United States
Environmental Protection
Agency
Office of the
Administrator
(1802)
EPA 100-R-99-007
September 1999
www.epa.gov/reinvent
to
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C7ntroductlorv. ....... , , ............................... . ...................... ..... ........ . .................... "1
•How Project X-L Works [[[ 2
WKy Project X-L? [[[ 2
TJKe Challenge of ^Experimentation ........... . .................................. . ............... 2
CTmproving tke ^-nvironment and Changing "How £P;A Works ............. . ..... 3
Project X-L Accomplishments ................................. . .................. . .......... ....... .3
XL- Projects in Brief. [[[ 4-
od -f-oi- Business ....................................... • .......................... ...... .................. O
od for1 Communities ................................ . ............... • ............. • ...................... '
ing -How ^RA Works [[[ 8
Waiting A^oi'e Flexible "Rules and "Regulations ................................................. 8
"UaUinq FVesK jAppfoacKes to Permitting ............................................... • ......... S
.Making Jnfoi-mation Less Burdensome and A^oce LAndecstandable ................. 9
^.Xplo>*i^9 7N)e\v Jdeas in <£njot*ceme.nt and (Compliance >\ssurance ............... 9
Promoting 7\)ew Concepts in ^Environmental StewardsKip ............................. 10
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"Do we need more common sense and fairness in our
regulations? \/ou bet we do. But we can
Kave common sense and still provide
saje drinking water.
We can Kave fairness and still
clean up toxic waste dumps.
d we ougnt to do it."
n March 1995, President Clinton and
/ Vice President Gore charged the
^-^ federal government with finding ways to
improve the way we manage the environment. They
called for building upon the strengths of the cur-
rent system, while overcoming its limitations. They
promised to reform the system, while retaining its
commitment to protect human health and to safe-
guard the environment. Project XL is one way the
U.S. Environmental Protection Agency is living up
to that promise.
Under Project XL, EPA made this offer to facili-
ties, sectors, states, and communities: lf\on have
an idea that offers better results than what would
he achieved under current requirements, then we
will work with you and other interested parties
i<> inn those ideas to the lest.
Project XL encourages environmental excellence
and Leadership by those who must comply with
EPA regulations and policies. Its experiments are
testing new ways of achieving environmental pro-
tection — methods that are better for the environ-
ment, better for project sponsors, and better for
citizens. These experiments are helping EPA ad-
just to a changing world and prepare for the 21"'
century.
This report briefly summarizes the progress we have
made to date. For more detailed information, see
the Project XL 1999 Comprehensive Report pre-
pared by EPAs Office of Policy and Reinvention.
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How Project
Project XL is finding ways to improve our envi-
ronmental regulatory system, including the way EPA
operates. It is based on a simple idea: project
sponsors can try new approaches if they can prom-
ise better environmental results than would be ex-
pected under the current regulatory regime. Project
sponsors must involve states, tribes, local govern-
ment, citizens, and others with a stake in the "ex-
periment" being tested.
Criteria for Project XL
• Superior environmental protection
• Increased flexibility, cost savings and
reduced paperwork
• Stakeholder involvement
• Innovation/pollution prevention
• Transferability
• Feasibility
• Monitoring, reporting and evaluation
• No shifting of risk burden
WKy Project
Since the early 1970's, environmental laws and
regulations have given us dramatic improvements
in public health and environmental quality. More
U.S. streams are fishable and swimmable. Our air
is cleaner. The bald eagle, once near extinction, has
been removed from the endangered species list.
But as we achieved these successes, we learned
that prescriptive regulations can have unintended
results. Sometimes, they can require greater costs
for smaller returns, or even discourage technolo-
gies that are cleaner and cheaper.
The world marketplace also has changed. Com-
panies need to get new products to their custom-
ers faster than ever before. Yet the wait for envi-
ronmental permits sometimes slows down their
ability to launch new products or react to market
demands. Today's industry leaders also realize that
preventing pollution and recycling raw materials can
save them money in the long run.
In the midst of this change, Project XL gives EPA
and its stakeholders an opportunity to:
• Experiment with new approaches to
environmental protection with the
meaningful involvement of interested parties:
• Test ideas that break down barriers
within the nation's separate air, water
and waste regulations;
• Try out technologies that provide
better options for meeting or
exceeding environmental standards;
• Use the knowledge, experience,
and resources of all stakeholders
to find better federal approaches
to environmental problems;
• Shi ft from pollution control to
pollution prevention ;
• Ensure environmental equity; and
• Find more sustainable solutions.
X eri mentaf ion
The first few XL projects posed many challenges.
EPA had never attempted this type of experiment.
As a regulatory agency, we were cautious in the
early stages. We and others had concerns about
how to test new approaches, yet maintain the same
level of protection that the current regulatory sys-
tem provides. We had to learn as we went along.
Project sponsors, regulators, and citizens alike in-
vested significant resources and time in XL's cre-
ative and complex experiments. After gaining ex-
perience, the Agency had a better idea of what in-
formation was important in a proposal and how
decisions should be made. In 1998, we worked
hard with our partners to streamline Project XL so
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negotiations would go more smoothly, quickly, and
predictably. We now expect this new process to
yield agreements for most projects in six months to
a year, compared to 24 months or longer under the
old process. For example, the Atlantic Steel
project, in Atlanta, GA has already shown results
hy producing a signed project agreement for phase
one just eight months after initial pre-proposal dis-
cussions.
The Agency also developed several guides to help
project sponsors, EPA staff, and citizens create
successful projects. Technical assistance is made
available to stakeholder groups participating in
project negotiations. EPA also contracts with pro-
fessional facilitators to get stakeholder discussions
and internal EPA teams off on the right track.
PVoject
tk<
H
ow
<£PA
As of August 1 999, XL sponsors were implement-
ing 14 projects, while 3 1 other project ideas were
being developed or negotiated, and a number of
additional concepts were also being discussed.
Seven projects have been in place for a year or
more. All were showing noteworthy benefits to
the environment, project sponsors, and stakehold-
ers. These benefits include: superior results for
the local environment and communities, and sub-
stantial operational benefits or cost savings for
project sponsors. However, the value of this pro-
gram goes beyond the benefits derived from each
project. Project XL's greatest value lies in its po-
tential for revealing improvements that can be made
in the current system of environmental protection.
Already, EPA has begun incorporating XL's suc-
cessful innovations and flexibility into regulations,
permits, and other core functions. Because of XL,
we are also changing EPA's internal culture to sup-
port the challenges facing EPA staff and meet the
needs of our partners. In this way, XL has begun
to encourage and reward excellence and leader-
ship throughout the country.
iskmervts
Project XL has a growing track record of produc-
ing benefits for the environment, participating
project sponsors, and the communities in w hich
they are located. Each XL experiment is tackling
significant environmental problems in a new way.
giving EPA. states, businesses, and communities
knowledge needed for the 21" century. All 14
projects in implementation are presented on pages
4-5. As a whole, these XL projects are exceeding
their environmental commitments. The benefits of
individual XL projects are summarized on pages
6-7, using data primarily from the seven projects
that have been in implementation since December
1 997 or earlier (Intel, Weyerhaeuser, Vandenberg
AFB, HADCO, Witco, Merck, and Jack M.
Berry). The results from the seven projects in op-
eration for just one year show significant benefits.
As we move from seven to 50 projects, from one
year of operation to several, and as we broadly
apply the lessons learned throughout EPA, the ben-
efits of Project XL should increase exponentially.
k'
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Intel Corporation
ned: November 19,1996) Intel is testing a facility-wide pollution cap that ensures its
. will remain a minor source of air pollutants. EPA. Arizona, and Maricopa County agreed to
..ange equipment and processes and build new facilities without air permit reviews, as long as
reduce wastewater discharges, air emissions, and solid waste generation. In exchange, EPA and Georgia
allowed process modifications without prior approval, streamlined the wastewater permit renewal process.
eliminated unnecessary sampling, and allowed annual certification to replace monthly reporting. The agreement
also reduces allowable air emissions by 60 percent using two emission caps: one for the plant's four major air
pollution sources and another for the remaining sources. (signed: November
3,1997) Vandenberg has agreed to reduce its annual emissions of o/one-causing chemicals by 10 tons or more
group different activities on the base as separate minor sources. This new method of
grouping activities allows the base to comply with rules that entail significantly less
administrative burden. The money saved will be used to reduce emissions by boilers
and other pollution sources. These steps may help prevent Santa Barbara County.
3A, where the base is located, from becoming a non-attainment area for ozone.
(signed: October 2, 1997) HADCO is testing
whether copper-rich sludge from its printed wiring boards manufacturing
operations can be recycled more easily by removing hazardous waste
pretreatment requirements. The low toxicity of the sludge made HADCO
eligible for either a solid waste variance or conditional delisting at facili-
ties in New Hampshire and New York. HADCO expects to implement
reclamation of 100 percent copper drilling, sawing, and edging dusts,
and to use its cost savings to increase pollution prevention and recycling.
(signed: October
*-• , •:
7,1997) Witco's chemical plant in Sistersville, WV is testing pollution
r
prevention, waste minimization, and alternative methods for reducing air
emissions. Witco has installed an incinerator that will destroy 98 percent of
the air emissions from a process unit and recover some 500,000 pounds of *»»^
methanol per year from a wastewater treatment unit. In exchange, EPA and West
Virginia are deferring hazardous waste air emission standards for Witco's two RCR
surface impoundments. Witco also conducted a study to identify additional '"
duction opportunities and is implementing many of the study recommendation
;ned: December 15,1997) Merck & Co., Inc. will reduce sulfur dioxide and
en oxide emissions at its Elkton. VA pharmaceutical plant to protect visibility and reduce acid rain in
,.^c« .y Shenandoah National Park. EPA and Virginia agreed to a facility-wide air pollution cap that will ensure
that Merck's emissions remain at least 20 percent below 1992 and 1993 levels and eliminate the need for permit
reviews for every process change. Merck is converting its coal-fired powerhouse to cleaner-burning natural
gas, a $ 10 million capital investment not required by regulations. (signed: August 8.
1996; project closed June 2, 1999) This project was designed to produce a comprehensive operating permit
to better integrate operation and compliance procedures at the company's citrus juice-processing facility in
LaBelle, FL. A 1997 change in operational management at the facility led to termination of the agreement. The
new permit would have relieved Berry of multiple permit renewal applications. Although the permit was not
completed, Berry did meet commitments to reuse wastewater, reduce air pollution emissions, and reduce solid
waste disposal. (signed: August 8. 1998) Molex is focusing on improving metal
recovery by upgrading the wastewater treatment facility at its electroplating facility in Lincoln. NE. The new
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treatment system generates separate sludge for nickel, copper, and tin/lead, although at higher operational and
compliance costs. Previously, these metal-bearing wastewater streams were combined for treatment. By keep-
ing them separate. Molex expects to reduce metal loadings to Lincoln's wastewater treatment plant by 50
percent and sell the sludge directly to recyclers. Nebraska has granted Molex a temporary exemption from
hazardous waste storage, handling, and shipment rules. (signed: August 19, 1998)
Lucent's Microelectronics Group is testing whether a comprehensive environmental management system (EMS)
can produce superior performance in a more efficient, transparent, understandable and flexible manner. The
EMS will consolidate all federal and state requirements into one permit. Regulators will participate in setting
environmental goals and tracking performance, with input from environmental organizations, community groups,
requirements for entire small business sectors, such as dry cleaners, photo processors, and printers.
DEP's Environmental Results Program replaces individual permits with a facility-wide, perfor-
mance-based, self-certification program. Company executives can certify annually that
they are meeting environmental performance standards. In exchange, each sector is
expected to achieve superior environmental performance through pollution pre-
turn a 138-acre brownfielcl site previously owned by Atlantic Steel into a
mixed business/residential development. This development, located in
downtown Atlanta, would include a bridge that would link motorists to an
interstate highway, and bicyclists, and pedestrians to a nearby passenger
rail system, thereby reducing traffic. However, because Atlanta does
not meet certain clean air standards, the city cannot receive federal fund-
ing or approval for transportation projects. EPA has agreed to measure
the project's benefits to clean air by comparing this site's benefits to simi-
lar likely sites in the region, thereby allowing construction of the bridge.
An EPA analysis shows that absorbing some of Atlanta's future growth '
the Atlantic Steel site would mean fewer emissions resulting from less auUj
mobile traffic. (signed: May 25.1999) Exxon is
implementing a cleanup of the Sharon Steel Superfund site in Fairmont, WV in
half the time a normal cleanup would take. In exchange, Exxon has asked for
streamlined hazardous waste removal processes and flexibility in wetlands mitiga-
tion, reporting requirements, and risk assessment criteria and analyses. Exxon also will
work with stakeholders and community groups to find developers interested in commercial
or industrial redevelopment of the site. (signed: June 30, 1999)
Andersen will test innovative performance requirements linked to production rates at its window and patio
door manufacturing plant in Bayport, MN. Andersen's per-unit air emission rate will be tied to incentives that
penalize higher emissions and reward reductions in volatile organic compounds. In exchange for accepting these
per-unit emission limits, Andersen can make production changes without obtaining prior approval. If successful,
ni™iii/*t;™-i;r»L-.^i iiw-^ntiv,^ m;iv chnnoe how EPA regulates emissions from certain industries.
:ned:July 12, 1999) New York's Department
of Environmental Conservation proposes to allow public utilities to centralize management of hazardous wastes
generated at remote locations (such as manholes), thus removing wastes from remote locations more quickly,
minimizing unnecessary paperwork, and saving time and labor. Hazardous waste laws require that all wastes, no
matter how small, be transported directly to a permitted treatment, storage, and disposal facility within 90 days.
Record-keeping is linked to each site of generation. By centralizing collection, record-keeping and management
of these wastes. New York hopes to increase public safety and reduce traffic problems around these sites.
Uep;
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XL projects have reduced air pollution, wastewa-
ter discharges, and disposal of solid and hazard-
ous wastes. The figures below show some of the
cumulative environmental benefits of only three
projects underway in 1997 and 1998. Putting some
of these gains into an everyday context, in one year,
these three XL projects have conserved enough
water to fill more than 1,300 Olympic-size swim-
Combined Intel, Weyerhaeuser and
Witco Results for 1997-1998
• Eliminated 20,853 tons of criteria air
pollutants (nitrogen oxide, sulfur
dioxide, paniculate matter, and
carbon monoxide)
• Recycled 2,089 tons of solid waste
• Recycled 690 tons of non-hazardous
waste
* Recycled 613 tons of hazardous waste
• Reused ] ,069 million gallons of water
" Eliminated 2.19 pounds per air-dried
metric ton of biological oxygen demand
in wastewater discharges
ming pools. They have reduced volatile organic
compounds (VOC) emissions equivalent to taking
more than 160,000 cars off the road for a year.
And they have recycled enough solid waste to fill
167 average-size garbage trucks—a convoy that
would stretch for nearly three-quarters of a mile.
For some projects, the sponsors must make sig-
nificant capital investments before they can realize
the experiment's full environmental benefits. There-
fore, as existing experiments mature and new
projects begin, XL's positive environmental impact
will continue to grow. In fact, the gains demon-
strated so far are small compared to the environ-
mental benefits that will accrue over time.
K* usme.ss
Project sponsors are reducing costs and improv-
ing their competitiveness through XL's operational
flexibility. Sponsors are benefitting from expedited
or consolidated permitting, reduced record-keep-
ing and reporting, and the flexibility found through
facility-wide emission caps, hi addition, sponsors
have enjoyed improved administrative efficiency,
industry recognition, better relationships with their
communities and stakeholders, better use of em-
ployee expertise, and improved relationships with
regulators. Many of these benefits also improve
the bottom line. For example:
/ii/ie/continues to avoid millions of dollars worth
of production delays in the competitive quick-to-
market semi-conductor industry by eliminating 30
to 50 permit reviews a year.
Weyerhaeuser expects to avoid $10 million in
future capital spending, is now saving $200,000 a
year by recovering and reusing lime muds, and will
continue to save $176,000 annually by consolidat-
ing reporting requirements.
Witco expects to save $800,000 over five years
through its negotiated hazardous waste deferral.
Merck expects to avoid millions of dollars in pro-
duction delays by eliminating repetitive permit re-
views and getting its products to market more
quickly.
In addition, within the first year of its XL project
HADCO saved transportation costs by reducing
sludge shipments as a result of installing a new sludge
dryer. Vandenberg AFB reduced costs by testing
each air pollution source using a less expensive pro-
tocol negotiated with the Santa Barbara County
Air Pollution Control District.
6
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for- (Sonantunities
Project XL was designed to increase understand-
ing between regulated industries and the communi-
ties and citizens they affect. Although not always
easy, efforts to reach out to environmental groups
and community stakeholders have yielded many
rewards. Companies are reporting information in
new ways to increase community understanding and
trust, and stakeholders have had real input into
project agreements. Benefits to communities in-
clude:
• Creating a cleaner local environment;
• Forging a real, informed trust with the
project sponsor:
• Offering input into a company's
environmental decisions:
• Improving access to information through
the Internet, direct reports from the facililx.
or local library holdings:
• Receiving reports in eas\ -to-undersiand
formats;
• Understanding a local facility's operations
better, and sometimes those of an industry
as a whole; and
« Receiving help with community projects.
such as computer donations, property set-
backs, and ride-reduction programs.
EPA is proud of Project XL's track record of pro-
ducing meaningful benefits. Even at this early stage.
XL has shown that prudent experimentation and
regulatory flexibility can yield economic gains for
businesses and government, better understanding
bv citizens, and a cleaner environment.
*1-Voject ^.L. must succeed!
giving us a place, at the
table as decisions are
made tKat a|^ect our com-
munities has proven to be
HigMy beneficial—-not only
fo r co m m uniti es b ut fo »* j n-
dustj'y as welI,w
• ,
,\1-
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"H
ow
Wo^Us
While individual XL projects have produced mean-
ingful results, Project XL's value goes far beyond
the immediate environmental gains and cost sav-
ings to individual project sponsors. The innovative
ideas being tested are also helping EPA to reex-
amine how it regulates and to find better ways of
encouraging environmental improvements.
In order to transfer these ideas, EPA is changing
some of its everyday functions, such as permitting,
rulemaking, and information management Although
it is early, Project XL is definitely influencing the
way EPA thinks about the next generation of envi-
ronmental protection.
Project XL is allowing EPA to test new approaches
that might not otherwise be considered in federal
regulations, and to test and confirm the flexibility
that already exists in environmental rules.
The Weyerhaeuser project allowed EPA to design
and test two additional compliance options in a new
air and wastewater regulation affecting the pulp and
paper industry (the Pulp and Paper Cluster Rule).
One option allows mills to meet stricter wastewa-
ter discharge limits by installing advanced technolo-
gies. In exchange, mills can receive public recog-
nition; additional compliance time; and reduced
monitoring, inspections, and penalties. Another
option allows kraft pulping operations to eliminate
specific requirements for production vents if they
clean up condensates in other parts of the mill. Many
of the air pollutants that come from production vents
originate in these condensates. If the condensates
are cleaner, air coming out of the vents will be
cleaner, too. We expect this new rule to eliminate
59 percent of toxic air emissions from U.S. pulp,
paper, and paperboard mills. Chloroform dis-
charges to water will fall 99 percent; dioxin and
furan discharges will be reduced by 96 percent.
3M Idea Impacts EPA Rule
Although ^Ni Corporation's XL proposal did not
reach final agreement, one of its ideas was
incorporated into federal rules ("or magnetic tape
manufacturers.
Based on the 3M proposal and other industry
input, EPA decided to offer companies an
alternative compliance option lor balancing
hazardous air pollutant emissions from solvent
storage tanks with emissions from other process
equipment.
The Molex and HADCO experiments are testing
several waste reduction and metal recyling and re-
covery options that are now restrained by RCRA
regulations. Many printed wiring board manufac-
turers and electroplating facilities face similar envi-
ronmental constraints. As a result of these experi-
ments, EPA may learn how problems can be ad-
dressed throughout these industrial sectors.
to T-Wmitfincj
Permits are EPA's primary tool for translating envi-
ronmental statutes and regulations into the require-
ments a facility must follow. Although they are suc-
cessful tools for protecting the environment, op-
portunities to improve on their limitations are ex-
amined in four of the initial seven XL projects: Intel,
Weyerhaeuser, Merck, and Jack M. Berry.
Facility-wide Limits: Merck, Intel, and
Weyerhaeuser each are testing facility-wide per-
mits that limit their total emissions. During 1997
and 1998, Weyerhaeuser remained under its caps,
reducing by 12 to 20 percent its actual emissions
of particulate matter, sulfur dioxide, nitrogen ox-
ides, carbon monoxide, and VOC's. Meanwhile,
Merck's facility-wide air permit allows its Stone-
wall Plant to change operations without having to
wait for individual permit reviews. Merck also has
the option of reducing its facility-wide caps instead
of implementing specific control technologies that
might be prescribed by future regulations. Taking
8
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a lesson from the Merck experiment, EPA allowed
limited pre-approval for some types of production
changes in 1998 regulations for controlling air emis-
sions from pharmaceutical plants. The Agency is
considering using pre-approval and "cap permits"
more extensively in the future.
Consolidated Permits: The Jack M. Berry facil-
ity must contend with separate air. water, and con-
sumptive use regulations, including separate com-
mitments to EPA. the Florida Department of Env i-
ronmental Protection, and the South Florida Wa-
ter Management District. Berry's XL project pro-
posed to consolidate these permitting requirements
into a single comprehensive operating permit. Al-
though the project has been closed due to a change
of the plant's operational management, the Berry
concept and process are being documented here
so that other interested parties can consider this
approach for further testing under Project XL.
^notion JL
ess
The EPA of tomorrow will rely on environmental
data and information that is less burdensome for
facilities to collect and report, easier for regulators
to review, and easier for citizens to obtain and un-
derstand. XL experiments are yielding lessons that
can help guide the Agency's new information man-
agement office and its efforts to improve environ-
mental information.
Better Public Access: Intel is improving public
access to information by: ( 1 ) using stakeholder in-
put to redesign reports on its environmental per-
formance: and (2) making these reports publicly
available on the Internet. Based on Intel's suc-
cess. we are asking future XL projects to develop
similar Internet reporting with interested stakehold-
ers.
Streamlined Reporting: EPA. states, and local
regulators routinely collect data from companies to
ensure compliance with the Clean Air Act, Clean
Water Act, and other environmental laws. Under
XL, Intel is consolidating routine reporting into quar-
terly reports and an annual report. Weyerhaeuser
has consolidated federal, state, and local air and
water reporting into two reports a year. Merck's
requirements for recordkeeping and reporting grow
more stringent as its actual emissions approach the
facility-wide cap. Berry would have been allowed
to use simpler, non-standard forms to report its en-
vironmental performance to multiple jurisdictions.
poncj
/sJ
w
n
ana
(Somplicmce y\ss u
One of EPA's most important responsibilities is
ensuring that companies comply with the laws that
protect human health and the environment. Through
Project XL, we are testing new tools, such as self-
certification, to encourage the regulated commu-
nity to move beyond compliance with environmen-
tal laws.
Weyerhaeuser's XL agreement allows the paper
and pulp mill to provide an annual compliance self-
certification report instead of monthly discharge
monitoring reports for its wastewater permit. EPA
provided this flexibility because the company had
established a 10-year history of meeting all required
discharge levels, and because of its commitments
to superior environmental performance.
In Massachusetts' Environmental Results Program.
printing and photo process ing representatives have
helped create a self-certification program linked to
stringent state performance and operating stan-
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dards. Certifications are signed by the company
owner, president, CEO, or other high-ranking offi-
cial and are subject to penalties for perjury if the
facility is not in compliance. Facilities not in com-
pliance will be required to specify interim milestones
toward achieving compliance by a certain date.
This will give companies more flexibility to choose
cost-effective compliance, strategies that can fur-
ther improve environmental performance and pre-
vent pollution. Meanwhile, all companies partici-
pating in the Environmental Results Program will
remain subject to regular state inspections and en-
forcement.
PVomotincj /\)ew Concepts in
^Environmental .Stewardship
XL is testing environmental management systems,
and promoting pollution prevention and recycling
as new ways for showing a company's commit-
ment to environmental stewardship.
Environmental Management Systems (EMS):
An EMS can be used to manage compliance, help
boost efficiency, cut waste, improve worker safety,
and bring attention to environmental matters not
covered by regulations. Weyerhaeuser's XL ex-
periment is using an EMS and standard work pro-
cedures that will take steps toward creating a
"Minimum Impact Mill." Lucent's EMS provides
a platform from which a consolidated multimedia
permit can be developed, and it allows regulators
to participate in setting annual goals and targets.
Pollution Prevention and Recycling: Witco is
implementing a waste minimization/pollution pre-
vention plan that will identify additional pollution
prevention opportunities. Witco also is generating
less sludge by reusing and recycling methanol. Else-
where, Vandenberg Air Force Base is reducing its
air emissions through a performance-based EMS
and pollution prevention techniques.
lAnderstandingf tke 7\)eeds
of AWtiple Stakeholders
Stakeholder involvement has proven to be one of
the most challenging features of Project XL. EPA
and project sponsors are learning valuable lessons
about opening up the decision-making process and
inviting stakeholders to participate. Environmental
advocates, community groups, and individual citi-
zens have told us what does and does not promote
meaningful participation. Among their views:
• The project sponsors and stakeholders must
establish clear ground rules for their roles and
responsibilities.
• EPA must clarify its role, as well as the role
of the sponsor, in managing a stakeholder
group.
• Project sponsors should identify local and
national stakeholders' needs early in the
project's development.
• Local groups and national environmental
groups should work together early in the
process to define their roles as participants
in the XL project. These early discussions
should help to avoid disconnects later in the
process.
Witco Corporation Waste Minimization/Pollution Prevention Solutions
at Sistersville, West Virginia Plant
Activity
One-time pollution prevention projects (1998)
Methanol recycling
Other pollution prevention options
TOTAL savings potential annually
Potential Cost
Savings
$42,000 (one-time)
$16,000/year
$620,000/year*
$636,000/year*
Potential Waste
Reductions
26,000 Ibs.
(one-time)
1, 100,000 lbs./year
730,000 lbs./year
1, 830,000 lbs./year
*Witco has not yet assigned the expense of implementing these projects; when it does, the net savings will be less.
10
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".Absolutely key to [^PA's] suc-
cess is forging strong partner-
ships—businesses/ communities/
environmentalists/ public KealtK
groups/ government at all levels—
pooling time/ talent/ and re-
sources to find protective/ com-
mon-sense/ cost-effective solu-
tions.*
— Carol
The lessons learned from XL projects will assist
EPA as we increase opportunities for stakeholders
to be involved in our programs, improve stake-
holder processes throughout the Agency, and share
information about successful stakeholder involve-
ment strategies.
to
While EPA has made many improvements over the
years in how we manage internal processes. Project
XL has revealed additional opportunities for im-
proving the way EPA operates. By beginning to
address some of the internal challenges. Project XL
has helped to increase EPA's capacity to innovate.
Already. Project XL has led to discreet changes in
internal guidance and operating procedures. These
changes support EPA's commitment to test and in-
corporate innovative solutions to environmental
problems.
For example, to further senior management involve-
ment in advancing innovative efforts, EPA estab-
lished the Reinvention Action Council (RAO. This
senior-level body was created to ensure quick de-
cision-making and adequate resources to move
projects along. The RAC's success in resolving
problems in Project XL led to expanded responsi-
bilities for the council. Today, the RAC helps ad-
vance progress for new and existing reinvention pri-
orities.
To address state concerns, EPA and the Environ-
mental Council of the States (ECOS) negotiated
an agreement that provides a way to test innova-
tive ideas based on state interests and priorities.
The ECOS-EPA agreement outlines principles and
a process to clarify how EPA and states will put
these good ideas to the test, outside of Project XL.
EPA's Office of Enforcement and Compliance As-
surance (OECA) set up a streamlined process for
screening the compliance history of companies that
want to participate in Project XL. The new screen-
ing guidance ensures that EPA and project spon-
sors are not simultaneously in cooperative and
adversarial positions. The Project XL experience
helped to develop the screening guidance now used
by the growing number of voluntary programs
throughout EPA.
In the past. EPA offices have been organized along
"media lines." working separately to carry out air,
water, waste and toxics programs. Project XL.
however, requires a "multi-media" approach. To
bridge these gaps. EPA has created a new model
for Project XL intra-agency teams. EPA's new pro-
cess for operating in these teams is set forth in the
Manual for EPA Project XL Teams. This system
has helped teams make decisions faster. These les-
sons will guide EPA as we continue to experiment
with solutions that cross traditional media lines.
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Since it was announced. Project XL has been held
to a very high standard. Expectations were great
for this program, which attempts to venture into
the future of environmental protection. Despite the
challenges, it has grown into an efficient and effec-
tive program that is pnxlucing environmental, eco-
nomic, and community benefits.
Although we are approaching our goal of running
50 different XL experiments. EPA's need to test
new tools and new solutions will not end. Our
stakeholders will continue to have innovative ideas
for achieving cleaner, cheaper, and smarter envi-
ronmental protection. And EPA is committed to
providing a vehicle for testing and implementing
those concepts.
Meanwhile, we will be hard at work testing, evalu-
ating, and judging the success of the XL experi-
ments and incorporating their lessons into EPA's
daily work. This important phase of Project XL
coincides with a renewed Agency-wide effort to
learn from this and other reinvention efforts and
open new doors for experimentation.
FVom Pilot to 1~Yc\crfL~tn
Project XL's greatest opportunity, and its greatest
challenge, is taking successful ideas from individual
pilot projects to system-wide practice. From its
inception. XL was designed to use site-specific ex-
periments to produce new solutions with broad
applicability.
EPA is now focused on identifying successful inno-
vations learned from Project XL and making
changes in our current system of environmental pro-
tection that help put Project XL's lessons into full
practice.
EPA is also developing the next phase of Project
XL. This "second generation" of the XL program
will continue to be shepherded by EPA's Office of
Policy and Reinvention, but will continue to reflect
the Agency-wide commitment to adopt and imple-
ment these innovative ideas. This next-generation
system of environmental protection will provide
even stronger incentives for high performance and
going beyond compliance by developing ap-
proaches such as a new "performance track."
Lessons learned in Project XL will be integral to
developing these high-performance alternatives.
(Soul iiAuiiAC) to ^c1.. u4c~l\
for y\Je.w Solutions
Since its inception. Project XL has had to adapt to
meet the needs of the environment. EPA. and all
stakeholders. Despite achieving the goal of 50
projects, EPA will still retain the capacity to do in-
tra-Agency, cross-media experimentation and re-
tain the Office of Policy and Reinvention as a pri-
mary gateway into EPA for new ideas that improve
environmental protection.
As we design the program's next phase, we will
take into account the current program's advantages,
successes, and hard-earned lessons. We will build
on our experience to identity and use the most com-
pelling incentives for participation, and the best in-
ternal mechanisms for testing new environmental
solutions.
EPA remains committed to the basic principles of
Project XL. Project XL results indicate that we
can create better environmental outcomes when all
affected parties work together toward a common
goal. EPA will continue to provide opportunities
for testing environmental solutions that can address
complex issues and result in higher quality public-
health and environmental protection.
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"Wkat C7 see in Project XJ- is a real paradigm skift-
~Tke old way of doing business was tkat gove»»Kv-
dictates eve»*y Knove a business must
take to protect tke environment.
ke new systein/ as envisioned by Project
is to work cooperatively and focus on tke
results: a cleaner environment; a faster,
less costly system; and more input
from tke community."
/ Chairman
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