New Tools for Environmental Protection Education, Information, and Voluntary Measures (2002) / Chapter Skim
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16. Challenges in Evaluating Voluntary Environmental Programs
16. Challenges in Evaluating Voluntary Environmental Programs
Pages 263-282
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From page 263... ...
The discussion that follows focuses on conceptual issues in evaluation of voluntary programs, setting aside for the moment questions of political will and adequacy of administrative resources to conduct program evaluations (Gormley, 2000~. Policy evaluation is a difficult task, one that is too seldom undertaken for traditional regulatory as well as novel voluntary programs.
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From page 264... ...
Although most voluntary agreements are nonbinding, some take the form of legally binding contracts.) In contrast to voluntary agreements, governmental efforts to persuade target groups to change their behavior via voluntary challenges or public voluntary programs typically involve less arm twisting.
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From page 265... ...
Inventories can also document changes in releases reported to complementary voluntary challenge programs. In addition to these government-sponsored voluntary programs, a wide variety of nongovernmental or unilateral programs exist (many of which are reviewed by Nash, this volume, Chapter 14~.
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From page 266... ...
However, it also can be an issue for government-sponsored voluntary programs which, unlike regulatory programs, typically do not rely on coercion to compel disclosure of monitoring nor threaten inspections to verify firms' reports. The extent of this problem was demonstrated by a study of 137 voluntary agreements by the European Commission in 1997, which found that 118 had no requirement for firms to report the results of their compliance monitoring,
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From page 267... ...
, while the fine line between cooperation and capture already has been noted (Ayres and Braithwaite, 1992:55~. Closely related to this distinction between ultimate and intermediate criteria is the distinction between voluntary programs that establish environmental performance objectives and "voluntary environmental management systems," which leave the setting of performance objectives up to individual participants and focus instead on management approaches to ensure that those goals are achieved.
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From page 268... ...
Second, a firm may be motivated by market pressures for environmental improvements from investors, lenders, insurers, customers, or workers.~° Third, a firm might opt for voluntary measures beyond those prompted by cost savings and "green" market pressures in order to forestall or avoid mandatory regulation or legal liability. A critical question in that case is whether the incentive for voluntary action lies in reducing costs by accomplishing the same environmental objective with greater flexibility than allowed by traditional regulation, or rather in reducing costs by meeting less demanding environmental objectives.
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From page 269... ...
However, government-sponsored information dissemination and technology transfer programs nonetheless may help firms recognize and take advantage of waste reduction opportunities and energy efficiency improvements (Storey, 1996~. Similarly, firms facing green market pressures also have incentives to change their behavior regardless of the existence of governmental voluntary programs.
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From page 270... ...
Similarly, a Canadian business survey reported that 95 percent of firms cited compliance with regulations as one of the top five factors motivating their environmental improvements. One implication is that in evaluation of voluntary agreements in particular, the applicable comparison is not necessarily the status quo or even the business-as-usual baseline, but rather what would have happened had regulations been adopted instead.
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From page 271... ...
33/5012 In 1991, the EPA challenged the business community to voluntarily reduce its releases and transfers of 17 high-priority chemicals by 33 percent by the end of 1992 and by 50 percent by the end of 1995, dubbing the program "33/50." Consistent with the previous discussion of voluntary challenges, requirements for participation were very flexible. A firm needed only to write to the EPA pledging some degree of reduction of its discharges of any of the 33/50 chemicals.
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From page 272... ...
The fact that participants in the 33/50 program made greater reductions than nonparticipants does not necessarily indicate that those reductions were prompted by the 33/50 program. Firms already inclined to make substantial reductions of 33/50 chemicals, whether in response to negative publicity associated with mandatory reporting of discharges to TRI, market forces, cost savings, or concurrent regulatory requirements, simply may have been the ones inclined to sign on for credit.
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From page 273... ...
Harrison and Antweiler (2001) found that facilities reporting on-site releases of regulated substances to the Canadian National Pollutant Release Inventory reported greater reductions of those substances over time than of other substances.
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From page 274... ...
NPRI The discussion of the 33/50 and ARET programs notes the potentially confounding influence of toxic pollutant release inventories in both countries. Firms may have been motivated less by the positive incentives in the form of public recognition offered by the voluntary challenge programs as discussed earlier, and motivated more by negative incentives (shame)
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From page 275... ...
for reduction of their TRI releases and transfers. These studies suggest a need for greater attention to regulation and liability in accounting for the rapid progress apparent in both discharge inventories and the voluntary challenge programs predicated on them.
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From page 276... ...
es (Harrison and Antweiler, 2001~. Indeed, a single Quebec facility, Kronos Canada, which adopted process changes in response to regulatory enforcement actions undertaken by both the federal and provincial governments in the early l990s (Picard, 1992; Hamilton, 1993)
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From page 277... ...
These findings, although far from constituting a complete risk assessment, reinforce the call for program evaluations to go beyond mere "outputs" and "outcomes" to consideration of "impacts." CONCLUSIONS The one clear area of consensus among students of voluntary approaches is that there has been too little attention to evaluation of either the economic or environmental benefits of voluntary programs (Storey, 1996; Davies and Mazurek, 1996; European Environment Agency, 1997; Beardsley, 1996; National Research Council, 1996; OECD, 1999; Mazurek, this volume, Chapter 13~. In part, this reflects the novelty of voluntary approaches; it is simply too early to assess their effectiveness in many cases.
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From page 278... ...
from differences resulting from lack of comparability between the "treated" and "untreated" groups. The tendency to assess environmental progress only relative to reference years almost certainly exaggerates program effectiveness, because some fraction of improvements typically would be attributable to market incentives and/or concurrent regulatory requirements in the absence of the voluntary program (to say nothing of the scenario in which the reference year is several years prior to the launch of the voluntary program)
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From page 279... ...
NOTES 1 Although such contracts are legally binding, they can still be considered voluntary agreements because parties enter into the contract voluntarily. 2 For reviews of European experience, see European Environment Agency (1997)
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From page 280... ...
561. European Commission Directorate 1997 Study on Voluntary Agreements Concluded Between Industry and Public Authorities in the Field of the Environment.
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From page 281... ...
Antweiler 2001 Information Dissemination vs. Environmental Regulation: The View from Canada's National Pollutant Release Inventory.
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From page 282... ...
Cowie 1997 Reducing toxic chemical releases and transfers: Explaining outcomes for a voluntary program. Policy Studies Journal 25(1)
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