2003
MAY 4-7, 2009 • HYATT REGENCY HOTEL
I [National
V^" Environmental
f I.—I PerformanceTrack
• U.S. Environmental protection £0ency
SAN FRANCISCO, CALIFORNIA
7
Harnessins the Power of Collaboration
x/PProxima1:e'y 500 people
yf J gathered in San Francisco,
/ L California, on May 4-7, 2009,
for the sixth National Environmental
Partnership Summit. Among the
participants were many former members
of Performance Track, who met with
EPA officials and the Performance Track
Participants Association to discuss
the future of environmental leadership
programs after the termination of
Performance Track.
The Summit opened with a plenary talk
by Maureen Gorsen, former director
of the California Department of Toxic
Substances Control, who spoke about
the future of pollution prevention and
green chemistry. Noting that chemical
production is doubling every 25 years,
with a $7.2 billion market for chemicals
in California alone, she spoke of a
"huge opportunity" to move toward
a cradle-to-cradle economy and shape
the global debate on chemicals
and products.
California is taking a step in that direction
by launching a Green Chemistry
Initiative, built on three strategies: to
build capacity, increase infrastructure,
and create tools for better decisions. In
December 2008, the initiative released
a set of six policy recommendations
to eliminate or reduce the use of
toxic substances in products or
This year's Summit was held near the San Francisco waterfront.
manufacturing processes. Two of the
recommendations (creating an online
toxics clearinghouse and accelerating
the quest for safer products) are being
implemented now. The initiative's final
report is available on California's Green
Chemistry site.
Laura Kimi Yoshii, acting regional
administrator for EPA Region 9,
welcomed the Summit participants to
California and focused her remarks on
the critical importance of partnerships
and collaboration in environmental
protection. "The best collaborations
are those where there's a clear sense
of what the issues are, and what the
different players can bring," she said.
"We need to get better at bringing
more people to the table."
Gwen Ruta, vice president of corporate
partnerships at the Environmental
Defense Fund (EOF), continued the
theme of collaboration in her plenary
speech the following day. Ruta
offered a "Tale of Two Partnerships"
to illustrate how EDF's approach to
partnerships has evolved. The first
partnership, formed in 2003 with
Citigroup, focused on reducing paper
use in the financial services industry,
which consumes about 10,000 pages
of paper per employee per year.
Through its partnership with EOF,
Citigroup switched to using 30
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percent recycled paper, providing
double-sided statements, and other
paper-saving strategies that could be
achieved without incurring new costs
to the company.
The second partnership is with another
financial services firm, Kohlberg Kravis
Roberts & Co. (KKR), which owns a
portfolio of companies and employs
more than 800,000 people. In this
case, EOF is working with the company
to systematize environmental
performance across the entire enterprise.
"On the surface, these examples look
similar," Ruta said, "but while the
Citigroup partnership provided business
benefits, they were not central to
Citigroup's future plans. The aim of
our agreement with KKR is to affect
its core business strategy. And one of
the ground rules in our partnership is
that [our partners are] going to help us
change the rest of the industry."
Ruta says that "Partnerships 2.0" is
about challenging facilities or companies
to go beyond what they can do on
their own. "Don't focus around the
edges of a facility's business," she
advised. "The threats we face and the
potential for environmental business
value are too important."
This new model of partnerships
requires a clear rationale, identifying
what will be achieved through the
partnership that could not be achieved
otherwise. It requires clear and
measurable environmental benefits
that "go deep." It also requires a
strategic focus on sustainability,
integrated within the company's overall
strategy to generate business value. It
should have an ambitious scope with
bold goals, creating an atmosphere
that will lead to widespread change.
Finally, it requires transparency, both
in terms of results as well as the
conditions of the partnership. "The
environment is our client, and
businesses are partners in serving
that client," Ruta said.
More information about EDF's new
partnership approaches, including
tools and reports, is available at
http://innovation.edf.org/home.cfm.
The Summit's closing plenary was
given by Gil Friend, CEO of Natural
Logic, who gave a wide-ranging talk
challenging what he sees as the myth of
an inherent conflict between business
and the environment. "Existence is
proof of the possible," Friend said,
pointing to examples of companies
such as Interface and DuPont whose
environmental initiatives have
improved their bottom lines.
Friend discussed the future of
environmental regulation and policy,
which he said faces a pivotal challenge
of getting the prices right. "The prices
we pay don't reflect their real costs,"
he said, noting by way of example
that the Rocky Mountain Institute has
calculated the real cost of gasoline
at between $12 and $20 per gallon.
"Perfect markets depend on perfect
information," Friend said. "In our
case, the price is lying."
Friend called for a shift in understanding
of the relationship between human
systems and natural systems, so that
the economy is seen as a subsidiary of
the environment. He said it is time to
take on the challenge of building "a
world that works for 100 percent of
humanity, in the shortest amount of
time, without ecological offense, and
to disadvantage of no one." Friend
concluded his talk by challenging the
audience with a question: "If it was
clear that who you are and what you
do made a difference, who would you
be, and what would you do?"
Lessons Learned from
Performance Track Site Visits
In this session, David Guest, Andy
Teplitzky, and Chris Menen of EPA's
Performance Track program described
lessons they learned in conducting 250
visits to Performance Track facilities
over the program's lifetime. EPA used
site visits as a quality control measure
for Performance Track. Over the life of
the program. Performance Track staff
visited 28 percent of current members
and 30 percent of all members, including
76 percent of organizations with more
than one facility in the program (these
organizations represent about 65
percent of the current membership).
Performance Track also developed a
site visit training program to ensure
consistency in evaluation; approximately
150 people participated in the training.
The initial focus of site visits was on EMS
implementation but later shifted to
environmental performance evaluations.
David Guest gave an overview of the
following noteworthy practices
identified during the site visits:
• Action plans for achieving
environmental goals.
• Performance Track logo used in
connection with Performance
Track goals.
• Control charts for each goal to
track progress.
• Flow charts for key steps in
goal execution.
• Graphic displays of progress
toward goals throughout
the facility.
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• Key performance indicators
identified, measured, monitored,
and reported to management.
• Frequent management review
of performance (monthly,
quarterly, etc.), enabling real-time
corrections.
• Soliciting stakeholder input on
goal selection.
The two most significant problems
identified during the site visits were
cases in which goals did not tie to
significant aspects at the facility or
other environmental priorities, and a
lack of progress on performance goals
(which sometimes was due to factors
beyond a facility's control).
Chris Menen described how the site
visits evaluated EMS implementation
at Performance Track facilities and
provided tips on how to correlate EMS
to performance. Performance Track
worked with members to identify EMS
weaknesses and improve their EMS.
As the site visit program matured.
Performance Track learned that third-
party verification was a very important
process for determining the quality of
an EMS, and decided to make it
a requirement for admission to
the program.
According to Menen, Performance
Track found that the following EMS
components are critically linked to
performance:
• The factors included in the scope
of the EMS and how the facility
defines its fence line.
• EMS monitoring and
measurement.
• The inclusion of environmental
aspects that are significant
to the facility.
Participants brainstormed and categorized their ideas for afresh approach to
environmental leadership and collaboration.
• Change management (planning
for changes in infrastructure,
management, and other factors).
• Compliance auditing, which
should be linked directly to EMS
legal requirements.
• Checking and corrective action
(frequent internal and external
audits, a process in place to
identify and correct problems).
• EMS management review
(involvement of top management
is critical).
Andy Teplitzky described lessons
learned about public outreach and
reporting. Performance Track asked
its members to identify and respond
to community concerns, inform the
community about important matters,
and report on the facility's EMS and
performance goals.
According to Teplitzky, public outreach
was challenging due to:
• Fear of transparency.
• Lack of management support.
• The sense that public relations is a
corporate responsibility.
• Little or no local community interest.
• The fact that many facilities are
located in industrial parks or
rural settings, and thus have no
surrounding "community" in the
conventional sense.
• The fact that most facilities had a
means to respond to concerns but
didn't know how to proactively
inform the public.
Based on discussions and observations
during Performance Track site visits,
Teplitzky assembled the following list
of good practices in public outreach
and reporting:
• Know and define your community.
• Develop environmental
curricula for local schools (and/
or participate in EPA's Schools
Chemical Clean-out program).
• Engage local schools by assisting
with school bus retrofit programs.
• In industrial park settings, engage
other businesses as your
"community." Hold an industrial
3
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swap meet, organize beneficial
reuse of materials.
• Establish and maintain a
community advisory panel.
• Match your business to serving a
community need.
• Issue community newsletters.
• Integrate environmental matters
into your facility tours.
• Sponsor Earth Day events.
• Make sure your environmental
measures are easy to read
and digest.
• Use surveys to determine the
issues that are important to
your community.
• Post your environmental measures
on your website.
• Publish annual environmental
reports.
• Provide environmental information
directly to customers. (In this case
customers are the "community.")
• Issue press releases.
• Publish environmental newsletters
for broader distribution beyond
the local community.
• Issue employee-specific
newsletters; this is especially
useful where your employees are
representatives of your community.
• Be proactive with community
complaints.
Environmental Leadership
Through Collaborative
Partnerships at the Facility
And Beyond
Jo Anne Shatkin and Jasmine Tanguay
of CLF Ventures, the nonprofit affiliate
of the Conservation Law Foundation,
described collaborative models for
partnerships between corporations and
nongovernmental organizations (NGOs).
For corporations, the benefits
of partnerships with NGOs include
enhanced credibility, higher environ-
mental performance, access to skills
and perspectives not available in the
company, independent validation,
recruitment, retention of high-performing
staff, skills development, product
innovation, and help in developing
a long-term vision.
For NGOs, the benefits include
access to corporate staff and their
skills, financial resources, technical
expertise/technologies, innovation,
enhanced visibility, and possibility to
enhance environmental outcomes.
Shatkin emphasized that it is important
for NGOs and corporations to choose
partners with whom they can be
compatible, and to establish a strong
basis of trust. Partnerships can fall into
a range of categories, including
philanthropic, transactional or
fee-for-service (where the engagement
is limited to a specific task or result),
joint programming (where the two
organizations work together on a project),
or integrative (a relationship that
evolves over time, aligning the
missions of both organizations).
According to Shatkin, factors that
make for a successful partnership
include the following:
• The company must be serious
about changing its behavior.
• The NGO must be able to
maintain clear accountability
to its stakeholders and maintain
its independence.
• Each partner must benefit
directly, and understand the
other's benefits.
• The rules of engagement must
be clearly agreed upon at the
outset through contracts or other
agreements.
• Individual participants must be
sufficiently senior to have their
organization's mandate and be
able to make decisions.
• Trust.
Shatkin and Tanguay described a
recent partnership undertaken
between CLF Ventures and
the Performance Track Participants
Association (PTPA) to take
environmental improvements beyond
the facility to the watershed level. The
goal of the partnership is to promote
collaborative efforts offsite, around
local water bodies and watersheds.
The first such effort is underway
with the Port of Houston Authority
to use Low Impact Design (LID) as an
innovative approach to stormwater
management. "Stormwater
management is in a state of flux,"
Tanguay said. "Nonpoint sources and
stormwater sources are getting
attention from regulators." LID tries
to replicate the predevelopment
hydrology through structural approaches
such as treating stormwater, managing
flow, and using pervious surfaces, as
well as nonstructural approaches such
as increasing infiltration, tree planting,
habitat restoration, and site best
management practices.
The Port of Houston Authority has
been working to improve its
stormwater management for many
years. In partnership with PTPA,
CLF Ventures offered to assess the
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facility's baseline stormwater footprint
and identify opportunities for LID.
Earlier this year, CLF Ventures met with
Port of Houston environmental staff
and toured Port-owned facilities,
and then delivered benchmarking
results, recommendations, and a
customized LID resource compendium.
The second phase of CL F Ventures'
partnership with PTPAwill involve
taking environmental leadership
beyond individual facilities to form
partnerships with other facilities within
a watershed to work on coordinated
environmental improvement projects.
Meeting of Former
Performance Track Members
At this meeting, attended by
approximately 30 people including
former members of Performance
Track, EPA officials, state officials, and
representatives of nongovernmental
organizations, participants discussed
the achievements of Performance Track
and the lasting benefits it created for the
environment as well as for the facilities
that were enrolled in the program.
Several participants pointed out that
Performance Track served as a mechanism
for driving change at their facilities,
helping to move "the middle of
the bell curve" forward toward
organizational change and improved
environmental performance.
Performance Track also was credited
with making progress on unregulated
environmental issues such as water
use, energy use, and greenhouse gas
emissions, demonstrating the ability
of voluntary programs to complement
regulations. Former members at the
meeting also said the program
enabled them to build networks of
relationships with other facilities, state
officials, and EPA regional offices
through which they could share best
practices, advance the state of the art,
and work together to solve problems.
Participants pointed to improvements
in their facilities' environmental
performance, a lasting ethic of
continuous improvement, a sense of
pride in their accomplishments, and
better relationships with regulators.
Life After Performance Track
John Flatley and Anne Vogel-Marr
of PTPA led a session to discuss
possible next steps in designing and
developing a new program to encourage
environmental performance.
Based on input from the PTPA
membership and board, Flatley and
Vogel-Marr have put together an initial
scoping document with a vision of
what the next steps could look like;
they wanted to solicit further discussion
and ideas from people attending
the Summit.
The scoping document proposes a
three-tiered program, with the first tier
being an on-ramp with no compliance
criteria: members would sign a code of
conduct and make a commitment to
eventually put an EMS into place. The
second tier would correspond to the
entry criteria for Performance Track.
The third tier would be a leadership
tier, defined through a rating system-
based standard. Facilities participating
in voluntary programs could get
points toward their leadership
rating. Alternatively, the third tier
could be similar to the Corporate
Leader designation.
One option proposed at the outset of
the discussion at the Summit was to
focus the effort on state environmental
leadership programs rather than trying
to reestablish a national program.
However, some members felt that having
the structure of a national program
would be important. Another option
proposed was for industry to
set up its own program to work
voluntarily with states and NGOs,
without involving EPA.
Vogel-Marr and Flatley directed the
discussion by asking what a new program
should do, what the membership
criteria should be, who the partners
should be, and how it should be
structured. Many of the features
suggested by participants in the
meeting resembled elements of
Performance Track, such as providing
national recognition and the sharing
of best practices, while avoiding more
controversial areas such as low priority
for inspections and regulatory flexibility.
A number of participants supported
the idea of tiered levels, along with a
broader involvement by partners such
as non-governmental organizations
and states.
PTPA will be convening a group of
interested parties to refine the scoping
document and will share the findings
with EPA's National Advisory Council for
Environmental Policy and Technology
(NACEPT) and others who request it.
Please contact John Flatley for more
information at: jflatley@amsnavista.com.
Participants' Input to EPA
on a Fresh Approach to
Environmental Leadership
and Collaboration
In this session, former Performance
Track members and others attending
the meeting were asked for their
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advice, feedback, and input on how
EPA and the NACEPT subcommittee
should move forward to pursue
environmental leadership and industry
collaboration. The group held a brain-
storming session and then organized
its more than 150 suggestions into
categories such as recognition
and incentives, the definition and
measurement of performance,
accountability, and new tools and
programs. The organized list of
suggestions will be provided to
the NACEPT subcommittee for
consideration.
Some of the suggestions from the
brainstorming session included the
following:
• Increase collaboration with other
federal agencies.
• Clarify the goals of environmental
protection.
• Establish Presidential awards for
high performers.
• Develop criteria for environmental
leadership.
• Create a mentoring program
through which high-performing
facilities can help others improve
their environmental performance.
• Create mechanisms for knowledge
transfer within sectors.
• Provide incentives for facilities to
meet milestones more quickly.
• Develop a beyond-compliance
sustainable business certification
program.
• Require labeling or disclosure of
chemicals in products to push
stewardship and sustainability.
• Develop a coherent vision for all
EPA voluntary programs.
• Coordinate existing state
leadership programs.
Chuck Kent, director of EPA's
Office of Cross-Media Programs,
wrapped up the discussion, thanking
members for their input and inviting
further dialogue.
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