Voluntary Programs to Reduce Pollution

James E. McCarthy
Specialist in Environmental Policy
Environment and Natural Resources Policy Division
July 13, 1995
95-817 ENR

SUMMARY

This report provides information concerning voluntary pollution prevention programs administered by the Environmental Protection Agency. Over the past 5 years, under both Republican and Democratic Administrations, the Environmental Protection Agency has developed a wide range of such programs and policies aiming to prevent pollution, improve efficiency, simplify compliance, and recognize or reward companies and organizations taking voluntary pollution prevention steps.

EPA has developed at least nine voluntary programs:

• - the 33/50 Program;
• - Green Lights;
• - Energy Star Computers;
• - Energy Star Buildings;
• - Climate Wise;
• - WasteWi$e;
• - Water Alliances for Voluntary Efficiency (WAVE);
• - PEST SMART; and
• - Project XL.

In addition, the Agency has developed several policies intended to encourage voluntary activities, both in response to legislation and on its own. These include the Agency's policy on environmental auditing and the Clean Air Act's Early Reductions program. The Agency also has programs that encourage pollution prevention in specific industries without having numeric goals or other ways of measuring progress. These include Design for the Environment, the Environmental Technology Initiative, and Compliance Assistance Centers.

This report provides brief descriptions of each of these programs and discusses proposed changes in the EPA budget that would cut or terminate some of the programs. In addition to the programs discussed here, the Agency has begun several regulatory reform initiatives, such as the Common Sense Initiative and the Reinventing Environmental Regulation Initiative. These are not discussed in this report, except to the extent that they incorporate voluntary programs or activities.

CONTENTS

INTRODUCTION
VOLUNTARY PROGRAMS
-- 33/50 Program
-- Green Lights
-- Energy Star Computers
-- Energy Star Buildings
-- Climate Wise
-- Wastewi$e
-- Water Alliances for Voluntary Efficiency (WAVE)
-- PEST SMART
-- Project XL
POLICIES THAT ENCOURAGE VOLUNTARY ACTIVITIES
-- Environmental Auditing Policy
-- Early Reductions
OTHER PROGRAMS
-- Design for the Environment
-- Environmental Technology Initiative
-- Compliance Assistance Centers
SUMMARY

Voluntary Programs to Reduce Pollution

INTRODUCTION

This report provides information concerning voluntary pollution prevention programs administered by the Environmental Protection Agency. Over the past 5 years, under both Republican and Democratic Administrations, the Environmental Protection Agency has developed a wide range of such programs and policies aiming to prevent pollution, improve efficiency, simplify compliance, and recognize or reward companies and organizations taking voluntary pollution prevention steps.

These programs have been supported by a wide range of interests, in most cases, because they seem to step away from a confrontational, command-and-control approach, while promising continued environmental improvement. The initial support from the regulated community and other interested parties led EPA to expand the concept to a wide range of problems in all environmental media.

Of late, however, some of the programs have been targeted for reduction or elimination, as the 104th Congress attempts to reduce EPA appropriations. Since they generally are not authorized in specific statutes, these programs may have fewer defenders in Congress than statute-based programs targeted for reductions.

Depending upon how one defines the type of program, EPA has developed at least nine voluntary programs. These are:

• - the 33/50 Program (also known as the Industrial Toxics Project);
• - Green Lights;
• - Energy Star Computers;
• - Energy Star Buildings;
• - Climate Wise;
• - WasteWi$e;
• - Water Alliances for Voluntary Efficiency (WAVE);
• - PEST SMART Pesticide Environmental Stewardship Program; and
• - Project XL.

In addition, the Agency has developed several policies intended to encourage voluntary activities, both in response to legislation and on its own. These include the Agency's policy on environmental auditing and the Clean Air Act's voluntary Early Reductions program.

In a third category, one might place numerous EPA programs that encourage pollution prevention in specific industries without having numeric goals or other ways of measuring progress. These include Design for the Environment, the Environmental Technology Initiative, and Compliance Assistance Centers.

This report provides brief descriptions of each of these programs. In addition to the programs discussed here, the Agency has begun numerous regulatory reform initiatives, such as the Common Sense Initiative and the Reinventing Environmental Regulation Initiative. The regulatory reform initiatives are not discussed in this report, except to the extent that they incorporate voluntary programs or activities.

In issuing its recommendations on FY 1996 appropriations, the House Appropriations Subcommittee on VA, HUD, and Independent Agencies included provisions that would affect several of these programs. These recommendations are discussed under the appropriate program headings.

VOLUNTARY PROGRAMS

Since 1991, EPA has inaugurated at least nine voluntary pollution prevention programs, each of which is described below.

33/50 Program

The 33/50 program gets its name from the goals it set for participating companies. Compared to the base year of 1988, the program seeks voluntary commitments to reduce releases to the environment and transfers to off-site facilities of 17 toxic chemicals 33 percent by 1992, and 50 percent by 1995.(1) The program was initiated in February 1991, when EPA invited 555 companies that had substantial releases of the target chemicals to participate. It later broadened the invitation to more than 8,000 companies, of which about 1,300 have chosen to participate.

Releases of the target chemicals are measured annually by the Toxics Release Inventory (TRI). According to the TRI, releases and transfers of the chemicals have declined 46 percent in the period 1988-1993, from a total of 1.47 billion pounds to 803 million pounds. The 1992 target of a 33 percent reduction was met a year ahead of schedule, and projections suggest that the program's final goal will be achieved, also possibly ahead of schedule.

Anticipating this achievement, the Agency is planning a "graduation ceremony" for autumn 1996, and is currently seeking stakeholder comments on "a Next Generation."

Despite apparent success, the 33/50 Program has not been without critics. In May 1994, Citizens Fund, the research and education affiliate of Citizen Action, released a study criticizing the program for taking credit for actions unrelated to the program. According to the study, "while many companies have cut their toxic waste at the source, those efforts were under way for 83 percent of the projects long before the Bush administration initiated the program in 1991." (2) The report also criticized EPA for allowing waste incineration, treatment, burning for energy recovery, recycling, and reductions due to production cutbacks to count toward the program's goals.

Many of these criticisms were echoed in a September 1994 General Accounting Office report. According to GAO, "the reported achievements of this program need to be tempered by the information that (1) about 40 percent of the reductions claimed took place before the program was formally established and (2) 26 percent of the reductions can be attributed to companies not participating in the program." (3)

Others have found more merit in the program, however. A study published by Resources for the Future concluded that while releases of chemicals were declining even without the program, after the inception of the program companies switched the emphasis of their pollution prevention efforts to the targeted chemicals:

Between l990 and 1991, releases and transfers of 33/50 Program chemicals fell by 21 percent, while releases and transfers of nonprogram chemicals fell by only 8 percent. The 1992 data reveal that reduction rates for the program chemicals are four times those reported for other TRI chemicals. (4)

These reductions reversed a trend in the previous two years. "This finding suggests that the 33/50 Program has been successful in setting priorities with respect to the chemicals targeted by firms in their pollution control efforts." (5)

Green Lights

Green Lights is a voluntary EPA program that promotes the use of energy-efficient lighting. The program began operation in January 1991. Since then, it has attracted more than 1,650 participants (corporations, government agencies, and others).

Green Lights participants sign a Memorandum of Understanding with EPA in which they agree to survey 100 percent of their facilities and, within five years of signing, to upgrade lighting in 90 percent of the square footage that can be upgraded profitably without compromising lighting quality. Participants also agree to appoint an implementation manager to oversee their progress, and to report their progress at least annually to EPA. EPA provides technical information, training workshops, computer software, financing information, and public recognition.

As of January 13, 1995, the participants included 19 Federal partners, 17 States, 67 county or city partners, and 804 corporations (including 184 of the Fortune 500). In addition, the participants included utilities, lighting manufacturers, lighting management companies, distributors, and endorsing organizations.

Lighting accounts for 20-25 percent of all electricity sold in the United States, according to EPA. By joining Green Lights, "participants realize average rates of return on their initial investment of 30 percent or more. They reduce their lighting electricity bill by more than half while maintaining -- and often improving -- lighting quality." (6)

If Green Lights were fully implemented in all facility space in the United States, the result would be a significant reduction in energy use and related pollution. According to EPA, full implementation would result in a savings of $16 billion per year in electric bills as well as a 12 percent reduction in utility emissions of air pollutants. (7)

In fact, however, the reductions claimed by the program have been much more modest. As of January 1995, Green Lights participants had committed 4.3 billion square feet, about 5 percent of all U.S. commercial and industrial space, to the program. Completed upgrades were estimated to be saving $80 million in energy costs annually, 0.5 percent of the potential. In pollution terms, the Agency estimated that the program had reduced emissions of CO2 by 700,000 tons, "the equivalent of removing 132,400 cars from the road." (8) This represented 0.3 percent of the possible CO2 reduction estimated by EPA if energy-efficient lighting were installed everywhere. (9)

Energy Star Computers

Office equipment is the fastest growing source of electrical load in the commercial sector, according to EPA, accounting for 5 percent of commercial sector demand currently, but having the potential to increase to 10 percent of the total by 2000 in the absence of conservation measures.

The Energy Star Computer program is designed to lessen this demand by encouraging computer manufacturers to design products that "power down" when not being used. Since many computers are left on when not in use, "this 'sleep' feature can cut a product's electricity use by over half," according to EPA. (10)

This program appears to have had a remarkable degree of success. According to the Agency,

• - By August 1994, more than 300 computer and monitor manufacturers, representing more than 80% of U.S. sales, had joined the program and are producing Energy Star PC systems. Over 40% of all computers sold in the U.S. in the first year of the program (July 1993-June 1994) were Energy Star....
• - More than 45 printer manufacturers, representing more than 90% of U.S. sales, are producing Energy Star printers. Over 85% of printers sold in the U.S. in the first year of the program were Energy Star. (11)

Building on this success, the Agency has expanded the program to include copiers and fax machines, and plans to work with large corporations and organizations to promote the purchase of Energy Star products.

One potential limit to the success of Energy Star computers is the increasing popularity of what are called "screen saver" programs. A screen saver program switches on to show moving images (geometric shapes, toasters with wings, fish swimming, etc.) when a computer is not being used. The original idea was that changing patterns helped preserve the computer monitor, which otherwise could have been damaged from displaying the same image for hours on end. According to EPA, there is no longer a need for "screen savers" because the current generation of monitors will not be damaged from continually showing the same image. Instead, screen saver programs themselves are the problem, if the goal is to reduce energy consumption, for, rather than power down, computers equipped with screen savers continue to use energy as if the computer were being used for productive purposes, negating the sleep feature of Energy Star technology. Given the widespread use of such programs, the Energy Star program may have difficulty reaching its full potential.

A more immediate problem for the program, however, may be funding. In approving its recommendations for the FY 1996 EPA appropriation, July 10, the House Appropriations Subcommittee on VA, HUD, and Independent Agencies cut $11.4 million from the requested amount for Global Climate Change activities, including the Energy Star programs. In addition, language was included which "admonishes EPA to stop spending funds for programs, such as Energy Star, which duplicate or are substantially similar with other Federal or commercial programs." (12)

Energy Star Buildings

Energy Star Buildings is another EPA voluntary program aimed at reducing energy consumption and the related pollution from power generation. Building on the Green Lights and Energy Star computer programs, building owners are asked to commit to a five-stage building upgrade: 1) Green Lights; 2) building tune-up; 3) heating, ventilating, and air conditioning (HVAC) load reductions (includes buying Energy Star computer products); 4) fan system upgrades; and 5) HVAC plant improvements. EPA offers guidance packages, technical manuals, case studies, software to calculate savings, and a data base of financing programs.

This program began in 1993, with the selection of 24 "showcase" buildings to demonstrate the potential energy and cost savings achievable. The Agency plans to fully launch the program upon completion of the demonstration phase in the fall of this year. As a result, there are few data available to measure its accomplishments .

Like Energy Star computers, Energy Star Buildings appears to be targeted for cuts in the 1996 appropriations process.

Climate Wise

Climate Wise, a voluntary program run jointly by EPA and the Department of Energy, aims to stimulate actions that will reduce or mitigate emissions of greenhouse gases in all sectors of the economy. According to EPA, "Climate Wise will help companies build on current efforts by providing selected technical assistance and by recognizing cumulative corporate-wide reductions.'' (13) Companies in the program take such actions as altering production processes, switching to lower carbon-content fuels or renewable energy, substituting raw materials, implementing mass transit and car pool programs for employees, and auditing and tracking energy efficiency improvements. According to EPA, "Eight Climate Wise companies, representing more than 3% of U.S. industrial energy use, committed to actions which will reduce greenhouse gas emissions by more than 20 million metric tons by the year 2000." (14)

While the overall objective of this program is clearly within the mission of EPA and DOE, it is difficult to judge its effectiveness for several reasons. The amount of reduction projected is large: under the President's Climate Change Action Plan, it appears to represent about 20 percent of the total reduction of greenhouse gases necessary to return U.S. emissions to 1990 levels by 2000. The baseline against which reductions are being measured is not specified in EPA's report, however; thus, it is not clear whether this comparison is valid. (15)

Further, the wide range of potential actions to be taken by the Climate Wise companies makes it unclear how significant a role EPA is playing in stimulating the company actions. This is, of course, a potential problem in judging the effectiveness of all of the voluntary programs. But in most of the others, the focus is sufficiently narrow that EPA's sponsorship of the program and the related publicity concerning its participants' accomplishments may be assumed to have some role in bringing about the resulting action. In this program, the potential actions are so diverse, and in many cases so specific to production processes and locations, that one may perhaps question whether EPA's role isn't more that of scorekeeper than of catalyst.

Climate Wise may also be targeted for cuts in the appropriations process.

Wastewi$e

One of the newest of EPA's voluntary programs, Wastewi$e was launched in July 1994. It is a voluntary effort to encourage reduction of municipal solid waste by large businesses, who commit to "conduct three waste prevention actions, increase or improve their collection of recyclable materials, and increase the purchase or manufacture of recycled products.'' of the 369 companies who joined Wastewi$e in its first months, 142 were Fortune 1000 companies. There is also a Wastewi$e Endorser program for trade associations who agree to encourage their members to join and provide information.

Comprehensive data are not yet available for Wastewi$e program accomplishments .

Water Alliances for Voluntary Efficiency (WAVE)

The WAVE program encourages efficiency in the use of water. Like the lighting and computer products targeted by other voluntary programs, plumbing fixtures have seen significant improvements in recent years that allow delivery of comparable levels of service with significant savings in resource (water and energy) use. Thus, WAVE is attempting to do for water consumption what Green Lights and Energy Star are doing for lighting and computers.

In its initial phase, WAVE has focused on the lodging industry, a major consumer of water. Its first five partners (Hyatt, Sheraton, Outrigger, Saunders, and Westin) represent 432 U.S. hotel properties with more than 166,000 guest rooms. WAVE is also supported by a number of water service companies, equipment manufacturers and suppliers, and it is endorsed by the American Hotel and Motel Association.

In the future, WAVE plans to add commercial office buildings, schools, universities, hospitals, restaurants, other commercial businesses, and multi-family housing as target groups.

According to EPA, "WAVE members are expecting to reduce water usage by over 2.25 billion gallons per year, for an annual savings of nearly $8.5 million in water, sewer, and energy costs." (17) While substantial, this amount represents less than 0.1 percent of commercial sector water use, which totaled 8.3 billion gallons per day in 1990. (l8) If other major water users (domestic, industrial, and agricultural) are considered, the water savings represents an even smaller percentage of use.

PEST SMART

The Pesticide Environmental Stewardship Program (also known as PEST SMART) is among the newest of EPA's voluntary efforts. On December 12, 1994, EPA, the U.S. Department of Agriculture, and the Food and Drug Administration announced a partnership with six major agricultural groups and 17 major utilities to design and implement environmentally sound practices regarding the use of pesticides. PEST SMART has developed a set of guiding principles and will develop a Pesticide Environmental Stewardship Recognition Program.

Project XL

On March 16, 1995, President Clinton unveiled a package of 25 measures designed to "reinvent environmental regulation." Among these measures was Project XL (for excellence and leadership). Under Project XL,

EPA will support company projects to replace existing regulatory requirements with alternative environmental management strategies where the company can demonstrate that such strategies will achieve better environmental results than expected to be achieved under existing law.... The final strategy will be embodied in an enforceable document and contain provisions that will allow EPA, the State and the community to monitor progress toward achieving results. (19)

The idea behind Project XL is that there are cases in which cost savings can be realized and environmental quality enhanced through a more flexible approach that may be prevented by existing regulations. In the initial phase, 50 demonstration projects will be chosen. These projects are expected to help resolve a number of issues such as how to establish a baseline, how to measure results, etc.

Unlike some other voluntary programs, Project XL was singled out for praise when the House Appropriations Subcommittee on VA, HUD, and Independent Agencies marked up EPA's FY 1996 appropriation, July 10. Language was included which "expresses support for the direction the agency is pursuing with regard to projects like the Common Sense Initiative and Project XL, where flexibility and partnership-type relationships are fostered." (20)

POLICIES THAT ENCOURAGE VOLUNTARY ACTIVITIES

In addition to voluntary programs, EPA has also developed policies that promote voluntary activities by the regulated community. Two such policies are the environmental auditing policy and the Clean Air Act's Early Reductions program.

Environmental Auditing Policy

On March 31, 1995, EPA released a new policy on the use of evidence gathered through environmental audits. The policy seeks to encourage such audits by offering not to refer certain violations for criminal prosecution and by reducing civil penalties for violations voluntarily reported after being discovered through self-evaluations. In order to qualify for relief under the policy, the company must disclose a violation in a timely fashion and must not have been required under current laws or regulations to report it. This latter condition has been subject to controversy, since a number of environmental laws, including the Clean Water Act and the Resource Conservation and Recovery Act (RCRA), require companies to disclose violations. (21)

At least 14 States have already enacted legislation establishing an environmental audit privilege. The specifics of such legislation vary from State to State. Some States only protect information obtained in "routine" audits, a provision that may not protect information from one-time evaluations. Some States protect information only if a company classifies it with certain language, such as "private," "privileged," or ''confidential.'' States differ on whether companies are immune from civil prosecution, criminal prosecution, or both. All 14 of the States require that the violations uncovered be corrected, but how promptly varies from State to State. (22)

Since most environmental programs allow State or Federal enforcement of environmental standards, the State privilege laws cannot provide protection from Federal enforcement even where companies comply with the provisions of State privilege laws. To prevent such Federal enforcement, the House Appropriations Subcommittee on VA, HUD, and Independent Agencies, in its markup of EPA's budget July 10, approved language that "limits the use of funds for the Agency to take legal action against states or individual facilities when such facilities have performed self audits and have admitted violations in a manner consistent with state laws." (23)

At the same time, 36 States do not have an audit privilege law. Even if the subcommittee language is approved, there would be no audit privilege in those States. Hence the importance of a Federal policy.

The final status of EPA's audit policy is undergoing review. Public comments were accepted by the Agency through the end of May, and some revisions are expected before the policy is finalized. Issues raised include: the absence of protection in cases of violations detected and reported under statutes such as RCRA and the Clean Water Act, which require reporting of violations; whether to protect audit information from public disclosure; the degree to which companies should be protected from prosecution in cases of harm to human health or the environment; whether the policy can protect violators from citizen suits, which are allowed under most environmental statutes; and whether to extend protection to individuals involved in wrongdoing in addition to corporations.

Some in the regulated community are also concerned that a policy issued by the Agency can be revoked as easily as it is issued. As a result, there is some pressure for legislation to codify a Federal audit privilege applicable in all the States.

Early Reductions

Under Title III of the Clean Air Act Amendments of 1990, EPA will grant six-year extensions of the compliance deadline for existing sources of hazardous air pollutants if they achieve voluntary early reductions of pollution. To qualify for the extension, a facility must reduce emissions of hazardous air pollutants (when compared to 1987 emissions or a later base year) at least 90 percent prior to proposal of the applicable regulation governing emissions from the source category. Hazardous air pollutant regulations (known as MACT standards) are generally scheduled to be proposed before the year 2001.

This program was mandated by Congress in the Clean Air Act Amendments. It is not yet clear what impact the program will have, but early indications are that its impact may be relatively small. According to the General Accounting Office,

Participation in the Early Reductions Program has been limited. As of September 1994, EPA had only 40 active applications from facilities and had approved 12 for the 6-year extension, provided the applicants are able to demonstrate achievement of the required reduction. EPA of finials told us that the number of facilities that are eligible to participate in the program is unknown. As of June 1994, EPA had identified between 8,000 and 13,000 major sources of pollution that are subject to either a 1992 or a 1994 MACT standard, but officials recognize that the benefits of the program do not apply for all of the identified major sources. Thus, taking into account that the Early Reductions Program may have no practical application for some major sources, EPA officials estimate that fewer than 10 percent of the eligible facilities are participating in the program. (24)

OTHER PROGRAMS

In addition to the programs and policies outlined above, EPA has developed numerous pollution prevention programs that address specific industries and have some of the trappings of voluntary programs, but generally without numeric goals or other methods of measuring progress. Three of these are described below.

Design for the Environment

Design for the Environment "creates voluntary and cooperative partnerships between EPA, industry, public interest groups, and other government entities to:

• - Create standard methodologies for using risk information and provide access to that information;
• - Develop customer-focused information products to convey risk reduction and pollution prevention options; and
• - Provide incentives for industries to engage in risk reduction activities." (25)

The program has projects underway in five industries: dry cleaning, screen printing, printed wiring boards, aerospace, and chemicals.

Environmental Technology Initiative

The Environmental Technology Initiative (ETI), which was announced in the President's 1993 State of the Union address, has as its goal to spur the development and use of innovative environmental technologies and to enhance the competitiveness of the U.S. environmental technology industry. The focus of the program has been on small businesses, particularly the metal plating and finishing industries, with the intention "to increase its ability to comply with environmental requirements while containing compliance costs." (26) Future emphasis will be on the six industry sectors involved in the Agency's Common Sense Initiative. These are auto manufacturing, computers and electronics, iron and steel, metal finishing and plating, printing, and petroleum refining.

ETI has been among EPA's fastest growing programs under the Clinton Administration, with funding of $36 million in FY 1994, $68 million in FY 1995, and a requested $126 million in FY 1996. Despite strong support from the Administration, funding for ETI has been targeted for elimination, at least by the House. The House budget resolution called for the program's termination, and the House Appropriations Subcommittee on VA, HUD, and Independent Agencies agreed to cuts of $126,519,000 in ETI in its recommendations on the EPA appropriation, July 10. The Senate budget resolution and the conference report on the budget did not address the issue, however.

Compliance Assistance Centers

A new initiative to encourage voluntary compliance with environmental regulations is the development of Compliance Assistance Centers for specific industries. The first such centers focus on dry cleaning, metal finishing, printing, auto service stations, and small farms. In addition to providing "plain-English guides to compliance" with the range of regulations governing the industry (air, water, waste, etc.), the centers will provide information concerning pollution prevention.

As an incentive for industries to access the new centers, the President's Reinventing Environmental Regulation initiative promises that "EPA will provide up to 180 days for small businesses to correct violations identified through federal or state technical assistance programs." Thus, small businesses "can access compliance assistance without fear of fines and penalties." (27)

SUMMARY

This report has reviewed nine EPA voluntary programs as well as other programs and policies developed by the Environmental Protection Agency to encourage voluntary reductions in pollution.

Many of the programs address significant environmental problems, and most appear to promise real progress. Yet it is difficult to judge the effectiveness of EPA's role, first because the programs are so new that most do not have measurable results, and second because many involve activities that might have been undertaken even without the EPA program.

This report has attempted to place the programs in perspective, where possible, using both EPA data and other sources. A more complete evaluation would require additional years of program experience, in most cases. Whether that experience will be obtained is in question in some cases, as several of the programs have been targeted for cuts or elimination in the FY 1996 appropriations process.

Endnotes

1. The chemicals, which were chosen because of their toxicity and the large volume of releases to the environment, are benzene, cadmium and compounds, carbon tetrachloride, chloroform, chromium and compounds, cyanides, lead and compounds, mercury and compounds, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, nickel and compounds, tetrachloroethylene, toluene, trichloroethane, trichloroethylene, and xylenes.
2. Bureau of National Affairs, "EPA 33/50 Voluntary Initiative Labeled 'Sham' by Environmental Group," Chemical Regulation Reporter, June 3, 1994, p. 263.
3. U.S. General Accounting Office, "Status of EPA's Efforts to Reduce Toxic Releases," Report No. GAO/RCED-94-207, September 1994, p. 6.
4. Seema Arora and Timothy N. Cason, "A Voluntary Approach to Environmental Regulation: The 33/50 Program," Resources, Summer 1994, p. 9.
5. Ibid.
6. U.S., EPA, Office of Air and Radiation, "Introducing ... the Green Lights Program," November 1993.
7. Ibid.
8. U.S, EPA, Office of Air and Radiation, "Green Lights Update," March 1995, pp. 1 and 3.
9. Estimated potential reduction in CO2 emissions is from U.S. EPA, Office of Air and Radiation, Green Lights Third Annual Report," March 1994, pp. 2-3.
10. U.S. EPA, Office of the Administrator, EPA Pollution Prevention Accomplishments: 1994, Report No. EPA 100-R-95-001, Spring 1995, p. 16.
11. Ibid.
12. U.S. Congress, House, Committee on Appropriations, Subcommittee on VA, HUD, and Independent Agencies, "Fiscal Year 1996 Markup Table," as reprinted in Bureau of National Affairs, Daily Environment Report, July 12, 1995, p. E-3.
13. EPA Pollution Prevention Accomplishments: 1994, p. 17.
14. Ibid.
15. It is also unclear whether the 20 million ton reduction projected represents the reduction in the year 2000, or the cumulative reduction between now and the year 2000. If the latter, the significance of the reduction, as measured against the goals of the Climate Change Action Plan, is less. Attempts to reach EPA staff to resolve these questions were unsuccessful.
16. EPA Pollution Prevention Accomplishments: 1994, p. 25.
17. Ibid., p. 18.
18. U.S, Geological Survey Circular 1081, Estimated Use of Water in the United States in 1990 (Washington: Government Printing Office, 1993), p. 30.
19. President Bill Clinton, Vice President Al Gore, Reinventing Environmental Regulation, March 16, 1995, p. 36.
20. House Appropriations Subcommittee Markup Table, previously cited, p. E-3.
21. See Bureau of National Affairs, "Many Violations May Not Qualify for Penalty Reductions Under Audit Policy," Daily Environment Report, April 19, 1995, p. AA-1.
22. Patchwork of State Privilege Laws Illuminates Need for Federal Policy," Bureau of National Affairs, Daily Environment Report, June 22, 1995, pp. A-14, A-15. The article reports the remarks of Doug McLeod, an attorney with Blackwell, Sanders, Matheny, Weary & Lombardi, of Kansas City, in a speech to the Air and Waste Management Association.
23. House Appropriations subcommittee, previously cited, p. E-3.
24. U.S General Accounting Offices Toxic Substances: Status of EPA's Efforts to Reduce Toxic Releases, Report No. GAO/RCED-94-207, September 1994, p. 8.
25. EPA Pollution Prevention Accomplishments: 1994, p. 12.
26. Ibid., p. 20.
27. Reinventing Environmental Regulation, p. 12.