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into which media at what times. The importance of such a system is identified by a number of European Community Directives which require member countries to bring these into existence and stipulate certain conditions for their operation (see Table 4). Given the number of possible variables, most permitting systems are highly complex. They have frequently grown over many years, with layer after layer of permits superimposed on each other.

Attempts are currently under way in several countries to develop more integrated systems of permitting that allow authorities to consider all environmental variables at the same time.15

Permitting systems reflect many variables, including the administrative culture of countries. Federal systems typically require more complex permitting structures, particularly when levels of government are not integrated (as in the United States), so that regulatory requirements and permits become primary means of communicating priorities between levels of government. Countries with a strong civil service tradition can rely on continuity in public administration to a greater extent than countries like the United States or the Netherlands where civil service is but a career station for many individuals. A strong civil service tradition generally results in more stable (some would say more rigid) administration. In countries with a strong civil service, comparable stability is frequently to be found in the staffing of private sector enterprises so that long-term relationships between administrators and enterprises can develop. Such relationships have both positive and negative results. All parties can afford to take a medium- to long-term perspective, relying on the continuity of the relationship to ensure that goals that have been postponed are also met. The need to deal again and again with the same people make commitments more readily enforceable since the alternative is to encounter difficulties at subsequent stages. On the other hand, lack of stability in relationships can lead to more aggressive pursuit of particular goals since delay is tantamount to failure. This fosters more confrontational relationships.

All of these factors in the permitting system will tend to impact the form and substance of environmental regulation. It is impossible in practice to determine the exact nature of these impacts since they can be both positive and negative.

Comparing Costs

The cost of environmental protection measures is an obvious measure of economic impact and appears to lend itself readily to comparison. Two problems arise, however. Comparing costs tends to obscure the related benefits, not only through environmental improvement but also through gains in efficiency. For example, the Canadian authorities moved in the mid eighties to significantly reduce acidifying emissions. This included major emission reductions at a nickel smelter in Sudbury, Ontario, the largest single source of sulfur dioxide emissions on the North American continent. The new requirements caused the operator of the smelter to rethink its smelting operations and undertake a far-reaching redesign

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