Analysis and
Evaluation of
The EPA
Common Sense
Initiative
Prepared by: Kerr, Greiner,
Andersen, and April, Inc.
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This study was funded by the U.S. Environmental Protection Agency under purchase order number 9W-0753-
NTSA with Kerr, Greiner, Andersen, and April, Inc. This report has not undergone formal EPA peer review. The
opinions expressed herein are those of the authors and do not necessarily represent those of the U.S. Environmental
Protection Agency, Mention of trade names does not constitute endorsement nor recommendation for use.
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I WASHINGTON, D.C. 20460
OFFICE OF THE
ADMINISTRATOR
July 29,1999
Dear Common Sense Initiative Stakeholders:
In 1998, the U.S. Environmental Protection Agency (EPA) initiated an independent review of the
four-year Common Sense Initiative (CSI). EPA launched CSI in 1994 with the broad purpose of
seeking "cleaner, cheaper, and smarter" sector-based approaches to protecting human health and
the environment and has been a primary component of EPA's regulatory reinvention efforts. The
evaluation was conducted by an independent third party, Kerr, Greiner, Andersen and April, Inc.,
under contract with the Office of Reinvention. This evaluation considers (1) the extent to which
CSI succeeded in meeting its goals, (2) what was gained from the sector-based, multi-
stakeholder, and consensus aspects of the Initiative, and (3) the extent to which EPA took actions
in response to recommendations that were made in two major mid-course studies of CSI, and the
impact of those actions on the last two years of CSI. The results of the evaluation are described
in the attached report titled, Analysis and Evaluation of the EPA Common Sense Initiative.
EPA believes that the themes and findings articulated in the evaluation are particularly reflective
of the good work and hard-earned experience of the six CSI Subcommittees. And in response to
the themes of the evaluation, EPA examined our current, sector-based activities and priorities,
and we have found much that is consistent with the themes and recommendations of this report.
We recognize that our sector-based work, including our continuing CSI activities, represents
work in progress - we have learned a great deal about how to conduct sector-based efforts and
some of the benefits and challenges of those efforts, and we are still exploring the ultimate
environmental improvements that will result. Reports such as this help us refine our sector-based
activities as we transition from special initiatives, such as CSI, to a "mainstreaming" of sector-
based approaches into the day-to-day operations of the Agency.
As EPA has effected this transition, it intended that the Sector-Based Environmental Protection
(SBEP) Action Plans for Fiscal Years 1999 and 2000 would provide the means for its
accomplishment. These Action Plans provide a framework and broad strategy for sector-based
work and support sector-based activities throughout EPA Headquarters and Regional offices.
They describe how EPA is following through on CSI commitments, as well as embarking on new
sector-based activities in response to new needs and lessons learned from CSI and other sector-
based initiatives. The SBEP Action Plans are where reviewers and stakeholders should look to
find EPA's transitional and longer-term commitments to ongoing CSI and sector-based activities.
1
Recycled/Recyclable .Printed with Vegetable Oil Based Inks on 100% Recycled Paper (20% Postconsumer)
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Several key themes of the Kerr report are consistent with current EPA priorities. First, we
recognize the importance of ongoing senior management commitment and leadership to
sector-based activities. The SBEP Action Plans grew out of a desire by Administrator Browner
to build on our lessons learned for CSI and develop new actions for sector-based environmental
solutions. Our new Associate Administrator for Policy and Reinvention Richard Farrell has
agreed to lead the transition efforts. One of the principal themes in the transition is to build the
Agency's management capacity to more effectively conduct sector work. In this regard, we have
fully engaged the Reinvention Action Council (RAC), which is an Agency-wide group of senior
career managers. The RAC meets quarterly to focus management attention on reinvention
priorities and to discuss issues and potential solutions. Also, the Fiscal Year 2000 SBEP Action
Plan proposes a permanent Office Director level forum to annually coordinate and plan sector
activities.
A second theme of ihe Analysis and Evaluation of the EPA Common Sense Initiative that is
consistent with current EPA priorities as described in the Action Plan is improving the link
between sector-based activities and core functions. EPA is taking several specific steps to
address this issue. For example, a senior level work group has been established to identify
opportunities for coordinated, multimedia rulemakings in an effort to demonstrate the benefits of
this approach. As another example, several sector-based permitting projects are underway,
including demonstration of a Pollution Prevention in Permitting Pilot's Clean Air Act Title V
permit for the pharmaceutical sector and the PrintSTEP permitting project for the printing sector.
A third theme is the importance of stakeholder involvement. EPA has adopted the Stakeholder
Involvement Plan, which was endorsed by the CSI Council and has taken steps to increase the
capacity of EPA employees to conduct stakeholder involvement activities wherever appropriate,
not just in sector-based activities. Also, to demonstrate its commitment to this approach, the
Agency continued to seek stakeholder involvement in sector-based work through the
establishment of a Federal Advisory Committee Act (FACA) committee, to ensure balanced
stakeholder participation. The newly created Standing Committee on Sectors in the National
Advisory Committee on Environmental Policy and Technology (NACEPT), will ensure
follow-through on CSI recommendations and projects, and it will also address important
evolving sector-based issues.
Continued assessment of the value and benefit of sector-based approaches is a fourth theme
that EPA strongly supports. In addition to evaluating CSI, the Agency has committed resources
to evaluating specific sector-based projects. These evaluations are used to inform current efforts,
develop new projects, draw lessons that could be applied to different sectors, and document the
costs and benefits of sector-based approaches. EPA is also working with its partners to develop
performance measures that are designed to relate sector-based activities to the Agency's goals as
reported under the Government Performance and Results Act (GPRA).
There are, however, two areas in which EPA believes that additional information is needed to
provide a more complete picture of CSI, beyond the information presented in. Analysis and
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Evaluation of the EPA Common Sense Initiative. First, the report provides very useful, often
detailed information on the activities and products of the six CSI Subcommittees; however, the
activities and products of the CSI Council should also be highlighted. Although the
Subcommittees clearly generated greater outputs, the Council produced several important
recommendations during its final two years. These are listed as bullets in several places. The
report, however, does not describe the process leading to these recommendations or the results of
the recommendations, which EPA believes are significant. Specifically, the CSI Council played
its own role in providing a forum for this effort and in making valuable progress in the issues of
Reinventing Environmental Information, environmental data quality, and environmental data
gaps; integrating and mainstreaming a sector-based approach within the Agency; and building
Agency capacity for stakeholder involvement. Second, the report does not credit the CSI
Council for its role in increasing the visibility and sense of legitimacy of sector-based work.
Further, while the report cites the importance of commitment from top Agency managers to CSI,
it does not note the vital role of the Council in providing the forum for the Administrator and
other top managers to interact with CSI participants.
Finally, the language in the report states that CSI is "closing down." In truth, much of the work
initiated under CSI is ongoing. The Administrator has stressed that CSI "transitioned" from a
special initiative to a mainstreamed, sector-based approach to environmental protection. During
this transition, she has emphasized that ongoing CSI projects will continue to receive support,
new sector-based activities will be identified and supported, and these efforts will be aligned to
the core work of the Agency. The NACEPT Committee, the Reinvention Action Council, and
the SBEP Action Plans for Fiscal Years 1999 and 2000 are some of the mechanisms she has
chosen to ensure that this transition occurs. The concept of a transitional phase is a more
accurate reflection of the Administrator's and the Agency's continuing commitment to sector-
based approaches, built on our experiences with CSI.
In conclusion, the themes and findings articulated in the Analysis and Evaluation of the EPA
Common Sense Initiative are reflective of the experience of the six CSI subcommittees and are
consistent with current Agency priorities. The CSI Council also had its own distinct role in
forwarding the value of the initiative, and forging both transitional and longer-term goals for
sector-based approaches in EPA. And finally, the NACEPT Committee on Sectors, the
involvement of the Reinvention Action Council, and the Fiscal Year 1999 and 2000 Action Plans
are visible embodiments of the Administrator's and the Agency's continuing commitment to
sector-based approaches to public health and environmental protection.
Lisa Lund
Deputy Associate Administrator
Office of Reinvention Programs
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
.Common Sense Initiative
INTRODUCTION
SECTION I: OVERVIEW OFCSI'S PRODUCTIVITY 5
SECTION II: UNDERSTANDING CSI'S RESULTS 19
SECTION III: KEY FACTORS INFLUENCING CSI RESULTS 35
SECTION IV: SUMMARY AND RECOMMENDATIONS 56
LIST OF ACRONYMS 61
APPENDIX 1: METHODOLOGY 63
APPENDIX 2: WORKS CONSULTED 67
APPENDIX 3: PROJECTS SUMMARY 71
APPENDIX 4: INTERVIEWS 78
APPENDIX 5: INTERVIEW QUESTIONS 82
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.Common Sense Initiative
EXECUTIVE SUMMARY
Purpose of This Report
The Common Sense Initiative (CSI) was launched in 1994 by the U.S. Environmental Protection
Agency (EPA) with the broad purpose of seeking "cleaner, cheaper, and smarter" sector-based
approaches to protecting human health and the environment. CSI has been a primary component
of EPA's regulatory reinvention efforts aimed at changing the environmental regulatory system to
meet current and future challenges.
The purpose of this study is to provide an independent review of the four-year Common Sense
Initiative effort. It considers both the extent to which CSI succeeded in meeting its goals and
what was gained from the sector-based, multi-stakeholder, and consensus aspects of the Initiative.
This study also reviews the extent to which EPA took actions in response to recommendations
that were made in two major mid-course studies of CSI, and the impact of those actions on the
last two years of CSI.
This evaluation was conducted by an independent third party, Kerr, Greiner, Andersen and April,
Inc., under contract with the Office of Reinvention.
Background of CSI
CSI was officially established in October 1994 under a Federal Advisory Committee Act (FACA)
charter as a Common Sense Initiative Council with specialized industrial sector subcommittees.
The formal role of the Council was to advise and make recommendations to the Administrator on
matters falling within the scope of the Initiative, either on its own or based on ideas developed by
sector subcommittees. The Administrator's charge to the Council underlined its responsibility for
identifying cross-cutting issues or potential joint projects affecting several sectors. Six industry
sectors were selected to test this new tailored approach. These sectors comprised a broad range
of experiences with a mix of large and small companies, as well as older and newer industries:
Automobile Manufacturing, Computers & Electronics, Iron & Steel, Metal Finishing and Plating,
Petroleum Refining, and Printing. In the fall of 1998, an announcement was made that the CSI
would conclude in December 1998. Three of the former CSI sectors (Metal Finishing, Printing
and Petroleum Refining) are continuing as workgroups under the newly created Standing
Committee on Sectors in the National Advisory Committee on Environmental Policy and
Technology (NACEPT)1.
Overview of Productivity
This study concludes that CSI was extremely productive in terms of projects developed and
recommendations submitted to the Agency for action, representing a tremendous amount of effort
on the part of the subcommittees and the Council. The Council and subcommittees worked on
'NACEPT is an EPA Advisory Committee created in 1988 to provide advice to the Administrator on a
variety of environmental policy, economics, finance and technology issues.
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.Common Sense Initiative
over 40 projects, including both individual projects and larger, multi-project efforts. And nearly
30 subcommittee recommendations were endorsed by the Council and submitted to the
Administrator for Agency action. These projects and recommendations addressed all eight of the
CSI program elements (Le., regulation, pollution prevention, record keeping and recording,
compliance and enforcement, permitting, environmental technology, community involvement, and
future issues). Four projects lead to recommended rule revisions that are being acted on by EPA.
Previous evaluations showed that the pace of progress in the first two years of CSI was hampered
by process-related problems, including: inadequacies in the consensus-process groundrules,
timelines and facilitation; insufficient technical assistance; and the relationship of the Council to
the subcommittees. This study found that the pace of development of CSFs recommendations
and project implementation increased for most of the subcommittees and the Council during the
last two years of CSI. This increased productivity can be attributed to: 1) increased mutual
understanding of participants' issues and concerns; 2) subcommittees' improvements in identifying
and focusing on actual opportunities for success; 3) participants' increased familiarity with the use
of consensus decision making; 4) adoption of project deadlines by the subcommittees and
Council; and 5) a stronger leadership role by EPA.
The CSI Council was thought to have played a lesser role in the actual productivity of the
Initiative by the CSI participants interviewed—including Council and subcommittee members.
Nevertheless, the Council mounted three major cross-cutting efforts during the last two years of
CSI: 1) commenting on Agency plans for improving environmental information and reporting
through the Reinventing Environmental Information (REI) initiative, resulting, in part, in the
creation of, and action plan on, data gaps, a strategy to address data quality and the formation of
a new information office; 2) supporting the Agency's efforts to provide effective future
stakeholder involvement in environmental decision making, resulting in the Stakeholder
Involvement Plan; and 3) supporting the Agency's integration of the lessons learned form CSI
into Agency core functions through the development of a sector-based approach in the Sector
Based Environmental Protection (SBEP) Action Plan.
Understanding CSI's Results
CSI participants interviewed stated that they gradually came to believe that the Initiative would
not be the vehicle for gaining far-reaching change to EPA's rules and regulations. The
participants modified their goals and expectations in response, particularly in the final two years of
CSI. Nonetheless, most of the participants interviewed felt that there were significant project
accomplishments. Most importantly, improved stakeholder relationships, better mutual
understanding and co-learning, and progress in trust building are widely viewed by participants as
not only valuable, but significant outcomes of the multi-stakeholder process. Stakeholders shared
perspectives, knowledge, and information in order to gain a better understanding of each other's
industries, and gained a new appreciation of each other's core concerns. In many cases,
participants felt that these changes in relationships were responsible for progress in CSI, and
would lead to the creation of long-term networks outside the CSI framework. Some participants
also felt that, as a direct or indirect result of CSI, there were projects or activities occurring or
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.Common Sense Initiative
under consideration outside of CSI that would not otherwise have happened, and that traditional
patterns of interaction between stakeholders on environmental issues would improve.
Several sectors developed comprehensive projects that show considerable progress in addressing
non-regulatory areas, such as industry operations, pollution prevention, community involvement,
and permitting. Also, some sectors offer the potential for going beyond compliance in regards to
environmental performance and creating measurable environmental benefits that meet the CSI
goal of "cleaner," and a few have developed environmental performance measures. Other
projects address "process" issues, such as record keeping and reporting or community
involvement, and while these projects are within the scope of "cheaper" and "smarter," they are
not expected to achieve a "cleaner" result.
Many CSI projects have been completed, but others are still underway. For those projects that
are in the early stages of implementation, it is too soon to tell whether success has been achieved.
However, the potential success of each project can be evaluated based on both the promise it
offers (i.e., its design) and the likelihood for implementation. There is concern among
stakeholders that these ongoing projects may experience difficulty reaching completion since the
CSI FACA has ceased operations. Interviewees feel that EPA has the key leadership role in
sustaining these projects through starring and funding. However, participants agree that the
commitments of other stakeholders to implement these projects are also important. While
recognizing that the NACEPT Sector Standing Committee, the Stakeholder Involvement Action
Plan, and the SBEP Action Plan address the importance of stakeholder involvement and
commitment, many stakeholders continually stressed the need for EPA to plan for multi-
stakeholder consensus processes in sector-based programs.
Recognizing the need to develop measures of success, all active subcommittees developed specific
performance measures to assess the outcomes of CSI projects. However, more general measures
of the outputs of CSI subcommittees and the Council were developed too late in the CSI process
to provide an effective basis for assessment.
Key Factors Influencing CSI Results
This study explored the factors that played a role in the quality of CSFs results. These factors,
related either to the multi-stakeholder, consensus process or to the characteristics of each
individual sector, were examined in light of how they led to differences in effectiveness and results
between subcommittees and either aided or inhibited Council and subcommittee efforts.
Multi-Stakeholder/Consensus Factors
So that all participants would have an equal voice, CSI used a consensus-based, decision-
making process. CSI's multi-stakeholder, consensus-based process, however, both
contributed to and inhibited the Initiative's success, particularly in the early stages of the
Initiative. Process-related problems such as lack of clarity in the operational definition of
consensus resulted in confusion and frustration among CSI stakeholders. The
subcommittees individually moved to clarify the definition of consensus, with mixed
results. The Council clarified the definition on a slower track, relying on the issuance of
iii
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.Common Sense Initiative
an EPA-developed white paper on consensus that offered an approach maximizing
flexibility in the consensus process. Once operating more effectively, the multi-
stakeholder consensus process played a critical role in some of the most creative of the
subcommittees' and Council's accomplishments. Ultimately, many participants saw the
process as useful and a welcome alternative to the usual litigious and adversarial policy
dialogue between stakeholders.
Several other process-related factors—including inadequate ground rules, poor
facilitation, lack of deadlines, lack of technical assistance for non-governmental
organizations (NGOs), and Council-subcommittee relations—also impeded subcommittee
and Council efforts during the first two years of CSI. EPA identified and overcame many
of these problems early in CSI at the subcommittee level, and improved the Council's
processes after the 1997 creation of the Office of Reinvention. Though major
improvements were instituted, the adverse effects of these process-related factors lingered
throughout the four years of CSI.
CSI participants identified two roles they believed were critical for EPA to undertake to
ensure the Initiative's success: providing leadership for CSI's mission and Unking the
Initiative to EPA's regulatory programs. The Administrator's leadership role drew praise
from participants, but their assessment of other senior managers varied by subcommittee.
Where senior management were actively engaged, their subcommittees were more
successful The Office of Reinvention was seen by many as a valuable step in creating
accountability for follow though of CSPs efforts in the context of other Agency
reinvention programs. There is still concern, however, that EPA has been limited in its
ability to produce a well-defined strategy for integrating the results of CSI, with its cross-
media, sector-based approaches, to single media-program regulatory
initiatives—particularly since this key objective was envisioned at the outset of the
Initiative.
Sector-Related Factors
While the sectors with a preponderance of smaller firms garnered the most success in CSI,
this study concludes that the factors contributing to their success can be cultivated in
sectors dominated by larger firms. Participants suggested a number of factors that may
provide an explanation for why these smaller-company sectors were more successful
during CSI: participation of senior decision makers at the table; incentives to negotiate,
such as pending regulations or the need for flexibility for competitive reasons; increased
access to EPA decision makers; and less contentious past stakeholder relationships due to
fewer community and national impacts. EPA demonstrated through the CSI experience
that careful preparatory and analytical work with a sector prior to multi-stakeholder
negotiations can prove useful in identifying sectors with the greatest potential to apply
innovative approaches and facilitate successful negotiations. This analysis should focus on
IV
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.Common Sense Initiative
factors that can contribute to success, such as understanding the needs and expectations of
all stakeholders, and identification of interested and viable subsectors.
Recommendations
Although the formal CSI process has ended, there are a number of new and continuing EPA
efforts that will continue to use sector-based, multi-stakeholder collaborative approaches. There
are opportunities for EPA to further test the use of this tool to support the regulatory process.
EPA should view CSI as a jumping off point for learning. The Agency should:
• support and further study multi-stakeholder, collaborative decision making as a
tool, both within the Agency and in the regions and states; one option might be to
engage in reasonable risk taking, for an appropriate sector, by experimenting with
applying the multi-stakeholder, collaborative model as an alternative to the
traditional Agency rulemaking process;
• provide rewards for EPA staff to support priority reinvention efforts;
• follow-through on key CSI recommendations, projects and ideas;
• build on existing capabilities in sector work, and support multi-stakeholder
"incubator programs;"
• assure a role for early stakeholder involvement in policy dialogues focusing on
innovative solutions;
• at least track spin-off activities and projects and perhaps formally study and
provide resource support to them as well; and
• in future multi-stakeholder efforts, give priority to technical and regulatory
education of non-industry, non-regulatory participants.
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.Common Sense Initiative
INTRODUCTION
A Overview of the Common Sense Initiative
In 1994, as part of the federal government's reinvention efforts, EPA launched CSI with the
broad purpose of using an industry sector-based, multi-stakeholder, consensus-based approach to
achieve "cleaner, cheaper, and smarter" ways of protecting human health and the environment.
Administrator Browner first announced the Agency's intention to experiment with an industry-
specific approach to environmental protection in her November 1993 speech to the U.S. Chamber
of Commerce. Noting that in spite of major environmental accomplishments over the previous
two decades, there were major shortcomings in the nation's environmental policy, namely:
• the polarized, adversarial nature of developing environmental policy among
stakeholders;
• regulating by media (e.g., air and water) rather than integrating multi-media
approaches that focus on facility and sector operations as a whole; and
• regulatory strategies that meet environmental goals, but not necessarily cost
effectively.
In order to change the current environmental regulatory system to address these challenges, EPA
decided to combine "commitment to the nation's environmental goals ... with common sense
innovation and flexibility." CSI was designed as a forum for realizing this fundamentally different
approach for creating environmental policy, encouraging collaborative "out-of-the-box thinking"
to find more effective solutions to environmental problems. It was distinguished from EPA's
traditional approach by uniquely combining a series of elements:
• focusing on industrial sectors (e.g., automobile manufacturing) instead of on media
(e.g., air, water and soil);
• promoting multi-media and pollution prevention approaches to environmental
problems;
• involving a wide range of stakeholders from industry, state and local government,
national and local environmental organizations, national and local environmental
justice groups, and labor; and
• making environmental policy decisions on a consensus basis with all stakeholders.
CSI was officially established in October 1994 under a FACA charter as a council with specialized
industrial sector subcommittees. The formal role of the Council was to advise and make
recommendations to the Administrator on matters falling within the scope of CSI, either on its
own impetus or based on ideas developed by sector subcommittees.
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.Common Sense Initiative
Six CSI Sectors
Six sectors representing a cross-section of
American industries were selected to test this
new, tailored approach:
Automobile Manufacturing,
Computers & Electronics,
Iron & Steel,
Metal Finishing and Plating,
Petroleum Refining, and
Printing.
At the time CSI began, these sectors
comprised 11 percent of the U.S. gross
national product, employed more than four
million people, and accounted for more than
12 percent of industry-reported toxic releases.
The CSI charter identified six program
elements in which the Council and sector
subcommittees should explore opportunities
for innovative, less costly, and more effective
ways to achieve a cleaner environment:
• regulation: looking for
opportunities for better results
at lower cost, and improved
rules through increased
coordination with stakeholders
in developing rules;
Major CSI Dates
11/93 U.S. Chamber of Commerce address by
Administrator Browner announcing
sector-based approach
10/94 Advisory Committee Charter for the CSI
Council completed by EPA
1/95 First CSI subcommittee meetings begin
5/95 First CSI Council meeting held
2/97 Announcement of creation of EPA Office
of Reinvention (OR) and it's
responsibility for managing CSI
2/97 First Independent CSI Program
Evaluation by the Scientific Consulting
Group
3/97 Final meeting of Automobile
Manufacturing Subcommittee
7/97 GAO evaluation of the first two years of
CSI
10/97 White Paper clarifying Consensus
prepared by OR
2/98 Announcement that an Agency Sector-
Based Environmental Action Plan would
be developed based on CSI experience
2/98 Announcement of NACEPT Standing
Committee on Sectors formation
12/98 Final meetings of CSI Council and the
five remaining subcommittees
4/99 Continuation of Printing, Metal Finishing
and Petroleum Refining Sectors under
Standing Committee on Sectors in
NACEPT
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.Common Sense Initiative
• pollution prevention: promoting pollution prevention2 and reducing the use of
toxics as a standard business practice;
• recordkeeping and reporting: developing simpler, more transparent ways for
industry to provide information to EPA;
• compliance and enforcement: identifying innovative ways to promote compliance
and encourage companies to improve performance beyond compliance;
• permitting: developing more efficient permits and permitting systems with
incentives for innovation and more effective public involvement; and
• environmental technology: providing incentives for innovative, environmentally
beneficial technologies.
In October 1996, EPA renewed this original two-year CSI charter for an additional two years.
Then, hi its 1997 guidance to the subcommittees, the Council added two additional program
elements:
• involving the community: creating opportunities for greater involvement by
residents and community groups in solving environmental problems; and
• future environmental issues: considering emerging issues and proactive solutions
The CSI Council concluded in December 1998. Three of the former CSI sectors (Metal
Finishing, Printing, and Petroleum Refining) are continuing as workgroups under the newly
created Standing Committee on Sectors in the NACEPT. This transition is part of the
Administrator's strategy to integrate the sector-based approach, learned by working on CSI, into
the Agency's core functions.
B. Purpose of Report
The purpose of this study is to provide an independent review of the four-year CSI effort. It
considers both the extent to which CSI succeeded in meeting its goals of progress toward a
"cleaner, cheaper, and smarter" system of national environmental management, and what was
gained from the sector-based, multi-stakeholder and consensus aspects of the Initiative. Key
questions this study has sought to answer include:
• Did the CSI approach—involving a full range of stakeholders in a consensus-based
effort to define and resolve major sector-related environmental issues—
demonstrate value and meet its goals?
• Did the stakeholder process generate innovative, beneficial results?
2Pollution prevention means source reduction—preventing or reducing waste where it originates, at the
source—including practices that conserve natural resources by reducing or eliminating pollutants through
increased efficiency in the use of raw materials, energy, water, and land.
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.Common Sense Initiative
• Were issues raised or resolved that have not traditionally been part of
environmental policymaking?
• Did the sector orientation allow EPA to define some environmental problems and
solutions more efficiently and effectively?
• Do the lessons learned from this effort point to a broader opportunity—with
necessary improvements in process design and execution—for using multi-
stakeholder decision-making approaches in the future?
In early 1997, two major studies assessed the accomplishments of the Common Sense Initiative
over its first two years, and made several recommendations as to how it could be improved.
These studies were:
• Review of the Common Sense Initiative by the Scientific Consulting Group (SCO),
which was commissioned by EPA in late 1996 and completed in February 1997,
and
• Regulatory Reinvention: EPA's Common Sense Initiative Needs an Improved
Operating Framework and Progress Measures, a General Accounting Office
Report (GAO/RCED-97-164), requested jointly by several Congressional House
and Senate committees, completed hi July 1997.
Therefore, this study also reviews the extent to which EPA took actions in response to
recommendations from the SCG and GAO reports, and the impact of those actions on the last
two years of the Common Sense Initiative,
To develop the information in this report, Kerr, Greiner, Anderson and April, Inc. (KGAA)
conducted over 100 interviews of CSI stakeholders and EPA staff and facilitators, and reviewed
relevant literature, documents, and reports3. The distinctive features of the Common Sense
Initiative included its sector orientation and its use of multi-stakeholder, consensus-based
negotiations to develop "cleaner, cheaper, smarter" environmental management solutions. In
assessing the benefits of the multiple features and combined effect of the Initiative, this evaluation
is stakeholder-driven; stakeholder perceptions regarding the value and innovative nature of CSI
provide the raw material for the evaluation. The evaluation is, therefore, based primarily on the
results of the interviews, supplemented by information from document reviews and transcripts of
CSI meetings. The evaluation also employed a focus group of key CSI participants to serve as a
resource at the outset of the study.4
3See Appendix 2 for a list of works consulted.
4Appendix 1 contains more detail on the methodology of the study.
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.Common Sense Initiative
In looking retrospectively at CSI, it is important to know the specific results and accomplishments
of the Initiative, as well as the factors that either cultivated productive efforts or hampered
progress. To explore these diiferent facets of CSI, the report has the following sections: Section
I: Overview of CSI's Productivity briefly describes CSI's accomplishments and how the
initiative's projects and recommendations covered the eight program elements; Section II:
Understanding CSI's Results describes actual results and stakeholder perceptions of the
initiative's achievements and disappointments; and Section III: Key Factors Influencing CSI
Results explores the multi-faceted issues that appear to have been most important for success or
failure. Finally, this report wraps up with Section IV: Summary and Recommendations, which
provides our overall findings and recommendations, for the new and continuing Agency sector
efforts.
Section I:
Overview of CSI's Productivity
PROJECTS AND RECOMMENDATIONS ADDRESS ALL EIGHT PROGRAM
ELEMENTS
The CSI projects and recommendations address each of the eight program elements, though some
areas were covered more comprehensively than others. Over the four years of CSI, the six
subcommittees worked on over 40 projects, many composed of multiple components, and nearly
30 recommendations were endorsed by the Council and submitted to EPA for action. The sheer
volume of this work effort is impressive, and represents a tremendous amount of effort on the part
of the subcommittees and Council. This section provides a summary of the projects and
recommendations and highlights examples that illustrate the work done in a particular area.
In Table 1 below, we show how many CSI projects and recommendations covered each program
element identified in the CSI Charter. This summary is meant to illustrate the breadth of
approaches used to test methods of achieving "cleaner, cheaper, and smarter" environmental
protection. Since many projects were multi-faceted, a single project or recommendation may
cover more than one program element. For example, the Petroleum Refinery Subcommittee's
Refinery Air Information Reporting System (RAIRS) involves components of both
"Recordkeeping and Reporting" and "Involving Communities."
Table 2 provides a more complete listing of the specific projects/reports developed by each of the
six subcommittees and the Council, including those formally endorsed as recommendations by the
Council.
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.Common Sense Initiative
Table 1: Number of Projects and Recommendations Covering Each CSl Program Element
CSI Program Element
Regulation
Pollution Prevention
Recordkeeping and Reporting
Compliance and Enforcement
Permitting
Environmental Technology
Involving Communities
Future Issues
Number of
Recommendations
11
4
7
1
4
4
5
8
Number of Projects
12
18
14
13
6
8
15
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Below, we give a thumbnail sketch of the productivity (i.e., number of projects) and highlight
some of the approaches taken for each of the eight Program Element categories.
Program Element 1: Regulations
The CSI subcommittees worked on 12 projects that related to regulations. Four projects lead to
recommended rule revisions covering very narrow, sector-specific issues that are being considered
by EPA that, when implemented, will result in cleaner, more efficient environmental management.
These include:
1) As part of the Metal Finishing Strategic Goals Program (SGP), EPA proposed a rule
under Resource Conservation and Recovery Act (RCRA) that provides a regulatory
incentive to recycle (instead of land disposing) F006 hazardous waste. This incentive
increases the time that wastes can be accumulated on site by offering a 90 day extension to
the current 90 day RCRA accumulation requirement (total 180 days storage) to those
facilities that will recycle the waste. The proposal, making waste management more
flexible and cost effective, was published in the Federal Register on February 1, 1999
(Metal Finishing Subcommittee).
2) Final changes to the New Source Performance Standard (NSPS) requirements for
monitoring pressures in electric arc furnaces were issued as a direct final rule in Spring
1999 (Iron & Steel Subcommittee).
3) Streamlined requirements for managing cathode ray tubes are to be proposed in Summer
1999 as modifications to RCRA Best Management Practices for non-listed hazardous
wastes (Computer & Electronics Subcommittee).
4) EPA is considering proposing an alternative standard recommended for the automobile
manufacturing Maximum Achievable Control Technology (MACT) rule; this alternative
standard would allow for better auto-by-auto comparability when measuring
environmental performance in Volatile Organic Compounds (VOC) reductions
(Automobile Manufacturing Subcommittee).
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The Metal Finishing Strategic Goals Program
change mentioned above. In addition, the
SGP seeks regulatory flexibility for
exceptional environmental performers, and
has secured a formal commitment from EPA
"to integrate the [SGP] into the rulemaking
process for all future regulations that have a
direct impact on the metal finishing
industry." According to the December 1998
meeting of the Metal Finishing
Subcommittee, EPA is working to
incorporate SGP into at least two upcoming
rules:
• Prctreatment Streamlining
Rule proposal under the
Clean Water Act (under
government review); and
• Metal Products & Machinery
Effluent Guidelines.
Several projects focused on general
regulatory framework issues, and resulted in
discussion papers and reports (e.g., the
Alternative Sector Regulatory System
Principles developed by the Automobile
Manufacturing Subcommittee), but did not
lead to recommendations for specific
changes to current regulations. Other
projects and recommendations addressing
regulations resulted in changes to EPA
guidance, policy, or interpretation of rules.
For example, as a result of feedback from
participants in the Public Access Project
(Computer & Electronics Subcommittee),
EPA developed and plans to implement in
the first half of 1999 a system to provide
easy public access on the Internet to
compiled and clearly stated regulatory
interpretations and policy decisions that
apply to the Computer & Electronics
industry. EPA also improved its guidance
is also affecting change beyond the RCRA rule
The Strategic Goals Program Approach
to Regulatory Reinvention
Officially launched in January 1998, the SGP is a
comprehensive Metal Finishing Sector program that
establishes industry-specific environmental goals and
commitments. It is a sector-specific environmental
stewardship program with the mission of going beyond
baseline compliance and substantially reducing
hazardous emissions and exposure. As of December
1998, over 150 facilities have signed onto the National
Goals Agreements as well as 17 states and 34 Publicly
Owned Treatment Works (POTWs). By 2002 these
goals include a 90 percent reduction in organic Toxic
Release Inventory (TRI) emissions and a SO percent
reduction in metals emitted to air and water (compared
to baseline 1992 year levels). These performance goals
are not linked to formal regulatory changes. However, a
major commitment to integrate the SGP into the
rulemaking process is described in National
Performance Goals and Action Plan (December 1997).
Specifically.
"Each of these integration decisions would be made by
the appropriate EPA program offices, and may vary
based on the circumstances of each prospective
regulation...The term "integrate" means several things:
(1) to be cognizant of the environmental benefits
achieved by metal finishers in the [SGP] at the time
a particular rulemaking gets underway,
(2) to consider whether the achievements of the [SGP]
should affect the objectives and content of
prospective rules;
(3) if deemed appropriate, to consider innovative
regulatory options for dealing differently with the
metal finishing industry (or participating facilities
in the SGP). Such options might include (but are not
limited to) a separate set of regulatory requirements
for firms that demonstrate strong performance,
elimination or modification of requirements based
on achievements in the [SGP], and delay or deferral
of rulemaking deadlines during the timeframe of the
Program."
Progress of the SGP will continue to be tracked by EPA
and stakeholders through a metal finishing working
group under NACEPT.
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to iron and steel facilities on implementing EPA-witnessed tests for air emissions as the result of a
recommendation from the Iron & Steel Subcommittee. Similarly, as a result of the work of the
Petroleum Refining Subcommittee, EPA is considering Alternative Work Practices Monitoring
Guidance as an alternative to determining mass emissions using Method 21 of the Clean Air Act
Amendments Methods Manual for leak detection and repair; the Alternative Work Practices
Monitoring Guidance proposes innovative, laser-based, leak-detection technology for determining
and potentially reducing mass emissions at petroleum refineries. While these are not formal rule
changes, sector-informed improvements to EPA guidance and policies can have an impact on
performance and may provide flexibility and certainty for individual businesses in meeting
environmental regulations.
Program Element 2: Pollution Prevention
The CSI subcommittees worked on more projects with pollution-prevention components (18
total) than any of the other program element. Four of the nearly 30 CSI formal Council
recommendations involved projects with pollution-prevention components: the SGP (Metal
Finishing Subcommittee); the Electronic Product Recovery and Recycling Roundtable (Computer
& Electronics Subcommittee); the Leak Detection Project (Petroleum Refining Subcommittee);
and the Life-cycle Management (Automobile Manufacturing Subcommittee). The SGP (Metal
Finishing Subcommittee) alone had nine separate projects with pollution prevention components.
The PrintSTEP design (Printing Subcommittee) is another fairly comprehensive project with
multiple pollution prevention elements.
Other projects with pollution prevention components that did not result in formal
recommendations include: the Multimedia Permitting Pilot (Iron & Steel Subcommittee) and the
New York City Education Project (Printing Subcommittee).
Program Element 3: Recordkeeping and
Reporting
Five of the six subcommittees worked on
projects addressing recordkeeping and
reporting issues. In total, 14 projects
addressed reporting issues. One of the most
extensive pilot efforts to consolidate reporting
requirements was the Computer & Electronics
Subcommittee's consolidated Uniform Report
on the Environment (CURE). The same
subcommittee developed The Basic Online
Disaster and Emergency Response (BOLDER)
software, which is a planning tool that
consolidates over 500 pages of federal, state,
and local agency response plans into one
30-page plan that is easy to access, understand,
Consolidated Uniform Report
for the Environment
This Computer & Electronics Subcommittee project
consolidates information required by 12 different
federal and state environmental reports for the
computer & electronics sector, reduces by 60 percent
the data elements reported, and streamlines the
reporting process. The development of CURE was
led by the Texas Natural Resource Conservation
Commission. CURE'S goal is to comply with
existing reporting requirements.
and implement. In addition, the CSI Council
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worked on the Reinventing Environmental Information (REI) Action Plan, the Data Quality
Strategic Plan, and the Data Gaps Strategy, and developed recommendations addressing all three.
Program Element 4: Compliance and Enforcement
There were 13 projects addressing compliance and enforcement issues, the majority of them in the
Metal Finishing Subcommittee. Most notable are the Metal Finishing 2000 Pilots that seek to
give flexibility to top performers (Tier 1 firms); the Environmentally Responsible Exit Strategy for
poor performers who would like to close down (Tier 3 firms); and the Targeted Enforcement
Strategy for chronic non-compliers (Tier 4 firms).
PrintSTEP
With PrintSTEP (Printing Simplified Total
Environmental Partnership), the Printing
Subcommittee has provided a design for
consolidating and simplifying permitting for
printers, providing incentives for preventing
pollution, promoting community participation, and
providing operational flexibility. Sector
participation will continue in a working group under
Program Element 5: Permitting
Four of the six subcommittees worked on
projects related to permitting. The Iron &
Steel Subcommittee, for example, developed a
multimedia permitting model for mini-mills.
Both the Computers & Electronics
Subcommittee and the Metal Finishing
Subcommittee looked at issues surrounding
the permitting of zero discharge systems. The
Printing subcommittee developed the
PrintSTEP design, an integrated, incentives-
based partnership that seeks to collect all of a
printer's different media permits into a single
document, with a single permitting agency point of contact
Program Element 6: Environmental Technology
Environmental technology was the subject of eight CSI projects in three subcommittees. The
Petroleum Refining Subcommittee promoted the use of an innovative laser leak detection
technology as a means of complying with EPA requirements. The Metal Finishing Subcommittee
completed several pollution prevention technology demonstration projects, including one that
sought to demonstrate the value and compliance efficacy of using pollution prevention
technologies to comply with the Chrome Maximum Achievable control Technology (MACT)
standard. The Computer & Electronics Subcommittee addressed barriers to using zero waste
water discharge technology, presented by current application of RCRA requirements.
Program Element 7: Community and Stakeholder Involvement
All of the subcommittees worked on projects addressing community and stakeholder involvement
- 15 projects total For example, the Iron & Steel Subcommittee addressed community
involvement in its Brownfields project and created a Community Advisory Committee pilot, while
the Printing Subcommittee made a community involvement plan an integral component of its
PrintSTEP pilot design. The Computer and Electronics Subcommittee developed A Resource
Guide for Constructive Engagement that will assist companies, communities, and governments in
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successfully collaborating on environmental issues by telling users where to find resources, but
also provides practical advice and case studies. These projects and recommendations were
consistent with other ongoing EPA efforts to improve stakeholder and community involvement in
Agency actions, and involved issues which cut across all of the sectors. Therefore, at the request
of EPA, the CSI Council, created a workgroup to support the Agency's effort to develop a more
extensive and consistent policy on stakeholder involvement. The Council produced a formal
recommendation on improving stakeholder involvement in Agency activities. The
recommendation led to the creation of an Agency-wide Stakeholder Involvement (SI) Action
Plan.
Program Element 8: Future Issues
The Council and two subcommittees—Computers & Electronics and Metal Finishing—
completed projects that dealt with future issues. This category includes the Metal Finishing
Environmental R&D Plan and the Computer & Electronics Subcommittee's recommendation on
Worker and Environmental Health. All of the CSI Council's recommendations include an element
on future issues facing the Agency, including recommendations on:
• the SBEP Action Plan, defining strategies for integrating sector approaches into
the work of the Agency;
• the Stakeholder Involvement Action Plan, including recommendations relating to
common vocabulary related to stakeholder techniques, analytic tools to integrate
stakeholder involvement and decision making, and establishment of internal
coordinating mechanisms within EPA to ensure that EPA staff is made more aware
of stakeholder involvement approaches;
• the REI Action Plan, focusing on improved access and efficiency in information
availability and management, which helped to lay the groundwork for EPA's new
Office of Information Resources Management;
• issues related to data gaps and data quality in the Agency's management of
environmental information.
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Table 2: CSI Projects By Program Elements*
Element Automobile Computers and Iron & Steel Metal Finishing Petroleum Printing Council
Manufacturing Electronics Refining
Regulations Alternative
Regulatory
System
Regulatory
Initiative Project
(mass per unit)
Alternative System of
Environmental
Protection
Barriers to Closed-
loop Water
Recycling
Compilation of
Regulatory
Interpretations and
Determinations
CRT recycling
NSPS rule revision for
monitoring pressure in
EAF's
Early stakeholder
involvement in rule making
Modified Guidance for non-
witnessed tests
RCRA MF F006 Wastewater
Sludge Benchmarking Study
F006 90-day Storage Rule
Extension
Alternative
Work/
Monitoring
Practices
Program
-
' See list of acronyms in Appendix 6
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Element Automobile Computers and Iron & Steel Metal Finishing Petroleum Printing Council
Manufacturing Electronics Refining
Pollution Life Cycle
Prevention Management
Electronic Product
Recovery and
Recycling
Barriers to Closed-
looped Water
Recycling
RCRA Barriers to
CRT Recycling
Permitting Improvements
Access to Capital
Approaching Zero Discharge
Chromium Pollution Prevention
Tech. Demo
CLEAN-Pollution Prevention
National Metal Finishing
Environmental R&D Plan
Environmental Technical
Verification
RCRA MFP006 Wastewater
Sludge
POTW Training Education &
Incentive
MF Guidance Manual
Environmental Responsible Site
Transition for Tier 3 Firms
Alternative
Work/
Monitoring
Practices
Program
Laser Leak
Detection
Technology
Testing
PrintSTEP
New York City
Education
Project
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Element
Recordkceplng
and Reporting
Automobile Computers and
Manufacturing Electronics
Iron & Steel
Metal Finishing
Petroleum
Refining
Printing
Council
Compliance
and
Enforcement
Reporting and Public
Access
Texas CURE
BOLDER
3R Project
Consolidated Multi-media
Reporting
Alternative Compliance
Strategy
Analysis and reporting of
compliance data
Expanded use of SEPs
RIITE Report
RITTE Pilots
Electronic Reporting Pilots
PEERL
Prototype Reporting and
Resource Link (web site)
Metal Finishing 2000 Flexible
Track Program, Pilots, and
Report
Clean Pollution Prevention
National Metal Finishing
Resource Center (NMRC)
MF Guidance Manual
Tier 4 Facility - Targeted
Enforcement
Environmentally Responsible
Site Transition Exit Strategy for
Tier 3 Firms
Compliance Assistance Tools
Industrial Pretreatment
Refinery Air
Information
Reporting
System
(RAIRS)
PrintSTEP
PrintSTEP
REI
Data Gaps
Data Quality
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Element
Permitting
Automobile Computers and
Manufacturing Electronics
Iron & Steel
Metal Finishing
Petroleum Printing
Refining
Council
Environmental
Technology
Barriers to Closed-
Loop Water Recycling
Barriers to Closed-
Loop Water Recycling
General Permitting Issues
Multi-Media Permitting for
Mini-Mills
Effective NPDES sampling
Computerized permitting
system
Environmentally Responsible
Site Transition for Tier 3 Firms
RITTE
Approaching Zero Discharge
Access to Capital (Pilots,
Report, Meeting)
National MF Environmental
R&D Plan
Approaching Zero Discharge
Chromium Pollution Prevention
Tech Demo
Environmental Technology
Verification Project
Alternative
Work and
Monitoring
Practices
Program
Laser Leak
Detection
Technology
Testing
PrintSTEP
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Element
Involving
Communities
Automobile
Manufacturing
Computers and
Electronics
Iron & Steel
Metal Finishing
Petroleum
Refining
Printing
Council
Future Issues
Community
Technical
Assistance/
Demographic
Environmental
Tool
Electronic Product
Recovery and
Recycling (EPR2)
Collection pilots
Constructive
Engagement
Electronic Product\
Recovery and
Recycling (EPR2)
Worker Environmental
Health
Community Advisory
Committee
Brownfields
Iron & Steel Liaison
Code of Conduct
7 of 12 Permitting
Recommendations
Early public involvement in
Rules
National MF Environmental
R&D Plan
Ad Hoc Risk Characterization
Workgroup
SOP
National MF Environmental
R&D Plan
Ad Hoc Risk Characterization
Workgroup
Strategic Goals Agreement and
Program
State/Region/City mini-goals
program pilots
Refinery Air
Information
Reporting
System
(RA1RS)
Refinery
Accidental
Release
Information
Communication
(Pilot in Norco,
La.)
PrintSTEP
New York City
Education
Project
Stakeholder
Involvement
Stakeholder
Involvement
REI
Data Gaps
Data Quality
SBEP
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PRODUCTIVITY INCREASED IN THE FINAL TWO YEARS
Many stakeholders noted that the pace of development and implementation of projects and
recommendations by the CSI Council and many of the subcommittees increased during the last
two years of CSI. For example, the Printing Subcommittee had explored a range of options
related to permitting over the first two years, but agreement over the ultimate shape of the
PrintSTEP program and the development of a multi-faceted, detailed pilot design were
accomplished during the latter half of CSI. The Computer & Electronics Subcommittee
developed four new recommendations during the last two years, developed the Constructive
Engagement guide, and made significant progress in developing and field testing both the CURE
and BOLDER projects. Petroleum Refining reorganized and re-started its efforts over the last
two years, both initiating and completing its primary projects during this period.
It is important to recognize the "learning curve" represented by the first two years of CSI. CSI
participants suggested several factors that contributed to the increased productivity during the
second two years of CSI and, as a result, improved its overall image:
• development of a better understanding of the issues and concerns of other
stakeholders;
• gradual improvements in recognizing which areas provided the greatest
opportunity for progress;
• increased comfort with the consensus negotiation process;
• adoption of deadlines (both self-imposed and resulting from the announced
ending of CSI); and
• a stronger leadership role by EPA6
With respect to the pace of productivity, the experiences of the subcommittees varied. For
example, the factors noted above were already in place prior to 1997 for at least one
subcommittee: Metal Finishing. Work on the SGP began in early 1996, and much of the
significant stakeholder negotiations were completed in that year. The SGP was endorsed by the
CSI Council in late 1997, building on the success of 14 subcommittee projects (most of which
were substantially underway in the pre-1997 timeframe). The second two years of CSI for Metal
Finishing were characterized by continued productivity and progress in actual SGP
implementation.
^or additional analysis of these and other factors, see Section III, which includes a table showing the
actions EPA took in response to the recommendations for improvement presented in the SCO and GAO reports.
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The Automobile Manufacturing Subcommittee completed its work early in the third year of CSI
operation (March 1997), and was cited frequently by participants as one of the less-productive
subcommittees. However, this sector exhibited productivity once the official decision to
discontinue the subcommittee was announced in Fall 1996. For example, most of the projects the
subcommittee worked on were developed and completed within the last nine months of its
existence. These projects addressed regulations, pollution prevention, and community
involvement
Unlike many of the other subcommittees, participants on the Iron & Steel Subcommittee noted
that significant progress was made in the first two years of the program. Of the 16 projects
worked on by the Iron & Steel Subcommittee, 12 projects were completed or in the
implementation phase before 1997. After having these early successes, the Subcommittee came
back to the broader issues of goals for the sector as a whole. This change in focus was the result
of a self-evaluation of sector progress done in Fall 1996. One of the findings of this self-
evaluation showed that stakeholders believed they were not addressing the larger, important
issues for the industry. Over the last two years, the subcommittee tried to reach consensus on
issues to work on tried to address a larger, more strategic framework for the sector. But
stakeholders said that the discussion of these broader goals became polarized, and ultimately, no
agreements were reached. As a result, limited progress was made covering new ground in the last
two years of CSI for the Iron & Steel Subcommittee.
The CSI Council mounted three major efforts separate from the subcommittee efforts during the
last two years of the initiative:
• launching Agency plans for improving environmental information and
reporting through the REI initiative, resulting, in part, in the creation of a
new information office, and analyzing issues related to data gaps and data
quality;
• developing a report on stakeholder involvement at EPA and making three
recommendations for improvement (resulting in the development of the
EPA Stakeholder Involvement Action Plan); and
• supporting EPA planning for future sector-based approaches, which has
been incorporated in the SBEP Action Plan.
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Section II:
Understanding CSFs Results
If stakeholders agreed on one thing, it was that success in CSI cannot be disentangled from
implementation. To the stakeholders, CSI was about making change happen, getting ideas and
concepts on the table, and ultimately making changes in how we pursue environmental goals. It
was about measuring real environmental improvement. To assess the value and success of CSI, in
this section we look at the results that emerged and ask, "Did it make a difference?' For many
CSI projects, it is too soon to tell But the potential can be evaluated, based on the design ("What
does it promise?") and on the likelihood for implementation ("What, where, and how strong are
the commitments?')- In this section, we present stakeholder perceptions of what CSI
accomplished.
A COMPREHENSIVE APPROACH TO PROBLEM SOLVING
A few CSI projects successfully used a comprehensive approach that tackled a broad range of
environmental issues, such as industry operations, pollution prevention, community involvement,
and permitting. In terms of environmental improvements, several sector subcommittees
developed comprehensive projects that show considerable progress in non-regulatory areas, and
others offer the potential for environmental gains that go beyond regulatory compliance. Three
CSI efforts were generally described by stakeholders as the most successful to address a range of
these issues (e.g., industry operations, pollution prevention, community involvement, and
permitting) and offer environmental gains:
• SGP (Metal Finishing Subcommittee);
• PrintSTEP (Printing Subcommittee); and
• CURE (Computers & Electronics Subcommittee).
Although each effort is viewed as successful by many of those interviewed, a wide range of
participants described the SGP as the most comprehensive outcome of CSI. This sector-wide,
national program has taken on large issues such as industry commitments to reduce emissions,
incentives for beyond-compliance behavior, and integration of reporting, information, and new
technology research and development as tools toward promoting a broader change of
environmental management within the sector.
The Printing Subcommittee's pilot design for PrintSTEP addresses a range of industry operations,
community involvement, and permitting issues. Many stakeholders on the Printing Subcommittee
feel that they have succeeded in developing a multimedia, one-stop approach to permits for
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printers that incorporate incentives for pollution prevention and provides a potentially strong role
for communities in reviewing and commenting on the local impact of printing facilities. The
design provides for integration of all permitting requirements under a single agreement, but does
not alter any regulatory requirements. The specific requirements for any printer seeking a
PrintSTEP agreement are determined by the levels of its environmental releases to all media.
Participation in PrintSTEP is voluntary, and some subcommittee stakeholders are concerned that,
while relatively comprehensive, the design may not offer strong enough incentives for companies
to participate.
CURE, developed by the Computer & Electronic Subcommittee, is another project viewed by
many CSI participants as an innovative success of CSI. The project focused on consolidating and
simplifying reporting, and providing information that is more readily understood by and accessible
to communities. Participants pointed out that a series of stakeholder focus groups were some of
the tools used to ensure that a wide range of stakeholder concerns and interests were addressed,
and that issues of information and reporting were not approached only as narrow technical
concerns.
UNFINISHED BUSINESS
Many CSI projects have been completed, but others are still underway. Some of these ongoing
efforts face uncertain implementation since the CSI FACA has ceased operations. Interviewees
generally feel that EPA has the key leadership role in sustaining these projects. However, they
believe that the commitments of other stakeholders to these ongoing projects are also important
Representatives from all stakeholder groups stressed that even the most outstanding achievements
of CSI are still very much "works in progress." Due to the multi-year nature of implementing
regulatory changes and voluntary programs, few of the more visionary CSI projects have been
fully implemented. There is stakeholder concern that some of the larger, more comprehensive
projects—ones with longer timeframes or which take on complex issues—may experience
difficulty reaching completion. Table 3 is a summary and characterization of the implementation
status of selected projects and recommendations about which stakeholders from the various
subcommittees frequently expressed concerns.7
For example, implementing the Metal Finishing SGP requires multi-year funding by the Agency,
and extensive coordination and commitment of numerous EPA offices, the regions, state and local
governments, industry, and other stakeholders. SGP is a comprehensive partnership, and while
EPA commitment to its implementation is very strong, the effort's size, scope, and timeline all
contribute to stakeholder concerns that difficulties could arise. Many stakeholders fear that the
7See Appendix 3 for a more complete listing of CSI projects and recommendations.
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high levels of motivation, interest, and program visibility—cited by stakeholders as important for
successful implementation—may prove hard for EPA to sustain over time. As one stakeholder
put it, "It has to be more than EPA speeches; mid-level managers have got to come through with
performance. The SGP needs to get integrated into regional [EPA Offices'] Work Plans. It
needs to get institutionalized." Concerns were expressed about the need for accountability and
empowerment of the EPA managers.
The Printing Subcommittee's PrintSTEP project provides a useful illustration of stakeholder
perspectives on the need for both EPA follow through and stakeholder commitment. While the
Printing Subcommittee completed a project design for PrintSTEP, implementation has just begun.
At the time we completed our interviews, many subcommittee participants were concerned and
uncertain about EPA follow through. In fact, it appears that PrintSTEP currently has both strong
EPA senior leadership and commitment of resources (the Office of Enforcement and Compliance
Assurance has dedicated staff over the next 2-3 years, $500,000-$600,000 to support state
implementation, plus additional funds for facilitation and other support). But even with solid EPA
commitment stakeholders also pointed to other potential weak links on the path to full
implementation, particularly state commitment to implement pilot projects and industry
commitment to educate and persuade its members to volunteer for PrintSTEP.
Some subcommittees sought to systematically identify key persons and offices to take
responsibility for implementing projects and recommendations. For example, the Computers &
Electronics Subcommittee stakeholders tried to find an EPA "home" for each of the sector's nine
recommendations. EPA staff identified offices and persons with the authority and interest to take
ownership of these efforts. In one case, based on a Computers & Electronics Subcommittee
recommendation on "obscure" policy determinations, EPA identified and developed meta-data on
about 4,000 documents which will be included in a Policy and Guidance Collection, accessible
(scheduled to begin in Spring 1999) through the EPA Home Page. However, while this project is
close to completion, most of the subcommittee's projects were developed less than one year ago
and implementation is only recently underway.
While there is high support and commitment by EPA for most projects, some subcommittee
participants noted that two of the three Automobile Manufacturing Subcommittee
recommendations have had weak or no follow through by EPA and do not appear likely to
progress:
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• One recommendation asked EPA to explore how to organize reporting
requirements to take advantage of pollution prevention opportunities in
life-cycle management (LCM). While the Office of Reinvention facilitated
discussions on data needs to support LCM concepts and promote
opportunities for its use, there is no official LCM home, project, or plan in
place that further develops or promotes LCM concepts.
• The Alternative Regulatory System/Community Technical Assistance
recommendation asked EPA to experiment with a new sector-based
information tool to improve the utility of data and address quality issues.
Other than placing the information work product (a sector report on
Automobile Manufacturing plants and demographics) on the Center for
Environmental Information and Statistics' (CEIS) and CSI Web sites, EPA
has not initiated plans that builds on this effort.
Some of the participants indicated they had originally expected further follow through by EPA
but, that with the closing of the Automobile Sector, attention to these projects faded.
CSI participants were clear that without EPA follow through on these projects, the sense of
success, that many stakeholders now share, would vanish quickly. In spite of the leadership they
believe EPA has, however, they recognize that, unlike traditional regulatory programs where EPA
and the state agencies are responsible for implementation, CSI has been a collaborative, multi-
stakeholder process. Many CSI projects go outside the usual boundaries and therefore require
EPA to find strong and effective partners, not only in the states, but in local governments,
industry, and (in some cases) environmental and environmental justice groups and labor.
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Table 3: Summary of Stakeholder Perceptions of Implementation Status of Selected CSI
Projects/Recommendations Based on Interviews
Sector
Automobile
Manufacturin
g
Computers &
Electronics
Iron & Steel
Metal
Finishing
Petroleum
Refining
Printing
Implementation underway
and completion highly
likely
Regulatory Initiative Project
(alternative mass/area
painting standard)
Barriers to Closed-loop
Water Recycling
Early Stakeholder
Involvement in Regulatory
Development
RITTE Program Pilots
Prototype Reporting and
Resource Link (PERRL)
Exit Strategy for Tier 3
Firms8
Laser leak-detection
approach and standard
Implementation
underway, but
stakeholders skeptical
of full completion
BOLDER
CURE
Iron & Steel Web site
Strategic Goals Program
PrintSTEP
Implementation absent or
weak, and stakeholders
skeptical of future completion
LCM Project
Community Technical
Assistance Data Project/
Alternative Regulatory System
Multimedia Reporting Pilots
Targeted Enforcement Strategy
for Tier 4 Firms
New York City Project
8The Metal Finishing Subcommittee identified four tiers of metal finishing facilities according to differing
environmental performance: top performers (Tier I); average performers (Tier II); old, poor performers (Tier III);
and rogue firms (Tier IV).
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MEASURABLE ENVIRONMENTAL BENEFITS STILL ANTICIPATED
Some projects are anticipated to have measurable environmental benefits (e.g., reduced air
emissions) if implemented and successful While many projects in CSI address "process" issues
about how to meet current environmental regulations in a cheaper, smarter, and faster manner,
they did not cover actions with environmental results (e.g., recordkeeping and reporting).
A few projects, however, are anticipated to have direct, potentially measurable environmental
benefits; a smaller number have developed environmental results performance measures. The
eight projects shown in Table 4 below focused on issues that will have direct environmental
results.
Table 4: Summary of Projects with Environmental Results
Sector
Automobile
Manufacturing
Computer &
Electronics
Iron & Steel
Metal
Finishing
Petroleum
Refining
Printing
Projects
Not applicable
Closed-Loop Recycling/
Eliminate Zero-Discharge
Barriers
Cathode Ray Tube
Recycling
Electronic Product
Recovery and Recycle
Brownfields
Multimedia Permitting
Pilot
Strategic Goals Program
Equipment Leaks
PrintSTEP
Environmental Goals/Actions
Not applicable
Promote elimination of wastewater discharges by Computer &
Electronics plants
Reduce lead waste through Cathode Ray Tube glass recycling
Collect, recycle, and reuse end-of-life residential computer and
electronic equipment, reducing disposal and need for new
materials
Clean up brownfields sites for redevelopment in Alabama and
Northwest Indiana
Reductions identified by facility in Pollution Prevention Plan
(limited to a single facility pilot; no further actions planned)
Tier I and Tier H
- 90% reduction in organic Toxic Release Inventory emissions
- 50% reduction in metals emissions to air and water
- 50% reduction in land disposal of sludges
Tier in exit strategy (which is Brownfields Prevention)
Tier IV chronic non-complier enforcement strategy
Reduce air emissions from refineries with better leak detection
Reductions in Volitile Organic Compound/hazardous air
pollutants emissions by participating printers
Stakeholders interviewed stressed that most of these projects are in the early implementation
phase and that environmental benefits should be measured only after the projects are implemented.
This was particularly true for the PrintSTEP project, since it is in the very early stages of
implementation with the detailed design being recently completed. EPA is currently seeking 3—5
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states to participate in three-year pilots for PrintSTEP. However, no pilots were initiated at the
time of our interviews. Also, while the SGP's early implementation phase is well underway, it still
has a considerable number of steps to complete.
PARTICIPANTS BRING HIGH EXPECTATIONS
While most CSI participants were able to cite specific accomplishments, few felt that they had
succeeded in addressing issues of the scope they had anticipated at the outset of CSI. In
particular, the initiative did result in a small number of narrow, sector-specific rule modifications,
but CSI made very little progress in addressing broad regulatory changes. The Administrator's
original description of EPA's goals created expectations (and sometimes concerns) that CSI
would provide an opportunity to rethink all environmental regulations from a sector perspective,
using a multi-stakeholder process. In light of the broad mandate for the CSI effort, many
stakeholders brought a variety of ambitious goals to the CSI negotiations. The types of goals
varied by stakeholder, with some objectives more widely shared, and others mostly specific to
particular stakeholders, including:
• developing alternative regulatory frameworks,
• increasing regulatory flexibility;
• developing pollution prevention-incentive approaches to promote
significant changes in environmental management;
• reducing reporting burdens;
• increasing access to and transparency of environmental information;
• increasing efforts to reduce cumulative environmental impacts on
communities; and
• improving conditions for worker safety and health.
At the outset of CSI, the EPA Administrator raised expectations that the initiative would search
for ways to improve environmental performance and fundamentally "change the regulatory
system." Therefore, early CSI participants joined with an expectation that they would be
working on far-reaching changes to the regulatory system, including both existing rules and rules
under development. For example, four of the six sectors (Automobile Manufacturing,
Computers & Electronics, Iron & Steel, and Printing) were interested in pursuing New Source
Review issues. It became clear, however, that this regulatory area was not "on the table," since
modifications to NSR issues were being explored in a number of other Agency efforts (e.g., NSR
Reform Initiative). Similarly, the Metal Finishing Subcommittee wanted to take on potential
changes to the upcoming Metal Products and Machinery effluent guideline, but initially found
resistance by EPA to addressing these potential regulatory issues as part of the development of
the SGP. The Metal Finishing Subcommittee's initiative did ultimately lead to a formal
commitment from EPA to integrate flexibility into the rulemaking process, directly impacting
metal finishing, and it also led to four recommended rule revisions. But this was not as far
reaching as many participants had hoped.
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The 1997 evaluation of CSI by the Scientific Consulting Group noted that the gradual realization
that changing regulations would not be readily accomplished within the context of CSI led to a
variety of responses by CSI participants—from focusing on narrower projects, to looking for non-
regulatory routes to make significant changes in environmental management policies toward or
practices within a sector, to frustration. The following examples highlight this transformation.
• Almost from the start, the Metal Finishing Subcommittee adhered to an
agenda that sought to address many broad issues of concern to the
stakeholders. The subcommittee was able to tackle some specific issues of
regulatory flexibility (e.g., extending the storage period for hazardous
wastes; MF2000 pilots with local requirements flexibility), but was not able
to incorporate federal regulatory and enforcement discretion components
of their original goals into the SGP. In addition, labor representatives9 felt
that their concerns for worker health and safety were not met.
Nonetheless, the rest of the Subcommittee members interviewed generally
expressed satisfaction with the scope of what they accomplished.
• The perspectives of those interviewed from the Printing Subcommittee
were not as uniform. The representatives of the largest printers and of the
environmental groups,10 respectively, expressed that the subcommittee
dealt insufficiently with the regulatory flexibility and pollution prevention
issues in which they had been interested at the outset. Among other
participants, however, views were mostly in agreement with the
characterization of an EPA staff person that the subcommittee "took on the
kind of issues CSI was really intended for," and an industry participant who
felt that "we did really well in meeting the goals."
Outside of these two subcommittees, there was far tess sense of having effectively addressed the
"original" goals or expected scope of CSI. Participants interviewed from the other four
subcommittees were nearly unanimous in their view that they were not successful in developing
approaches to the issues which were most important to them at the outset of CSI, with many
expressing disappointment with the lack of overall accomplishment. Even from these
subcommittees, however, most of the participants we interviewed said that they felt there were
significant project accomplishments.
9In general, labor representatives participating in CSI felt that since two other federal agencies—the
National Institute of Occupational Safety and Health and the Occupational Safety and Health
Administration—were not CSI participants, it was not possible for the Initiative to address labor's priority
environmental and worker health issues in an effective way.
All the environmental group representatives resigned from the subcommittee about a year before the
conclusion of CSI, though two representatives continued to comment on PrintSTEP.
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Automobile Manufacturing Subcommittee members, for example, widely
agreed that LCM was innovative and that such discussions had not
previously taken place between stakeholder groups or even within the
industry, but they wished that the discussion could have gone further. For
example, reluctance on the part of several participants to reveal information
that they viewed as confidential hampered efforts to carry the discussion
beyond hypothetical examples, resulting hi a lack of conclusions drawn
from real data and diminishing the usefulness of the LCM effort as a real
tool Participants (especially environmental justice participants) also felt
positively about the community-based information tool
Participants on the Computers & Electronics Subcommittee were
unanimous hi their view that they had made significant progress where
projects addressed practical issues such as cathode ray tube glass recycling,
pilots for recovering end-of-life computer and electronics equipment, the
emergency response software planning tool (BOLDER), consolidated
reporting (CURE), and public access to EPA regulatory determinations.
Moreover, some did feel that they met their original individual goals, even
if the subcommittee as a whole did not, and vice versa. For example, in the
alternative strategies workgroup, environmental groups were successful in
achieving their goal of adding worker health and safety issues to the
agenda, but the overall workgroup goal of testing a conceptual framework
for an alternative environmental management system was not met. The
barriers workgroup as a whole thought they had met the overall goal of
more efficient and cost-effective recycling of cathode ray tube glass
recycling, however, one individuals' stated goal of total deregulation was
not achieved.
Iron & Steel and Petroleum Refining Subcommittee members noted the
incremental benefits of projects such as the community-based
redevelopment process and SEPs initiatives for Brownfields projects; the
recommendations on permitting issues and air monitoring requirements;
and the establishment of iron and steel liaisons.
The Petroleum Refining Subcommittee members noted the benefits of their
efforts on streamlined air information reporting and equipment leaks
technology.
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SIGNIFICANT INTANGIBLE BENEFITS
Regardless of regulatory or environmental results, improved stakeholder relationships, better
mutual understanding and co-learning, and progress in trust building are widely viewed by
participants as not only valuable, but a significant outcome of the multi-stakeholder CSI process.
Some benefits have already been realized through the development of new networks of
relationships, including new stakeholder collaborations, project partnerships, and educational
initiatives.
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The 1997 evaluation of CSI by the Scientific Consulting Group concluded that "CSI has had
considerable success in the area of process."11 At that mid-point, participants were getting to
know and understand the other stakeholder groups. Those new relationships and a movement
toward trust helped some subcommittees begin to focus on and resolve substantial issues. The
1997 evaluation found that, "The involvement of multiple stakeholders... and the ensuing process
of developing understanding, working relationships, and sometimes trust and respect were viewed
as valuable by almost all participants."12 The four-year evaluation, at the close of CSI, both
supports the earlier finding and indicates ways in which these new networks of relationships may
be a step toward changing some of the traditional patterns of interactions between stakeholders
on environmental issues.
Building Networks
A majority of the CSI participants interviewed cited improved stakeholder relationships, better
mutual understanding, and progress in trust building as significant and important outcomes of CSI
. This view is common whether or not the participant considered his or her subcommittee's
projects successful, or if CSI as a whole did or did not meet his or her expectations—though
somewhat more prevalent in those subcommittees that also had substantive successes. This was
true even for the Council, which Subcommittee and Council participants generally felt had a
limited substantive role; one Council member commented, for example, that the Council played a
very important role in "developing conversations between people who normally didn't talk to each
other outside of a courtroom."
The growth in relationships took some time to develop; in general, participants felt that it was a
more marked characteristic of the final two years of CSI than the first two. Toward the end of a
focus group involving diverse stakeholders from the Council and various subcommittees, one
member commented, "The beauty of the process is that we all tend to agree here [about the value
and potential for long-term results of the CSI process and ways to strengthen it]; that would not
have happened two years ago."
Participants did not consider improved relationships to be simply a matter of good feelings.
Across all the CSI subcommittees, participants stressed the importance of the educational aspect
of the CSI experiment: diverse stakeholders sharing perspectives, knowledge, and information in
order to gain a better common understanding of an industry; the values gained from its technical
processes, regulatory complexities, and economic realities; and its potential environmental,
community, and worker impacts. Many said this mutual learning outcome has been invaluable,
11 Scientific Consulting Group, Review of the Common Sense Initiative. February 1997, p.35.
12 Ibid. p. 38.
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.Common Sense Initiative
and noted that better mutual understanding is a necessary foundation for the reinvention of any
regulatory framework.
Educational Benefits
The educational benefit was both technical and motivational Stakeholders gained a new
appreciation of each other's core concerns by reaching a higher level of understanding:
• Regulators (federal, state, and local government) learned more about
different industries, hopefully making them better and more informed
regulators.
• Industry, depending on their previous level of interaction with regulators,
gained a new appreciation for the level of sophistication and complexity of
environmental management in the United States. This was especially true
for subcommittees predominately characterized by small businesses, such
as printing and metal finishing. Participants from all subcommittes said
they gained a new understanding of environmental and community
concerns.
Environmental, labor, and environmental justice participants sometimes found greater
understanding for the interests and concerns of some companies or industries. They gained
improved technical understanding of particular industry sectors, the sometimes difficult economic
balancing act of a company, and the financial barriers that may be in the way of doing more
environmentally. For example, the "Access to Capital" workshop involving Metal Finishing and
Computers & Electronics participants, brought lenders into the dialogue of gaming capital
investments for pollution prevention. Some environmental stakeholders gained slightly more
comfort with the concept of the flexibility in responding to some regulatory requirements that
industry wants (but only with built-in safeguards and results that go beyond compliance); as a
tradeoff, some industry participants became more willing to consider providing the more
transparent information and increased accountability sought by the environmental and community
groups.
CSI Seeds Spin-Off Efforts
In many cases, participants felt that the CSI experience and the new network of relationships
would lead to long-term and expanded networks with stakeholder groups that participated in CSI
as well as others they now understand better or perhaps see as less threatening. Building new
relationships beyond the framework of other CSI participants was integral to some parts of CSI
projects—e.g., the regional pilots of the SGP for metal finishers, which require multi-stakeholder
processes to identify more local concerns.
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But a few participants also mentioned that, as a direct or indirect result of CSI, there were
projects or activities occurring or under consideration elsewhere that either would not otherwise
have happened, or not have happened in that form. Many stakeholders expressed the expectation
that these kinds of spin-off effects will multiply over time. Some examples include:
• During dialogue in various CSI subcommittees (e.g.,Computers &
Electronics; Automobile Manufacturing), it became clear to a handful of
academics and environmentalists that the non-governmental community
needed leadership in the area of products and product stewardship. From
their perspective, some NGO representatives were blocking constructive
progress—for example, in LCM discussions in the Automobile
Manufacturing Subcommittee—because they were new to the topic and
suspicious of "industry's issue." As a result, a university stakeholder
secured grant money to develop a course to educate NGOs on product
stewardship issues and explore avenues for NGOs to play a leadership role.
• Industry and environmental stakeholders from the Computers &
Electronics Subcommittee developed a good CSI working relationship. As
a result, their respective organizations (Electronics Industry Alliance and
the World Resources Institute) have completed a joint report and are
developing a follow-up report, both on climate change and the electronics
industry.
• At a Ford automobile manufacturing plant in Deerborn, MI, Ford Motor
Company, the Environmental Defense Fund, and the Ecology Center of
Ann Arbor worked cooperatively to involve the community in the
complex's permitting process. According to the Ford representative, his
CSI experience gave him insight into access for local communities and
mitigated his fear of bringing neighbors into the permit process.
• In the Iron & Steel Subcommittee, a good measure of the value of
improved relationships is the number and types of projects the participants
are engaged in outside the formal CSI process. Many stakeholders
identified projects and activities they are working on now with CSI
participants they had no or limited involvement with prior to CSI.
Examples include:
expanded use of multi-stakeholder groups to explore environmental
impacts, and possible solutions, of plants on local communities;
joint efforts of labor and NGO stakeholders to identify common
concerns with respect to new or expanded facilities at several
locations; and
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joint continuing industry discussions (involving both integrated
mills and mini-mills) on developing an overarching environmental
policy for the steel industry.
• From the Printing Subcommittee, an industry representative has undertaken
an effort to promote greater awareness of environmental justice issues and
the potential role printers can play through his industry association.
• A senior state government representative who served on the Metal
Finishing Subcommittee stated that because he found the CSI multi-
stakeholder approach a valuable tool for creating improved relationships
and developing out-of-the-box solutions, he is encouraging his staff to look
for opportunities to use this approach for tackling selected state
environmental challenges.
• The Electronic Products Recovery and Recycling Roundtable (EPR2)
created by the Computers & Electronics Subcommittee provides a
permanent vehicle for multi-stakeholder exploration of issues, such as
institutional barriers to recycling and environmentally preferable designs for
recycling and reuse of electronic equipment
PERFORMANCE MEASURES DEVELOPED LATE IN THE PROCESS
Specific performance measures have been developed to assess outcomes of some CSI projects.
More general measures of the outputs of CSI subcommittees and the Council were developed too
late into the CSI process to provide an effective basis for assessment Recognizing this oversight,
the 1997 SCO and GAO reports recommended that EPA develop performance measures to
evaluate all levels of CSI, including results-oriented performance measures to assess how actions
taken as a result of CSI have led to measurable environmental improvements. Two lands of
performance measures have been developed:
• Subsequent to the SCG and GAO reports, EPA launched an effort to
develop performance measures for the Council and subcommittees.
• Both prior to and since the reports, all active subcommittees developed
performance measures tied to specific subcommittee projects.
Measures of Council and Subcommitte Efforts
Subsequent to the recommendations of the GAO and SCG reports, EPA initiated an effort to
develop performance measures for the Council and subcommittees. While no measures were
developed for the CSI program as a whole, performance measures were developed for the
Council activities and four of the sector subcommittees (Computers & Electronics, Iron & Steel,
Petroleum Refining, and Printing). For two subcommittees, there were no measures developed:
the Automobile Manufacturing Subcommittee, which had already ended its work, and the Metal
Finishing Subcommittee, which had already developed project-related measures for the SGP.
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Measures for Projects/Programs
Three subcommittees developed performance measures to evaluate the success of particular
projects or products: Computers & Electronics, Printing, and Metal Finishing. While the Printing
and Metal Finishing Subcommittees both have developed measures of environmental performance
(for PrintSTEP and SGP, respectively), the SGP performance measures are far more extensive,
and include specific performance goals (which the PrintSTEP measures do not). The Computer
& Electronics Subcommittee developed performance measures to gauge the impact of specific
initiatives. For example, CURE's performance measures include the number of data elements
reduced and the amount of time spent preparing reports.
Metal Finishing
Prior to the SCG and GAO reports, the Metal Finishing Subcommittee was in the process of
developing quantifiable, results-based performance measures for the SGP. Metal finishers who
sign up to the SGP commit to voluntarily reduce hazardous air, water, and solid-waste emissions;
to reduce both water and energy use; and to increase metals utilization in their metal finishing
operations. Table 5 summarizes the environmental improvement goals.
Table 5. Environmental Improvement Results Expected from SGP
Reduced Hazardous Emissions
("Cleaner" Goals)
90 percent reduction in organic TRI emissions
SO percent reduction in toxic metals emissions
SO percent reduction in hazardous sludge disposal
Reduced sludge generation
Reduced worker & community exposure
Improved Resource Utilization
("Smarter" Goals)
98 percent metals utilization
50 percent reduction in water use
25 percent reduction in energy use
The metal finishing industry has pledged, as part of their goals commitment, that 80 percent of
metal finishers nationwide will achieve these facility-specific goals. An online tracking system has
been established in the Metal Finishing Compliance Assistance Center to measure both individual
facility and industry-wide performance in meeting these goals. Facilities fill out a 1992 baseline
year sheet that documents that year's performance with respect to organic TRI emissions, metals
emissions, sludge generation/disposal, energy and water use, and metals utilization. They also fill
out a yearly performance sheet (starting in 1998 and continuing out to 2002, the last year of the
five-year program) to gauge improvements in performance compared to the baseline year.
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PrintSTEP
The Printing Subcommittee has developed draft measures for evaluating the effectiveness of the
PrintSTEP program.13 Environmental impacts will be assessed by measuring pollutants released
prior to and after facilities begin participation in PrintSTEP, normalizing for production.
Pollutants measured will include specific indicators in wastewater, VOC and HAP emissions, and
volumes of waste previously disposed and now recycled. While these measures do not include
specific goals, they address:
• reductions in waste and emissions,
• relative success in achieving compliance,
• use of pollution prevention approaches,
• increased ease of facilities in meeting regulatory requirements,
• ease of administration for state agencies,
• involvement of the public, and
• cost-effectiveness for all stakeholders.
The effort to develop performance measures just began during Winter and Spring 1998, while CSI
came to a close in December 1998. In this context, activity- and output-oriented measures (e.g.,
schedules or objectives for reports, and recommendations) were developed by the Designated
Federal Officers for the subcommittees and the Council They either related to the work to be
completed before the end of CSI or, in some cases, retrospectively established measures for
activities already completed. According to CSI participants, there was little interest in these
measures on the part of subcommittee or Council members. Although a few members of the
Computers & Electronics Subcommittee suggested that it was useful to have a clear statement of
project endpoints, the development of the measures had little to no impact on the work. The
principal reason members gave for lack of interest was that the measures-development effort came
so late hi the CSI process.
13 "Evaluation Strategy for the PrintSTEP Pilot Projects," draft (February 1999).
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Section III:
Key Factors Influencing CSI Results
In this section we analyze the factors that played a role in the quality of CSI's results. This
section explores, for example, what factors led the Metal Finishing Subcommittee to create a
wide-ranging agenda, and what factors influenced other subcommittees to focus on projects much
narrower in scope. Understanding the factors that led to CSI's results is a complicated endeavor,
since the initiative was far ranging, involved a wide array of stakeholders, extended over a four-
year timeframe, and produced a myriad of work products. Drawing out these factors is made
even more complex because the Council and six subcommittees operated very independently of
one another.
The first part of this section covers Multi-Stakeholder/Consensus Factors and examines how
process factors—such as consensus, Council-subcommittee relationships, groundrules,
facilitation, deadlines, technical assistance,, and leadership—were enabling or limiting factors in
Council and subcommittee efforts. The second part of this section covers Sector Factors and
examines how factors such as industry size, participation of decision makers, access to EPA, and
pre-CSI sector studies aided or inhibited Council and subcommittee results. This section
concludes with a table that summarizes the various SCO and GAO recommendations regarding
these factors and EPA's responses.
A. Multi-Stakeholder/Consensus Factors
The CSI process is a significant departure from the traditional EPA policy development process.
The process involved representatives from industry, environmental organizations, environmental
justice and community groups, labor unions, and regulatory agencies that brought different
perspectives and priorities to the table for discussion (the multi-stakeholder dimension of CSI).
So that all participants would have an equal voice, CSI used a consensus-based, decision making
process. This presents a series of findings that reflect stakeholders' perspectives on how CSI's
multi-stakeholder, consensus-based process contributed to or inhibited the Initiative's success.
STRUGGLES TO DEFINE AND IMPLEMENT CONSENSUS
This four-year study and the SCG two-year study found that many participants felt that the CSI
consensus requirement had been an obstacle to achieving results, particularly in the early stages of
the Initiative. The June 1996 CSI Council Operating Principles defined consensus as follows:
"Consensus will be considered reached when all the council members at the table can accept or
support a particular position, even though the position may not be their first choice." Despite
this, participants reported that some CSI stakeholders viewed consensus as a requirement for
unanimity and a license to wield veto power. Without effective groundrules and strong
facilitation, even a single participant could use this extreme approach to consensus to bring the
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efforts the workgroup or subcommittee to a halt. The SCG report, describing process-related
problems in several of the subcommittees, recommended that EPA clarify the meaning of
"consensus."
The struggle to define concensus in a clearer way followed two paths. First, following the SCG
report, the Office of Reinvention developed a White Paper entitled "Consensus Decision-Making
Principles and Applications in the EPA Common Sense Initiative" (October 1997) to clarify the
operational meaning of "consensus" for CSI, and the responsibilities of participants for helping to
make the consensus process work. The White Paper suggested several options providing
flexibility for parties to have a voice in consensus decision making:
• fully support;
• accept, though not the first choice;
• allow agreement to go forward without dissent;
• provide an alternative view on a certain issue within the context of allowing
an agreement to move forward; and
• indicate no consensus.
In the case involving "no consensus," the White Paper stated that "all parties are responsible for
fully articulating their interests and identifying alternatives."
The White Paper put forward an approach maximizing the flexibility in the consensus process, and
indicated that the groundrules for decision making should not include a veto-oriented approach.
The White Paper proved to be an important step for the Council in clarifying that body's
application of consensus, but had less impact on the subcommittees.
Second, the subcommittees had addressed the definition of consensus before the publication of the
SCG report and the White Paper—demonstrating the extent to which subcommittees and the
Council tended to operate autonomously on procedural issues. Subcommittees' approaches to
the consensus process were, however, extremely uneven. Examples from the Metal Finishing,
Printing and Automobile Manufacturing Subcommittees illustrate how varied these approaches
were:
• In March 1995, the draft Operating Principles for the Metal Finishing
Subcommittee suggested flexibility in the operation of consensus:
"Subcommittee Members agree to strive for as broad, inclusive, and
informed a consensus as possible when making Subcommittee decisions,
particularly with respect to final recommendations ... If agreement among
all Subcommittee Members cannot be reached on SL decision, a
Subcommittee Member may express a minority view that will be reflected
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in the meeting summary and/or the Subcommittee's final
recommendations."14
• The draft Operating Principles also stressed the expectation for "good
faith" participation, and dealt with issues such as not characterizing other
members' views or positions to the press— problems which plagued some
of the other subcommittees.
• In 1996, the Printing Subcommittee created its own procedures workgroup
to resolve both operating rules and agenda-setting issues. The
subcommittee also brought in an outside, nationally-recognized expert in
early 1997 to spend a day training members on how to negotiate most
effectively to achieve their interests in the consensus process.
• The Automobile Manufacturing Subcommittee did not resolve its approach
to the consensus process. At the point where the industry participants
announced then- intention to withdraw from CSI and the subcommittee
planned the timeline to end its CSI work, the Automotive Manufacturing
Subcommittee still lacked any defined operating procedures.
However, CSI's use of the consensus requirement proved valuable to more than one
subcommittee project. The evolution of the three projects in particular demonstrate this value:
Metal Finishing's SGP, Printing's PrintSTEP, and Computer & Electronics' CRT Recycling
Project, as described in the section below.
CONSENSUS SUPPORTS CREATIVE SOLUTIONS
The process of making decisions by consensus played a critical role in some of the most creative
of CSI's accomplishments. The strongest example of CSI's multi-stakeholder, consensus-based
process as an innovative policy development tool is the Metal Finishing Sector's Strategic Goals
Program. The metal finishing industry came to CSI having participated in EPA's Sustainable
Industry (SI) Program since 1990, where they had forged good stakeholder relationships with
regulators at the national, state, and local government level The industry and regulators worked
on projects that improved their mutual understanding of the sector, including the sector's traits,
trends, future environmental regulatory outlook, and the barriers—both economic and regulatory
—affecting the sector's ability to improve environmental performance. The major SI result was
the concept of industry tiers: categories of different levels of environmental performers who
would have different policy options and environmental improvement incentive mechanisms
applied to them (e.g., regulatory flexibility for Tier I, compliance assistance for Tier II, transition
to responsible closure for Tier III, and targeted enforcement for rogue outfits in Tier IV).
14 Environmental Protection Agency, "Common Sense Initiative/Metal Finishing Industry Sector
Subcommittee: Operating Principles" (Draft, 3/4/95).
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However, the new stakeholders representing environmental, environmental justice, and labor
interests who were not part of the SI dialogue initially felt that the agenda of the new Metal
Finishing Subcommittee was "rigged," by the regulators and industry representatives who had
been working in SI. The new stakeholders thought they were wasting their time and threatened a
walk-out. Out of necessity to convince the new stakeholders their views mattered and that they
had procedural standing on par with industry, the subcommittee developed operating ground-rules
defining how the consensus-process should function and a working definition of reasonable
consensus. This increased the environmental, environmental justice, and labor participants'
comfort with sitting at the table and working collaboratively.
Metal Finishers Rely on Consensus For Goals Agreement
One of the critical incentives for EPA to conduct consensus-based processes is that decisions
carry more weight, not only because they address the critical issues and concerns, but because
they offer the Agency policies that begin with a broad base of support. Metal Finishing
Subcommittee participants credited the consensus process as critical to the development of the
Goals Agreement It took two years of hard work to hammer out that agreement, and to design
the action plan to implement it The SI "backwards mapping" analysis, identifying drivers and
barriers for changes in environmental management practices, did not foresee the pollution-
prevention oriented, voluntary goals-based, beyond-compliance partnership national program that
was to become the SGP. The pollution prevention elements of the SGP are due largely to
environmental NGO stakeholder contributions (with strong support from environmental justice
and labor participants) to the SI tiering policy concept and resulted from extensive negotiations
on the shape of the SGP between all stakeholder participants. The labor stakeholders were
successful in writing a single goal committing the industry to demonstrate improvements in
worker and community exposure reductions. In Metal Finishing, consensus-empowered
representation served to bring forth a result that was creative, collaborative, and as close to a win-
win situation as anyone got in CSI.
Printers Rely On Consensus To Develop PRINTStep
The Printing Subcommittee's PrintSTEP Project is another example where consensus was critical
to a creative CSI accomplishment. PrintSTEP came out of stakeholder interest in: l)more
efficient and flexible permitting, 2) involvement of communities in environmental decision making,
and 3) increased incentives for pollution prevention. One of the more unique outcomes of the
PrintSTEP agreement was the extent to which the level of community involvement is linked to the
opportunities for one-stop permitting and permitting flexibility—an outcome resulting from
extended negotiations to reconcile the concerns of industry and environmental justice
stakeholders. While not nearly as comprehensive as the SGP, this was still a very intense and
prolonged process of working to achieve consensus. In 1998 alone there were 20 project team
and workgroup meetings (usually two-day) and numerous conference calls. It is unlikely that a
non-consensus process would have generated a project of this sort (Le., Unking flexibility to
community involvement).
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In addition to the Metal Finishing SGP and Printing PrintSTEP projects, there are many other
examples of creative accomplishments resulting from a consensus process: the consensus
negotiations around data elements for inclusion in the Computer & Electronics Subcommittee
CURE; the Automobile Manufacturing Subcommittee's consensus document on "U.S.
Automobile Assembly Plants and Their Communities;" and alternative regulatory systems
developed in the Automobile Manufacturing Subcommittee (Principles of an Alternative Sector
Regulatory System) and the Computers & Electronics Subcommittee (Alternative System of
Environmental Protection). The Computers and Electronics Subcommittee CRT Recycling
Project is one such example. In the case of CRT recycling, the industry trade association had
tried on a number of occasions to convince EPA of the viability of recycling CRT glass. For
example, on one such occasion, the Electronics Industry Association argued that the RCRA Total
Concentrate Leachate Procedure (TCLP) was not applicable to CRT glass since the test that
abrades glass on glass and tests the surface for lead leaching is a phenomenon that does not occur
in a landfill. Frustrated with the lack of progress with EPA's Office of Solid Waste, industry took
the issue into CSI hoping to show that applying the hazardous waste definition of RCRA to CRT
glass was excessive. Industry's goal was to remove CRT glass from regulation as a RCRA
hazardous waste.
Environmentalists and states were supportive of the concept of recycling CRT glass— particularly
because of the environmental benefits of such recycling, which include less lead dispersed into the
environment and large energy savings from usingrecycled glass versus virgin materials. However,
these stakeholders were concerned about potential environmental and human health impacts were
CRT glass mishandled—for example, ground into a leaded glass dust and either dumped or made
into a food container product such as a soda bottle. Other concerns with the deregulation of CRT
glass included how another sector (mining for example) might use the precedent as a loophole to
avoid related RCRA waste management requirements.
CSI's multi-stakeholder, consensus-based process provided an avenue out of these conflicting
stakeholder concerns. The subcommittee developed a recommendation that included a set of
management standards regarding CRT glass handling that, if followed, allows firms to handle
CRT apart from RCRA hazardous waste requirements—requirements that render handling and
transportation of CRT glass uneconomical While from industry's perspective the management
standards still impose considerable cost (since CRTs must be transported as tubes as opposed to
crushed glass, which takes up less space), the recommendation marks a significant step forward in
making CRT glass recycling cost effective. CSI's multi-stakeholder, consensus-based process
played an important role in achieving the recommendation. In the absence of multi-stakeholder
buy-in, industry believes such a recommendation would have been met with a lawsuit by the
environmental community.
While there were many multi-stakeholder, consensus-related problems, many of those
interviewed, especially from the subcommittees that had achieved greater success, saw the
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process as useftil and a welcome alternative to the usual litigations and adversarial policy dialogue
between stakeholder groups. With the Initiative leaving the stage of EPA's reinvention efforts,
many stakeholders expressed concern that EPA not miss the lesson that while stakeholder-based
collaboration has high transaction costs, it can also be the best approach to achieve creative win-
win. Stakeholders were clear about the many shortcomings of CSI, but most stressed that EPA
should be able to learn from the many CSI design and execution problems (see next finding
below), to more clearly recognize the challenges and to help channel the efforts of future multi-
stakeholder efforts more effectively.
PROCESS-RELATED FACTORS SLOW PROGRESS
While interviewees felt that the requirement for consensus-based decision making played a major
role in some of the most creative CSI accomplishments, the two-year CSI evaluations by SCG
and GAO described problems associated with a consensus approach. Stakeholders interviewed
for this four-year study mentioned many of the same issues.
Several process-related factors—including inadequate groundrules, absent or poor facilitation, a
lack of deadlines, a lack of technical assistance for NGOs, and Council-subcommittee relations—
impeded subcommittee and Council efforts during the first half of CSI. EPA identified and
overcame many of these problems early in CSI at the subcommittee level, and improved the
Council's processes after the 1997 creation of the Office of Reinvention. Even though these
reforms were instituted, many of the adverse effects of these process-related factors lingered
throughout the four years of CSI.
The following are the major process-related problems found in the two-year evaluations as well as
this study:
• inadequacies in consensus-process groundrules, timelines, and facilitation;
• insufficient process and support for providing education on technical,
regulatory issues critical to a level playing field; and
• the relationship of the CSI Council to the subcommittees, and the overall
role of the Council
These process-related problems are outlined in great detail in the earlier SCG and GAO reports.
This finding summarizes the issues, delineates EPA's efforts to address the problems, and
summarizes the progress the subcommittees and the Council made in the last two years of CSI.
Inadequate Groundrules, Facilitation, and Deadlines
During the first two years of CSI, there were numerous conflicts that prevented the CSI Council
and subcommittees from effectively pursuing their goals. These conflicts were, at least in part, a
result of: the absence of groundrules and clear operating procedures, inadequate facilitation, a
narrow definition of consensus, and a lack of definite and realistic timelines. Although the 1997
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GAO and SCG two-year reports described the need for improvement in these areas, in many
cases, EPA had already taken steps to resolve these problems. Although there were major
improvements, many participants felt that the initial process breakdowns limited the final
accomplishments of CSI.
Groundrules
Running a multi-stakeholder, consensus-based process requires attention to the procedures
necessary to ensure that conflicts and common interests can be explored in as constructive an
atmosphere as possible. Those interviewees who had participated at the beginning of CSI felt
that, at the outset, in the absence of overarching operating rules, each subcommittee had to
develop its own set of groundrules (covering, for example, issues such as the nature of consensus,
approach of members to resolving conflicts and seeking solutions, treatment of subcommittee
discussions outside the subcommittee, level of participation, and development of agendas) with
uneven results. According to participants, for example, the Metal Finishing and Iron & Steel
Subcommittees accomplished this relatively quickly while the Petroleum Refining Subcommittee
spent a large part of the first two years ongroundrule discussions. For the most part, the various
subcommittees developed their groundrules independently. The subcommittees described by
participants as more successful in developing groundrules included Metal Finishing, Printing,
Computers & Electronics, and Iron & Steel Those subcommittees with the most difficult
groundrule-related problems were Petroleum Refining and Automobile Manufacturing.
One specific groundrule-related problem that many members described as affecting subcommittee
efforts in the first two years of CSI was the absence of clearly defined criteria for removing (or
not re-inviting) members not participating in a "responsible" manner in CSI. EPA chose to
deselect stakeholders in the Printing (environmental justice representative), Computers &
Electronics (environmental representative), and Petroleum Refining (environmental and industry
representatives) Subcommittees. Many participants, including those agreeing with the specific
decisions, felt that the deselection process was dealt with on an ad hoc basis. Although EPA and
many CSI stakeholders perceived the deselected subcommittee members as contentious
representatives and distracting for the subcommittees, the process of deselecting tfiose individuals
likewise distracted the subcommittee from working together.
Many interviewees commented that general groundrule problems delayed their efforts—even in
the subcommittees which overcame them—and contributed to the failures of some subcommittees
to build effective problem-solving relationships. While it is not possible to say, for example,
whether the Automobile Manufacturing Subcommittee would have been more productive in the
absence of its problems with groundrules, it is reasonable to say that these problems at least
increased the difficulty of the challenge.
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Facilitation
Many of the early CSI-problems, including difficulty developing groundrules and following those
groundrules once established, are related to CSI facilitation problems. Facilitation problems were
noted during stakeholder interviews and are well documented in the SCG report.
At the onset of the Initiative, only three subcommittees had trained neutral facilitators (Metal
Finishing, Printing, and Petroleum Refining), instead, other subcommittees used either EPA staff
or volunteer stakeholders to facilitate. According to CSI participants, the absence of professional
neutral facilitation at the start-up of CSI slowed the relationship-building process in several
subcommittees (Automobile Manufacturing, Iron & Steel, and Computers & Electronics).
Ultimately, the use of trained facilitators for the Metal Finishing and Printing Subcommittees was
lauded by many participants. Participants interviewed from both of these subcommittees believed
that the roles of their facilitators were critical to the development of the SGP and PrintSTEP.
Trained facilitators also particularly improved subcommittee and workgroup function for the
Petroleum Refining Subcommittee. However, participants in the Automobile Manufacturing
Subcommittee noted that, for most of the life of the subcommittee, the facilitators had difficulty
keeping some of the more outspoken stakeholders on agenda. As one industry stakeholder put it,
keeping the group in line and on agenda was "like herding cats." Despite the improvement in
facilitation made by EPA after the beginning of CSI, many stakeholders stated that, for some
subcommittees, effects of conflicts stemming from the lack of adequate facilitation early in the
process lingered throughout the remaining years of CSL
Deadlines
Participants on some subcommittees commented that one barrier to progress during the first two
years was the lack of any clear sense of timelines for completing the work of the sectors. Once
deadlines were imposed in these subcommittees, they helped to galvanize action. The motivating
effect of deadlines after a slow start seems to have been a factor for four of the subcommittees:
the Automotive Manufacturing Subcommittee after it decided on a date to shut down, the Printing
and Computer & Electronics Subcommittees after first setting their own deadlines, and both of
these and the Petroleum Refining Subcommittees after a discussion earner in 1998 of CSFs
transition and potential completion. Setting deadlines separate from other elements in the flow of
project development seems not to have been an issue to participants on either the Iron & Steel or
Metal Finishing Subcommittees.
Technical Assistance for Non-governmental Organizations
In a sector-based, multi-stakeholder consensus process, education of participants without strong
technical or regulatory background can be an important factor for building the necessary
knowledge for collaborating on innovative approaches. No systematic provision was made under
CSI to provide this kind of technical support to environmental organizations or environmental
justice representatives.
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The SCO report recommended that EPA provide technical training for environmental
organizations or environmental justice representatives prior to the initiation of new
subcommittees. However, no new sectors were added to CSI, and this issue was never addressed
overall for on going CSI work. The need for technical support was addressed in a variety of ways
by the six subcommittees. For example, in the Computers & Electronics Subcommittee,
environmentalists were allowed to contract (at EPA's expense) with their own technical
consultants. With increased understanding of the technical issues from a trusted source, the
environmental stakeholders felt more confident of the technical details of particular projects, and
more willing to take risks—an important factor hi the agreements on CRT glass recycling and the
zero discharge project. In the Automobile Manufacturing Subcommittee, by contrast,
environmental and environmental justice stakeholders were not given the freedom to select project
consultants. Industry wanted veto authority over any possible consultants. In the end, no
consultants were hired, and the environmental representatives lacked adequate technical expertise
to feel confident about making compromises or strategy decisions.
Relationship of Council to Subcommittees
During the first two years of CSI, the CSI Council lacked a clear role, as noted in the 1997 SCO
Report. The original goal for the Council was both to review the work of the sector
subcommittees and to tackle issues that cut across several sectors (e.g., duplicative reporting and
common regulatory issues such as flexibility under air regulations). However, the SCG study
reported that many participants felt that the Council served largely as a barrier to bringing forward
ideas or recommendations to the Administrator by blocking consensus agreements on
recommendations hammered out in the subcommittees. Several stakeholders interviewed from
the Iron & Steel Subcommittee, for example, noted that after what they regarded as an overly
critical review by the Council of part of the Subcommittee's work on Brownfields, the
Subcommittee declined to send a revised recommendation back to the Council and focused
instead on promoting two related pilot projects. Council and subcommittee participants felt that
the subcommittee and Council relationship improved in the last two years of the initiative, but that
the Council added little value to the work of the subcommittees.
The ambiguity of the role of the Council was rooted in its origin. Since there was an
Administration limitation on creating new FACA committees at the time EPA initiated CSI, a
council with subcommittees was necessary rather than a series of sector-specific FACA
committees. But the subcommittees began meeting (in late 1994 and early 1995) several months
before the first meeting of the Council (May 1995), and the Council had difficulty defining a
unique role for itself.
EPA made an initial effort to improve the working relationship between the Council and the
subcommittees in 1996. In June 1996 the Council adopted revised operating principles for
reviewing work of the subcommittees which included a three-part framework under which
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Council reviews of subcommittee work would be tailored to the level of support required by the
subcommittee:
• a variety of information-sharing mechanisms to keep the Council informed
of the work of the subcommittees ("Framework A");
• mechanisms for dialogue and feedback between the Council and the
subcommittees on issues that are nearing the recommendation stage
("Framework B"); and
• more formal review of recommendations proposed to the Council, with a
range of consensus, minor modification, or no consensus decisions, and a
stipulation that the Council indicate to the subcommittee changes that
might make consensus possible.
A more comprehensive effort to define the Council's role and improve its operations was
undertaken following the creation of the Office of Reinvention (OR) in 1997. OR focused both
on:
• continuing to improve the relationship between the Council and
subcommittees, and
• directing the Council's efforts to assist the Agency on several cross-cutting
issues common to many of the subcommittees' efforts.15
OR worked with the Council to develop a broader framework for review of subcommittee efforts.
One aspect of OR's approach involved guidance from the Council to the subcommittees on the
stages for developing effective plans and recommendations, and the program elements
subcommittees should consider in the development of their projects and recommendations.16 The
other aspect (discussed previously) involved clarification of the concept of "consensus," using an
approach that provided greater flexibility in the application of the requirement for consensus.
Among the CSI participants we interviewed, those who were members of the Council (many of
whom were also subcommittee members) generally commented favorably on the efforts initiated
by OR—both on the fact that the Council now had a specific role, and on the smoother
relationship that had emerged with the subcommittees. Even these Council members, however,
15This ultimately led to the Council's work on Agency initiatives on environmental information,
stakeholder involvement, and future sector-based approaches.
16Memorandum from Lisa Lund (EPA Deputy Associate Administrator, Office of Reinvention) to CSI
Council Members (September 9, 1997); "Proposed Guidance from the Council to the Sectors: Key Elements of A
Sector Approach to Environmental Protection." (September 1997)
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often indicated that the real work of CSI was being done by the subcommittees, and the role of
the Council in that work was limited. Among CSI participants serving only on subcommittees,
there was some awareness of the changes at the Council level, but little feeling that it affected
subcommittee work, except in reducing lingering concerns about Council micromanagement.
Most indicated that their subcommittees operated fairly autonomously from the Council, and that
the Council provided little added value to their work.
SUCCESS IS TIED TO SENIOR LEADERSHIP AND LINKAGES WITH CORE
AGENCY PROGRAMS
Most participants felt that, for CSI to succeed, EPA must provide strong leadership, technical
support, and linkages of CSI initiatives to the Agency's core programs. In general, they felt that
the Agency's actual performance had been mixed. The 1997 SCG report had focused on the need
for continued or improved effort by EPA in two of these areas. Its recommendations called for:
• continued demonstration of commitment to CSI by the Administrator and
other senior managers; and
• clarification of linkages between CSI and the accomplishments and goals of
the enforcement office and of the program offices' statutory mandates.
Administrator Browner Leads by Example
For providing leadership of the mission of CSI, participants in every subcommittee lauded
Administrator Browner for such a bold, out-of-the-box experiment. Her demonstration of
leadership and her belief in the possibilities of CSI is what brought—and kept—many
stakeholders to the table. Her chairing of the Council convinced stakeholders that CSI was taken
seriously. Both from industry and environmental participants' perspectives, this commitment at
the highest political level of EPA was a strong motivator. As one stakeholder put it, when asked
what prevented her from leaving the table after numerous discouragements and setbacks, "I
figured if Carol could sit there, so could I."
Active Leadership in Subcommittees Pays-off
At the level of EPA leadership of the subcommittees, the perceived importance to participants of
EPA leadership was also clear. Participants noted that where senior management (Le., the
Assistant Administrator, Regional Administrator, and Deputy Assistant Administrator)
demonstrated leadership and were actively engaged in their CSI subcommittees, significant results
were more likely to be achieved. Subcommittees with less-involved cochairs experienced more
difficulties. It was especially critical to industry participants that EPA senior management be
visible and involved.
Metal Finishing and Printing were the two subcommittees where EPA leadership was most widely
noted and appreciated in our interviews. Participants commented, often without prompting, on
the crucial roles played by senior EPA political and career leaders in the successes of these two
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subcommittees. The key in both cases was described as the active leadership played by EPA
managers in working closely with participants at the most detailed kvel that helped them hammer
out key agreements. With respect to the Petroleum Refining Subcommittee, some members noted
that EPA senior managers had played a key leadership role in persuading industry participants to
stay at the table reorganizing the subcommittee and re-directing the subcommittee's efforts;
without that leadership, they felt the Petroleum Refining subcommittee would have ceased
operating similarly to the Automobile Manufacturing Subcommittee. By contrast, participants on
some other subcommittees felt, as the discussions became difficult or contentious, senior EPA
leadership waned; yet they felt this was exactly when the EPA leaders could have made the most
difference.
Some of the EPA staff and managers interviewed questioned whether it was appropriate for
participants to expect EPA to take a leadership role in the actual negotiation of agreements. They
noted that EPA was actually a stakeholder on the subcommittees as well, and that had EPA
presented its own agenda, it would have defeated the purpose of encouraging a multi-stakeholder
definition of the issues. But there were cases, particularly in the case of the Iron & Steel and
Petroleum Refining Subcommittees, where some members were looking for EPA to outline the
issues and present the range of possible solutions. The types of leadership envisioned by
stakeholders included forcing participants to find areas where they do agree as a means of
defining a sector agenda, and emphasizing the overriding preeminence of pollution prevention in
the subcommittee's work. Another version of the appropriate role was offered by one of the EPA
managers: "One of the things EPA should have been doing was to be the manager at the table:
let's get these pieces done and out to work on. You have to know when to push; let the group
find its own direction, but make sure there is a direction and something is getting done."
Trouble Linking to EPA's Core Programs
Several participants, particularly on the subcommittees that had struggled hardest and
unsuccessfully with addressing core regulatory issues, commented that EPA was never able to
effectively link its CSI initiative to the day-to-day regulatory business of the Agency. Several of
the EPA staff we interviewed also commented that the CSI initiative failed to get buy-in from
Agency regulatory staff, and in particular, that CSI efforts involved almost no career managers
from the core regulatory programs. While the creation of the Office of Reinvention was seen by
many as valuable in creating a home for CSI and other reinvention efforts, there was still concern
that EPA's leaders had been unable to define a strategy for Unking the CSI effort to ongoing
relevant media-program regulatory initiatives—particularly if the objective was to re-focus some
of the media program efforts into cross-media, sector-based approaches. As an example, some
participants noted that several of the subcommittees had tried to deal with similar air pollution
issues (New Source Review and Title V), but that no concerted CSI-wide effort had been made to
explore the possibility of sector-oriented approaches to some of those issues.
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Summary ofSCG and GAO Recommendations and EPA's Responses
Table 6 summarizes the discussion above on the various SCG and GAO recommendations and the
actions taken by EPA in response to the recommendations.17
Table 6: EPA Responses to Recommendations by SCG and GAO
Topic Area #1; Steps to Improve CSI
Recommendation
EPA Action
EPA should provide more leadership, guidance,
and clearer operating framework on expected
results and most useful types of projects and
recommendations. [SCG/GAO]
OR worked with the Council to define support needed by
EPA on cross-cutting issues on sector approach, information
and reporting, and stakeholder role. OR worked with
Council to develop guidance on "Key Elements of a Sector
Approach to Environmental Protection." EPA provided
leadership/direction in Metal Finishing and Printing
Subcommittees at time of report
EPA and Council need to clarify the role of the
Council with respect to subcommittees.[SCG]
"Key Elements" guidance used to better define the role of
the Council with respect to subcommittees. Built on
previously developed "ABC' approach to presentation of
subcommittee work to the Council.
EPA should modify or clarify use of "consensus"
concept. [SCG]
White paper on "consensus" issued in Fall 1997.
EPA should develop screening process for new
participants and guidelines for continued
participation. [SCG]
No systematic guidelines.
For new CSI sectors: EPA should examine
opportunities for and barriers to change prior to
selection and provide key technical training
where needed for participants prior to initiation.
[SCG]
Not applicable; no new CSI sectors.
EPA should require development of performance
measures to evaluate all levels of CSI, including
results-oriented performance measures to assess
how actions have led to measurable
environmental improvements. [SCG, GAO]
Council and four subcommittees developed performance
measures focused largely on activities and process. Two
subcommittees developed performance measures to evaluate
impacts (including environmental impacts) of projects.
17
Additional recommendations of the studies concerned performance measures, which are discussed
under Section II.
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Topic Area #2 Steps to Institutionalize Successful Elements of CSI
EPA should consider non-FACA approaches for
some sector objectives. [SCG]
EPA should continue to demonstrate commitment
of Administrator and other senior managers.
[SCG]
EPA should build additional management and
staff support for CSI, including dedicated
organizational unit to coordinate CSI with other
reinvention efforts. [SCG]
EPA should clarify linkages between CSI and the
accomplishments of the program offices' statutory
mandates. [SCG]
EPA should clarify connection between CSI and
enforcement [SCG]
There should be an increase of participation of
EPA Regional and state/local agencies.[SCG]
EPA developed the SBEP Action Plan with support of the
Council and concurrence of senior EPA management.
EPR2 was created through Computers & Electronics
Subcommittee as a non-FACA forum for recovery and
reuse of electronics components.
Both Administrator and several other senior officials
continued to play active roles in CSI.
EPA created OR. with major management and staff
commitment to CSI- Little development of new
commitment in other program offices.
No action.
No new action. The EPA Office of Enforcement and
Compliance had issued memoranda in 1995 on
relationship of enforcement efforts and CSI.
No new action overall. Some state programs involved in
pilots.
B.
Sector-related Factors
Multi-stakeholder, consensus-type factors played a significant rote in CSFs successes and
shortcomings. However, could CSI have worked equally well for all industry sectors had there
been no early process problems with the Council and subcommittees? What can we learn from
CSI regarding sector-related factors that could prove important to other sector-based efforts?
This section examines the characteristics of the industrial sectors involved in CSI and reviews how
these factors fostered or inhibited the work of various subcommittees. Based on the comments by
participants, and the experiences of the subcommittees, the following sector-related factors,
discussed below, stand out:
• typical firm size for the sector (Le., small versus big companies);
• participation of decision makers;
• incentives to negotiate;
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• regular access to EPA decision makers;
• history of stakeholder relationships; and
• level of up-front preparations in advance of CSI.
SECTORS WITH SMALLER FIRMS WERE MORE SUCCESSFUL, HOWEVER
SUCCESS FACTORS COULD BE APPLIED UNIVERSALLY
CSI worked best for sectors with a preponderance of smaller firms. However, the factors of
success for smaller-company sectors suggest that the right circumstances and setting can be
cultivated to promote a successful multi-stakeholder approach for sectors dominated by larger
firms.
Of the six CSI sector subcommittees:
• three were composed of industrial giants (Automobile Manufacturing, Iron
& Steel, and Petroleum Refining);
• one involved a mixture of giant and smaller firms in which the giants played
a stronger role (Computer & Electronics); and
• two were composed mainly—even in terms of economic output—of
smaller firms, but with some important larger companies (Printing and
Metal Finishing).
CSI participants generally agreed that the subcommittees most successful at meeting the broader
goals were the Metal Finishing Subcommittee and the Printing and Computer & Electronics
Subcommittees (which were moderately successful). The three large-company sectors were least
successful. So what accounts for the smaller company sectors' ability to undertake a CSI multi-
stakeholder exploration?
Participants suggested a number of factors, which, taken together, may provide part of the
explanation for why these smaller-company sectors were more successful:
• Participation of Decision-makers,
• Incentives to Negotiate,
• Lack of Regular Access to EPA, and
• History of Contentious Stakeholder Relationships.
Participation of Decision Makers
CSI participants noted the importance of having decision makers at the table—for industry,
government, and national NGO decision makers. Decision makers were visibly involved in the
subcommittees of the sectors with small firms (Metal Finishing and Printing). Stakeholders
commented on the value of relationship building among industry decision-makers and the fact that
key commitments could be made in workgroup and subcommittee meetings. The lack of senior
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government leadership at the subcommittee level affected the participation of senior industry
leadership, for example, the lack of industry decision maker participation was strongly noted in
two sectors—Iron & Steel and Automobile Manufacturing. In Iron & Steel, industry
representatives repeatedly had to confer with senior management on key decisions. In
Automobile Manufacturing, key national NGO environmental representatives were not at the table
but had a significant influence on their peers' reluctance to discuss New Source Review (Clean
Air Act) requirements, which was an important industry agenda item. In these two
subcommittees, the industry and environmental representatives at the table consulted with more
senior decision makers who were not at the table, and who also instructed their subordinates and
peers not to make particular agreements under discussion.
CSI's experience contrasts with efforts in the Netherlands, which achieved broad negotiated
agreements on sectoral approaches to achieving environmental goals with some large-company
sectors. One of the crucial early steps the Netherlands took with the first large-company sector
(the chemical industry) was to involve corporate CEOs in the first phases of the negotiations that
established the basic parameters for future discussions. Later, the more technical phases of the
negotiations were handled by environmental or other technical staff. Involving key industry
decision makers did not guarantee results (Netherlands' negotiations with the petroleum refining
sector failed), but was a necessary step where success was achieved.18
Pending Regulations as an Incentive to Negotiate
CSI participants described a sector's major incentives to negotiate as potentially including
pending regulations or the need for flexibility for business efficiency or competitive reasons.
Virtually all the sectors included in CSI faced significant future potential federal regulations. For
example, the large companies in five of the six sectors were interested in addressing New Source
Review issues under the Clean Air Act, metal finishing firms were concerned both with
Brownfields issues and the upcoming Metal Products and Machinery Effluent Guideline, and firms
in Computers & Electronics were looking for regulatory flexibility that would make it easier for
them to respond quickly in a rapidly changing, competitive market The only significant exception
may have been some of the smaller types of printing operations represented on the Printing
Subcommittee. But even those firms were concerned about permitting and reporting burdens and,
along with the companies of the other sectors, were interested in increasing flexibility and
reducing those burdens.
18 See Paul E. de Jongh, The Netherlands Approach to Environmental Policy Integration, prepared for
Enterprise for the Environment, Center for Strategic and International Studies, 19%; Robert Kerr, The
Netherlands Target-Group Covenants: Setting Priorities and Driving Changes, prepared for EPA/OSW, 1996.
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Lack of Regular Access to EPA
For the small-company sectors (e.g., Metal Finishing and Printing), participants indicated that
access to decision makers at EPA was a significant benefit of participating in CSI. They felt that
this provided a level of access that they did not have through other avenues. For the large-
company sectors, such access was also valuable—however, these sectors already have other
avenues through which to access EPA Examples of the other avenues of access to EPA large
companies typically enjoy include:
• participation on environmental advisory committees;
• direct access to the Administrator, and
• business lobbying of other key decision-makers in Congress or the
Administration.
The lack of regular access is an important issue. In the case of large-company sectors, there are
almost always ongoing, multi-stakeholder efforts at the Agency (e.g., the Clean Air Act Advisory
Committee) to address these industries concerns. Thus, as noted by several industry participants,
they saw CSI as one of many possible venues to meet their regulatory reform goals. If CSI had
turned out to be the only, or the major, venue for dealing with their particular sector-related
concerns on these regulatory agendas, it might have attracted greater large-company attention.
Since, as discussed previously, CSI did not succeed in addressing larger media regulatory issue
the large-company sectors continued to rely on their roles in those other venues.
issues,
History of Stakeholder Relationships
Interviewees noted that stakeholder relationships in CSI were more contentious for heavy-
polluting industries—defined as Iron & Steel, Petroleum Refining, Automobile Manufacturing,
and, to a lesser extent, Computers & Electronics—both historically and within CSI. These
sectors have far greater community and national environmental impacts than the two sectors with
more successful subcommittees (Metal Finishing and Printing), which were dominated by smaller
firms.
In conclusion, responses by the interviewees suggest that it is the combination of these factors
(participation of decision-makers, lack of regular access to EPA, and history of contentious
stakeholder relationships) that accounts for the importance of a small-company sector's success as
a subcommittee. Small company size thus seems to be one important indicator of the potential for
a sector to be involved in a successful broad exploration of new approaches, but the particular
circumstances of a sector are more important to consider.
Finally, several participants suggested an important caveat about sectors dominated by small
companies. They noted that, among small-company sectors, it was important to select sectors
(such as Metal Finishing and Printing) with strong industry networks and "associations which could
communicate and support new national initiatives.
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CAREFUL ANALYSIS OF SECTORS, PRIOR TO NEGOTIATIONS, PAYS OFF
It was also found that careful preparation and analytical work with a sector prior to multi-
stakeholder negotiations can help identify sectors with the greatest potential for developing and
supporting innovative approaches and facilitate successful negotiations. Several of those
interviewed, particularly participants on the Metal Finishing Subcommittee, suggested that a
critical pre-process step for effectively exploring innovative approaches to environmental
improvement in sectors may be to methodically explore the industrial and regulatory contexts of
the sector with potential stakeholders before starting negotiations. Prior to the beginning of CSI,
EPA and the Metal Finishing sector had been engaged, through EPA's SI program, hi an
extensive process of analysis and dialogue on potential future approaches to environmental
problems in the sector.
Work with the Metal Finishing sector began under SI in 1990. While this work involved
extensive technical studies of the sector, the central element involved getting industry and state
and federal regulators together to explore the industry's perceptions of its needs and the
expectations and objectives of the other stakeholders. While it is difficult to determine the degree
to which this prior groundwork was critical in establishing the basis for the sector's success under
CSI, many participants and EPA staff involved with the Metal Finishing Subcommittee
emphasized its importance. At the beginning of CSI, the principle of a tiered approach to the
industry based on environmental performance, had already been conceptualized. While the other
stakeholders in CSI (environmental groups, environmental justice, and labor) had not been
involved in the SI work, and there were major initial tensions as a result, the SI groundwork
provided a strong starting point Even though the Goals Agreement was a major new concept
that emerged from CSI, the understanding of perspectives on the regulatory and economic
contexts and perspectives developed during SI made it possible to move more quickly to identify
viable alternatives.
Interviewees also called attention to some previous groundwork in two of the other sectors,
Automobile Manufacturing and Printing. In both cases, however, they noted significant
limitations. The Automobile Manufacturing sector participated on the President's Council on
Sustainable Development (PCSD), and there had been initial discussions there of an alternative
performance-based approach to environmental management in the Automobile Manufacturing
industry, these discussions, however, did not involve either all of the industry or all of the
stakeholders. For the Printing sector, the Great Printers Project in several of the Great Lakes
states involved a voluntary, consensus-based, multi-stakeholder effort to combine incentives for
pollution prevention with reduced reporting burdens for lithographic printers. But lithographic
printing was only one of five of the printing sub-sectors involved in CSI, and the Great Printers
Project approach had little appeal for many of the larger printers in the other sub-sectors.
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COMBINED FACTORS CONTRIBUTE TO CSI SUCCESS
With respect to the six sectors that participated in CSI, it is difficult to pinpoint with precision
which specific sets of factors contributed most to their different levels of success in meeting the
goals of CSI, or to say with certainty the extent to which multi-stakeholder process issues and
sector-characteristic issues predominated. There is, however, some revealing information:
• The CSI sector generally regarded by stakeholders and EPA staff as most
successful (Metal Finishing): participated in previous sector analyses prior
to CSI; was facing both cleanup and water regulatory issues; comprises
largely smaller firms; and was described by interviewees as having one of
the most effectively managed multi-stakeholder processes, with strong
EPA leadership, participation of stakeholders who were decisionmakers,
and one of the less contentious histories of stakeholder relationships.
Some of the subcommittee participants also commented on the opportunity
for contact with EPA officials provided by CSI.
• The three sectors with predominantly large companies (Automobile
Manufacturing, Iron & Steel, and Petroleum Refining), which met only one
of the likely sector success-factors (incentive of pending regulations), were
described by participants as having less-successful process experiences.
Interviewees described the Automobile Manufacturing and Petroleum
Refining Subcommittees as having the most process problems: no initial
facilitation; slow development of groundruks; and strongly adversarial
histories between participants. While there are significant regulatory and
environmental concerns for both sectors, many participants had alternative
venues for presenting their concerns to EPA (e.g., other advisory
committees and regular direct contacts with EPA decision makers or
Congressional representatives). The Automobile Manufacturing
Subcommittee shut down early in 1997 with, from the perspectives of most
Subcommittee members interviewed, limited substantive results.
• Descriptions offered by Petroleum Refining Subcommittee participants for
the first two years of the subcommittee were similar to those of the
Automobile Manufacturing Subcommittee in many respects. A major
difference in interviewees' descriptions, however, was the strong EPA
leadership provided at the time the Petroleum Refining Subcommittee was
on the verge of closing down at the midway point in CSI. The strong EPA
leadership persuaded industry stakeholders to stay at the table, and led to
the reorganization of the subcommittee membership to involve participants
less weighted down by past conflicts. Iron & Steel Subcommittee
participants described a smoother experience initially with the multi-
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stakeholder process and with EPA leadership, and were able to generate
several significant results in the first two years, but were unable to continue
making progress when they tried to take on broader sector issues.
Participants noted the inability of stakeholders to 'leave their baggage at
the door" with respect to these broader issues, the existence of alternative
venues, and the fact that participants at the table were often unable to
negotiate agreements because decision makers not at the table vetoed ideas
that were being discussed by the Subcommittee.
Interviewees generally considered the Printing and Computers &
Electronics Subcommittees to have had some significant substantive
successes, though not at the level of the Metal Finishing Subcommittee and
the SGP. Participants described both the Printing and Computer &
Electronics Subcommittees as having some initial process problems, but
ultimately resolved them. The Printing sector was most similar to metal
finishing in terms of limited initial adversarial history, typical size of
companies, and previous stakeholder and analytic work involving the
sector (e.g.t Great Printers Project and EPA's Design for the
Environment). However, some of the participating printing sub-sectors
were composed of large firms with very different environmental and
regulatory concerns, and previous stakeholder and analytic work involving
the sector had focused on the smaller firms. Fewer Printing company
decision-makers were involved in the Printing Subcommittee, than on the
Metal Finishing Subcommittee, but most industry representatives from
large and small companies commented on the value of CSI in providing
contact with EPA decision makers and access to other venues for
discussing their concerns with the Agency.
The Computers & Electronics Subcommittee involved industry participants
that represented firms of widely divergent sizes and concerns.
Subcommittee participants indicated that this diversity affected various
workgroups differently. One Computer & Electronics workgroup, which
focused on overcoming a variety of specific problems (e.g., CRT recycling,
obscure regulations, recycling collection pilots, zero discharge), included
strong leadership by small companies. The workgroup on reporting (i.e.,
CURE and BOLDER) involved both large and small industry participants,
and a wide range of active state and local government representatives;
while there were conflicts over some issues on the scope and nature of the
information to be integrated/and required, past conflicts were not
predominant, and relevant decision makers for all parties were involved.
Participants described the workgroup on alternative strategies (worker
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health, studies of cancer rates, and constructive engagement) as most
dominated by large corporation and national NGO concerns, and most
hamstrung by preexisting adversarial positions.
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Section IV:
SUMMARY AND RECOMMENDATIONS
A. Summary
Initial expectations of the Common Sense Initiative were high. The program was launched with a
flourish of optimism. It promised, as Administrator Browner announced in July 1994, "a
fundamentally different system of environmental protection that replaces the pollutant-by-
pollutant approach of the past with an industry-by-industry approach of the future." It was
ambitious: six sectors covering a range of industries and business sizes, some fairly new sectors
such as Computers & Electronics, and other more traditional sectors like Iron & Steel and
Petroleum Refining. It was hampered by both design and process problems. "Great idea, poor
execution," was a comment often made by CSI stakeholder participants. Some of CSI's projects
may be very meaningful, while several are less than satisfactory, when compared to the original
concept of "fundamental change."
In the view of most of the stakeholders we interviewed, at least one sector produced a fairly
remarkable product, despite these limitations: Metal Finishing's SGP. In addition, many
stakeholders feel that at feast one other sector has developed an innovative project design, which,
when implemented, offers the opportunity for permitting reform, beyond-compliance
environmental improvements, and increased community involvement: Printing's PrintSTEP.
Participants on the Metal Finishing Subcommittee and to a lesser extent those on the Printing
Subcommittee, generally felt that their accomplishments could be said to be the first steps in the
beginning of "a fundamentally different system." But participants on these subcommittees, as
well as other CSI stakeholders, did not feel that they had successfully tackled fundamental
regulatory change. Essentially, in the case of the SGP, they felt that they successfully (for the
present) circumvented regulatory obstacles, but that the regulatory issues still remain to be dealt
with.
Two "alternative regulatory systems" were developed or recommended for EPA consideration,
one by the Automobile Manufacturing Subcommittee (Alternative Sector Regulatory System
Principles), the other by the Computers & Electronics Subcommittee (Performance Track
Program). Both of these products, while innovative, were presented to the Council at the
conceptual level and there was insufficient time for the subcommittees to form solid
recommendations and pilot them within CSI. Moreover, stakeholders perceive that these
projects may become dormant at EPA and that the core programs in the Agency are committed in
only the most limited way to the alternative systems conceptualized in these two efforts.
This CSI evaluation effort has documented findings that span a range of both successes and
failures of the Initiative. But two overall findings from the participant interviews stand out:
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1) CSI participants widely believe that consensus-based19, multi-stakeholder
collaboration can be a valuable policy development tool; and
2) Many participants feel that the inability of CSI to affect the regulatory regimes of
the participating sectors should not be viewed as a failure, but as a missed
opportunity. Participants feel that there was very little risk taking on the part of
EPA and other stakeholders in the area of regulatory change, and a lack of
coordination with ongoing, sector-relevant regulatory efforts in the media program
offices.
B. Recommendations
Although CSI has formally ended, there are a number of both new and continuing EPA sector
efforts, such as the SBEP Action Plan and continuing, voluntary, sector-oriented programs such
as SI and Design for the Environment (DfE). These efforts—it is hoped—will continue to pursue
multi-stakeholder collaborative approaches. Moreover, participants widely believe there are
opportunities for EPA to further test the use of this tool, to support regulation development at
EPA, and to support the work of states and local governments.
A wide range of stakeholders with otherwise diverse perspectives believe that EPA should view
CSI as a jumping off point for learning. They feel that the Agency should:
• provide recommendations;
• continue to test, support, and study multi-stakeholder approaches;
• provide rewards for EPA staff to support priority reinvention efforts;
• follow through on key CSI recommendations, projects, and ideas;
• build on existing capabilities in sector work, and support multi-stakeholder
"incubator programs;"
• assure early stakeholder involvement in policy dialogues focusing on
innovative solutions;
• track CSI spin-off activities and projects and perhaps formally study and
provide resource support to them as well; and
• provide regulatory and technical assistance to non-technical, non-
regulatory participants.
191.e., "Reasonable" consensus, as outlined in the EPA White Paper on Consensus, backed by good
operating groundrules, competent facilitation, fixed deadlines, and other process and execution improvements, as
described in the September 1997 Guidance to Subcommittees.
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CONTINUE TO TEST, SUPPORT, AND STUDY MULTI-STAKEHOLDER
APPROACHES
Support and further study multi-stakeholder, collaborative decision making as a tool, both within
the Agency and in the regions and states. One option might be to engage in reasonable risk
taking, for an appropriate sector, by experimenting with applying the multi-stakeholder
collaborative model as an alternative to the traditional Agency rulemaking process. In the
National Academy of Public Administrator's (NAPA) report, Resolving the Paradox of
Environmental Protection: An Agenda for Congress, EPA, and the States (September 1997), a
summary finding in the chapter on reinventing regulation, reads: "EPA's reinvention initiatives
have yet to change the bask programs or attitudes of the agency." The stakeholders and EPA
staff we interviewed also felt that EPA's core work of developing regulations and managing the
nation's compliance and enforcement system has been little touched by CSI. They noted that
unless the career managers and rulemaking staff at EPA are more involved in, and held
accountable for, contributing to overall reinvention, no fundamental change can occur. Some
interviewees suggested identifying a rulemaking (or set of rulemakings) for an appropriate sector
(one which had already gone through an "incubator" process) and the multi-stakeholder
collaborative approach in developing new sector objectives and requirements, rather than the
traditional rulemaking process.
PROVIDE REWARDS FOR EPA STAFF TO SUPPORT PRIORITY REINVENTION
EFFORTS
Stakeholders and EPA staff were concerned that (outside the OR) there were substantial
disincentives and few rewards for most Agency staff to support CSI. We heard frequent
comments that staff had to "steal" time from their "real" work to support CSI, that work on CSI
was "not a career builder," and that it was not taken into account in performance evaluations by
managers for whom it was anything but a priority. All stakeholders were concerned that this issue
must be addressed to achieve meaningful integration of reinvention initiatives into core Agency
programs. EPA staff and state stakeholders, particularly, suggested that a number of critical
measures be considered, such as clear inclusion of priority reinvention activities in the
performance evaluation criteria for managers and staff, clearly defined budget support within core
programs for those efforts, and priority consideration for awards to staff (both from the
Administrator and from program managers).
FOLLOW THROUGH ON KEY CSI RECOMMENDATIONS, PROJECTS, AND IDEAS
Interviewees were insistent on the importance of follow through on major CSI recommendations
and projects. One industry participant on the Printing Subcommittee, when asked whether CSI
was worth the effort he and other stakeholders had put into it, replied that if PrintSTEP were
implemented, the time and resource drain was a drop in the bucket; if not, it was a colossal waste
of time. In less dramatic, but equally emphatic terms, we heard the same message from the vast
majority of the most committed participants. Many were concerned aboufthe likelihood of follow
through due to the transition from CSI to a less visible venue (even for those sectors carried over
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into NACEPT), particularly given the challenges CSI has faced in institutionalizing changes.
There is some doubt about even the most visible CSI efforts (e.g., SGP, PrintSTEP, and CURE),
and more concern about the others. Minimally, most stakeholders would like to see a clear
delineation of responsibility and accountability for outstanding CSI recommendations and
projects, as well as a clear statement of any Agency decisions that particular projects are not
priorities for follow through.
BUILD ON EXISTING CAPABILITIES IN SECTOR WORK AND THE SUPPORT OF
MULTI-STAKEHOLDER "INCUBATOR PROGRAMS"
Metal Finishing Subcommittee participants believe that the SI program has demonstrated its value
in providing a foundation on which the SGP could be built during CSI. SI is also working with a
number of other sectors (e.g., the NJ Batch Chemical Sector Project). SI is well respected by
industry and most other stakeholder groups. There are also programs such as Design for the
Environment which have provided technically oriented support to sectors. Focusing adequate
resources on EPA sector-oriented programs, and linking them effectively to Agency core media
programs, was an area in which interviewees expressed considerable concern. Interviewees who
raised this concern were asked their perspectives on the extent to which SBEP addressed their
concerns. In general, non-governmental stakeholders were usually uncertain, often feeling that
they lacked adequate understanding of Agency operations. State and local stakeholders generally
felt that the adequacy of SBEP depended entirely on how it was connected to the Agency's
budgeting process. EPA interviewees from media program and regional offices who were
supportive of sector-based approaches were concerned that SBEP largely collated existing
Agency efforts, and might not prove to be a budgetary driver for further integration of sector-
based approaches; they felt that active Agency management leadership would be necessary to
make the SBEP a strong basis for sector-oriented initiatives.
ASSURE EARLY STAKEHOLDER INVOLVEMENT IN POLICY DIALOGUES FOR
FOCUSING ON INNOVATIVE SOLUTIONS
Stakeholders who believed they worked on innovative CSI projects emphasized that one of the
most valuable aspects of the Common Sense Initiative was the active engagement of all
stakeholders in negotiations. In particular, the most fruitful negotiations began with a discussion
of which problems were most important to address and the range of possible answers to those
problems. This up-front involvement of a wide range of stakeholders in identifying issues and
solutions resulted in some of the most creative CSI products. While the Stakeholder Involvement
Action Plan, the SBEP Action Plan, and the NACEPT Sector Standing Committee address the
continuing importance of stakeholder involvement, many stakeholders stressed that it is especially
important to emphasize that EPA needs to include an up-front, formative role for multi-
stakeholder consensus processes to help identify issues and policy options.
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TRACK CSI SPIN-OFF ACTIVITIES AND PROJECTS, AND PERHAPS FORMALLY
STUDY AND PROVIDE RESOURCE SUPPORT TO THEM AS WELL
The Agency needs to pursue information on spin-offs, links, stakeholder contact networks, etc.,
to better understand ways in which multi-stakeholder collaborative projects have worked outside
of the FACA constraints of CSI. Part of EPA's objective in CSI was to foster culture change.
Many stakeholders feel it is important to track this—both with sectors that "succeeded" and
"failed"—in order to understand long-term ramifications.
PROVIDE TECHNICAL AND REGULATORY EDUCATION TO NON-INDUSTRY,
NON-REGULATORY PARTICIPANTS
Environmental NGO and environmental justice representatives stressed that such educational
support is crucial to creating a better process and more-even playing field in multi-stakeholder
negotiations. Environmental justice representatives and environmental groups often deal with
broad issues of environmental protection and are not necessarily sector-savvy, nor familiar with
the often technical details of specific sector regulations and of the complex interrelationships
among national, state, and local government regulatory programs.
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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LIST OF ACRONYMS
3R Reporting & Recordkeeping Requirements Inventory
BOLDER Basic On-line Disaster and Emergency Response
CLEAN-P2 Compliance Leadership through Enforcement, Auditing and Negotiation
CRT Cathode Ray Tube (recycling project)
CSI Common Sense Initiative
CURE Consolidated Uniform Report for the Environment
DfE Design for the Environment
DFO Designated Federal Officers
EAF Electric Arc Furnace
EPR2 Electronics Products Recovery and Recycling Roundtable
F006 Metal Plating Waste Water Sludge
GAO General Accounting Office
HAP Hazardous Air Pollutant
LCM Life-Cycle Management
MACT Maximum Achievable Control Technology
NACEPT National Advisory Committee for Environmental Policy and Technology
NGO Non-Governmental Organization (generally refers to non-profits)
NMRC National Metal Finishing Resource Center
MP&M Metal Products and Machinery Effluent Guideline
NSR New Source Review (Clean Air Act)
NSPS New Source Performance Standards
OEC A Office of Enforcement and Compliance Assurance
P2 Pollution Prevention
PERRL Prototype Reporting and Resource Link
POTW Publicly Owned Treatment Works
PrintSTEP Printing Simplified Total Environmental Partnership
RAIRS Refinery Air Information Reporting System
REI Reinventing Environmental Information
RCRA Resource Conservation and Recovery Act
ROTE Regulatory Information Inventory Team Evaluation
SBEP Sector-Based Environmental Protection Action Plan
SCG Scientific Consulting Group
SEP Supplemental Environmental Project
SI Stakeholder Involvement Action Plan
SI Sustainable Industry Program
TRI Toxics Release Inventory
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APPENDICES
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APPENDIX 1: Methodology
The distinctive features of the Common Sense Initiative included its sector orientation and its use
of multi-stakeholder, consensus-based negotiations to develop "cleaner, cheaper, and smarter"
environmental management solutions. In assessing the benefits of the multiple features and
combined effect of the Initiative, this evaluation is stakeholder-driven; stakeholder perceptions
regarding the value and innovative nature of CSI provide the raw material for the evaluation. The
evaluation is based on an interview approach, supplemented by document review and attendance
of CSI meetings. The evaluation also employed a focus group of key CSI participants to serve as
resources at the outset of the study.
1. Documents, Reports and CSI Meetings
KGAA reviewed both the extensive documentary record of the Common Sense Initiative and
some of external reviews and discussions of CSI as a step in defining the issues and detailing the
outcomes of CSI. Documents reviewed included subcommittee and Council reports, analyses,
recommendations, project designs, process-related guidance, performance measures and other
documents and meeting minutes of the Council and subcommittees. In addition, KGAA reviewed
external reports and articles on CSI. As discussed above, this specifically included looking at the
mid-CSI evaluations by SCO and GAO for information on CSI issues, concerns, and progress
through early 1997, and as a baseline of recommendations against which to compare subsequent
changes in CSI.20
During the course of the research, KGAA also attended CSI Council and subcommittee meetings.
These included:
• Council meetings on October 15, 1998 and December 17, 1998;
• a meeting of the Printing Subcommittee on December 2-3, 1998; and
• a meeting of the Petroleum Refining Subcommittee on December 10-11,1998.
2. Interviews and Focus Group
KGAA initially interviewed EPA staff who were highly involved in CSI. KGAA sought to
interview a mix of staff including some who had been involved during the initial phase of CSI,
some involved over the entire four years, and some involved only more recently (e.g., since the
creation of OR). We also had a few preliminary interviews with some non-EPA CSI participants.
The purpose of these initial interviews was to provide KGAA with additional information on:
A list of relevant documents and reports is in Appendix 2: Sources Consulted.
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• background and perspectives on workgroup, subcommittee, and Council processes
and how they evolved over time;
• the development and implementation of specific CSI projects, recommendations,
and other accomplishments (both direct and indirect); and
• identification of possible Council or subcommittee members to participate in a
preliminary focus group.
KGAA conducted a telephone focus group with eight non-EPA CSI participants in November
1998. The purpose of the focus group was to gain a broad perspective on the evolution of CSI
and to collect information that would help refine the data collection strategy and interview scripts.
In addition, KGAA sought advice on potential stakeholders to contact during the evaluation.
Using the information from the literature review, initial interviews, and focus group, KGAA
developed a set of interview guides—one tailored specifically for each of the six subcommittees, a
seventh for the CSI Council, and some additional questions for specific stakeholder groups,
facilitators, and EPA staff and managers.21 Questions posed during interviews by KGAA fell into
nine categories:
• Goals/expectations for CSI,
• Participants/roles,
• CSI organization/structure,
• Relationships,
• EPA rok,
• Accomplishments/shortcomings,
Effects outside of CSI,
• Decision-making processes/ownership of outcomes, and
• Lessons learned/next steps.
Through conversations with EPA representatives, focus group participants, and initial sector calls,
KGAA developed a list representing industry, labor, environmental group, environmental justice,
and state or local stakeholders from the six subcommittees and the Council Since EPA was also
a stakeholder in the process, KGAA interviewed numerous EPA staff and managers; these were
divided between senior managers who participated on or chaired subcommittees and the Council,
Designated Federal Officers (DFOs) for the Council and subcommittees, and the EPA staff who
provided technical support to the subcommittees. KGAA also interviewed several of the
independent facilitators for the CSI process.
1 See Appendix 5 for lists of questions.
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The following tables show the total number of participants in each stakeholder group, including
Council members who did not serve on any of the subcommittees, and the total number of
stakeholders by subcommittee, including those who were interviewed because of their roles on the
Council or their perspectives on specific stakeholder issues. For purposes of these tables, EPA
stakeholders include only DFOs and senior managers who were formally CSI participants, since
these were the EPA participants with the most direct responsibility for EPA's role on the Council
and subcommittee. Including both those serving exclusively on the Council and those also serving
on subcommittees, 21 Council members and DFOs were interviewed.22
Table 1: Interviewees by Stakeholder Group
Stakeholder
Environmental Justice
Environmental NGOs
EPA
Industry
Labor
State/Local
No.
5
13
19
26
4
17
^Since some CSI participants served only on the Council, and some EPA participants changed
subcommittees, the subcommittee totals and stakeholder totals are not the same.
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Table 2: Interviewees by Sector Subcommittee
Subcommittee
Automobile Manufacturing
Computers & Electronics
Iron & Steel
Metal Finishing
Petroleum Refining
Printing
No.
12
12
13
12
13
17
In addition to these stakeholders, KGAA also interviewed four of the independent CSI
facilitators, and 18 additional EPA staff who played a variety of technical and management roles
in support of CSI, for a total of 106 interviewees. (See Appendix 4 for a complete list of those
interviewed.)
3. Data Analysis and Limitations
Analysis
Interview data was collated by stakeholder group and sector or Council, and information was
developed on the issues relevant to the sectors and stakeholders in terms of the issue areas
developed through the questions. After the information from stakeholders and other interviewees
was analyzed for sector findings, sector results were combined to identify cross-sector trends,
success factors, and limiting factors.
Limitations
The interview data has not been analyzed on a statistical basis, nor would it have been meaningful
to do so with small samples by either stakeholder group or sector. Since Office of Management
and Budget approval was not obtained for use of a formal survey instrument, the interviews
followed a general interview guide, varied by subcommittee and stakeholder group, and obtained
qualitative information. In addition, the selection of those to be interviewed was not done on a
random basis.
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APPENDIX 2: WORKS CONSULTED
Administrative Conference of the US Dispute Systems Design Working Group. (1995 March).
Evaluating ADR Programs: A Handbook for Federal Agencies.
Andress, CaroL (1998 Autumn). P2 Collaboration: Lessons From the Great Printers Project.
Pollution Prevention Review.
Canadian Round Tables. (1993 August). Building Consensus for a Sustainable Future: Guiding
Principles.
EPA Common Sense Initiative Council Stakeholder Involvement Work Group Report.
EPA, Office of the Administrator. (1997 October). Reinventing Environmental Protection: The
Strategic Goals Program for Metal Finishing. EPA100-F-97-004.
EPA, Office of Reinvention. (1998 December). Lessons Learned About Protecting the
Environment in Common Sense, Cost-Effective Ways. EPA100-R-98-011.
EPA, Office of Solid Waste. (1999 February). Proposed Rule Aims to Promote Metals Recovery
from Waste Treatment Sludge (F006). EPA530-F-99-009.
General Accounting Office. (1997 July). EPA's Common Sense Initiative Needs an Improved
Operating Framework and Progress Measures. RCED-97-164.
ICF Kaiser. (1998 December). Compressor Seal Controls and Costs. Final Report.
ICF Kaiser. (1998 December). Compendium of Sensing Technologies to Detect and Measure
VOCs and HAPs in the Air. Draft Final Report.
ICF Kaiser. Development of a Straw Alternative Work/Monitoring Practices Program. Draft for
Refining Subcommittee.
ICF Kaiser. (1998 December). Rupture Disks/Costs Report. Draft Final Report.
Kerwin, Cornelius and Langbein, Laura. (1995 September). An Evaluation of Negotiated
Rulemaking at the Environmental Protection Agency, Phase I.
Keystone Center. (1997 May). Regulatory Reinvention Assessment: Summary of Stakeholder
Comments. Prepared for U.S. EPA, Regulatory Reinvention Team.
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Langbein, Laura I. and Kerwin, Cornelius. (1997 November 20). Regulatory Negotiation Versus
Conventional Rulemaldng: Claims, Counter-Claims, and Empirical Evidence,
National Academy of Public Administration. (1997 September). Resolving the Paradox of
Environmental Protection.
National Academy of Public Administration. (1995 April). Setting Priorities, Getting Results: A
New Direction for the Environmental Protection Agency.
Otis, Andrew. (1998 Summer). EPA's Metal Finishing Strategic Goals Program: Sector-Based
Environmental Protection. Pollution Prevention Review.
Pritzker, David M. and Dalton, Deborah S. (1995 September). Negotiated Rulemaking
Sourcebook.
Scientific Consulting Group. (1997 February 18). Review of the Common Sense Initiative.
Prepared for U.S. EPA, Regulatory Reinvention Team.
Society of Professionals in Dispute Resolution. (1997 January). Best Practices for Government
Agencies: Guidelines for Using Collaborative Agreement-Seeking Process.
CSI C&E Sector Report. Accomplishments and Lessons Learned from a Multi-Stakeholder
Sector-Based Effort: The Final Report of the Computer & Electronics Sector Common Sense
Initiative. EPA PUB#743-R-98-001. Draft #1.
CSI Automobile Manufacturing Sector Document Alternative Sector Regulatory
System/Community Technical Assistance Project Team. Final and Support Documents.
Background Briefing Materials on the Data Gaps Strategy for the CSI Council. (1998 October
15).
CSI Iron & Steel Sector Document Brownfields Work Group Guiding Principles.
CSI Iron & Steel Sector Document. Brownfields Work Group Notebook. (1997 May).
Charge for the Standing Committee on Sectors of the National Advisory Council for
Environmental Policy and Technology. EPA. (1998 December).
PrintSTEP Pilot Program. Community Handbook Template. CSI Printing Sector. (1998
November).
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"Consensus Decision Making Principles and Applications in the EPA Common Sense Initiative"
(1997 October 1) White Paper prepared for the CSI Council
"Data Quality Strategic Plan" (Draft) (1998 October 15) CSI Council
"EPA Stakeholder Involvement Action Plan" (1998 December) Presented to CSI Council
"Instruction Manual for EPA Regions, States, and POTWs: Recommended First Steps in
Implementing the Strategic Goals Program" CSI Metal Finishing Sector Document.
CSI Metal Finishing Sector Document Lessons Learned and New Project Guidance: Developing
a Flexible Track System for Top Environmental Performers (1998 July).
CSI Sector Document Life-Cycle Management/Supplier Partnerships Project Team:
Conclusions Document. (1997 March 27).
CSI Automobile Manufacturing Sector Document Life-Cycle Management/Supplier Partnership
Project Team (Final and Support Documents).
Meeting Minutes for the CSI Council and Sector Subcommittees, 1995-1998. (Many available at
www. epa.gov/csi).
CSI Printing Sector New York City Education Project, Summary and Assessment Report.
CSI Refining Sector document (1998 December) One-Stop Reporting and Public Access
Project, Development of a Sector-Based Air Emission Reporting System Draft Report.
CSI Refining Sector Document Petroleum Refining Subcommittee Lessons Learned (1998
December) Presentation to Council
CSI Iron & Steel Sector Document Permit Issues and Recommendations.
CSI Printing Sector (1998 November) Plain Language Workbook Template.
CSI Metal Finishing Sector Document (1997 August 22) Putting the Pieces Together in 1997:
Strategic Goals Program Summary Materials.
CSI Automobile Manufacturing Sector Document Regulatory Initiative Project Mass Per Unit
Area Summary Report and Recommendations.
Presented to CSI Council (1998 December) Sector Based Environmental Protection Action Plan.
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CSI Printing Sector (1998 June 30) State Guide to PrintSTER.
CSI Metal Finishing Sector Document (1997 December 16) Strategic Goals Program: National
Performance Goals and Action Plan.
CSI Council (1998 December 15) Summary and Status of Performance Measures.
CSI Automobile Manufacturing Sector Document (1997 July 15) US Automobile Assembly
Plants and Their Communities.
CSI Metal Finishing Sector Document (1998 September) Workgroup Report: F006
Benchmarking Study.
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APPENDIX 3: PROJECT SUMMARY
Project
Autos
Life Cycle
Management
Regulatory
Initiatives
Auto Plant
Community
Economic,
Demographic and
Environmental
Profile
Alternative Sector
Regulatory System
Principles and
Progress '
CSI
Recommendation
yes
yes
yes
no
but several consensus
documents
Implementation
Status
inactive;
leads are OPPTS/OR
active (?)
OAQPS
inactive
CEIS
OR
CSI Program
Elements
pollution
prevention
regulation
involving
communities
regulation
Midpoint
Changes (Dec
96)
somewhat, flurry
of activity as auto
shutdown Spring
97
see above
see above
see above
Addressing
Larger/more
controversial
Issues
somewhat large --
most innovative
Auto product
very small
community based
environmental
protection - unique
data tool, no further
work known
large issues but a
conceptual
document
Rule changes
or Guidance
changes
no
yes - possibly but
the
recommendation is
very meager
no
no
Direct
Environmental
Results
could indirectly lead
to results
no
no
no
Performance
Measures
not a ware of any
not aware of any
not aware of any
not aware of any
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Project
Computers &
Electronics
Product
Stewardship
• EPR2
• Collection
Pilots
CRT Recycling
Barriers to
Closed-loop Water
Recycling
Public Access
BOLDER
CSI
Recommendation
no
no
yes
yes
yes
yes
Implementation
Status
active
completed
active
OSW
active
OW
active
OECA
Active
Regions 9 & 6
OPPTS
CSI Program
Elements
P2, future issues
P2, involving
communities
regulation
regulation
environmental
technology
permitting
record keeping
and repotting
Record Keeping
and Reporting
Midpoint
Changes (Dec
96)
held conferences
completed pilots
and evaluation
yes
significant
progress
yes
significant
progress
no
significant -
pilots in 2 states.
plans for better
BOLDER
Addressing
Larger/more
controversial
Issues
medium, a start at
big future issues
mediumyes
potentially large
small
medium to smalt
Rule changes
or Guidance
changes
no
yesyes
measure CRT
recycle potential
potentially yes
no
rather coordination
of policies
no
Direct
Environmental
Results
yes
but difficult to
measure
conceptually yes
no
indirectly yes
Performance
Measures
yes
evaluated
collection pilot
results '
somewhat
examined media
transfers and P2
implications in
study.
EPA has
identified metrics:
i.e., the number of
policies that need
clarification
yes, paper work
reduction, others
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Project
CURE
Worker Health
Alternative
Regulatory System
• Principles
• Performance
Track
• Constructive
Engagement
• Worker
Health
CSI
Recommendation
yes
yes
yes
yes
yes
yes
Iron and Steel
Brownfields
Supplemental
Environmental
Projects (SEPS) and
Redevelopment
Consolidated Multi-
media Reporting
no
draft recommendations to
council for comments.
but not finalized
no
no
Implementation
Status
active
OPPTS
active
OPPTS
active
OR
OPPTS
active pilots in Indiana and
Alabama
compliance and
Enforcement
CSI Program
Elements
record keeping
and reporting
?
regulation
regulation
community inv.
future issues
involving
communities
low
record keeping
and reporting
Midpoint
Changes (Dec
96)
significant, pilot
in TX, resolved
data issues
significant
progress on the
last three bullets
in the last year of
CSI. The
principles were
completed in '96
Addressing
Larger/more
controversial
Issues
potentially large
small
large but
conceptual
low
medium
Rule changes
or Guidance
changes
somewhat decided
to drop some data
elements
no
no
Direct
Environmental
Results
no
no
not in its current
conceptual state
Performance
Measures
yes
no
no
if implemented
would have
measured
transaction costs
by industry and
state agency
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Project
Alternate
Compliance Strategy
SEPs and Improved
Compliance
Iron and Steel Web
Sites
Iron and Steel
Liaisons
Regulatory Barriers
Pilot
Steel Pickle Liquor
Workshop
Permit Issues
CSI
Recommendation
no
no
yes
yes
recommendations on
stakeholder involvement
in rules
no
yes
series of 12 permitting
recommendations
Implementation
Status
liaisons established at HQ
and Region V. Part of
Sector Based Action Plan
included in analytical
blueprint for rule making
white paper by EPA OSW
pending
included in Permit Reform
Action Plan
CSI Program
Elements
compliance and
enforcement
compliance and
enforcement
environmental
technology,
involving
communities
regulation,
involving
communities
regulation
permitting
Midpoint
Changes (Dec
96)
initiated before
Dec. 96 formal
recommenda-tion
in Feb 97
Addressing
Larger/more
controversial
Issues
high
low
low
low
medium
medium
medium
Rule changes
or Guidance
changes
Direct
Environmental
Results
Performance
Measures
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Project
Multi-Media
Permitting
Community
Advisory Committee
Compliance Data
Monitoring
Substantial
Compliance
Code of Conduct
CSI
Recommendation
no
no
no
no
no
no
Implementation
Status
active pilot at Bethlehem
Steel Burns Harbor,
Indiana
EPA OECA revising draft
report
rule revision adopted to
amend NSPS requirements
for monitoring internal
furnace pressure
CSI Program
Elements
permitting,
pollution
prevention
involving
communities
compliance and
enforcement
regulations
initiated after Dec
1996.
compliance and
enforcement
involving
communities
Midpoint
Changes (Dec
96)
initiated prior to
Dec. 1996 first
draft report in
March 97
low
rule revision to
amend NSPS
requirements for
monitoring
internal furnace
pressure
initiated and
ended after Dec.
1996
initiated and
ended after Dec.
1996
Addressing
Larger/more
controversial
Issues
high
low
low
low
low
Rule changes
or Guidance
changes
Direct
Environmental
Results
pollution prevention
reductions identified
in pollution
prevention plan
Performance
Measures
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Project
Metal Finishing
Strategic Goals
Program
CSI
Recommendation
yes
Implementation
Status
well underway
National goals agreement
signed. 250+ companies.
17 states. 34 POTWs.
Mini Goals Programs in
10 areas across the
country. Key ones
underway in Chicago,
LA, NY.
CSI Program
Elements
all
Midpoint
Changes (Dec
96)
yes
Addressing
Larger/more
controversial
Issues
large small and in-
between.
Rule changes
or Guidance
changes
Federal level:
FOO6 storage rule
(definite); F006
delisting
(possible); input to
the MP&M
effluent guideline.
Direct
Environmental
Results
yes
Performance
Measures
voluntary
achievement of
12 goals,
including 90%
reduction in TR1
emissions, 50%
reduction in land
disposal of
hazardous
sludge, etc.
Petroleum
Refining
Equipment Leaks
Workgroup
Refinery Air
Information
System (RAIRS)
Refinery
Accidental
Release ,
Information
Communication
Workgroup
yes
no
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Project
Printing
PrintSTEP
New York City
Education Project
CSI
Recommendation
no
no
Implementation
Status
EPA seeking 3-5 states to
undertake 3- year pilot
projects
project handed off to EPA
Region 2
CSI Program
Elements
1- stop notifi-
cation/agree-
ment for permits
(w. goal of single
permit)
•flexibility for
operational
changes
•Community
participation
•PI incentives
multistake-holder
pilot for
providing P2&
compliance
assistance to
small printers.
Outreach effort
uses community
groups.
Midpoint
Changes {Dec
96)
almost all design
work; design
com-pleted
12/98if success-
fully
implemented,
potentially broad
impact on
environ-mental
performance in
the printing
sector.
design & initial
implementation
through 1996.
community based
outreach began
in 1997.
Addressing
Larger/more
controversial
Issues
Rule changes
or Guidance
changes
Direct
Environmental
Results
noprojected
reductions in
environmental
releases by
participating
printers.
potentially
innovative pilot
design for
technical
assistance
performance
measures designed
to account for
behavioral
changes &
environ-mental
impacts during
pilots.
no
Performance
Measures
no
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APPENDIX 4: INTERVIEWS
Council and Subcommittee Participants Interviewed
(Includes EPA Senior Managers and DFOs)
Name/Affiliation
Jeff Adrian, The John Roberts Company
Carol Andress, Environmental Defense Fund
Guy Aydlett, Hampton Roads Sanitation District
Kathleen Bailey, EPA, DFO
Bob Banks, Sun Company
Dan Bartosh, Texas Instruments
Bob Benson, EPA DFO
John Bowser, EPA DFO
Gina Bushong, EPA, DFO
Diane Cameron, Natural Resources Defense Council
Doreen Carey, City of Gary
David Carlson, Chrysler
Robert Collin, University of Oregon
Andy Comai, United Automobile Workers
Todd Crawford, Missouri Dept of Natural
Resources, Division of Environmental Quality
Lisa Doer, Citizens for a Better Environment
Kerry Drake, TNRCC
Lois Epstein, Environmental Defense Fund
Brock Evans, Endangered Species
Charles Fox, EPA AA, Office of Water
Jeanne Fox, EPA RA, Region H, Co-Chair
George Frantz, Mass. Office of Environmental
Affairs
Ken Geiser, TURI, University of Mass
David Gardiner, EPA, AA, Office of Policy
Prudence Goforth, EPA DFO & former CSI Dep.
Dir.
Charles Griffith, ECAA
John Glenn, Louisiana DEQ
Frank Grimes, USW
John Hamilton, Indiana Dept of Envir Mgmt
Council
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Sector
Printing
Printing
Metal Finishing
Petroleum Refining
Computer & Electronics
Metal Finishing
Computer & Electronics
Printing/C&E
Metal Finishing
Iron & Steel
Automotive
Printing
Metal Finishing
Printing
Automotive
Printing
Petroleum Refining
Iron & Steel
Printing
Printing
Computer & Electronics
Metal Finishing
Automotive
Petroleum Refining
Iron & Steel
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Russ Harding, Michigan DEQ
Judy Hecht, EPA Office of Water, Alternate DFO
John lannotti, NY State Dept of Env Conservation
David Isaacs, Electronic Industries Association
Hazel Johnson, People for Community Recovery
Gary Jones, Graphic Arts Technical Foundation
Walter Jones, International Brotherhood of
Teamsters
Date Kalina, RR Donnelley and Sons, Co.
Vicki Keenan, Association of Graphic
Communications
Marci Kinter, Screenprinting and Graphic Imaging
Association
Rich Lahiere, Honda
Jessica Landman, Natural Resources Defense
Council (representative for John Adams & served on
workgroups)
Jeff Lo wry, Environmental Control and Laboratory
Techenglas
Mark Mahoney, EPA Reg. 1, Alt DFO
David Marsh, Marsh Plating Corporation
Keith Mason, EPA, Alternate DFO
Terry McManus, Intel
Bob McBride, A. C. Plating
Stuart McMichaeL, Custom Print, Inc.
Stan Meiberg, EPA DRA, Region IV
Ed Meyer, Minn. Pollution Control Agency
Kevin Mills, EDF
Frank Mirer, United Auto Workers
Robin Morris Collin, University of Oregon
Andrew Neblett, TNRCC
Dianne Nielson, Utah DEQ
Tim O'Brien, Ford
Robert Perciasepe, EPA, AA, Office of Air and
Radiation
Mike Peters, Structural Metals
Bob Phillips, GM
Mahesh Podar, EPA Office of Water, DFO
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Automotive
Iron & Steel
Metal Finishing
Computer & Electronics
Printing
Printing
Printing
Printing
Printing
Automotive
Computer & Electronics
Metal Finishing/C&E
Metal Finishing
Automotive
Computer & Electronics
Metal Finishing
Printing
Automotive/Refining
Printing
Automotive
Automotive
Printing
Computer & Electronics
Automotive
Iron & Steel
Iron & Steel
Automotive
Iron & Steel
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Alan Powell, EPA Region IV, DFO
Bowdin Quinn, Grand Calumet Task Force
Wayne Raush, Shell Oil
Charlotte Read, Save the Dunes
Rick Reibstein, Mass Office of Technical Assistance
Chris Rhodes, Institute for Interconnecting and
Packaging Electronic Circuits
Margie Richard, Deep South Center for
Environmental Justice
William Riley, Bethlehem Steel
Steve Rowley, NUCOR Steel
Bill Saas, Taskem, Inc.
Ted Smith, Silicon Valley Toxics Coalition
Velma Smith, Friends of the Earth
Bill Sonntag, National Association of Metal Finishers
Steve Souders, EPA Alt DFO
Mike Stahl, EPA OECA AA,
Wilma Subra, Louisiana Environmental Action
Network
Steve Thompson, Oklahoma DEQ
Dave Ulrich, EPA DRA, Region V
Frank Villalobos, Barris Planners Inc.
Stoney Vining, Marathon
Craig Weeks, EPA DFO
Gordon Wegwart, Minnesota Pollution Control
Agency
David Yetter. Texaco, Inc.
Ken Zarker. TNRCC
Yes
Automotive
Petroleum Refining
Petroleum Refining
Iron & Steel
Computer & Electronics
Computer & Electronics
Petroleum Refining
Iron & Steel
Iron & Steel
Metal Finishing
Computer & Electronics
Iron & Steel
Metal Finishing
Petroleum Refining
Printing
Petroleum Refining
Petroleum Refining
Iron & Steel
Metal Finishing
Petroleum Refining
Petroleum Refining
Iron & Steel
Petroleum Refining
Petroleum Refining
Other EPA Staff Interviewed
Name/Affiliation
Sector
John Alter, EPA OPPTS
Computer & Electronics
Warren Beer, EPA Region DC
Computers & Electronics
Deborah Craig, EPA, Region II
Printing
Vivian Daub, EPA, Former CSI Director
Jim Durham, EPA RTP
Petroleum'Refining
Ken Garing, EPA NEIC
Petroleum Refining
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Dave Jones, EPA Region DC
Carol Kemker, EPA Region IV
Lisa Lund, Dep. Associate Administrator, OR
Dave Markwordt, EPA OAQPS
Tom Ripp, EPA OECA
Gary Rust, EPA, OAQPS
Dave Salmon, EPA RTP
Eric Schaeffer, EPA OECA
Stan Siegel, EPA Region n
Chris Tirpak, EPA OPPTS
Julie Winters, EPA OPPTS
Elaine Wright, EPA Region HI, Former CSI Director
Computer & Electronics
Automotive
Petroleum Refining
Petroleum Refining
Printing
Automotive/ Printing
Petroleum Refining
Printing
Computers & Electronics
Computers & Electronics
Facilitators
Name
Greg Bourne
John Ehrman
John Ungelbach
Debra Nudehnan
Sector
Printing
Council/ Automotive
Metal Finishing
Printing
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APPENDIX 5: INTERVIEW QUESTIONS
Interview Questions for Printing Subcommittee Participants
What were your original reasons for participating in the work of the printing sector of CSI Did those
reasons change over time? What were your reasons for continuing [discontinuing] participation?
The two projects developed by the printing subcommittee are the NYC Education project and PrintSTEP.
Were other projects considered?
What were the major factors leading to the selection of these projects as the focus of effort for the
subcommittee? What role did various stakeholders play in the selection?
To what extent do you feel these projects address major environmental issues of the printing sector? What
is their potential for significant impact on the environment? On the complexity and cost for printers of
meeting environmental requirements?
What were the most difficult/positive factors in developing projects?
Would the (a) PrintSTEP/(b) NYC Education project have happened without CSI?
Was development of the PrintSTEP (or NYC Education) project the major benefit of being involved with
CSI? What were other (or more important) benefits?
How would you describe the relationships between the stakeholders on the printing
subcommittee/workgroups? How did they change over time? What were the major factors in those
changes?
Were the right people involved on subcommittee and/or workgroups to achieve CSI goals? For example,
were there enough people who were technically knowledgeable about printing, with hands-on expertise?
Were members able to represent the concerns of the stakeholder groups they represented? To make
decisions? To build consensus?
How actively involved were subcommittee or workgroup members? To what extent were members able to
take a leadership role in defining problems and projects?
How did the absence of representatives of the environmental groups during the last year of the
subcommittee's work affect the subcommittee's work?
What changes would you suggest for the selection of members in any future stakeholder efforts for the
printing sector?
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What would you say about the level of trust during the course of the four years? Benefits of the process in
building trust?
What was the most important role played by EPA with respect to the work of this subcommittee/
workgroup? How would you describe EPA's support and follow through for the subcommittee's work?
Leadership in defining goals or identifying opportunities?
What changes have you seen in how EPA works with the printing sector generally as a result of CSI?
How would you describe the relationship between the work of the subcommittee and the work of the
Council? Were there changes in this relationship over the course of the four years?
What lessons can be learned from the development of the NYC Education project? The development of
PrintSTEP? From the overall work of the subcommittee and workgroups?
There has been a lot of discussion of the costs of CSI in relation to the outcomes and benefits. How would
you evaluate the benefits against the work/costs involved hi participation?
To what extent did the work of the printing subcommittee and workgroups meet the goals of CSI?
One effect of CSI that some people have described is that CSI model has impacted activities outside of
CSI—that is, that new activities and relationships have been started outside of CSI as a result of the
relationships and work developed through CSI. Do you know of any examples of this kind of cross-
fertilization?
For the future after CSI:
What is needed to make PrintSTEP work from here?
What lessons have been learned generally from CSI which should be applied to future relationships
between EPA and the printing sector?
Are there lessons from CSI which could be applied elsewhere (e.g., at regional, state, or local
levels)?
What would you like to see as next steps?
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Questions for Metal Finishing Subcommittee/Workgroup Participants
1) Goals
In your subcommittee experience, were goals clearly defined? When did the goals get defined and
how did they change over time? Could you describe the process for goals development?
In your workgroup experience, were the goals for particular projects understood at the outset?
Were the goals clear in context of the larger Metal Finishing sector goals (i.e., the SGP)?
What was your experience with developing the National Performance Goals Agreement Document?
Why did it take almost two years to craft? What were the major points of contention from different
stakeholders' perspectives?
Do the Performance Goals represent your best expectations for facility and sector environmental
performance, from your stakeholder group's perspective? Are they as ambitious as you would
have liked? Are they too ambitious?
2) Participation/Role
Selection
It is often remarked that the Metal Finishing Subcommittee CSI was a success because it dealt with
mostly small businesses, with the inference that success via a CSI-type process is more difficult to
achieve with large industries. To what extent do you believe this is true?
Was it helpful that groundwork had been laid with the Metal Finishing sector and key stakeholders,
via EPA's Sustainable Industry Program? On a scale of 1 to 10 (with 10 being of highest
importance), how would you rank the significance of the Sustainable Industry pre-CSI work with
Metal Finishers to the ultimate success of the subcommittee outcomes?
What is your perspective on the makeup of the subcommittee? Were the right people at the table?
The right mix? How significant was it that key industry leaders played a hands-on role in both
subcommittees and workgroups?
Participant Expectations/Reasons for Participating
What brought you to the table? What made you stay?
Do you feel the Metal Finishing CSI work has fallen below, met, or exceeded your original
expectations? Did your expectations for Metal Finishing sector success change over time?
Level/Continuity of Participation
Were the same people involved at the start as are currently involved in Metal Finishing CSI sector
work? How have any changes affected the process and products of the sector?
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Both the number and the "mission" of workgroups seemed to fluctuate significantly (evolve, may
be better word...) over time. To what extent did that affect continuity—or was it clear, at the
working level, what issues/projects each workgroup was handling, albeit under a different name.
How would you characterize the leadership of the different stakeholder groups?
Participant Capabilities
Did particular stakeholder groups have difficulty engaging? Were there barriers in technical
understanding of both the industry and its complex regulatory picture? Was there an improvement
in understanding and engagement as time went on?
3) CSI Organization/Structure
How would you characterize the relationship between the subcommittee and the CSI Council?
Overall, was the Council a help or a hindrance?
How important were the facilitators to the success of your sector?
To what extent did the bureaucratic structure of a FACA process limit or enable success?
4) Relationships
Could you describe your relationship with other stakeholders prior to the convening of the Metal
Finishing Sector? How has that changed with your involvement in CSI?
Do you make use of relationships established or unproved via your CSI participation in non-CSI
work in your organization/Agency/business? Has the relationship-building aspect of CSI been
valuable?
5) EPA Role
How would you characterize the level and quality of EPA follow through on subcommittee
recommendations? Were good working relationships established with media offices (OW, OSW)
at EPA for Metal Finishing Actions? Has implementation met your expectations?
Do you see any fundamental ways EPA has changed as a result of interacting with or being
informed by the Metal Finishing Subcommittee and its workgroups?
How important were the DFOs to the success of your sector?
What role has the Office of Reinvention played, in your experience?
How important were the subcommittee co-chairs to the success of your sector?
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6) Accomplishments/Shortcomings
Projects and Programs
What is the most significant accomplishment of your sector? Given that most people point to the
Metal Finishing SGP as the ultimate success story of CSI, could you offer your opinion as to the
critical factors that went into the realization of that success? Which of these factors are unique to
the sector, and which could be taken away as lessons learned for future sector-based, consensus-
driven, multi-stakeholder efforts?
How were the major issue areas arrived at for the Action Plan, and how did ideas for projects
("Enabling Actions") arise—from the ground up via the workgroups or from the subcommittee (or
Council) on down?
Which of the projects/actions do you feel contribute the most to helping the Metal Finishing
industry reach their performance goals? Are there projects that ought to have been brought
forward that didn't make it? Do the projects under-represent certain stakeholders and has there
been any discord because of this?
Did you think the activity of developing recommendations for the Council to be productive for your
sector?
Results
What actions resulted from recommendations to the Council, and were these valuable? What is
your sense of the level and commitment of implementation of any recommendations made to the
Council?
Do you have any concerns for full realization/implementation of the SGP, as CSI is ending?
Could the SGP have happened without CSI?
Costs
What is the status of the analysis of burden reduction and other cost-benefits study? Do you feel
that the SGP was achieved at an unreasonably high transaction cost? Have you seen data as to
exactly how much EPA has invested in SGP specifically, and in your subcommittee CSI work, in
general?
7) Cross-fertilization
Could you offer examples of the way relationships or project ideas and/or results have been used
by you or your organization outside of the direct context of CSI?
Are there any CSI-seeded pilots and/or activities, either never funded or currently unfunded by
CSI, that are going on out in the states or local government arena?
Are there any other cross-fertilization benefits you can think of?
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8) Derision-making Processes/Ownership of Outcomes
Were operating principles for consensus-based, multi-stakeholder committees developed for/by
your Subcommittee? How important was this activity (developing the principles) to making the
process run smoother?
9) Lessons Learned/Next Steps
What are the most significant lessons learned that came out of the Metal Finishing sector, and do
you believe these lessons are informing EPA as it moved into this "beyond CSI" phase?
What are your personal lessons learned, arising out of your participation in the sector?
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Petroleum Subcommittee/Workgroup Questions
1) Goals
What are the major environmental issues facing the petroleum sector? How were these issues
addressed in the goals/objectives and products of the subcommittee and workgroups?
Were any known major environmental issues facing the petroleum sector "tabled" or "passed
over?" If so, what were the reasons?
What are the critical economic and market conditions faced by the petroleum sector? Did these
conditions affect the goals/objectives and selection of projects for the work groups?
What are the biggest regulatory burdens within the petroleum sector? How did these issues impact
the selection of work group topics and products?
2) Participation/Role
How did changes in the stakeholders, over time affect the work and outcomes of the subcommittee
and workgroups?
Did the stakeholders have appropriate knowledge of issues facing the petroleum sector? Were any
gaps in knowledge addressed as the projects moved forward?
Are you involved in the implementation of any products of the petroleum sector?
Did the projects/outcomes of the petroleum sector address the issues that originally got you to
participate in the process? If not, did your experience with CSI help your current/future efforts to
address those issues?
3) CSI Organization/Structure
What comments did the subcommittee and Council make on the One Stop Reporting and Public
Access Project (now RAIRS)? Comments on other petroleum sector projects and
recommendations?
Did the general approach of the subcommittee and Council review of projects and
recommendations change over time?
How did the subcommittee decide which actions would go to the Council as recommendations?
What was the role of the facilitators in the petroleum sector?
4) Relationships
Are you working with petroleum sector participants on any other projects not initiated by CSI?
Did you have any previous history with the petroleum sector CSI participants?
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Given the historical adversarial relationship of stakeholders in the petroleum sector, did these
relationships improve as a result of the CSI process? If so, what were the biggest factors for
improvement? If not, what could have facilitated improved relationships?
5) EPA Role
EPA staff is involved in the detailed technical issues for the Equipment Leaks and alternative
LDAR requirements projects. What was EPA's role in initiating these projects and how will their
continued involvement affect the ultimate success of these projects?
Would more EPA involvement in the larger issues facing the petroleum sector nave made a
difference in the types of projects the work groups selected?
6) AcgnmpKslmients/SliOTtenmings
There are three main projects for the petroleum sector: Equipment Leaks/LDAR, RAIRS, and
Accidental Releases. What other projects were considered?
Would these projects have been implemented without CSI? Are the issues that these projects are
designed to address closer to resolution as a result of the petroleum subcommittee/workgroup
efforts?
Do the projects address the major environmental issues in the petroleum sector?
Do the projects address the issues you hoped to address when you agreed to participate in the
petroleum sector?
7) Cross-Fertilization
Could you offer examples of the way relationships or project ideas and/or results have been used
by you or your organization outside of the direct context of CSI?
Are there any other cross-fertilization benefits you can think of?
8) Decision-making Processes/Ownership of Outcomes
Were certain stakeholders critical to success/problems addressing specific issues?
Did the consensus process affect the progress of specific projects in the petroleum sector? How
did consensus issues shape the design of the three primary projects of the petroleum sector? How
did consensus issues affect the type of projects selected by the petroleum subcommittee?
9) Lessons Learned/Next Steps
What are the key lessons learned from the One-stop/RAIRS project?
What is needed to make one-stop reporting work from here?
What is needed to move onto streamlining multimedia reporting?
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What are the key lessons learned from the Equipment leaks/LDAR projects?
What is needed to increase the use of innovative LDAR protocols?
Could lessons learned from the petroleum sector projects be applied elsewhere? (Other states, other
industries, etc.)
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Questions for Iron and Steel Sector of CSI
1) Goals
What are the major environmental issues facing the iron and steel sector? How were these issues
addressed in the goals/objectives and products of the subcommittee and workgroups?
Were any known major environmental issues facing the iron and steel sector "tabled" or "passed
over?" If so, what were the reasons?
What are the critical economic and market conditions faced by the iron and steel sector? Did these
conditions affect the goals/objectives and selection of projects for the work groups?
What are the biggest regulatory burdens within the iron and steel sector? How did these issues
impact the selection of work group topics and products?
2) Participation/Role
How did changes in the stakeholders affect the work and outcomes of the subcommittee and
workgroups?
Are you involved in the implementation of any products of the iron and steel sector?
Did the projects/outcomes of the iron and steel sector address the issues that originally got you to
participate in the process? If not, did your experience with CSI help your current/future efforts to
address those issues?
3) CSI Organization/Structure
How would you assess the review process by the subcommittee and Council on the Guiding
Principals for the Brownfields project? Comments on other projects?
Did the general approach to review and comments on projects/recommendations by the
subcommittee and Council change over time?
What was the role of the facilitators in the iron and steel sector? Were they a major factor in the
success/failure of the sector?
4) Relationships
Are you working with iron and steel sector participants on any other projects not initiated by CSI?
Did you have any previous history with the iron and steel participants?
How did your work on the subcommittee/workgroup affect your relationships with other
stakeholders?
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5) EPA Role
What was the EPA's role in moving forward with the "12 general permitting recommendations?"
Which EPA offices and staff were involved with acting on these permitting recommendation? Was
the staff directly involved in the iron and steel sector, or, was EPA staff outside the sector
involved?
What EPA involvement is critical to get the most out of the iron and steel sector recommendations
and projects?
6) AccompHshmente/Shortconriiigs
At first, the iron and steel sector seemed to focus on specific projects and recommendations. Later,
the sector focused on broader issues impacting iron and steel. Which focus (specific or broad) was
more successful and why?
What is the most successful accomplishment of the iron and steel sector? The Brownfields pilot
projects are often discussed as an accomplishment of the iron and steel sector. What factors led to
the success of the Brownfields pilots?
Do the projects implemented by the iron and steel sector address the issues you hoped would be
addressed when you agreed to participate in the iron and steel CSI project?
7) Cross-fertilization
Could you offer examples of the way relationships or project ideas and/or results have been used
by you or your organization outside of the direct context of CSI?
Are there any other cross-fertilization benefits you can think of?
8) Derision-making Processes/Ownership of Outcomes
Were certain stakeholders critical to success/problems addressing specific issues?
Did the consensus process affect the progress of specific projects in the iron and steel sector? How
did consensus issues shape the design of the primary projects of the iron and steel sector? How did
consensus issues affect the type of projects selected by the iron and steel subcommittee?
9) Lessons Learned/Next Steps
What are the key lessons learned from the iron and steel sector projects?
Did any specific project(s) result in key lessons on issues important to you?
Could any of the lessons from iron and steel be applied elsewhere?
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U.S. EPA Headquarters Library
Mail code 3201
Automotive Sector Questions 12°P Pennsylvania Avenue NW
Washington DC 20460
1) Goals
What are the major environmental issues facing the automotive industry? Were the definitions of
the major issues shared by all parties at the onset of CSI? Did these definitions "meld" as the
subcommittee worked to generate a profile of the industry? Were projects chosen by the
subcommittee based upon these major issues? If not, what deciding criteria were used to select a
project to work on?
How did the goals of the subcommittee change over time? What aspects of the original goals (that
were later jettisoned) are difficult to deal with in a CSI-type process? Why?
2) Participation/Role
What were your expectations reasons for participating in the work of going into CSI? How did
these expectations change over time?
How did the level of participation on the subcommittee/workgroup and commitment to CSI change
over time? In particular, did the NSR project discussed by the subcommittee hi Fall 1996 affect
your commitment or participation?
Do you believe that EPA chose the "right" set of stakeholders to participate in the automotive
subcommittee and workgroups?
What was the level and continuity of participation of all stakeholders in subcommittee and
workgroup? How did that affect the outcomes?
Did stakeholders have sufficient resources and capabilities to fully participate in your
subcommittee's work—particularly with regard to technical issues surrounding air permitting for
auto manufacturing plants? If not, what recommendations would you make to improve stakeholder
capacity?
3) CSI Organization/Structure
To what extent was the subcommittee and workgroup structure helpful in terms of selecting
projects and making recommendations to the Council? What was the effect of combining the
workgroups on alternative regulatory and community technical assistance and involvement?
How would you evaluate EPA's facilitation of CSI (for example, in terms of quality, independence,
value added)? Were ground rules clear, adequate, and followed?
4) Relationships
Please characterize your working relationship with the other stakeholders at the outset of your
involvement in the subcommittee/workgroup. How did your relationships change? What were the
chief causes of these changes?
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What value do you place on CSI relationship building? Please explain.
Have the relationships you developed during CSI moved forward since the subcommittee shut
down (Le., are you hi contact with other stakeholders in a way that differs from your pre-CSI
relationships)?
5) EPA Rote
Was EPA's role in the automotive sector well defined? In your opinion, did EPA provide too much
or not enough direction and leadership? How did EPA's direction, leadership, and agenda-setting
role change over time?
What changes, if any, would you recommend for EPA's role?
Did EPA adequately support the efforts of the automotive subcommittee and work groups?
6) Atynrnpltehments/Shnrtfinniiiige
What were the chief accomplishments of the automotive sector — in terms of actual work products,
environmental improvement, and relationships? Please delineate any benefits in terms of:
- human health and environment?
-cost savings and paperwork reduction?
-regulatory streamlining?
What were the chief shortcomings of the automotive sector? How could these shortcomings have
been better addressed? What would have made it useful to continue the work of the subcommittee?
Do you consider any of the automobile sector results (be they of a process/relationship nature or
actual work products) to be truly groundbreaking?
How would you weigh the transaction costs of your involvement in CSI relative to its outcomes?
7) Cross-fertilization
What benefits have occurred as a result of CSI outside of the direct CSI context? (For example,
state or local stakeholder efforts, or other new stakeholder relationships, processes inspired by CSI
8) Decision-making Processes/Ownership of Outcomes
To what extent was the requirement for consensus an asset to CSI? To what extent was consensus
a liability to CSI? Was the consensus requirement one of the more important elements in the
shutdown of the subcommittee, or was it secondary?
9) Lessons Learned/Next Steps
What do you think are the chief lessons learned for the automotive sector?
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Has CSI shown a new potential role for EPA in regulatory development and stakeholder interaction
in the automotive manufacturing sector? Please explain.
How does CSI compare with EPA's traditional way of dealing with the automotive sector?
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Questions for Computers & Electronics SubcommitteeAVorkgroup Participants
1) Goals
Do you believe that the work of the Computers & Electronics Subcommittee and workgroups has
met the goals of CSI? Do you feel those goals are well understood by all participants?
Was there a common definition of the major issues facing the Computers & Electronics sector
going into the process? Did the definition of issues change over time?
To what extent did the competitive and secretive nature of the computer industry affect the
openness of the goal/agenda setting process?
2) Participation/Role
What was your motivation for participating in the work of the Computers & Electronics sector?
Did that motivation change over tune?
Were the right people involved on the subcommittee and/or workgroups? Did you have any
concerns about how stakeholder representatives were chosen? Was the mix appropriate for the
kind of work you were doing? What changes would you suggest for selection of members in any
future stakeholder efforts for this sector?
How would you categorize the level of participation of subcommittee or workgroup members?
Were there difficulties that arose out of differing technical understanding?
Did you have sufficient resources and capabilities to fully participate? If not, what
recommendations would you make for future stakeholder efforts to improve this capacity?
3) CSI Organization/Structure
Could you characterize the relationship between the work of the subcommittee and the work of the
Council? Did this relationship change over the course of the four years?
Compared to some of the other CSI sectors, Computers & Electronics seemed to make greater use
of formal recommendations to the Council, as a means to forward work. Was this part of an
overall subcommittee strategy? Did you find it a useful way of working? How could the
recommendations process be improved?
Did you find the FACA process to be a help or a hindrance, overall? What aspects of FACA were
most helpful or caused the most difficulties? Do you feel that future sector work needs to be done
under a full FACA process?
4) Relationships
How would you describe the relationships between the stakeholders on the Computer & Electronics
Subcommittee/workgroups? How did they change over time? What were the major factors in those
changes?
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What would you say about the level of trust during the course of the 4 years? Benefits of the
process in building trust? Has any of the relationship-building carried over into your other non-
CSI work?
5) EPA Role
What EPA role with respect to the work of the subcommittee/workgroups was roost significant?
Was EPA's support and follow through for the subcommittee's work adequate? Did EPA exhibit
leadership in defining goals or identifying opportunities?
Have you seen any changes in how EPA works with the Computers & Electronics sector as a result
of CSI? For example, was there any value-added to XL projects brought forth by sector firms due
to relationships or trust-building that occurred via CSI?
6)
In May 1996, the Computers & Electronics Subcommittee agreed upon "a vision" for a facility-
based Alternative System of Environmental Protection. This seems to have been carried forward in
terms of the Performance Track Program recommendation. Were there difficulties in tacking the
concept to a more concrete product within the context of this subcommittee? Did the "vision"
guide any of the other projects/products the workgroups focused on (other than the
recommendation that was put forth)?
Which of the sector projects/products do you feel is most significant? Could any be characterized
as "breakthrough?" Did the subcommittee take a strategy of developing smaller, do-able projects
that dealt with specific issue areas?
To what extent do you feel these projects address major environmental issues of the Computers &
Electronics sector? Potential for significant impact on the environment?
How significant was it that the sector was unable to engage other co-regulators in the CSI process,
such as OSHA and NIOSH? Do you fed this kind of integration is essential to your sector in
particular? To all sector-based work?
Would projects such as CURE or BOLDER have happened without CSI? How necessary was a
consensus-based, multi-stakeholder model to designing and carrying out these projects?
How would you weigh the transaction costs of your involvement in this subcommittee relative to its
benefits?
7) Cross-Fertilization
New activities and relationships often have been started outside of CSI as a result of the
relationships and work developed through the CSI. Do you know of any examples of this kind of
cross-fertilization in your sector or organization?
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8) Decision-Making Processes/Ownership of Outcomes
To what extent were participants able to define problems and projects? Did the consensus process
aid or hinder the decision making?
9) Lessons Learned/Next Steps
What are the overall lessons-learned out of the work of the subcommittee and workgroups?
What is needed in terms of follow-through on Computers & Electronics sector recommendations?
On projects, such as CURE and BOLDER?
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Questions for Council Participants
1) Goals
From your perspective, what were the major goals of Council?
How did the work of the Council support those goals?
Were there changes over time either in the goals themselves or in the work of the Council in
relation to those goals?
2) Participation/Rote
What were your original expectations/reasons for participating on the CSI Council?
Were there unrealistic expectations for success at the outset of CSI, and how did these affect the
early work of the Council?
Did those expectations change over time?
How did the mix of sectors chosen for CSI affect the work of the Council? Do you feel that the
sectors chosen best fit what CSI could accomplish?
Did stakeholders have the right level of participant at the table for the work of the Council?
What was the intensity, consistency, continuity of participation of stakeholders on the Council?
How did that affect the outcomes?
To what extent did various Council participants/stakeholders provide leadership in defining the
goals and activities of the Council?
How would you describe your role as a member of the Council?
Were all stakeholders able to fully participate in the work of the Council? Are there changes which
could have facilitated stronger participation?
3) CSI Organization/Structure
Did you participate on a subcommittee as well as on the Council? How would you evaluate the
role of the Council with respect to the work of your subcommittee/sector? Other subcommittees?
How would you describe the special role of the Council?
4) Relationships
How effectively did various stakeholders work together on the Council?
How did relationships change over time? What led to those changes?
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5) EPA Rote
How effective was the role of the Council in providing recommendations to EPA?
How strong has EPA follow-through been on recommendations of the council?
How would you describe EPA's role in defining the agenda and objectives of the Council? Any
changes in EPA role over time?
Have there been changes in the way EPA does business as a result of CSI?
6) Accomplishments/Shortcomings
What are the most important products/projects/ recommendations coming out of the Council's
work?
Did the Council successfully tackle core environmental/regulatory issues?
How would you evaluate the work of the Council on:
-developing a plan for future sector-based approaches by the Agency?
-developing better approaches for EPA's work with stakeholders?
-promoting a revised approach to use and management of information by EPA?
How would you describe the costs of participating on the Council specifically, or in CSI generally,
relative to the outcomes?
7) Cross-fertilization
What benefits have occurred as a result of CSI outside of the direct CSI context?
8) Derision-Making Processes/Ownership of Outcomes
What have been the strengths/weaknesses of the Council's process for making decisions?
How has that process changed during the course of CSI?
9) Lessons Learned/Next Steps
What do you regard as the key lessons of CSI generally? Of the work of the Council specifically?
Has CSI shown a new potential role for EPA in environmental policy? If so, how describe?
Adequacy of current steps for CSI follow up? Any additional steps that EPA should be taking to
follow up on CSI?
Any concerns with respect to implementation of Council recommendations now that CSI is ending?
How does CSI compare with other EPA ways of doing business with regulatees and stakeholders?
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