The Greening of Industrial Ecosystems (1994) / Chapter Skim
Currently Skimming:
From Voluntary to Regulatory Pollution Prevention
From Voluntary to Regulatory Pollution Prevention
Pages 98-107
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From page 98... ...
discussed by Allenby in this volume, spans the distance from engineers attempting to redesign products and processes, to government officials seeking new incentives to encourage pollution reduction, to heads of state negotiating pollution prevention principles in international agreements based on sustainable development. Part of the attractiveness of pollution prevention rests on the perception that it allows all interested parties to achieve their separate goals.
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From page 99... ...
Pollution prevention tends to reduce the cross-media pollution that old-style regulation sometimes produced. To the extent that industry undertakes most pollution prevention measures voluntarily, the costs of regulation can be reduced.
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From page 100... ...
Conflicts have yielded to sustainable development and other promises of benefit to both environmental and economic interests. POLLUTION PREVENTION: A CRITICAL REAPPRAISAL Understanding how the current enthusiasm for pollution prevention may be overstated requires drawing upon economics, law, and policy analysis of how governmental programs work in modern American society.
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From page 101... ...
The initial enthusiasm for pollution prevention has developed in large part because pollution prevention is seen to be profitable to companies that invest in it. The first pollution prevention activities have in fact proven relatively inexpensive to implement, and some yield relatively high rewards the harvest of low-hanging fruit.
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From page 102... ...
The pollution prevention philosophy suggests that it is possible to phase out or phase down the use of the 189 toxic chemicals targeted by Section 112 of the 1990 amendments to the Clean Air Act. Indeed, one prominent EPA pollution prevention program encourages companies to attempt this task, ahead of the mandatory rollbacks that the statute will require later.
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From page 103... ...
-So far we have heard only friendly talk about existing collaborations, but such talk may have ominous overtones when viewed from the perspective of a disgruntled competitor or the Justice Department. The EPA newsletter on pollution prevention reported efforts to develop a pollution prevention technical information exchange team among several major manufacturers.
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From page 104... ...
POLLUTION PREVENTION AS A NEW REGULATORY TECHNIQUE While government's role in pollution prevention currently appears to emphasize awards, university courses, research programs, and voluntary goals and deadlines, "regulatory" pollution prevention has also clearly made an impressive debut, including substance bans, technology specifications, and incorporation of pollution prevention obligations in actions related to permits and enforcement. While this paper focuses on federal pollution prevention, it is important to stress that the states have been at the forefront of pollution prevention activity over recent years.
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From page 105... ...
Citing the 1990 Pollution Prevention Act, which requires the EPA to review all regulations of the agency prior and subsequent to their proposal to determine their effect on source reduction, the EPA has created its Regulatory Targeting Project covering proposed rulemaking for all media affected by 17 major industries. Under this approach future rules and permits will contain pollution prevention measures wherever possible.
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From page 106... ...
Further, although much- of the pollution prevention optimism focuses on industrywide efforts to develop goals and strategies, in permitting and enforcement individual companies or facilities may be left on their own. Although an industrywide coalition may have substantial bargaining power in discussing pollution prevention goals with EPA, an individual facility or company has considerably less stature.
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From page 107... ...
The entanglement of pollution prevention with regulation almost inevitably will limit the flexibility that industry is hoping to find in nonadversanal pollution prevention. Thus industry, government, and environmental groups must critically examine the inner workings of pollution prevention and be vigilant to deter it from becoming a rationale for national industrial policy and a more intrusive form of regulation.
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