it is therefore  fully effective only on a hot car.  Eighty percent of an
automobile's  total  emissions  occurs within the first 2 minutes  of the  start.  Electrically
heated catalysts decrease the heating time, and thereby reduce the amount of hydrocarbons
that escape during the cold start  period.   They are heated by electric  energy conducted
through metal substrates.

       A manifold mounted converter, using a more conventional type of catalyst, can also
help to reduce the  cold start problem. It absorbs the sensible heat in the exhaust quickly
and because  the catalytic action  is  exothermic (heat-generating), it  provides  a hotter
exhaust faster to the main underbody converter.
Session 3C — Vehicular Emissions Control Technologies

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Clean Air Marketplace 1993	Page 73


Palladium Catalysts

       Catalysts have traditionally been made of platinum, platinum rhodium, or platinum
palladium rhodium.  Last year a catalyst made solely of palladium was developed that
decreased the time it takes for the converter to reach efficiency. These catalysts have been
effective in meeting the LEV and ULEV standards in tests.

Compressed Natural Gas Catalyst

       A compressed natural gas catalyst was tested by EPA on a Dodge Dakota pickup
truck and several other car models and it was found to have an acceptable conversion
efficiency. The catalyst allowed the vehicles to comply with the ULEV standards and was
considered successful.

Hydrocarbon Traps

       Substrate manufacturers have  recently  found a way to impregnate  the ceramic
substrate with activated carbon to absorb 77 percent of the non-methane hydrocarbons
emitted in the first 60 seconds.

Utility Engines

       In the state of California, beginning January 1,1995, utility engines (e.g., lawn and
garden equipment) are going to be subject to  emission control standards.  It has been
found that 4 percent of the total hydrocarbons emitted in California comes  from utility
engines. The standards will continue  to tighten significantly through 1999.

       Engine manufacturers have developed several different strategies to conform with
upcoming emission regulations. Some of those strategies include:

       •      tuning engines and  carburetors to make engines run more smoothly (1995);

       •      converting to overhead  valve engines, which run much cleaner;

       •      catalytic aftertreatment, particularly if the first two  options fail;

       •      converting to overhead  valve + catalyst engines (1999); and

       •      converting to 4-stroke + catalyst engines (utility engines).

       This  industry faced the following problems in catalyst design for utility engines:

       •      Effectiveness and efficiency (i.e., being able to design a catalyst to meet the
              standards)


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       •       Durability

       •       Temperature of exhaust  and shell of structure  where  the catalyst is
              mounted (in many cases, the muffler)

       •       Safety (e.g., mechanical malfunction, fire)

       •       Mechanical durability

              Cost

Motorcycle Catalysts

       Catalysts  on motorcycles and  motorbikes are very effective in  reducing  the
emissions of hydrocarbons, CO, and  NOX.  In virtually every  case, the use of these
catalysts is the result of regulatory action.  For example, catalysts are being installed on
motorbikes and motorcycles in Taiwan  at the rate of 1 million units a year, and the
potential market in that area could expand in the next 5 or 6 years to nearly 6 million units
a  year.   (In  some areas  of Southeast  Asia, the  motorcycle  is  the  major form of
transportation.)  Taiwan already has three-phase standards in place and catalysts are
already in production. In Japan they begin in 1996.  There are standards in South Korea
but few motor vehicles to which they are applicable.  In India, Singapore, and Malaysia,
standards are currently being considered.
           John Mooney, Manager of Technology and New Applications at Engelhard
           Corporation, focused his discussion mainly on diesel catalytic aftertreatment
           devices.  Diesel exhaust is perceived by  the public as dirty because of (1)
           particulates visible to the human eye; (2) a  characteristic odor; and (3) gaseous
           emissions that contribute to smog.  Diesel exhaust consists of solid organics,
           carbon, aerosol organics derived from the  fuel or lube oil, HC, CO, SO2 gases,
and free organic liquids.

       Preregulation emissions controls have usually  focused on particulate  matter, and
not as much on hydrocarbons or carbon monoxide.  In 1998 there will be a fairly strict
standard for NOX. The three catalytic devices that are being applied for the future are (1)
diesel oxidation catalysts (DOC); (2) catalytic soot filters (CSF); and (3) lean NOX catalysts.
 Session 3C — Vehicular Emissions Control Technologies

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Clean Air Marketplace 1993                                             Page 75
Diesel Oxidation Catalysts

       The first DOC was developed in 1968 and there has been quite an improvement in
their formulation in the last couple of years. The DOC  is similar to those catalysts used
on spark ignited engines.  However, the liquids collect on the surface of the catalyst, are
oxidized to gaseous components, and  then are consumed by the catalyst. The following
characteristics all pertain to DOCs:

       •      DOCs collect and oxidize aerosol HC. This is sometimes termed the soluble
              organic fraction (SOF). The sources are from fuel and lube oil  consumed or
              not burned by the engine;

       •      In DOCs gaseous emissions are oxidized just as they are in  an oxidation
              catalyst;

       •      DOCs reduce odor and irritants;

       •      DOCs have low deterioration — some DOCs last for ten years with little
              deterioration;

       •      DOCs are a lower cost technology compared to other types of aftertreatment
              devices;

       •      DOCs are the most effective technology  in terms of reducing particulate
              matter; and

       •      DOCs need low sulfur fuel.

       Ninety-eight percent of fuel sulfur combusts in the combustion chamber into SO2,
and about 2 percent combusts into SO3. The engine companies dropped the specifications
for sulfur from 0.3 to 0.05 percent.  A catalyst is very effective in oxidizing SO2 to SO3.
SO3, once formed, hydrolizes with water to form sulfuric acid, which is collected in the
filter used to collect particulates. The catalyst companies have been successful in striving
to produce a catalyst  that  would be  selective, that  is, oxidize  the soluble  organic
hydrocarbons  but not oxidize SO2 to SO3 and form particulate.

Catalytic Soot Filter

       A CSF  is made from an extruded monolith that collects particulates.  This type of
trap has a collection efficiency of 60-90 percent with only a 2-4 percent  fuel  penalty.  The
regeneration system is either onboard using a fuel burner or electric heater or the whole
unit can be taken off and regenerated with a heater.  The surface  that collects soot is
coated with a  catalyst. There are several additional features of a CSF:
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Page 76                          	 	Clean Air Marketplace 1993


             CSFs can be used for 4-stroke engines without a regeneration system;

             CSFs oxidize the HC and CO and remove odors and irritants;

       •     CSFs decrease the regeneration emissions;

             CSFs increase the collection period, i.e., the time it takes to fill the trap;

       •     CSFs provide complete regeneration to the baseline condition;

             CSFs decrease the temperature at which the collected soot is combusted by
             50-200°C; and

             CSFs provide low deterioration  (up to 75,000 miles).

        A significant stride toward cleaning up the diesel engine would be the use of low
 sulfur fuel.

 Lean NOX Catalysts

        Lean NOX catalysts reduce NOX in oxidizing atmospheres with zeolites (molecular
 cages that pick up and reduce HC and NOX emissions).

        Southwest Research has a program funded by CARB to  study lean NOX catalysts
 and further their development.  Many catalyst companies have lean NOX development
 programs and the progress is continuous.  Further developments are expected in 1994.
           Reginald  Modlin, Manager of Vehicle  Emissions  Regulatory  Programs at
           Chrysler Corporation, gave his talk from the perspective of the automobile
           manufacturer.  He felt that  the  theme of the conference (New Business
           Opportunities Created by the  Clean  Air  Act  Amendments) can be  a  bit
           misleading, because the Clean Air Act is about clean air. The  link between
           clean air and a healthy economy is not  direct.  The maintenance of  a  clean
 environment may complement a healthy economy, but one does not necessarily follow the
 other.  Cleanup of the environment will  be costly.  New technology and new jobs will
 result, but the costs should not and cannot be hidden. The discussion  focused on attitudes
 and goals for the future and the importance of government and  industry cooperation.
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Clean Air Marketplace 1993                                              Page 77
       The state of California provides the largest clean air challenge of any state.  The Air
Resources  Board is still  struggling to  show compliance with National  Air  Quality
Standards.  Non-attainment areas  like  California are required to  conduct advanced
inspection  programs.  The State's check system has come under review recently, and
information gathered shows that the system is riddled with the potential for error and the
inappropriate passing of otherwise failing vehicles. Non-attainment areas like California
are required by the CAA to implement enhanced IM programs.  (EPA is currently finishing
guidelines for these programs.)

       The problem in California is the perception that all the jobs previously associated
with testing will be lost because of the new IM programs.  There is less of a  focus on air
quality and more of a focus on jobs.  In addition, there has been little discussion of the jobs
created by the  need to fix the increased  volume of failing cars.  When people point to
perceived  potential for  loss  of jobs  without acknowledging the  potential business
opportunities, the discussion no longer focuses on clean air. If we do  not keep our focus
on improving air quality, we run the risk of adopting policies that may be more politically
acceptable, but result in little sustainable environmental benefit. Solutions to  the complex
environmental  problems  that  we all face  require complex solutions, and automobile
manufacturers, regulators, and government officials should resolve the problems by using
cost effective measures and properly educating the public as to what they are paying for.

       From the technology side, an integrated  strategy  could be built.  For instance,
regulatory policy could both tighten vehicle emission control and consider ways to reduce
customer inconvenience. The tools used in this example are an IM test  station, vehicle on-
board  diagnostic systems, traffic monitoring control systems, roadside vehicle emissions
monitoring, and scrappage.  Finding and fixing the most polluting cars and trucks is the
single  most cost effective  control  strategy  for emissions control  of motor vehicles.
Increasing the  frequency of inspection  can  be achieved simultaneously to reducing the
inconvenience of inspections to the consumer, with an on-board diagnostic system. With
the addition of a transponder, the data stored in the system's computer could be broadcast
to a roadside monitor.  Knowing the real-time emissions performance of the vehicle, a
central processor could notify the owner of the need to  have his vehicle checked and
possibly repaired if it is out of compliance.

       The central processor could  also routinely search the files for vehicles that have
somehow missed the roadside monitor and generate notice to the  owner that a periodic
inspection is needed. Testing would not be required at the IM  station for those who have
encountered a  station  and have reported passing conditions, thus reducing customer
inconvenience.

       Direct linkage with vehicle registration and licensing systems would assure that the
owners would acknowledge notifications for service.  Direct integration of a gross polluter
scrappage  program  into this einissions monitoring system based  on actual measured
emissions of the vehicles pulled from the road could help in establishing emissions trading
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Page 78                                             Clean Air Marketplace 1993
banks to help small businesses adjust emissions abatement requirements to their ability to
purchase hardware. This time phasing of emission abatement equipment could extend to
major industrial facilities as well.

       The vehicle's transponder could also aid in reducing traffic congestion, the data
reflecting exactly where the vehicle is located. Another option for the consumer would be
an onboard location display that would provide traffic information accumulation by  the
traffic control system. Development of these systems would take a coordinated effort from
several disciplines to minimize the complexities of each. People need to put aside their
own personal biases and work together to provide a coordinated solution.

       Lastly, the effect of fuels on vehicle emissions should be discussed. An increase in
the cost of gasoline is not palatable to government officials. Whether or not regulating fuel
formulation is a  rational policy option depends on the  extent to which fuels impact on
tailpipe emissions. According to soon to be released data obtained from tests aimed at
determining the emissions difference imposed  by fuels alone, the imposed difference can
range from 14-48 percent. Properly addressed, fuel formulation is a cost effective motor
vehicle emission control strategy.
           Dr. George M. Sverdrup, Program Manager at Battelle Memorial Institute, is
           involved in two programs: (1) a comprehensive assessment of toxic emissions
           from coal  fired power plants, including two with clean coal demonstration
           projects; and (2) the CleanPleet program, a demonstration of five  alternative
           fuels and a control gasoline in 111 Federal Express delivery vans in Southern
           California.  Dr. Sverdrup limited his remarks to the CleanFleet program.

       The goal of CleanFleet  is to  demonstrate and document the operations (vehicle
performance, maintenance, reliability, durability, safety), emissions, and economic status
of five alternative fuels. All the liquid and gaseous fueled vans used  were model year
1992 vans built  by Ford, Chrysler, and Chevrolet.

       The following chart gives some details on the fuel type being tested, the location
of each fleet, the number of vans being used, and the number of control vans in operation.
Control vans operate on regular, unleaded gasoline to provide a base for comparison.
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Clean Air Marketplace 1993
Page 79
TYPE OF FUEL
Propane
Reformulated gasoline
Electricity (lead acid batteries)
Methanol
Compressed natural gas
LOCATION
Rialto
South Central Los Angeles
Culver City
Santa Ana
Irvine
NUMBER OF
VANS
20
21
2
20
21
NUMBER OF
CONTROLS
6
9
—
3
9
The vans were phased into operation beginning in April 1992 through September 1992 and
will complete the 24-month test in the fall of 1994.  Federal Express has used all five fuels
successfully in its daily operations.

       Some highlights of the five sites, illustrating problems encountered and solutions
developed are as follows:

Rialto (propane)

       A number  of  issues were addressed to provide a successful demonstration of
propane gas. Initially, the Federal Express drivers were concerned about the accuracy of
the fuel gauges and how the fuel gauges read during driving. Problems were encountered
with the diaphragms in the regulators, which were replaced with a new material.  There
have also been problems in the last several months with the electronics added to the vans
from one manufacturer to convert from gasoline to propane. The propane fuel tanks are
sensitive to grade — if there is a grade, the fuel tank may not completely fill and the van
may subsequently run out of gas. Changes also had to be made to the fuel nozzle to allow
it to fit into the vehicle fuel tank and adjustments were also made to guard against hand
fatigue  while  fueling vehicles.  Since  Federal  Express usually drives its vans into  a
warehouse to pack them, duct work and air handling equipment were added to the facility
to increase ventilation. Flammable gas detectors were also installed near the floor.

South Central Los Angeles (Phase 2 reformulated gasoline)

       Underground  tanks provide storage  for  the California Phase 2 reformulated
gasoline. There  is  a special fuel dispensing management system in use (TIR1S) to test an
automated system for  fleet operators reporting fuel use to the government, on a vehicle-by-
vehicle basis.

Santa Ana (methanol)

       An above-ground vaulted tank was installed to provide the fuel. Although the fuel
storage tank and M-85 dispensing system were specified to be compatible with M-85 and
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Page 80                                             Clean Air Marketplace 1993


were warranted as such, some components were not compatible with methanol. These
components had to be changed to provide long-term trouble-free operation.  Suppliers are
only now manufacturing hardware that is compatible with high methanol content motor
fuel.  Some problems were experienced with the fuel pickup line in the fuel tank. This
was remedied by the vehicle manufacturer. There were significant permitting procedures
to be met in the installation of this tank.  The fuel being used is  M-85 — 85 percent
methanol and 15 percent Phase 2 reformulated gasoline.

Culver City (electric vehicle)

       Two electric G-Vans are being demonstrated. Initially, they had lead-acid batteries.
Under Federal Express driving conditions, there were found to have a range of about 25
miles.  One G-Van is now being outfitted with nickel-cadmium batteries. A Ford Ecostar
will be added to  the project in 1994.

Irvine (compressed natural gas)

       21 vans are  operating on compressed natural gas (CNG) which is supplied onsite
by a natural gas  compressor, cascade tank storage system,  and a dispenser. As for  the
propane site, enhanced air handling  equipment was installed in the  building into which
the vehicles are bought.  A system of 24 flammable gas detectors near the ceiling control
operation  of  the new ventilation  system.   Range  of the  vehicles from  the  three
manufacturers varies from about 120 to 150 miles. An extra fuel tank was added to each
of the seven Dodge CNG vans to  increase the range to 120 miles.  During the past few
months, problems  have  been  encountered with the electronics used  to control fuel in
Chevrolet vans modified to run on CNG. The problems have largely been resolved as they
were  for those propane vans that use the same electronic system.
Questions and Answers

         What is the effect of diesel filters on diesel engines?
         John Mooney answered that there is a 2-A percent negative fuel economy because
         of the additional back pressure.  However, passive regeneration systems avoid
the problem.
      L

  ** \
   •  I
^^^™
What are some different problems concerning retrofit engines versus new engines?

John Howitt replied that the most important difference relating to retrofit engines
is temperature.
Session 3C — Vehicular Emissions Control Technologies

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Clean Air Marketplace 1993
                                  Page 81
                          Session 3 — Panel D
                          Alternative Vehicle Technologies
                          September 8,  1993
                           2:00 p.m. - 4:00 p.m.
                          Moderator:
                          Panelists:
Phil Barnett
Martin J. Bernard, III
Gorik Hossepian
Dr. Roberta Nichols
Paul Gifford
Introduction

       Phil Barnett, U.S.  House of Representatives, Subcommittee on Health and the
Environment, introduced the session by stating that high emission inventories are a prime
problem addressed by the Clean Air Act Amendments (CAAA). Under the CAAA, many
urban areas must reduce their emission inventories by 50-60 percent and in some areas,
such as the southern coast of California, by as much as 70-80 percent.

       Mobile  sources  are  the  primary  cause of  emissions  in  major  cities.    The
development  of  cleaner  fuel  technologies  is therefore  crucial  to the  successful
implementation of  the  CAAA's emission reduction  provisions.   At  the same time,
continued economic growth must be fostered.
Presentations
           Martin  J. Bernard III, Executive  Director of  the  National  Station  Car
           Association (NSCA) discussed his association's efforts to develop a nation-wide
           station car program to fill electric vehicle market niches in urban and suburban
           markets.
           There are three early market niches for electric vehicles: service vehicles,
shuttle buses, and, most importantly, station cars.   These are early niches because the
vehicles operating in each require relatively simple technology, have simple driving
patterns and return  daily to a central  location  for servicing.  Station cars are battery-
powered electric vehicles driven by transit passengers to and from a station. Station cars
will probably be small, but not 'mini', and fully safety-certified if the mass transit criteria
favored by the NSCA are adopted. Some vehicles which would operate only on local
streets might not be  safety certified, but the NSCA is not interested in supporting those
                                   Session 3D — Alternative Vehicle Technologies

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Page 82	Clean Air Marketplace 1993


types of vehicles. Station cars would be designed to have a 45-mile range and capable of
being used on freeways, but only in a limited capacity because the station cars are meant
to be primarily urban vehicles.

       Two advantages to using electric cars  rather than conventional cars on short,
commuter trips are:

       •       More than half of the emissions released during a 20-mile trip are released
              within the first five miles and are caused primarily by the "cold start" of
              the engine.  Because most trips  to a commuter station are less than five
              miles long, using station cars would greatly reduce emissions.

       •       Traffic congestion involving conventional cars has a high emission impact.
              By encouraging  public transportation ridership, some of this congestion
              could be avoided.

       The startup funding for NSCA came primarily  from the Electric Power Research
Institute  (EPRI). The Transit Development Corporation, a non-profit corporation set up
in the mid-1970s by the transit industry to perform research and development, is also
providing support to station car demonstrations.

Stage 1:  Local Demonstrations (1993-1998)

       The following presents a two-stage process for the introduction of station cars. The
first period, running from  1993-1998, will  involve local demonstrations of the vehicles.
Many of these local demonstrations will be supported by local utilities, transit authorities,
and other state and local agencies. The American Public Transit Association has set up an
electric station car task  force to motivate the transit industry to  encourage these efforts.
Each demonstration would involve a fleet of 25-30 cars and would be centered around one
or more commuter train or light rail  or rapid transit stations.  Initially, the vehicle would
be  assigned to one person, possibly  an employee of the utility  or transit agency, who
would be given priority parking at the station. The vehicle  would be  recharged at the
station or at the assigned individual's home at night.  The station car would therefore be
used primarily as a forward commuting vehicle.

       Nine  major cities, including Atlanta, Boston,  Los  Angeles, San Francisco, and
Washington, D.C., have committed to this  program.  These transit operators have made
a commitment to station car development.  The vehicles provide clean air access to mass
transit and could eliminate the need for second or third household cars since it could be
used for other local trips.  As  the  demonstrations go,  they will  presumably attract new
riders to the public  transportation  system  by making transit  a door-to-door service.
Demonstration funding for the first stage will come from  state and  local air quality
agencies, state departments of transportation, local electric utilities, and ARPA (which will
put $500 million into the development of electric vehicles, though not exclusively station
 Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993                                             Page 83
cars, in the next few years). NSCA also hopes to interest the Federal Transit Authority in
station car development.

       There are several demonstration programs already underway. In San Franscisco
in 1994, for example, 45 station cars will be located at five stations, and have been paid for
with local and ARPA funds. In Orange County, the station cars will be used by "reverse
commuters" to go to jobs in local  industry,  hi Miami, officials have  found that  the
program would encourage commuters to use the city's mass transit system, because it
allows the riders to conveniently run business and personal errands in the city during the
day.

Stage 2: Full-Scale Programs

       The second stage of the station car introduction will begin in 1998 and will involve
a number of concurrent programs, including maintenance and charge-ups for cars at the
station, on-board diagnostic systems, and monthly billing capabilities.  The uses of the
vehicles would also be expanded.  Dr. Bernard envisions the car as a multiple-use vehicle,
that could be used for all kinds of trips in suburban and downtown areas.  The cars, in the
second stage of the program, would therefore no longer be used exclusively for forward
commutes, but also for reverse commutes, shopping trips, and local business trips.

       During the second stage, the vehicles could be owned by a variety of  groups,
including transit authorities and local employers, but the  station cars will probably be
owned by third party leasing firms, or perhaps by parking garage operators. In California,
for example, the American Automobile Association has expressed interest in operating
station cars.

       At first, most of the station cars will be conversion cars but, starting in 1995, station
cars could be built as electric cars from the "ground up" and will be ultra-lightweight,
graphite, fiber-based vehicles.  While the NSCA would  prefer to have one manufacturer
make all the cars, to cut the per-vehicle cost, the participants in the program want their
cars to be produced locally.   Cottage  industries  are therefore  the  key  to program
expansion.  However, efforts will be  made to  link the  smaller manufacturers into a
coherent program.  The NSCA will perform reliability testing, and EPRI will develop
testing protocols so the manufacturers will be operating from the same set of data.
                                   Session 3D — Alternative Vehicle Technologies

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Page 84       	Clean Air Marketplace 1993


           Gorik Hossepian, Manager, Fuel Cell Program, Allied Signal Aerospace Co.,
           discussed  his company's efforts to  produce a viable  fuel-cell for vehicular
           power systems. Fuel cells are a particularly attractive option, according to Mr.
           Hossepian, because  they are a  technical discontinuity; that is, they represent
           a revolutionary innovation, not an evolutionary one.  The development of a
           viable fuel cell could reduce the U.S. trade deficit dramatically — by over $21
billion annually — through a reduction in oil imports and increase in technology exports.
Fuel cells could be a major global opportunity, not just for Allied-Signal, but for the U.S.

       Fuel cells are much more efficient power sources than  conventional  electric
generators  because the cells transform chemical  energy directly into electrical energy
without heat and mechanical energy steps.  In addition, emissions are almost non-existent
when compared with combustion engines, because there is almost no physical contact
between the nitrogen  and the oxygen at high temperatures,  as is the case  with the
combustion process. Eventually, fuel cells (assuming they are twice as efficient as the cells
being produced today) will be able to save three million barrels of oil per day.

       There are two fuel cell programs sponsored by Allied Signal: the Monolithic Solid
Oxide Fuel Cells (MSOFC) program and the Proton Exchange Membrane (PEM) program.
The MSOFC is the highest power density fuel cell  being developed today,  making it
attractive for high power needs such as vehicles and industrial sites.  The MSOFC is a
multi-fuel device — it has operated on anything from packed charcoal to natural gas.
Unlike other fuel cells, the energy is produced through the transport  of oxygen ions and
not hydrogen ions. The MSOFC also has the potential to  be economical, perhaps costing
under $1,000 per kW installed.  The PEM cell is  preferred for non-fossil fuel applications,
and will be used for transportation applications.

       Allied Signal has great interest in fuel cell technology.  Fuel cells fit in well with
Allied Signal's hardware product lines.   In  addition, the company's expertise in key
material technologies and in the aerospace and  transportation industries provides Allied
Signal with a competitive advantage,  which is the key to making  fuel cells economically
viable.  Fuel cells will be the next replacing technology in the auxiliary power unit market,
of which Allied Signal currently controls about  90 percent.

       There are three potential markets for fuel cells:

       •      Power utilities, which have  already started using the technology;

       •      Transportation, which should be the next major fuel cell user, because of
              regulatory mandates to create emission-free cars; and

       •      Aerospace, which is a  sector lagging in fuel cell applications. This can be
              attributed to the fact  that fuel cells have a bad reputation, and aircraft
              companies prefer to deal in proven technologies.
 Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993	Page 85


       The presentation concluded with a projection of the future of fuel cells.  By 2010,
fuel  cells will  represent a  $35  billion  market worldwide, with much of the  growth
occurring after 2000.  By 2003, 500,000 zero-emission vehicles will be produced, largely
because of the California vehicle law, generating a transportation market for fuel cells.

       Environmental regulations relating to vehicle emissions have created a market pool,
not a market itself. The search for potential commercial uses for the PEM fuel cell  has
been motivated by current legislative mandates, but a viable product has not yet been
developed.  Before any growth can occur, the technology and performance of the cells
must improve significantly.  Allied Signal has attempted to do this through advancements
in materials and systems.
           Dr. Roberta Nichols, Electric Vehicles External Strategy Manager, Ford Motor
           Co., presented an overview of Ford's efforts to produce electric-powered cars.
           Dr. Nichols began with a brief discussion of the history of electric vehicles,
           noting that such vehicles do not represent a new technology.  In the early part
           of the  century, in fact, there were more electric cars than gasoline-powered
           cars. Once hand-crank starters were replaced by electric starters, however, the
internal combustion-powered cars became more prevalent. Since that time, the lack of a
battery that could  power a car with satisfactory range and sufficient lifetime has been the
primary obstacle to marketing electric cars.

       There are several advantages to electric vehicles:

       •       Electric  vehicles have  zero emissions.   The improvement in  air quality
              provided by these cars  is especially pronounced in those countries, such as
              France,  where most  electricity is provided  by  nuclear or hydro-electric
              power plants;

       •       The ability to recharge electric vehicles at home precludes the need to stop
              at filling stations;

       •       Preliminary indications are  that electric vehicles will  be more reliable and
              require  less maintenance than  internal combustion vehicles because the
              engine will be simpler  to maintain.  Oil and spark plugs, for example, do
              not  need to be changed in an electric car; and

       •       Electric vehicles are quiet and can therefore be used in situations, such as
              a park setting,  where conventional vehicles would be too loud.  Dr. Nichols
                                    Session 3D — Alternative Vehicle Technologies

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Page 86	Clean Air Marketplace 1993


             did note that the quiet operation of the motor could pose a safety problem
             because pedestrians cannot hear the car coming.

       Conversely, there are also some disadvantages to the use of electric vehicles:

       •     The reduced driving range of electric-powered  cars means that electric
             vehicles will never provide an equal replacement  for the traditional family
             car;

       •     The high cost and  short lifetime of electric vehicle batteries make electric
             vehicles more expensive to operate than conventional gasoline vehicles.
             Considering electricity alone,  electric vehicles are very inexpensive.  But
             when  the cost of replacing batteries is factored  in, the cost per mile  of
             operating an electric vehicle is higher than the cost per mile of operating a
             gasoline engine.  The cost of running an electric car in the U.S. would  be
             equivalent to the cost of running a 30 mpg car on $3.75 per gallon gasoline.
             This gap is especially pronounced in the U.S., where gasoline prices are
             lower than in European countries:  In the U.S., electric cars cost 14 cents a
             mile to run, compared with four cents a mile for conventional vehicles,
             while  in France, the cost is about 15 cents a mile  for both.

       •     Though electric vehicles themselves do not produce  emissions, the power
             plants which supply  the electricity to the vehicles do, at  least  in the U.S.
             These secondary emissions must be considered, but there does appear to  be
             a net benefit.

       Ford is examining a number of consumer issues. The initial cost of electric vehicles
will be very high, though the price  will eventually decrease as the technology is refined
and volumes increase.  This high initial cost, coupled with the high  battery  cost and
limited range of the vehicles will make electric cars a hard item for Ford to sell.  The
consumer, in effect, is being asked to pay more for less.

       The primary obstacle that must be overcome in electric vehicle development is the
development of better battery technology.   There is no clear indication as to what the
battery of the future will be. Ford is currently using sodium sulfur batteries in its electric
vehicle program. Though these batteries have four times the energy of a conventional
lead/acid battery, a battery source with twice the energy as the sodium sulfur battery may
be needed. To  this end, the U.S. Advanced Battery Consortium (USABC) was formed  in
January  1991.  USABC  is a business partnership among  Ford, General  Motors, and
Chrysler with participation by EPR1 and battery  development companies throughout the
world.  The U.S.  Department of  Energy has matched (dollar for dollar) industry funds
given to USABC.  By the end  of 1995, over $260 million will  be spent by USABC  on
advanced battery technologies.
Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993                                             Page 87
       Ford currently is operating an electric vehicle demonstration program. Eighty-two
ECOSTAR vans, a modified version of Ford's European Escort van, are being delivered to
customers on  a 30-month  lease, after  which time they will be  returned to Ford  for
evaluation.  The purpose of the demonstration is to  confirm  the technology, develop
vehicle expertise, and gain information  on customer satisfaction.

       The ECOSTAR  has  exceeded  Ford's targets in several performance areas.  The
ECOSTAR has a range of more than 100 miles per day, surpassing the initial 100 mile
target; is able to accelerate from 0-50 in 12 seconds, bettering the target time by 2 seconds;
and is able to carry a 900 pound payload, compared to the 700 pound target.  The recharge
time of seven hours,  however, is longer than the five to six hour target.

       The van has a single speed integrated transmission and a top speed of 70 mph.
The ECOSTAR acceleration is also roughly similar to that of the gasoline powered Escort;
the performance of the electric van is slightly better in the 0-50 mph range, but slightly
worse in the 50-70  miles-per-hour range.   Air conditioning and heating systems are
available, though both cut down severely on the range of the vehicle in extreme weather
conditions; using the air conditioning in a temperature of 105 degrees cuts  the range by
a third, while using the heater at zero degrees reduces the range by 40 percent.

       The development  of a  market for  electric-powered cars will  hinge on  the
development of greater advantages for the cars to outweigh the several disadvantages. In
the end, consumer satisfaction must be the primary goal because all the legislation in the
world will not support an electric vehicle program unless the customer is satisfied
           Paul Gifford, Ph.D., Director of Product Development, Energy Conversion
           Devices, Ovonic  Battery Company, Inc., described his company's efforts to
           develop a high powered battery based on a nickel metal hydride power source.
           Dr. Gifford began by listing seven areas that must be maximized in the design
           of batteries used  to power electric vehicles:

       •      specific energy content and electrical energy density, which relate to how
             far a vehicle can travel;

       •      power, which  determines how fast a car will be able to accelerate;

       •      low  temperature performance, so a  car  may  perform  well  in  inclimate
             weather;
                                   Session 3D — Alternative Vehicle Technologies

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Page 88                                             Clean Air Marketplace 1993


       •      cycle life, which determines how long a battery will last before it must be
             replaced;

       •      abuse  resistance, which is important because vehicle drive  trains are
             pushing at high ranges — up to 320 volt systems;

       •      rapid recharge capability; and

       •      environmental compatibility.  Batteries should not contain heavy metals,
             such as cadmium and lead, which could ultimately result in downstream
             pollution.

       The recognized need to develop improved batteries led to the creation of USABC.
In May 1992, USABC granted Energy Conversion Devices, Inc. the first contract to develop
a nickel metal hydride battery, to be produced by its Ovonic Battery Company subsidiary.
Ovonic's development  is proceeding  well, and the  company  has remained ahead of
schedule in its deliverables.

       Some of the technical specifications of the nickel metal hydride battery are:

       •      high energy density (80 watt hours per kg, 240 watt hours per Ib  versus
             34-36 watt hours per kg for conventional lead/acid batteries);

       •      high  power (greater than 200  watts  per kg, even  at high  depths of
             discharge);

       •      long life  (1000 cycles at  100 percent depth  of discharge);

       •      wide operating temperature (-20°C to +60°C);

       •      quick charge capability (60 percent in 15 minutes);

       •      totally sealed/maintenance free unlike some other batteries  which,  for
             example, may require watering systems;

       •      tolerance to overcharge  and over-discharge; and

       •      environmental  acceptability.  The nickel metal hydride batteries do not
             contain any heavy metals and have been independently certified as passing
             EPA's pollution standards.
 Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993
Page 89
       The  following table compares the performance of a  vehicle running on  a
conventional battery versus the Ovonic battery:

Range
Top speed
Acceleration
Lifetime
Recharge time
ADVANCED LEAD/ACID BATTERY
120 miles
100 mph
0-60 mph, 8 seconds
20,000 miles
2 hours
OVONIC BATTERY
greater than 250 miles
100 mph
0-60 mph, less than 8 seconds
100,000+ miles
60 percent in 15 minutes
100 percent in 1 hour
The nickel metal hydride battery does not need to be replaced — the battery would last
the lifetime of the car.

       Ovonic is located in Troy, Michigan and employs 80 people in three facilities. It is
a fully integrated battery company, manufacturing its own electrodes, cells, and hydride
materials (metal alloys which store hydrogen as a solid and represent the heart of the
battery technology).  Ovonic has produced batteries in a wide range of shapes and  sizes
— from a 30  amp per  hour cell to  a 250  amp  per hour cell.  These cells have  been
configured into battery modules and  full electric vehicle battery packs.
Questions and Answers
       L  We have heard different views on the progress of battery technology.   Dr.
  f^  I  Nichols seems more pessimistic than Dr. Gifford. How do you account for the
   •   I  difference in your assessments?

Dr. Gifford stated that while work was left to be done in battery development, significant
progress has been  made.   Dr.  Gifford stated that the results presented are actual
experimental results demonstrated with existing cell and battery hardware.  He also
pointed out that the nickel metal hydride battery was currently being successfully tested
in a mini van in Troy, Michigan.

Dr. Nichols characterized the differences between her and Dr. Gifford as "where we are
today versus where we want to go." She stated that Dr.  Gifford was discussing potential
battery development, and that the batteries currently being tested do not quite match up
to the projected technical specifications.  She also said that it was too soon to comment
whether Dr. Gifford was being overly optimistic.
                                   Session 3D — Alternative Vehicle Technologies

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Page 90                      	          Clean Air Marketplace  1993
        Does Ford make station vehicles?
  *>
   •  I Dr. Nichols responded that it is too soon to tell whether Ford will enter into the
T"^^J station car market.  While Ford has not traditionally been in that business, the
status of electric vehicle technology makes the nature of the market uncertain.
         Can the sodium sulfate battery be disposed of safely?

         Dr. Nichols said that the USABC  contract with the battery developers requires
         them to develop a means to recycle any battery that is produced.

         What is the cost of the PEM for transit operators?
  *
   •  I  Mr. Hossepian responded that the current cost is greater than $2,000 per kW, and
^•^J  may be as high as $8,000 per kW. To make the technology economically viable,
however, the cost must be in the $20-$30 per kW range.
         What are the logistics of station cars?

         Dr. Bernard responded that ownership will rest in a third party — not the person
         who  uses the car, and not the transit agency. The car would be rented to a
customer who would keep it until it was needed for the next transit trip, perhaps using
it during the day at work. While the station cars might not ever be financially viable, they
will be economically viable, because the environmental benefits will outweigh the costs of
the program.  The station car might replace the third car in  a three car household, thus
providing benefits. The station cars currently use lead/acid batteries, and NSCA expects
to use such batteries until at least 2000,  because  they are  the only affordable  battery
systems available.

         Have you considered using solar power for electric vehicles?

         Dr. Bernard responded that not enough energy can be collected to power cars
         using only solar power.  Mr. Hossepian agreed, and stated that sufficient power
density simply does not exist with a solar energy  source. Mr. Gifford pointed out that
solar power cannot stand on its own as an energy  source, but with the right technology,
solar power could be used for vehicle range extension.

Dr. Nichols explained that The ECOSTAR van uses a solar powered fan to blow  out hot
air while the van is idle, to prevent drain on the air conditioning when the van is started.
Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993                                              Page 91
a
         The comparison in gas prices  between the U.S. and other countries that Dr.
         Nichols presented is misleading because the gas taxes between those countries
         vary so much.  If more electric cars are used, will not tax revenue be lost?
Dr. Nichols agreed with the questioner's point, but speculated that if many electric cars
were in use and there was a resulting reduction in fuel tax collected, then some sort of tax
would probably be imposed on batteries or alternative fuels to make up the difference.
a
        Are venture capital markets active in the development of alternative vehicle
        technologies?
         Mr. Gifford indicated that venture capitalists are probably waiting to see what
the market for batteries will be.  We do not expect significant involvement on their part
until the technologies are developed further.

Dr. Nichols responded that because of this trend, government agencies would probably
remain  the prime  source of funding  for alternative vehicle technologies.   Because the
legislative  mandates  of  the U.S.  government are driving  electric vehicles  into  the
marketplace at a faster rate than they would otherwise be  introduced, the government
recognizes that they have a responsibility to help manufacturers develop such vehicles.

Mr. Hossepian added that venture  capital companies are very active in the development
of fuel cells.
         What has been the effect of the President's clean air initiative on the industry?

         Dr. Nichols responded that the initiative is not close to being in final form and
         no one in industry knows what the final initiative will contain,

         // we put "ambassador vehicle" cars on the road that have not been safety
  f} I  certified, as Mr. Bernard implied we might, are not we just hurting ourselves?
a
         Dr. Bernard stated that the NSCA does not support the production of non-safety
certified vehicles, but such vehicles may be produced in any case. Mr. Bernard added that
his association depends on cottage industries because Original Equipment Manufacturers
(OEM) are not willing to work in a small market niche, such as in station vehicles.

         How does the intensity of U.S. efforts to produce electric vehicles compare to
  C}~  I  efforts in the rest of the world?
a
         Dr. Nichols responded that U.S. technology is as good as technology anywhere
and the U.S. could be at the forefront of the electric vehicle market if it could bring that
technology into the marketplace at an affordable price.
                                   Session 3D — Alternative Vehicle Technologies

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 Page 92                                              Clean Air Marketplace 1993
 Mr.  Gifford  explained  that there is a  high  visibility  of  effort  in  developing battery
 technology in the U.S., largely due to the efforts of USABC. At the same time, while the
 U.S.  may  be a leader today  in the  development of advanced battery  technology,
 competition abroad will be a problem in the future.  The level of activity in Europe and
 Japan is very intense.  In Europe, the size of the electric vehicle market is potentially larger
 than  it is in  the U.S., and the  Japanese and  Korean auto companies are pursuing the
 development of technology with great vigor, though they do so with a lower public profile
 than  the  U.S.

 Mr.  Hossepian stated that the U.S. is out spent by two and one-half to one by  the
 European community, and by five to one by the Japanese in fuel cell technologies.  Most
 of the money in Europe and Japan goes toward demonstration programs for relatively
 poor technology, while  some U.S. money is being spent on solving  technical problems,
 which makes the technology viable. In sum, the U.S. is  ahead of Europe and Japan from
 a technical standpoint, but it is  being out spent at an alarming rate.
         Is Ford using fuel cells?

         Dr.  Nichols responded that the development of fuel cells is still in the research
         stage, and is handled through a different department.
Session 3D — Alternative Vehicle Technologies

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Clean Air Marketplace 1993
                                 Page 93
                         Session 4 — Panel A
                         Electric Power Services (including DSM)
                         September 8,  1993
                           4:15 p.m. -6:15 p.m.
                         Moderator:
                         Panelists:
Renee Rico
Jeffrey VanSanf
William Hederman
Carlton Bartels
John Henry
Introduction

       Renee Rico, Chief, Market Innovations Branch, Acid Rain Division, U.S. EPA,
discussed  how the electric power industry is at  a  crossroads, faced with mandates to
consider the environment while providing least cost service.  The opportunities in the
Clean Air  Act (CAA) go well beyond the traditional command-and-control technologies.
Opportunities for compliance with a variety of 1990  Clean Air Act Amendments (CAAA)
requirements, include fuel choice, energy efficiency and demand side management (DSM).
While the acid rain program contains probably the best known requirement facing utilities,
they also have to comply with Title I ambient air quality standards requirements, including
those for ozone.  The Energy Policy Act builds on  the issues the CAAA began to address,
such as how utilities consider their planning and delivery of services, Interstate issues, least
cost planning for meeting energy needs, as well as accounting for lost revenue due to DSM
and conservation. Greenhouse gases is another issue that will be discussed.
Presentations

          Jeffrey VanSant, Vice President and Director of Fuel Supply, New England
          Power Company,  New  England  Electric System  (NEES),  discussed his
          company's efforts  to  reduce emissions based on least  cost strategies and
          increased  energy conservation.  NEES has one of the nation's largest  DSM
          programs.  A critical part of NEES' commitment to reduce the environmental
          impacts of electric service by 50 percent by the year 2000 is its DSM program,
one of the largest  in the nation.

      NEES's retail electric companies serve about half of Massachusetts, most of Rhode
Island, and part of New Hampshire.  It also  owns New England  Power Company, a
wholesale power company.
                                           Session 4A — Electric Power Services

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Page 94                                            Clean Air Marketplace 1993


History of DSM at NEES

       NEBS' commitment to conservation and load management was first articulated in
1979 its long range plan,  the  first in a series of company planning initiatives.  The
commitment was stepped up in 1985 with a second plan in which NEES committed itself
to a balanced, least cost planning process.   In 1989, in  cooperation with the utility
commissions in Rhode Island,  Massachusetts, and New Hampshire, and  also with the
Conservation Law Foundation, the NEES retail companies pioneered the development of
regulatory mechanisms that provide utilities with the opportunity to earn a return on their
conservation and load management investments. The objectives of the mechanisms were:

       •     To guarantee value to the customer

       •     To share the savings fairly

       •     To ensure the company is paid only  for  performance

       In the third NEES plan, announced  in 1991, NEES reaffirmed its commitment to
conservation as part of an overall strategy with the following objectives:

       •     To reduce the impact of emissions by 45 percent in the next decade

       •     To cause no  real  increase in electricity rates in the next decade

       •     To combine supply and demand side strategies  to meet these goals

DSM is expected to contribute about 10 percent of the  total emissions reductions.

Savings, Spending, and Shareholder Value

       Since  1979  NEES has spent $341 million  on  DSM.   DSM spending  currently
amounts to five percent of revenue, making NEES's DSM program one of the largest in the
country as a percentage of revenue.  The incentive measures have been a success. In 1990,
before tax incentives earned by the company were $4.3 million; in 1991, they were $7.3
million, and in 1992, $10.5 million. NEES expects to  save 600,000 megawatt-hours over the
period 1990 to the end of 1993 as a result of the DSM programs installed.

       The key here is not just the  real savings achieved, but  the development with the
Conservation Law  Foundation  of highly advanced evaluation techniques for measuring
energy saved and continuous monitoring. Since 1987, 3,000 tons of NOX emissions, 7,000
tons of SO2 emissions, and two million tons of CO2 emissions have been reduced as a
result of DSM programs. The reductions are not huge,  but they are real and quantifiable.
DSM is an  ideal pump primer for emissions trading, and emissions trading can provide
an additional incentive to undertake DSM.


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Other Emissions Reduction Initiatives

       NEES is involved in several innovative projects, the objectives of which are to:

       •      Push the edge on technology,  both in pollution control and the efficient
              creation and use of energy

       •      Gain knowledge about technology to  help tackle environmental strategies
              in the future

       •      Participate in the regulatory process

       •      Establish the value of offsets

       •      Ensure low cost access to offsets

       Selective non-catalytic reduction

       Selective non-catalytic reduction is a chemical process for reducing NOX emissions.
Urea is injected into a boiler where it combines with  NOX to yield elemental nitrogen and
water. The project at Salem Harbor, a cooperative arrangement with the Massachusetts
Department of Environmental Protection, is a  good example of pushing the technological
edge. This is the first successful commercial application of selective non-catalytic reduction
in a coal-fired boiler, and it has cut NOX reductions  by almost 50 percent.

       Renewable Power

       In 1991 NEES issued a "green" request for proposal — a solicitation for proposals
for renewable resources. As a result, NEES recently announced that it will purchase 36
megawatts of electricity from seven renewable plants, including New England's first wind
power project.  The cost of power for most of  these projects is less than the cost of power
produced by modern fossil fuel plants. The technologies and processes employed by these
plants include state-of-the-art wind turbines, combustion of methane produced at landfills,
and municipal solid  waste combustion.  This  competitive solicitation was the first of its
kind in the United States.

       Coalbed Methane

       NEES has also participated in a pilot program  to demonstrate the feasibility and
cost of capturing coalbed methane at two sites in West Virginia and Pennsylvania.  The
goals were to collect scientific data demonstrating the  potential cost of coalbed methane
offsets, to help establish the value and verifiability of coalbed methane offsets, and to
secure access to sources of offsets. In the process NEES has developed a valuable data
base. The  results of the program are an $11 per ton CO2 equivalent cost, factoring in


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expected methane flow rates, the price at which it would be sold into a pipeline, and
associated development costs.  NEES expects to continue its pilot projects.

       International Greenhouse Gas  Reduction

       NEES has also participated in a reduced impact logging project in Malaysia.  This
pilot project tests new methods of harvesting that reduce the impact on the forest.  It
involves better planning and minimizing destruction of trees not targeted for harvesting.
An environmental audit committee, consisting of an expert from the University of Florida
and  the Rainforest  Alliance, has been established  to measure the results.  The first
harvesting is underway using the reduced impact  logging techniques.  Initial results
appear to confirm that CO2 will be offset at a cost of $l-$2 per ton.

       NOX Trading

       NEES is pursuing NOX trading on two fronts. First, it is working  closely with
NESCAUM (North East States for Coordinated Air Use Management) to develop protocols
for quantifying NOX reductions, in order to create and document a NOX reduction credit.
The  next step  will be to address the banking and trading of credits. Second,  NEES is
actively pursuing trading partners in Massachusetts and Rhode Island to help prime the
trading system.

       The CAAA, with their expansion of market-based emission credit trading to more
localities and  more  affected sources, were  a turning point in  emissions regulation,
providing  market-based  options to meet emissions  reduction  goals.  Market-based
approaches have many advantages over traditional command and control approaches, and
should  be  adopted  for other emissions.  Market-based approaches  result  in least cost
compliance, and encourage expenditures beyond what would be done under a command
and control environment.  Market-based systems encourage industry through competition
and  incentives to  stimulate  technology development.   They  can create economic
development opportunities by:

       •      Fostering technology development

       •      Providing incentives to use energy more efficiently

       •      Reducing the costs for everyone

       •      Making offsets available to new industry

       NEES plans to offer offsets as an inducement to industries that choose to  locate in
its service territory.  A good example of the economic development opportunities are the
thousands of jobs created by NEES' DSM program.  In conclusion, with a market based
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Clean Air Marketplace 1993                                              Page 97
system, adverse environmental impacts  can be reduced in a cost effective manner,
development opportunities can be created, and shareholder value will increase.
           William Hederman, Managing Director, RJ. Rudden Associates, Inc., discussed
           integrating natural gas and electric utility resource planning.  He chose to
           discuss this topic because  of the uninformed opposition of utilities to fuel
           substitution he has encountered in litigation at the state commission level.  In
           many cases integrating natural  gas and utility DSM programs will result in
           major efficiency gains that  benefit all.  DSM is important to gas and electric
utilities for very different reasons.

       It is important to keep in mind  the differences between gas and electric utilities.

       •      Vertical integration:  Gas utilities are much less vertically integrated than
              electric utilities.

       •      Planning horizons: Electric utilities are comfortable planning 20 or 30 years
              ahead or considering the life  of a power plant. A gas company often plans
              only 20 or 30 months into the future. It does not take more than a year or
              a year and a half to put new gas  capacity in place, with the exception of
              long haul pipelines. Local gas systems therefore have a different mentality
              than electric utilities.

       •      Outages:  A big part of  load management on the gas side is planning for
              interruptions of major industrial customers.  Electric  utilities have more
              information about their load  and market than gas suppliers do.  When the
              gas and electric combination utilities start dealing with DSM on the  gas
              side,  they typically bring some of their electric market and gas market
              people together to  talk.  The electric side has information on penetration
              rates and age of appliances. The gas side does not and may not collect this
              type of  information.  Because of the mistaken belief that the U.S. was
              running out of gas supplies, regulators have often  prohibited gas utilities
              from making expenditures  for market research  or marketing.   Where
              marketing and market research are allowed, the exclusion of costs from
              revenue requirements consitutes a major negative factor.

       •      Implications of  DSM:   On  the  electric side DSM tends to mean less
              electricity.  On the gas side  it tends to mean more gas.  That appears to
              have created serious resentment on the part of the  electric utility.
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       Despite the differences there are opportunities to improve air quality with natural
gas.

       •       Cooling:  One major opportunity is gas cooling. One of the advantages of
              using gas as part of electric DSM is its persistence  (i.e., ability to stay in
              place).  Gas equipment,  unlike a high  efficiency bulb, will continue to
              produce electricity savings  far into the future.  There  is little potential for
              electricity use at the site to increase over time once gas cooling equipment
              is in place.

       •       Water heating:  Another possibility  is hot water supply, but it is more
              controversial. Going to a high efficiency electric water heater may lock out
              an option that is even more efficient,  such as gas.   Officials at EPA  have
              talked informally about supporting gas over electrical hot water at the state
              level, but have not done so yet.

       What utilities need are not directives from EPA, but objective, expert information
about externalities and how to take them into account when considering gas and electric
power.   An  individual  utility does not have the expertise,  the data, or the economic
resources to develop definitive externality values.  The more perceptive state regulators
are looking to come up with some way to increase efficiency in their regions.  They are
therefore interested in more efficient use  of the gas  and electric utilities'  infrastructure.
Between one-fourth and one-third of states have or are considering gas-electricity fuel
substitution requirements.

       Looking at gas and  electricity demand over a given  year shows that even in very
different climates, excess seasonal capacity in gas and electricity are complementary. The
highest demand for gas is during the winter when gas is used to heat homes. The highest
demand  for electricity is in the summer when it is used  to power  air conditioners. Gas
suppliers and utilities are forced to build  capacity for these peak periods  that then goes
unused much of the rest of the year.  Gas cooling systems can increase use in a low-use
season.  Using the seasonal spare capacity in both systems will delay the need to build
more power plants. There is considerable potential for synergy.  That economic gain need
not end  up  solely in the  hands of the  gas company  or the electric company.  The
breakthrough of  DSM is that incentives can be offered in such  a way  that all parties
benefit.

       The challenge is to get over the almost emotional rejection of the idea, just because
gas and electricity are competitors. Competition should be maintained. To quote a friend
from  the Hill — the idea  of putting two monopolies in  a  room and asking them to
cooperate does not give people "warm fuzzies."  Fuel substitution  needs to take place in
such a way that competition is preserved, but the economic advantages of offering cheaper
service as a result of greater efficiency should not be overlooked. Because fuel substitution
is a  more efficient use  of  resources, it should give those regions that implement it a


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Clean Air Marketplace 1993                                             Page 99
competitive advantage in power costs at the national level.  This is beginning to occur in
a few regions where there are gas and electric combination utilities, such as Consolidated
Edison in New York and Baltimore Gas and Electric.

       The best way to overcome competitor and regulator distrust is a strategy first used
with DSM. A technical working group including the electric utilities, gas suppliers, and
regulators should be set up to start finding common ground and building trust.  They can
begin with many technical issues  such as how  to establish avoided  costs, externality
values, discount rates, and incremental costs. The group needs to decide which building
simulation  models are acceptable and how to run base and post-DSM cases.  Then the
debate can focus on meaningful issues. Many  DSM  consultants and technicians are
missing a strategic opportunity here.  They seem to think that the top executives want to
think narrowly on gas-electricity fuel substitution.  There is a revolution in efficiency going
on. Time has shown that those who choose to stick their head in the sand  tend to face
premature retirement.
           Carlton Battels, Director, Environmental Brokerage Services, Cantor Fitzgerald,
           discussed the SO2 allowance trading system created by Title IV of the 1990
           CAAA and Regional Clean Air Incentives Market (RECLAIM)  in the South
           Coast Air Quality Management District (SCAQMD) in Los Angeles, California.
           The SO2 allowance trading system is one of the most innovative parts of the
           1990 CAAA.  The Act sets a  maximum level  of emissions, and the  market
decides the least cost method of reaching this level. This will result in great efficiencies
and lower costs in reducing SO2 and acid rain. The market acts to drive innovation in the
emission reduction system.  Allowing trading  in allowances has reduced the price of
eliminating SO2 from $1,200 to $200 per ton.

       Cantor Fitzgerald is trying to formalize the market by establishing a centralized
marketplace which brings buyers,  sellers and  traders together.  By  establishing that
recognize that all allowances are the same, greater efficiency in trading can be achieved.
Currently,  emissions  allowances are sold through  detailed  and  complex one-to-one
contracts. This should not be necessary. By creating trading rules, a more efficient, liquid,
and low cost commodity market can be created.  Cantor Fitzgerald is  in the process of
establishing a  screen based trading system, similar to the one used for U.S. government
bonds, to create a centralized marketplace from decentralized information. It will provide
a place to turn when one needs or has allowances, a  place where the price is set by the
entire market.
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       Cantor Fitzgerald needs to tailor the market to fit the needs of the industry. In
particular, Cantor Fitzgerald has created a transaction, the forward-looking contract, that
is based on the way utilities buy and sell power and fuel. The  forward-looking contract
is a purchase of several years supply at a time with a set delivery schedule and payment.
This with the needs of today's industry.

       Cantor Fitzgerald will be running a screen-based trading system in the California
Regional Clean Air Incentives Market (RECLAIM) starting in January and, is trying to set
up such a program in the acid rain allowances market.

       The advantages of a centralized marketplace are:

       •      Price discovery, resulting from many transactions occurring at one time in
              one place. A risk adverse group, such as the electric utility, is especially
              reluctant  to  make price commitments when there is  price uncertainty.
              Cantor's system posts sales and price, but keeps names secret.

       •      Better deals, resulting from the availability of many buyers and sellers. A
              centralized market makes it easy to combine the offers of several buyers or
              sellers to match  the exact quantity that you wish to buy or sell.   In a
              decentralized market,  the cost of finding the  best deal  is much more
              expensive.

       •      Standardized agreements,  resulting in  quicker,  simpler  and cheaper
              transactions.  Everything is done with standardized agreements, signed
              beforehand. Specialized contracts are rarely necessary. The broker arranges
              and supervises the exchange of money and emission credits. The contract
              is set up in such a way that today's ratepayers do not pay for allowances
              for tomorrow's ratepayers. There are also tax advantages to spreading the
              sale over several years.  In sum, the contract fits into cost regulation today,
              and it is consistent with the way rates are set.

       The allowance market by law is open to everyone, and there is a role for financial
intermediaries because of the rigid way utilities look at pricing. Intermediaries can smooth
out cost flows.

       Cantor Fitzgerald will be running a market-clearing, computer-assisted auction in
California, with the aim of bringing order into an ill defined market with minimum risk
to the participants. RECLAIM, a trading system for SO2 and NOX in SCAQMD, will come
into existence in December.  Emitters, including utilities, will  then be able to trade
emissions allowances within the district. At a given moment every person faces the same
prices. Everyone either gets a price they are happy with or they do not make a trade. The
computer calculates the price over time, making it possible to weigh the costs of installing
new emissions control equipment with the value of the product, emissions credits.
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Clean Air Marketplace 1993                                           Page 101
          John B. Henry II, President, Clean Air Capital Markets (CACM), discussed the
          SO2 allowance market from another perspective.  CACM, an environmental
          investment bank, has structured the majority of private placement (one-to-one)
          SO2 transactions, totalling more than 200,000 allowances. It currently has eight
          full-time professional employees and continues to grow. Many of the deals are
          not made public because of concerns about negative publicity and competitive
pressures, contributing to the lack of information mentioned by Mr. Bartels. Deals that
CACM have been involved with are:

       •      A deal between Wisconsin  Power and  Light and the Tennessee Valley
             Authority (TVA).  The public reaction to the first allowance transaction
             showed how important politics and public perception are in this market.

       •      ALCOA, the world's largest aluminum manufacturer, has undergone some
             significant  fuel switching at a plant in Indiana.  The emissions allowances
             were sold to Ohio Edison.

       •      NEES is  compensating generation for reduced utilization deal with Ohio
             Edison now awaiting EPA approval.

       •      Illinois  Power avoided  the  major expense of installing scrubbers by
             purchasing a bundle of allowance streams from several sources that CACM
             had put together.

Increasingly, deals are not announced, making it difficult to obtain price information. The
information that is available is often unreliable. In addition, utilities have  only limited
staff working on allowances, and allowances have not been a major priority. Full time
specialists are needed to close deals.

       CACM acts as a  confidential advisor/ advocate and does not take capital positions
in its trades. CACM is paid only if an allowance deal is concluded. Its job is to structure
deals for its clients.  The allowance trading market is driven by prudence rather than
greed, and the public relations aspects are highly important. Rate-making is a large part
of any deal as well, because utilities are so highly regulated. Who pays and who benefits,
the rate payers or the  shareholders, must be determined  in each case.  There are also
political limitations on the deals that can be done, particularly ones between distant areas.

       Utilities are the major players in the allowance market in which CACM operates.
The utility industry represents the largest accumulation of capital in the economy, as well
as the most regulated industry in the economy.  Utilities are required  to exercise
compliance planning, which is what shapes the market. Compliance plans  traditionally
have consisted of one or a combination  of two options:
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       (1)    The scrubber, which is a huge capital investment, paid for over 25 to 30
             years, and

       (2)    Fuel switching to low sulfur coal  or  gas, which involves a  long term
             contract of 10 to 15 years.

Both of these  compliance options  can  be viewed  as  the utility purchasing emissions
allowances from its own system. These purchases are called "on-system" purchases while
allowances bought from other utilities or sources in the emissions allowances market are
"off-system" purchases. Utilities make commitments to clean up years in advance, and the
methods they traditionally choose involve long-term streams of reductions,  rather than
annual reductions. This shapes the allowance market. Every  utility is set up to reduce
emissions through "on-system" measures.  Every deal so far has been a major policy
decision, requiring the participation of the CEO and the chairman of the board. No utility
is yet willing to look at "off-system" compliance in a  fundamentally different way than
"on-system" compliance, meaning that utilities  are not interested in short term or small
allowance trades.

       A utility that is buying "off-system" allowances is looking for a secure supply at
reasonable prices.  CACM believes the solution is to lock  in long term streams through
private placement.

       How do you overcome customer resistance to "off-system" transactions? CACM's
experience is that requests for proposals, bulletin boards and auctions do not meet market
needs. A centralized market will not solve the  needs of utilities. CACM has found that
the main obstacle to off-system compliance is that utilities are  struggling with least-cost
versus least-risk. The regulatory structure of who pays, who benefits, and who takes on
risk makes the market very complicated.  Public utility commissions need to learn more
about the allowance market, but cannot  be expected to give utilities a blank check and
rubber stamp every allowance deal.  Those advocating allowance transactions need to
recognize that they are competing with suppliers of on-system emissions reductions, such
as low sulfur coal suppliers and scrubber manufacturers.  The price of allowances must
be  competitive with the scrubbers and  fuel switching, which are sold in  customized
contracts in a decentralized marketplace.

       The CAAA SO2 emissions reduction plan has two phases. Phase I, which ends in
1999, requires a 3.5 million ton annual reduction in SO2 emissions, a fairly easy standard.
Most of this has been met with fuel switching, in many cases at negative or close to zero
cost. Scrubbers supply much of the remaining reductions. Thus, in Phase I,  the price of
allowances has been very low. Phase II, starting in 2000, requires an annual reduction of
more than 8 million tons.  At least half of this will be met through fuel switching, with the
rest coming  from scrubbers and allowance  purchases.   According  to Mr.  Henry,
shareholders will not willingly pay for scrubbers, and utility management are preparing
to go before their regulatory boards to get permission to have rate payers pick up the cost.
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Clean Air Marketplace 1993                                            Page 103
      There will be a two-tiered market for allowances — a  forward market, which
CACM is involved with today, will be joined in the future by  a short term allowance
market.  The window for forward high-value Phase II allowance deals is 1994-1996.  As
seen in the EPA auction, the short term price of an allowance is considerably lower and
after 2010 will fall as the uncertainty associated with the transition to lower emissions is
eliminated.
Questions and Answers
         Is the centralized marketplace described by Mr.  Bartels a complement or a
         substitute for the one-to-one private placement transactions that Mr, Henry has
         been working on?

Mr. Bartels explained that there is significant overlap, with both systems offering streams
of allowances, but standardized trading cannot take over everything.  Private placement
trades offer a lot more hand holding.  As the market develops, there will be a transition.
Originally, power exchange involved as much effort as emissions trading today, but now
power exchange is commonplace and top management is not involved.  Cantor also sees
a two tier market.  There is definitely a rivalry between the centralized marketplace and
private placement firms.

Mr. Henry commented that utilities lack confidence in how their regulatory commissions
will  treat their allowance decisions.  In  theory, allowances could  be  traded  as a
standardized commodity,  but that is not what  is going  on.  Given the window of
opportunity for Phase II, which will close in just a few years due to long-term planning,
large deals need to be made if they are to be made at all. CACM is not focused on EPA
developing an annual, short-term market.  From the seller's point of view, EPA's annual
forced sale of 2.8 percent of a  utility's paper one-year at a time with 100 percent cash up
front is a disaster.  Utilities do not want this product because it doesn't meet their need
for scarcity of supply. However, the auction is in the law, and will continue to be held.
Ms. Rico added that the irony is that Congress did not think the auction through because
there is no floor price set. There will always be a market for an allowance at close to zero
cost.
         What are examples of rate payers taking the risk and of shareholders taking the
         risk?

         Mr. Henry answered that in the Wisconsin Power and Light deal, the rate payers
paid for the clean up and got the proceeds from the sale. The shareholders of Ohio Edison
paid for the ALCOA allowances^  At Pacific Corp., the rate payer paid for the clean up,
and the proceeds will go back to the rate payer.
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Mr. Henry added that there is no evidence that CEOs are going to put shareholder money
at risk to create additional allowances for the sale.  Mr. Bartels commented that utilities
have not awakened to the fact they are all in the market, whether they have made a trade
or not.  They are also all at risk, rate payers and shareholders alike, whether they have
made a trade or not. There is no way to get a least cost compliance plan without at least
considering trading. Utilities are going to be asked about their allowance management
plan.  Before a utility can say that the technology solution is the most cost effective one,
it must examine allowance trading options.  If  they do not do it now, they may be held
accountable for that oversight later.

Mr. Henry added that  there is sometimes a difference between regulatory  theory and
regulatory reality, which can lead to higher  cost, rate based option being preferred to a
lower cost option that puts the shareholders  at risk.
  f} I
   * \
L""""i
         A Maryland emitter was interested in buying NOX allowances and selling CO2
         reductions, and wanted advice on doing so.
         Mr. VanSant remarked that NEES has NOX allowances to sell. However, the
political  obstacles  to trading allowances over such a distance would  be difficult to
overcome.   NESCAUM  is currently running a model trade program, which NEES is
participating in.  At the moment they are just going through the protocols of creating and
certifying NOX emission  reductions.  However, Maryland  is part of the Mid-Atlantic
Region Air Management Association (MARAMA), rather than NESCAUM.  In terms of
selling CO2, NEES  is a competitor.
         Is it true that there is no official system for CO2 now?

         Mr. VanSant stated that at the moment, greenhouse gases such as CO2 are not
         part of a trading system. Several European utilities have expressed interest in
buying greenhouse gas emission allowances.  First, market structures for creating and
certifying credits need to be developed.
         How can we get regulators to look at economic alternatives such as trading
         allowances fully?

         Mr. Hederman suggested that educating the regulators is the answer.  Working
with the appropriate committees can lead to progress. A lot of effort is going into putting
together guidebooks with model  regulations.   Lawrence Berkeley Labs  has put one
together on gas.  Mr. VanSant pointed out that since 1985, NEES has been pursuing gas-
electric  deals by which NEES would use  gas in the summer, the off-peak for gas use.
NEES has made a commitment to gas, and its gas needs are growing, but it could never
get a gas company to play ball.  As a result NEES has built its own excess capacity.  Order
636, which makes gas companies accountable for the capacity they pay for, will make fuel
switching deals possible.  When the gas companies are paying for pipeline  that they are
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Clean Air Marketplace 1993                                            Page 105
not using, and the state commissions hold them accountable, they will be forced to lay it
off to the highest valued market. Examples of this include New England Electric Utility,
Ocean State, and a gas company in Tennessee.

The  questioner noted that allowances that are traded from  one utility to another are
quickly taken off the market, and only those that are traded to third parties act as financial
instruments.  Mr. Bartels responded that the market is dominated by users, who view
allowances as operational assets rather than as trading vehicles.  However, third parties
can reduce the risk and cost incurred by the end user in the market. Although the market
is being designed for the utility market, the participation of the investment community will
be needed to defray risk and increase liquidity. The questioner clarified that the effect of
this type of trading would be two classes of allowances:  one set that was traded and one
set that was kept by utilities.  Mr. Bartels contended that utilities do not have a different
"class" of allowance, rather they are consuming the allowances that  they keep.  An
allowance is a commodity and also a future.
a
         What is the effect of advocacy groups further reducing the emissions allowances
         available by buying and retiring them?
         Mr. Bartels stated that there have been a few cases and several groups that are
interested.  However, the market has $1.8 billion in capital.  Even at today's low prices,
it would take all the money of all the environmental groups in the country to make a
noticeable dent in emissions.
         What are the chances of a CO2 market being included in a CAA amendment?

         Mr. Bartels answered that the Montreal  Protocol includes a  greenhouse gas
         market as an option. A bill to create such a market will be introduced in the
near future. Ms. Rico pointed out that there is discussion of'how the U.S. will meet its
obligation to stabilize greenhouse gas emissions at 1990 levels. The administration would
prefer to use  voluntary reduction programs.   A market implies that reductions are
mandatory. In light of uncertainty in many countries about reduction goals and the way
they will be reached, there is a reluctance  to discuss trading in the absence of knowing
what the goal  is.  There are concerns  about how  to measure reductions and monitor
international trades.   A greenhouse gas market is not  impossible, but there  are some
practical steps  to getting a program up and running in terms of the infrastructure required.
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                          Session 4 — Panel B
                          Stationary Source NOX Control Approaches
                          (Including Fuel Switching)
                          September 8, 1993
                           4:15 p.m. - 6:15 p.m.
                          Moderator:
                          Panelists:
Joseph A. Belanger
Vincent M. Albanese
Joel Bluestein
Mitchell B. Cohen
Dr. Michael J. Wax
Introduction

       Joseph A.  Belanger,  Director  of  Planning and Standards, Bureau  of Air
Management, Connecticut Department  of  Environmental Protection, noted  that NOX
control approaches are an important subject because air quality conditions are so bad that
NOX control beyond RACT (reasonably  attainable control technologies) will be needed.
Flexibility will be the key to a rational NOX control policy.
Presentations

           Vincent M. Albanese is Vice President for External Affairs at NALCO Fuel
           Tech, which has intellectual property rights to NOX control patents.  NALCO
           Fuel Tech's marketing structure is an international one, with offices in England
           and Germany; they have recently expanded to Taiwan and Korea. NALCO's
           strategy is to manage the technology of its licensees by establishing marketing
           partnerships or strategic alliance setups.

       Mr. Albanese focused on the specific control technique of selective non-catalytic
reduction (SNCR).  SNCR involves spraying urea into a specific temperature zone of the
flue gas in a boiler or other equipment.  The NOX components of flue gas are converted
to nitrogen and water in the resulting reaction.

       NOX reduction in a power generation boiler  is a low capital pollution control
device; operation and  management of the system comprise most of the expense.  This
technology can produce  a  40-70  percent reduction  of NOX,  although  the particular
reduction is dependent on site-specific factors.  The type of process, for instance, renders
the pollution reduction more or less effective; a range of 20-95 percent has been observed
over processes ranging from gas burners to solid waste incinerators.
                        Session 4B — Stationary Source NO  Control Approaches

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Page 108                                            Clean Air Marketplace 1993
       Capital costs for SNCR range from $5-$20 per kilowatt.  The Annualized Busbar
Cost is 0.5-2.5 mils per kilowatt-hour (one mil is 1/1000 of a dollar) or $0.05-$0.25 per
MMBtu.  This cost range includes many kinds of processes, including new processes as
well as retrofits.

       At a demonstration of SNCR at Wisconsin Electric Power Company (WEPCO), site
specific factors resulted in  effective use  of reagents.   At a cyclone unit, the cost of
containment was $1,000 per ton.  For WEPCO  and the cyclone unit, the capital cost was
$7-$10 per kW. Mr. Albanese is excited about these benefits, and their implications  for
how major sources of NOX may  comply with the regulations.

       Longer term use of  SNCR was demonstrated at LILCO (Long Island Lighting
Company).  The unit ran for  8 months, resulting in total use cost of $950 per ton.  This unit
was run under dispatch conditions, as opposed  to a constant  load.  At a commercial
installation at NEPCO (New England Power Company), three units currently have SNCR
as the stand-alone technology for NOX  reduction.

       Experience in delivering  SNCR technology in cost-effective ways is growing at a
frantic pace.  The rapid rate of technology growth often outpaces the ability of consultants
and regulators to publish information  guides.  Therefore,  it is difficult for someone not
directly involved with NOX pollution control to keep up  with the costs and technologies.

       When a NOX source  is faced with compliance measures,  it must determine what
combination of available technology is best to use. For RACT, for instance, SNCR can
stand-alone.   However, combustion management  used with SNCR  may be a more cost-
effective option. The NOX reduction attainable  by these technologies tends to be additive
when technologies are used  in combination.

       Several possible measures may be  used to attain NOX reductions as required by
regulations,  including gas reburn (GR), selective catalytic reduction (SCR), low NOX
burners (LNBs), and SNCR.  With SNCR the cost is "expense intensive" but not necessarily
expensive in terms of  dollars per ton of NOX  reduced.  Nearly 90%  of the cost  is
concentrated in operation. This combination is attractive in the ozone season, which lasts
from 6-7 months (roughly April through October) out of each year. The system can be
operated to  reduce NOX, and it can be turned off in seasons when ozone is less of a
consideration. This flexibility is an example of what we must strive for in making rational
NOX control policy.
Session 4B — Stationary Source NO  Control Approaches

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Clean Air Marketplace 1993	Page 109


          Joel Bluestein, Director, Gas-Based NOX Control Center, has been involved in
          researching fuel-type strategies.  He began his presentation by polling the
          audience to determine their affiliations.  There were three to five regulators,
          four to six equipment manufacturers, and about 15 consultants or lawyers, as
          well as  many  other  professionals.  Mr.  Bluestein  addressed NOX control
          requirements under Title I, rather than acid rain provisions. Low NOX burners
may not be  sufficient  to meet Title I requirements that may go beyond the reductions
required by  Title IV regulations.

      There are several approaches to using gas in existing coal and oil burners.  Co-
firing is the  simultaneous  firing of a small portion of natural gas with coal.  It has the
benefit of reducing emissions, and addresses both operating and environmental problems.
Seasonal gas-based NOX control is a cost-effective approach. Conversion to gas matches
the period of best gas  availability and  low gas prices  to the peak ozone season — when
NOX reduction is most needed. Emissions of SO2, CO2, particulates, and air toxics are also
reduced. On the low end, there is zero capital, but the incremental cost of natural gas is
a consideration.  The high end cost is $10-$20 per kilowatt for gas conversion.

      Gas reburn uses natural gas to  chemically reduce NOX emissions by injecting the
gas into the boiler above the primary combustion zone. The gas doesn't actually burn, as
there is not sufficient oxygen.  Instead, natural gas  chemically reduces the oxides of
nitrogen and gas, and the remaining  combustion gases are  burned out by excess air.
Reburn of 15-20 percent natural gas has reduced NOX by 50-70 percent in recent long term
testing of coal- or oil-fired burners. This reduces the primary fuel input; for example, coal
input can be reduced by 18 percent by injecting natural gas above the combustion zone.
Consequently, emissions caused by coal burning are also reduced. When overtired air is
applied  in conjunction with low NOX burners, an additional reduction is achieved. Gas
reburn  can  reduce NOX  in cases  where simple conversion may not  be  effective.
Additionally, it is less  economically sensitive to gas prices since it uses less gas.

      There are several gas reburn projects currently supported by the Gas Research
Institute, DOE, and EPA.  These projects encompass  the major boiler configurations
(cyclone, wall, and  tangential),  as well as gas technology combinations.  The costs of
projects at Ohio Edison, Illinois Power,  PS Colorado, Midwest Utilities, and Kansas Power
and Light have ranged from $30-$35 per kilowatt.  NOX control has ranged from 50-75
percent.  At Illinois Power's Hennepin facility, long-term gas  reburn data showed an
overall 67.3  percent reduction — lower than that required by  EPA and NESCAUM
regulations.  This reduction  was produced with tangential firing.  Full scale  data was
presented on NOX produced by coal designed utility boilers that had switched fuel or were
using gas firing to reduce NOX.  The numbers were very low, ranging from 0.05 pounds
of NOX per million Btu to 0.46 pounds per million Btu.

      Reburn is specifically applicable to coal, oil, and gas-fired units that cannot meet
RACT limits with combustion  modifications alone.   It is  suitable for meeting  more
                         Session 4B — Stationary Source NO  Control Approaches

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Page 110                            	Clean Air Marketplace 1993


restrictive requirements for existing sources.  Reburn is an option for the lowest achievable
emission rate  (LAER), a very strict  level that applies to  new sources  in ozone non-
attainrnent zones.

       Finally, Mr. Bluestein  presented a graph  discussing the cost and effect of NOX
control technologies.   While not trying to identify the best technology, he believes that
there will be a large range of technologies used for NOX control. The graph showed the
cost of control in dollars per ton versus the percentage of NOX reduced. All technologies
fell under the $2,500 per ton mark. In the 30-50 percent NOX reduction range, low NOX
burners are inexpensive. SNCR's are in the 50-70 percent range, and require more control.
The highest range of  NOX  reduction can be created by SCR, seasonal gas conversion,
advanced gas reburn,  SNCR plus gas reburn, and low NOX burners plus  gas reburn.

       The moderator noted that as a regulator, he likes to see technologies with high NOX
reduction which are in the under $1,000 per ton range.
           Mitchell B. Cohen, a Senior Consulting Engineer with Asea Brown  Boveri-
           Combustion Engineering Systems (ABB), gave a slide presentation overview
           of integrated NOX reduction techniques.  ABB's innovative techniques are
           achieving NOX emissions that  are below Japanese, German, and  U.S. NOX
           emission  regulations for new  coal  fired utility  units.   Japan's national
           regulations  require NOX emissions of around 250 ppmvd at 3 percent oxygen,
while German levels are about 120 ppmvd  and U.S. levels in some local areas just under
100 ppmvd.

       NOX reduction in boilers can be achieved with combustion improvements, flue gas
treatment at high gas temperatures with ammonia or urea (SNCR), and tail-end flue gas
treatment (SCR) at lower gas temperatures with ammonia and catalyst. In designing a unit
for NOX control, the engineer must analyze the fuel and the operating process  (e.g., base
load or cycling load). High reliability and optimization of post-combustion techniques is
the objective of each design.   Every unit design is site specific.

       SNCR and SCR can reduce combustion NOX for pulverized coal. ABB has analyzed
in-furnace and post-combustion NOX reduction methods.  Tangential firing produces lower
NOX levels than wall firing, and the emission levels of both have decreased steadily over
the past 30 years. The  lowest in-furnace NOX system integrates the furnace  design with
the tangential firing sys'tem and pulverizer equipment to guarantee less than or equal to
0.1 pounds of NOX per million Btu, or the equivalent of a  volume of NOX of about 73 ppm.
The most cost effective way to reduce NOX is by  maximizing in-furnace control.
Session 4B — Stationary Source NO  Control Approaches

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Clean Air Marketplace 1993                                            Page 111
       Mr. Cohen discussed optimized selective catalytic reduction systems. As Federal,
state and  local  regulations require increasingly  lower NOX emissions, low NOX firing
systems can minimize reductions necessary from SCR systems. An optimized SCR system
has many benefits, including lower initial capital costs, minimized catalyst replacement and
disposal costs, lower system pressure drop, lower auxiliary power, and lower ammonia
consumption. ABB uses the Tangential Firing System 2000 (TFS2000) in combination with
its Environment 2000 (E2000)  unit.  E2000 is an  integrated NOX control system with an
optimized steam generator design for highest efficiency.  The unit has two levels of
overtired air and a vertical downflow SCR chamber, controlling NOX emissions levels to
under  100 ppm.  In-furnace NOX control involves local and global air staging.  In the
TFS2000 furnace, which is used in the E2000  unit, oxygen is managed throughout the
combustion process to minirnize emissions of CO, and VOCs. This new tangential firing
system  effectively  uses vertical  and horizontal staging to lower NOX emissions.   It
produces complete mixing, has high combustion efficiency, and protects furnace walls from
corrosion.

       The main difference between SNCR and SCR is in operating temperature.  SNCRs
run at higher temperatures, 1600°F-2000°F, while SCRs operate between 575°F-750°F. SCR
systems are  reliable for several reasons:  their  operation is simple and  they have no
moving components, minimal  maintenance, and a long catalyst life.  SCRs utilize either a
ceramic-based or plate type catalyst on which the reaction with ammonia takes place.

       SCR costs have been declining.

       •     In 1985,  the capital cost for a new  coal  fired utility unit  was $100 per
             kilowatt.

       •     By 1993, this cost has been reduced to about $30 per  kilowatt.

       •     Capital costs for firing systems have  held relatively steady at less than $20
             per kilowatt, and by  1993 have fallen as low as $10 per kilowatt.

NOX control technology will become more viable as experience is gained in retrofitting and
operating  these systerfis.  Some cost ranges  for  LNCFSs  (low NOX concentric firing
systems) are  $10-$15 per  kilowatt for an in-furnace  combustion system, and $30 per
kilowatt for a combined system (TFS2000 + SCR).

       ABB helps promote the effectiveness of NOX control techniques by providing local
and state regulatory and environmental groups with information on air pollution control.
                         Session 4B — Stationary Source NO  Control Approaches

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Page 112	Clean Air Marketplace 1993


           Dr.  Michael J.  Wax,  Deputy  Director,  Institute of Clean  Air Companies
           (ICAC), made several "macro remarks," in light of all the technical information
           that had been presented by the other speakers.  ICAC members sell all types
           of control technologies.  ICAC takes  the position of favoring performance-
           based rules over command and control rules. Regulators should set rules that
           specify emission limits, but are technology neutral.  Competition should be
allowed to minimize the costs of compliance with maximum control over technologies.
Each NOX producing source is different; it would be impossible to specify one type of
control. In other words the marketplace should decide what NOX control technology to
use.

       ICAC research has come across a problem  that is not limited to NOX control. The
problem is that important information is missing from the marketplace. At least two NOX
control technologies, SCR and SNCR, are misunderstood. Their capabilities are still viewed
as more experimental than they actually are.  The extensive use of these technologies
overseas and in the U.S. has not been acknowledged; SNCR and SCR are still seen as risky.
The costs of SCR and SNCR are also misunderstood. It is assumed that  costs are higher
than they actually are, but air pollution control equipment costs actually  drop over time.
The numbers typically associated with SCR, such as $150 per kilowatt, are too high.  ICAC
estimates lower SCR costs:

             Coal-fired units: $30-$70 per kilowatt

       •      Oil- and gas-fired units: $15-$30 per kilowatt

       •      SNCR costs for utility boilers similiarly are lower than commonly believed,
             and are $8-20 per kilowatt.

These latter numbers are the ones that should be  used in setting regulations and setting
facility compliance.  In the initial evaluation, costs for new NOX control technologies are
higher than they will be after implementation.  Several factors have decreased costs for
NOX control technologies: increased experience, technical advances, and more competition.

       Another beneficial aspect of competition is  that it makes people smarter.  If several
suppliers are bidding on a NOX control job, prices  will be forced down. Competitors will
see each others' innovat]ive designs and work harder to produce equipment that satisfies
the buyers' needs and requirements.

       In closing, ICAC would like to see as much accurate information as possible in the
marketplace. More information helps both the public and utility groups.
Session 4B — Stationary Source NOX Control Approaches

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Clean Air Marketplace 1993                                            Page 113
          Vince Albanese noted that a lot of comments were made regarding capital
          costs.  This is an incomplete picture, because the issue of cost is a complex one.
          He presented a graph showing the costs, in dollars per ton NOX reduced  for
          various technologies, that was produced by a NESCAUM contractor working
          on an EPA report.  The graph shows that the costs for six technologies overlap
          at RACT-type costs, including low NOX burners plus  overtired air, SNCR
uncontrolled, SNCR controlled, reburn on cyclic and wet bottom boilers, overfired air, and
low NOX burners.

       Dollars/ ton NOX reduction costs tend to overlap when one considers the broad
data available. The ACT document has  shown the sensitivity of site-specific variables as
they affect costs.  Ninety percent  of the costs are wrapped up in capital; this has  been
realized because retrofit units must be set up.  The costs ranges are wide, and sensitivities
are being probed. There are very rough guides available to make economic conclusions.
Therefore, flexibility and market incentives must be encouraged.
Questions and Answers
         Can you clarify  what is meant by "level playing field" standard  based on
         output?

         Mr. Belanger suggest  that in the  long term,  we should  be  talking about a
standard based on emissions per utility output.  In other words, the standard should be
based on the change in NOX emissions per kilowatt-hour.  This would treat NOX as a paid-
for resource; companies would,  in effect, be buying each unit.  The Connecticut EPA is
researching the possibility  of developing this concept.
         What are the 'regulatory barriers to implementing NOX control technologies?
  *>
   •   I  Mr. Albanese explained that there are regulatory barriers to implementing the
"•"•J  NOX reductions, but these barriers are diminishing.   At  the time literature
research  was initiated by EPA and others to  investigate RACT and  other measures,
technologies  other  than burners and combustion  modifications  had not  yet  been
commercially used.   Recently,  field  demonstrations and  commercial  use of other
technologies have been rapidly accepted, so the issue of RACT technology is not so clear
cut anymore.

Mr. Albanese added that there is a  perception that technologies beyond  combustion
modification have high cost. Because RACT is a retrofit requirement, many site specific
factors govern cost, and cost therefore ranges widely.  Regulators are now allowing that
other technologies can be utilized to comply with RACT.
                         Session 4B — Stationary Source NO Control Approaches

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Page 114                                            Clean Air Marketplace 1993
Mr. Belanger commented that the question of seasonal regulation needs to be examined.

Mr. Bluestein added that ozone is a seasonal problem.  Looking at production of ozone
and requiring control and  reductions seasonally  is a major change  in philosophy for
regulators.

Mr. Bluestein indicated that fuel switching has not been looked at as a control technology.
A level playing field refers to whether emission levels are based on fuel. The field is level
when limits are set in  a fuel neutral way.  What works best, and is most cost effective, is
site specific. In the context of ozone rules starting at'a baseline, total emissions must be
reduced. There is the question of fuel switching being satisfactory if it is the cheaper
solution. Fuel  based1  rules  provide  a  dis-incentive to NOX control.  Using cleaner fuel
should be encouraged  by the regulating community.  In the serious and severe ozone non-
attainment  zones, substantial NOX emissions reductions will be required. Companies will
need  flexibility to reduce NOX emissions, including fuel approaches.  In the  spirit of
flexibility, cost effective solutions should be promoted.
         To what extent would a fuel-neutral policy push companies away from more
         expensive technologies?

         Dr. Wax responded that  a fuel-neutral  policy would not  necessarily  push
companies away from'what are seen as more expensive technologies.  The company's
selection of a technology would depend on the regulation, price of the control technologies,
and might be a mixture of controls and clean fuels.

Mr. Cohen explained that it makes sense to put in SCR in some cases, because some units
do not have adequate furnace  space to accommodate low NOX burner technology.  A
generalization cannot be made on this issue.  Mr. Bluestein added that a fuel-neutral policy
might encourage gas burning, but only marginally.
      L
  f} I
   *  I
^^•""
         With respect to anticipation of change, is each process optimized to anticipate
         a change in NOX regulatory levels?
         Mr. Cohen acknowledged that uncertainty in regulations has been a problem.
 SCR technology can accommodate additional reductions.  Low NOX burners can be fine-
 tuned to a certain point.

 Mr. AJbanese explained that with regard to regulatory uncertainty, the source must be
 aware of the margin of reductions required. When the reagent-based technology is  not
 pushed to the maximum reduction level, or when a combination of technologies is used,
 there is the potential to generate air emission credits.
 Session 46 — Stationary Source NO  Control Approaches

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Clean Air Marketplace 1993                                            Page 115
a
        If gas burning provides additional pollution control and has seasonal benefits,
        why should a regulator be willing to undertake the seasonal approach?
         Mr. Bluestein responded that NOX reduction primarily for ozone non-attainment
is very expensive. In'order to make air healthy, it is worth the extra money in the summer
time when air quality is poor.  In winter, when the emissions are not hurting us, why
should companies spend the money? Additionally, if other pollutants can be reduced, that
should be taken into account.
        At $500-$2,000 per ton, is NOX control perceived as expensive?

        A panelist responded that if the costs for NOX controls seem high, they are
        reasonable in respect to cost-effectiveness.  A National Academy of Sciences
study found that NOX controls work 3-10 times as well as VOC controls, which range from
$10,000-$20,000 per ton. Costs for NOX control are lower, and control is much more cost
effective, by a 30:1 ratio. Car emissions reductions have increased from 96-98 percent.
Previously, power plants were reducing 0 percent of their emissions; now they can reduce
75 percent of these emissions.

        To what  extent will snfall businesses be adversely affected if EPA does  not
        accept fuel switching as an alternative NOX control?
         Mr. Belanger explained that fuel switching must be viewed with respect to its
limitations.   As opposed to switching  from coal to  gas, the reductions attained by
switching from oil to gas might not meet necessary standards.

Mr. Bluestein added that NOX RACT guidance requires the total savings during a period
to be equivalent to the year round savings. For smaller boilers, it may be possible to get
EPA to sign off on credits.  EPA will accept documentation of savings.
       L
  f%  I
   *   I
"™^""
         Will small boilers would be expected to match the savings and reductions
         achieved by large boilers?
         Dr. Wax indicated that unit control costs will become higher for small boilers,
and the rules will acknowledge this limitation.  However, costs are not so prohibitive as
to disallow fuel switching.

       L The technologies discussed today  address  many programs.  Are  there any
  ^}  I technologies that address the solid  waste issue (e.g., the ash produced by coal
   *   I fif^d boilers)?

Mr. Belanger responded that these NOX reduction technologies should not change the
marketability of soda ash.
                         Session 4B — Stationary Source NOX Control Approaches

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Page 116	Clean Air Marketplace 1993


Mr. Cohen pointed out that there are disadvantages to some NOX controls, namely that
ammonia emissions are higher and there is potentially higher levels of carbon in the fly
ash.  These considerations  go hand-in-hand in examining  a specific site.  For example,
greater fineness may be required. Each situation must be evaluated.

Dr. Wax commented  that increased solid waste problems have not been a problem in
Germany. None of the fly ash created by NOX controlled units is landfilled there, and
ammonia slip has been kept low, at levels of 2 ppm and less.
Session 4B — Stationary Source NO Control Approaches

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Clean Air Marketplace 1993
                                Page 117
                          Session 4 — Panel C
                          Vehicular Emissions Control Services
                          September 8, 1993
                           4:15 p.m. - 6:15 p.m.
                          Moderator:
                          Panelists:
Ken Thomas
William Dell
Gary Muggins
Jay Gordon
Dan Grubbe
Introduction

       Ken Thomas, Horiba Instruments, is a leading manufacturer of equipment for the
Federal Test Procedure, and one of the designers of the IM240 test.  Despite perceptions
to the contrary, the  IM240 is a simple, quick, viable test of whether a car meets Federal
Test Procedure regulations. It is different from other inspection and maintenance tests in
that vehicles are driven on a dynamometer, which simulates real driving patterns.  The test
measures hydrocarbons, CO, and NOX as a vehicle is operated at many different speeds.
This is important because vehicle acceleration and deceleration can be significant sources
of pollution in malfunctioning vehicles.  The IM240 captures the total exhaust stream,
which also distinguishes it from other tests.

       The purge test, which is part of the IM240 test, is conducted while the vehicle is on
the dynamometer. This test investigates whether the charcoal canister, which is designed
to  prevent evaporative emissions from  the  gas  tank,  is  functioning  properly and
recirculating the fuel vapors.  The pressure test, also a part of the IM240 test, ensures that
a fuel system is working correctly and recirculating vapors in the  system.
Presentations
          William Dell, Director of Marketing for Systems Control Corporation, focused
          his presentation on two basic issues: the responsibilities of inspection and
          maintenance (I/M) firms, and how I/M firms cooperate with the government
          to create better vehicle inspection programs.
          State agencies  typically contract an I/M firm to be the single point  of
responsibility for the design, development, and operation of a vehicle inspection program
                               Session 4C — Vehicular Emissions Control Services

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Page 118                           	Clean Air Marketplace 1993


to meet the requirements of the CAAA.  I/M contracts are usually very complex, often
including items such as:

       •     Financing for the inspection program

       •     Siting and acquisition of land and buildings for use in the program

       •     Sacility design

       •     Testing equipment and procedures

       •     Staffing of facilities

       •     Public relations and advertising

       •     Technician training

       •     Initial operation of the program

       •     Quality assurance

       Mr. Dell presented slides of facilities currently performing under I/M contracts.
For example, there is a multiple lane, high impact program in Texas, which has developed
a fully automated assembly line testing procedure.

       How an I/M firm goes about Implementing these contracts throughout a state is
an important issue. The primary importance of cooperation between state governments
and the industry in getting these programs operational cannot be too lightly stressed.  In
the legislative phase,  I/M  contractors  generally help  governments  design  programs
through a number of different methods, the most visible of which is direct lobbying.  Firms
also work with various agencies, helping to  develop definitions and program designs. This
education process is accomplished through  testimony at hearings, working with legislative
staffs, as well as advising individual legislators.

       In the regulatory phase, I/M contractors lend their technical expertise to help state
agencies gather information and design specific portions of the tests.  Firms also work with
the press, helping the public understand the program.

       If handled  properly,  cooperation between the  state and  contractors  helps
tremendously in designing an effective program, and does not give the firms involved
unfair advantage.  However, there is a fine line between positive cooperation and conflict
of interest.
 Session 4C — Vehicular Emissions Control Services

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Clean Air Marketplace 1993                                           Page 119
       Cooperation between governments and the I/M industry is also crucial in the
Request For Proposal (RFP) development phase. The states with the best RFPs are those
that worked with contractors to incorporate their technical expertise and  other advice.
Firms, for instance, can lend information and field research capabilities in order to solve
potential problems before a RFP is even released.

       Consensus building is critical to developing a sound inspection program. The state
of Virginia, for example, has developed ad-hoc committees of individuals and groups
affected by  I/M requirements to deal with the development of rules  and RFPs.  The
Coalition for Safer, Cleaner Vehicles has also been reaching out to different parties in order
to build consensus.
           Gary Hugging is the  Executive Vice President of the Coalition for Safer,
           Cleaner Vehicles  (CSCV), a national non-profit consumer environmental and
           industry organization  committed  to  assisting  states  in  adopting effective
           vehicle emissions and safety inspection programs. The coalition also provides
           public education  on the benefits of vehicle inspection programs.

       Mr. Huggins began by focusing  on the Maintenance  or the "M" side of I&M
programs.   New enhanced  vehicle inspections,  required  by the 1990 Clean Air Act
Amendments, will be much more effective than past requirements and are expected to fail
between 15-25 million vehicles in the first testing cycle (two years).  It is vital that we now
focus on effective automobile technician training programs to assure that vehicles that fail
enhanced inspections can be  effectively repaired.  Not one ounce of pollution is removed
by inspection alone.  The key to the success of I&M programs will be effective vehicle
repairs.

       This need led CSCV to create the Education/Training Advisory Board (ETAB) for
the purpose of  developing guidelines for effective technician training programs and  to
assist states in  addressing important issues  related  to  improved vehicle maintenance.
Additionally, CSCV created the National Education Resource Center (NERC) to draw on
the expertise of companies involved with technician training and automotive repair to help
states and industry develop  solutions to  problems involved with the implementation of
effective I&M programs.  To  address the  need to focus more organizations and states on
the "M" side of I&M, EPA along with CSCV and other interested organizations also began
the Vehicle Maintenance Initiative.

       To  begin  building a regional infrastructure of qualified  trainers,  CSCV,  in
cooperation with EPA and the Coordinating Committee for Automotive Repair (CCAR),
                               Session 4C — Vehicular Emissions Control Services

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Page 120	Clean Air Marketplace 1993


is initiating a National Train-The-Trainer Program. The goal of the program is to prepare
sufficient numbers  of people in I&M  areas to train  automotive technicians for  the
implementation of enhanced I&M and to begin grassroots efforts to build support for the
program.

       CSCV also serves on several state I&M advisory committees and is encouraging
states that have not formed them to do so. The Coalition believes these local efforts will
be vital in the implementation of effective programs and in building public support.
           Dan Grubbe is Manager of Arizona's Vehicle Inspection Program, one of the
           most extensive vehicle inspection programs in the U.S.  He provided a brief
           overview of his program and its  testing procedures.   Loaded tests are
           performed on 1981 and post-1981 vehicles as well as all diesel vehicles, and
           idle tests are performed on older vehicles. The program includes tests on
           operational air injection, the catalytic converter, the fuel inlet restrictor, and the
presence of a gas cap.

       Handling 1.7 million vehicles annually, the Arizona  program is considered mid-
sized, and has a single I/M contractor. The program has a 14 percent failure rate.

       The Arizona plan has reaped considerable rewards: attainment has been reached
in the  Tucson area and the frequency of nonattainment  in Phoenix has declined.  To
maintain these types of results, especially with a state Vehicle Miles Traveled (VMT)
growth of over 3 percent, the state is considering enhancing the program.

       The high degree of public approval and confidence in inspection  programs must
be maintained. Therefore, when selecting an I/M contractor, it is crucial to consider the
need to  maximize the convenience to the customer  and to  minimize  the costs.  For
example, sites must have adequate facilities and efforts must be made to reduce waiting
times at emissions testing sites. More importantly, programs must improve their ability
to accurately diagnose and repair vehicles the first time.  The inability to do this could
prove to be a major factor in the erosion of public confidence in inspection programs. The
ability to diagnose and correct malfunctions can be improved through better education and
training of mechanics, and  by providing  them with diagnostic trouble-shooting guides.
Diagnostic aids and better vocational/technical  schools can provide  information on
common problems and how to remedy them.

       Before turning to the questions and answers section of the panel, Gary Huggins
stressed that vehicle emissions control efforts will continue to be one of the most important
Session 4C — Vehicular Emissions Control Services

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Clean Air Marketplace 1993                                            Page 121
components in the effort to improve air quality. Vehicle emissions control efforts are much
more cost effective than other options, and, according to a survey, 70 percent of the public
supports inspection efforts as opposed to other methods. The panelists assembled at the
conference represent both ends of the vehicle inspection effort: those developing the tests
and  inspection programs, and those actually  implementing the tests and inspection
programs and ensuring that the mechanics are able to repair the cars effectively.
Questions and Answers

        How long does the IM240 inspection test take to complete?
         Mr. Thomas responded that the test is called IM240 because it takes 240 seconds
         to complete.  It uses simulated road conditions, including inclines and declines.
EPA is considering a "fast pass" system in which a car could be designated  as "super
clean" within the first 45 seconds or so of the test.

         What percentage of the 14 percent that fail in the Arizona program get waivers?

         Mr. Grubbe responded that the current waiver rate is 1.09 percent of the total
         population. There are three waiver limits: vehicles of model year 1974 or earlier
have a $50 limit, vehicles of model years 1975-1980 have a $200 limit, and vehicles of
model year 1981 or later have a $300 limit.
         What is the difference between the pressure test and the purge test?

         Mr. Dell responded that the pressure test associated with the IM240 makes sure
         that the system is not leaking, and the purge test makes sure that the stored
vapors get burned in the engine.
         How do IIM contractors finance these programs?

         Mr. Dell explained that a lease-back arrangement for land and buildings is a
         common  financing tool;  the  equipment  assets are usually funded  by the
companies.  There  are also less obvious financing methods, such as the  involvement of
bonding agencies.
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         What opportunities does the IIM industry see in leveraging new areas of work
         into IIM contracts?

         Mr. Dell responded that as an industry, I/M contractors are trying to incorporate
as much as they can into  the contracts, as this would maximize  the convenience to
customers. However, it is difficult to expand the scope of the contracts in a number of
areas.  For instance, safety inspections are a stronghold of the automotive repair industry
and many lawmakers and regulators are reluctant to become involved. There are also
opportunities to include other aspects of the process, including vehicle registrations and
recalls.
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                                Page 123
                          Session 4 — Panel D
                          Alternative Fuels
                          Septembers, 1993
                           4:15 p.m. - 6:15 p.m.
                          Moderator:
                          Panelists:
Charles L. Gray, Jr.
William Holmberg
Jerrold L. Levine
Raymond Lewis
Carl Moyer
Dr. Jeffery Seisler
Introduction
       Charles L. Gray, Jr., Director of Regulatory Programs and Technology for the Office
of Mobile Sources, U.S. EPA, introduced the topic of alternative fuels by suggesting that
the automotive fuels industry is experiencing the greatest rate of change since its original
creation and growth. This change has been caused by a shift in the focus of the Clean Air
Act, from exclusively trying to  change vehicle technology to reduce emissions,  to a
combined strategy of dealing with both the vehicle and the fuel. The change has also been
driven by the weak U.S. economy and U.S. dependence on  foreign oil.  There are high
expectations for dealing with economic problems in the U.S.  and unless the imported oil
problem is addressed, there is little hope  of the economy improving.  Clean  fuels are
alternatives to imported petroleum, not to each other.

       There are a variety of alternative fuels programs  already  in place  or being
established, including 41 established oxygenated fuels programs in carbon monoxide (CO)
nonattainment areas; the introduction of reformulated gasoline in many of the U.S.'s ozone
nonattainment areas in 1995; expanded fleet programs focusing on alternative fuels; and
the Presidential Task Force to set goals for converting the Federal fleet.  The Federal fleet
is expected to be a model for state and local government fleet programs. It will combine
the provisions of the Energy Policy Act with the fleet provisions of the  Clean Air Act to
clean the air and stimulate the market for alternative fuels.  The alternative fuels industry
has a bold, exciting future beyond what has already been achieved.
                                                   Session 4D — Alternative Fuels

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Presentations

           William Holmberg, Regulatory and Policy Advisor for the National SoyDiesel
           Development Board (NSDB), discussed the potential of Biodiesel fuel to be a
           part of the transition  to a sustainable society, and particularly the role  of
           farmers in the NSDB in bringing about that change.

           There are pros and cons to Biodiesel.  The advantage of Biodiesel include the
fact that it is:

       •      Renewable, with a very positive energy balance; effective in stabilizing
             greenhouse gas emissions;

       •      Chemically similar to diesel but biodegradable and nontoxic;

       •      Essentially free of sulfur and aromatics;

       •      Helpful) in reducing CO, hydrocarbons, particulate matter, visible smoke
             and, with some  fine-tuning, nitrogen oxides (NOX) emissions;

       •      A  team player with petro-diesel and requires no  significant engine
             modifications or infrastructure changes.

       The chief disadvantage of biodiesel is  its  cost.  Other disadvantages include
biodiesel's tendency in some situations to damage elastomers and concrete, although much
of this damage can be avoided by using proper materials.

       The main distinction between a renewable fuel and a fossil fuel is that  naturally
occurring fossil fuels can be produced at minimal cost to the producer, while  Biodiesel
requires that farmers be paid for the feedstocks they grow. However, when environmental
benefits and societal benefits, including nation-building, are taken into account, the cost
of Biodiesel balances  out and  provides the opportunity to move towards a sustainable
society. To achieve this balance, Biodiesel must receive the same financial incentives as
other alternative fuels.

       Biodiesel also differs from fossil fuels in that the board of directors of the NSDB is
comprised  of farmers, not corporate executives.  The work and goals of the board reflect
the members' background  and strong commitment to  sustainable agriculture.   The
priorities of the  NSDB,  as  described by  NSDB President  Gary Ellington, reflect that
dedication. These priorities:

       •      Look ahead to an increase in farm profitability by generating new markets
             for surplus agricultural products;
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993
Page 125
       •      Look to the left to ensure that all aspects of the Biodiesel industry meet the
             needs of the environmental and public interest communities; and

       •      Look to the right to make sure that they are a part of the nation-building
             process of energy security and job creation.

       The discussion moved on to compare the modern evolution of fuel ethanol and
Biodiesel and exploring the potential of biofuels, Biodiesel in particular.  The purpose of
initiating the renewable fuels industry was to find new markets for agricultural products,
which are in great surplus.  The following chart delineates several  key  points in the
comparison.
EVENT
Start up
Requirements to reduce
emissions
Octane rating/cetane index
Oxygen content
Energy security
Basic industry and job
creation
Greenhouse gas
stabilization
Increased emissions
Exploration of alternative
uses of the fuel
Cooperative relationship
with government and
environmentalists
Integrated approach from
soil biology to tailpipe
FUEL ETHANOL INDUSTRY
1975
CO and unburned hydrocarbons
High Octane
113(R+M)/2
35 percent weight
Fair to high with cellulosics as
feedstocks
Already significant with great
potential
Fair, with energy balance of 1:1.3
Evaporative emissions and NOX
Focus on 1 0 percent ethanol
blends
Limited efforts to develop
cooperative relationships
Limited interest
BIODIESEL INDUSTRY
1992
CO, unburned hydrocarbons,
particulate matter
High Cetane
49 and higher for saturated oils/fats
as feedstocks
Neat form, about 1 1 percent weight
Low with conventional feedstocks,
but fair to high with microalgae as
feedstocks
Just starting, with great potential
Outstanding, with energy balance of
1:4
NOX can be controlled with timing
retardation, additives, engine
modification
Extensive efforts to determine best
blends, best engine/fuel
relationships, best relationships with
other fuels
Extensive efforts to build
cooperative relationships
Extensive interest in cooperative
exploration
                                                   Session 4D — Alternative Fuels

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       The accomplishments of the NSDB reflect the growth of the  Biodiesel industry:

       •      Over $5 million in investment by farmers in  the past  13 months.

       •      Registration of Biodiesel variations with EPA, and attempts to determine
             "substantially similar" diesel blends not exceeding 2.7 weight  percent
             oxygen.

       •      Working in cooperation with engine manufacturers  to  gain support  for
             Biodiesel blends.

             Joint effort with ASTM and NCWM to establish standards.

       •      Supervision of contracts with the Southwest Research Institute, the National
             Institute for Petroleum and Energy Research, and ORTECH  of Canada to
             conduct engine emissions research and testing, as required by EPA.

       •      Wide range of demonstrations involving blends of Biodiesel with different
             fuels (petro-diesel, natural  gas,  compressed natural gas  (CNG)/liquid
             natural gas (LNG), methanol and ethanol)  and applications in marine,
             underground, and  railroad  industries,  fleet operations, and  individual
             vehicle and equipment tests.

       •      Working in cooperation with the National Renewable Energy Laboratory to
             assemble and catalogue all demonstration and test data.

       •      Working in  cooperation with the Departments  of  Agriculture,  Energy
             (DOE), Transportation, and Defense in developing additional data needed
             to  meet  EPA requirements, DOE   requirements  for  alternative fuel
             classification, and engine manufacturer and end-user  requirements.

       One of the goals of the NSDB is inclusiveness — working together cooperatively
with all interested parties. Therefore, in addition to promoting the interests of Biodiesel,
the Biodiesel industry would like to team up with the CNG/LNG, ethanol and methanol
industries,  so that the fuels meet the DOE classification of an alternative fuel when used
together.  By the end of October 1993, Biodiesel will be used in more heavy-duty engines
than all other alternative  fuels combined.
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993                                             Page 127
           Jerrold L. Levine, Director for Corporate Studies at Amoco Oil Corporation,
           discussed the alternative transportation fuels industry, CNG in particular, and
           Amoco's role in the CNG industry. While legislation will mandate the supply
           of an increasing level of alternative fuels, no particular fuel is identified in
           either the Clean Air Act or the Energy Policy Act. While market dynamics are
           expected to determine the alternative fuel of choice, under the Energy Policy
Act, CNG is likely to prevail as the clean fuel of choice.  By entering the CNG industry,
Amoco has the opportunity to position itself as a leader in the clean transportation fuels
industry.

       Alternative fuels represent a new retail market opportunity. The combination of
all  fleet requirements covered  by the Clean  Air  Act, the Energy Policy Act, and  the
President's order for a 50 percent Federal fleet  expansion, are expected to drive  the
alternative fuels market.  By 2010, alternative fuels could  replace somewhere between
550,000 and 1.1 million barrels per day of equivalent demand for gasoline, or 8-15 percent
of the demand for gasoline.  The lower estimate assumes that alternative fuels will satisfy
the basic requirements of existing Federal and state legislation. The high estimate assumes
significant participation by other states and the conversion of existing vehicles.

       In  comparison to methanol, ethanol, and propane, natural gas generally has lower
CO, volatile organic compounds (VOCs), and NOX emission levels  than do reformulated
gasolines.   The  operating characteristics of natural gas  (e.g.,  cold weather starts,
convenience  of refueling, and "driveability") generally are superior to those  of other
alternative fuels, except for convenience of refueling. In terms of maintenance, natural gas
and propane vehicles require  fewer oil changes and engine tune-ups and have longer
engine life.  Converted  light-duty  vehicles tend to suffer from poor acceleration and
limited range, problems generally not encountered  in larger vehicles such as pickups and
vans.    Dedicated  CNG  vehicles  will be  redesigned with engine  control  systems,
compression  ratios, and port fuel injection in order to overcome  these problems.

       LNG has the same operating characteristics as CNG, but vehicles can carry much
more  fuel and have an extended driving range.  The disadvantage of LNG is that it  has
a very low temperature and requires special handling. As a result, it is not being seriously
considered for cars  and light trucks, but is being reviewed for use in larger medium- and
heavy-duty trucks,  tractors, and  railroads.

       There are several reasons why CNG is likely to be the clean fuel of choice:

       •      CNG has a distribution system in place.  Development of a dedicated
             infrastructure for  methanol, the next most likely alternative  fuel, is  not
             likely, especially under the accelerated timetables for use of alternative fuels
             prescribed by the  Energy Policy Act.
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       •      CNG is clean burning. Emissions are 85 percent lower than gasoline, and
             generally lower than other alternative fuels.

       •      CNG is safe.  It is neither toxic nor corrosive.

       •      Natural gas is domestically abundant.  A 50-year conventional supply is
             available, with hundreds of years of unconventional supply available.

       •      CNG is inexpensive.  It is typically priced 2CMO percent below gasoline.
             All other  alternatives are more expensive than gasoline.

       •      CNG reduces engine maintenance expense.

       •      CNG performs. It has an octane reading of over 130 and yields essentially
             the same  fuel efficiency (mpg) as gasoline.

       •      CNG can be sold via public or private fueling.

       The challenge facing industry is to respond to the need for fueling facilities while
having enough CNG vehicles to justify the investment. There are several reasons why the
market for public CNG  fueling stations is expected to  grow:

       •      High initial investment necessary for gasoline fueling facilities (typically
             $200,000 to $300,000 for existing sites) and a strong desire to get away from
             underground storage tanks may lead many fleet managers to remove their
             on-site fueling stations and utilize public fueling.

       •      Many fleet managers indicate that they want to initiate a pilot program for
             their vehicles to get comfortable with CNG before committing to a full-scale
             program. A public fueling site could be used for this purpose.

       •      Public fueling development will encourage  manufacturers to produce more
             dedicated CNG vehicles.

       •      The size and availability  of a public fueling program will help establish
             CNG as the alternative fuel of choice.

       The keys to success of CNG public fueling systems can be likened to the three legs
of a stool, all of which must be  in place  and work effectively for the system  to succeed:

             A proactive local distribution company (LDC).  Generally this would be
             the  local  utility.   A  proactive LDC has  an aggressive fleet marketing
             program  consisting of fleet  customer prospect lists,  solicitation  of  fleet
             customers, and incentives or rebates against the cost of vehicle conversion.
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Clean Air Marketplace 1993                                            Page 129
       •      A retail fuels marketer.  Successful retail fuels marketers are willing to
             form alliances and commit resources.  They bring to the table existing
             service station sites and a knowledge of transportation fuels marketing.

       •      Local  conversion  and technology centers.  This allows fleet owners to
             convert vehicles locally and have confidence that there is local technical
             support to maintain the vehicle. This is necessary until auto manufacturers
             begin manufacturing sufficient numbers of dedicated CNG vehicles.

       Fueling stations should be convenient for customers:

       •      User-friendliness.  A CNG dispenser should be similar to a liquid fuels
             dispenser, both in appearance and in operation.

       •      Fast-fill dispensing. Dispensing of CNG into the vehicle's storage cylinder
             should take about the same amount of time as liquid fuels dispensing at the
             station.

       •      Priced and dispensed in familiar terms. CNG should be priced in cents
             per  equivalent gallon and dispensed  in equivalent gallons,  allowing the
             purchaser to easily compare fuel cost savings to gasoline.

       •      Easy payment. The station cashier should be able to take various forms of
             payment — cash, major credit cards, and government fleet cards — with no
             need to pre-arrange vehicle fuel purchases.

       Amoco began marketing CNG two years ago, with three CNG fueling stations in
operation by the  end  of  1991: public stations in Denver and  Boulder, CO,  and a
demonstration station in Washington, D.C. The Colorado stations were the first public
CNG fueling stations in the U.S.  opened by a major oil company.  In the past two years,
Amoco has equipped a total of 17 stations with CNG, more than any other major retailer.
Although volume  for these stations continues to be  low and the stations tend not to be
economically profitable, Amoco expects to add about 15 more stations this year in markets
where local distribution companies and governments are receptive.

       Amoco would enter the CNG fuels market for three reasons:

       •      Amoco has been a leader for many years in producing quality fuels for the
             transportation industry.   CNG  public  fueling initiatives are  viewed as
             providing an additional product to the existing transportation fuels product
             slate.

       •      Marketing CNG strengthens Amoco's strong corporate  commitment to
             environmental leadership.  Amoco  believes that it has the opportunity to
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Page 130                                            Clean Air Marketplace 1993


             position  itself  as  a leader in the  growing  market of alternatives to
             petroleum-based fuels.

       •      As a customer-focused company, Amoco is dedicated to meeting its fleet
             customers' needs as they comply with mandates of the Clean Air Act and
             the Energy Policy Act.
           Raymond Lewis, President of the American Methanol Institute, believes that
           people must realize that alternative fuels are real, current, and economic. In
           examining what alternative  fuels and clean  air can  do for jobs  and the
           economy, he explored how alternative fuels can form a healthy competition
           that generates clean fuel technology and economic development.

       Methanol, by current definitions  of clean fuels including reformulated gasoline,
represents  the largest alternative fuel. Methyl tertiary butyl ether (MTBE), a methanol
derivative, is the fastest growing chemical in the world and uses around 40 percent of the
methanol in the U.S. It is used as an oxygenate in oxygenated and reformulated gasoline.
Mayor Pena started an oxygenated fuels program in  Denver that spread to other cities.
The program was so successful that it was incorporated into the Clean Air Act. Currently
in place in 41 cities, the oxygenated fuels program is considered one  of EPA's  most
successful programs, with high implementation and acceptance rates, as well as tangible
CO reductions.

       Reformulated gasoline programs  were introduced later and have the potential to
double the current demand for MTBE. Reformulated gasoline was developed in California
where specific environmental  concerns  led to a  search for  cleaner burning fuels.  The
refinery industry recognized the potential of methanol to be a tremendous competitor in
the marketplace and set its fuel standards to be as clean as methanol fuel.  ARCO initially
developed a reformulated gasoline with a goal to be as clean as M85 (85 percent methanol
fuel). As a result, Unocal and Chevron lost market share and responded by cleaning their
products.  Under the Clean Air Act, the oil industry was forced to acknowledge the
potential for reformulated gasoline because three companies had  voluntarily developed it
through competition in the  marketplace.  The presence of methanol in the fuels  industry
as a product and the competitive driving  force of M85, forced the development and
marketing  of a cleaner gasoline product.
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993                                            Page 131
       There are three benefits to using neat fuels (e.g., M85 and M100) in flexible fuel
vehicles.

       •     Neat Methanol fuels are the most similar to liquid fuels currently in use.
             Although vehicles are being built with different materials, competition has
             reduced price, allowing the consumer to  adopt an alternative fuel while
             avoiding excessive cost.

       •     Because flexible fuel vehicles can run on either methanol, gasoline (or some
             combination thereof)/ consumers are not constrained by the availability of
             alternative fuels.

       •     M85 is a transition fuel that can be used during the development of an
             infrastructure for dedicated vehicles that will be even cleaner and more fuel
             efficient.

       It is important to consider methanol supply and availability in the U.S. and the
capital cost  of methanol conversions.  Viewing the overall capital requirement for the
development of an alternative fuel infrastructure, the cost of methanol is lower than that
of CNG. Methanol can be derived from natural gas — it is the largest use of natural gas
as an alternative fuel which is growing in domestic supply. Methanol also can be derived
from oil, coal, biomass, sewage sludge, new steel coke oven processes that turn emissions
into methanol, and conversions of closed ammonia plants. There is also a rapidly growing
distribution  infrastructure  for methanol that requires approximately one tenth the capital
cost of a CNG station.  Methanol can be transported in liquid pipelines like gasoline and
dispersed through liquid fuel pumps with only minor modifications. Large oil pipeline
companies have made a commitment to transporting methanol through their commercial
pipelines once there is sufficient volume. Methanol has the capacity to displace crude oil,
and industry has acknowledged and should welcome the competition it provides.

       The use of methanol as  an ether, the  development of Biodiesel fuel which is
partially made from methanol, and the role of methanol in reformulated gasoline are
examples of competition within  the alternative fuels industry.  The ultimate goal is to
create sufficient competition within the alternative fuels industry so that consumers can
choose which alternative fuel they want to use. The best way to achieve this goal  is to
level subsidies of alternative fuels to allow the  market to determine competition.
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Page 132                                             Clean Air Marketplace 1993
           Carl Moyer, Chief Scientist for Acurex Environmental Corporation, presented
           an overview of the business aspects of alternative fuels. He has considerable
           experience  demonstrating alternative fuels, supporting  fleet programs in
           California, and helping state and local agencies develop incentive programs for
           successful energy programs.   The future of the alternative  fuel industry, its
           pace, and elements of alternative fuel program  success can be outlined in six
themes.

(1)  Driving Forces for Alternative Fuels

       Driving forces for alternative fuels are weak and not well aligned.  This is a time
of great fuel change, but most of the changes are going to happen in gasoline and diesel.
Emission standards alone will not drive alternative fuels.

       •      There is a  strong response  of gasoline to meet the alternative fuels threat.
              In California, gasoline is capable of meeting  emissions standards for light-
              and medium-duty vehicles through low emission vehicles (LEVs), while the
              standards  for zero emission  vehicles will  require entirely  different
              technologies.   There is no room  for alternative fuels  in  the light-  and
              medium-duty sectors solely to meet emission standards.  But there  is a
              possible exception: if the gasoline LEVs are late for some reason, a demand
              for flexible-fueled transitional LEVs may be  triggered.

       •      Heavy-duty diesel standards can be met by clean diesel until the 2000s.
              Emission standards cannot be used to force out clean diesel and  switch to
              alternative fuels.  Local decisions to overtly favor clean fuels over diesel for
              buses and some other fleets (Seattle, Sacramento, Texas) are an exception to
              this.   '

       •      Emission reduction  credits can  be critical  to making  alternative fuels
              competitive, particularly natural gas and methanol in the heavy duty (HDV)
              sector.  When markets are thin, it is hard to equate a real dollar value with
              NOX  credits, and transaction costs are high.

       The relatively minimal Energy Policy Act requirements (100,000-300,000 vehicles
per year) are divided between methanol, natural gas, and propane, and between original
equipment manufacturers (OEM) and vehicle conversions. This division results in a fairly
small niche for each  technology.  Also,  available financial incentives reward fuels in
competing ways.  For instance:

       •      The  Energy  Policy   Act   and  rate   basing  reward   capital-intensive
              technologies, such as natural gas and propane, but they do not support
              methanol.
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993                                             Page 133
       •      The energy  tax  punishes all  alternatives  and  local taxes tend  to  be
             confusing.

       •      Site specific evaluations of fleet options are needed by all fleet operators;
             however, it is difficult for fleet operators to understand all of their options
             and respond appropriately.

(2)  Niche Strategies

       Niches can work for low, medium, and heavy duty vehicles. Fleet economics favor
niche strategies, where marketing costs decrease with large volume sales and high mileage
vehicles favor natural gas and propane.  While there is a shortage of certified natural gas,
engines and rate basing benefits are temporary.  Methanol can adapt to niches by careful
matching of fuel supply to vehicles.  Fuel suppliers must take risks and work to link fleet-
fueling retailers to fleet users.  Fleet fuel retailers are eager to meet this demand because
fleet vehicles are required to convert and the Energy Policy Act opportunity is very near-
term. The methanol industry needs dedicated suppliers who are willing to work to make
methanol succeed.  The question facing the industry is  how long OEMs will stay with
methanol cars, if they do not need them for emission requirements or CAFE credits.

(3)  Cost-Consciousness

       Government and business fleets are extremely cost-conscious in a time of recession
and require a delivered value in their alternative fuel vehicles.  Trials and experiments
with alternative  fuels are ending and retail fleet purchases are impending. Suppliers of
vehicles and fuel must provide service, reliability, and competitive costs to retailers who
want value and quality.  Suppliers must be willing to provide the labor intensive on-site
presence necessary  to help and support their customers as they make  the transition to
alternative fueled vehicles.

(4)  Market  Value

       Emission standards alone will not drive  alternative  fuels; therefore,  success for
methanol is more likely where NOX  reductions offered by alternative  fuels have real
market value (i.e., in  air quality-impacted areas).  Emission credits  can be worth up to
$30,000 per heavy duty  vehicle in their net present value or 20tf per gallon of methanol.
Unfortunately, it is difficult to take advantage of emission credits  for several reasons.
Markets are  thin, it is difficult to locate buyers, verification of credits requires costly testing
and auditing, and skimming and factoring for breather-benefits adds cost.

(5)  Inherent Advantages

       Although natural gas and LPG are better positioned, methanol can compete in the
alternative fuel fleet market. The lower cost of fuel offers inherent advantages for natural
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Page 134	Clean Air Marketplace 1993


gas, but vehicle technology still needs improvement. Fleets are not affected by economies
of scale, which is also a benefit for natural gas. However, methanol can take advantage
of fleet operations by working niches.

(6)  Cost-Prohibitive Alternatives

       Ethanol production and electric vehicles (EVs) probably will not be viable options.
Their costs are too high. In particular, EVs need a better platform with less weight and
fewer losses.  He suggests that EVs may become viable for fleets where  air credits can be
obtained during urban design.

       The 1990s have provided real, albeit limited, opportunities for alternative fueled
vehicles.  Success will require  suppliers of fuels and equipment to work closely with
buyers. This has nof been the case so far.  Natural gas suppliers tend to be more service
oriented and may fit into this role more easily. Broader alternative fuel vehicle markets
will require different policies than those implemented in 1974-1992. Although individually
the different  policy acts have useful features, when added up, they provide no decisive
guidance except for emissions. A question to consider is why there is not greater emphasis
on the balance of payments and domestic jobs in the promotion of alternative fuels.
           Dr. Jeffeiy Seisler, Executive Director of the Natural Gas Vehicle Coalition
           (NGVC), discussed natural gas technology (vehicles, hardware, and the fueling
           process) that is available on the market today and  efforts by the natural gas
           industry and fuel retailers to bring the fuel to the marketplace.

           There are challenges facing the NGVC, especially in that convincing the natural
gas industry that there is a viable transportation market. The  NGVC has been particularly
striving to:

       •      Achieve a balanced approach to developing a regulatory/legislative market
              for natural gas vehicles and strengthen the gas industry's support of that
              market.

              Facilitate  and commercialize natural gas vehicle development.  Natural gas
              is worldwide and requires international tie-ins.  It is necessary to provide
              the opportunity for U.S. companies to export their technology abroad.

       There are  many advances  in natural  gas vehicle technology.  To  date,  most
technology has been mechanically-based retrofit, taking a standard gasoline vehicle and
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Clean Air Marketplace 1993                                            Page 135
adding on natural gas cylinders, a regulator, and fuel mixer.  Retrofitted vehicles work
with either gasoline or natural gas, though the fuels are not mixed. These retrofits have
had  minimal  effect  on the  outside appearance of the vehicles.  Examples of new
technologies include:

       •       IMPCO is at the forefront of developing computer  technology for  closed
              loop systems that work with tailpipe sensors.

       •       Diesel engines are using fuel injectors to inject natural gas and spark plugs
              to ignite the fuel; the heat of compression engines cannot generate sufficient
              heat to meet the ignition temperature of CNG.  Hercules  has a "new look"
              diesel  engine that uses spark plugs.

       •       The defense  industry  is  becoming involved  in  developing  cylinder
              technology out of lightweight composites.

       •       Browning Ferris and  Southwest Research Institute produced a dedicated
              natural gas  Mack garbage truck that was driven from Texas to Boston.

       •       Brooklyn Union is experimenting with closed loop garbage trucks that run
              on natural gas  that  is collected from landfills and compressed.

       •       Bluebird and Hercules are producing natural gas school  buses.

       •       The Big Three  auto manufacturers are all in various stages of developing
              natural gas vehicles.   Ford has introduced the dedicated CNG Crown
              Victoria; General Motors Corporation is taking an after market conversion
              approach  through  a  contract  with IMPCO to convert  new trucks; and
              Chrysler has the "cleanest burning internal combustion engine on the road,"
              which has been certified as surpassing California LEV standards.

       •       Natural gas is being used in on- and off-road vehicles, water  vehicles, and
              trains.  For instance,  one can find natural gas in Zambonis, Disneyland
              water  rides, police  cars, Giant food delivery vans, Entenmann's delivery
              trucks, airport shuttle buses, Burlington  Northern  LNG trains, off-road
              forklifts, and mass transit buses.

       There are different ways in  which natural gas vehicles can  be fueled, but it is
difficult to predict which method will be predominant.  Instead, utilities will use different
market development styles to develop their natural gas fueling markets. Fueling methods
include:

       •       Fueling at the utility,  which is oriented towards fleet operators.
                                                   Session 4D — Alternative Fuels

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Page 136              	Clean Air Marketplace 1993


       •      Selling through the fence, where a utility puts the CNG dispenser outside
             of the utility yard so that the customer does not have to enter the utility
             property.

       •      Dedicating a natural gas station for fleet operators.

       •      Installing pumps at independent retailers (e.g., a utility-owned pump at a
             privately-owned gas station).

       •      Gas companies establishing their own, non-regulated,  non-rate-based
             businesses  (e.g., Natural Fuels in Denver, CO).

       •      Taking  over-the-road  cylinders  to  places  not served  by  natural gas
             pipelines.

       •      Slow-fill and home refueling.

       Dr.  Seisler concluded by highlighting some of the changes necessary  to make
alternative  fuels, and CNG in particular,  acceptable in the marketplace.  Organizations
representing  alternative   fuels  must look  to  establish a  balanced  approach  to
legislation/regulation that will build  in standards and legitimize alternative fuels in the
marketplace.  Public relations and communications must be used to get the message out
that alternative fuels are available and consumers must choose which fuel they want  to
use.  In  addition to  having sufficient time and economic resources, alternative fuel
suppliers need to be visionaries to succeed.
Questions and Answers
         There is an issue concerning inherently low emission vehicle (ILEV) standards,
         which recognize that there are two sources of hydrocarbon!organic emissions
         from motor vehicles, exhaust and evaporative. Why would ILEV standards not
         provide a strong market incentive for alternative fuels?

Mr. Moyer explained that the ILEV concept fundamentally requires dedicated vehicles.
Lessons from the 1980s show that it is  extremely challenging to match vehicles with user
application if the vehicle does not have some option for another fuel. Flexible fuel or dual
fuel vehicles take away many of the advantages sought through ILEV. Work in California
has tried to recognize high in use emissions and include whole life cycle emissions, from
the refinery to the tailpipe.  ILEV standards favor alternative fuels, but regulators cannot
impose standards requiring dedicated vehicles without experiencing extreme backlash from
the vehicle users.  Retrofit technologies in the heavy duty area could also help address this
problem.
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993                                           Page 137
Mr. Gray added that dedicated alternative fuel vehicles will be very attractive, despite their
drawbacks, relative to the draconian measures that will need to be implemented to meet
increasingly strict  air standards.   Mr. Moyer asserted  that  legislation that  supports
alternative fuels with some tailoring to community acceptance, and more aggressiveness
from the agencies for lower NOX standards for new engines, should be encouraged. Mr.
Levine pointed out that a standard for heavy duty vehicles was established, but only the
Detroit Diesel Corporation  (DDC) was prepared to  meet it.  Rather than letting DDC
benefit in the marketplace, the standards were changed and DDC was told not to take the
initiative standards seriously.

         Will the car companies take proposed standards seriously if they have been
         ignored in the past?

         Mr. Gray answered that such a statement presumes that the CAA will not be
implemented. Unless that situation changes, it is difficult to propose alternatives that are
less negative than a technology solution.
         Why does the methanol industry find the ILEV concept objectionable?

         Mr. Lewis pointed out that the methanol industry does not object to the concept,
         but rather the implementation.  ILEV assumes that only one thing, the volatile
emissions equipment, fails and ignores all of the other components on the system of a car.
It prevents a market for transition fuels such as M85 because they fail emission standards.
Industry has fuel that would lead to Ml00, but regulators have set a standard  that only
M100, which is not market-ready, can meet.  Presently, M85 should be banned from the
major programs,  like state  fleets, and implementation deadlines are so short  that it is
impossible for car companies to address the problem. ILEV is not a fuel neutral standard.
Mr. Gray added that ILEV is a performance standard based on air quality.
     L
^%  I
 •   I
         Is there a nationwide effort that makes Congresspeople aware of the potential
         to cause a significant reduction in the balance of trade or to  process unused
         grain or garbage?
Dr. Seisler explained that the NGVC is looking at the government to use and balance all
of the opportunities it has to support alternative fuels: mandates, incentives, credits, basic
communications, and development of standards to force the adoption of alternative fuels.
Mr. Lewis commented that it is a problem for an alternative fuel to get established in an
existing infrastructure where the current costs are very low. It does not make sense for
methanol to have to compete in an arena where all fuels are not created equal.
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         Why is the alternative fuel industry not focusing on the issue of replacing foreign
         oil instead of focusing on how one fuel is disadvantaged in  terms of other
         alternative fuels?

Mr. Lewis answered that when one industry goes out to promote this idea, it is viewed
as feathering its own nest.  Promotion of alternative fuels has to be perceived as good for
the whole country and not for one private industry.
  f% I
   •  I
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         When you talk about reducing dependence on foreign oil, you assume that all of
         the alternatives are domestically produced, but many foreign oil producers are
         gearing up to produce methanol for the 1995 oxygenates seasons.  Also, even if
         methanol is domestically produced, is it not still a finite resource?
Mr. Lewis explained that the source of methanol is natural gas, so if there is a source for
one alternative fuel then there is a source for both.  Also, methanol can be produced from
renewable resources.  Mr. Gray responded that a domestic policy initiative needs to say
that some amount of our fuel will be derived from domestic resources and some from
renewable resources, while promoting technological development and preserving jobs. Mr.
Levine went on to say that in order to produce methanol, there needs to be a lot of natural
gas in one place.  There is a lot of natural gas in the U.S., but it is spread out.  There is
much more concentrated natural gas in the Middle East and former Soviet Union, but the
economy will not import expensive methanol if petroleum fuel is inexpensive.
        Have there been any attempts to quantify methane releases from methane uses?

        Dr. Seisler responded yes,  however  the  focus  needs to  be on  developing
        greenhouse gas standards, which include methane and carbon dioxide.
Session 4D — Alternative Fuels

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Clean Air Marketplace 1993                                           Page 139
                            Keynote Address by
                            Senator Max Baucus

                            "An Environmental Renaissance'
                            September 9,  1993
      Two days ago the Fall session of Congress began, and the Environment and Public
Works Committee has a lot to do.  Next Tuesday we will hold our first major hearing on
the implementation of the Clean Air Act Amendments of 1990.  At the hearing I hope to
hear a lot more about the subject being discussed at this conference: new environmental
technologies.

      I believe that on environmental issues, this year will be among the most productive
in more than  two decades.  That is because there is a basic change in government
philosophy and in public attitudes toward environmental protection.  We are leaving an
era of reaction, backlash, and fear, and entering one of hope and progress.

      We seem to be resolving a bitter and destructive argument that has  hindered
environmental progress for decades: the contention by some that environmental protection
will destroy jobs and end economic growth; and the argument by  others that a vigorous
economy and technological advances will destroy the environment.

From Conservationism To Common Ground

      Before we discuss the future, it may be helpful to talk a little bit about the past, and
about the historic processes that brought us all here today.

      As a mass movement, modern environmentalism dates from the first Earth Day
celebration in 1970. In those days, now familiar environmental issues were very new to
government and industry.  People were sick and tired of burning rivers, dirty air, and
toxic dumps.  They asked Congress to respond, and Congress did respond. The  Clean
Water Act, the Clean Air Act, and the Safe Drinking Water Act all date from that era.

      In  those and  following years,  however, too  many environmentalists viewed
industry not as a partner to work with, but as an enemy to conquer. Too many members
of the business community took the same view of environmentalists. Bitter divisions
between the Executive Branch and Congress, and between industry and environmental
groups, made advances impossible. Legal and political battles, not scientific analysis and
cooperation, dominated the environmental landscape.  The result, of course, was that for
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Page 140                                           Clean Air Marketplace 1993
a full decade, from the early 1980s to the early 1990s, environmental progress halted, and
at times was reversed.

       This year we can clear the air, so to speak.  That means, as I like to say, that we are
on the  verge of a Renaissance — a rebirth of environmental progress. At the core of this
Renaissance, as at the core of the Renaissance in Europe hundreds of years ago, is better
understanding.  It is the understanding that we must preserve our natural resources to
sustain ourselves both economically and physically.

       Industrial and environmental groups have found common ground in the goal of
sustainable development — a growing economy, secure  jobs, a  healthy and clean
environment. The challenge is no longer whether, but how to reach the goal.

Taking Stock

       Last winter, when I became Chairman of the Committee, I looked  over the agenda
for the 103rd Congress and I saw a lot to do:  the Clean Water Act, implementation of the
Clean Air Act Amendments of 1990, the Endangered Species Act, and the Environmental
Justice Act.

       But I decided that rather than try to rush through it all, the Committee should step
back and look at the big canvas. So we  held a long series of what I called "Taking Stock"
hearings. I brought in scientific experts, environmental groups, legal scholars, economists,
and ordinary citizens to discuss where our country and our world stand on environmental
issues.  I listened to testimony on many different environmental  topics  and considered
many different approaches to our environmental goals.

       I emerged from those hearings more confident than ever that we have the makings
of a consensus on the right way to approach environmental protection, a way to keep our
country environmentally clean and  economically healthy, a way  to achieve sustainable
development.

       I  am optimistic about the future because,  as Russell  Train  reminded me, my
generation is more environmentally  conscious than his.  And our children, he noted, are
even more driven to achieve environmental preservation than we are.

Corporations Are Changing Their Ways

       1 am also optimistic because American businesses are catching on.  Companies now
listen to advice from inside and from outside. They are changing their ways and adopting
environmentally safer practices — not just for public relations,  but because it make good
business sense.
Keynote Address — Senator Max Baucus

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Clean Air Marketplace 1993                                            Page 141
       •      Dow Chemical used ideas submitted by its own employees to reduce waste
             in five of its plants, saving the company $10.5 million through recycling and
             increased efficiency.

       •      Xerox changed its packaging, eliminating 10,000 tons of waste and saving
             up to $15 million per year.

       •      AT&T saves at least $25 million a year in supply costs by  eliminating
             ozone-depleting substances.

Government Must do the Same

       Government can learn some lessons from companies like these. We who write laws
must be just as thoughtful and innovative as they are. We must take some new directions.
In the spirit of re-inventing government, we must look for ways to re-invent environmental
laws. The traditional "command and control" approach to environmental law is no longer
as effective as it once was in solving our environmental problems.

       This  does not mean lowering  environmental standards.  Nor  does it mean
sacrificing our economy for the sake of preservation. The "Taking Stock" hearings brought
home  to  me  the  importance  of three  things:  (1) developing  new, cutting  edge
environmental technology; (2) creating market-based incentives in our environmental laws
and programs; and (3) finding multi-media solutions tailored to particular facilities.

Developing New Technology

       Green technology can make environmental controls more efficient and more
effective — and it is critical to our economy. A recent study found that the air pollution
control industry can create 40,000 U.S. jobs per year by the year 2000. This job growth is
fueled by a 44 percent  increase in worldwide demand  for environmental  goods and
services.

       Green technology, however, will not develop automatically.  We must avoid a naive
faith that demand for these products will arise on its own.  Instead, we must create  it by
using tough regulatory  standards.  The California  Air Resources  Board, for example,
requires that by 1998, 2 percent of the cars produced for sale in California must have zero
emissions. That makes some people mad.  But it gets results.  Major auto companies and
small firms are now developing electric cars for the California market. And over 100,000
miles, an electric car is 200 times cleaner than the least-polluting conventional vehicle.

       I want to see that kind of advance nationwide, in all industries. The Environment
Committee has given us a start by reporting an "enviro-tech" bill I introduced earlier this
year.  I believe this legislation will get us started, by setting an overall strategy for Federal
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environmental technology research and development, and fostering private development
of technology.

       Other countries are well ahead of us in understanding the importance of green
technology, both for environmental and economic reasons. For example, I recently visited
Japan and spoke with Mr. Okamatsu, the Vice Minister for International Affairs at Japan's
Ministry of International Trade and Industry. I expected a tough discussion of U.S.-Japan
trade conflicts, the bilateral  deficit, the  Clinton  Administration's trade negotiating
framework, and so on.  But in fact what interested Mr. Okamatsu most was not trade.  It
was my enviro-tech bill. He knew more about that bill than virtually anyone I have met
in the U.S., and he told me that it is precisely  the sort of thing the U.S. needs to do not
only to protect the environment, but to improve our international economic position as
well.

Using The Market

       The second step is to use market forces to promote environmental protection.  At
times, this will happen automatically. At times, we can create markets, as California has
done for the electric car. And at other times, we will have to eliminate market incentives
that push companies to pollute.

       •      First, we have to insist that a product's price reflect its full social cost. We
              cannot let companies use "pollution subsidies" to cut costs and underprice
              environmentally responsible  competitors.

       •      Second^ we have to look for ways to create markets to reduce emissions.
              We have already begun to do so with the 1990 Clean Air Act Amendments,
              which created the allowance trading program for  sulfur  dioxide.  I am
              looking forward to hearing  more in the days ahead about California's
              RECLAIM program.

       On the whole,  this new market for  acid rain allowances is working well. There
were some problems in the way initial allowances were achieved, but those are growing
pains.  They should not overshadow the overall success of the first auction last March. We
must learn from these mistakes to ensure the future success of other markets.

Finding Multi-Media Solutions

       The third new step is to use what some call "multi-media solutions." This means
considering the total emissions of all pollutants into all media rather than focusing only
on single sources of emissions into one medium. This way, we can find the cheapest way
for a facility to reduce its pollution overall.
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Clean Air Marketplace 1993	Page 143


      This approach makes economic and  environmental sense.  Strict divisions by
medium are unnatural.  They  ignore  the inter-relationship between the elements that
comprise the environment. When we write laws, we must understand their effects on one
another.  As Bill Ruckelshaus told the Environment and Public Works Committee this
summer:

      "... the Administrator of EPA must follow rules of nine major statutes, none
      of which were designed to work with one another. There is no integrating
      principle built at all into this statutory armory.  Each is written to stand
      alone, as if the world were made entirely of air or water or some other
      target of concern.  No word in  all this law directs EPA to simply find the
      combination of policies across all programs that will garner the maximum
      benefit to the environment for every dollar of cost expended."

      I read with great interest a recent account in the Wall Street Journal of a joint study
by EPA and Amoco regarding its Yorktown refinery in Virginia. EPA regulations required
the refinery to install a pollution-prevention system at a cost of $41 million.  The study,
however, showed that the refinery could achieve greater overall pollution reductions for
$11 million, without u$ing the required prevention system.  How did they discover this?
I know the more interesting question may be "Who told the boss?" But we can learn more
from the answer to the first question.

      Most of the pollution being regulated at the facility  was toxic benzene vapor.
EPA's Air Pollution Office, therefore,  had an important part to play if an innovative
solution was to be found.  Amoco and EPA jointly studied  the plant's overall emissions
of gases, fluids, and solid waste.  They found that emissions of vapors from dirty water
were 20 times less than predicted. On the other hand, releases at the loading docks where
fuel is pumped into barges were extremely high.  But benzene vapors coming from inside
the refinery were regulated under the Clean Air Act and benzene vapors escaping at the
loading docks were not.  Amoco had to build a $41 million dollar water-treatment facility
to clean up the dirty water.  After a bill like that, they decided not to make any changes
in the loading docks. The benzene vapors there, a much worse problem than the vapors
at the water emission point, went untouched.

      Obviously, this is not a story of successful pollution control. It is an example of a
rigid law that forces companies and environmental control officials  to concentrate on a
minor problem and ignore the top priority.  We have to change the law.  And we have to
find the other laws that have similarly perverse results, and change them. With this
example in mind, the Senate Environment Committee will study the use of multi-media
approaches in the near future.

      Most cases  will not be as  simple as this. Just as in the Acid Rain Allowances
Trading Program, there will be a learning curve as we find  the best ways to reduce total
pollution.  We may find it best reorganize EPA to deal with particular sectors of the
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industrial  base, or into  geographical teams that help particular  plants lower overall
emissions.  But it is clear that we have to make changes if we do not want to repeat the
Yorktown experience all over the country.

Common Ground

       The Yorktown refinery project is not a happy story.  And it did not have a happy
ending, whether you are an ordinary North Carolina citizen who wants pollution reduced,
or the guy who ended up short $30 million, or the worker at the loading dock who is still
breathing in benzene vapors. But it is a story with a moral. It shows that if the laws are
well designed, industry and government can cooperate.  Despite the distrust that originally
existed between Amoco' and the EPA, the two sides collaborated and came up with  the
right answers. Only the  law stood in their way.

       A related problem is that environmental teams, as well as laws, are too specialized.
Like the wise men in the Indian folk tale, they often look only at the truck, or the side, or
the foot, or the tusk — and they miss the whole elephant.  Multi-media examination of a
facility goes against  today's emphasis on hyper-specialized training.  But in the end, as
happened in the Yorktown project, we may find a multi-media approach more efficient
and much more effective.

       Add to multi-media approaches better technology and market based incentives to
prevent pollution, while continuing to keep the regulatory requirements high, and I think
we are out of the Dark Ages and on our way to a Renaissance in environmental law.

Conclusion

       As always, 1  am inspired by my western roots. One of my favorite authors is a
Montana native named Norman MacLean, who wrote the now-famous novel A River Runs
Through It.

       Toward the end of his life, MacLean wrote an account of the Mann Gulch Fire of
1949 on the Upper Missouri. The book, Young Men and Fire, tells the story of the 13 young
firefighters — called "Smokejumpers" because they used planes and parachutes to reach
the fires as fast as possible — who jumped into the gulch and died when the fire caught
them on a steep hillside. The book recounts a tragic episode in Montana history. But it
also tells an inspiring story of your people who worked together for the common good,
of the lessons we can learn from terrible experiences, and  of how important it is always
to try and find new and better ways to solve our problems. Toward the end of the book,
MacLean writes about how the "Smokejumpers" reacted to the  fire:

       "The Mann Gulch tragedy immediately became a  flaming symbol to the
       Smokejumpers and  to  firefighters generally, especially  those  in the
       Northwest...  It was some of these who said to  me not long after the fire,
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       'God damn it, no man of mine is ever going to die that way.' Small cracks
       were soon filled in, especially with technical improvements... the training
       of the crews was also improved in many particulars... [and] in the early 40
       years since the Mann Gulch tragedy, no Smokejumper has died on a  fire
       line."

       That is a lesson for people in all walks of life, but is particularly important for those
of us in the environmental field. We have had a lot of disasters, a lot of failures, and some
tragic individual incidents.  But we can learn from them all just as we learned from the
Yorktown refinery. We can use new technologies, new economic tools, and new overall
approaches to our problems. And by doing so we will  prevent future failures.

       Which brings me back to the subject of this meeting. Innovative new technologies
for cleaning our polluted air are on display here at this Conference. Take a look at them.
In technical brilliance and in the new approaches their inventors bring to environmental
protection, they are an inspiration.   They tell me  very  clearly that we  can make  an
environmental Renaissance a reality.
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Keynote Address — Senator Max Baucus

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Clean Air Marketplace 1993
                               Page 147
                         Session 5 — Panel A
                         Federal, State, and Local Regulatory Programs
                         September 9, 1993
                          9:15 am. - J1:15 a.m.
                         Moderator:
                         Panelists:
S. William Becker
Michael Bradley
Bruce S. Carhart
David Jordan
Robert Brenner
Introduction

       S. William Becker, Executive Director, State and Territorial Air Pollution Program
Administrators, described the panel as a collection of officials at  different levels of
government in charge of implementing market-based regulatory strategies.  This panel,
according to Mr. Becker, provides the opportunity to explore examples of how market-
based initiatives can work and to discuss what we can do to improve them.
Presentations

          Michael Bradley, Executive Director for Northeast States for Coordinated Air
          Use Management (NESCAUM), began his remarks by stating that NESCAUM
          is moving forward with a number of issues.  The mission of NESCAUM is to
          pursue clean air goals, but do it at the lowest cost and in a way that will
          promote  economic expansion and new jobs.  This was a  key overriding
          criterion  in the way NESCAUM pursued its strategies, particularly as the
Northeast was still  in  the midst of a regional  recession  when the  Clean  Air  Act
Amendments (CAAA) were passed.

      This past summer, with the widespread number of ozone non-attainment days,
illustrates our regional ozone  problem.  The realization that NOX is a part of our ozone
problem is one of the major changes from the earlier approaches in the 1980s.  Thus,
NESCAUM foresees  NOX emission reductions to be approximately 60-70 percent during
this decade.

      NESCAUM is actively  pursuing a regulatory framework which promotes control
programs that  encourage  technological advances,  hopefully at a low cost and utilizes
economic incentives which will result in an effective approach.
                     Session 5A — Federal, State, and Local Regulatory Programs

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NOX Reduction for Utilities and Industrial Boilers

       A significant amount of NOX emissions come from industrial boilers and electric
power generation facilities.  After holding meetings and information gathering sessions,
NESCAUM developed emissions performance standards that included innovative concepts
(e.g., allowing a utility to over-control one or more boilers, while under- or not controlling
another boiler in the same state,  in order to focus on  those facilities that will be in
operation for the longer term).  The states are moving forward with  their own NOX
reduction strategies that are consistent with this policy. Although NESCAUM's policy was
initially received with much opposition by the utility industry, the industry  is now
concentrating on devising the most cost effective strategies to comply with the standards.

       The NESCAUM states are  also attempting to allow utilities to  choose  the best
control strategy to attain the performance standard. The utilities may choose any strategy
(e.g.,  fuels changes, seasonal strategies, combustion modifications) that is most cost
effective.  In particular, selective  non-catalytic  reduction  is the one technology with
measurable, cost effective results that has been used recently by utilities in the Northeast.
More advanced  technological solutions (e.g, selective catalytic controls) are also being
considered.  There is a healthy  level of competition between control technologies that
reduce emissions from all types of fuels, as well as competition with cleaner fuels like
natural gas.  The stage is being set for a second  round of NOX reductions two different
policy approaches are being considered:

       •      A performance standard, and

       •      An allowance cap approach, which sets a baseline level of emissions for
             each major  source (e.g.,  boiler), effectively allowing  the major source to
             decide what control  options to pursue, including purchasing credits.

       The regulations will be based  on energy output, not on the amount of energy
content of fuel going into the facility. Focusing on energy output provides incentives for
overall efficiency, demand-side management techniques, and conservation, and  places a
higher value on  renewable resources.  NESCAUM is currently undertaking a feasibility
analysis on this alternative.

Motor Vehicle Control Strategies

       NESCAUM is also  focusing on California's low emission vehicle  (LEV) program.
The estimated emissions control cost per vehicle that California has set has dropped by a
large magnitude in less than 2 years. This is crucial to those who see  motor vehicles as
a key component in an overall reduction program.

       The California standards mandate production of zero-emission vehicles by model
year 1998. This has led to an unprecedented shift in research and development activities
Session 5A — Federal, State, and Local Regulatory Programs

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Clean Air Marketplace 1993                                           Page 149
to sectors within the automobile manufacturing industry, battery manufacturing area, and
electronic component area, to attempt to produce an electric and hybrid electric vehicle,
which is affordable and performs well. There also has been a tremendous effort on state,
local, and Federal government levels to form partnerships with the private sector to
facilitate the development of these technologies and implement demonstration programs,
as well as to look at broader infrastructure issues.

Economic Incentives for the Emissions Trading Program

       Emission trading and  economic incentives  have to play a role, because  without
these incentives, states may not be able to achieve their goals. NESCAUM met with 12-15
private sector representatives and promoted a summer demonstration program. The goal
was to promote innovative, traditional, non-traditional, and seasonal  control strategies.
Actual control strategies implemented included trip reduction, demand-side management,
application of selective non-catalytic reduction, seasonal fuel switching, use of alternative
fuels for both light and heavy duty vehicles, vehicle scrappage, and aggressive  fugitive
emission controls.  Massachusetts is about  to adopt regulations that are the most
innovative emission trading regulations on the books today.  These regulations  will get
attention from other states in  the Northeast.

       NESCAUM is interested in putting regulatory initiatives into place by promoting
a high degree of market competition; the utility NOx/industrial NOX competition has
illustrated the benefit of doing this. The market is certainly responding, and there is more
to come. NESCAUM is looking to continue to encourage mechanisms that will advance
technologies, as well as innovative strategies and market competition.
           Bruce S. Carhart, Executive Director, Ozone Transport Commission (OTC),
           explained that the OTC was created in the Clean Air Act Amendments of 1990
           to coordinate the control of ground-level ozone in the Northeast and mid-
           Atlantic states. Air quality activities have generally been on a state-by-state
           basis.   There is  now statutory recognition  that regional  problems require
           regional solutions, and should not be addressed solely on a state-by-state basis.
Toward that end, the OTC coordinates air quality management strategies in the ozone
transport area.  The  goal is  to provide attainment and maintenance  of ambient ozone
standards by  statutory attainment  dates.   The commission must be  creative  and
imaginative in the way it brings about attainment and maintenance.  Clearly, economic
incentives are going to play a part. One area to focus on is emission offsets, specifically
trading programs.
                     Session 5A — Federal, State, and Local Regulatory Programs

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Page 150
Clean Air Marketplace 1993
       Mr. Carhart introduced a slide show that discussed the following topics:

       •      Background information on the OTC. In the Northeast, there are substantial
             urban areas that contribute to the ozone problem. A non-attainment map
             shows established  areas  of  non-attainment  throughout  the  region.
             Modelling studies have been performed to further identify the nature and
             severity of the problem.

             Background information on the air quality challenge.

       •      Offset requirements of the CAAA.

       •      The  extent to which  emission  offset  programs  have  been/are being
             developed in the Northeast and mid-Atlantic states. The OTC is developing
             trading programs because:  1) it is sound policy to encourage progress
             toward  economic growth, while also moving toward  ozone reduction
             requirements; 2) there is the potential for reducing costs of compliance; and
             3) there is the potential for reducing emissions that would not otherwise
             occur.

             The May 18,1993, Memorandum of Understanding (MOU) that OTC signed
             relating to NOX emission offset programs. The preamble discusses trying
             to achieve  greater air quality benefits as well as economic benefits than
             would otherwise occur in the absence of such a program.

       •      Future activities  for the OTC, including interstate offset trading systems.
             The OTC has initiated correspondence with EPA and wants to evaluate past
             offset experience to demonstrate the potential to create emission reduction
             credits.
           David Jordan, Former Administrator, Indianapolis  Air Pollution Control
           Division, Semor Project Manager, ERM Midwest, explained that he has the
           perspective or a local air pollution agency official, as well as someone who has
           industrial  clients.   Mr. Jordan outlined  major issues  that state and local
           agencies have to deal with, and also described some private sector concerns.
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      Some concerns of regulators include:

      •      Meeting obligations of the CAAA, including non-attainment obligations,
             deadlines, and plans to submit. Regulators want flexibility from EPA, and
             particularly want to be able  to determine if their source is in compliance
             with regulations.

      •      Being a partner with industry, which includes being kept abreast of future
             changes in industry.

      •      Economic growth, primarily  the expansion of the industrial base.

      •      Fiscal stability, which would allow a program to grow in the future.

      Some examples of industry's concerns are:

      •      Consistency  across  counties,  states,  and  regional boundaries  in the
             enforcement of laws.  Industry wants to see laws uniformly enforced.  A
             facility is put at a competitive disadvantage if it is forced to comply when
             competitors are not.

      •      Certainty about what the ground rules are. Industry wants to know what
             the regulations are, what the  standards are, when they have to be met, and
             how to  demonstrate compliance.

      •      Flexibility in how industry manages operations.  Day-to-day operations
             change, and industry wants this reflected in regulations.

      •      Industry wants regulators to have quality staff in order to better understand
             how indu-stry does business.

      Joint opportunities for  how these concerns can possibly be addressed  include
changing the way business has been conducted in order to make market-based solutions
more attractive.   There are environmental interests, business' interests,  and regulatory
interests that have to come together to address these issues. Some possible options for
addressing various concerns include:

      •      Better communication  and consensus-building among all interests in the
             rulemaking process.  Everyone has an obligation  to get involved in the
             process to 'avoid the  typical  regulatory-negotiation approach.  There is a
             need to involve EPA in this process, and  there is a need for more outreach
             and training on obligations. Small business assistance programs are a very
             important aspect in making a rulemaking successful.  Involving the public
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             will help in heading off negative reactions from environmental groups to
             certain regulatory stances.

       •      More  flexible regulations can  be  written  using different  types of
             technologies. We have a strong track record of attaining regulatory goals
             (e.g., Acid Rain).  What we have to understand is the relationship of these
             programs to our ability to meet our environmental obligations.

       •      Maximizing flexibility.  We want the environmental benefit that we desire
             at the least cost. The CAAA provide opportunities for this; more flexibility
             is given to state and local agencies to develop rules and regulations to meet
             the standards (e.g., ozone control obligations). There is also an opportunity
             to involve the public and decision makers in development.

       •      EPA's role in an audit program. EPA must make sure there is consistency
             across the country in the effort to meet environmental goals. EPA also has
             a role in providing technology to regulators, in order to provide information
             to be used in the rulemaking process. EPA also needs to set up a good
             technology exchange program.

       •      Efforts to rejuvenate local and state governments.  There has recently been
             considerable attention surrounding Mr. Gore's "Reinventing Government"
             approach. This approach has been going on for some time at the local level,
             and we want it to continue to be encouraged.

       •      Efforts to do business in sensible ways, such as the efficient spending of
             resources.   There will  be efforts  to change the way we do business,
             including  multi-media  approaches,  efforts   to   coordinate  different
             governmental interests, TQM approaches, and team building to assess cross-
             media impacts and our business practices.

       In closing, there are a great deal  of opportunities for the future to try  to make
market-based approaches succeed.
           Robert Brenner, Acting Deputy Assistant Administrator, Office of Air and
           Radiation, U.S.  EPA, began by tying together the presentations so far.  We
           have heard the need for regulatory approaches that really challenge industry
           and reward companies that are clever in their approach. If we do our job right
           in developing the regulations, we  will further build a constituency  that
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Clean Air Marketplace 1993                                            Page 153
supports the CAAA (e.g., industries that can gain a competitive advantage by being smart
in how they comply with the CAAA).  The economic incentive programs that work best
are those that are designed by regulators, industry, environmental groups, and all relevant
parties together.  These types of programs will not just provide equivalent environmental
results to traditional regulatory approaches.  Almost always, part of the savings that you
achieve by using this approach are used for better protection of the environment.

       Regulators are also becoming more supportive of incentive programs because these
programs are the best way to promote new technologies and  prevent pollution.  For
instance, systems that encourage firms to move beyond compliance requirements have
been very successful. Under such programs people understand that there is a real market
for cheaper technologies that can meet stricter standards. Incentive programs such as
marketable permits provide powerful stimulus for pollution prevention because sources
with zero emissions can  sell permits they no  longer need.   As new technologies are
developed, other areas will find it easier to meet air quality goals.  Other advantages of
incentive programs include better monitoring and better recordkeeping.  The ability to
accurately quantify the results of the programs is important.

       It is important to continue the concept of regulatory negotiation, round tables, and
other consensus-building approaches for feedback on regulations  (especially before the
public comment period).  It is  also very important that we provide timeliness and
predictability in our regulations.  The problems we have had in the past have made it
difficult for  state  and local agencies to have the lead time they need to develop new
approaches  for more effective compliance.  As we  work  with  other parts of the
administration (e.g., DOC, DOE, DOT, OMB), we intend  to  constructively  develop
innovative approaches and get these rulemakings out on time.  It is very important that
we find ways to cooperate and provide flexibility to regulators across the country to enable
them to meet  their  area's  transportation needs,  energy  concerns, increase export
opportunities, and produce state air quality plans.
Questions and Answers
         To what extent are other types of trading programs, such as for Volatile Organic
         Compounds (VOCs), being examined?

         Mr. Carhart explained that priorities had to be established for initial efforts. We
decided on NOX because it was a new requirement.  Also NOX trading has an advantage
over VOC  trading which involves both reactivity and toxicity.   However,  we  have
consciously put together the May  18, 1993  MOU so that it could be added onto in the
future.  If it appears that there is a  need  to expand into VOCs, there is always that
possibility.  In the short run, NOX became the priority.
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        How can the OTC meet its emission reduction requirements without an LEV
        program?

        Mr.  Carhart responded that the OTC has been looking at a broad range of
options for meeting the emission reduction requirements. We find that just relying on
specifically indicated strategies in the CAAA is not going to do the job in the Northeast.
The OTC believes that we need a  balanced approach between VOC and NOX, and between
stationary and mobile sources.  To date, the OTC has not found a way  to attainment
without LEV.
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         What is the relationship between regional air pollution authorities and state air
         agencies (i.e., What is the mission of NESCAUM and the OTC?)?
         Mr. Bradley answered that due to the regional nature of the markets, it makes
a lot of sense to pursue consistent regulatory programs.  To achieve this,  NESCAUM
supports the exchange of information. Out of that consensus-building process, a consistent
approach is borne.  There are many benefits to pursuing a consistent — not a uniform —
approach in  terms of environmental equity. The regional process saves a lot of resources
by having a regional rather than a state-by-state process. Mr. Carhart added  that the
course is replicated for the OTC, in that there is a shared commitment on ozone control
in the region.
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         What are the advantages and ramifications of taking the approach of pounds per
         kilowatt hour?
         Mr. Bradley responded that the current regulations to control NOX and SO2
emissions in the Northeast are based on the energy input in a boiler, which is in pounds
per million BTU units.  This creates the incentive to become as efficient as possible, in a
way that produces fewer emissions.
         They have done this in California.  Would you go about it the same way?

         Mr. Bradley responded that NESCAUM is looking at a California program, the
         South Coast utility averaging program, restricted just to utilities. We are looking
at expanding the population of sources to include all of the major NOX emission sources.
      L  To what extent are you planning on incorporating public participation in the
  f} I  development of the energy output approach?
 JJ
^"™"  Mr. Bradley responded that the process is really only a feasibility analysis right
now.  It  is made up of a committee of all of the state and EPA offices, as well as an
advisory committee made up of private sector and environmental advocates. There will
be a public  process, and  there will be a broader comment process as we develop the
program.  However, there are a lot of sticky issues to be resolved, and things are not final
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Clean Air Marketplace 1993                                            Page 155
yet.  For example, we have to come up with a feasible way to measure and deal with
baseline emissions.
      U How do we use market-based incentives to effect individual behavior, or to
  f% I influence companies' actions to provide incentives for changing their employees'
   •  I behavior, particularly in light of the mobile source problem ofNOx emissions?
T""^"" Do  you have comments  on the extent to  which state  or local regulatory
processes,  market incentives, or state emissions fees can be used as  incentives to change
individual behavior?

Mr. Brenner responded that, as was pointed out earlier in the conference, the price of a
product should reflect its full environmental implication. States are trying to do this on
their own, and trying to deal with relatively diverse sources. It may be more efficient to
handle on a Federal level.

Mr.  Brenner added that the employee  commute (also known as the  employee trip
reduction  program), if implemented correctly, will strpngly encourage  employees to
commute in more environmentally friendly ways.  For example, groups of companies are
getting together to work jointly to set up incentives.  It is difficult, and for years we have
been trying to inject into the transportation sector the right  kind of  market signals. The
current transportation sector is like  the utility sector 15 years ago: utility pricing was not
very rational given environmental economic  impacts.  Over  time, utility  pricing  has
become more rational. The challenge now is to see whether we can do something similar
in the transportation sector so that we can send pricing signals so people make the right
kind of investments.
       L  EPA Regions are increasing the number of requests from  states for fairly
  f%  I  innovative public/private partnership proposals.  We are seeing that EPA is
   •   I  reducing its funding for market-based incentives, and that the Inspector General
 •"^•"  (IG) is about to "land on" anyone who touches a public/private partnership. Mr.
Gore's recent report cited two overzealous IGs illustrating a restriction  of creativity
instead of an encouragement to educate people and get them on the right track.

Mr. Brenner  pointed  out that it  is difficult to implement or find funding  for these
programs.  However, there is a lot of momentum behind developing these  kinds of
programs, even without additional funding from EPA.  We are finding that state and local
governments are funding their own programs. We are continuing to do the best we can,
but hope that, as people see the merits of the programs, they will grow.

As far as the comment on IGs,  there is a whole body of statutes and regulations that make
the new types of approaches difficult to implement.   One  of the  messages of the
"Reinventing Government" report is that it is time to look at procurement regulations and
determine whether they have become too detailed and burdensome to pursue some of the
innovative types of approaches.  In defense of IGs, they are simply making sure that we
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adhere to the requirements that are in place.  "Over-zealousness" occurs in any regulatory
agency. Unfortunately, we cannot simply ask the IGs to ignore the regulations.  Instead,
we should start reforming the regulations.

Mr. Carhart responded that we face a difficult task in states — trying to make ends meet
in order to augment decreases in grants and  state and local appropriations.  If a state and
local regulator are asked to choose between spending a certain amount on cleaning up the
air toxics problem versus a market-based incentive scheme with an unsure payoff, the air
regulator does not have much choice.  EPA  has been saying to us that they are going to
earmark money for market-based approaches, but this reduces the funding on  other,
perhaps more important, issues that have greater  impact on public health.

One of the ways to overcome this problem is  for industry to sell to the government.  There
should be an understanding that one  cannot expect a government regulator to accept
something that only makes industry's job easier,  without helping the environment, and
without pursuing additional recordkeeping and monitoring to ensure the desired results.
A more successful approach is to convey a  system in which one sees more reductions,
better recordkeeping, and better monitoring.

         What is the status of the need for California reformulated fuel within the LEV
        program?  What kind of emission credits would EPA give for an LEV program
        with Federally reformulated gasoline?

Mr. Carhart stated that the position of the OTC has been very clear. The intent has always
been to use Federally reformulated fuel in the LEV program.  As far as court cases are
concerned, the position of the states will be upheld. OTC has looked at the LEV program
with Federally reformulated fuel and found that we should be getting most of the emission
reductions even without California reformulated  fuel.  All of the indications show that
Federally reformulated fuel is the technically feasible thing to do.

Mr. Brenner explained that it would be difficult to determine what the credits would be.
In determining the credits, we look at not only the vehicle and the fuels, but maintenance
requirements as well. What sort of maintenance requirement would have to go along with
the program in order to get the desired program results?
r
         What type  of consideration  is  being  made  to  allow for  site  specific
         considerations in implementing technology transfers? In some cases, they may
         actually increase CO and air toxics.

Mr. Brenner responded that site specific  considerations will enter the discussion.  If we
offer flexibility in programs, such as technologies that increase VOCs while reducing NOX,
the problem can be compensated  for in  other ways.  If the technologies are no longer
economic, it might not be appropriate for that area. The point is to give people several
options as  to where they  get reductions.  The flexible approaches are also important
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because it may be possible to achieve more reduction and remain economically viable for
the industry.
        Do you think there is enough time to implement that type of flexibility into the
        NOX reduction provisions we have been discussing? Is the process too far along?

        Mr. Brenner responded that we have an economic incentives rulemaking that
deals with trading. We are trying to set up ways so that we can achieve better — not just
equivalent — environmental results.
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The  approaches discussed  so far  seem pretty  slow in coming about (e.g.,
performance standards).  Why is it taking so long, and what types of things
could be done to speed things up to make this a more common practice?
Mr. Bradley indicated that we are asking for a new mind set, a new approach. There are
technical,  institutional, and political obstacles  that are difficult to  overcome.  The
momentum is beginning  to build through successful application of flexible, innovative
approaches.

Mr. Becker added that the goal is to have equal or greater emissions reduction, the
assurance that those reductions will occur, and increased monitoring and recordkeeping.
There has to be mutual trust.

Mr. Brenner  pointed out that we have to overcome some baggage  (e.g., the Bubble
Program implemented  in the 1980s)  from the past where  the emphasis was more  on
regulatory relief than regulatory reform. These programs were seen by many as lowering
environmental goals rather than achieving the same or better environmental goals at lower
cost. Thus, there is suspicion.  Also monitoring is difficult to facilitate in these types of
programs.

Mr. Carhart added that developing interstate NOX offset trading programs is new. It is
a  problem  of trying  to  coordinate  trading  and  nonattainment  planning efforts
simultaneously, and we are finding that it simply takes  time. On the  positive  side, the
time spent now is likely to be well spent, as it is designed to produce both an attainment
and maintenance  plan and an economic incentive program, in tandem.  This should be
viewed as a benefit to everyone, instead of trying to create an attainment and maintenance
program first, and then trying to retrofit economic incentives after the Title I program has
already  been  created.
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         Could you comment on the possibility that emission reduction credits, once
         certified, may be assigned a lower (or zero) value in the future if a state changes
         its reduction standards?  Some have argued that this is necessary, but others
         argue that it will retard investment in early reductions. Is such a system really
market-based if the creator of the credits is asked to take on that much risk?

Mr. Carhart responded that, based on the modelling that has been done, NOX control is
a very effective way of reducing regional ozone.  We are quite likely to see a second stage
of NOy control in order to provide for attainment within the region. For that reason, the
OTC has taken an aggressive posture toward evaluating additional NOX emission control
strategies aimed  at that second phase.  In fact, just this week, both the OTC Stationary
Source Committee and  Mobile Source Committee met (separately), to discuss additional
NOX emission control strategies that are available.  For any system of this sort to work,
there  must be  predictability, and establishing the new SIP limits expeditiously will help.
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                                Page 159
                          Session 5 — Panel B
                          Technology Development and Diffusion
                          September 9, 1993
                           9:30 a.m. - 11:30 a.m.
                          Moderator:
                          Panelists:
Steve Harper
Nick Nikkila
Tim Mohin
Robb Lenhart
Dr. Joseph Ben-Dak
Introduction

       Steve  Harper,  Senior Policy Analyst, Office  of Air and Radiation, U.S.  EPA,
introduced the panelists for this session.  A diverse set of perspectives has been presented
at this conference.  In simpler days environmentalists could point to technology as a
monolith that created  environmental degradation.  The discourse today is much more
sophisticated. There is an increased realization that only technological transformation will
allow us both to continue to grow economically and to solve our environmental problems.

       Gus Speth, former Head of the World Resources Institute and current Director of
the United Nations Development Programme, has written very  eloquently  on this topic,
identifying the need for a "wholesale technological  transformation."  The  need  for a
technological  transformation manifests itself domestically in many ways.   Technology
transfer provides  the only means for  economically solving some  of  the  current
environmental problems of which Senator Baucus spoke and those  that the Senate will
confront in various re-authorization bills in Congress.  In the air quality arena, the ground
level ozone pollution  in cities like Los Angeles, Houston, and  New York  is a  problem
which many people believe cannot be solved using current technology without shutting
down the economy —  an effect which no one wants. As we tackle progressively tougher
environmental problems, the cost of cleaning will climb substantially. We need to find
cleaner and cheaper solutions. As our economy grows, innovative technology will permit
us to improve both our environmental and our economic well-being. Internationally, some
feel innovative technology  is  the  only hope for sustainable  development.   Indeed,
discussions of sustainable   development  increasingly  turn   to topics  such  as   de-
materialization  and technologies that  effectively reduce the connection  between  the
economy and nature.

       It is important to note that although the primary focus of the panel  today — and
of the conference — is on environmental technology, or what some  call  "dark green"
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technology, much of what is needed throughout industry is what is termed "light green"
technology.  Light green technology is  technology  that will  have significant impacts,
although not having environmental improvement as its primary focus. Examples of light
green technologies include energy efficiency breakthroughs such as the use of light-weight,
fuel-efficiency boosting and composite materials in automobile manufacturing.

       The Clinton Administration has significantly increased  the Federal government's
focus on technology development and diffusion.  For example, EPA has convened the
Innovative Technology Council to make decisions on how environmental  technology
monies will be spent and, more  importantly, to  get  the various parts of the Federal
government to act together. The Environmental Technology Initiative will provide $36
million in its first year and  is projected to grow to a cumulative $1.9 billion over an 8-9
year period. More recently, President Clinton has convened the President's Council on
Sustainable Development. It is safe to assume that many public and private sector leaders
will  want to  focus  on technology  innovation and  diffusion as the cornerstone to
sustainability.   It is  in  innovative technology that our economic and environmental
objectives can meet cooperatively.

       An important question the panel may want to address is how much effort  and
funding to apply toward innovative technology development, versus toward the  actual
diffusion of current technologies which are innovative but which, for a variety of reasons,
have not found a market niche.  The fundamental question  for the panel is, "What is the
proper  role of government in both  technology  development and  diffusion?"    The
environmental goods and services market is unique in that it  is created and shaped by
regulations that EPA and other agencies are charged with implementing. EPA and DOE
have traditionally played a role in supporting both basic and high-risk research activities.
Typically, this has been  in partnership with the private sector and increasingly through
mechanisms such as Cooperative Research and Development Agreements (CRADAs).

       Some say EPA plays an important role in discouraging the market acceptance of
innovative technologies  since the "best available technology" syndrome is woven  into
many statutes.  This syndrome leads to risk aversion on the part of permit writers  and
companies that could potentially face severe penalties if they try something innovative that
does not work.  Besides cleaning up  its regulatory act, the government can  have many
other important roles, such as providing and sharing state of the art information, thereby
facilitating uniform technology protocols against which new technologies can be judged.
The  government is important  as  a  sophisticated consumer.  Although  the  Federal
government has received criticism in  the past, President Clinton is making great strides
with procurement policy changes to encourage and increase the extent of the government's
purchasing role (e.g., the Federal government encouraging the use of recycled paper).

       The incentives and  flexibility that are built  into the  Clean Air  Act are key  to the
marriage of stringency and flexibility in fostering technology innovation. At EPA we have
developed a database, called the Clean Air Marketplace (CLAM) Database, to track  new
Session 5B — Technology Development and Diffusion

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Clean Air Marketplace 1993                                            Page 161
technology and business activities directly related to the Clean Air Act. Currently, we
have over 600 projects in the database.   Not all of them are new  technologies, but there
is  a tremendous, amount  of  technological ferment  in  the market.   The pace and
predictability of future EPA regulations will have a large impact on the marketplace.
Presentations

           Nick Nikkila, Director, Economic Development and Business Retention, South
           Coast Air Quality Management District (SCAQMD), described the efforts of the
           regional air  pollution control agency in assisting in the development and
           commercialization of new, less polluting technologies.

           The SCAQMD — comprised of Los Angeles, Orange, and Riverside counties
and the non-desert portion of San Bernadino County — was given the legislative authority
to regulate air pollution in the Los Angeles area. In all, the SCAQMD covers 13,350 square
miles and a population  of over 13 million people. It also covers in excess of 9 million
resident vehicles which, coupled with tourist traffic, drive approximately 270 million miles
each day.

       The combination of topography, meteorology, and population has produced a level
of air pollution that is beyond any conditions experienced elsewhere in the United States.
The problem is growing and the population of the area is projected to increase by more
that 30 percent by the year 2010. If we are to have healthy air quality in the Southern
California Basin, it will only come about as a result of new, lower-emitting technologies
such as fuel cells for mobile and stationary applications, commercially acceptable zero-
emission vehicles, non-VOC coatings and inks that are usable in all printing and coating
applications, and ultra-low NOX burners.  As a result, the SCAQMD, more than any other
air pollution  control agency  in the country,  depends upon the  development and
commercialization of new  technologies.  While  stringent regulatory  requirements can
provide incentives  for technology development, it is our belief that this alone is not
sufficient  to meet the needs of our  area. The SCAQMD must play a larger  role in the
solution.

       Since SCAQMD  created of the Office of  Technology Advancement in 1988, the
office has invested in excess of $34 million toward the research and development of low-
emitting technologies.  Because this money is used to leverage  additional research and
development funding, the  result has been in excess of $100 million dedicated to the
development of low-emitting technologies.   In a risk-averse corporate culture, our
participation has had value far beyond the dollar amount contributed.  We often are able
to give technical innovators in corporate America the credibility they need within their
own companies to advance research and demonstration projects, even when our share is
only 10 percent of a project or less. The  SCAQMD has provided co-funding for over 100
research and development projects.
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       Initially, the vision was something like that in the movie, Field of Dreams — "Build
it and they will  come."  In reality,  demonstrating the efficacy and  feasibility of a
technology does not guarantee investment in its commercialization and use. Since gaining
that perspective, we have initiated two separate actions:

       •      The Best Available Control Technology (BACT) designation program; and

       •      The development of a new Technology Commercialization Loan Program.

The Best Available Control Technology (BACT) Designation Program

       In the state of California, all new sources of pollution are required to be equipped
with BACT level controls or processes. As a result, a BACT designation can make a new
technology a much more viable commercial product.  Within our agency, we are now
building a discrete group, which will be dedicated to BACT designations and will have a
close  tie to our technology advancement program.   In that way, we can maximize the
opportunities for private investment in the commercialization of new technologies.

       As a technology becomes available for commercial investment, we perform a BACT
analysis.  A subsequent BACT designation should then serve to attract investors to that
technblogy.  One  of  the things we have heard from investment bankers today is that,
"What is BACT today may not be BACT tomorrow."  This creates uncertainty in regard
to the time-frame  for  marketability of the technology in which they might be considering
investment.  In response, the SCAQMD is now considering  establishing a fixed,  or
guaranteed life of  three years for BACT designations. The designation would be valid for
three  years whether a new technology with improved effectiveness comes out next week
or next year. Once a technology is termed BACT, it would hold that designation for three
years.  This means that there will be an overlap of technologies that are  BACT.  This
strategy would assure investors a reasonable market period for the new technology being
considered.  All signs suggest that this will improve the opportunities for timely, private
investment in the  commercialization of newly  emerging technologies.

Commercialization Capital

       Private investment is not always attractive to the technology entrepreneur. Often,
an entrepreneur goes to the bank with only an intellectual property — often regarded as
poor collateral for a loan.  On the other hand, if that same entrepreneur seeks funding
from a venture capitalist, the entrepreneur would be  forced to pay a very  high price, most
often  in the form of equity  in their company.   After working for years to develop a
technology, it is difficult for individuals to give up a large part of their company to people
who have invested comparatively very little themselves.  In response, the SCAQMD has
begun an effort which we hope will result in  the creation of a revolving loan  fund
dedicated to the commercialization of new  technology.  Initially, the source of funding
would be a part of the current vehicle registration fee.  For that reason, projects that could


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Clean Air Marketplace11993                                           Page 163
be funded would be limited to those that are related to mobile sources.  If this proves
successful, we will look for opportunities to expand this program to cover stationary
source-related technologies as well. Currently, a contractor has been hired to develop
recommendations for the structure and administration of such a  loan program.  Any
suggestions from those familiar with existing loan programs are welcome.

      The SCAQMD recognizes  that efforts  to develop and  commercialize a new
technology can be useless if the customer is not able to buy the product. That is why the
low interest loan program is  available for customers  who want to purchase  the new
technology.

      The SCAQMD is taking other bold steps toward an improved regulatory climate
for innovations, including  the new market-based approach which the SCAQMD terms
RECLAIM (Regional Clean Air Incentives Market).  Hearings are scheduled to begin on
September 9, 1993, and are expected to last until October 15, 1993, when RECLAIM will,
hopefully, be approved.  If adopted, RECLAIM could change the regulatory mode both
nationally and internationally.  Inspection of non-RECLAIM sources has revealed that in
just one  instance, the SCAQMD has  saved more  than 19,000 businesses in Southern
California over $1.7 billion, while opening the way for more rapid economic recovery and
air quality improvement.

      Through  the SCAQMD's knowledge of new emerging technologies and their
partnerships with businesses in their district, SCAQMD has been able to retain 4,000 jobs
which otherwise would have left the basin. Given California's poor economic situation,
economic enhancement must go hand-in-hand with environmental improvement. The
approach of  the  SCAQMD  is proactive  because  it  combines  development,
commercialization, and the use of new technologies to create greater opportunities  for
innovation and improving the economy.
          Tim Mohin, Senior Fellow,  U.S. Senate Environment and  Public Works
          Committee, spoke about the National Environmental Technology Act of 1993.
          The bill was introduced by Senator Baucus on May 18,1993; co-authors of the
          bill include Senator Lieberman and Senator Mikulski.
Goals of the Legislation

      The National Environmental Technology Act is the embodiment of the marriage
between the environment and the economy. The goal of the legislation is to foster a strong
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U.S.  environmental technology industry,  leading to increased job creation,  economic
development, and a healthy environment.  A strong environmental technology industry
is  a  win-win situation for  America.  In determining the  goals of this  legislation,  the
Committee of Environment and  Public Works  asked, "What can we  do within our
jurisdiction that will foster this industry?," resulting in four primary objectives of the bill:

       •      Coordinate the efforts of the Federal government related to environmental
             technology;

       •      Provide  the  necessary seed money  for the capitalization of innovative
             technologies  development in the private sector;

       •      Reduce market barriers that exist for the environmental technology market;
             and

       •      Disseminate information by  Linking users and developers.

Coordination

       The National Environmental Technology  Panel was organized to meet the first
objective, coordinating government efforts.  According to a Congressional research service
report, there are over ten different agencies within the Federal government that have a
combined total annual spending of over $4 billion for environmental technology.  The
report illustrated that it was difficult to  specifically determine how this money  is being
spent.  The  Federal Coordinating Council  for  Science  Engineering and  Technology
(FCCSET) has developed a panel within its existing structure to coordinate environmental
technology efforts throughout the government.  The Clinton  administration has already
designated this panel, which would act as the National Environmental Technology Panel.
The  panel aims to find  out what is already being done by Federal agencies and to create
a budget crosscut  of all the dollars that are being spent on environmental technology
today. From this information, FCCSET will develop a national strategy for addressing our
critical environmental technology needs, indicating where we need to start investing our
dollars. This strategy will form the basis for a research agenda for the future.  Each year
the panel will review the budgets of those separate agencies requesting environmental
technology funds as one single budget request.  Joint reporting will maximize coordination
efforts, reduce duplication, and enhance the goal of a national strategy for environmental
technology.

Funding

       Environmental technology development is consistently  suffering from a lack of
venture capital.  Venture capitalists tend  to be conservative; therefore, the high risk, high
pay-off ventures often do not get funded.
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       Bureau of Environmental Technology

       The National Environmental Technology Act addresses the funding issue through
provisions for the Bureau of Environmental Technology and the Environment Innovations
Research Program. The  Bureau of Environmental Technology, located at EPA, would be
a focal point for the development of environmental technology.  It would be modelled after
successful government programs such as the Advanced Technology Program (ATP) at the
Department of Commerce and the Advanced Research Projects Agency (ARPA) at DOE.
These  tend to be non-bureaucratic agencies which  are  nimble and can  fund the
development  of  innovative technology projects focusing on  pre-commercial, product-
oriented research and development. The proposed appropriation levels for this project are
$36 million for the first year (FY 94), and $120  million in the third year.

       To encourage public and private partnerships the bill requires that 95 percent of
the money appropriated to this bureau be spent outside the Federal government in private
and  public partnerships.  Developing a public and private  partnership  requires a 50
percent match from businesses  (25 percent for smaller businesses).  In addition, more
projects will be conducted in coordination with other Federal agencies. The bill contains
a first-year waiver, allowing 10 percent of these  dollars to  be spent within the Federal
government for start-up  costs during the first year. There have been complaints that EPA
is a regulatory agency and not a technology development agency.  EPA's first priority is
regulation; however, the agency spends over $100 million per year on environmental
technology. The agency has experience and is well positioned to anticipate the future
regulatory agenda and, therefore, the environmental technology needs of the country in
the future.  The bureau director must work  with the heads of other agencies such as ATP
and  ARPA.

       Environmental Innovation Research Program

       The purpose of this program is to advance both clean-up and pollution prevention
technologies.  The program is specifically geared toward commercially viable technologies.
This program uses the Small Business Innovative Research (SBIR) programs model, which
is proven  in  developing successful ventures and technologies.   It uses a carefully
structured, three-phase approach to set aside dollars for programs. The Environmental
Innovation Research  Program is  funded through money that would have  been used to
clean up sites within the federal government.  The costs of federal cleanup have been
estimated in the billions and as high as $1 trillion over the next  thirty years. This program
will  tap 1.25 percent of the funds that would be appropriated for cleanup and these funds
would be spent in the private sector, to develop technology for the cleanup of these sites.
This is necessary to reduce future costs and to provide solutions for those sites which we
currently do not have the knowledge or technology available  to clean up.  The scope of
the Technology Research Program is not limited to cleanup technologies, it also includes
pollution prevention technologies.  The development of new technology  for pollution
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prevention is also in the interest of the cleanup endeavor, since prevention technologies
will result in  less pollution to clean up in the future.

Reduce Market Barriers

      Technology Verifications Program (EPA)

      The goal of the Verification Program is to break down the barriers of performance
and equipment standards by setting up a program within  EPA that would verify new
technology developments.  It is difficult for developers to get into the market when their
technology is not trusted. There exists a need for a credible  third party to verify the cost
and performance  characteristics of new technologies under tested conditions.  This is
needed to combat  the inertia to employ the technologies used to develop the performance
standard.  In practice, the permit writers look at the background  document to find  the
backbone  process upon which  improved performance is  based  and then utilize this
technology.

      EPA's development of  verification will provide the regulated  community  an
introduction  to new  technologies and  simultaneously give credibility  to  the new
technology.  Therefore, the regulated community will have greater flexibility in choosing
technologies to be implemented.  The program  would rate a new technology versus  the
technology upon which the performance is based. EPA would look at the technology and
verify cost and performance. The  result will not be a "Pass/Fail" endorsement, but a
description of how well a  technology compares  to the regulatory line.  A verified
technology will not  guarantee  compliance with  the  standard for  users  of the new
technology; it will provide a  verification of how that new technology performs.  During
the review of technologies, those that are pollution prevention approaches are  favored.

      Innovative Technology Testing Program (EPA)

      Another barrier to the development and marketing of new technologies is the lack
of adequate testing facilities.  The issue of liability stands as a huge barrier when a new
technology is in need of demonstration or testing.  Risk averse companies do not want to
take on this  liability  and, therefore, do  not  promote  testing at their facilities.  The
Innovative Technology Testing Program builds on the existing EPA Superfund Innovative
Technology  (SITE) program, which  focuses on cleanup.   The  SITE  program  allows
developers of new technologies to  come  on-site and demonstrate  how their new
technology works.  The Federal government should expand this program to  include
Superfund sites and other federal facilities.  The testing provision intends that the federal
government  assumes the risl^ for the development of innovative technologies.
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Disseminate Information

      Coordination between EPA and NIST

      The National Institute  for  Standards  and Technology  (NIST), Department of
Commerce, has a network of manufacturing technology development centers.  There are
currently seven existing centers, expected to increase to 100 in the next budget year. This
increase  offers an incredible  opportunity  to spread the  news  about environmental
technology.  We feel that this is one of the most effective ways in which to distribute this
information about environmental technology. The current focus of NIST facilities is to help
small businesses improve their manufacturing processes. This program proposes that these
facilities could simultaneously  help businesses with their environmental strategy.  EPA
should be connected with this network.  The bill also has provisions to connect EPA with
the Agricultural Extension Centers.

       Clearinghouse

       All of the information developed under this act will be collected and distributed
by  a clearinghouse.   It is  our hope that this will get  the information out to  small
businesses.  The program will  possibly  promote exports to other countries and provide
information  to technology developers on the sources of technical and financial assistance
that they can access to help export their products.

       National Environmental Technology Advisory Council

       This council will be part of the existing NACEPT council that EPA already operates.
The concept behind the program is to bring private sector and non-government expertise
involvement into these technology programs.  The program seeks to combat the criticisms
that bureaucrats are picking winners and losers while they have no idea about real market
forces. This is a fair criticism  and  that  is why it is important to bring into this council
people from business and academia  who really understand the market forces that are
driving decisions.

Remaining Challenges

      This bill is only the first step on  a  long road of environmental technology in this
country.  Japan's Ministry of International Trade and Industry (MITI) has taken an interest
in this bill. This is encouraging  because it indicates that we must be doing something right
to draw such esteemed international interest.  The largest remaining challenge is to  break
down some of the barriers between business and government. We need to stop wasting
money and  energy fighting each  other and  focus on our shared goals of a  cleaner
environment and a healthier bottom line.  Environmental technology is a means for both
government and industry to achieve our goals. We need solid ground rules to direct our
efforts. A regulation should be tough, but it should also be reasonable and flexible. The
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importance of focusing on incentive systems so that we can go beyond the regulations
cannot be stressed enough. The Amoco situation, where there is no incentive for Amoco
to stick its neck out and take action because they run the risk of not doing enough by the
standard of some future regulation, is a shame. We need to find ways to build in both
incentives and flexibility.

       All the economic indicators point to a strong environmental technology industry
— on which we need to capitalize.  We need to become a world leader, and to do that,
EPA, industry, environmental groups, and Congress need to work together. The National
Environmental Technology Act provides a good start for such cooperation.
          Robb  Lenhart,  Director  of Business  Services,  National  Environmental
          Technologies Applications Corporation (NETAC), began  by endorsing the
          leveraging of which Mr. Harper spoke. Many of the issues discussed at the
          conference are being dealt with in this legislation. Mr. Lenhart expanded on
          NETAC's role in helping small businesses get new, innovative technology into
          the market.

History of NETAC

       NETAC was founded as a partnership of industry, government, and the academic
community; it recognized that many of the solutions for the environmental industry must
come from different  segments, not just from industry alone.  Created in October of 1988,
NETAC is  a subsidiary  of the  University of Pittsburgh  Trust.   At  that  time  EPA
Administrator  Lee Thomas came to Pittsburgh  and spoke with the University about
establishing this type of program.  It was recognized that the SITE program was beginning
to provide a forum  for providing the  operating and cost data for new environmental
technologies.  What  was missing at that point was the commercialization assistance that
many individual entrepreneurs and small-  to medium-sized companies needed to take
their  technologies successfully to the  market.   NETAC was  established  to focus on
providing this commercialization assistance.

       NETAC is a non-profit organization that accelerates commercialization of priority
environmental technologies. NETAC operates on an annual budget of approximately $1
million, as part of the start up fund from EPA. Fulfilling this mission  means identifying
the technologies which are available, and then providing the services needed  to move
those technologies successfully into the marketplace. An important lesson learned in the
past five years of operation is that NETAC must do more than just help the  companies
who are developing new technologies;  it must also assist the end users who are seeking
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innovative ways to solve their problems. NETAC now offers product and information
services on emerging innovative technologies to help users get access to the available
technologies.

Air Pollution Controls in the Market

       Earlier in the  conference we heard about the overwhelming need for innovation.
The need for new technologies drives  market opportunities.  A market survey was
conducted  by the Environmental  Business Journal,  showing  that air pollution control
represents a market of $5-$6 billion per year over the last four years.  (Numbers that you
may hear from EPA of $20-$30 billion differ due to construction costs not included in the
costing by the Environmental Business Journal.)  The overall annual cost for environmental
goods and  services in the U.S. is  approximately $135 billion, with air pollution control
representing a large part of the total. Air pollution control costs are even more  significant
when one looks at the projected growth: in the 1980s, averages of 12-15 percent growth
for environmental costs were normal; projections show 5-7 percent averages for the 1990s.
Air pollution control costs show the highest projected growth.

Need for Innovative  Technologies

       One needs only to  look at  the remediation side of the current marketplace to see
how things stand.  Over 40 percent of the technologies currently being identified for site
reclamation work are innovative, emerging technologies. This number has increased by
about 10 percent over the past three years.  The same trend is true for the air pollution
control business. Looking at the sites on the National Priority List (NPL), one sees that the
reason that approximately one-quarter of the sites appear on the NPL is because of their
air impacts. The potential exists for many chemicals or compounds to become airborne.
This is a serious problem demanding technologies that can address this issue. What does
this mean in  terms of new business for companies in the air pollution control field? A
study by the BT1 consulting group identified new service offerings for environmental firms
in 1993; approximately one-fifth of all new proposals for this year from the environmental
field deal with the air segment.

       Venture capitalists are also good indicators of the business in environmental
technology. A survey by the Environmental Business Journal looking at the level of interest
of investors showed that — compared to eleven other areas in the environmental segment
— interest  in air pollution control ranked  third. Interest in air pollution control  has
increased while resource recovery has decreased, the latter resulting  from recycling and
reclamation programs that have not been as economically successful as expected.

What Does This Mean for an Industrial Company Financially?

       It is important for industrial companies to recognize that environmental technology
development  and commercialization can be a successful process.  NETAC compared four
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separate companies in the air pollution control field, looking at financial performance
figures, annual sales, compounded annual growth rates over a three-year period, operating
profit margins, operating profit/sales, the return on equity, the net income based on
average shareholder equity, and the price-to-eamings ratio.   As  a general rule,  if a
company achieves operating profit margins greater than 8-10 percent, or if the company's
return on equity is in excess of 20  percent,  the company is  doing fairly well.  Some
companies in  the  past,  however, continued to achieve these  levels year after year.
Comparing the air pollution control industry to other environmental control segments with
regard to employment level, employment  figures for air pollution firms have increased
while other environmental organizations are in decline.

       NET AC recently compared different environmental segment niches and illustrated
a qualitative ranking for sales growth  rate, operating profit margins, and financial stability.
In general, air pollution  control ranked  in the top  two or three  segments in  the
environmental  field.  Other segments that  ranked near air pollution  control were
remediation and water/ wastewater treatment, all representing good returns for companies
who are involved.

What Does NETAC Do?

       NETAC's efforts  in commercialization

       Initially, NETAC was set up to encourage commercialization. This endeavor began
by breaking down the continuum of technology development into  a number of stages.
NETAC uses a six-stage  model based on participants, commercialization factors, success
criteria, and an "activity balance" between technology and business  factors.  NETAC
maintains a micro approach to  solving some  of  these  technology commercialization
problems.  NETAC analyzes the players  involved:  technology professionals, business
professionals, users, suppliers, financial investors, and regulatory personnel. NETAC  also
looks into how each tends to get more or less involved as development progresses from
the initial idea or  proof of concept  stages through  prototype and  pilot  development,
demonstration, and commercialization activities.  NETAC has developed success criteria
for each stage that must be fulfilled in order to move forward successfully to  the next
stage.  Different commercialization factors  utilized in the process are technology, market
factors, competition both within the U.S.  and abroad, and business and  management
issues.

       NETAC's research shows that more companies fail due to a lack of attention to
business   issues than to  technical  considerations.   Generally, small  companies or
entrepreneurs do not focus enough on business.  Sometimes they have spent millions in
development and  then  find themselves asking, "Who needs this?" or  "Where  is my
market?"  Many technical successes are business failures. How can the business issues be
properly addressed?  The point is that there are some key levels of accomplishment that
need to be addressed as one moves through the development process. Both technical and
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business factors need to be dealt with at every stage of the process.  In the beginning,
companies too frequently neglect business factors — there is a trade-off.

      NET AC, as a new group dealing with technology commercialization, has been able
to look at some of these issues from the business side.  With this perspective NETAC has
been able to help companies deal with commercialization. NETAC identifies the barriers
to commercialization and develops strategies to get around them. NETAC hosts seminars
and  conferences to offer strategies for  avoiding barriers.   "The  Valley of Death", a
schematic illustrating different types of financing applicable to the technology development
process, was introduced from a DOE publication. The valley illustrates the difficulty of
accessing the proper funding at the appropriate time during the development process.
Clearly, as you move from stage to stage in development, the need  for funding changes.
NETAC has identified many sources of funding for entrepreneurs by developing lists of
venture capitalists who work in the environmental field, and by creating relationships with
corporations  where, through  corporate partnering,  we help entrepreneurs get their
technologies demonstrated and developed.  There are many  different avenues that can be
pursued in obtaining funding; NETAC tries to offer  these  financing options in a clear
manner to businesses.  NETAC  does not have actual  funding from the EPA to support  the
development process.  In  most instances, NETAC has been involved  in  technology
development and demonstration activities supported directly by the client organization.
When investors are looking at an organization, they  are primarily concerned with: (1)  the
business operation; (2) the potential for turn-around of profit; and (3) technology. Good
profit margins and a proven track record for the organization are important.

       Technology Information

       Another large aspect of  NETAC's capability is technology information services, as
it is  important to disseminate technology into the marketplace.  NETAC has a database
called ETAP  which has nearly 2,000 emerging innovative technologies.   The Vender
Information System for Innovative Treatment Technology (VISIT) database of EPA has
about 300, but is more focused, whereas  the NETAC database is more comprehensive in
selecting new solutions.  NETAC provides another technology information service called
"Product Profile", which consists of a two-page description of technologies that have been
developed from  vendor  information.   Approximately 250  technologies  have been
developed in the past 2-3 years for this service.  The Product Profiles include process
descriptions, technology applications, operating parameters of the  process, and vendor
information.  NETAC has no investment or equity interest in any of the technologies —
this  is  purely  a service  to offer technology information to businesses  looking  for
environmental technologies. NETAC does independent confirmation tests to screen  out
"fly-by-night" technologies from this Product Profile service.

       NETAC  also offers technology  evaluations, independent assessments,  and
demonstrations that illustrate that a technology can work.   NETAC has developed test
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protocols for products that have been applied to oil spill clean-ups, and also offers business
evaluations, market assessments, arid industry analyses.

       In summary, there is a connection between what we have been trying to accomplish
here — the seed that was planted five years ago by EPA — and some of the initiatives
described at this conference. We believe that this illustrates how we can work together to
solve some of the most pressing U.S. environmental problems.
           Dr.  Joseph Ben-Dak, Chief,  Global Technology  Group,  United Nations
           Development Programme (UNDP), deals with technology transfer, adaptation,
           and conversion  of military technologies  to civilian markets.   His remarks
           focused on the international view of sustainable development.

           Most of the developing countries do not have an organization like NET AC, nor
a technology assessment or dissemination program, nor even a Clean Air Act.  Nor is there
any chance of such a regulation in the near future.  These countries, therefore, have very
little of the regulatory function that is taken for granted both nationally and regionally.
Markets are applicable, under some conditions.  U.S. companies (correctly)  believe that
third world countries do not have the money to  pay  for their technology. This will not
change drastically, but you really can determine some sub-populations of interest from the
general group.

       Part of the reason  we are  going to  be dealing more with clean  air is because the
administrator of UNDP, Gus Speth, is speaking in a tone the rest of us like very much.
The idea that one can make  a living in a less developed country and at the same time be
very much in tune with environmentally sound technologies is beginning to be something
very much in fashion.

       There are essentially seven different  groups in which clean air technologies are
relevant, five of which are described below.  The UNDP is dealing with all these groups.
Group 1: Commonwealth of Independent States and Eastern Europe

       The Commonwealth of Independent States and many parts of Eastern Europe have
experienced extensive environmental damage to their air and water supplies.  These areas
require immediate action.  The people of each strata of the population in these countries
are beginning to become aware of the damage and there is a growing interest in obtaining
funds for the environment  from the European Community.  These are not good years for
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the European Economic Community,  but, there is  a  great deal being  attempted by
European corporations.

      Now is the time to pull in U.S. technology. We must use a great deal of Japanese,
U.S., and European companies and pull together the best technology solutions and services
from each.  There are currently over 170 requests to the UNDP from countries in Eastern
Europe. This represents a large sum of money that could be applied in the next five years
to environmental technology.

Group 2: China

      China represents a large percentage of humanity.  To put their population  into
perspective, there are factories in China with 80,000 workers that are considered "small".
There is a growing awareness in China of the issue of air and water pollution, particularly
in cities with both open and closed industrial parks. If one wants to do business in China,
the most important thing is not to go about it as a market, but to try to develop the
technology with the country, catering to its needs and its situation. Packages are made of
complementary  technologies by looking at what already exists  locally and pulling this
together with foreign technologies.  Approximately 20 percent of the military industry,
which currently produces  strictly  military products, will  be  totally  converted  to
environmentally oriented goods in the next ten years. There is an enormous amount of
research and development in this area. Unfortunately, these industries are not being given
a  fair chance by U.S. and other foreign countries to pull together local resources with
foreign efforts.

Group 3: Small Island States

       Small island states, which politically represent about one-third of the members of
the U.N. community, include Papua New Guinea, Indonesia, and others. These countries
consist of gentle, precarious ecosystems, and have a great need for technology.  There are
62 states defined as island states which are calling for technology. If one creates a wise,
careful coalition of technology, more can be done for these precious ecosystems  and
humanity because a large portion of the population lives on island states  or in seashore
areas.

Group 4: Newly Industrialized Countries

       The  large, newly industrial countries of Indonesia, Malaysia, and some larger
countries of Africa  such as Nigeria, are  an  untapped resource  for  products  and
collaboration opportunities in environmentally sound technologies. Africa, Latin America,
and other less developed countries represent one of the biggest  challenges because  they
are able to  fund little development.  One of the biggest challenges that one faces in
entering those markets is the so-called "appropriate technologies" and ways to reduce the
overall cost.
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       As "citizens of the world," we ought to look at these issues in addition to our local
concents.  This is a high priority for the next level of development. The U.S. needs to help
the UNDP develop standards internationally.  The relationship between what happens in
this country and what will happen in less developed countries is obvious.

       The issue of sustainable development indicates that we must focus on developing
environmentally sound technologies that are relevant in producing a living, as well as a
sustainable standard  of resources both internationally and nationally that makes  sense in
the long run.  That is, we must apply a lot of loving care to the questions of how the
environment and natural resources are being treated.  Many more countries today are
talking about these issues.  Ten years ago, no lesser developed  countries talked about
sustainable development. Even today, leaders of these countries still do not consider the
environment a priority,  but at  least  they recognize that the environment is a concern.
There is an element of support from other international organizations such as the Global
Environment Facility, the World Bank, the  Commission on Sustainable  Development
within the secretariat of the U.N., the UNKTAD, and the  UNEP.  The combined budget
for these  organizations  is $1 billion every five years.  This budget must be  applied
specifically to environmental issues especially dealing with sustainable development. This
is particularly relevant for the lesser developed countries of the world.

Group 5:  Cities and  Super-Cities

       Cities and super-cities — composed of large critical masses of over 700,000 people
typically operate under a built-in economy of scale to apply technology.  The people in
these cities are aware of the importance of the environment, because they have seen it
destroyed. The large population makes it necessary to buy services for the people in these
cities, and in doing  this create a private/public combination that makes  sense  for  the
situations  in these cities. There are no less than 20 large cities which have asked  the
UNDP for assistance. They are seeking mid-course  correction of their current situation.
These cities are open to technologies, open to utilizing debt, and intend  to take these
actions in  the near future.

       Often the military is the most logical partner because military personnel are already
technically oriented.  The military leaders understand technology from being involved in
weapons and military equipment. Many military leaders understand that their role in the
world may change. Some critics say that the UNDP  is doing  too much with the military,
that it is not fashionable at this time. They do not understand that, as in Daniel Webster's
story, "You must work with  the devil to kill  it."  There are approximately 42 different
military groups  looking  to  redirect  their energy and manpower.   The more  you tie
technology and innovations to these communities the more success you will enjoy. Many
assume that the private sector is ineffective in less developed  countries. In many of these
countries they are so interested in the technology they ignore the infrastructure and quality
control. Source reduction technologies are far better than control technologies. Pollution
prevention is a key concern for the regions. All should remember that we are first citizens
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of the world and  that  we  should work  together to  improve the  economic  and
environmental situation across the world through technology application.


Questions and Answers
a
         It seems that throughout the conference people have been speaking about control
         technologies as either a light green or dark green technology.  Can you explain
         the difference?
People use both of these terms broadly to describe technologies which reduce pollution,
including source reduction, control technologies, and pollution prevention. As Mr. Harper
described earlier, dark green technologies are those created with the intent of improving
the environment, light green  technologies  are those which  reduce the threat to the
environment as an incidental bonus.
         In Georgia, entrepreneurs speak about incubation centers that generate sustaining
         revenue and lock in technical support.  To what extent have your organizations
         thought about this approach?

 Mr. Mohin stated that although he has thought about this approach, it is not included in
 the legislation.  He  looked at a similar program at Iowa State University.  Mr. Lenhart
 indicated that it was a process which could be factored in, but that NET AC does not run
 any  special programs as of yet to deal with this issue.  Many programs focusing on
 business deserve greater attention.
         How does government coupling with innovative technology effect investments
         in research and development?

         Mr. Nikkila pointed out that 87 percent of over $100 million spent in California
 has been on California companies.  Mr. Mohin added that we are making progress in
 change, but we still have a long way to go.  We need a better way to combine the bottom
 line.  Corporations are not in the environment business, they are in the money-making
 business.  From Congress' standpoint we  need  to make it  part of  the  bottom line by
 promoting tax  incentives, tax  credits, and taxes  on  hazardous waste generators.  Mr.
 Harper indicated that the political environment is changing across the world. Similarly,
 there is change in corporate culture.
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        A statement was made earlier in regard to industry not  wanting to be
        innovative.  Who is coming to the SCAQMD? Are they vendors for off-the-shelf
        technology?

Mr. Nikkila explained that under the RECLAIM program, innovators are given a goal, such
as a law, around which to focus their innovative efforts.  The RECLAIM program also
encourages innovators to sell and, thereby share, what they have developed.
         When  speaking  about breaking  the  barriers  to  technology innovation, you
         mentioned that technology verification would not guarantee compliance.  Does
         this mean that verifiers would have a separate set of standards?

Mr. Mohin responded that there is a need to compare existing technology with regulations.
Moving away from specific regulations, verification is more of a credibility check.  EPA
would provide  information to prospective consumers that  the  technology has  some
legitimacy.  In other words, using an EPA "verified technology" does not mean that EPA
is guaranteeing its use will automatically ensure compliance.  EPA has the responsibility
to help drive technology.
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                                Page 177
                          Session 5 — Panel C
                          Export Promotion
                          September 9, 1993
                           9:30 a.m. - 11:30 a.m.
                          Moderator:
                          Panelists:
Richard A. Wegman
Rodney Sobin
Lewis P. Reade
F. Bradford Smith
Introduction

       Richard A. Wegman, Partner, Garvey, Schubert, and Barer, noted that the U.S. is
almost twenty-five years into the "modern environmental age," exemplified by the fact that
much of its environmental technology is now second generation.  As a result, American
companies are well situated to take advantage of a burgeoning international market for
these technologies and services.  The market, currently estimated at $30 billion  for air
pollution control technologies alone, is projected to grow substantially by the year 2000 to
as much as $80 billion.

       In light of these statistics, the panelists were asked to address several topics during
the course of their presentations:

       •     What more can government, at all levels (but  particularly the Federal
             government), do to promote exports and American companies that wish to
             serve this market?

       •     Are the efforts of the different Federal government agencies involved in this
             area well coordinated? If not, how can coordination be improved between
             and among the  agencies?

       •     [For the public  sector panelists] What is President Clinton's Inter-Agency
             Strategic Plan going to look like and what sort of results can be expected?
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Presentations

           Rodney Sobin, Analyst,  U.S. Congress, Office  of  Technology Assessment
           (OTA), began his remarks by highlighting a current OTA project, provisionally
           titled "American Industry and the Environment," which is examining trade,
           the environment, and competitiveness. Several reports have been or currently
           are being prepared for this study:

       •      Trade and Environment:  Conflicts and Opportunities (released May 1992), is
             a background paper that examines the relationships between trade practices
             and laws, and environmental concerns and regulations.

       •      Development  Assistance, Export  Promotion, and  Environmental  Technology
             (released September 1993), discusses the use of environmental aid, and
             includes the use of environmental aid to promote exports of environmental
             technologies.

       •      The third report, a final assessment scheduled for release in  November
             1993, will address competitiveness of the environmental business services
             sector,  and  analyze the  effects  of environmental  regulations on  the
             competitiveness of U.S. manufacturing.

       Mr. Sobin provided a brief overview of the organization of export promotion in the
U.S.   The  Federal export  promotion and  financing apparatus  is  complex, with
responsibilities divided among numerous agencies. Some of the programs and initiatives
of the Federal agencies that have primary responsibility for promoting U.S. exports and
related investment abroad are as follows.

       •      The International Trade Administration  (ITA) of  the  Department  of
             Commerce operates the U.S. Foreign and Commercial Service, a network of
             U.S.  regional  offices and commercial  officers  overseas, and a  Trade
             Information Center.  ITA also distributes information via trade data banks,
             electronic bulletin boards, and  publications.  Its responsibilities include
             gathering and disseminating market data and trade leads, providing export
             education, facilitating trade missions, shows, and connections between U.S.
             companies and  potential customers abroad.

       •      The Export-Import Bank (Eximbank) promotes exports by accepting credit
             risks  that are unlikely to be accepted by private lenders. It provides credit
             insurance, loan guarantees, and some direct loans to finance U.S. exports.


             The Overseas Private Investment Corporation (OPIC) provides loans, loan
             guarantees, political risk  insurance, and other services to private  sector
Session 5C — Export Promotion

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Clean Air Marketplace 1993                                            Page 179
             investors for financing  investments  in  developing and  middle-income
             countries.   OPIC  hopes  to  establish an  International  Environmental
             Investment Fund.

       •      The  Trade and  Development Agency (TDA) funds pre-feasibility  and
             feasibility studies conducted by U.S. firms for projects in developing and
             middle-income countries. TDA also supports technical assistance, training,
             and trade events.

       Support for activities like TDA's is important because U.S. involvement at planning
stages increases the likelihood of winning design, construction, and project management
contracts, as well as providing  opportunities for the export of manufactured products.

       In addition, other agencies support environmental export activities even when it
is not their primary mission:

       •      The U.S. Agency for International Development (U.S. AID) supports and
             administers many  programs  including the  U.S.-Asia  Environmental
             Partnership, the Environmental Credit Program, the Private Investment and
             Trade Opportunities program, and the Bureau for Private Enterprise, in
             addition to  supporting  other activities such as feasibility studies, trade
             events, and environmental training.

       •      The  Department of Energy (DOE), active  in promoting cleaner energy
             technology trade and transfer, administers an Export Initiative Program,
             leads the interagency Committee on Renewable Energy Commerce and
             Trade (CORECT), and provides technical assistance capability.

             The Energy Policy Act of 1992 authorizes U.S. AID and DOE to lead export
             and technology transfer initiatives for renewable energy, energy efficiency,
             and clean coal technologies to developing countries and Eastern Europe.

       •      The Environmental Protection Agency (EPA) plays a role as a provider of
             technical expertise. EPA also helped create the U.S. Environmental Training
             Institute, whose courses are designed to allow U.S. companies to showcase
             their environmental products and services  to foreign private and public
             sector  officials of developing countries while providing training  and
             technical assistance. EPA also recently developed a Green Pages directory
             of environmental firms.

       A number of states have developed significant export promotion programs that in
some cases target  environmental  products and services.  They have taken a growing
responsibility for export promotion by posting representatives overseas, planning  trade
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events, promoting export awareness and education, providing advice on financing, and
passing on trade leads. States can also help businesses gain access to Federal services.

       Many private sector organizations such as industry associations also work toward
increasing environmental exports by helping coordinate public and private efforts.

       Other efforts such as objective, independent performance evaluations of U.S.
environmental technologies could be used to  help  speed the diffusion of innovative
technology domestically  and promote  exports of U.S. products.  Programs like the
Superfund Innovative Technology Evaluation program for remedial treatment technologies
could be used as a model for expanding into pollution prevention and control technologies
of interest to industry and utilities.

       Responsibility for the problems of export promotion lie with both the public and
the private sectors.  Industry needs to recognize  that reaping the rewards of exports takes
significant effort, time, and expense, in addition to developing an export culture within the
company products and services often need to be adapted to the needs of foreign markets
and practices. However, an environment with multiple agencies and programs has led to
poor coordination, program duplication, and a lack of overall  strategy. The low level of
awareness in the private sector (and sometimes, the  public sector) of what services are
available and how to access them is also a problem.  Several initiatives are underway to
attempt to address these issues, although many  face the same  problems as the programs
and agencies they represent:

       •      An interagency Trade Program  Coordinating Committee (TPCC):  to
             develop an overall export strategy; along with an environmental subgroup
             to develop an environmental export strategy.

       •      An Interagency Working Group  on  Environmental Technology:  to
             develop   strategies  to  further  environmental  exports,  technology
             development, and technology diffusion;

       •      The  Trade  Information  Center (Commerce):   to direct  inquiries to
             appropriate agencies;

       •      Trade and Investment Services Center (U.S. AID) and Export Promotion
             Initiative (DOE): to provide coordinated services to U.S. exporters;

       •      CORECT (DOE): to provide coordination for renewable energy exporters;
             and
Session 5C — Export Promotion

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      •      The U.S.-Asia Environmental Partnership:  to coordinate environmental
             exports, technology cooperation, and investment in the Asia-Pacific region.

These initiatives should assist in improving agency coordination.
          Lewis  P.  Reade,  Director  General,  United  States-Asia  Environmental
          Partnership (US-AEP), United States Agency for International  Development
          (USAID), began his presentation by noting that USAID recognized early the
          relationship between economic development and  the  environment.   The
          environment is a major issue in developing and newly industrialized countries
          for a number of reasons. For example, the environment is a major component
of sustainable development. The poor, who are the focus of economic development efforts,
usually suffer the most from environmental degradation. From an economic development
standpoint, a strong economy supports a good environment, and a good environment
supports strong economic growth.

       The two principal goals of the U.S.-Asia Environmental Partnership are to:

       •      Work with U.S. and Asian governments, non-governmental organizations,
             and the private sector to identify and address environmental problems that
             prevent sustainable development and sustainable economic growth.

       •      Provide  technology  transfer   opportunities for  U.S.  producers   of
             environmental technologies and  services.

       USAID does not underwrite specific projects, but rather provides the "software"
that needs to be in place so that American companies can take  advantage of the Asian
market.  To  that end, US-AEP provides information (in the form of relationships, and
technical information and  training), networking opportunities, and access to  financing
related to these technologies.

       Asia, a vast region supporting over half the  world's population and many of its
resources, is experiencing rapid population and industrial/economic  growth,  and
consequently some serious environmental crises. Studies  show Asia is already having a
major impact on global air quality, and the situation is expected to worsen.  USAID hopes
to help improve conditions in the thirty-four developing and newly  industrialized Asian
countries which are part of this partnership. Therefore, there is a role for U.S. businesses
to play in helping Asia address and remediate the negative environmental trends.
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       US-AEP's  role is one  of  coordination.  It supports  the  environmental  and
commercial efforts of other agencies with core funding, currently $100 million over five
years.  The partnership expects these core funds to leverage significant contributions from
the  U.S.  and  foreign  governments,  private  sector  companies,  non-governmental
organizations, and multilateral  development institutions.  Through US-AEP, substantial
business opportunities are created for U.S. technology, goods, and services.

       US-AEP expended about $4 million, originally for organization and now for project
start-up. All of the current projects are less than a year old; some are only a few weeks
old.  They estimate that their work thus far has generated in excess of $50 million for U.S.
companies.

       US-AEP's theory  is that a  system is necessary in order to help companies; this
system focuses on four major components, and some supporting activities.

       •     Creating   links   between  American  companies and potential  foreign
             customers that lead to business opportunities in the long run.

       •     Underwriting companies that go out to demonstrate their technologies.
             Examples  include  efforts currently underway  in cooperation with the
             Department of  Commerce,  and similar  activities  with the National
             Association of  State  Development Agencies  to open nine Offices of
             Technology Cooperation.

       •     Helping companies that have opportunities in Asia to seek trade financing.
             An arrangement with the Bankers Association  for Foreign Trade and the
             Commerce Department will help towards this end. US-AEP has established
             an 800 number for those in the industry to call to find out which banks are
             prepared to meet their export financing needs for environmental goods and
             services.

       •     Developing a  "one-stop" phone network  called  the  Environmental
             Technology Network for Asia.  Such a network would contain trade leads
             generated   by  the  technical  overseas  representatives,  plus  all  the
             environmental laws,  regulations and current  practices  of the Asian
             countries.

US-AEP also hopes to generate interest among larger commercial banks to  coordinate with
OPIC and the Environmental Development Fund to provide equity financing for American
companies. Three banks have already signed on, and arrangements are being made with
several others.

       Biodiversity conservation is another area in which US-AEP has become involved,
by producing education  in the practice of sustainable harvesting of non-timber forest
Session 5C — Export Promotion

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Clean Air Marketplace 1993                                            Page 183
products and coral reef products.  A consortium composed of the World Wildlife Fund,
the Nature Conservancy, and World Resources, Inc., and others, are involved in this effort.

       America needs to rethink  its  attitudes  and business  practices  to become more
oriented towards international trade.  Marketing environmental goods  and services is a
highly technical and engineer-oriented process; they are not like standard commodities that
we are used to trading. Five years ago, only 8 percent of the U.S. GNP came  from trade;
today it is 12 percent. Currently, only 1 in 11 American business persons have passports,
compared with 1 in 2 British, and  practicaDy every Dutch business person.

       US-AEP is involved in sponsoring a variety of projects specifically in the clean air
marketplace, such as a conference on reducing pollution in mega-cities on the Pacific Rim,
a joint project with EPA and IBM to help the Koreans address the problem of CFCs, urban
pollution  monitoring in Hong Kong, and dealing with  bus  emissions and  electrifying
vehicles in Nepal and Thailand. They believe that the U.S. has significant technology to
help in activities like these, technology that came about and is improving as a result of the
Clean Air Act Amendments.
           F. Bradford Smith, President and CEO, Environmental Elements Corporation
           (EEC), noted that his remarks would respond to some of the data presented
           by the other panelists to provide a context for discussing how the government
           can promote  environmental exports.    He  provided  some  background
           information on the history and nature of EEC's business.

       Mr. Smith disagrees with the OECD's estimate of a $30 billion market for American
 environmental products. For example, in their 1992 annual report, ABB, one of the largest
 suppliers (as measured  by revenues) of air  pollution control equipment in the world,
 disclosed world-wide revenues of only  $540 million for these types of products.  This is
 less than 2 percent of the world market as defined  by OECD.  Some of the statistics
 deserve further scrutiny.  Other issues that affect  American entry into world  markets
 include:

       •      The world  market for  environmental  goods  and  services  is highly
              fragmented. Most industrialized nations have companies in this field with
             significant, proprietary technology.  As a result,  this is an internationally
             well-populated,  highly qualified, and competitive marketplace.
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Page 184                        	Clean Air Marketplace 1993


       •      "Need" and "market" are not synonymous.   Most of the statistics (like
             OECD's) are based on need, which in some cases, i.e.,  Eastern Europe, is
             very  obvious.   However, the need  for  goods  and  services  does not
             necessarily create a market.  First, there must be the ability to get through
             a process, outlined as:

                     dream —> vision -> policy —» plan -» program —>
                     prospect -> project -» bids —> contracts -> work

             This requires technical skill, administrative management, skillful  policy
             making, and substantial funds. Currently, there is a great deal of need, but
             very few markets.

       •      The money must be indigenous to the geography in which  the need arises.

These factors greatly complicate what is required of American  government and industries.

       Assuming a supporting  industry technology and interest to enter the  world
marketplace exists, along with governmental policy, American companies also have specific
needs:

       •      Profits — however, the investment cycle for international "prospecting" is
             several  years, at best.

       •      Established business relationships — Mr. Smith concurred  with Mr. Reade
             that international business is far more dependent on and influenced by
             personal relationships  than it  is in the U.S.  American companies are  in
             danger  of being  viewed and  treated  as  opportunists  when  it  comes  to
             bidding on project-specific opportunities.

       •      Export  culture — Mr.  Smith also agreed with  Mr. Sobin's  comments that
             there needs to be private sector responsibility for increasing this culture
             within their companies.

       •      A relatively  stable  or thriving domestic marketplace for a company's
             products and services — Because of the investments required, an industry's
             ability to export is dependent on strong demand at home.

       This last point leads to a key issue that had not yet  been addressed.  The U.S.
domestic air pollution control marketplace, to the extent that it is being  influenced by Title
IV of the Clean Air Act, is a great disappointment, in part because of reasons  subject to
Federal policy and regulatory process influence.  This has to be examined  as a component
of export promotion policy.
Session 5C — Export Promotion

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Clean Air Marketplace 1993                                            Page 185
       American  government  and  industries  must  face  the  reality  of the role  of
government financing and how this helps our international competitors.   Currently,
American industry is not  equipped to  compete in the international marketplace with
foreign  companies whose  governments are using  financing capability as  a domestic
economic development tool. Financing can be a key component that may distinguish one
country's efforts from another, despite equal technological expertise.  This is a policy-level
issue that the government must address.

       In addition, Federal policy needs to be much more specific and recognize that we
are dealing with a crowded  world  marketplace.   In order to  deal with  the market
effectively, the U.S. needs a much stronger and more buoyant domestic market. Countries
export the technologies, products, and services in which they excel.  This can only come
about as a result of a strong domestic market that has provided both the demand and the
competition to hone these components to a world-class level.

       Barriers to the domestic market are few but they can and should  be addressed as
a national priority by both policy and regulatory people at the state and Federal levels.
Questions and Answers
     L
f%  I
 •   |
         Can you provide some theories as to why the domestic market for environmental
         goods and services is so soft, and what might the government do to strengthen
         it?
Mr. Smith explained that industry has not been purchasing many of these goods and
services mainly because the government has not enforced the Clean Air Act Amendments
of 1990 in a complete or timely manner. This resulting atmosphere of uncertainty among
industry, despite the self-enforcing deadlines laid out by Title IV, has led to the attitude
that the deadlines do not mean anything. Some industries are not complying, and are
prepared to wait and see what happens. In addition, there is the continuing recession that
American industries have yet to recover from, despite  what economic indicators may
show.  Lastly, there has been a serious lack of coordination among Federal and state
regulators.  Their differing concerns, air quality (Federal) and rate setting (state), have not
been resolved as they pertain  to environmental compliance costs,  a  major  issue for
industry. Being able to recover their costs is significant for industry, who want reasonable
assurance that this will happen before making extensive  capital investment.

         What do you think can be done — by both the private sector and the government
         — to stimulate greater awareness and interest in overseas markets among U.S.
         companies?

Mr. Smith stated that the government's efforts to help American companies are extensive,
but are too unfocused.   There is no qualitative screening of data and information, and
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Page 186	^	Clean Air Marketplace 1993


companies get overwhelmed and discouraged.  Project development money is another
lacking  item that would greatly help companies.   Such funding would  go towards
feasibility studies very early on, typically long before proposals or specifications are issued.
This type of "soft" money is something most companies cannot afford; however, some
foreign governments support their companies in this manner. American companies often
work on projects where the feasibility studies have been done by another country, and are
subsequently forced to play "catch-up."  Therefore, getting into a project early on can be
key.

Mr. Reade concurred  with Mr. Smith on several  of his points.  However,  he strongly
disagreed with Mr. Smith's argument that a domestic base is necessary for export culture.
Many newly industrializing countries market products in the U.S. that they do not sell in
their own countries. Strong companies that can afford to engage in long-term prospects
by maintaining a continuing presence in a country and establishing relationships to create
a market for their goods are the ones that will succeed. Technology products designed for
use in the U.S. cannot always be applied [in the same form] in another country (e.g., using
an  expensive computer to perform tasks  for which another country might rely on
inexpensive labor.)

Mr. Smith responded to this by distinguishing between a company trying to  sell leftover
products, versus having a base market on which to build.  The environmental business
within the U.S. has not measured up to expectations, and companies are feeling the effects.
He  is not aware of a major technical breakthrough generated by the U.S.  in the last ten
years. To illustrate this, he noted that  50 percent of the scrubbers installed as a result of
the Clean Air Act were  of European design.  Exports will not make up for a lack of a
domestic market, because without this market, the products and technology will not be at
a world-class level, and consequently, internationally competitive.

Mr. Sobin commented  on several different issues raised by the other panelists.  First, U.S.
foreign assistance is often relatively less capital intensive than for other European countries
and Japan. The U.S. typically provides money for rural training and agriculture,  which
are not as export intensive as projects like power  plants or sewer  systems, which  other
countries are likely to  assist.  Therefore, the issue of development assistance  may be one
worth examining.  In addition, the appropriateness of a technology in a given marketplace
is important.   American  products often  have a reputation  for  being  too  complex,
sophisticated,  and  expensive,  and  after-assistance  is   often poor.    Lastly,  most
businesspeople  are unaware of where to go to get information. There is a whole export
promotion structure set up, but it in him has not been very well marketed.
Session 5C — Export Promotion

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Clean Air Marketplace 1993                                            Page 187
a
        Stronger environmental regulations have been promulgated in Europe.  How is
        this related to the fact that 50 percent of scrubber technologies are developed in
        Europe?
Mr. Smith responded that the initial blossoming American market for particulate control
and scrubber technology was a result of the Clean Air Act of 1970 and the amendments
in 1977. That market became dormant in 1981, and has not made a comeback since 1990.
In the meantime, strong acid rain regulations were being passed in Scandinavia, Germany,
and Japan. As a result, the second generation of scrubbing technology moved overseas,
primarily to Germany. This is the technology that has moved back to the U.S. in response
to the Clean Air Act of 1990.  This anecdote strongly illustrates why it is important to have
a strong domestic base.
  f% I
   •  I
^•^^"
guy?"
         Many small environmental technology companies face problems that bigger
         companies do not; how is the government qualifying the information and leads
         they make available to companies; is the government and its programs (i.e., the
         nine overseas export offices discussed by Mr. Reade) capable of helping "the little
 Mr.  Reade answered that small- and medium-sized firms  usually do not have the
 discretionary funds that are necessary for market, sales, and product development.  The
 job of the technical representative, in addition to making contacts with buyers, distributors,
 intermediaries, etc. and gathering information,  is to be  responsible for qualifying the
 people and companies that they believe would be of interest  to American  firms.  These
 representatives,  both Americans and foreign  nationals,  have been  hired for their
 backgrounds, which typically include engineering and sales.  Representatives may also
 eventually identify lead agents in the host countries who  would be  responsible for
 qualifying the contacts/

 Mr. Sobin explained that while these representatives will help the situation with small- and
 medium-size firms, they still cannot replace face-to-face contact. Intermediaries cannot set
 up arrangements with distributors or joint ventures — both for cultural and  legal reasons.
 They can smooth the way and reduce costs somewhat, but it is still a costly and uncertain
 risk.  However, they can cut down on  the time investment that would be involved
 otherwise.
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Page 188                                            Clean Air Marketplace 1993
         Would the weaker U.S. dollar provide any advantages for export opportunities,
         and is this of consequence in the immediate term?

         Mr. Smith felt that it does not seem to hurt or help; most hardware is being
produced locally and the role that U.S. firms are playing at the moment (start-up, process
and detail engineering) does not translate into a huge portion of the  money that is being
generated.   In  addition, the manufacture of engineered products  (as an example) is
becoming increasingly international as companies move parts of their operations around
to different locations world-wide where they can be done at the lowest cost. Lastly, many
of today's contracts are being denominated in dollars, particularly in the Middle East.
Session 5C — Export Promotion

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Clean Air Marketplace 1993                                          Page 189
                            Keynote Address by
                            Donald A. Deieso
                            President and CEO, Research-Cottrell
                            Companies

                            Introduction by Robert Brenner, Acting Deputy Assistant
                            Administrator, Office of Air and Radiation, U.S. EPA

                            September 9, 7993
       Of course as all of you are aware, it is one thing to have these good ideas and
another thing to have people like Steve Harper who can really make them happen. And
it is a lot harder to make them happen than it is to have a good idea. So as Carol Browner
said yesterday, we are very grateful to you for putting this together and doing such an
excellent job.  One of the very nice parts of my job at EPA is the opportunity to work with
some very creative, innovative, and dynamic people who are involved in this effort to
implement the Clean Air Act. You have heard from a number of them over the last couple
days and you are about to hear from another, Don Deieso. Don is the President and CEO
of the  seven  Research-Cottrell Companies.  They are one of the oldest and largest air
pollution control firms in the United States.  He is also now Executive Vice President of
their parent firm, Air and Water Technologies Corporation.

       We asked  Don to speak not only because of his central role in the Clean Air
Marketplace,  but because  he  has a  fairly  unique prospective:  he  has personally
participated  in  just about every  side  of  this marketplace.   He  has  been Assistant
Commissioner for Environmental Management and Control at the New Jersey Department
of Environmental Protection. He has been the Chief Chemical Engineer for ConEd in New
York, where  he was responsible  for corporate environmental science and engineering
activities. Prior to that, he actually developed waste treatment systems at ConEd.  Notice
that he really has some technical skills as opposed to a lot of us "policy wonks" who are
involved  in this area.  He also worked for EPA.  He directed hazard remediation in our
Region II Office. He has also done a stint in academia where he has done some teaching
on environmental science at Rutgers University.

       Over the past few years, Don has been a member of our Clean Air Act Advisory
Committee and that is where we at EPA  have learned that not only have his experiences
made him unusually knowledgeable and  insightful on air pollution issues, but he also has
not hesitated  to speak very directly to us about the right way to implement the Act.  To
my way of thinking, what could be a better combination  for a conference speaker — he
knows what he is talking about, given his experiences he really  can relate to all of you,
and I can confidently say he will tell it to you straight.
                                          Keynote Address — Donald A. Deieso

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Page 190                                           Clean Air Marketplace 1993
Address by Donald A. Deieso

       Rob, thank you very much.  Steve, let me first commend EPA once again for an
outstanding conference. This started out as a very small group but, as I understand now,
it is a record attendance of over 300 and that is to your credit, finding a niche and filling
it and letting this activity grow.  As  a  former  EPA-er,  I am extremely  proud of the
accomplishment.

       As a high school student back in New Jersey during the late 1960s, I remember a
number of public hearings on the proposed sulfur-in-fuel air regulations that were very
controversial  at that time,  and I  remember distinctly the loud opposition raised by
industry.  Adopt these, they argued, and we will be out of business. The regulations of
course were adopted, business continued, and life went on.

       During the implementation of the 1977 Clean Air Act Amendments, I served in a
advisory role to EPA on the development of specific new source performance standards.
The public hearings were no less contentious, and the theme of the 1960s echoed again in
the position of the regulated community who said "economy versus environment." They
created an illusion that the American people cannot have both.  During my tenure in New
Jersey under Governor Tom Kean in the  mid- and late-1980s, there was not a week that
went by that we were not visited by one of the Fortune 50 companies resident in our state,
and always the arguments were the same: If you impose this regulation, if you levy this
enforcement action against us, if you force this site cleanup, we will have no choice but
to leave the state.  In fact, so consistent was the pattern that it became known to the
Governor as the "caster appeal" (casters being those devices on the bottom of a  chair that
make it roll easily), so-named because  one would believe that the  major manufacturing
facilities in the state were on casters, and we would find them up and down the  New
Jersey Turnpike going to Pennsylvania  or going to Delaware or moving to wherever the
regulations were the least burdensome.

       For those of us who participated in the process leading to the 1990 Clean Air Act
Amendments, the subcommittee chambers resounded with overstated, poorly documented,
and  ill-supported statements by both sides of the debate.  Potential cost impacts of the
Amendments on the regulated community were consistently cast in billions of dollars a
year — reminiscent of Carl Sagan's comments about the  extent of the universe — and yes,
the "economy versus environment" debate was raised again and again and again. I would
like to report to you that, nearly three  years after the passage of the 1990 Clean Air Act
Amendments, the overall domestic air pollution control  market is smaller now than what
it was in 1989.  So we gather for this conference  this week, a conference entitled "Clean
Air Marketplace 1993," and we will discuss wonderfully complex and elegant topics such
as finance, public-private partnerships, and globalization of technology — and this is very,
very  good.   And yet, I hear the ghosts of thirty  years ago  in the "economy versus
environment" debate even today, and it causes me to wonder just how far we have really
progressed culturally toward the goal of improving our environment.
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      Our firm, along with others, participated in a study prepared by EPA last year on
the benefits to the economy of the Clean Air Act Amendments.  At the core of the findings
was the principle that the air pollution control act and business  would create jobs —
special types of jobs, high-tech jobs. This report was prepared presumably to blunt many
of the arguments made by the  regulated community that it  would cause tremendous
hardship on  the economy:   plant closures, displacement  of workers,  layoffs,  and
unemployment.  I suppose we can agree that this  logic would add up the jobs gained,
subtract the jobs lost, and declare this a victory for society. We could do that, but I search
desperately in that equation for  the parameters of public health and welfare the basis of
all of our actions.   More intriguing to me was the notion that environmental control
programs had to "pay their way" and had to be  measured in  a  traditional  return-on-
investment approach, the way  you would introduce a new product to a consumer
marketplace.  And yes, that might be the beginning stages of free enterprise as applied to
environmental programs. But we must clearly understand that we  have a debt to society
programs, we have quite a bit of affirmative action of 40 and 50 years of industrialization
to make up, and I am not quite  sure that analysis is proper in time.

       It has been clear to  me that economic prosperity is  a  prerequisite  for robust
environmental industry and business. In  fact, the past  two  years have  demonstrated
convincingly  that environmental firms are not recession-proof, nor are we recession-
resistant.  The capital structures of this country's major environmental firms  have been
severely damaged by the poor economic climate of the past two years. Stocks are at 50-60
percent of the value they enjoyed less than two years ago. These are the same firms that
this nation expects to invest in advanced technology demonstration projects and research
and development.  Well, be assured the money simply is not there. But as with Charles
Dickens — it was  the best of times, it was the worst of times — as depressed as the
domestic market has been, as interesting and exciting have the offshore opportunities for
these U.S.-based  environmental  firms been  for us in the past two years.

       Last February, in testimony  before the Senate Environment and  Public Works
Committee, I  presented  the five components which create a robust  environmental
marketplace:

       •      Strong laws and regulations;

       •      A  general will on  the part of the regulated community to comply with the
             spirit as well as the letter of the law;

       •      A  strong enforcement program;

       •      A  healthy national economy; and

       •      Cost-effective control techniques.
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All five, incidentally, apply as effectively domestically as they do internationally.  Let us
examine each of these separately.

Strong laws and regulations

       We have environmental laws and regulations in the United States.  We have
environmental laws and regulations throughout Europe and in many of the developing
countries of the Pacific Rim. In fact, one could argue these laws, when studied, are very
strong. The European Economic Community requirements promise to be as stringent and
in some cases more stringent than U.S. emission standards. Certain standards in Japan
have out-paced us here.  The  requirements for waste-to-energy plants, for instance, in
Japan are considerably tighter than those in this country.  International treaties have been
developed for greenhouse gases, biodiversity; all of those hint that we are globalizing, we
are making  more consistent, the environmental requirements country-to-country. More
impressive to us, there is not a client that we deal with based in the U.S. that retains our
products or services for work in developing countries that does not immediately say:   I
would like this facility, I would like that piece of equipment, to comply with U.S.-based
standards.  Notwithstanding that perhaps Thailand  or Malaysia may not have the same
stringent requirements today, they understand that the investment is a sound investment
for the future.

A general will to comply with the spirit as  well as the letter of the law

       There is a general will on the part of the  regulated community  to operate in
compliance with environmental standards. It has been in some cases less than consistent,
and I continue to be struck by the wide diversity of commitment.  Fortune magazine on
July 26 (a  few weeks ago) had a wonderful article in which they assessed the nation's top
companies and rated  them on the 10 worst, 10 best, and 10 most improved.   Without
names it was fascinating to see that among the 10 worst were multi-national, multi-billion
dollar companies that  for the last 10 years, by Fortune's review and discussions with those
corporate  officers, would indicate status quo.

A strong enforcement  program

       Most of us think of enforcement in the traditional sense of an EPA or state DEP cop
on  every corner.  And somewhere that notion is becoming obsolete.  Enforcement today
is now actually taking two facets — the first is of course traditional environmental
reporting  obligations in which the regulated community must come forward with their
moments  of non-compliance.  But there is another very subtle and very powerful force
building in enforcement on the financial side.  The Securities and Exchange Commission
in  its  regulation of  publicly  traded  companies  is  now  asking  for  disclosures of
environmental liabilities.  No longer in an annual report can a company hide the fact that
there is a $150 million site cleanup that it faces. The accounting community, the auditors,
the Price  Waterhouses of the country (i.e.,  the "Big Eight"), are also under pressure to
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Clean Air Marketplace 1993                                           Page 193
disclose, to ask the company to disclose, to find material in discussion with corporate
management those items that would suggest that there is an environmental exposure that
the company faces. This of course was highlighted a year and a half ago when one of the
Big Eight was sued by shareholders. They  were sued because they had knowledge that
the company was facing a $150 million exposure. The net worth of the company was $100
million. The environmental exposure was  clearly material, something the shareholders
needed to know, deserved to know, and by law had a right to know. And those elements
of enforcement in fact last year grew. Very quietly and subtly the SEC and EPA connected
databases so that now when EPA has an enforcement action against Company A that will
become immediately pa,rt of the SEC record on Company A and so the SEC will police those
disclosures to see that shareholders are well informed of any exposures that the company
may have.  That enforcement promises to be as  powerful,  if not  more so, than  the
Environmental Enforcement Officer at your door.

A healthy national economy

       We would benefit from a healthy, international economy. Here perhaps is the true
Achilles heel  to growing the environmental business. The U.S. is not the only nation
struggling with a sluggish economy; many of our fellow European allies and competitors
are locked in their own conflicts with deficits, unemployment, trade imbalances of many
sorts. In some cases and in some  countries — for example Eastern Europe, parts of the
Pacific, and Latin and South America — it is literally true to say that they cannot afford
to protect the environment and to heal and rehabilitate the environment. It simply cannot
be done.  We have operations in Eastern  Europe, and the devastation that we see is
something that I can  only imagine in the pages of our Donora, Pennsylvania, incident of
1948.  Some  areas  of  complete  deforestation, health records of local hospitals with
respiratory ailments  that would dwarf anything that London in the 1960s would have
offered.  And yet, these are the countries  that today simply  cannot afford  a scrubber,
cannot afford an electrostatic precipitator, or water and wastewater treatment.

Cost-effective control techniques

       In the same discussion in February, I said I found it increasingly difficult to define
what a U.S. environmental firm is.  Most of us sit here today with a notion that there is
a U.S. environmental business.  My own company, for instance, and almost every one of
our major competitors in this country, owns or is partially owned by an offshore company.
We compete in this country and abroad with environmental business firms that design and
manufacture the same basic categories of equipment; in fact, indistinguishable in the U.S.
is, a U.S.-based company. So,  in short, much of the globalization  that we speak of  has
already occurred.  There is not a firm without a major and/or significant ownership by a
firm from offshore. Similarly, there is not a technology in the U.S. that is not in some way
a hybrid of ideas that have been spawned in either Germany or Japan and that are in play
in our field today. So in short, there really  is not a U.S. company and there is not a U.S.
market; it is truly is  a global market.  Nearly 20-30 percent of our revenue is based in
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international business. Of that, more than half is sold and negotiated in the U.S. for multi-
nationals here to be installed and/or designed in other countries.  So more and more we
are seeing one massive incestuous group of competitors and technologies all in  play, all
improving and all benefiting, one idea for the other.

       Does this mean that our environmental business is condemned to chase country-by-
country and without any sense of U.S. identity? We think the answer is no.  We continue
to lead the world here in much  of the technology developed. There was a notion during
the last Presidential campaign that Japan and Germany had better ideas, that they were
well  advanced of anything that we have in this country, and we would benefit.  Let me
be very clear. The environmental program, the environmental technologies were born in
the United States.  We were treating wastewater before any  other nation.  We were
chlorinating wastewater in 1909.  We had the first electrostatic precipitator. We had the
first  scrubbers.  These ideas were spawned and  developed here  in the U.S., and that
leadership and technology continues.

Solutions to industry-wide problems

       We find ourselves, however, faced with a few major shortcomings.  Let me offer
some very practical solutions to the problems that our industry faces.

       •      First, the U.S. government must subsidize the expansion of environmental
             businesses in undeveloped and developing nations by providing  loan
             guarantees and access to capital at below-market rates  for very specific
             projects.

             >•       We and  a German partner were recently defeated in  a large
                     scrubber  project in Thailand by a Japanese firm. We were defeated
                     not because we did not have the best technology — in fact, we had
                     the number-one rated technology). When,  in the final moments
                     when that government came forward in Thailand and said, "but we
                     have no money for this project... you must finance it", we packaged
                     our best  financing through commercial  banks, but the Japanese
                     came in with financing backed by their government with complete
                     loan guarantees and, of course, it was something that we could not
                     match.

             ••       Similarly, in Mexico a year and a half ago, the Japanese government
                     advanced the Mexican  government $250 million for air pollution
                     and environmental control.  There was a hitch: the work had to be
                     done by Japanese firms.
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Clean Air Marketplace 1993                                           Page 195
             These are marketplaces that U.S.-based companies have developed, have
             spent quite a bit of time and energy, and have wonderful technology to
             play.  But U.S. companies do not have a level playing field by any measure.

             Second, investment tax credits need to be offered in this country for all
             of its environmental technology purchases — a well-trodden issue.

             Third, tax  credit for R&D  on  environmental  expenditures  and
             environmental initiatives.  We have wonderful technologies today that
             your public companies must expense.  For those of you who are unfamiliar
             with P&L and public finance reporting, it means that every dollar of R&D
             must be discounted against a profit.  Well,  those of you that are in the
             financial community study the profit and loss statements and operating
             statements of the public companies in the environment today, and you will
             find many of them in major distress. That is not the condition under which
             one invests in R&D, and it is simply not going to be  made easy.

             Lastly, there are  accounting rules that could easily favor environmental
             research and development as an item that could be capitalized and enjoyed
             over the next 20 and 25 years.  Those two would be of tremendous help in
             freeing these companies to do  what they must do.
Conclusion
       In closing, let me suggest a few thoughts.  First and clearly, this technology of the
U.S.-based  companies is  more than competitive — in many  instances  it is superior.
Second, the quality of the engineers and scientists in the companies, universities, and EPA
rank among the top in the world. There is no doubt in that regard.  Third, we are at a
considerable disadvantage in the world marketplace because of competitors' government
backing and subsidies  and — perhaps no different than  the  Airbus in a non-related
industry — it is  coming home to roost here, and the prospects for the future are even
dimmer if we cannot muster government support.  If there are any questions that you
have, I would be delighted to entertain them.
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Page 197
                          Session 6
                          Connections Among Clean AirAct/ISTEA/Energy
                          Policy Act
                          September 9, 1993
                           2:00 p.m. - 4:00 p.m.

                          Moderator:    Susan F. Tierney
                          Panelists:      G.B. Arrington
                                       Joseph Goffman
                                       Michael Stanton
                                       Mary Margaret Whipple
                                       Ben G. Henneke
Introduction
       Susan F. Tierney, Assistant Secretary, Office of Policy Planning and  Program
Evaluation, U.S. Department of Energy (DOE), noted that there has been an upward trend
in ozone precursor and greenhouse gas emissions, oil imports, and vehicle miles travelled
(VMT) in the last few decades. Each of these upward trends is part of a common problem.
To paraphrase Secretary O'Leary, "It is the car, Stupid."  The Clean Air Act Amendments
(CAAA), the Intermodal Surface Transportation Efficiency Act (ISTEA),  and the Energy
Policy Act of 1992,  provide  an integrated response to  the problems  created  by motor
vehicle emissions.  These statutes begin to focus on issues that are critical to  reducing
motor vehicle emissions — improving fuel options, reforming motor vehicle operation, and
reducing VMT.  The three acts also provide an opportunity to fight vehicular  emissions
in a comprehensive  way while considering national security, the environment, jobs, and
economic  development.   Together,  the statutes  encourage innovation and  business
opportunities, as well as promise to combat negative air quality trends.
Presentations

           G.B. Arrington, Director of Strategic and Long-Range Planning, Tri-County
           Metropolitan Transportation District (Tri-Met) of Portland, Oregon, discussed
           how integrated land use and transit planning in Portland over the last twenty
           years have resulted in a more vibrant economy, as well as cleaner air and less
           traffic.  Portland's efforts can serve as a model for many other communities
           facing similar problems, according to Mr. Arrington. The success of Portland's
innovative public policy can be seen in its thriving downtown, smooth functioning transit
mall, and soon to be expanded urban light rail system. MAX, the light rail system, is in
fact part of an integrated plan to shape urban growth, move people around the area, defer
highway investment, and enhance the quality  of life.  Development dollars invested in
projects adjacent to the light rail line have exceeded the cost of the line by four-fold.
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       In the 1970s Portland's central city was dying. Expanding the public transit system
was chosen  over highway development as a key part of a comprehensive strategy to
promote downtown growth.  Before MAX started operations, Tri-Met buses accounted for
half of the rush hour trips into the city and one-third of all trips downtown.   Since MAX
began its operations, Tri-Met's market share of travellers has doubled. Today, one in three
people in Portland ride public transit at  least once a month.  Sixty percent  of riders are
choice  riders (i.e., individuals who have a car available).

       The success of this system has hinged on the cooperation between government land
use planners and the transit authority. This cooperation comes out of the belief that new
rail systems should not be seen  solely as transit investments, but must also  take into
account the community's vision of its own growth. The transit authority, for instance, asks
local governments along the rail corridor to help make development more dependent on
transit by limiting parking, widening sidewalks, improving pedestrian access, and allowing
mixed  use development. For its part, Tri-Met provides investment funds and assists local
jurisdictions in planning to stimulate economic development around transit stations.

       Public transit has been key to  the downtown investment strategy in Portland for
years.  Transit corridors have been spines for  growth, the most intense development, and
the lowest parking ratios.  The plan is to build downtown around public transit, and to
use it to shuttle people around Center City once they are there.  Since 1972, strict limits
have been set on parking in an effort  to create automatic demand for mass transit.   New
office buildings,  for instance, have strict maximum but no  minimum  limits on parking
space.

       Rather than wither away as critics predicted, the downtown has thrived.  Portland
has grown from having 56,000 jobs in 1975 to 86,000 today, an increase of over 50 percent,
while the number of cars entering downtown has not changed.  Portland would have to
add six new parking garages, each as tall as its highest building, if the city were to reduce
its dependence on  public transit.  In addition to saving resources, Portland's reliance on
public  transit has halted the growth in traffic congestion and has helped markedly improve
air quality.  Portland has gone from being out of compliance with national ambient air
quality standards two out of every three days in 1973 to having  100 percent compliance
in 1992. Portland has not had an air quality violation since 1987.

       Portland has been pursuing a balanced transportation plan. Rather than widening
highways to accommodate growth, the area chose to invest in public transit.  Portland has
not built a radial freeway or widened  any arterial highways in 20 years, and the city is in
the process of expanding MAX. In 1991 the State Land Use and Conservation Commission
passed a new transportation rule which is  designed to reduce  dependence on single
occupant vehicles.  It calls for a ten percent reduction in the number of parking spaces and
a ten  percent reduction in  VMT in the next twenty years.   The rule requires  local
governments to adopt land use and subdivision strategies within the next two years that
allow transit-oriented  development as a matter of right. The Portland metropolitan area
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Clean Air Marketplace 1993                                           Page 199
is  required to consider changes in land use  plans  in lieu of making  transportation
investments.  The state transportation plan reduced the need for state highway building
from $37 billion to $24 billion by assuming investments in public transit.

       The common thread in Portland's land use and transportation plans is the desire
to contain  growth: Portland  wishes to "grow up", as opposed to  "growing out", to
substantially  increase  density  in  transit corridors, and  to  help  ensure  that  new
development is served by public transit.

       Portland shows the dramatic impact that integrated land-use, transit planning can
have. Some examples are:

       •      The Transit Mall. This four block, $180 million mall is a prime place to
             shop in Portland. Light rail provides a  larger retail market, which has
             attracted stores.

       •      Lloyd's Center. A mall with 1.3 million square feet across the river from
             the  transit  mall  has been  renovated to take advantage of light  rail
             customers.

       •      The Oregon Convention Center.   An $85 million, 400,000 square-foot
             convention center was designed with mass transit in mind.  It has only 400
             parking spaces.

       •      The Arena.  A  $205 million, 20,000 seat arena has been built adjacent to a
             MAX station.  It has  only 3,000 parking spaces.

In sum,  7  million square feet  of  development,  valued at  over $1  billion, have been
completed  immediately adjacent to MAX stations since MAX was built.  Another  $440
million in new development has been announced.

       The lesson  to learn from Portland is  the value of  regional, integrated land-use,
transit planning with the force of law.
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          Joseph Goffman, Senior Attorney, Environmental Defense Fund, discussed the
          use of market-based approaches to achieve policy goals, which he contended
          can greatly complement the traditional comrnand-and-control approach. The
          CAAA, ISTEA, and the Energy Policy Act  provide examples of laws that
          integrate a variety of policy tools, including market incentives, for achieving
          their goals.

The CAAA institutionalized the conclusion that the market can be  used as  a  tool for
stimulating innovation.   The Act empowers state  and local  authorities to force new
stationary source technologies, new fuels, and new approaches to mobile sources.  Title IV
of the CAAA, the acid rain program, created the market for SO2 emissions. Mandatory
reductions on individual plants are made flexible with a market that allows plants who
reduce emissions by more than their standard to sell credits to those who do not meet
their reduction standards. Under a market system all utilities,  vendors, and consultants
constantly have an incentive to find new, better and cheaper ways of getting the job done.

       Another example of the use of market-based incentives in environmental policy is
the Energy Policy Act of 1992.  The Energy Policy Act addresses a wide range of issues,
including utility regulation and the diversification of motor fuels. One provision of the
Energy Policy Act creates a voluntary registry of firms that reduce greenhouse gas
emissions. Although greenhouse gas emissions are not yet regulated, the Energy Policy
Act creates several incentives to reduce emissions:

       •      Those  who expect  that greenhouse  gas  reductions  will  eventually be
             mandatory stand to  benefit by  having their  baseline  emissions and
             reductions recorded  now in the hopes of getting credit later on.

       •      The registry, by publicizing a firm's emissions reductions, could be used to
             a firm's advantage in public relations.

       Many of the actions taken to reduce pollutants in  response to the CAAA will also
reduce greenhouse gasses. The registry gives firms the option of telling the public about
the positive greenhouse gas reduction side effects that result from complying with the
CAAA. Those innovators who can reduce both CAAA pollutants and greenhouse gasses
will be rewarded by the marketplace.

       Together, the  CAAA, the Energy Policy Act, and ISTEA provide a much more
diverse policy framework to encourage innovation than traditional command-and-control
techniques. They provide a powerful inducement to firms to think about both greenhouse
gas and traditional pollutant management.

       The idea of using markets  for pollutant reduction  commodities is critical to the
success of clean air efforts. The CAAA offer a critical opportunity to expand the pollution
reduction  market.  States putting  together their State Implementation Plans (SIPs) for
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Clean Air Marketplace 1993                                            Page 201
ground level ozone have the option of creating a market for ozone precursor emissions
reduction.  As governments and polluters are developing pollution reduction plans, the
focus should not be limited to technology mandates, but rather should include market
frameworks among the tools for reaching compliance.
           Michael Stanton, Director, Federal Liaison Department, American Automobile
           Manufacturers Association (AAMA), spoke of the challenges the auto industry
           faces in trying to meet the demands of the CAAA, the  Energy Policy Act, and
           ISTEA.

           One of the major causes of difficulty is the differences among the three acts.
The CAAA have been debated and discussed in Congress for eleven years, while ISTEA
and the Energy Policy Act appeared on the scene much more recently.  The Energy Policy
Act and the CAAA also have different objectives; the Energy Policy Act's goal is to reduce
consumption of  oil, while the CAAA attack pollution.  The two acts differ on  many
smaller, yet very significant points as well, such as the definition of a fleet or classification
of certain fuels.

       The AAMA, in order to encourage alternate fuel vehicle (AFV) demand, wanted
an AFV exemption from transportation control measures (TCMs), such as high occupancy
vehicle (HOV) lanes, put into the Federal law. However, if this exemption were included
at the Federal level, states would not be allowed to count the air pollution credits in their
SIPs.

       In considering the CAAA and the Energy Policy Act, the AAMA wants what is best
for its customers — the closer the programs in the two acts are, the better.  Unfortunately,
sometimes compliance with one act is not compatible with compliance with the other. For
instance, the auto industry had originally hoped to meet the CAAA fleet mandates through
the use  of reformulated  gasoline, even though the likelihood of success of such an
approach is unknown.   The  Energy  Policy Act,  however, requires that many  fleets
purchase AFVs; reformulated gasoline is not considered to be an alternative fuel.

       The auto  industry currently faces several sets of requirements in addition to the
fleet programs in the Energy Policy Act and CAAA. ISTEA includes safety requirements.
The CAAA contains hundreds of requirements, many technology forcing, and many of
which  the auto makers do not yet know how they will meet. In addition, the CAAA and
Montreal Protocols require that the auto makers eliminate the use of CFCs, which affects
their production processes. The AAMA estimates that meeting Federal safety requirements
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adds $1,000 to the price of a car, with emissions controls costing an additional $1,600.
Controlling CFC emissions adds $125 to $150.

       Given all these requirements, the big challenge to auto manufacturers is to try to
promote  APVs,  and  make  them  compatible  with CAAA  requirements.   The auto
manufacturers are working with DOE, the General Services Administration (GSA) and the
Federal Fleet Conversion Task Force to try to jump start the use of AFVs. The difficulties
are not just in production. The greatest obstacle to overcome is the  lack of demand, which
threatens the sustainability of an  AFV program.  Congress intended government to lead
the way through Federal purchase requirements.

How Will Auto Manufacturers Supply the Vehicles and How Will GSA Purchase Them?

       Auto manufacturers have  been supportive of fuel-neutrality in the Energy Policy
Act throughout its development because they do not know which fuel will be the winner,
if in fact any single fuel is.  They would prefer to let the market decide.

       Each fuel presents certain advantages and disadvantages. For example, compressed
natural gas (CNG) is a very clean burning but space consuming fuel. As the Big 3 look
actively into all fuels, they are finding that the biggest challenge is solving market needs,
fuel  needs, and  vehicle needs  simultaneously.   Auto manufacturers are currently
developing and selling flexible fuel vehicles (FFVs) that run on M85 or E85 (methanol and
ethanol blends)  and  dedicated  vehicles that  run  on CNG  or  electricity.   Auto
manufacturers expect to sell FFVs that can run on ethanol, methanol or gasoline during
the transition period  to alternative fuels.  Such  vehicles can  be made to  run  without
extensive and expensive reconfiguration, but these fuels are not clean enough to meet the
strict final emission standards mandated by the CAAA. Electricity is a fuel option that is
clean enough to satisfy the regulations, but is very expensive. Two percent of all vehicles
sold in California in 1998, and ten percent by 2003, must be electric  powered.

       The manufacturers are approaching the AFV requirements differently.

       •      Ford has put a lot  of effort into FFVs, focusing on the Taurus, a mid-sized
             vehicle.  In addition, it is working on using liquid propane gas as a fuel on
             its light duty  trucks.  Ford is the only one of the  domestic  auto  makers
             working on a CNG powered passenger car, using the Crown Victoria.  By
             putting four CNG cylinders in the trunk and behind the back seat, Ford has
             achieved a driving range of several hundred miles. In the area of electric
             powered vehicles,  it is developing what Mr. Stanton calls a mini-mini-van.
             Ford has done everything possible to make the van feel like a  gasoline
             powered vehicle, including using a key rather than a button to start the
             vehicle and having the vehicle inch  forward when the brake is  released
             from a standstill. These improvements have centered around Ford's main
             concern in developing consumer acceptance of AFVs.
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Clean Air Marketplace 1993                                            Page 203
       •      General Motors  Corporation  had a Lumina FFV, but it is backing off
             production as sales have been poor. For CNG, General Motors is using the
             Sierra pickup truck because it has room for the fuel canisters that will allow
             a driving range that matches gasoline.  General Motors is also working on
             bi-fuel vehicles, and an electric powered passenger car.

       •      Chrysler has been working on a compact FFV for 1993-94, the Dodge Spirit.
             Like General Motors, it has chosen a larger vehicle for CNG.  Chrysler has
             the electric T-Van  on the market, which  sells for between $100,000 and
             $125,000.

What Are Auto Manufacturers  Looking for from Government and Fleet Customers?

       Auto manufacturers are looking for  purchase commitments.  It is expensive in
terms of capital and time to start  up a production line, and it is not economical to do so
without purchase commitments. The auto industry is also looking to narrow the scope of
vehicles that they will market as  AFVs. There are about 600  gasoline powered models
currently in the market, and only  a limited number will be able to make  the transition to
alternative fuels. Automobile manufacturers also want to focus  on certain areas of the U.S.
for the development of infrastructure. Commitments to deliver fuel must be made in order
for vehicles to be matched  with fuels. An example of a program attempting to do this is
DOE's Clean Cities program.

       Surveys say that people  are not willing to pay more for less.  Auto manufacturers
have  a responsibility to provide AFVs that will have the  driving range, operating
characteristics, and cost of a gasoline powered vehicle if these vehicles will be successful.

What Has Government Been Doing?

       In 1992 the Federal government purchased 6 models of AFVs.  Of the 3,100 vehicles
purchased, 2,600 were  M85 compact sedans.  GSA  has also  purchased predominately
compact gasoline powered sedans —17,000 of the 18,200 vehicles purchased were compact
sedans. Compact cars, however, do not lend themselves to CNG because they do not have
the capacity to store sufficient fuel to match the range of a gasoline powered vehicle.
Therefore the question is whether companies should  focus on  compact vehicles or try to
broaden the market.  Chrysler has focused on the compact vehicle because of the Federal
government business. Ford has opted for mid-sized vehicles  because that is what non-
government fleets purchase. Companies are also taking into account the fact that certain
fuels are better  suited to some areas of the U.S. than others, in their model development
calculations.
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What Needs to Be Done?

       •      Funding incremental cost:  The incremental cost of FFVs and AFVs over
             gasoline powered vehicles ranges from close to zero in the case of FFVs, to
             $4,000-$6,000 for CNGs, to $100,000 for current electric vehicle prototypes.
             Government support in lowering incremental costs will increase the size of
             the AFV market.

       •      Availability of alternative fuels:  Right now there are about  600 CNG
             fueling stations nationwide, and not all of them are open to the public. We
             need to make sure that they all operate the same way, the connections are
             the same, the pressure is the same, and the quality is the same.

       •      Driving range: Auto manufacturers need to solve the storage problems of
             CNG and methanol, which gallon for gallon only get you half as far as
             gasoline.

       •      Consumer education:  This is a huge challenge that many groups will need
             to work together to  meet.

       •      Fuel and fuel facility standardization: Government, fuel providers, and
             auto makers need to work together to set standards. For example, the units
             in which different fuels are sold need to be standardized.

       All of these problems must be overcome if the volume of vehicles and fuel sold is
to be adequate.  Finally, there are  many market and technology unknowns, such as fuel
prices, to be addressed.
           Mary Margaret Whipple, Vice Chairman,  Arlington  County  Board,  and
           Member, Washington Metropolitan Area Transit Authority Board, presented
           one example of how local and regional authorities are responding to ISTEA,
           CAAA, and the Energy Policy Act.

           The problems of air pollution and traffic are caused and experienced at a local
 level, and must be responded to at that level.  Local governments and citizens generally
 feel  they  know  their own communities best and want to be involved in  formulating
 responses to pollution problems. National policy must be particularly flexible to deal with
 the different needs  of rural and urban communities.  For example, the most important
 transportation priority for a rural  county in Virginia may  be paving roads or erecting a
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Clean Air Marketplace 1993                                           Page 205
guard rail, while improving mass transit may be more important to the urban counties.
ISTEA recognizes the importance of local response, and allows for strong local involvement
in implementation.  ISTEA also  recognizes the interconnections with the CAAA, and
provides congestion management and air quality funds for non-attainment areas.  ISTEA
congestion funds can be used for HOV lanes, traditional highways, public transit, bike
paths, or other modes of transportation.

       The Metropolitan Planning Offices (MPOs) have a leading role in deciding how to
allocate funds. The Washington MPO includes Maryland, Virginia, and Washington, DC.
In the first year that ISTEA funding was available, Maryland made its  funding decisions
at the state level while in Virginia a committee of local officials came up with a plan. DC
could not spend ISTEA funds because it was at its obligation authority limit. The Virginia
committee muddled through, trying to balance the need to give something to every area
with the need to use the funds where they would do the most good. In the first year, this
was done with little scientific data about likely air quality effects of different  programs.
This year more scientific data and agreements led to a smoother outcome, which involved
purchasing new buses for the metro system. This experience has shown that the flexibility
of ISTEA at the local level is a significant benefit but takes additional effort.

       Washington  is  a serious  ozone non-attainment area, and  is required to reach
attainment by 1999. The Metropolitan Washington Air Quality Committee (MWAQC) is
responsible for developing the air quality attainment plan (SIP) to reduce emissions by 15
percent. It consists of elected officials from the Washington area and regulatory officials
from Maryland, Virginia, and Washington. MWAQC has been meeting for more than a
year, quantifying sources of pollution and making long, unconstrained lists of possible
reductions, often without reference to cost per ton or feasibility.  Choosing which sources
to reduce, how, and by how much was complicated by regular revisions of emissions
targets.  In the last few months the committee focused on a shorter, more reasonable list
of possible reductions, and has now published a plan.

       The plan that was finally  agreed upon relies heavily  on required programs, such
as enhanced I/M and Stage E Vapor Recovery systems, and reformulated gasoline. Once
the preferred technical solutions  were exhausted, the remainder of emissions had to be
eliminated through paint and coatings and pesticide formulation regulations, TCMs, bans
on open burning, and episodic measures such as a prohibition on lawn mowing on poor
air quality days.

       Measures that require people to change their behavior must pass the common sense
test. Previous positive experiences with snow emergency routes and lawn watering limits
during water shortages demonstrate that episodic measures tan work.  Further emissions
cuts will require more  serious and expensive measures, such as additional TCMs.

       Ultimately this region will pay more attention to  land use  and transit issues.
Members of the Council of Governments have spent much of the last few years developing
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a plan  for regional  excellence,  which emphasizes coordinated land use  and  transit
planning.  At the moment local officials are much more informed about air quality and
health issues than the general population.  It has been difficult to generate public interest,
and education will therefore be a key to the long term success of any program.
           Ben G. Henneke, President, Clean Air Action Corporation, discussed common
           assumptions about vehicle use that have been built into 1STEA, CAAA, and
           the Energy Policy Act, and why he believes some of them are incorrect.  He
           then discussed some innovative  local solutions to improving air quality.

           Most assumptions built into the  three acts originated in the 1988 Alternative
Fuels Act, and some of them are faulty.  The first incorrect assumption is that VMT will
continue to grow at its historic rate.  VMT has grown in recent years because the car has
improved.  When a product improves or falls in price, people demand more of it. The cost
per mile of operating a  car  has declined over  the  years, and  cars  have  unproved
significantly.  Poor land use planning has exacerbated VMT growth, but the main reason
that VMT has increased is the steady improvement of automobile quality and price. Cars
in their present form, however, cannot get much better. A commuter, for instance, will not
spend another two hours a day in  his/her car because of its comfort.  Therefore, the
growth in VMT should slow.  Further, alternatives to vehicle use are growing, helped by
ISTEA. Highway funds are now going to different modes of transit.

       The second incorrect assumption concerns the viability of alternative fuels. Fuel
neutrality is not a realistic option because of the chicken and egg problem of lack of supply
and demand infrastructure. But even if one  fuel were chosen, the numbers simply do hot
work. None of the alternative fuels available  is as cheap and plentiful as  gasoline.
Gasoline is still  the cheapest option, even when taking into account the additional cost of
cleaning up the air that it creates. Even  if CNG were a zero emission fuel, it would still
not be economical.  Petrochemicals and home heating are more effective uses  of natural
gas.  This is bad news for the underlying assumptions of the acts.  The only chance for
alternative fuel to decrease our oil import dependence is if research drives down the price
of alternative fuel.

       Mr. Henneke discussed the example of a MPO that succeeded in  improving air
quality in spite of a lack of resources.  Its  strategy  had annual, seasonal, and episodic
elements. This city had been classified as in attainment because a recession brought down
emissions.  When  the economy began to pick up the city found that it was not eligible for
funds set aside  by the CAAA and ISTEA for cities with air quality and traffic  problems.
The MPO concluded that encouraging cleaner  gasoline was the solution  for which it was
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Clean Air Marketplace 1993                                           Page 207
easiest to build political support. The MPO asked the five gasoline suppliers in the area
to sell less polluting gasoline during the time of year that air quality was poorest.  Four
suppliers refused the first year, but Sun Companies provided leadership and this past year
all five agreed.

       Inspection and maintenance (I/M) is politically unpopular, and the state in which
this city is located was reluctant to impose  tougher I/M standards. The city managed to
get ISTEA congestion funds that, combined with corporate funding of 20 percent, was used
to buy mobile inspection  stations. These  stations  will be parked at the  offices of the
corporate sponsors, allowing employees to have their vehicles inspected while they are at
work.

       Episodic measures on high ozone days included free public transit and requesting
that people drive their cleanest car and do not fill up the tank.  Free mass transit has
resulted in a 50 to 70 percent increase in ridership.

       Another method of reducing mobile source emissions now being developed is the
elimination of toll bootH lines. The lines created by toll booths are in effect large stationary
sources made up of mobile sources.  In addition to idling,  many drivers slam on the
accelerator after paying, releasing large amounts of extra pollution.
Questions and Answers

         What sort of AFV programs is General Motors focusing on?
  ?
   •   I Mr. Stanton responded that General Motors is focusing on CNG. General Motors
 ^^™ is  the  industry  leader  in  conversions, although the legal  questions  about
 warranty requirements with conversions are an obstacle.
     U
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         Why did not the AAMA comment on DOE regulations based on the Energy
         Policy Act of 1992, sections 407 and 503, which refer to AFV data acquisition
         programs?
 Mr. Stanton responded that the regulations were brought to the attention of the AAMA
 several months ago.
     L
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 •   I
         What are examples of government policy working to increase innovation or
         create a need that innovators can fill, and how do these relate to the creation of
         a market for pollution allowances?
 Mr. Stanton responded that auto safety regulations are an example.  Auto makers were
 required to include passive  restraints on all  vehicles unless  two-thirds of the states
 required that passengers wear seat belts. Forty-two states now require that passengers
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wear seat belts, but most of the laws do not meet the specific requirements set by the
Federal government.  In the meantime, most cars are now manufactured with anti-lock
brakes and air bags because of increased consumer safety awareness,  a result of Federal
regulations.

Mr. Henneke added that in terms of creating demand for pollution credits, it should be
recognized that people respond to price signals, but they also choose to ignore them. For
example, many people choose not to buy generic cereal:  But the price of generic cereal
versus name brand or pollution credits versus on-system pollution reduction at least keeps
prices honest.  If people know the cost of a ton of reduction then they  can choose the
cheaper one.

Mr. Goffman responded that many baffles hide and distort true costs. Another example
is the employee trip  reduction rule, which  is unpopular and of unknown cost, but is
required.  Pollution credits are an easy solution, but sometimes the market does not work,
and buyers and sellers cannot discover price signals.

Mr. Arrington pointed out that technical solutions attack the symptoms, not the problems.
People want options not to drive and to have livable, vibrant cities. The  market has not
recognized this need.  California has given  up on land use  and transit planning.  It is
doing everything with technical solutions.  Cleaner cars are not a good solution.

Ms. Whipple responded that people do not drive their cars more because they are more
comfortable. They drive more because housing policy is creating a situation where people
live far from where they work.
7
         What did the oil companies do to clean up the fuel in the city Mr. Henneke
         described?

         Mr. Henneke responded that they reduced Reid vapor pressure.

         Why does Portland have a pollution problem and what can other cities learn
        from Portland?
         Mr. Arrington explained that Portland's weather and geography are much like
Los  Angeles' —  pollution is  trapped  in the basin.   Cleaner fuel, inspections  and
maintenance, a parking plan, and no new roads are the programs that have worked for
Portland.
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Clean Air Marketplace 1993                                            Page 209
         Can tour buses that travel between cities or across regions receive mobile source
         credits? Can a tour bus operator receive credits for buying cleaner engines, or
         only for running on alternative fuels?

Robert Brenner, in the audience, explained that EPA provides guidance, which localities
can adopt.  Credits are only available within those localities.   Within those  localities,
credits could then be sold.

         Are the  suburbs around Portland the same as those around other cities with
         large housing developments and strip zoning?
      L
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         Mr. Arrington responded that the urban growth area is legally limited.  Transit
service is offered to those areas with high density, mixed use only. Portland has strong
regional  plans and state support.  The state air agency sets  parking ratios regionally,
including the suburbs, as part of the SIP, to guarantee a level playing field throughout the
region.   The mega-store national chains  that  are  marked by large parking lots are
complaining, and negotiations are underway.
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                          Session 7
                          The Global Marketplace — Export Opportunities
                          September 9, 1993
                           2:00 p.m. - 4:00 p.m.

                          Moderator:    Donald C. Conners, Esq.
                          Panelists:     Russell Sturm
                                       Alvin Aim
                                       John Schofield
                                       Alan Scarsella
                                       Roger Strelow
Introduction
       Donald C. Conners, Esq., President of the Environmental Business Council of the
U.S., Inc., introduced the focus of this session: to raise the collective consciousness about
the opportunities for export of environmental goods and services that grow out of Clean
Air Act regulations and policies.  Mr. Conners noted that the session would  focus on
specific export opportunities and, in particular, how companies with competitive clean air
technological products and services could promote the sale of these goods and services
overseas.

       There are major initiatives  at the Federal level, both at the White House and in
Congress, as well as among the states, to promote jobs and the environment.  The White
House perception is that the U.S. environmental industry has a competitive advantage in
the global marketplace — there is an opportunity to create jobs in the U.S.  by helping
industry connect to overseas markets  and assisting in the  development of  worldwide
markets for  environmental goods and services.

       Some of the Federal initiatives were set forth in President Clinton's April 22,1993,
Earth Day speech:

       •      The  Federal government must engage in the purchase of environmental
             goods and services — these are referred to as "green" goods and services.

       •      The  government  must develop a coordinated  Federal strategy on  how
             Federal' agencies  might  work in  cooperation with the  environmental
             industry to connect  industry to markets.

       The White House has set  up a committee, led by Commerce Secretary Ron Brown,
to deal with issue of promoting the  environmental  market and particularly  export
opportunities. The committee, in a  series of meetings nationwide, recently invited industry
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Page 212	Clean Air Marketplace 1993


to come forth and suggest ways the Federal government could ensure a healthy domestic
industry, which is an important precursor to a healthy export industry.  The committee
will dissolve when it issues its report. The long-term sustained effort toward the promotion
of environmental  goods and services then will rest in the Trade Promotion Coordinating
Council, formally created by the Export Enhancement Act of 1992.

       Congress is currently engaged in a similar initiative to promote the export of
environmental goods and  services  in the global marketplace.  There  are currently four
major pieces of legislation  pending:

             The National Trade Development Act of 1993

       •      The National Environmental Technology Act of 1993

       •      The Environmental Technologies Export Financing Act of 1993

       •      The Green Tech Jobs Initiative of 1993

       The Office of Technology Assessment recently issued a report that pertains to
development assistance and linkage between the programs outlined in the legislation and
the promotion  of environmental technologies.   Hopefully, everyone will leave this
conference with an understanding of the need to assist industry in creating an effective
partnership so that companies will be better able to find and exploit market opportunities
worldwide.


Presentations

          Russell  Sturm, Program  Director  of Private  Sector  Activities and  the
          International Institute for Energy Conservation (IIEC), spoke about the energy
          efficiency component  of the industry  and discussed  the  global  market
          opportunities his work has identified. A publication put out by IIEC, entitled
          Seizing the Moment, characterizes the industries, identifies export opportunities,
          and describes U.S. government activities already in place to assist the energy
efficiency industry.

       Exporting is a definite opportunity in which U.S. manufacturers have a competitive
advantage.  An example  of this is the significant potential for exporting refrigerator
technology to India as,it continues to develop.  India currently  has 15 percent annual
growth in  the  demand for refrigerators, and  the  potential for continued growth is
considerable. In ten years, for instance, the Indian market will equal the U.S. market, and
in 22 years it will be four times that of the United States. In addition to this growth, the
Indian demand  for high efficiency U.S. refrigerator technology will also expand since most
of the  refrigerators currently in the  Indian market  are  relatively inefficient; improved


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Clean Air Marketplace 1993	Page 213


energy efficiency will be necessary for India to prevent current problems created by power
shortages that constrain industrial growth.  U.S. refrigerator  firms  therefore have a
significant opportunity in India, which is especially important since the U.S. refrigerator
market already has 99.9 percent penetration.

       Second, The World Bank projects that during this decade, $1 trillion in capital will
be required to meet the electricity infrastructure demands of the developing world. At the
same time, there are $230 billion available from traditional sources of capital to meet that
demand. Therefore, there is going to be a 75 percent shortfall in capital required to meet
the demand or else more cost effective means must be used to provide expanded energy
services.

       Another dynamic affecting this market is environmental constraints — especially
CO2 reductions.  With  global treaties limiting CO2 emissions, the only way economic
growth can occur is through the use of new technologies that will allow us to reduce the
generation of electricity at the same time as we expand energy services.

       The energy efficiency industry is difficult to characterize because it is fractured into
different pieces without a unified identity.  It does, however, include the following:

       •      Energy.services companies

       •      Building environmental control industries

              HVAC

       •      Building products

       •      Industrial and process controls

       •      Motor adjustable speed drives

       •      Automobile sub-sectors

       •      Agricultural sub-sectors

       •      Lighting manufacturers

       •      Window manufacturers

       •      Household appliances

       Each sub-sector of this industry is represented through a trade association. Even
within  these  sub-sectors there  are  "sub sub-sectors".   For example,  wood window


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manufacturers,  aluminum  window  manufacturers,  and  vinyl  manufacturers  are
represented.   Though  the  energy  efficiency  industry  has  many specialized  trade
associations, there does not yet exist a unifying umbrella organization that speaks on
behalf of all efficiency companies.

       What is the size of this energy efficiency industry? It is difficult to tell just how big
it is because oftentimes, the industry is not recognized as an industry unto itself. There
is an approximately $18 billion dollar per year U.S. market for energy efficient  products
and services.  There is currently an $84 billion dollar global market.  If,  however, energy
efficiency products represent an alternative energy resource, there is a trillion dollar per
year global marketplace because they are substitutes for traditional resources.

       What domestic forces have caused this tremendous growth in the energy efficiency
market?   U.S. utilities have recognized that energy efficiency  products  and services
represent an alternative means of delivering energy services, in part because regulatory
reforms have allowed them to profit by investing in the delivery of energy services in the
least cost manner.  With a long-term investment  perspective, a utility makes decisions on
purchasing power plants with paybacks of 15-20 years. The utility can provide added
energy services at a rate of two and a half cents per kilowatt hour by investing in  the more
efficient refrigerator, for example.

        An example of U.S. government involvement is the Golden Carrot Program where
EPA  brought utilities  together to  come  up  with $30 million  — as a reward to
manufacturers of refrigerators — to bring a more efficient refrigerator technology into the
US economy beyond DOE standards.

       The energy policies of the U.S., such as regulatory reform for the utility  industry,
and  the encouragement of efficient energy are spreading  globally.   This is because
environmental and economic constraints dictate the use of energy efficiency in expanding
the delivery of energy services necessary to fuel economic growth.

       In Thailand, for instance, there is 10 percent  growth in electricity demand growth
each year.  There  is simply not enough time or capital to build power plants at  that rate.
To avoid economic growth constraints, Thailand needs to  find  ways of expanding its
energy  services that can  be  rapidly  implemented.  It  has  adopted Demand  Side
Management (DSM) as a response, and has made a $189 million commitment to DSM in
the next 5 years. Thailand has also created  an $80 million per year annual fund to finance
energy efficiency investments. The fund focuses on lighting, refrigeration, building design,
and  industrial  motors.   These are  all technological innovations dominated by  U.S.
industries.

       Another example of an export opportunity that involves technology in which the
U.S. has advantages is in Mexico. Mexico is currently developing the largest demand side
management demonstration in the residential sector.  This January, the Mexican national
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Clean Air Marketplace 1993                                           Page 215
utility is procuring one and one half million compact florescent lightbulbs.  This is the
largest procurement in the history of the lighting industry. This initiative is based on the
superior energy performance of compact florescent light bulbs. The Mexican national
utility's investment will be $20 million, in the first stage of the project.  The government
of Norway is investing an additional $4 million because they are interested in the potential
carbon offset benefits of this program down the line. The relevance to the private sector
is clear. It is the largest procurement 'in the history of the industry for a technology in
which the U.S. excels.

       Some of the main barriers  between these export opportunities and the  energy
efficiency  industry are:

       •     Lack of recognition of opportunity

       •     Lack of government  perception of opportunity

       •     Lack  of government organization  and  finance mechanisms to assist the
             industry

       The Committee on Energy Efficiency Commerce & Trade (COEECT), mandated by
Congress  last winter in the Energy Policy Act of 1992, coordinates the various activities of
the Federal government  to promote energy efficiency.  In effect, DOE is looking for
guidance  from the industry.

       The International Institute for Energy Conservation (UEC), Alliance to Save Energy,
and the American Council for an Energy Efficient Economy have had preliminary meetings
with industry representatives to establish a "Business and Energy Efficiency Advocates'
Consortium." to provide a unified, guiding voice.

       In  1971,  the U.S. had a new technology in hand known as VCRs. We invented and
initially produced the technology. Twenty years later, the U.S. exported $65 million worth
of high-end VCR equipment. At the same time, it was importing $1.5 billion worth of this
technology from Japan. We are on the edge of opportunity with the efficiency industry;
the global market is on  the  verge of explosion.  Environmental impacts and  capital
restraints  on infrastructure investment limit growth in the energy sector. We have a very
strong domestic energy efficiency industry. The opportunity is out there.
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          Alvin Aim, Senior Vice President  for SAIC Corporation, focused on three
          aspects of the Clean Air Marketplace in relation to exports:  (1) the Clean Air
          industry itself; (2) participating in the industry; and (3) how the government
          could assist the industry in the area of exports.

          In the mid-1970s, two very important technological developments occurred
that were influential at the start of the domestic air pollution control market:  (1) EPA's
regulatory posture resulting ultimately in industry  adopting the stack-scrubber as a
technology to  deal with sulfur oxides, and (2)  the  1970 Clean Air Act requirements
resulting in adoption of the catalytic converter  as the main VOC control technology.

       The prospects for the air pollution industry are great (even with increased U.S.
emphasis on hazardous waste and other issues  that are less pressing to large parts of the
world) in part due to the devastating air pollution problems in Central/Eastern Europe,
Mexico City, as well as  U.S. cities.  The market is  great — especially in developing
countries, and  the U.S. has a strong technological position.

       However, entering the  environmental export  business is  difficult and time
consuming.  Things are often done very differently elsewhere;  personal relationships are
often much more important.  Oftentimes that means placing someone in another country,
which  is an expensive undertaking.  Therefore, the  early years are a very expensive
education.

       What can government do to help the environmental industry?

       •     The  government needs  to  spend more money  to  find  out what our
             competitors are doing.   This could  be helpful in the formulation of
             government policy.

       •     The government also  needs to create more mechanisms to help establish
             personal relationships between U.S. business and foreign business (e.g., via
             trade missions). Commercial attaches at the embassies could be helpful as
             well.

       •     The government should establish exchange programs to bring more foreign
             visitors to the U.S. to investigate U.S. products.

       •     The  government should target  more expenditures up front.   It  should
             provide help to countries around the world to develop their indigenous
             environmental capabilities.

       •     Feasibility  studies are particularly effective.  These  would  provide an
             opportunity for U.S. firms to develop specifications on which to bid.  If the
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Clean Air Marketplace 1993                                            Page 217
             feasibility studies  are  done  by competitors, we will have  very little
             opportunity to bid on the subsequent work.

             Intelligence is key.  We need much better intelligence in foreign markets.
             The government needs to develop some policy for promoting U.S. firms at
             embassies.

             As far as financing is concerned, the government can provide money and
             information to help firms get started but, ultimately, the success is really up
             to individual companies.  The industry needs  to  work  together, be
             aggressive, and share information on what works and what does not work.
           John Schofield, President  and  CEO of Thermatrix, Inc., presented his
           observations as a technology developer for a new company.  His company has
           developed a flameless thermal oxidation technology which he claimed will
           have a major impact in the marketplace as a replacement for incineration. This
           technology was introduced for the first time  in September 1992.  Thermatrix
           had immediate success in getting orders for equipment using this technology
in the U.S. market.

       Initially Thermatrix had only $250,000 for this development. Thermatrix appeared
at one conference per month for marketing purposes, and began receiving domestic orders.
They immediately started manufacturing equipment.  In early December, they began to
receive foreign inquiries, but were unable to service them due to lack of funds. It is very
expensive to open an export market, especially when funds are limited.  In checking with
all of the organizations that assist in exporting, nobody could provide any assistance with
the up front market development.  A business can only get a loan if  their company is
profitable.  Unfortunately, Thermatrix was not profitable  because it was still growing and
profits were funnelled back into the company. Basically, there was no way to get any
money from any export agencies to assist in these exports.

       The inability to get funding to develop a company means that piece by piece you
begin to  sell the company  overseas.  What the U.S. is doing, instead of exporting goods
and services manufactured here, is exporting technologies and companies.

       Thus,  Thermatrix received  several foreign inquiries about its  newly developed
technology, and several countries wanted to purchase units to be  shipped overseas and
installed.  Because Thermatrix did not have the funding nor the infrastructure to do this,
the first step was to sell some of the company equity to a venture capital firm representing
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the government  of Singapore.  Then, Thermatrix entered into a licensing agreement
whereby they would receive the funding from forward royalties in exchange for allowing
manufacture  of  units with  Thermatrix's technology  for installation  in  Sweden and
Germany.  The same thing occurred with Samsung of South Korea. Once again, however,
Thermatrix did not have the funding to service inquiries. Thus, Samsung set up an agency
to import the units; they sent an agent to the U.S. at  their expense be trained on
Thermatrix technology equipment; Samsung is also paying  50 percent of costs  at an
upcoming exhibit in South Korea.  Still, however, Thermatrix could not  get any financial
assistance  from U.S. organizations to assist in exporting.

       The Belgium government approached Thermatrix and offered $2 million to establish
a manufacturing  and engineering facility in Belgium to help service the European market.
Again, however,  Thermatrix cannot get any assistance from the U.S. exporting agencies to
undertake such an activity.

       Furthermore, EPA does not certify technology. Some sort of high level certification
would assist firms in the exportation market.  With the current push on environmental
technology, unless the system changes, the U.S. will continue to export technology and
companies, but not exports.
          Alan Scarsella, Director of International Business Development for Wahlco
          Environmental Systems, Inc., spoke of work at Wahlco in developing funding
          sources through U.S. and foreign government agencies, and private institutions
          to broaden the company's export opportunities. Wahlco has worked to try to
          find capital, put together deals, and  finance the opportunities that they see
          developing in Eastern Europe, Asia, and elsewhere.

       In  Poland,  Wahlco worked through a joint venture  partner  who  acted as its
manufacturer's representative.  Wahlco had worked with this company for 20 years prior
to this particular venture and was able to make good connections.

       Also, there is a Clean Air Foundation in Poland that was helpful in getting Walcho
into one of the plants in Warsaw.  As a result, Wahlco was able to put one of its units in
the plant as  a demonstration unit at a very low cost both for  Walcho and the  customer.
The cost was paid for  in coal,  a barter arrangement.   Mr. Scarsella reiterated  how
advantageous it was to have a partner in Europe that was very familiar with  the Polish
economy as  well as with the barter system. The demonstration unit was very successful.
Wahlco signed an agreement with the plant manager to install several more  units — this
time for deiitchmarks and U.S. dollars.
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       In India, Wahlco's experience was not as positive. Wahlco became involved with
a plant owned by one of the state electricity boards. As in Poland, Wahlco made the plant
connection through a joint venture. In 1991, Wahlco received an initial offer to bid, made
an offer, and quoted a price.  Two years  later, Wahlco was still waiting for feedback.
Finally, they were asked to resubmit the bid because the coal had been changed and the
particulate amount had increased by  a magnitude of five.  Wahlco had to double the
capacity of the unit they had designed. Wahlco did this but kept the price the same.  By
that time, however, people that had been making decisions had been replaced, and the
new staff were not  very  familiar  with  the technology  and  felt there  had been some
wrongdoing on Wahlco's part in reference to the quoted price (which, in actuality, was the
same as the original quote from two  years earlier).  Wahlco was offered unacceptable
conditions: they might be allowed to install  a demonstration unit, but only if it was
entirely at Wahlco's expense; if the first year's demonstration is successful, the electricity
board may consider whether it wants  to purchase the equipment.

       There is a U.S. AID program called TEST, handled by a joint advisory panel of U.S.
and Indian representatives.  They have offered to help  Wahlco in any way they can to
clear up this kind of issue. Sanders International is the primary contractor for TEST and
have been very helpful;  they perform  the same type of role that the consultants to
government agencies should play.

       Although Wahlco representatives spent two weeks educating plant representatives
on their technology and  Wahlco  has their own people posted in India,  there is  no
guarantee of ultimate project success.  One cannot necessarily do business in one country
the way one  does it somewhere else.  Wahlco  is  currently working with its Indian joint
venture to resolve the situation and  salvage  the job.   If a reasonable demonstration
agreement is  reached, Wahlco hopes to  have  the assistance of one  of  the  national
laboratories as a third party to certify  demonstration results.

       Like other U.S. manufacturers, some of our best prospective customers lack the
ability to pay for the product.  Many U.S. investors would respond to the right incentive
to provide their capital, especially if the investment would help improve conditions in their
native country. The Earth  Day slogan was "Think  globally, act locally." Any improvement
in the environment has its incremental effect on  the whole. The U.S. should encourage
people to invest in cleaning up the environment, whether it is in this country or elsewhere.
We can do that with the right incentives. We gained experience with alternative energy
incentives.  Hopefully we can use those lessons to design incentives that encourage
individuals to invest in purchasing U.S. environmental products regardless where they are
used.  It would help us both economically and environmentally.  I believe it would also
help us politically.
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           Roger  Strelow,  Vice  President  of  Environmental  Affairs  for  Bechtel
           Corporation, endorsed the notion of finding a suitable mechanism for high-
           level certification of environmental technologies.  This could be particularly
           helpful when promoting technologies abroad. One of the Congressional bills
           being considered has a provision that would create a high-level entity separate
           from EPA to give U.S. firms a mechanism for promoting technology abroad.

       Bechtel is the largest environmental engineering and construction company in the
United States.  It is an  $8 billion company that is heavily involved abroad.  The  key
industry sectors Bechtel serves are fossil power, petroleum and chemicals, and mining and
metals.  Betchel designs and builds industrial facilities, highways, airports, and power
plants. Bechtel often does its air quality work as an integral part of a broader project, for
example, in designing and building an entire power plant.  Some 30^40 percent of Bechtel's
total business is overseas.

       The Environmental Technology Export Council strengthens some of the linkages
between  larger and  smaller  firms in common export ventures.  Bechtel's business
philosophy has been generally to avoid proprietary technologies.  Bechtel usually helps
customers look over the entire range of available domestic and foreign technologies.  It
rarely develops a technology that is its own. One area that has been a notable exception
is with flue gas desulfurization (FGD).

       For the Coal Strip Power Plant  in Montana, Bechtel  designed  a system for  a
particular application.  It developed a Dolomite Lime FGD process.  Bechtel also has a sea
water scrubbing technology that is now being licensed overseas along with the Coal Strip
derived process. Another technology is the confined zone dispersion — to remove sulfur
without having to have a scrubbing unit.  Cheaper  than a scrubbing unit, this may be
particularly attractive to regions like Eastern Europe.  However, it only removes about 50
percent compared to the 90 percent success rate  of scrubbing units.

       Bechtel has performed a number of overseas studies and feasibility assessments —
from the UK to Saudi Arabia, and  from New Zealand to Japan — in the area of FGD.
Bechtel sees a  substantial global FGD market developing over the next 15 years of some
$45 billion, about half retrofit/ half  new facilities. The U.S. portion of this market should
be about $9 billion.  However, there is a  substantial portion not open to U.S. firms. The
open market for US FGD abroad, where US firms can be competitive, is approximately $25
billion. Western Europe and the Asia Pacific area are the focal points for the development
of this market.

       One alternative, especially for smaller companies is to find appropriate linkages
with firms like Bechtel.  This enables the smaller company to  gain some leverage.  One
example, in the hazardous waste treatment field rather than the air pollution field, helps
to illustrate the potential.  A thermal distillation  technology that actually qualifies for
RCRA recycling can be used to treat a  wide variety of hydrocarbon wastes and was
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Clean Air Marketplace 1993                                            Page 221
developed by an independent entrepreneur. Bechtel discovered it early in its development.
Recently, the technology company has contracted with an affiliate of Bechtel, Zytel-Bechtel
(a joint Japanese-U.S. firm that specializes in the engineering and production of process
technology units), to be the exclusive designer and fabricator of its equipment. Bechtel
gives an operational guarantee for the equipment Bechtel  designs and builds.   This
operational guarantee  by Zytel-Bechtel is an enormous  asset to a small technology
company that is not heavily capitalized.

      There are plenty of opportunities for the  private sector, even without additional
government intervention, to do  a better  and smarter job of competing with foreign
enterprises in the export market for air pollution control and other environmental types
of work.  However, we cannot stake the future of our companies on government becoming
organized and getting out on the front line to work with us.
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                         Session 8
                         Looking to the Future — New Directions for
                         Environmental Technology
                         September 9, 1993
                          2:00 p.m. - 4:00 p.m.
                         Moderator:
                         Panelists:
Richard Ayres, Esq.
Braden R. Allenby
Howard Geller
Dr. Richard Klimisch
Bruce Smart
Introduction
       Richard Ayres, Esq., Partner at O'Melveny & Myers, opened the discussion by
reflecting  on the  future of environmental  technology over the next 30 years.   The
environmental technology marketplace is rapidly changing because, according to the
House Committee on  Merchant Marines  and  Fisheries,  most of the 58,000 small
environmental companies in the U.S. do not export their technology. Ten to fifteen years
from now, global  environmental trade may expand.  Over the next three decades, this
marketplace will go "offshore and upstream."  During this time frame the developing
world will acquire the technology that the developed world has today, and environmental
pollution abatement will undoubtedly follow. Furthermore, environmental technology will
provide innovations in pollution prevention and  life-cycle controls.  Examples of these
possible innovations include energy efficiency technology, alternative energy generation
technology, and life-cycle analysis.
Presentations

          Braden R. Allenby, Research Director, Technology and Environment, AT&T,
          focused on defining environmental technology.

          Americans lack a certain perspective on technical issues; they tend to trivialize
          tasks and turn them into products. This is not environmental technology. A
          better definition of environmental technology can be formulated  using the
environmental impact equation:

       Environmental Impact  = Population x
                              Wealth /Unit Population x
                              Environmental Impact / Unit Wealth
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       Several terms in this equation need to be refined. The environmental impact term,
for instance, is unacceptable today because of such problems as species depletion, global
climate change, and the loss of soil and water resources.  The population is increasing and
can be considered exogenous.  The  wealth  / unit  population term is also increasing
because the developing world will not give up its right to develop, and the developed
world will not give up its right to increase wealth.

       As a result, environmental impact / unit wealth must compensate not only for the
first two terms, but for environmental impact as well.  Moreover, environmental impact
/ unit wealth is a technological term because quality of life and economic development are
created through the applications of  technologies.   It is not, however, limited just to
technological products (e.g., scrubbers).  This  definition of environmental technology is,
therefore, much broader in scope than the  term "environmental  technology"  usually
implies and involves,  for example, a technology's diffusion into society.

       Today there is no such thing as environmental technology because we have not yet
developed a sustainable technological base. A useful example is the manufacture of cars.

       Industry must focus on other things besides manufacturing processes and tailpipes
to assess environmental pollution.  For instance, industry should look at how cars are used
in society.  The Japanese, for example, use cars for many different reasons than Americans
do, and this will affect pollution. Because of this cultural difference, green technology in
America  is viewed differently  than elsewhere.    The above differences  will affect
competition between  U.S.  and foreign markets because other countries  are trying to
develop towards a more sustainable position.

       The environmental industry is, by nature, transitory.  Today, environmentalists
push for companies to develop technologies that eliminate pollution stemming from the
starting point of industrial processes.  This was not the case several years ago.  A Virginia
electronics manufacturing plant, for example,  went from emitting CFCs and chlorinated
solvents to near zero  pollution level  reportable under the Superfund Amendments and
Reauthorization Act in 2-3 years, by re-engineering components and processes from the
ground up. The implication of this approach is not to focus on controlling emissions, but
to re-engineer industry away from any practice that produces emissions at the start of the
industrial process. The most  important green technology issues are as follows:

       •      Policy should not be directed towards subsidizing or improving existing
              technology, but should establish boundary conditions that will encourage
              industry to take environmentally appropriate actions.

       •      Policy should  focus  on systems.  By taking a life-cycle  approach to
              productivity, technology, and service within the same context in which they
              are used in our culture and economy, we can minimize negative impacts
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Clean Air Marketplace 1993                                            Page 225
             and,  therefore,  begin  to  develop  new  insights  into  environmental
             technology.
           Howard Geller, Executive Director of the American Council for an Energy
           Efficient Economy, is dedicated to advancing energy conservation technologies.
           Mr. Geller discussed a study that illustrated the potential economic savings
           and pollution reduction in the utility industry and reviewed some emerging
           technologies in energy conservation.

       According to Mr.  Geller,  if industry uses less energy in making a product  or
providing a service, then less pollution will result. Improving the efficiency of energy use
is cost effective because the energy savings generated are worth more than the cost of the
energy efficient technology. The following study illustrates this point.

       Acid Rain and Electricity Conservation, a study concluded in 1987, focused on the role
of more efficient electricity use in cutting emissions of SOX in the Upper Midwest.  The
study presented potential energy savings that could result over a 20-year period if utilities
promoted these new technologies.  A  base-case load growth  of 1.7 percent  per  year
between 1985 and 2005 was predicted, assuming normal  electricity use with no  new
efficient technology.  More efficient energy use could result in a growth rate of only 0.9
percent per year for the same time period.

       The same study can be used to simulate fuel use and emissions scenarios. These
scenarios tested the effectiveness of conservation and further emissions control technology.
In addition, the study assumed there would be legislation reducing SO2 emissions  by 5
million tons in 1995 and by 10 million tons in 2000.  The results were as follows:

       •       Before the new legislation, emissions slowly rose; after the legislation, the
              more efficient technology reduced emissions by 7-11 percent.

       •       For the period 1985-2000, electricity costs to the consumer  totalled  $355
              billion.  Employing conventional emissions control technology added
              $3.6-$8j4 billion  in electricity costs to the consumer.  However, if more
              efficient electricity  and pollution measures  are employed, there is a net
              economic savings of $3.7 to 10 billion.

       The savings more  than  offsets the cost of the pollution control technology and
therefore, makes this scenario profitable.
 Session 8 — Looking fo the Future - New Directions for Environmental Technology

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Page 226     	       Clean Air Marketplace 1993


       The following examples illustrate the emerging technologies focusing on energy
conservation.

       •      Energy efficiency in refrigerators has dramatically improved over the past
             20 years. Until about 1970, electricity use in these appliances rose because
             of added features.  By the early 1970s, electricity use in refrigerators began
             declining while average unit size  increased roughly 10 percent.   Public
             pressure and  higher  oil prices  during this  time  period  drove the
             development of more efficient refrigerators.

       •      More recently,  EPA sponsored a  contest  to see which  refrigerator
             manufacturer could build the most efficient, pollution-free machine. As a
             result, products now use only 350-500 KWHr of electricity compared to the
             1500-2000 KWHr common 15 to 20 years ago.

       •      Other appliances that have increased energy efficiency are clothes washers
             and clothes dryers. Heat pump and microwave clothes dryers should be
             available to consumers in the next five years.

       •      Lighting, particularly compact fluorescent lamps, now use less energy and
             are gaining popularity in the marketplace. Improved incandescent lamps
             are also readily available to consumers.

       There are many benefits stemming from more efficient energy use.  By using less
energy, industries can pass on their savings to consumers. Lower energy costs to industry
also will help create new  jobs,  limit our  dependence  on foreign oil, and, ultimately,
produce environmental benefits such as reduced pollution.
           Dr. Richard Klimisch, Vice President of the Engineering Affairs Division at the
           American Automobile Manufacturers Association, introduced the United States
           Council for Automotive Research (USCAR).  This organization comprises
           consortia that are involved in the research and development of new vehicles.
           USCAR considers both  the  environment and the needs of society when
           designing  new  technologies.    There  are  five  consortia  forming  the
environmental side of USCAR:

              The Auto/Oil Air Quality Improvement Research Program, a partnership
              between the auto and oil industries to improve air quality.
Session 8 — Looking to the Future - New Directions for Environmental Technology

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Clean Air Marketplace 1993                                           Page 227
       •      The Low Emission Technology Program, which is involved in measuring
             pollution using remote sensing technology.

       •      The Low Emission Paint Partnership, focusing on the goal of reducing and
             eventually eliminating solvents in paint.

       •      The  U.S.  Advanced Battery  Consortium, which  helps develop better
             batteries so that electric vehicles have a better range with less cost.

       •      The Vehicle Recycling Partnership, which works on the reuse, recycle, and
             disposal of vehicles. Currently it is developing methods to recycle plastics
             found in vehicles.

       Lastly, the discussion focused on America's dependence on cheap  gasoline. Fuel
consumption is controlled by fuel prices.  Therefore, to decrease fuel consumption, fuel
prices  must rise.  This will inevitably spur  the production of more efficient vehicles.
However, efficient vehicles will  only be produced in mass quantity when markets open
and the public demands new technology.
           Bruce Smart, Senior Fellow at World Resources Institute and author of Beyond
           Compliance:  A New Industry  View of the Environment, discussed his views on
           how America can solve its environmental problems correctly and efficiently.
           We cannot really tackle these problems, according to Mr. Smart, until both the
           environmental and business communities agree on goals and policies for
           change.  Technology is the key to solving  our problems.   However, this
technology must be developed through industry — government and environmental groups
cannot play the central role.

       Environmental problems involve too much emotion.  This emotion causes groups
to take sides, allowing issues to become stagnant in Washington. Therefore, technology
must replace emotion with fact; we must set priorities and better define our problems.
Only when the problems are better denned can we decide how to tackle them efficiently.

       The environmental and business communities must agree to move towards solving
our environmental problems by developing a consensus on the following issues:

       •      Correct indicators of the environment;

       •      A hierarchy of relative risk; and
 Session 8 — Looking to the Future - New Directions for Environmental Technology

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       •      Proper dissemination of information to the public.

       When the problems are better  defined, we  can  apply specific technologies to
properly  solve them. The development of these specific technologies will undoubtedly
help America become more competitive in world markets.
Questions and Answers:

        How we can provide incentives to promote new technologies?
         Mr. Smart answered by stating that business can respond accordingly if we can
         institute a fee system for pollutants or give credit for a lack of pollution.  These
incentives will help our tax and fiscal system reflect the social costs of environmental
degradation.

Mr. Allenby added that it may be difficult for governments to adopt incentives such as
fees and rebates. Community right-to-know programs to spread the word regarding
environmental degradation may also be useful.

Mr. Geller responded that utility incentives (i.e., rebates) and the gas guzzler tax already
provide incentives.  Perhaps the gas guzzler tax could be expanded to tax owners or issue
rebates according to the amount of emissions vehicles produce.
         Why didn't anyone mention renewable technology?

         Dr. Klimisch responded that a talk on soydiesel was given the day before. More
         needs to be done with renewable energy to limit CO2.

Mr.  Geller added that  wind technology and solar-thermal technology are gaining
popularity and will expand in use. More bio-fuels are also on the horizon.

         Many  companies have  developed environmental technologies  but have not
         marketed them.  How can we force companies to release their products?
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         Mr. Smart explained that more rapid depreciation schedules, investment tax
credits, and incentives for new technology by raising the costs of using old technology are
some answers.
         How was USCAR formed when many other similar environmental problem-
         solving consortia failed to form?

         Dr. Klimisch responded that the time was right. Other consortia failed because
of economic distress in the member companies.
Session 8 — Looking to the Future - New Directions for Environmental Technology

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Clean Air Marketplace 1993                                            Page 229
        How will the development of electric cars affect energy efficiency?

        Mr. Geller  responded that one  must  look  carefully  at  the  total resource
        requirements of a technology. Economies in the marketplace will help determine
which energy sources will be better used.
         Can we really attain long-term sustainable development?

         Mr. Allenby answered that one must assume sustainable development is possible,
         but it is questionable whether there are data to support this stance.

         How will pollution prevention spur development in companies?

         Mr. Allenby explained that pollution prevention will not yield as much as is
         hoped because compared to emissions reporting, pollution prevention reporting
is complex and more difficult for non-technical people to understand. Pollution prevention
is a good idea for managers of facilities to know, but it will not be an effective driver for
practical developments.  In addition, the environmental benefit that will result is just a
good next step in the right direction.
 Session 8 — Looking to the Future - New Directions for Environmental Technology

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                                Page 231
                          Session 9
                          Public/Private Partnerships in Cleaning the Air
                          September 9, 1993
                           4: J5 p.m. - 6:15 p.m.
                          Moderator:
                          Panelists:
Steven Howards
Daniel Greenbaum
Isaac Manning
Steven Coffin
Ben G. Henneke
Introduction

       Steven Howards, President of Environmental Strategies, prefaced his remarks by
posing the following questions: Why would air quality regulators want to work with the
private sector?  Why would the private sector want to work with air quality regulators?
Models and examples of public/private sector partnerships, particularly partnerships that
use the private sector to facilitate the implementation of public programs, show that such
partnerships can  form, work, and be successful  in creating stronger pollution control
programs and in fostering greater competition in the clean air market.

       The private sector, especially those industries that might gain broader markets from
the implementation of stronger control programs, can play a key role in helping air quality
regulators develop and implement their programs. The private sector wants to participate
in program implementation in order to be a part of the program development process,
understand how decisions are made,  and shape  programs to create additional market
opportunities for environmentally, economically, and socially responsible products.  The
public sector needs information and support from the private sector in getting programs
implemented.   To the  extent possible, the public  sector  needs private sector help in
developing programs that nurture competition in the marketplace and create an incentive
for the development and marketing of cleaner products. Although the motivations of the
involved parties  might be quite distinct, the potential  for powerful public/private
partnerships exists if both the public and private sectors take time at the outset of program
development to see  how their interests coincide and to subsequently develop programs
that harness their joint energies.

       There are  successful programs in which the public and private sectors created
unusual collaborative processes using their joint technical resources to create consensus-
based  programs  that  encourage the  private sector to  aggressively pursue market
opportunities. Programs based on pub lie/private sector partnerships can be economically
sounder, and can better anticipate and address points of controversy, allowing the private
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sector to actively contribute to the implementation of programs, rather than serve only as
passive observers.


Presentations

           Daniel Greenbaum,  Commissioner  of  the  Massachusetts  Department of
           Environmental Protection, discussed efforts by the State of Massachusetts to
           forge public/private sector partnerships and develop ideas for the direction of
           future partnerships.  Because  the  public sector cannot alone  protect the
           environment, the relationship between the public and private  sectors becomes
           crucial to the entire issue of environmental protection. The public sector can
pass rules, enforce rules, and  give incentives, but the  private sector makes decisions,
investments, and propagates expertise and  ideas.

       Mr. Greenbaum began by  discussing the role that the public sector should play in
clean air. In describing this role, one sees seemingly contrasting approaches: a "command
and control", "tough-on-the-environment" stance, versus a cooperative relationship with
the private sector.  The command and control approach has  achieved a certain level of
success in clean air.  However, a command and control approach  limits the input of ideas
and expertise, which is necessary for comprehensive  and sustainable clean air programs.
An approach  incorporating both stances (command and  control, and cooperation) would
be more successful — the Clean Air Act Amendments serve as an example.  It sets very
straightforward clean  air goals  (e.g., the acid  rain program  and ozone attainment
requirements), but does not specifically mandate how to reach these goals. The Clean Air
Act Amendments allow the market to determine how to  reach clean air  goals in the
cheapest and  most effective way possible.

       Implementing the Clean Air Act Amendments is a  classic zero-sum  game. The
reality of the Clean Air Act is not whether pollution reductions are made, but how  they are
made.   If one industry (e.g., auto manufacturing) does not make sufficient reductions,
reductions have to be made by another industry  (e.g., utilities).  People are a necessary
part of making choices to achieve pollution reductions. If partnerships that involve people
making decisions are not fostered in the development  of clean air programs, different
economic sectors will not understand their integral role in meeting clean air standards and
will be less willing to comply with any programs that impact their industries.

       Two examples  of  successful  public/private sector partnerships that  broadly
encourage people to go beyond  basic requirements  in  order to benefit from economic
incentives include:

       •     Transportation control measures.  Massachusetts addressed the  issue of
             creating business, development, and incentive opportunities — that are not
             in opposition to clean air goals — by chartering a transportation task force.


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Clean Air Marketplace 1993                                            Page 233
             The task force, comprised of the public, private, and public interest sectors,
             developed a set of proposals to meet the air pollution reduction goals.  As
             a part of the negotiation process, the business community identified the
             public sector as responsible for maintaining transportation systems and built
             into the State Implementation Plan (SIP) — a set of enforceable performance
             standards for public sector maintenance and operation of transit  systems.
             The Boston Chamber of Commerce also proposed an entirely market-based
             emission incentive program in which a fee would be imposed on those who
             drive more than a certain number of miles per year in  more highly
             polluting vehicles, while granting credits to those who drive less  than the
             amount and/or in less polluting vehicles.  Even though the program would
             not generate profits for the government, it would allow economic and
             market incentives to influence the current automobile pricing system.

             Although there was not agreement on all points, a market-based proposal
             was  developed that outlines collective goals, activities for individuals to
             participate in, and an overall time line for events. The proposal does not
             control how the goals are going to be met, but rather, tries to offer people
             options to  reduce the growth  in trips.  Under the proposal, the market
             encourages many of the reductions, as well as promoting cooperation.

       •      Emissions  trading.  In  a  project involving almost  no  public money,
             Northeast  States for Coordinated Air Use Management  (NESCAUM)
             developed a voluntary program with twelve companies, two state agencies,
             and  the city of Philadelphia  to work with companies to measure  air
             emissions and use emission credits effectively. This program will develop
             the market for credits, thereby encouraging companies to invest in greater
             emission reductions than required by the Clean Air Act Amendments.

       Enforcement cases are  an  additional  forum  from which public/private  sector
partnerships can develop.   Enforcement  actions provide the  government with  many
opportunities either to be very tough  or to  look at opportunities  for partnerships to
advance clean air.   For example, enforcement actions were brought  against the New
England Power Company. The company agreed to come into compliance, and additionally
agreed to be one of the first commercial installations in the country to  use  selective
noncatalytic reduction to reduce NOX emissions.  This voluntary reduction with new,
untested  technology brought about very  substantial reductions and  improved  public
relations with neighbors around the plant.  The company is looking into  applying the
technology at  other plants that do not have  enforcement issues to earn marketable
emission credits. This sort of unlikely partnership not only produces cleaner air and lower
costs, but it also tests out new technologies and gets them moving at a faster pace.

       There is also the potential for public/private sector partnerships resulting from
implementing private sector licensing processes and certification  programs for traditional
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government roles.  Private sector companies fulfilling traditionally public sector roles
provide several economic and service-related benefits.  These programs build a greater
private sector pool  of expertise, provide better service to people, make available more
service to people, force better quality control, and encourage a very active and competitive
private market providing the services.  Several such programs are being implemented in
Massachusetts.

       •      Starting in October, much of the Superfund cleanup process will be turned
             over to licensed site professionals. The licensed professionals will render
             opinions  on  cleanups and  be subject to audits  in the same way that
             accountants are subject to audits by the IRS.  The program will  allow a
             large number of relatively uncontaminated  sites to move  forward  more
             quickly and allow private expertise to operate.

       •      Massachusetts is certifying private toxic use reduction planners, rather than
             solely relying on the  limited resources of public sector specialists. These
             private sector individuals will have responsibility for developing toxics use
             reduction plans with industries.

       •      Massachusetts has developed a rulemaking for  stationary source emitters
             that includes some privatization of the permitting process.  The State will
             not  review plans from every company, but  will  have  private sector
             specialists, who in addition to reviewing completed applications, will help
             companies submit their permit applications accurately.

       Two fundamental elements  form the basis of successful public/private sector
partnerships:

       •      Both sides of the partnership  must have some incentive to be involved.
             Unfortunately, many  in both the public and private sectors  do not
             understand what incentives to  partnerships are.    Understanding the
             economic  and  environmental  incentives  of  public/private   sector
             partnerships will encourage involvement from both sides and begin  to build
             the trust necessary to  sustain both the partnerships and clean air.

       •      People in different sectors  are beginning to understand  that there are
             common   environmental   problems   that   everyone   —   not   just
             environmentalists — is trying to  solve.  Implementation of the Clean Air
             Act Amendments may be the stepping stone for building trust between the
             public and private sectors.  People will see that with trusting, more gets
             done with less bureaucratic wrangling. There  is a  surprising amount  of
             common ground on which to move forward, a large and diverse group  of
             people who recognize and support their interest in implementation, both of
             which should result in successful implementation of clean air programs.
Session 9 — Public/Private Partnerships in Cleaning the Air

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Clean Air Marketplace 1993                                            Page 235
           Isaac Manning, an architect and real estate developer who works with the
           North Texas Clean Air Coalition (NTCAC), discussed the role of clean air in
           sustaining a strong economy and the role of public/private sector partnerships
           in achieving environmental and economic goals in the Dallas-Fort Worth
           metropolitan  area.   When the  business community and Chambers  of
           Commerce  began   losing  opportunities  for  economic  and  industrial
development because of poor air quality, it became clear that there was little distinction
between clean air and economic development.

The five myths of nonattainment are:

       •      It is not my fault.  Ninety-two percent of VOCs emitted in the Dallas-Fort
             Worth area are from mobile and area sources.

       •      It is not  my county, plant, or town that is causing all  of these problems.
             Currently four counties in the Dallas-Fort Worth area are not in attainment,
             11 counties could be in non-attainment by 1996.

       •      There are too many or not enough air monitors. Air monitors are necessary
             to determine compliance. They are crucial for reaching attainment, as they
             prove the programs are working.

       •      It is impossible to comply.  With that attitude, everything is impossible.
             Texans, Mr. Manning pointed out, like a challenge; attainment is difficult,
             but not impossible.

       •      YOM can change the Clean Air Act Amendments. Too much time is wasted
             fighting the law and not working for solutions.

       The Dallas-Fort Worth area can be used as a case study for refuting  the myths of
nonattainment, illustrating the potential of public private partnerships.  Only  eight percent
of the emissions in the area are from stationary sources. As a result, the area  lacks surplus
emissions from industrial development that could provide emission offsets to reach
attainment.  The only way for the area to meet the air quality standards required by the
Clean Air Act Amendments, which allow continued economic growth, is by reducing air
emissions from mobile and area sources. The singular goal of NTCAC — comprised of
the Dallas Chamber of Commerce, the Fort Worth Chamber of Commerce, the North Texas
Commission, and the North Central Texas Council of Governments  — is  to bring the
Dallas-Fort Worth metropolitan area into attainment.

       NTCAC, a partnership between the public and private sectors, worked with EPA
Region VI and the Texas Air Control Board to develop a program to bring Dallas-Fort
Worth into attainment before 1996 and maintain air quality as required by the Clean Air
Act Amendments.  The private sector supported clean  air programs as  a long term
                       Session 9 — Public/Private Partnerships in Cleaning the Air

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business decision, and in this way generated political support for implementation of clean
air rules and programs.

       The joint efforts of NTCAC and the private sector resulted in the creation of a SIP
and a privately run "shadow SIP."  The shadow SIP is based on the  Tulsa-Oklahoma
Ozone Alert Program.  On days that are likely to have ozone exceedances, certain activities
are either encouraged or discouraged (e.g., using public transportation and not cutting
grass, respectively).  The public sector was invited to join the program through the
transportation authorities. The Tulsa program showed that if free rides were offered on
ozone-alert days, overall ridership on public transportation would increase.   The Fort
Worth transportation authority has experienced a 30-40 percent increase in ridership since
the inception of the Ozone Alert Program.  The  Dallas Area Rapid Transit joined the
program in August 1993.

       Another element of the shadow SIP program involves corporations ranking their
employees' performance on ozone-alert days and linking that performance directly to their
bonus compensation.  Under the program, employees get the impression that  if they do
not comply with ozone-alert requirements, they will be impacted financially.  A final
element of the  program involves educating school children. Children are taught simple
ways to reduce air pollution.  In addition, children directly feel the affects of ozone-alert
days because their schoolday starts later.  Children can  directly pressure their  peers and
parents into compliance.

       Clean air truly is a public and  private partnership.  Because the  economic and
environmental  future rests on partnerships, industry, business, government, and public
interest groups must work together in creative ways, discarding stereotypes about
individual groups.
           Steven Coffin, Vice President of the Colorado Interstate Gas Company (CIGC)
           and  Vice Chairman of  the  Colorado  Air Quality Control  Commission,
           discussed two examples of business opportunities that have been developed
           for the natural gas industry through efforts to address the air quality issues
           facing Colorado.

       The natural gas industry is in a good position to seize opportunities created by the
Clean  Air Act and do something about air quality problems in Colorado because the
problems are related to carbon monoxide and particulate matter — not ozone. In addition,
visibility is an important air quality concern.  The majority of these pollutants are caused,
directly or indirectly, by mobile sources in Colorado.
Session 9 — Public/Private Partnerships in Cleaning the Air

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Clean Air Marketplace 1993                                           Page 237
       There is a strong impetus fair environmental protection in Colorado.

       •      People come to the State for outdoor activities, the quality of life, and the
             mountains.

       •      Denver (like Dallas)  went through a major economic downturn that was
             directly linked to air quality. Despite improvements in air quality resulting
             from "easy" control measures, economic growth has generated more vehicle
             miles travelled  and  more  cars  on the  road,  challenging air quality
             improvements.

       Colorado is in the position of having to implement additional, more difficult control
measures to meet air quality standards.  Natural gas utilities, distributors, and pipelines
are beginning to recognize their potential, to contribute to the pollution, and to become
players in developing State and private programs to use natural gas to reduce emissions.

Business Opportunity #1:  CNG Vehicle Industry

       In the early 1980s, CIGC and the Public Service Company started promoting the
use of natural gas  to operate vehicles on a pilot-project basis. Although the project was
not intended to become a major venture, over time it became  an established  business.
Several elements contributed to the success of the pilot CNG vehicle programs, including:

       •      Poor air quality is a  hindrance to economic development;

       •      Nationwide energy security problems have been recognized;

       •      Natural gas is more economically efficient ($0.60 per gallon equivalent of
             gasoline) than gasoline; and

       •      The natural gas industry is indigenous to Colorado and an important part
             of the Colorado economy.

       Additionally, several pieces of legislation encouraged the development of CNG
vehicle programs in the state.

       •      At the  Federal  level,  the Colorado delegation  influenced Congress to
             modify  the alternative fuel fleet requirements of the  Clean  Air  Act
             Amendments of 1990 to include carbon monoxide nonattainment areas.

       •      At the State level, tax  credit and other financial incentives promoted the
             use of alternative fuels.
                        Session 9 — Public/Private Partnerships in Cleaning the Air

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Page 238                     	       Clean Air Marketplace 1993


       The natural gas industry began to see that market demand was greater than could
be serviced through a pilot project approach. In 1990, Natural Fuels Corp. was created to
put all of the operations for a CNG vehicle infrastructure together:  vehicle conversion,
refueling station  development, fuel sales, and vehicle servicing.   This venture  has
improved public relations and the economic position of  both public utilities and private
fleet operators:  utilities sell more natural gas and fleet operators can convert their vehicles
for economic purposes while cleaning the air.  Currently, there are approximately 3,000
CNG vehicles on the road in Colorado with 18 service and refueling stations.

       There are both negative and positive aspects of the CNG vehicle market. On the
negative side:

       •     The market is more difficult than anticipated;

       •     The cost of conversion is still high and a barrier to market growth;

       •     Customer convenience is poor; and

       •     Customer  acceptance  —  attitude,  behavior, thinking  about  CNG  or
             converting cars — is low.

       The industry is working with the  government to address these negative aspects.
On the positive side, the CNG vehicle market has:

       •     Generated business opportunities — additional  gas has been sold;

       •     Generated a significant amount of goodwill — CNG vehicles have become
             a part of the clean air solution;  and

       •     Paved the  way for other companies to get into the CNG business (e.g.,
             Total, Amoco).

Business Opportunity #2:  Conversion of Woodburning Fireplaces

       The second business opportunity involves the conversion of woodburning fireplaces
to natural gas.  Fireplaces are a significant contributor  to the  air pollution problem in
Denver.  However, as a result of a strong  educational program and close work with local
and  state governments, some woodburning fireplace bans are being put into effect.  For
example, "The Great Stove and Fireplace Changeout" was an illustration of the public  and
private sectors joining together to implement a voluntary mechanism for cleaning the air.
Participants in  the program included  public  utilities,  the  woodburning industry  (i.e.,
manufacturers  and sellers of fireplaces), and a major financial  institution.  The program
was a two-month cooperative effort that incorporated an aggressive advertising campaign,
educational outreach, low interest loans for fireplace conversions, municipal waivers of
Session 9 — Public/Private Partnerships in Cleaning the Air

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Clean Air Marketplace 1993                                           Page 239
sales  tax and building permit fees,  discounts,  and rebates to encourage  voluntary
conversions from wood burning  to natural gas  fireplaces and stoves.  The program
resulted in a 25 percent increase in sales of clean burning appliances, an improvement in
air quality, and the establishment of an ongoing coalition to increase public awareness of
the polluting aspects of woodburning fireplaces.

       A number of Federal and state programs, including the Clean Air Act Amendments
and the Energy  Policy Act of 1992 fleet requirements,  and state and Federal financial
incentives, will have a determining impact  on the industry.  The key to the  success of
natural gas, and all clean fuel industries, is legislative support to ensure the development
of a strong  market for the fuels. If companies look creatively at the air quality problem,
it becomes clear that there are more potential products and ways to make money than ever
thought possible.
           Ben G. Henneke, President of the Clean Air Action Corporation, used the
           Tulsa Ozone Alert Program to discuss the importance of building on successful
           program ideas and of including industry, regulators, and environmentalists in
           public/private sector partnerships.   Through the input  of many different
           perspectives,  each  time  a  clean  air  idea  works, it  has  wide-ranging
           implications.  As it  is adopted elsewhere, it is consistently improved.  Mr.
Henneke discussed how the Tulsa program has grown from a privately funded effort to
one involving Federal funding and broad educational programs.

       Despite the success of the Tulsa program in generating emission reductions and
government support through simple control measures, people will only do "inconvenient"
things occasionally. Public and private sectors, and environmentalists, must work together
to reduce pollution. By involving three perspectives in the discussion, typically opposing
factions can be  brought together in a cooperative manner.  Tulsa's public/private
partnership is comprised of approximately 50 percent  environmental public  interest
groups, 25 percent public sector, and 25 percent private industry. Environmental groups
and industry will join forces in the development of clean air programs, while regulators
are overwhelmed just to implement required laws and regulations. The government's role
is to provide information, so that creative, voluntary programs may develop. The joint
efforts of environmental groups  and industry have created an  atmosphere of cooperation
and a certain level of compromise. In the spirit of cooperation, environmental groups and
regulators establish goals and a time frame, while the industrial sector determines how it
will meet those requirements in  the goals.
                       Session 9 — Public/Private Partnerships in Cleaning the Air

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Page 240                                 	Clean Air Marketplace 1993


       The potential for public and private sector partnerships, particularly involving
environmentalists,  is much greater than most  realize.  The willingness of industry to
participate in clean air programs is significantly underestimated when industry is given
the freedom to determine how it will reach clean air goals.  The potential for public and
private sector partnerships can  only increase  as  people build, through shared ideas,
examples of clean air programs that have been successfully implemented.


Questions and Answers

         What is being used to clean up gasoline and diesel in Tulsa?
         Mr. Henneke answered that nothing is being done to clean up diesel.  To clean
         gasoline, the Reid vapor pressure (RVP) was reduced and voluntary reformulated
gasoline  was put in place.  Companies were not required to use Federal or California
reformulated fuel, but they were required to clean the fuel in whatever way was most
economical.  Mr. Howards pointed out that  the problem with diesel  is  sulfur and
aromatics.  In Denver, refineries developed  ways to  reduce the sulfur content  of diesel
cheaply,  which resulted  in the marketing of diesel based on its clean air qualities.  This
marketing strategy started building voluntary consumer demand for cleaner products.
         New York State has been very slow in pushing its clean air regulations.  Do
         states talk to each other?

         Mr. Greenbaum explained that NESCAUM, which includes the air directors from
New York, New Jersey, and the other Northeast states, meets regularly to come up with
joint strategies.  By 1989 all eight member states had adopted seasonal lower RVP gasoline.
The members of NESCAUM are now  part of the  larger Ozone Transport Commission,
established in the Clean Air  Act Amendments of 1990, which  is working to develop
everything from cleaner gasoline and cars to a regional emission credit trading system.
New York has played an active part of this group.
Have you looked at soydiesel?
       L

  *>
   •   I  Mr. Henneke responded that there are several ways to clean up diesel emissions
^™™  if there is no  Federal standard: (1)  inexpensive catalysts can be retrofitted on
most diesel engines; (2) engines can be overfeed with natural gas and alcohols, as is being
done with methanol and ethanol; or (3) inherently less polluting fuels, such as soydiesel,
can be used.
Session 9 — Public/Private Partnerships in Cleaning the Air

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Clean Air Marketplace 1993
                                Page 241
                          Session 10 — Panel A
                          Financing Companies and Projects
                          September 9, 1993
                           4:15 p.m. - 6:15 p.m.
                          Moderator.
                          Panelists:
Robert Brenner
Jerry Esmay
Robert Grady
Jake Tarr
Frank Pope
James H. McCall
Introduction
       Robert Brenner, Acting  Deputy  Assistant Administrator, Office of Air and
Radiation, U.S. EPA, introduced the session by reiterating Donald Deieso's statement in
the afternoon's keynote address:  Unless the financing works, the project is not likely to
happen.  This session offers us the opportunity to hear from several people who are
involved in financing CAAA-related projects, which, according to Mr.  Brenner, is an
excellent way to explore the critical role of financing in the Clean Air Marketplace.  These
representatives can offer valuable help to both government and industry in identifying the
hurdles to financing clean air projects and approaches we can take to facilitate financing.
Presentations

           Jerry  Esntay,   Environmental  Project  Specialist,  International  Finance
           Corporation (IFC), began by explaining that the IFC is the private sector arm
           of the World Bank,  financing only private companies without government
           project guarantees.  The U.S. is the largest single shareholder of the World
           Bank, owning approximately 25 percent of the shares outstanding compared
           to most other countries, which  generally hold  about 6 percent or less.
Conversely, the U.S. represents only about five percent of industry that is sponsoring
environmental projects through  EFC.

       The EFC is the project financier of businesses that set up in Group 2 countries and
help mobilize resources for projects within  these countries.  Despite some popular
perceptions, adequate financing is generally available.  What are lacking are viable projects
that qualified U.S. firms are willing to support. The following are a few examples of the
various types of international projects for which U.S.-based firms can acquire financing
through the IFC:
                               Session WA — Financing Companies and Projects

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Page 242	Clean Air Marketplace 1993


       •      Manufacturing operations where research and development is accomplished
             primarily in the U.S.; and  manufacturing,  management efficiency, and
             quality control services in Group 2 countries.  These projects allow for the
             development of new technologies within the U.S., as well as provide Group
             2 countries with goods, services, and much needed industrial training.

       •      Build own Transfer (BOT) projects.  An example of a BOT project is the
             arrangement that a European environmental firm has made with a facility
             that cannot afford to invest in pollution  control equipment but will be
             required to meet European Community (EC) emissions standards. The firm
             sells equipment and services to the facility on  a per cubic meter of air
             cleaner basis; by installing equipment on-site and charging the facility for
             cleaning their emissions over a period of fifteen  years.   By the end of the
             fifteen years, the equipment is paid for and can then be turned over to the
             facility.  This type of venture may  become  more  common as Central
             European firms try to break into the EC, and could be a  great opportunity
             for  environmental businesses to  get  their  foot  in   the  door of  the
             international market.

       •      Model Industries, which set examples for other industries to follow.  A
             heavy polluting auto manufacturer located in South America, for example,
             and the  U.S.  will join forces with an environmental consulting firm to
             provide   waste  minimization,  pollution  control,  and   clean-up   of
             contaminated soils.  In doing so, the  auto manufacturer will improve its
             regional  and  global reputation, and  the  environmental consultants will
             establish an international business base with minimum risk and capital.

       The IFC is the largest single development bank for the private sector in the world.
It has financed over 1,000 business ventures all over the world, in more than 90 countries,
with total project costs exceeding $60 billion. The IFC offers financial structuring and acts
as a catalyst for other financing  options. When considering  projects to finance, the IFC
looks for strong management, a strong  market, and solid  financial resources.  The IFC
looks for value added ventures, where the community will also benefit as a result of the
project.

       Mr. Esmay concluded  that the private sector  will be the driving force behind
meeting  future environmental regulations, as the public sector will not have the necessary
capital requirements.
 Session JOA — Financing Companies and Projects

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Clean Air Marketplace 1993	Page 243


          Robert Grady, Vice President, Robertson Stephens & Co., began by stating that
          the current financial market has not been kind to environmental stocks.  He
          provided a performance comparison of environmental services stocks in the
          first two quarters of 1993 by comparing a Roberts & Stephens Co. index of 132
          environmental services firms to the  S&P  400  and the NASDAQ indexes.
          Environmental services stocks were down about eighteen percent in value in
the first two quarters of 1993 while the S&P 400 and NASDAQ indexes were up by about
three and one half percent, and four percent respectively.

       Mr. Grady sought to debunk three  pieces of conventional wisdom related to
investing in environmental stocks: (1) Environmental markets are dead; (2) Business does
not like regulation; and (3) Investors are willing to invest in socially responsible companies
just to be socially responsible.

Misperception 1 — Environmental markets are dead

       The misperception that environmental markets are dead is due in part to misplaced
premium valuations of environmental stocks that resulted from the passage of the Clean
Air Act Amendments, and the election of Clinton and Gore. As a result of disappointing
growth that followed premiums,  investors became disenchanted with environmental
stocks.  They did not understand that clean air regulations were not  scheduled to take
effect immediately. This pessimism remains and affects all environmental stocks.

       The primary reason for the misperception that the environmental market is dead
is the recent rapid shift in the definition of an "environmental firm." The environmental
industry has been changing its focus from remediation to pollution prevention. Companies
in their strategic decisions, as well as public statutes, regulations, and implementations
schemes,  have been  stressing  prevention  over  end-of-pipe controls.   The Global
Environment  Fund's  Market Survey for 1993 estimates that  industries will spend  four
times as much on industrial process changes as on actual pollution control equipment to
meet the mandates of the CAAA of 1990. Production process changes, factory automation
changes,  substitution  of various  types  of  raw materials,  and  energy  efficiency
improvements are examples of ways industries are responding to the changing demands
of the clean air marketplace.

       Along the same line, the Global Environment Fund's Survey states that the under-
performance of the remediation side of the environmental industry is not purely a cyclical
phenomenon related to the overall economy; in fact, it is related to the overall importance
of pollution prevention.  Remediation companies that specialize solely  in removal and
hauling of hazardous substances are only part of the environmental  industry and will
continue their relative decline. Stocks which will perform well are process technology
improvements that help the environment, instrumentation and monitoring companies, and
companies performing cleanup for the Department of Defense and the Department of
Energy.
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Misperception 2 — Business does not like regulation

       The second piece of faulty conventional wisdom is the myth that businesses do not
like regulation.  In  fact, many environmental companies, as well as investors, rely on
regulatory timeliness and regulatory certainty in order to maintain a consistent and reliable
marketplace.  Companies rely on regulations to provide them with the rules of the road.

       The key from a financing perspective is that regulations come out on time and are
enforced.  A recent  example of the importance of promulgating regulations consistently
and in a timely manner was  demonstrated by EPA's decision to delay the issuance of
Subtitle D of the Resource Conservation and Recovery Act (RCRA).  This delay hurt those
companies  that were taking steps in order to comply with the regulations by investing in
and implementing new technologies.

Misperception 3 — Investors are willing to invest in socially responsible companies just
to be socially responsible

       The third misperception is that investors are willing to pay a premium to invest in
socially responsible  markets.  This might have been that case for a short period in 1990,
and may to a certain extent be true, but companies have to make money in order to be
attractive to investors.

       The changing nature of the environmental industry is the result of the need for
companies  to adapt to the requirements of a true marketplace (e.g., having the attributes
that are required to  be a successful company — serving a growing market, having strong
margins, having a strong management team, and developing a strong business plan).
These attributes  are essential in  order to make environmental companies attractive to
investors and ensure future interest in investing in the environment. Mr. Grady indicated
that investors will be very selective and will be looking  for a well planned business
strategy, triple play companies  (companies whose products promote environmental
improvement, energy efficiency, and economic efficiency simultaneously), regulatory
progress in the  sector, and margins that can sustain growth  and profitability in  the
business.

       Conclusion:

       Changing demands in  the marketplace will result in growth in new sectors of the
environmental industry.   Consistency and timeliness  of  regulations  and the proper
enforcement of these regulations will be essential to the continued growth of the industry.
Investors will be selective, which will impact the type of financing available to firms.  But
significant  new funds continue to pour into mutual funds and other sources  of equity
financing, which  is good news for environmental firms wishing to access the equity
markets.
Session 1QA — Financing Companies and Projects

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Clean Air Marketplace 1993	Page 245


      Just as the early enthusiasm in 1990 was misplaced, Mr. Grady concluded, the
current pessimism or "doom and gloom" attitude is also misplaced.
          Jake Tarr, Vice  President, Arete Ventures, summarized the key investment
          criteria that venture capital firms such as Arete Ventures look for in possible
          clean air related investments. The most important criteria is a clearly defined
          near-term market need, which in most cases is created by regulation.  Other
          qualities important to a venture capital firm include: a management team that
          presents a compelling  story of success, modest capital requirements, and a
strategy to maintain a sustainable market advantage.

       In most cases, venture capital firms are not looking to invest in projects such as
electric vehicle companies or SO2 remediation companies because of the enormously high
capital requirements and the fact that these firms will be at a huge disadvantage against
larger competitors.  Instead, Arete" is looking  for companies that specialize in areas such
as development of instrumentation, dispersed power generation, and vehicle-related
component technologies (i.e., storage tank technologies, gas lines, and batteries).  Such
companies will contribute greatly to the future of the environmental industry.

       Arete Ventures has recently backed the following projects:

             •       Environmental Monitoring (Continuous Emissions Monitoring)

             •       Solid Polymer Fuel Cell Power Systems

             •       Landfill Gas Treatment Systems (Advanced Gas Processing)

             •       Gas Adsorption Heat Pump

             •       Polycrystalline Silicon Photovoltaic Cells & Modules

             •       High Temperature Super Conductors For Power Transmission

             •       Fungal Bioremediation
                               Session 10A — Financing Companies and Projects

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Page 246	Clean Air Marketplace 1993


          Frank Pope, General Partner with Technology Funding, Inc., stated  that
          environmental  technology  firms  are  facing  a  capital  shortage  at  the
          commercialization stage because of unique barriers to the market.  These
          barriers are the result of unknown factors that make it very difficult to project
          if and when a new technology will be successful  and profitable.  Venture
          capital is a very conservative business and most of these firms will not invest
in the environmental industry because there is not a proven series of success.  Out of 650
professional venture capital firms in the country, less than 20 of these firms will consider
environmental technology investments.

       Venture capital investors are hesitant to commit funds to environmental firms for
a variety of reasons:

       •      Most firms are not making money

       •      Many companies have not lined up customers

       •      The industry is young and the management is inexperienced

       •      Many firms experience permitting delays

       We are at the crossroads in developing an enormous private industry market in the
environmental sector.  Much of the future success will be the result of strong government
backing and efforts by advisory groups such as the California Environmental Technology
Partnership, which assists in  resolving problems between industry and the government.
With the assistance of such  advisory groups, the  government has made changes in
procurement and testing  regulations which have in turn minimized barriers  to the
environmental market and environmental firms more attractive to investors.

       Other options for environmental firms to turn to for funding are private investors,
private companies, joint ventures, general grants, and the government.  Various tax  breaks
(i.e., for the use of recycling equipment) also provide financial assistance.

       Environmental firms that seek financial assistance should be persistent.  We are in
the early stages of what could potentially be a  huge marketplace.
Session  10A — Financing Companies and Projects

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Clean Air Marketplace 1993                                            Page 247
          James H. McCall, President, Environmental Capital Corporation, reiterated
          some of the financing difficulties that many small businesses experience when
          trying use services and technologies in the environmental marketplace. The
          Air Quality Assistance Fund/1146.1 Demonstration Program was developed
          with the South Coast Air Quality Management District (SCAQMD) to assist
          small businesses in  complying with environmental regulations.   This is a
demonstration of help to mitigate the impact of the compliance requirements of SCAQMD
Rule 1146.1, which requires owners of boilers, process heaters, and steam generators to
reduce their NOX emissions.

       The Air Quality Assistance Fund is now a $4 million and was created with fines
and penalties. The majority of these funds are set aside to provide loan guarantees for
small businesses.

       The program is structured to provide incentives for banks to make loans to small
businesses and to create a  secondary market  for these loans.  In  addition, the Federal
Reserve Bank of San Francisco has advised all banks that participation in this program will
enhance their compliance with the Community Investment Act.

       Listed below  are some  examples of how the community  will benefit from the
program.

       •      Small  businesses will benefit by  receiving assistance through multiple
             credible channels.  The high level  of professional technical assistance and
             compliance support, and lower cost debt capital with fixed rates and long-
             term repayment  terms  will also be significant benefits of the SCAQMD
             program.  The program will also facilitate compliance and  help owners
             small businesses avoid diversion from operating the business by assisting
             in  the  permitting process, and focuses  on lenders that are familiar with
             businesses and thereby avoiding time-consuming efforts to establish new
             relationships.

       •      The program will also  provide assistance  to SCAQMD  by helping to
             mitigate regulatory impact on small  businesses,  facilitating compliance,
             improving community relations, enhancing staff utilization,  and meeting
             CAAA mandates.

       •      The program will assist  the banks by mitigating credit risk with  credit
             enhancement of small businesses,  providing liquidity for loans, reducing
             interest rate risk, and enhancing compliance with the Federal Community
             Reinvestment Act. The program will also assist in improving  relationships
             with small  business customers,  improving community  relations, and
             providing a new financial service product to the market.
                               Session WA — Financing Companies and Profocts

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Page 248	Clean Air Marketplace 1993


      •      Utility  Companies  will benefit  from the program through  improved
             relationships, customer retention, and enhanced community relations.

      •      Consultants and vendors will benefit from new marketing tools.

      The benefits of this program to the community are pragmatic and  specific — this
program can be a model that will be replicated in other communities in the future.
Session 10A — Financing Companies and Projects

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Clean Air Marketplace 1993
                                Page 249
                          Session 10 — Panel B
                          Financing Exports and Investments
                          September 9, 1993
                           4:15 p.m. - 6:15 p.m.
                          Moderator:
                          Panelists:
William A. Delphos
John Wisniewski
Edward Sanders
Harvey Him berg
Introduction

       William A.  Delphos, President  of Delphos International, a company  which
specializes  in  helping U.S. companies obtain government financing for international
business. Mr. Delphos is also the Chairman of the U.S. Environmental Training Institute,
a public/private  partnership that promotes  the  transfer of  environmentally  sound
technology and management principles by providing training courses to public and private
sector officials from developing countries around the world.
Presentations

          John Wisniewski, Vice President of Engineering at the Export-Import Bank of
          the  United  States  (Eximbank),  and responsible for the evaluation of the
          environmental  aspects  of bank  transactions,  began  by  describing his
          organization.  Eximbank facilitates the export of U.S. goods and services by
          providing loans or loan  guarantees to foreign buyers of U.S. goods and
          services in order to offset the effects  of export subsidy credits from  other
governments. The Bank has helped finance more than $280 billion of exports from the U.S.
to more than 150 countries, mostly developing countries. Financing programs include:

       •      Direct loans to foreign buyers of U.S. goods and services.

       •      Guarantees to U.S. and foreign commercial lenders for repayment protection
             for their loans to foreign buyers.

       •      Export credit insurance to protect U.S. exporters against foreign buyers'
             inability to meet payment obligations.
                                Session 10B — Financing Exports and Investments

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Page 250                                            Clean Air Marketplace 1993
       •      Working capital guarantees to encourage commercial lenders to make loans
             to small- and medium-sized U.S. businesses that have exporting potential.

       Eximbank does not give preferential treatment to any U.S. product, company, or
industry, nor does it allocate specific sums  of money to countries or geographic regions.
instead, it responds to specific requests for  financing from foreign buyers and American
exporters.

       Environmental exports are not new to Eximbank. Recently, however, the Bank has
placed additional emphasis on enhancing environmental exports. Some recent examples
of loan and loan guarantee programs the Bank has supported include:
                  i
       •      A feasibility study for water  and sewage treatment in Istanbul, Turkey;

       •      Over $100 million in U.S. equipment and project management services to
             improve water resources and  infrastructure in rural areas in Venezuela; and

       •      A wide array of other U.S. pollution control equipment exports.

       Eximbank is participating in a number of inter-governmental working groups
involved in the development of a U.S. export strategy for U.S. environmental goods and
services (e.g., Interage-ncy  Working Group  on Technology and  Exports, whose findings
were  released in a November 1993 report).   The  report includes  results from  public
stakeholder meetings held  in Los Angeles, Dallas, and Boston.
           Edward Sanders, President of Sanders  International,  explained  that  his
           company provides business facilitation services, specializing in environmental
           technology transfer and venture promotion, working primarily in Central and
           Eastern Europe.  Sanders International has been the recent  recipient of U.S.
           Agency for  International Development (USAID) contracts in Eastern Europe
           and India to help facilitate environmental investments and  exports in those
regions.

       The Clean Air Marketplace Conference 1993 highlighted the availability of a variety
of sources of assistance for financing environmental exports.  Financial assistance for
specific projects, however, may nonetheless seem difficult to obtain.   The conditions
attached  to the financing  make it difficult  to match  projects with the financing
requirements.   Among companies  with  which Sanders International  works, there is
generally  an assumption that financing will be available without a  careful analysis of
Session  WB — Financing Exports and Investments

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Clean Air Marketplace 1993
Page 251
whether a particular project fits with financing sources that are likely to be available. Two
screening devices can facilitate the identification of sources of financing:

       •     Determine whether the transaction is public or private.  Who is the buyer
             of the product (or the partner in the investment)?  If private, do financing
             sources really have access to appropriate funds?  Potential sources of
             financing differ for public versus private transactions. Consequently, the
             conditions attached to funding will be also different.

       •     Determine whether the transaction is an export or an investment. If the
             transaction involves exports, financier concerns will likely be focused on the
             security for the loan; in "tougher markets" the general lack of security can
             be  a tremendous roadblock to project  progress.  An example  shows the
             importance of the issue:  a recent project in Central Europe was expected
             to  be   successfully carried out, but  fell  through because local  bank
             guarantees  were  simply not available on  reasonable terms.    If the
             transaction is an investment, financiers will want the project principals to
             have equity in the project.
           Harvey Himberg, of the Overseas Private Investment Corporation (OPIC),
           explained that OPIC has  provided  financing,  insurance  and  supported
           feasibility studies for environmental projects overseas. Mr. Himberg focused
           his remarks on investments as an alternative and complement to direct export
           finance. Direct financing may have advantages for environmental goods and
           services, in terms of entering and competing.   However,  from a broader
perspective, it may not always be in the best interests of the parties.   Another way to
export and obtain access to  export financing  is through a project structured as a direct
investment. The relationship between investments and exports has been growing. Indeed,
U.S. exports of manufactured goods and services go overwhelmingly to locations that
already have substantial direct U.S. investment. In more competitive markets, companies
may require more proximity to their  markets than a purely export relationship can
provide, and local companies will maintain a  competitive advantage.

       Financing and insuring overseas investment is a specialty of OPIC.  OPIC is an
agency  of the  U.S. government organized for the sole purpose of providing financing,
insurance, and pre-investment services to companies seeking to enter  markets through
direct investment. An investment can take various forms including direct equity loans for
enterprises, leases, licensing agreements, and management contracts.  OPIC offers services
in nearly 140 countries, including those in Latin America, Asia, Africa, Eastern Europe, and
                                 Session 10B — Financing Exports and Investments

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Page 252                                            Clean Air Marketplace 1993
the newly independent states (MS) of the former Soviet Union.  OPIC (with funding from
USAID and US-Asia Environmental Partnership (US-AEP)) provides funding for feasibility
studies for  prospective investment projects in Eastern Europe, NIS countries, the Asia-
Pacific countries, and Africa.

      OPIC loan guarantees range from $1 million to $200 million per project. Loans are
made on a non-recourfee and Limited  basis (i.e., the income of the foreign enterprise must
be sufficient to repay the loan and the assets must be sufficient to provide security for the
loan or loan guarantee), at U.S. commercial rates of interest, with terms ranging from five
to twelve years.  These rates and terms are not  always available from commercial banks
in the countries in which  OPIC operates.  OPIC insurance provides U.S. companies with
protection  against "political risks"  including expropriation of assets  by the host
government,  inconvertibility of local currency,  and  politically  motivated  damage  to
physical assets and facilities.

      Two examples  (one large and one small) of environmental projects that OPIC has
assisted include:

      •      Ford Motor Company. This project involves a facility located in Brazil that
             manufactures  emission  control  equipment for sale  to  Brazilian auto
             manufacturers. Without the project, Ford would  not  have been able  to
             compete with domestic manufacturers.  Furthermore, the supply of U.S.
             components to the project (e.g., test equipment)  will amount to about $10
             million  of exports to Brazil.

      •      Environmental Systems Corporation. The project involves a firm located
             in the Slovak Republic that provides environmental engineering services to
             industries located throughout Eastern Europe. While small ($3 million in
             U.S. exports), it is assisting in the continued development of substantially
             larger markets.

      Other  OPIC initiatives,  both  independent, and in  coordination with other U.S.
government agencies), include:

      •      The OPIC/USAID environmental investment mission to Argentina, Chile,
             and Brazil (November 1993).

      •      Development of an environmental investment fund, which will provide
             equity financing to U.S. companies interested in investing in environmental
             projects but lacking sufficient equity.

             A project development program  that will include feasibility studies and
             other pre-investment support  for environmental investments in the Asia-
             Pacific region, in coordination with USAID and the  US-AEP.
Session 10B — Financing Exports and Investments

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Clean Air Marketplace 1993                                            Page 253
Questions and Answers
         To what extent do groups like Eximbank, Sanders International, and OPIC assist
         small businesses (i.e., 10 employees and under)?

         Mr. Wisniewski explained that Eximbank has a Congressional mandate to focus
on small business, and that at least 10 percent of all Eximbank authorizations are to be for
small businesses.  The current Administration supports small businesses  in exporting
environmental  services.   As  a government agency with a Congressional  mandate,
Eximbank is compelled to find reasonable assurance of repayment  in transactions of
support.

Mr.  Delphos expanded  on the response by saying that in general, if  certain  base
requirements for a project are met (e.g., minimum length of operation, specific equity
status, ability to produce and sell product, and the existence of a foreign order or prospect
for a foreign order), then legitimate programs are available to assist in funding.  Naturally,
if the project is a pure start-up that is still in development, financing will likely be difficult
to obtain.

Mr. Sanders added that many programs are available to help finance programs other than
just straight exports. For example, in Central Europe, the  Enterprise Funds concentrate
largely on environmental projects. Intermediaries often can more cost effectively service
small loans.  The projects between $1-$10 million are  the biggest gap in the overall
financing scheme.

Mr. Himberg pointed out that the problems and challenges of helping small businesses in
financing exports are magnified in investment projects because investment  projects take
both more up-front and long-term financing to sustain.  Thus, small businesses will require
a certain amount of capital base in order to initiate and maintain projects.
         What would Eximbank and OPIC do in terms of credit markets in response to
         CO2 reduction projects?

         Mr. Himberg responded that it is difficult to finance stand-alone projects such as
these (i.e., projects that do not generate a stream of income by themselves).  If the project
were linked to some sort of market that would produce a stream of income, the project
could possibly be the type of investment that OPIC could assist.   There  exists the
possibility of user-fee systems. Under an OECD agreement, there are provisions related
to "tied aid," in the sense of a mixture of commercial financing with grants.  If one can
show that a project would not be financially or commercially viable otherwise, then it can
be eligible for tied aid. Thus, if a company can categorize a  project as being environmental
(e.g., fluidized bed clean coal technology), obtaining funding will be easier.
                                Session 10B — Financing Exports and Investments

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Page 254                                            Clean Air Marketplace 1993
         To what extent have the panelists dealt with financing CO2 prevention projects,
         and  how  can  one compare  this  to CO2  control?   Also, how  can one
         quantitatively compare the pay-backs/spin-offs from the initial venture?

Mr. Wisniewski responded that Eximbank finances all of the above types of projects.  All
renewable  energy is  treated by Eximbank  as  environmentally beneficial.  Eximbank
supports projects that have these beneficial environmental effects, including those with and
without income streams.
         How can one develop methods to assess the above types of projects?

   •   • Mr. Himberg explained that OPIC is not involved with demonstration projects;
         instead, OPIC is involved with fully commercial projects.  To the extent that
other agencies draw conclusions that might be useful, OPIC utilizes the information in
looking at technologies for the first time. Mr. Wisniewski added that Eximbank also uses
certain commercial data to assess projects.
         What is meant by a "feasibility study", and what role does OPIC play in them?

         Mr.  Himberg  responded  that  the  company involved in  the  long-term
         implementation of the project should be intimately involved in performing the
feasibility shady.  OPIC does not fund third-party feasibility studies. Current feasibility
programs include project development in Eastern Europe and NIS countries, Asia and
Africa. Eximbank has an "engineering multiplier" program that finances feasibility studies.

Mr. Delphos pointed out  that there is not a single "feasibility study" program to facilitate
U.S. companies going overseas or starting to conduct market research in order to locate
distributors.
         Can you clarify the meaning of a feasibility study?
  *1
   •  I  Mr. Himberg explained that he is referring to a feasibility shady as a shady of the
^^™""  financial and  commercial feasibility of a planned project.  The product of a
feasibility shady is a business plan for an investment that would be eligible to apply for
OPIC funding or insurance.  It should not be confused with a purely technical feasibility
shady.

         Are these feasibility studies 100-percent funded?

         Mr. Himberg  responded that OPIC feasibility studies are "cost-shared", with
         between 50-75 percent of the feasibility shady funded, depending on whether the
U.S. investor is a large, small, or medium sized business. It becomes a reimbursable grant
if the project goes ahead  within two  years  (i.e.,  the company pays OPIC back).  Mr.
Wisniewski commented that Eximbank finances feasibility studies as loans and  guarantees
Session  WB — Financing Exports and Investments

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Clean Air Marketplace 1993                                           Page 255
to foreign borrowers, which have to be repaid in any case, regardless of whether the
project goes forward.

      L  To what extent are government efforts to stimulate exports and joint ventures
  f} I  in  environmental  technologies  reducing  or  diminishing  similar  efforts
   •  I  domestically?
Mr. Himberg responded that government efforts  abroad could structure  the incentive
schemes so as to have the desired outcome.  Mr. Wisniewski added that Exirribank treats
services just like capital goods, and last year Eximbank supported over $1 billion in service
exports. But in any transaction, one can expect that about 15 percent of the  transaction is
for services (e.g., management services, engineering services).

Mr. Himberg pointed  out that the difficulty of financing services directly, with non-
recourse financing, is that assets are not always apparent. OPIC participates in some direct
financing. Many projects initially involve equipment but later involve services in order to
maintain the equipment.
                                Session 10B — Financing Exports and Investments

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APPENDICES

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   APPENDIX A
Conference Program

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The
Clean Air
Marketplace  1993
New Business Opportunities Created by the Clean Air Act Amendments
September 8-9, 1993 • Sheraton Washington Hotel • Washington, D.C.
Co-sponsors:

American Automobile Manufacturers Association
American Gas Association
American Institute for Pollution Prevention
American Institute of Chemical Engineers
American Petroleum Institute
Chemical Manufacturers Association
Coalition for Safer, Cleaner Vehicles
Edison Electric Institute
The Environmental Business Association
The Environmental Business Council of the U.S., Inc.
Environmental Law Institute
Institute of Clean Air Companies
Manufacturers of Emission Controls Association
National Association for Environmental Management
National Association of Manufacturers
NESCAUM
South Coast AQMD
STAPPA/ALAPCO
U.S.-Asla Environmental Partnership
U.S. Environmental Technology Export Council (U.S. ETEC)
Appendix A — Conference Program
                                                 Page A- 1

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                       Conference Agenda
September 8
7:30 - 8:30 a.m.   Registration
8:30 - 9:15 a.m.    Welcoming Remarks
           NORTH COTILLION BALLROOM
      Ihtroducfton fey WJcJftael HL Skajiiro, Aettog Assistant Adralaistrator, Office of Air and
            Radiation:,. CAS-EPA
      Speaker: The Honorable Carol M* Browner, Administrator, 1LS. EPA
9:30 -11:30 a.m.
SESSION 1:  CLEAN AIR ACT- JOBS, COMPETITIVENESS,
            EXPORTS
            NORTH COTILLION BALLROOM
      This panel presents a variety of perspectives on the impact of the Clean Air Act Amendments of 1990 on U.S. industry,
      specifically its effects on employment, export opportunities, and overall competitiveness. How compatible are clean air
      and economic growth?

      Moderator:   Jeffrey C. Smith - Executive Director, Institute of Clean Air Companies
      Panelists:    Robert Brenner - Acting Deputy Assistant Administrator, Office of Air and
                        Radiation, U.S. EPA
                  Dr. Richard Klimisch - Vice President, Engineering Affairs Division, American
                        Automobile Manufacturers Association
                  Daniel W. Noble - Vice President, Director of Research, Environmental Business
                        International, Inc.
                  John Quarles, Esq. - Partner, Morgan, Lewis & Bockius
                  Paul Templet - Professor, Louisiana State University
SESSION 2: POLLUTION PREVENTION AND THE CLEAN AIR ACT
                      MARSHALL ROOM
      What is the connection between the Clean Air Act Amendments and pollution prevention? Our panelists view this
      question from both Federal government and private sector vantage points.

      Moderator:   John S. Seitz - Director, Office of Air Quality Planning and Standards, U.S. EPA
      Panelists:     Dr. Thomas Hauser - Executive Director, American Institute of Pollution
                        Prevention
                  Howard Klee, Jr. - Director, Regulatory Affairs, Amoco Corporation
                  Amy Laspia - President, Environmental Management Consulting
                  Dr. Dhiren C. Mehta - Manager, Technology Applications, Hughes Environmental
                        Systems
                  Eric Schaeffer - Director, Pollution Prevention Policy Staff, U.S. EPA
      The Clean Air Marketplace Conference and  Exhibition
  Page A-2
Appendix A — Conference Program

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September 8 (continued)
11:30 a.m. - 12:45 p.m.   Lunch Break (Free Time)
1:00-1:45 p.m.   Keynote Address                    NORTH COTILLION BALLROOM
                      , Vasn&nfcergfc, Associate DeputyA<3mirustra^r,
     The Clean Air Marketplace Conference and Exhibition
 Appendix A — Conference Program                              Page A-3

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Septembers  (continued)
2:00 - 4:00 p.m.
SESSION 3: CONTROL TECHNOLOGIES AND SERVICES -1
      These four panels begin the conference's focus on market developments in specific technology and service sectors.
      Panels A and B both delve into stationary source control technologies. Panel C addresses control technologies for
      traditional vehicular sources. Panel D looks to the future of alternative vehicular technologies, including electric cars
      and fuel cells.

    Panel A: Electric power technologies                                     MARSHALL ROOM
      Moderator:   Paul M. Stolpman - Acting Director, Office of Atmospheric Programs, U.S. EPA
      Panelists:     Eugene C. Grassland - Manager of Business Development, Pure Air Corp.
                   William R. Elliott - Vice President and General Manager, Electric Supply, Northern
                          Indiana Public Service Co.
                   Steven Feeney - Manager of Upgrade Projects and Services, Babcock & Wilcox, Inc.
                   John U. Huffman -Project Development Manager, Kenetech/U.S. Wind Power Inc.
    Panel B: Stationary source VOCs/air toxics control                           HOLMES ROOM
      Moderator:   Bruce C. Jordan, Jr. - Director, Emission Standards Division, Office of Air Quality
                          Planning and Standards, U.S. EPA
      Panelists:    C. Shepherd Burton - Senior Vice President, ICF Kaiser Engineers,
                          Environment Group
                   David A. Doles - Sales Engineer, Stationary Source Catalysts, Engelhard Corp.
                   Dr. Orman A. Simpson - Director, Remote Sensing Technology, MDA Scientific Inc.
                   Paul D. White - Business Director, Environmental Projects, Johnson Matthey Corp.
    Panel C: Vehicular emissions control technologies                            CALVERT ROOM
      Moderator:    Bruce Bertelsen - Executive Director, Manufacturers of Emission
                          Controls Association
      Panelists:     John S. Hovvitt - Manager, New Technical Ventures, Allied Signal Corp.
                    Reginald Modlin - Manager of Vehicle Emissions Regulatory Programs,
                          Chrysler Corporation
                    John Mooney - Manager, Technology and New Applications, Engelhard Corp.
                    Dr. George M. Sverdrup - Program Manager, Battelle Memorial Institute
    Panel D: Alternative vehicle technologies                                    WARREN ROOM
      Moderator:   Phil Barnett - U.S. House of Representatives, Subcommittee on
                          Health and Environment
      Panelists:    Martin J. Bernard HI - Manager, National Station Car Association
                   Gorik Hossepian - Director, Fuel Cell Program, Allied-Signal Aerospace Co.
                   Dr. Roberta J. Nichols - Electric Vehicle External Strategy Manager,
                          Ford Motor Company
                   Paul Gifford - Director, Product Development, Energy Conversion Devices, Inc.
      The Clean Air Marketplace Conference and Exhibition
  Page A-4                                        Appendix A — Conference Program

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September 8 (continued)
4:15 - 6:15 p.m.
SESSION 4:  CONTROL TECHNOLOGIES AND SERVICES - II
       These four panels continue our examination of specific technologies and services. Panel A examines service opportunities
       in the electric power market, notably including allowance trading and demand-side management. Panel B focuses on
       the increasingly important subject ofNOf control approaches, including fuel switching. Panel C examines the growth
       market in services related to vehicular emissions control. Panel D features a discussion about the leading candidate
       alternative fuels, including reformulated gasoline.

    Panel A : Electric power services (including DSM)                            MARSHALL ROOM
       Moderator:    Renge Rico - Chief, Market Innovations Branch, Acid Rain Division, U.S. EPA
       Panelists:     Carlton Bartels - Director, Environmental Brokerage Services, Cantor Fitzgerald
                    William F. Hederman - Managing Director, R.J. Rudden Associates, Inc.
                    John B. Henry, n - President, Clean Air Capital Markets
                    Jeffrey W. VanSant - Vice President and Director of Fuel Supply, New England
                          Power Company
    Panel B: Stationary source NOx control approaches (including fuel switching)        HOLMES ROOM
      Moderator:    Joseph A. Belanger - Director of Planning and Standards, Bureau of Air
                          Management, Connecticut Department of Environmental Protection
      Panelists:     Vincent M. Albanese - Vice President, External Affairs, Nalco Fuel Tech
                    Joel Bluestein - Director, Gas-Based NOx Control Center
                    Mitchell B. Cohen - Senior Consulting Engineer, Asea Brown Boveri,
                          Combustion Engineering Systems
                    Dr. Michael J. Wax - Deputy Director, Institute of Clean Air Companies
    Panel C: Vehicular emissions control services                               CALVERT ROOM
      Moderator:    Kenneth Thomas - Marketing Manager, IM Systems, Horiba Systems, Inc.
      Panelists:     William Dell - Director of Marketing, Systems Control Corp.
                    Jay Gordon - President, Gordon Darby Corp.
                    Daniel Grubbe - Manager, Vehicle Emissions Inspection Program, Arizona
                          Department of Environmental Quality
                    Gary Huggins - Executive Vice President, Coalition for Safer, Cleaner Vehicles
    Panel D: Alternative fuels                                                 WARREN ROOM
      Moderator:    Charles L. Gray, Jr. - Director, Regulatory Programs and Technology, Office of
                          Mobile Sources, U.S. EPA
      Panelists:     William Holmberg - Regulatory Advisor, National SoyDiesel Development Board
                    Jerrold L. Levine - Director for Corporate Studies, Amoco Oil Corporation
                    Raymond Lewis - President, American Methanol Institute
                    Carl Moyer - Chief Scientist, Acurex Environmental Corporation
                    Jeffrey Seisler - Executive Director, Natural Gas Vehicle Coalition
                    I
      The Clean Air Marketplace Conference and Exhibition
 Appendix A — Conference Program                                        Page A-5

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Septembers  (continued)
6:30 - 8:00 p.m.                           SOUTH COTILLION BALLROOM AND MEZZANINE




     Reception (cash bar)




     Reception will be held in exhibits area. Conference participants are encouraged to tour the exhibits.
     The Clean Air Marketplace Conference and Exhibition
  Page A-6                                Appendix A — Conference Program

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September 9
8:30 - 9; 15 a.m.    Keynote Address	NORTH COTILLION BALLROOM
        p^kfir; HlfeH0itor&l>le Sfenatp Max B9treu$» Ch^irtn^n of th« Senate Enviroameflt sftd
9:30 -11:30 a.m.
SESSIONS: ROLE OF THE GOVERNMENT IN SUPPORTING THE CLEAN AIR MARKETPLACE
      Session 5 panels examine the role of all levels of government in facilitating and supporting the clean air marketplace.
      Panel A focuses on how Federal, state, and local government regulations can help shape the market for new clean air
      technologies. Panel B addresses government's role in directly supporting the development and diffusion of innovative
      technologies. Panel C is the first of several conference discussions about exports of clean air technologies, in this case
      how the Federal government can promote such exports.

    Panel A: Federal, state, and local regulatory programs                      MARSHALL ROOM
      Moderator:   S.  William Becker - Executive Director, State and Territorial Air Pollution Program
                          Administrators
      Panelists:    Michael Bradley - Executive Director, Northeast States for Coordinated Air Use
                          Management
                   Robert Brenner - Acting Deputy Assistant Administrator, OAR, U.S. EPA
                   Bruce S. Carhart - Executive Director, Ozone Transport Commission
                   David Jordan - Former Administrator, Indianapolis Air Pollution Control Division;
                          Senior Project Manager, ERM Midwest
    Panel B: Technology development and diffusion                             HOLMES ROOM
       Moderator:   Steve Harper - Senior Policy Analyst, Office of Air and Radiation, U.S. EPA
       Panelists:    Dr. Joseph D. Ben-Dak - Chief, Global Technology Group, United Nations
                          Development Programme
                   Robb Lenhart - Director of Business Services, National Environmental Technology
                          Applications Center
                   Timothy Mohin - Senior Fellow, U.S. Senate Environment and
                          Public Works Committee
                   Nick Nikkila - Director, Economic Development and Business Retention,
                          South Coast Air Quality Management District
    Panel C: Export promotion                                                WARREN ROOM
      Moderator:   Richard A. Wegman - Partner, Garvey, Schubert, and Barer
      Panelists:    Lewis P. Reade - Director General, U.S .-Asia Environmental Partnership, U.S. AID
                   F. Bradford Smith - President and CEO, Environmental Elements Corporation
                   Rodney Sobin - Analyst, U.S. Congress, Office of Technology Assessment
       The Clean Air Marketplace Conference and Exhibition
  Appendix A — Conference Program                                       Page A-7

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September 9 (continued)
11:30 a.m. -12:45 p.m.  Lunch Break (Free Time)
1:00 - 1:45 p.m.   Keynote Address                    NORTH COTILLION BALLROOM
                         r, Apling Deprty Assistant A&ainisftatqr.



     Speaker; Donald A. JPeieso* President and CEO of Research»CottreH Compaoies
     The Clean Air Marketplace Conference and Exhibition
  Page A-8                               Appendix A — Conference Program

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September 9 (continued)
2:00-4:00 p.m.
SESSION 6: CONNECTIONS AMONG CLEAN AIR ACT/ISTEA/               MARSHALL ROOM
            ENERGY POLICY ACT
      This panel brings senior Federal and local policymakers together -with leaders from the NGO and corporate sectors to
      examine the many interfaces among the Clean Air Act Amendments, the Intermodal Surf ace Transportation Efficiency Act,
      and the Energy Policy Act of 1992,

      Moderator:   Susan F. Tierney - Assistant Secretary, Office of Policy Planning and Program
                          Evaluation, U.S. Department of Energy
      Panelists:    G.B. Arrington, Jr. - Director of Strategic and Long-Range Planning, Tri-Met
                   Joseph Goffman - Senior Attorney, Environmental Defense Fund
                   Ben G. Henneke - President, Clean Air Action Corporation
                   Michael J. Stanton - Director, Federal Liaison Department, American Automobile
                          Manufacturers Association
                   Mary Margaret Whipple - Vice Chairman, Arlington County Board, and Member,
                          Washington Metropolitan Area Transit Authority Board


SESSION 7: THE GLOBAL CLEAN AIR MARKETPLACE -                     HOLMES ROOM
            EXPORT OPPORTUNITIES
      This panel continues the conference's examination of export issues. The focus this time is on specific export opportunities
      that companies with competitive clean air technologies and services can capitalize on. Executives of companies which
      have been successful in the export market share their experiences.

      Moderator:   Donald L. Connors, Esq. - President, Environmental Business Council of the U.S., Inc.
      Panelists:    Alvin L. Aim - Senior Vice President, Science Applications International Corp.
                   Alan N. Scarsella - Director, International Business Development, Wahlco
                          Environmental Systems, Inc.
                   John T. Schofield - President & CEO, Thermatrix, Inc.
                   Roger Strelow - Vice President, Environmental Affairs, Bechtel Corporation
                   Russell Sturm - Program Director, Private Sector Activities, International
                          Institute for Energy Conservation

SESSION 8: LOOKING TO THE FUTURE - NEW DIRECTIONS FOR            WARREN ROOM
            ENVIRONMENTAL TECHNOLOGY
      Where is the next generation of clean air, pollution prevention, and energy efficiency technology headed? These experts
      provide their diverse perspectives on this important topic.

      Moderator:   Richard E. Ayres, Esq. - Partner, O'Melveny & Myers
      Panelists:    Braden R. Allenby - Research Director, Technology and Environment, AT&T
                   Howard Geller -Executive Director, American Council for an Energy
                          Efficient Economy
                   Dr. Richard Klimisch - Vice President, Engineering Affairs Division, American
                          Automobile Manufacturers Association
                   Bruce Smart - Senior Fellow, World Resources Institute
      The Clean Air Marketplace Conference and Exhibition
 Appendix A — Conference Program                                       Page A-9

-------
September 9  (continued)
4:15-6:15 p.m.
SESSION 9: PUBLIC/PRIVATE PARTNERSHIPS IN CLEANING THE AIR     MARSHALL ROOM
      Cleaning the air requires more than state-of-the-art technology. At the state and local level it requires building coalitions
      of diverse interests. This panel features public and private sector leaders from several different states who have helped
      build effective public/private partnerships.

      Moderator:   Steven Howards - President, Environmental Strategies
      Panelists:    Steven Coffin - Vice President, Colorado Interstate Gas Company; Vice Chairman,
                          Colorado Air Quality Control Commission
                   Daniel Greenbaum - Commissioner, Massachusetts Department of Environmental
                          Protection
                   Bfln G. Henneke - President, Clean Air Action Corporation
                   Isaac Manning - North Texas Air Coalition
SESSION 10: FINANCING THE CLEAN AIR MARKETPLACE
      Financing the clean air marketplace presents many challenges and opportunities. Panel A focuses onfmancing specific
      companies and projects. Panel B addresses the financing of exports and foreign investments.

    Panel A: Financing companies and projects                                  HOLMES ROOM
      Moderator:   Robert Brenner - Acting Deputy Assistant Administrator,  Office of Air and
                         Radiation, U.S. EPA
      Panelists:     Jerry Esmay - Environmental Project Specialist, International Finance Corporation
                   Robert Grady - Vice President, Robertson Stevens & Co.
                   James H. McCall - President, Environmental Capital Corporation
                   Frank Pope - General Partner, Technology Funding, Inc.
                   Jake Tarr - Vice President, Arete Ventures
    Panel B: Financing exports and investments                                 WARREN ROOM
      Moderator:   William A. Delphos - President, Delphos International
      Panelists:    Harvey Himberg - Director, Development Policy and Environmental Affairs,
                          Overseas Private Investment Corp.
                   Edward Sanders - President, Sanders International
                   John Wisniewski - Vice President, Export-Import Bank of the United States
      The Clean Air Marketplace  Conference and  Exhibition
   Page A-10                                      Appendix A — Conference Program

-------
                        Clean Air Marketplace
                            Steering Group
         Richard E.A;pm, Esq.
              Pdrmr
          O'Melveagwitf Myers
            Urtice Bertelsen
           Michael Bradley
             Dale Brooks
              Conmtiwt
          ftrrnksmd Associates
        OonaldJU.
         Cheryl M. Fates-, JEsq,
                                                    r. Thomas Haiuser
                                                         . Muggins
                                                        Vic* President
                                             CoaM&rt for Safer, CU&mr VMtks
      William I, King
ufatpry Manager,
    •Ford Motor Campatty

      ErifeJ.Mcyas -
      Gettertit Cffw&el
  Environmental Law Institute
       NickNikkito
   , Kcottowc Dewfopment Program
                                                 Robert Px OuelfeEfe, Sr.
                                                   Deborah Sheiman
                                                   Resource Spzdtitist
                                             Natural Resources Offense Comtil

                                                    Jeffrey C Smith
                                                   Sx&cutive director
                                                    Paul Wilkinson
                                          Director, Pettey and Environmental Anatysiy
                                                American Gas Association
Appendix A — Conference Program
                     PageA-U

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APPENDIX B
 Exhibitors

-------
                                           Exhibitors
Air Daily
4418 Mac Arthur Boulevard
Washington, DC 20007
(202) 298-8201
Fax (202) 298-8210

The American  Institute of Chemical Engineers
345 East 47 Street
New York, NY 10017
(212) 705-8124
Fax (212) 752-3294

Berty Reaction Engineers Ltd.
1806 Bent Pine Hill
Fogelsville, PA 18051-1501
(215) 391-1676
Fax (215) 391-9434

Black & Veatch
B & V Waste Science and Technology
100 CambridgePark Drive
Cambridge, MA 02140
(617) 547-2553
Fax (617) 547-1416

Brown & Root Environmental
910 Clopper Road
Gaithersburg, MD 20878-1399
(301) 258-8705
Fax (301) 258-2568

Columbia Scientific Industries
Continous Emissions Monitoring Systems
11950JollyvilleRoad
Austin, TX 78759
(609) 783-6313
Fax (609) 784-3759

EPA and DOE
Climate-Wise
401 M Street, SW
Washington, DC 20460
(202) 260-4407
Fax (202) 260-0512

Design for the  Environment
401 M Street, SW
Washington, DC 20460
(202) 260-0880
Fax (202) 260-0981
Engineering-Science, Inc.
10521 Rosehaven Street
Fairfax, VA 22030-2899
(703) 934-2319
Fax (703) 591-1305

Entropy,  Inc.
P.O. Box  12291   ,
Research  Triangle Park, NC
27709-2291
(919) 781-3550
Fax (919) 787-8442

Environmental Business Council of the U.S., Inc.
1601 Trapelo Road
Waltham, MA 02154
(617) 890-4242
Fax (617) 890-2881

Environmental Law Institute
1616 P Street, NW, Suite 200
Washington, DC 20036
(202) 939-3833
Fax (202) 328-5002

U.S. Environmental Technology Export Council
2000 K Street, NW, Suite 750
Washington, DC 20006
(202) 466-6933
Fax (202) 466-8009

Environmental Resources Management, Inc.
855 Springdale Drive
Exton, PA 19341
(215) 524-3500
Fax (215) 524-7335

EPA Green Lights Program,
Energy Star Programs
401 M Street, SW
Washington, DC 20460
(202) 233-9099
Fax (202) 233-9569

Ford Motor Company
1350 I Street, NW
Washington, DC 20005
(202) 962-5379
Fax (202) 962-5457
Appendix B — Exhibitors
                                  Page B-l

-------
                                           Exhibitors
                                         (continued)
Information Resources, Inc.
Oxy-Fuel News
Octane Week
499 South Capitol Street, SW, Suite 406
Washington, DC 20003
(202) 554-0614
Fax (202) 554-0613

Lancaster Laboratories, Inc.
2425 New Holland Pike
Lancaster, PA 17601-5994
(717) 656-2301
Fax (717) 656-2681

The Mcllvaine Company
2970 Maria Avenue
Northbrook, IL 60062
(708) 272-0010
Fax (708) 272-9673

MG Refining & Marketing Inc.
1000 Louisiana
Houston, TX  77002
(713) 759-0510
Fax (713) 759-9426

Nalco Fuel Tech
101 Frontenac Road
Naperville, IL 60563-1746
(708) 983-3242
Fax (708) 983-3240

National Association for Environmental
Management
1455 Pennsylvania  Avenue, NW, Suite 1000
Washington, DC 20004
(202) 737-3415
Fax (703) 391-2178

National Geothermal Association
Geothermal Resources Association
803 Prince Street
Alexandria, VA 22314
(703) 922-5473
Fax (703) 922-5473

Omstar Clean Air Corporation
126 Marine Avenue
Wilmington, CA 90744
(310) 835-6909
Fax (310) 835-0723
Scott Environmental Technology
6205 Route 611
Plumsteadville, PA 18949
(215) 766-7230
Fax (215) 766-2051

Scott Specialty Gases, Inc.
6141 Easton Road
P.O. Box 310
Plumsteadville, PA 18949
(215) 766-8861
Fax (215) 766-2070

Thermacon Enviro Systems
111 West 40th Street
New York, NY 10018
(212) 704-2111
Fax (212) 704-2089

U.S.-Asia Environmental Partnership
1133 20th Street, NW, Suite 300
Washington, DC 20036
(202) 835-0333
Fax (202) 835-0366

Vara International
Calgon Carbon Corporation
1201 19th Place
Vero Beach, FL 32960
(407) 567-1320
Fax (407) 567-4108

ViGYAN, Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041-2406
(703) 931-1100
Fax (703) 820-4322

W. L. Gore & Assoc., Inc.
P.O. Box 1100
Elkton, MD 21922-1100
(410) 392-3300
Fax (410) 392-6624

Welsh Technologies
P.O. Box 4214
River Edge, N] 07661
(201) 489-3465
Fax (201) 489-3110
Page B-2
                Appendix B — Exhibitors

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APPENDIX C
 Participants

-------
                                        Participants
Dan Abbasi
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-4332

Richard F. Abrams
CeraMem Separations
20 Clematis Avenue
Waltham, MA 02154
(617) 899-0467

Eman Ahmed
Saudi Education Mission
600 New Hampshire Avenue, NW
Washington, DC 20037
(202) 298-8833

Vincent Albanese
NALCO Fuel Tech
1001 Frontenak Road
Naperville, IL 60563
(708) 983-3254

Braden R. Allenby
AT&T
131 Morristown Road
Basking Ridge, NJ 07920
(609) 639-2244

Alvin Aim
Science Applications International Corporation
1710 Goodrich Drive
McLean, VA 22102
(703) 821-4530

Arlene Anderson
U.S. Department of Energy
1000 Independence  Avenue, SW
Washington, DC 20585
(202) 586-3818

Linda Anderson-Carnahan
EPA Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2864

Phillip Andres
STAR Compliance Services
4333 Stern Avenue,  Suite 106
Sherman Oaks, CA  91423
(818) 784-3304

Mike Andrews
Int'l Brotherhood of Painters & Allied Trades
1750 New York Avenue, NW
Washington, DC 20006
(202) 637-0744

Vernon Anthony
Delmar Publishers, Inc.
5105 Cemetary Road
Milliard, OH 43026
(614) 771-7028

Edward J. Apple
SC Johnson Wax
1525 Howe Street
Racine, WI 53403
(414) 631-2761

Doug Ardell
The Mcflvaine Co.
2970 Maria Avenue
Northbrook, IL 60062
(708) 272-0010

Ross Ardell
The McDvaine Co.
2970 Maria Avenue
Northbrook, IL 60062
(708) 272-0010

G.B. Arrington
Tri-Met
4012 Southeast 17th Avenue
Portland, OR 97202
(503) 238-4977

Dwight Atkinson
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6921

Rob Atkinson
U.S Congress Office of Technology Assessment
Washington, DC 20510

James Austin
NY Senate Environ. Conservation Committee
New York State Senate,
Room 310, L.O.B.
Albany, NY 12247
(518) 455-3411
Bob Axlerad
U.S. EPA
Appendix C — Participants
                                PageC-1

-------
                                         Participants
                                         (continued)
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9315

Eric Aynsley
Scott Environmental Technology
6205 Route 611 P.O. Box 369
Plumsteadville,  PA 18949
(215) 766-7230

Richard E. Ayres
O'Melveny & Myers
555 13th Street,  N.W., Suite 500 West
Washington, DC 20004
(202)383-5211

Alan Bahl
Red Star Yeast
2100 Van Deman Street
Baltimore, MD 21224
(410) 633-8575

Michael Baker
Committee for Economic Development
2000 L Street, NW, Suite 700
Washington, DC 20036
(202) 2%-5860

Paul Balasic
Environmental Elements Corp.
P.O. Box 1318
Baltimore, MD21203
(410) 368-7143

Jennifer Barber
White  Lung Association
P.O. Box 1483
Baltimore, MD21203
(410) 243-5864

Mark Bareta
Black and Veatch
11401 Lamar Ave.
Overland Park,  KS 66062
(913) 339-2000

Christina Barnes
Stevens Publishing
1170 National Press Building
Washington, DC 20045
(202) 942-1422

Phil Barnett
U.S. House of Representatives
2415 Rayburn House Office Building
Washington, DC 20515
(202) 225-4952

Jerry Barnhill
AquAeTer, Inc.
P.O. Box 1187
Brentwood, TN  37024
(615) 373-8532

Randy Barrett
Washington Technology
1953 Gallows Road
Vienna, VA 22182
(703) 848-2800

Carlton Bartels
Cantor Fitzgerald
One World Trade Center
New York, NY 10048
(212) 938-5000

Jim Barton
Columbia  Scientific Industries Corporation
11950Jollyville Road
Austin, TX 78759
(512) 258-5191

Philip Barton
Fidelity Management and Research Co.
82 Devonshire Street
Boston, MA 02109
(617) 570-7911

Robert M.  Bates
Southwest Marine, Inc.
1300 Crystal Drive, Suite 1709S
Arlington, VA 22202
(703) 979-2270

Max Baucus
U.S. Senate
SH-511 Hart Sehate  Office Building
Washington, DC 20510-2602
(202) 224-2651

Earl Beaver
American  Institute of Chemical Engineers
345 East 47 Street
New York, NY 10017
(212) 705-7407

S. William Becker
 Page C-2
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
State & Territorial Air Pollution Program Admin.
444 North Capitol Street, NW, Suite 307
Washington, DC 20001
(202) 624-7864

William Beeman
Committee for Economic Development
2000 L Street, NW, Suite 700
Washington, DC 20036
(202) 296-5860

Joseph A. Belanger
Connecticut Department of Environmental
Protection
DEP-79 Elm Street, P.O. Box 5066
Hartford, CT 06102
(203) 566-2506

Roy Belden
Chadbourne & Parke
1101 Vermont Avenue, NW
Washington, DC 20005
(202) 962-4526

Alan Belkin
ECRA  Laboratories
273 Franklin Road
Randolph, NJ 07869
(201) 361-4252

DeWain Belote
Doed Motor Co.

Joseph Ben-Dak
United Nations Development Programme
One United Nations Plaza
New York, NY 10017
(212) 905-5027

Jeffrey A. Berg
Raymond James & Associates
880 Carillon Parkway
St. Petersburg, FL 33716
(813) 573-3800

Joan Berkowitz
Farkas Berkowitz & Co.
1220 19th Street, NW
Washington, DC 20031
(202) 833-7530
Timothy Bernadowski
Virginia Power
P.O. Box 26666
Richmond, VA 23261
(804) 771-3246

Martin J. Bernard
National Station Car Association
501 14th Street, Suite 210
Oakland, CA 94612
(510) 444-8707

Jeffrey Bernardo
Kidder Peabody & Co., Inc.
10 Hanover Square, 15th Floor
New York, NY 10005
(212) 510-3792

Bruce Bertelsen
Manufacturers of Emission Controls Association
1707 L Street, NW
Washington, DC 20036
(202) 296-4797

Jozsef Berty
Berty Reaction Engineers, Ltd.
1806 Bent Pine Hill
Fogelsville, PA 18051-1501
(215) 391-1676

Clifton Bittle
Environmental Science & Engineering, Inc.
P.O. Box 1703
Gainesville, FL 32607
(904)333-6601,

Thomas Black
U.S. General Accounting Office
441 G Street, NW
Washington, DC 20548
(202) 512-2867

Donald Bliss
O'Melveny & Meyers
555 13th Street, NW, Suite 500 West
Washington, DC 20004

Bernard Bloom
Grumman
1760 Business Center Drive
Reston, VA 22096
(703) 438-5479
Appendix C — Participants
                                Page C-3

-------
                                        Participants
                                        (continued)
Joel Bluestein
Gas-Based NOX Control Center
1655 N. Fort Myer Drive, Suite 600
Arlington, VA 22209
(703) 243-4947

Debbie Boger
Design for the Environment, U.S. EPA
401 M Street, NW
Washington, DC 20460
(202) 260-0880

Ben Bonifant
Management Institute for Environ, and Business
1220 16th Street, NW
Washington, DC 20036
(202) 833-6556

Stuart Bone
Environmental Business Journal

Wood Bouldin
Columbia Scientific Industries Corporation
11950 Jollyville Road
Austin, TX 78759
(512) 258-5191

Ella S. Bowman
WNC Regional Air Pollution Control Agency
Buncombe County Courthouse
Asheville, NC 28801-3569
(704) 255-2655

Herbert Braden
Noell, Inc.
2411 Dulles Corner Park, Suite 410
Herndon, VA 22071
(703) 793-6500

Hazel Bradford
McGraw-Hill/ENR
1200 G Street NW - Main Office
Washington, DC 20005
(301) 229-1001

Michael Bradley
Northeast States for Coordinated Air Use  Mgmt.
85 Merrimac Street
Boston, MA 02114
(617) 367-8540
Michael Brandon
S+ME, Inc.
3100 Spring Forest Road
Raleigh, NC 27604
(919) 872-2660

Ronald Braun
IT Corp.
11499 Chester Road
Cincinnati, OH 45246
(513) 782-4600

Rhea Brekke
New Jersey Department Environmental
Protection & Energy
401 East State Street, CN  402
Trenton, NJ 08625-0402
(609) 984-1484

Robert Brenner
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-7400

Jeanne Briskin
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-5520

Kevin Bromberg
Law Offices of Kevin L. Bromberg
1725 K Street, NW
Washington, DC 20006
(202) 775-8146

Dale Brooks
American Institutue of Chemical Engineers
1300 Eye Street, NW
Suite 1090 - East Tower
Washington, DC 20005
(202) 962-8690

Gregory A. Brown
Stone & Webster Engineering Corporation
1201 Connecticut Avenue, NW
Washington, DC 20036
(202) 466-7415
Page C-4
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Carol M. Browner
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-4700

Susie Bruninga
BNA
1231 25th Street, NW
Washington, DC 20037
(202) 452-5358

Kevin R. Bryson
Stone & Webster Engineering Corporation
#3 Executive Campus
Cherry Hill, NJ 08034
(609) 482-3677

Tom Burgum
Burgum and Grimm, Ltd.
106 North Carolina Avenue, SE
Washington, DC 20003
(202) 546-3414

Richard M. Burke
Lancaster Laboratories
2425 New Holland Pike
Lancaster, PA 17601-5994
(717) 656-2301

C. Shepherd Burton
ICF Kaiser Engineers
Environment Group
101 Lucas Valley Road
San Raphael, CA 94903
(415) 507-7101

Barbara Bush
American Petroleum Institute
1220  L Street, NW
Washington, DC 20005
(202) 682-8450

Bill Byers
CH2M  Hill Co.
2300 NW Walnut Boulevard
Corvallis, OR 97330-3538
(503) 752-4271
Jeff Campbell
Board of Trade of the City of Chicago
141 West Jackson Boulevard
Chicago, IL 60604
(312) 341-7264

Melissa  Carey
Electronic Industries Association
2001 Pennsylvania Avenue
Washington, DC 20006-1813
(202) 457-8733

Bruce Carhart
Ozone Transport Commission
444 N. Capitol Street, Suite  604
Washington, DC 20001
(202) 508-3840

David Carlton
Mitchell International
9889 Willow Creek Road
San Diego, CA 92131
(619) 530-8955

Mark V. Carney
U.S. Generating Company
7475 Wisconsin Avenue
Bethesda, MD 20814
(301) 718-6800

Gale J. Carr
Ogden Martin Systems Inc.
2200 Wilson Boulevard, #600
Arlington, VA 22201
(703) 875-8900

David Carstater
LICA Systems, Inc.
10400 Eaton Place, Suite 302
Fairfax,  VA 22030
(703) 359-0996

Donald  Carter
S+ME, Inc.
3100 Spring Forest Road
Raleigh, NC 27604
(919) 872-2660

Bhaskar Chandan
Carnot
15991 Red Hill Ave
Tustin, CA 92626
(714) 259-9520
Appendix C — Participants
                                 Page C-5

-------
                                        Participants
                                        (continued)
Peter Charrington
ERM Inc.
855 Springdale Drive
Exton, PA 1^341
(215) 524-3500

Rahul Chettri
ViGYAN Inc.
5203 Leesburg  Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100

Steve Cochran
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-7428

Steven Coffin
Colorado Interstate Gas Company
P.O. Box 1087
Colorado Springs, CO 80944
(303) 573-4425

Mitchell B. Cohen
Asea Brown Boveri
Combustion Engineering Systems
1000 Prospect Hill Road
Windsor, CT 06095
(203) 285-2482

Kenneth Cole
American Nuclear Services
P.O. Box 87
Etna, OH 43018-0087
(614) 964-0130

Libby Conde
Entropy, Inc.
P.O. Box 12291
Research Triangle Park, NC 27709-2291
(919) 781-3550

Raymond Connor
Manufacturers of Emission Controls Association
1707 L Street, NW, Suite 570
Washington, DC 20036
(202) 296-4797
Donald' L. Connors
Environmental Business Council of the U.S., Inc.
Choate, Hall & Stewart
53 State Street
Boston, MA 02109
(617) 482-1390

Glenn Conover
Sutron Corporation
21300 Ridgetop Circle
Sterling, VA 20166
(703) 406-2800

Nancy Cookson
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
(202) 887-1241

Clare Corcoran
Bruce Environmental
1850 K Street, NW, Suite 290
Washington, DC 20006
(202) 775-6655

Julie Crippen
The Crippen Companies
10132 G&H Colvin Run Road
Great Falls, VA 22066
(703) 759-5900

Linda Critchfeld
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9087

Ted Cromwell
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, DC 20037
(202) 887-1383

Eugene Grassland
Pure Air Corporation
7540 Windsor Drive
Allen town, PA 18195
(215) 481-5589
 Page C-6
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
John K. Crum
American Chemical Society
1155 16th Street, NW
Washington, DC 20036
(202) 872-4534

Thomas V. Crumley
Energy and Environmental Sales Corporation
650 Poydras, Suite 2045
New Orleans, LA 70130
(504) 523-1509

Richard Cudahy
SYCOM Enterprises
7475 Wisconsin Avenue
Bethesda, MD 20814
(301) 718-6600

Kate Cudlipp
Environmental Business Journal
2415 20th Street, NW
Washington, DC 20009

Kevin Curtis
Virginia Power
P.O. Box 26666 OJRP/9
Richmond, VA 23261
(804) 771-6358

Gene D'Andrea
CSCV National Education Resource Center
U.S. Highway 1
Morrisville, PA 19067
(215) 295-0722

Robert Daly
Balston, Inc.
260 Neck Road
Haverhill, MA  01835
(508) 374-7400

Kathleen Daniel

R. Gene Darnell
EPA -  CERT/Univ. of Michigan
2565 Plymouth Road
Ann Arbor, MI 48105
(313) 741-7851

John Darrow
W.L. Gore & Associates, Inc.
101 Lewisville Road
Elkton, MD 21921
(410) 392-3300
Carolyn Dawson
Coal & Synfuels Technology
1616 North Fort Meyer, Suite 1000
Arlington, VA 22209
(703) 528-1244

David De Bruyn
EPA Region 10
1200 6th Avenue/8T-082
Seattle, WA 98101
(206) 553-4973

Rich Deblasi
Environmental Maintenance Solutions, Inc.
P.O. Box  37
Thornwood, NY 10594
(914) 747-1583

Mike Deegan
Teledyne Environmental Systems
2111 Wilson Boulevard, Suite 1100
Arlington, VA 22201

Donald A. Deieso
Research-Cottrell Companies
P.O. Box  1500
Somerville, NJ 08876
(908) 685-4255

William Dell
Systems Control Corporation
755 North Mary Avenue
Sunnyvale, CA 94086
(410) 280-0088

William A. Delphos
Delphos International
3000 K Street, NW, Suite 690
Washington, DC 20007
(202) 237-6300

Faustin Denis
Industrial Environmental Technologies
234-18 133rd Avenue
Rosedale, NY 11422
(718) 276-2300

Carolyn DeVinny
The DeVinny Group
13101 Washington Boulevard
Los Angeles, CA 90066
(310) 306-8584
Appendix C — Participants
                                 Page C-7

-------
                                        Participants
                                        (continued)
Deborah DeYoung
Committee on Environmental and Public Works
U.S. Senate
Washington, DC
(202) 224-6176

Scott R. Dismukes
Doepken Keevican Weiss & Medved
37th Floor, USX Tower, 600 Grant Street
Pittsburgh, PA 15219
(412) 355-2641

Karen Doerschug
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031-1207
(703) 218-2509

David A. Doles
Engelhard Corporation
101 Wood Avenue
Iselin, N] 08830
(908) 205-5237

Cathy Dombrowski
Airtech News
14120 Huckleberry Lane
Silver Spring, MD 20906
(301)871-3299

Lise Dondy
Connecticut  Innovations, Inc.
845 Brook Street
Rocky Hill, CT 06067
(203) 258-4305

Perle Don-
National Geothermal Association
803 Prince Street
Alexandria, VA 22314
(703) 836-3654

Donna Downing
U.S. Congress Office of Technology Assessment
Washington, DC 20510

Brenda Doyle
U.S. EPA
401 M Street, SW
Washington, DC 20460
David Driesen
Natural Resources Defense Council
1350 New York Avenue, NW, Suite 300
Washington, DC 20005

Elizabeth Drye
U.S. Senate
316 Senate Hart Building
Washington, DC 20510
(202) 224-4042

Dennis Dubberley
Brown & Root Environmental
910 Clopper Road
Gaithersburg, MD 20878-1399
(301) 258-8621

Dana Dudley
Texas Instruments Inc.
P.O. Box 650311, M/S 3933
Dallas, TX 75265
(214) 917-6212

Damian Durrant
Greenpeace
1436 U Street, NW
Washington, DC 20009
(302) 319-2518

Shari Effman
Thermacon Enviro Systems
345 New Albany  Road
Moorestown, N] 08057
(609) 235-9471

Scott Ellensworth
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
(202) 887-1286

William Elliott
Northern Indiana Public Service Company
801 E. 86th Avenue
Merrillville, IN 46410
(219) 647-6024

Kathy Ellis
NAVFAC Chesapeake Division

Barbara Ennis
National Association for Environ. Management
131 Morristown Road
Basking Ridge, NJ 07920
 Page C-8
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
Richard C. Entz
Lancaster Laboratories
2425 New Holland Pike
Lancaster, PA 17601-5594
(717) 656-2301

Michael Epstein
National Inst. of Standards and Technology
A303/222
Chemical Science & Technology Laboratory
Gaithersburg, MD 20899
(301) 975-3385

Jerry Esmay
International Finance Corporation
1850 I Street, NW
Washington, DC 20433
(202) 473-0661

Caren Ewing
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-2556

Heidi Farber
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-2632

Alan Farkas
Farkas Berkowitz & Co.
1220 19th Street, NW
Washington, DC 20031
(202) 833-7530

Ralph Fasano
White Cap, Inc.
1819 N. Major Avenue
Chicago, IL 60639
(312) 637-2000

Denis Faustin
Industrial Environmental Technologies
234-18 133rd Avenue
Rosedale, NY 11422
(718) 276-2300
Steven Feeney
Babcock & Wilcox, Inc.
20 South Van Buren Avenue, P.O. Box 351
Barberton, OH 44203-0351
(216) 860-2783

Sarah S. Fehrer
Science and Policy Associates, Inc.
West Tower, Suite 400,1333 H Street, NW
Washington, DC 20005
(202) 789-1201

Stephen Felix
Lenzing USA Corp.

Danielle Fern
Manufacturers of Emission Controls Association
1707 L Street, NW
Washington, DC 20036
(202) 296-4797

Larry Ferrell
B&W Nuclear Technologies
3315 Old Forest Road
Lynchburg, VA 24501
(804) 385-3560

Louis Fiorucci
EMS Environmental, Inc.
801 East Street
Frederick, MD 21701
(301) 695-5828

T. Gary Flynn
Santa Fe Technologies
2642 Wild Cherry Place
Reston, VA 22091
(703) 715-2556

Marcie Francis
TAS, Inc.
1000 Potomac Street, NW
Washington, DC 20007
(202) 337-1744

Patricia Franco
Electronic Industries Association
2001 Pennsylvania Avenue, NW, Suite 1100
Washington, DC 20006
(202) 457-8703
Appendix C — Participants
                                 Page C-9

-------
                                         Participants
                                         (continued)
Julie Frieder
U.S.  EPA
401 M Street, SW
Washington, DC 20460
(202) 260-2741

James Frock
Scott Environmental Technology
6205 Route 611, P.O. Box 369
Plumsteadville, PA 18949
(215) 766-7230

Charles L. Fryxell
Mojave Desert Air Quality Management District
15428 Civic Drive, Suite 300
Victorville, CA 92392
(619) 245-1661

Celeste Furr
Information Resources, Inc.
499 S. Capitol Street, SW
Washington, DC 20003
(202) 554-0614

Lee  D. Garrigan
American Consulting Engineers Council
1015 15th Street, NW, Suite 802
Washington, DC 20005
(202) 347-7474

Walter Gehlmann
ViGYAN Inc.
5203 Leesburg Pike, Sbite 900
Falls Church, VA 22041
(703) 931-1100

Howard Geller
American Council for an Energy Efficient
Economy
1001 Connecticut Avenue, NW, Suite 801
Washington, DC 20036
(202) 429-8873

Mary Beth Gentleman
Foley,  Hoag & Eliot
One Post Office Square
Boston, MA 02109
(617) 482-1390

Rodney A. Gibson
Geraghty and Miller, Inc.
2840 Plaza Place, Suite 350
Raleigh, NC 27612
(919) 571-1662
Paul Gifford
Energy Conversion Devices, Inc.
1707 Northwood Drive
Troy, MI 48084
(313) 362-1750

Carl A. Gilbert
Dravo Lime Company
3600 One Oliver Plaza
Pittsbugh, PA 15222
(412) 566-5501

Eric Gilchrist
9130 Weant Drive
Great Falls, VA  22066
(703) 820-4524

Debra Giles
Ferrofluidics
40 Simon Street
Nashua, NH 03061
(603) 883-9800

Jennifer Giles
Enviro-Management and Research, Inc.
1015 18th Street, NW
Washington, DC 20036
(202) 293-5300

Jajiet Gille
Alliance for Acid Rain Control
444 N. Capitol Street, Suite 602
Washington, DC 20001
(202) 624-8199

Jerry Gillespie
Callidus Technologies, Inc.
7130 South Lewis, Suite 635
Tulsa, OK 74136
(918) 496-7599

William Gillespie
District of Columbia
2100 Martin Luther King Jr. Boulevard, SE
Washington, DC 20020
(202) 404-1180

Joseph Goffman
Environmental Defense Fund
1875 Connecticut Avenue, Suite 1016
Washington, DC 20006
(202) 387-3500
 Page C-10
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Thomas Goldsmith
National Association for Environmental Mgmt.
1455 Pennsylvania Avenue, NW, Suite 1000
Washington, DC 20004
(202) 737-3415

Jay Gordon
Gordon Darby Corporation
2410 Ampere Drive
Louisville, KY 40299
(502) 266-5798

L. Barry Goss
Science Applications International Corporation
P.O. Box 2502
Oak Ridge, TN 37831
(615) 481-4609

Robert Grady
Robertson Stevens & Company
555 California Street
San Francisco, CA 94123
(415) 781-9700

Geneva Graham
The Port Authority of New York & New Jersey
One World Trade Center, Room 64E
New York, NY 16048
(212) 435-4065

Anne Grambsch
U.S. EPA
401 M Street, SW PM 221
Room 3009
Washington, DC 20460
(202) 260-5728

Charles L. Gray
U.S. EPA
2565 Plymouth Road
Ann Arbor, MI 48105
(313) 668-4404

Neil Gray
Highway Users Federation
1776 Massachusetts Avenue, NW
Washington, DC 20036
(202) 857-1217

Daniel Greenbaum
Massachusetts Dept. of Environmental Protection
One Winter Street
Boston, MA 02108
(617) 292-5856
Lestelle Greenwalt
MEMA
1325 Pennsylvania Avenue, NW, Suite 600
Washington, DC 20004
(202) 393-6362

Daniel Grubbe
Arizona  Department of Environmental Quality
600 North 40th Street
Phoenix, AZ 85008
(602) 207-7017

Tom Guay
Environmental Compliance Alert
12413 Ellen Court
Silver Spring, MD 20904
(301) 622-9078

Shannon Guernsey
American Lung Association of Northern Virginia
9735 Main Street
Fairfax, VA 22031
(703) 591-4131

Leah Gurowitz
Podesta  Associates,  Inc.
1001 G Street, NW
Washington, DC 20001
(202) 393-1010

Burl Haigwood
Fuel Reformation
499 S. Capitol Street, SW, #406
Washington, DC 20003
(202) 554-0614

John Hakel
AGC of  California
1255 Corporate Center Drive
Monterey Park, CA 91754
(213) 263-1500

Stephen  Hall
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-5016

Ed Haltom
United Elchem Industries, Inc.
11535  Reeder Road
Dallas, TX 75229
(214) 241-6601
Appendix C — Participants
                               Page C-11

-------
                                        Participants
                                        (continued)
George Hansen
Arthur Andersen, & Co.
711 Louisiana
Houston, TX 77401
(713) 237-5011

LuAnne Hansen
Automotive Chemical Manufacturers Council
1325 Pennsylvania Avenue, NW
Washington, DC 20004
(202) 393-6362

Penny Hansen
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 253-9150

Steve Harper
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-5580

Matthew Harrington
Clean Air News
501 Slaters Lane, #320
Alexandria, VA 22314
(703) 549-3823

Thomas Hauser
American Institute of Pollution Prevention
c/o University of Cincinnati
Mail Location 71
Cincinnati, OH 45221
(513) 556-2517

David Hawkins
Natural Resources Defense Council
1350 New York Avenue, NW, Suite 300
Washington, DC 20005
(202) 783-7800

Richard Head
SRS Technologies
1500 Wilson Boulevard
Arlington, VA 22209
(703) 522-5588
William F. Hederman
R.J. Rudden Associates, Inc.
1110 N. Glebe Road, Suite 725
Arlington, VA 22201
(703) 812-8500

Holly Hegner
O'Melveny & Meyers
555 13th Street, NW, Suite 500 West
Washington, DC 20004
(202) 383-5300

John Heiderscheit
Chadbourne & Parke
1101 Vermont Avenue, NW, Suite 900
Washington, DC 20005
(202) 289-3000

Jeffrey Heim'erman
U.S. EPA
Crystal Station One
2805 Jefferson Davis Highway
Arlington, VA 22202
(703) 308-8806

J Fred Heitman
JAYCOR Environmental
1608 Spring Hill Road
Vienna, VA 22182
(703) 847-4000

Gary Helms
CH2M Hill
P.O. Box 4400
Reston, VA 22090-1483
(703) 471-1441

Ben Henneke
Clean Air Action Corporation
320 S. Boston, Suite 1501
Tulsa, OK 74103
(918) 592-0300

John B. Henry
Clean Air Capital Markets
1250 24th Street, NW, Suite 300
Washington, DC 20037
(202) 466-0520

Pam Herman
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-8705
 Page C-12
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
Thomas M. Heron
UEC Environmental Systems
600 Grant Street, Suite 770
Pittsburgh, PA 15219-4776
(412) 433-6572
f
Robert Herzstein
Southern California Edison
2244 Walnut Grove Avenue, Room 399
Rosemead, CA 91770
(818) 302-7479

Jon Hiler
American Society of Agricultural Engineers
2950 Niler Road
St. Joseph, MI 49085
(616) 429-0300

A. Judson Hill
Florida First Processing
One Church Street, Suite 801
Rockville, MD 20850
(301) 762-6115

William R. Hill
Entech, Inc.
560 Oak Ridge Turnpike
Oak Ridge, TN 32830
(615) 481-3231

Harvey Himberg
Overseas Private Investment Corporation
1100 New York Avenue, NW
Washington, DC  20527
(202) 336-8400

Russell A. Hinz
American Lung Association of Northern Virginia
9735 Main Street
Fairfax, VA 22031
(703) 591-4131

Barbara Hirsch
APPA
1446 Duke Street
Alexandria, VA 22314
(703) 684-1446

Robert Hirsch
Parsons Environmental Services, Inc.
321 Norristown Road, Suite One
Ambler, PA 19002
(215) 540-4211
James Holian
Brown & Root Environmental
910 Clopper Road
Gaithersburg, MD 20878-1399
(301) 258-8705

Elise Holland
U.S. Congress Office of Technology Assessment
Washington, DC 20510
(202) 228-6858

William Holmberg
National SoyDiesel Development Board
499 S. Capitol Street, SW
Washington, DC 20003
(202) 554-1025

John Hoppe
Burns and Roe
812 Old Lee Highway
Fairfax, VA 22031
(703) 207-0800

Dirk Horn
Noell, Inc.
2411 Dulles Corner Park, Suite 410
Hemdon, VA 22071
(703) 793-6500

Betsy Horsman
U.S. ETEC

Gorik Hossepian
Allied Signal Aerospace Company
2525 West 190th Street, P.O. Box 2960
Torrance, CA 90509
(310) 512-1932

Mark Howard
National Association of Regional Councils
1700 K Street, NW, Suite 1300
Washington, DC 20006
(202) 457-0710

Steven  Howards
Environmental Strategies
1600 Wynkoop Street, Suite 200
Denver, CO 80202
(303) 436-1860
Appendix C — Participants
                                                             Page C-13

-------
                                         Participants
                                         (continued)
John Howitt
Allied Signal Corporation
P.O. Box 580970
Tulsa, OK 74158
(918) 266-1406

John Huffman             j
Kenetech/U.S.  Wind Power, Inc.
1730 M Street,  NW, Suite 1050
Washington, DC 20036
(202) 833-8954

Gary Huggins
Coalition for Safer, Cleaner Vehicles
321 D Street, NE
Washingotn, DC 20002
(202) 543-4499

Carrie Hunter
ECO Magazine
1212 New York Avenue, Suite 345
Washington, DC 20005
(202) 842-8416

Joe Ingram
Island Press
1718 Connecticut Avenue, NW, Suite 300
Washington, DC 20009
(202) 232-7933

Susan Ishmael
Associated Builders & Contractors
1300 North 17th Street
Rosslyn, VA 22209
(703) 812-2039

Andy Jabali
Environmental Maintenance Solutions, Inc.
P.O. Box 37
Thorn wood, NY 10594
(914) 747-1583

Wendy  B. Jacobs
Foley, Hoag & Eliot
One Post Office Square
Boston,  MA 02109
(617) 482-1390

John Jeffery
ViGYAN, Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100
Robert Johnson
Liquid Carbonic Industries
810 Jorie Boulevard
Oak Brook, IL 60521
(708) 572-7231

Russ Jones
American Petroleum Institute
1220 L Street, NW, Suite 1200
Washington, DC 20005
(202) 682-8450

Tom Jones
Texas Instruments Inc.
P.O. Box 650311, M/S 3933
Dallas, TX 75265
(214) 917-6217

Bruce C.Jordan
U.S. EPA
Research Triangle Park, NC 27711
(919) 541-5572

David Jordan
ERM Midwest
8465 Keystone Crossing, Suite  190
Indianapolis, IN 46240
(317) 251-0708

Mark Joyce
U.S. EPA
401 M Street,  SW
Washington, DC 20460
(202) 260-4717

Mary Ellen Joyce
American Petroleum Institute
1220 L Street, NW, Suite 1200
Washington, DC 20005
(202) 682-8450

Robert Jubach
Team Environmental Services, Inc.
5320 Spectrum Drive
Frederick, MD 21701
(301) 694-5202

Jacqueline Kaldon
Emissions Exchange Corp.
1001 G Street, NW, Suite 400
Washington, DC 20001
(202) 638-1918
 Page C-14
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Gerald Karey
Oilgram News
1200 G Street, NW
Washington, DC 20005
(202) 383-2250

Marie-Ange Katzeff
Embassy of Belgium
3330 Garfield Street, NW
Washington, DC 20008
(202) 333-6900

Morris Kaufman
Stackhouse Garber
2 Todmorden Lane
Wallingford, PA 19086
(215) 565-0852

Andy Kaupert
General Motors
1660 L Street, NW
Washington, DC 20036
(202) 775-5073

Heather Anne Keith
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
(202) 887-1320

John Keller
P.O. Box 768
Olney, MD 20830-0768
(301) 774-5086

Merilynn Kessi
AMK Associates
P.O. Box 1440
Columbia, MD 21044
(410) 964-9373

James Kiefer
MidCon Development Corp.
701 E. 22nd Street
Lombard, IL 60148
(708) 691-3514

William King
Ford Motor Co.
1350 I Street, NW
Washington, DC 20005
(202) 962-5379
John Kinsman
Edison Electric Institute
701 Pennsylvania Avenue
Washington, DC 20004
(202) 508-5711   '

Brian Klatt
Rust Environment and Infrastructure
4738 N. 40th Street
Sheboygan, WI 53083
(414) 458-8711

Howard Klee
Amoco Corporation
Mail Code 4808, 200 East Randolph Drive
Chicago, IL 60601
(312) 856-2320

Andrea Klein
Intertrade Development Corporation
4825 Reservoir Road, NW
Washington, DC 20007
(202) 333-9112

Richard Klimisch
American Automobile Manufacturers Association
7430 Second Avenue, Suite 300
Detroit, MI 48202
(313) 871-2300

Adam Klinger
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9122

Charles Knebl
The Pollution Prevention Letter
P.O. Box 13315
Silver Spring, MD 20911-3315
(301) 495-7747

Terresa Knierieman
National Association of Manufacturers
1331 Pennsylvania Avenue, NW, Suite 1500 N.
Washington, DC 20004
(202) 637-3175

Chris Knopes
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6921
Appendix C — Participants
                               PageC-15

-------
                                        Participants
                                        (continued)
Warren Koenig
Scott Environmental Technology
6205 Route 611
Plumsteadville, PA 18949
(215) 766-7230

Steven A. Kohl
Raymond James & Associates
880 Carillon Parkway
St. Petersburg, FL 33716
(813) 573-3800

Zofia Kosim
U.S. EPA
Crystal Station One
2805 Jefferson Davis Highway
Arlington, VA 22202
(703) 308-8733

Andrew Kralkov
U.S. News and World Report
2400 N Street, NW
Washington, DC  20037
(202) 955-2673

Colyn Kreger
Cheryl Minor Consultants, Inc.
P.O. Box 944
Rural Hall, NC 27045
(919) 969-5755

Sue Krieg
Mojave Desert Air Quality Management District
22321 Shawnee Road
Apple Valley, CA 92307
(619) 247-4876

Joe Krumenacker
Scott Specialty Gases, Inc.
6141 Easton Road, P.O. Box 310
Plumsteadville, PA 18949
(215) 766-8861

Lisa Ann Kurbiel
United Nations Development Programme

John Paul  Kusz
Safety Kleen Corporation
1000 N.  Randall Road
Celyin, IL 60123
(708) 697-8460
Vincent Lajiness
Coastal Corporation
One Woodward Avenue
Detroit, MI 48226
(313) 496-2447

Joe Lang
Oregon Sandblasting and Coating
P.O. Box 1171
Tualatin, OR 97062
(503) 692-3575

Robert M.  Large
Lancaster Laboratories
2425 New  Holland Pike
Lancaster,  PA 17601-5994
(717) 656-2301

Amy Laspia
Environmental Management Consulting
701 Fourth Avenue, S., Suite 500
Minneapolis, MN 55145
(612) 337-9537

John Laumer
Elf Atochem North America
900 First Avenue
King of Prussia, PA 19406
(215) 337-6813

Joseph Laznow
SRS Technologies
1500 Wilson Boulevard
Arlington, VA 22209
(703) 522-5588

Dennis Leaf
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9129

Robb  Lenhart
National Environmental Technology Applications
Center
615 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5511
 Page C-16
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Jerrold L. Levine
Amoco Corporation
200 E. Randolph Drive
Chicago, IL 60611
(312) 856-2605

Raymond Lewis
American Methanol Institute
815 Connecticut Avenue, NW, Suite 800
Washington, DC 20006
(202) 467-5050

Sherri Lilienfeld
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, PA 18195
(215) 481-7501

Rosanne M. Lindsay
EPA Region 5
77 W. Jackson (AR-185)
Chicago, IL 60604
(312) 353-1151

David P. Lingo
Mid-Continent Area Power Pool
430 Century Plaza
1111 Third Avenue South
Minneapolis, MN 55404
(612) 341-4618

Jan Linsenmeyer
U.S. Congress Office of Technology Assessment
Washington, DC 20510

Steve Linsenmeyer
Liquid Carbonic Industries
8124 Norris Lane
Baltimore, MD 21222
(202) 228-6863

George Linzer
The Bruce Company
501 3rd Street,  NW, Suite 260
Washington, DC 20001
(202) 434-9364

Stephen Lipmann
Environmental Research and Analysis
140 North Broadway
Irvington, NY 10533-1215
(914) 591-7414
Laura Litvan
Nation's Business
1615 H Street, NW, Suite 300
Washington, DC 20062
(202) 463-5497

Olga Loera
ViGYAN Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100

Lon Loken
PACE, Inc.
9893 Brewers Court
Laurel, MD 20723
(301) 490-9860

Frederick Long
MEB
1220 16th Street, NW
Washington, DC 20036
(202) 833-6556

Francois Louis
Renault, USA
15 Volvo Drive, Building D
Rockleigh, NJ 07647
(201) 784-4627

Barbara Loux
Mojave Desert Air Quality Management District
22521 Shawnee Road
Apple Valley, CA 92307
(619) 247-4876

Louis Luedtke
Research-Cottrell
P.O. Box 1500
Somerville, NJ 08876
(908) 685-4255

Ilmar Lusis
Lockheed Environmental Systems &
Technologies Co.
1901 N. Fort Myer Drive, Suite 305
Arlington, VA 22209
(703) 516-9091

W. Howard Macfadden
15112 SE 2nd Street
Bellevue, WA 98007
(206) 641-0622
Appendix C — Participants
                               Page C-17

-------
                                        Participants
                                        (continued)
Carole Macko
BNA
1231 25th Street, NW
Washington, DC 20037
(202) 452-4030

Bruce Maillet
Wehran Envirotect
6 Riverside Drive
Andover, MA 01810-1121
(508) 682-1980

John Malanchuk
International Technology, Inc.
1133 21st Street, NW
Washington, DC 20036
(202) 331-8510

Karen Malkin
National Park Service
18th and C Street, NW
Washington, DC 20240
(202) 208-4911

Isaac Manning
North Texas Air Coalition
2421 Westport Parkway
Fort Worth, TX 76177
(817) 224-6010

Bella Maranion
U.S. EPA'
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9138

Stanley March
Tenneco Gas-Environmental
P.O. Box 2511
Houston, TX 77252-2511
(713) 757-8387

Jayne Mardock
Clean Air Network/NRDC
1350 New York Avenue, NW, Suite 300
Washington, DC

Larry Marigold                .
MG Refining & Marketing, Inc.
1000 Louisiana, Suite 6500
Houston, TX 77002
(713) 759-0510
Mary Markeete
American Institute of Chemical Engineers
345 East 47 Street
New York, NY 10017
(212) 705-7329

Chuck Marshall
JACA Corporation
550 Pinetown Road
Ft. Washington, PA 19034
(215) 643-5466

Mary Ann Massey
Research-Cottrell
P.O. Box 1500
Branchburg,  NJ 08876
(908) 685-4185

Suzanne Mattei
NYC Comptroller
Municipal Building, Room 517
New York, NY 10007
(212) 669-7396

Damon Matteo
Lawrence Livermore National Laboratory
P.O. Box 808, L-795
Livermore, CA 94550
(510) 423-0366

Eric Maurer
EPA Region  4
345 Courland Street
Atlanta, GA  30365
(404) 347-2864

Carol May
American Gas Association

Susan Mayer
Congressional Research Service

Larry McAfee
Air-Cure Environmental, Inc,
275 West Street, Suite 204
Annapolis, MD 21401
(410) 268-2450

James H. McCall
Environmental Capital Corporation
P.O. Box 1373
Solanal Beach, CA 92075
(619) 755-3535
Page C-18
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Maria McCann
NYNEX Government Affairs
1300 I Street NW, Suite 400 West
Washington, DC 20005
(202) 336-7882

Diana McCauley
American Institute of Chemical Engineers
345 East 47 Street
New York,  NY 10017
(212) 705-7329

Dave McDonald
Wessels, Arnold & Henderson
901 Marquette Avenue, Suite 2700
Minneapolis, MN 55402
(612) 373-6235

Peter McKenzie
Brooklyn Union Gas
One MetroTech Center
Brooklyn, NY 11201
(718) 403-3009

Terrence  McLaughlin
DOE, Energy, Research, ER-8.2
1000 Independence Avenue
Washington, DC 20585
(301) 903-6432

Gary McNeil
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9173

Paul McNeill
Coalition for Safer, Cleaner Vehicles
321 D Street, NW
Washington, DC 20002
(202) 543-4499

Peter Meeh
Enseco Air-Toxics Laboratory
5033 Stoneybrook Boulevard
Milliard, OH 43026
(614) 876-6834
Dhiren Mehta
Hughes Environmental Systems
Mail Stop MB/A20/SN206
P.O. Box 10011
Manhattan Beach, CA 90266
(310) 536-5487

Richard Mendez
Defense Fuel Supply Center
Cameron Station
Alexandria, VA 22304
(703) 274-2840

Donna Mercado
American Gas Association

James Merkel
Monex Resources, Inc.
45 NE Loop 410, Suite 700
San Antonio, TX 78216
(210) 349-4069

Dean Merkle
2500 Q Street, NW, Apartment 544
Washington, DC 20007

Susan Merther
Science and Policy Associates, Inc.
West Tower, Suite 400,1333 H Street, NW
Washington, DC 20005
(202) 789-1201

Erik J. Meyers
Environmental Law Institute
1616 P Street, NW, 2nd Floor
Washington, DC 20036
(202) 328-5150

Jeffrey A. Meyers
Columbia Gas Distribution Companies
200 Civic Center Drive
Columbus, OH 43216-0117
(614) 460-5956

Matt Middaugh
Can Manufacturers Institute
1625 Massachusetts Avenue, NW
Washington, DC 20036
(202) 232-4677
Appendix C — Participants
                               Page C-19

-------
                                         Participants
                                         (continued)
Ken Miller
Gannet News Service
1000 Wilson Boulevard
Arlington, VA 22229-0001
(703) 276-5806

Rich Miller
Scott Specialty Gases
614 Easton  Road, P.O. Box 310
Plumsteadville, PA 18949

Cheryl Minor
Cheryl Minor Consultants, Inc.
P.O. Box 944
Rural Hall, NC 27045
(919) 969-5755

Diane Miskowski
BCM Engineers
3 Perry Lane
Burlington, NJ 08016
(609) 235-6523

John Mizroch
U.S. ETEC
2000 K Street, NW, Suite 750
Washington, DC 20006
(202) 466-6933

Reginald Modlin
Chrysler Corporation
800 Chrysler Drive East
Auburn Hills, MI 48326-2757
(313) 576-8077

Timothy Mohin
U.S. Senate Environ. & Public Works Committee
Washington, DC 20037
(202) 224-5031

John Mooney
Engelhard Corporation
101 Wood Avenue
Iselin, NJ 08830

Bruce Moore
Central & South West Services, Inc.
P.O. Box 660164
Dallas, TX 75266-0164
(214) 777-1288
Eileen Moran
Public Service Resources Corporation
One Riverfront Plaza, 9th Floor
Newark, NJ 07102
(201) 596-6710

Michael Morley
Vara International
Calgon Carbon Corporation
1201 19th Place
Vero Beach, FL 32960
(407) 567-1320

Patrick Morrissey
General Motors
1660 L Street, NW
Washington, DC 20036
(202) 775-5015

John Moses
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6380

Ronald M. Moskal
Calgon Carbon Corporation
P.O. Box 717
Pittsburgh, PA 15230-0717
(412) 787-6314

Leslie Moy
2613 Arvin Street
Wheaton, MD 20902
(301) 942-1637

Carl Moyer
Acurex Environmental Corporation
P.O. Box 7044
Mountain View, CA 94039
(415) 961-5700x3900

Andrew J. Murphy
Acurex Environmental Corporation
PO Box 13109
Research Triangle Park, NC 27709
(919) 544-4535

Paul Murray
Herman Miller, Inc.
855 East Main Avenue
Zeeland, MI 49464
(616) 654-5035
 Page C-20
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
 Dean Murville
 Murvex International
 3710 Garfield Street, NW
 Washington, DC 20007
 (202) 338-5214

 Jon Naimon
 IRRC
 1755 Massachusetts Avenue, NW
 Washington, DC 20036
 (202) 234-7500

 Matt Naud
 ICF Incorporated
 9300 Lee Highway
 Fairfax, VA  22031-1207
 (703) 934-3933

 John Nelson
 The Pearlman Group
 2000 L Street, NW, #702
 Washington, DC 20036
 (202) 296-2739

 I.L Newlin
 Rhone-Poulenc Inc.
 CN 5266
 Princeton, NJ 08543-5266
 (908) 297-0100

 Robert Newman
 EA Engineering, Science  & Technology
 11019 McCormick Road
 Hunt Valley, MD 21031
 (410) 584-7000

 John Nichols
 Dovco Industrial Fabricators, Inc.
 1700 Ridgely Street
 Baltimore, MD 21230
 (410) 625-6000

 Mary D. Nichols
 U.S. EPA
 401 M Street, SW
 Washington, DC 20460
 (202) 260-2090

 Roberta Nichols
 Ford Motor Company
 Village Plaza, Suite 1200
23400 Michigan Avenue
 Dearborn, MJ 48124
(313) 248-2369
Joseph Niemiec
Brooklyn Union Gas
One Metro-Tech Center, 19th Floor
Brooklyn, NY 11201-3850
(718) 403-3247

Nick Nikkila
South Coast Air Quality Management District
21865 Copley Drive
Diamond Bar, CA 91765
(909) 396-2660

Jane Nishida
Chesapeake Bay Foundation
164 Conduit Street
Annapolis,  MD 21401
(410) 268-8833

Daniel Noble
Environmental Business Research
4452 Park Boulevard, Suite 306
San Diego,  CA 92116
(619) 295-7685

Ola Nordquist
Swedish Attache of Technology
10880 Wilshire Boulevard, #914
Los Angeles, CA 90024
(310) 475-0589

Claudia O'Brian
Design for the Environment
401 M Street, SW
Washington, DC 20460
(202) 260-0880

Eileen O'Hara
Lafarge Corp.
P.O. Box 4600
Reston, VA 22090-1415
(703) 264-3668

Jesse O'Neal
Coerr Environmerital Corp.
6320 Quadrangle Drive, #320
Chapel Hill, NC 27514
(919) 419-0567

Carlos O'Neill
U.S.  EPA
1413 Fernandez Juncos Avenue
Santurce, PR 00909
(809) 729-6952
Appendix C — Participants
                               Page C-21

-------
                                        Participants
                                        (continued)
James T. O'Neill
ViGYAN Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100

Nancy Olsen
Island Press
1718 Connecticut Avenue, NW, Suite 300
Washington, DC 20009
(202) 232-7933

Greg Ondich
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-5748

Robert Ouellette
BCM Engineers
3 Perry Lane
Burlington, NJ 08016

Joanne Oxley
Enviro-Management and Research, Inc.
1015 18th Street, NW, Suite 310
Washington, DC 20036
(202) 293-5300

Louis Paley
U.S. EPA
Crystal Station One
2805 Jefferson Davis Highway
Arlington, VA 22202
(703) 308-8806

Keith Pandorf
Pandorf's Haz Mat Training & Consulting
759 Columbus Avenue
Lebanon, OH 45036
(513) 932-7669

Richard W. Parker

Ria Patterson
Elf Atochem North America
900 First Avenue
King of Prussia, PA 19406
(215)337-6869
Carl Pavetto
Systematic Management Services, Inc.
20201 Century Boulevard
Germantown, MD 20874
(301) 353-0072

Bruce Perry
Environmental Manager's Advisor
EHM1, 10 Newmark Road
Durham, NH 03824
(603) 868-1496

David Peterson
PSA Peugeot Citroen/USTR
2000 Town Center #1700
Southfield, MI 48075
(313) 948-9600

Anne Phelan
Environmental Law Institute
1616 T Street, NW, Suite 200
Washington, PC 20036
(202) 939-3853

Jennifer Phillips
ViGYAN Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100

Richie D. Pickens
Nalco Fuel Tech
1001 Frontenac Road
Naperville,  IL 60563-1746
(708)983-3511

Jane Piepho
Babcock and Wilcox
20 S. Van Buren Avenue, P.O. Box 351
Barberton, OH 44203
(216) 860-6246

Mark Pine
Arthur D. Little, Inc.

Bill Piske
IEA Field Services
120 South Center Suite 200
Morrisville, NC 27560
(919) 460-0852
 Page C-22
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
 Mahesh Podar
 U.S. EPA
 401 M Street, SW
 Washington, DC 20460
 (202) 260-5387

 Terry Poles
 Engelhard Corporation
 101 Wood Avenue
 Iselin,  NJ 08830
 (908) 205-6633

 Robert Polito
 Environmental Resources Management, Inc.
 855 Springdale Drive
 Exton, PA 19341
 (215) 524-3500

 Frank  Pope
 Technology Funding, Inc.
 2000 Alemeda De Las Pulgas, Suite 250
 San Mateo, CA 94403
 (415) 345-2200

 Michael E. Porter
 Harvard University Business School
 Aldrich Hall #200, Soldier Field Road
 Boston, MA 02163
 (617) 495-6309

 Lawrence Pratt
 Environmental Law Institute
 1616 P Steet, NW
 Washington, DC 20036
 (202) 939-3800

 Mary Prendergast
 ASME
 1828 L Street, NW, #906
 Washington, DC 20036
 (202) 785-3756

 Doris Price
 U.S.  EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9067

Nancy Prolman
U.S.  EPA
401 M  Street, SW
Washington, DC 20460
(202) 260-2744
John Quarles
Morgan, Lewis & Bockius
1800 M Street, NW
Washington, DC 20036
(202) 467-7000

Gloria  Quinn
Edison Electric Insititute
101 Wood Avenue
Iselin, NJ 08830

Theresa Quinn
B&V Waste, Science and Technology Corporation
100 Cambridge Park Drive
Cambridge, MA 02140
(617) 547-2553

Walter D.  Ramsay
4501 Arlington Boulevard, #324
Arlington, VA 22203
(703) 525-1780

Todd Ramsoter
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6921

Dawn Randall
Coalition for Safer, Cleaner Vehicles
321 D Street, NW
Washington, DC 20002
(202) 543-4499

Fred Rappold
ERM, Inc.
855 Springdale Drive
Exton, PA  19341
(215) 524-3500

Jay Ratafia-Brown
Science Applications International Corporation
1710 Coodridge Drive, P.O. Box 1303, 2-2-5
McLean, VA 22102
(703) 448-6343

Mick Rayder
ECG, Inc.
8150 Leesburg Pike, Suite 401
Vienna, VA 22182
(703) 448-8900
Appendix C — Participants
                               Page C-23

-------
                                         Participants
                                         (continued)
Maurice Raymond
Rhone-Poulenc Specialty Chemicals
CN 7500 Prospect Plains Road
Cranbury, NJ 08512-7500
(609) 860-4506

Lewis Reade
U.S. AID
320 21st Street, NW, Suite 3319
Washington, DC 20523-0064
(202) 647-9969

Lisa A. Reale
Delmar Publishers Inc.
3 Columbia Circle
Albany, NY 12212
(518) 464-3500

Isabel Reiff
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031-1207
(703) 934-3006

Ruth Reiman
Texas Air Control Board
12124 Park 35 Circle
Austin, TX 78741
(512) 908-1219

W. Rerman
AAA News Service
1448 New York Avenue, NW
Washington, DC 20005
(202) 942-2050

Byron Rettig
Petrolite Polymers Division
1709 Industrial  Boulevard
Kilgore, TX 75662
(903) 984-5077

Richard Rhoden
American Patroleum Institute
1220 L Street, NW
Washington, DC 20005
(202) 682-8480

Michelle Rice
MD Dept. of the Environment
2500 Broening Highway
Baltimore, MD 21222
(410) 631-3240
Renee Rico
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9153

Marilyn Ripin
JAYCOR
1608 Spring Hill RD
Vienna, VA 22182
(703) 847-4106

Leslie S. Ritts
Chadbourne & Parke
1101 Vermont Avenue, NW, Suite 900
Washington, DC 20005
(202) 289-3000

Eve Robinson
Thompson Publishing Corp. ,
1725 K Street, NW, Suite 200
Washington, DC 20006
(202) 872-4000

J. Thomas Robinson
Nyacol Products, Inc.
P.O. Box 349
Ashland, MA 01721
(508) 881-2220

Phyllis Robinson
Business  Publishers, Inc.
951 Pershing Drive
Silver Spring, MD 20910-4464
(301) 587-6300

John Rolfe
Pegasus Consultants
345 Third Street, Suite 640
Niagara Falls, NY 14303
(716) 285-3856

Paul Rosasco
Harding  Lawson Associates
707 17th Street, ARCO Tower 2400
Denver, CO 80202
(303) 292-5365
Page C-24
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
Bob Rose
U.S. EPA
Crystal Mall II
1921 Jefferson Davis Highway
Arlington, VA 22202
(703) 305-5511

Robert Rose
Leon G. Billings Inc.
901 15th Street, NW #570
Washington, DC 20005
(202) 371-0764

Julie Rosenberg
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9154

Peter Rosenberg
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-8869

Carl S. Russell
Sun Co.
1801 Market Street
Philadelphia, PA 19126
(215) 977-6927

Rafael Sanchez
U.S. EPA
Crystal Station One
2805 Jefferson Davis Highway
Arlington, VA 22202
(703) 308-8730

Ernest Sandelli
K&M Engineering & Consulting Corporation
2001 L Street, NW, Suite 500
Washington, DC 20036
(202) 728-0390

Edward Sanders
Sanders International
1616 P Street, NW, Suite 410
Washington, DC 20036
(202) 939-3480
Gary Saunders
Engineering-Science Inc.
401 Harrison Oaks Boulevard, Suite 201
Gary, NC 24513
(919) 677-0080

Alan Scarsella
Wahlco Environmental Systems, Inc.
3600 West Segerstrom Avenue
Santa Ana, CA 92702-6495
(714) 979-7300

Eric Schaeffer
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-8636

Reeva Schiffman
First Environment, Inc.
90 Riverdale Road
Riverdale, NJ 07457
(201) 616-9700

John Schofield
Thermatrix, Inc.
3590 North First Street, Suite 310
San Jose, CA 95134
(408) 944-0220

Barry Schroer
U.S. EPA

Douglas Schuessler
Ecology and  Environment, Inc.
1700 N. Moore Street
Arlington, VA 22209
(703) 522-6065

Peter Scott
Global  Environmental Fund
1250 24th Street, NW, Suite 300
Washington, DC 20037
(202) 466-0529

Tony Scott
Sutron  Corporation
21300 Ridgetop Circle
Sterling, VA  20166
(703) 406-2800
Appendix C — Participants
                                Page C-25

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                                         Participants
                                         (continued)
James Seal
OMSTAR Clean Air Corporation
4180 La Jolla Village Drive, Suite 415
La Jolla, CA 92037
(310) 835-5377

Jeffrey Seisler
Natural Gas Vehicle Coalition
1515 Wilson Boulevard, Suite 1030
Arlington, VA  22209
(703) 527-3022

John S. Seitz
U.S. EPA
Research Triangle Park, NC 27711
(919) 541-5616

Jennifer Selber
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9177

David Selden
American Management Systems, Inc.
1777 N. Kent Street
Arlington, VA 22209
(703) 908-5087

U. SenGupta
Vara International
1201 19th Place
Vero Beach, FL 32960
(407) 567-1320

Andrea Shal al Fsa
Reuters
1333 H Street,  NW
Washington, DC 20005
(202) 898-8465

Greg Shamitko
USAir, Inc.
Pittsburgh International Airport, P1T/K125
Pittsburgh, PA 15231
(412) 747-3070

Mark R. Shanahan
Ohio Air Quality Development Authority
1901 Le Veque Tower
50 West Broad Street
Columbus, OH 43215-5985
(614) 224-3383
Rich Shank
Science Applications International Corporation
655 Metro Place S., Suite 745
Dublin, OH 43017
(614) 793-7600

Michael H. Shapiro
U.S. EPA
401 M Street, SW
Washington, DC 20460

Deborah Sheiman
Natural Resources Defense Council
1350 New York Avenue, NW  Suite 300
Washington, DC 20005
(202) 783-7800

Robert Sheriff
Atlantic Environmental Inc.
2E-Blackwell Street
Dover, NJ 07801
(201) 366-4660

Claire Sherry
U.S. EPA

David Sherve
MTI
41762 Christy Street
Fremont, CA 94538
(510) 490-0900

John Shoaff
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-1831

Jerry Shoemaker
Engineering-Science
10521 Rosehaven Street
Fairfax, VA 22030-2899
(703) 591-7575

Albert Short
United States-Asia Environmental Partnership
1133 20th Street, NW, Suite 300
Washington, DC 20036
(202) 835-0333

Glyn Short
 Page C-26
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
Richard Siegel
B&V Waste Science and Technology Corporation
100 CambridgePark Drive
Cambridge, MA 02140
(617) 547-2553

Daniel Silver
U.S. - Asia Environmental Partnership
1133 20th Street NW, Suite 300
Washington DC,  20036
(202) 835-0333

Karl Simon
U.S. EPA
401 M Street, SW (6405J)
Washington, DC 20460
(202) 233-9299

John Simpson
Public Utilities Reports
2111 Wilson Boulevard, Suite 200
Arlington, VA 22201
(703) 243-7000

Orman Simpson
MDA Scientific, Inc.
3000 Northwoods Parkway, Suite 185
Norcross, GA 30071
(404) 242-0977

Kara Sissel
Clean Air Report
1225 Jefferson Davis Highway
Alexandria, VA 22202
(703) 892-8516

Richard Skaggs
CalTest Instruments, Inc.
Omstar Environmental Products
126 Marine Avenue
Wilmington, CA 90744
(310) 835-5377

David Slaughter
Thompson Publishing Group
1725 K Street, NW, Suite 200
Washington, DC 20006
(202) 872-4000

Anthony R. Sloan
Anthony Sloan and Associates
23 Chestnut Lane
Wayne, PA 19087
(215) 964-0620
Bruce Smart
World Resources Institute
1709 New York Avenue, NW, Suite 700
Washington, DC 20006
(202) 638-6300

Alan Smith
Environment Plus/Brooklyn Union Gas
One Metrotech Center
Brooklyn, NY 11201
(718) 403-3373

F. Bradford Smith
Environmental Elements Corporation
3700 Koppers Street
Baltimore, MD 21227
(410) 368-7090

Jeffrey Smith
Institute of Clean Air Companies
1707 L Street, NW
Washington, DC
(202) 457-0911

Kenon Smith
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9164

Michael Smith
Graseby Andersen Inc.
4801 Fulton Industrial Boulevard
Atlanta, GA  30336
(404) 691-1910

Rodney Sobin
U.S. Congress Office of Technology Assessment
Washington, DC 20510-7025
(202) 228-6369

Daryl K. Solomonson
TRW
One Federal Systems Park Drive
Fairfax, VA 22033
(703) 803-4990

George Spencer
Air Daily, Ltd.
4418 Mac Arthur Boulevard
Washington, DC 20007
(202) 298-8202
Appendix C — Participants
                               Page C-27

-------
                                         Participants
                                         (continued)
Sam Spencer
Air Daily, Ltd.
4418 Mac Arthur Boulevard
Washington, DC 20007
(202) 298-8202

Bryan C. Spielman
Thermacon Industries
111 West 40th Street
New York, NY 10018
(212) 704-2111

Curtis Spraitzar
2925-1 19th Street South
Birmingham,  AL 35209
(205) 879-5561

Beverly Stanton
Manfacturers of Emission Controls Association
1707 L Street, NW, Suite 570
Washington, DC 20036
(202) 296-4797

Michael Stanton
American Automobile Manufacturers Association
1620 Eye Street, NW, Suite 1000
Washington, DC 20006
(202) 775-2729

Lynne Steingass
The Environmental Policy Center
2000 L Street, NW, Suite 710
Washington, DC 20010
(202) 296-7444

Stan Stephenson
Coalition for Safer, Cleaner Vehicles
The After Market Research Inst, Inc. Box 648
Southeastern, PA 19399
(215) 964-9820

Mary Stevens
Weinberg, Bergeson, & Neuman
1300 1 Street NW, Suite 1000 W
Washington, DC 20005
(202) 962-8528

Kevin Stickney
Wheelabrator Technologies, Inc.
Liberty Lane
Hampton, NH 03842
(603) 929-3354
Jerry Stilkind
USIA News
301 4th Street, NW
Washington, DC 20008
(202) 619-4157

Lori Lee Stall
Radian Corp.
2455 Horsepen Road
Herndon, VA 22071
(703) 713-1500

Paul M. Stolpman
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9140

Mary Stone
National League of Cities
1301 Pennsylvania Avenue, NW
Washington, DC 20004
(202) 626-3030

Donald H. Stowe
Dravo Lime  Company
3600 One Oliver Plaza
Pittsburgh, PA 15222
(412) 566-5574

Thomas Strang
Motor and Equipment Manufacturers Assn.
P.O. Box 13966
Research Triangle Park, NC 27709-3966

Roger Strelow
Bechtel Corporation
50 Beale Street
San Francisco, CA 94105
(415) 768-2759

Donna Strumbel
East Ohio Gas Company
1717 E. Ninth Street, Room 826
Cleveland, OH 44114
(216) 736-5359

Russell Sturm
International Institute for Energy Conservation
750 1st Street, NE, Suite 540
Washington, DC 20002
(202) 842-3388
 Page C-28
             Appendix C — Participants

-------
                                        Participants
                                        (continued)
George Sugiyama
Pilsbury, Madison & Sutro
1667 K Street, NW, Suite 1100
Washington, DC 20006
(202) 463-2382

Margaret Sullivan
U.S. - Asia Environmental Partnership
1133 20th Street, NW, Suite 300
Washington, DC 20036
(202) 835-0333

Robert Sullivan
JAYCOR
1608 Spring Hill Road
Vienna,  VA 22182
(703) 847-4008

Eric Summers
Science and Policy Associates, Inc.
West Tower, Suite 400, 1333 H Street, N.W.
Washington, DC 20005
(202) 789-1201

Rupert Surcouf
Energy and Environmental  Sales Corporation
650 Poydras, Suite 2045
New Orleans, LA 70130
(504) 523-1509

Nancy Sutley
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-4123

George Sverdrup
Battelle Memorial Institute
505 King Avenue
Columbus, OH 43201-2693
(614) 424-5014

Kevin T. Swift
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
(202) 887-1286

John Tallmadge
Clean Air  Network
Yuji Tanaka
Cosmo Oil of U.S.A., Inc.
280 Park Avenue, 22nd Floor, East Building
New York, NY 10017
(212) 949-9710

Jake Tarr
Arete Ventures
6110 Executive Boulevard
Rockville, MD 20852
(301) 881-2555

Grant Taunton
Human Resources Consulting Services
314 S. Smedley Street
Philadelphia, PA 19103
(215) 893-9383

Lawrence Taylor
Envirotest Systems, Inc.
2002 Forbes Boulevard
Tucson, AZ 85745
(602) 620-1500x427

Valerie Taylor
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-0880

Paul Templet
Louisiana State University
11831 Pride Point, Hudson Road
Zachary, LA 70791
(504) 388-6428

Kenneth Thomas
Horiba Instruments, Inc.
3901  Varsity Drive
Ann Arbor, MI 48108
(313) 973-2171

Louis Thomas
Columbia Gas
200 Civic Center Drive
Columbus, OH 43216
(614) 460-6801

Gary Threatt
A.O. Smith Water  Products Co.
Highway 1  North, P.O. Box 600
McBee, SC 29101
(803) 335-8281
Appendix C — Participants
                                Page C-29

-------
                                        Participants
                                        (continued)
Susan Tierney
U.S. Department of Energy
Forrestal Bldg., 1000 Independence Avenue, SW
Washington, DC 20585
(202) 586-5800

Maria Tikoff
U.S. EPA
401 M Street, SW
Washington, DC 20460
(703) 233-9178

Rex Tingle
AFL-CIO
815 16th St., NW, Room 704
Washington, DC 20006
(202) 637-5203

Yves Tondeur
Triangle Labs
6320 Quadrangle Drive # 240
Chapel Hill, NC 27510
     493-0877
Jeffrey Tranen
New England Electric Systems
25 Research Drive
Westborough, MA 01582
(508) 366-9011

David Trossman
Alex, Brown & Sons, Inc.
135 East Baltimore Street
Baltimore, MD 21202
(410) 783-5330

Whitney Truelove-Cranor
U.S. EPA
Judiciary Square
2805 Jefferson Davis Highway
Arlington, VA 22202
(703) 233-9036

Jose A. Trujillo
K&M Engineering & Consulting Corporation
2001 L Street, NW, Suite 500
Washington, DC 20036
(202) 728-0390

Hank Trzcinski
Advantage Plus Analysis Corporation
8503 Marquette Street
Vienna, VA 22180
(703) 573-2441
Norman Umberger
ViGYAN Inc.
5203 Leesburg Pike, Suite 900
Falls Church, VA 22041
(703) 931-1100

Hiroyuki Umetani
Teijin America, Inc.
10 East 50th Street
New York,  NY 10022
(212) 308-8744

Kenneth Underwood
AeroVironment, Inc.
222 E. Huntington Drive
Monrovia, CA 91016
(818) 357-9980

Richard Vaccaro
Killam Associates
27 Bleeker Street
Millburn, NJ 07041
(201) 912-2455

Rene Van Breusegen
Schriebner,  Grana, & Yonley Inc.
271 Wolfner Drive
Saint Louis, MO 63026
(314) 349-8399

Amy Van Kolken
Michigan Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-7040

Jeffrey W. VanSant
New England Power Company

Michael P.  Vanderbergh
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-7960

Lynn Vendinello
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-8612
 Page C-30
             Appendix C — Participants

-------
                                         Participants
                                         (continued)
Laura Viani
American Metal Market
601 13th Street, NW, Suite 520 South
Washington, DC 20005
(202) 639-6931

Karen von Clef
Veriflo Corp.
250 Canal Boulevard
Richmond, VA 94804
(215) 340-0756

Carol Vukmanic
USAir, Inc.
Pittsburgh International Airport, PIT/K125
Pittsburgh, PA 15231
(412) 747-3084

James S. Wallis
Scott Specialty Gases, Inc.
6141 Easton Road, P.O.  Box 310
Plumsteadville, PA 18949
(215) 766-8861

William Walsh
Greenpeace
1436 U Street, NW
Washington, DC 20009
(202) 319-2491

Anthony Walters
Environmental Systems & Solutions, Inc.
3100 33rd Place, NW
Washington, DC 20008
(202) 966-6698

Bruce Warden
IT Analytical Services
11499 Chester Road
Cincinnati, OH 45246
(513) 782-4600

Ann Watkins
U.S. EPA
Judiciary Square
501 3rd  Street
Washington, DC 20005
(202) 233-9113

Denise Watts
City of Irvine
1  Civic Center  Plaza
Irvine, CA 92713
(714) 724-7322
Michael J. Wax
Institute of Clean Air Companies
1707 L Street, NW
Washington, DC 20036
(202) 457-0911

Wendy Webb
GE Plastics
One Plastics Drive
BurkviUe, AL 36752
(205) 832-5611

Henry Weber
H & W Management Science Consultants
415 East 52nd Street, Suite 1D/C
New York, NY 10022
(212) 355-1448

Richard A. Wegman
Garvey, Schubert, & Barer
1000 Potomac Street, NW, Suite 500
Washington, DC 20007
(202) 965-7880

Abbie Weiner
Lean Power Corporation
8700 Georgia Avenue
Silver Spring, MD 20910
(301) 588-2200

Stephanie Weisband
Advanced Sciences, Inc.
2000 N. 15th Street, Suite 407
Arlington, VA 22201
(703) 243-4900

Roy Weiskircher
USX Corp.
Room 2206 USX Tower, 600  Grant Street
Pittsburgh, PA 15219
(412) 433-5914

Ellyn Weiss
Foley, Hoag, & Eliot
1615 L Street, NW,  Suite 850
Washington, DC 20036
(202) 775-0600

Jeff Wells
EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6787
Appendix C — Participants
                                Page C-31

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                                        Participants
                                        (continued)
John Wells
The Bruce Company
501 3rd Street NW, # 260
Washington, DC 20001
(202) 434-9358

Jonathan Welsh
Welsh Technologies
P.O. Box 4214
River Edge, NJ 07661
(201) 489-3465

Jeffrey Wendle
CET Engineering Services
1240 North Mountain Road
Harrisburg, PA 17112
(717)541-0622

Vaughn Whatley
EPA Region 8
999 18th Street, Suite 500, 8-OEA
Denver, CO 80521
(303)294-1111

J.E. Wheeler
Eclipse Inc.
1665 Elmwood Road
Rockford, IL 61103
(815) 877-3031

Mary Margaret Whipple
Washington Metro Area Transit Authority Board
2100 Clarendon Boulevard, Suite 300
Arlington, VA 22201
(703) 358-3130

Paul White
Johnson  Matthey Corporation
460 East Swedesford Road
Wayne, PA 19087-1880
(215) 971-3118

John P. Whitescarver
Carter & Burgess
P.O. Box 16525
Washington, DC 20047
(703) 471-9196

Mary Lynn Wilhere
DR1/ McGraw-Hill
1200 G Street, NW, 10th Floor
Washington, DC 20005
(202) 383-3544
Paul Wilkinson
American Gas Association

Richard D. Wilson
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-7645

Sherie Winston
Engineering News Record
1200 G Street, Suite 1100
Washington, DC
(202) 383-2255

John Wisniewski
Export-Import Bank of the United States
811 Vermont Avenue, NW
Washington, DC 20571
(202) 566-8802

Rosemary Wolfe
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9176

Carol Woodyard
The Clean Air Review
10400 Whitestone Road
Raleigh, NC 27615
(919) 870-1845

Mitch Wool
Geraghty & Miller
555 Clyde Avenue
Mt. View, CA 94043
(408) 961-5700

Bob Wright
MG Refining & Marketing, Inc.
1000 Louisiana, Suite 1000
Houston, TX 77002
(713) 759-0510

Lloyd Wright
U.S. EPA
Judiciary Square
501 3rd Street
Washington, DC 20005
(202) 233-9191
 Page C-32
             Appendix C — Participants

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                                       Participants
                                       (continued)
Sergey Yakubov
Russian Embassy
1125 16th Street, NW
Washington, DC 20036
(202) 347-5031

Helen Yoest
Entropy, Inc.
P.O. Box 12291
Research Triangle Park, NC 27709-2291
(919) 781-3550

Marcia Zalbowitz
EV  Inside
1915 Kalorama  Road, NW #102
Washington, DC 20009
(202) 387-6185

Joseph Zeigler
Joy  Environmental Technologies Inc.
10700  N. Freeway, Towerpark North
Houston, TX 77037
(713) 878-1037

Stanley Zwicker
Dames & Moore
911  Wilshire Boulevard
Los Angeles, CA 90017
(213) 683-1560
Appendix C — Participants                                                  Page C-33

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