Presentation on theme: "Industrial Footprint Project"— Presentation transcript:
1 Industrial Footprint Project Regulatory Performance Advisors, November 13, 2003Industrial Footprint ProjectCarol KraegeWashington State Department of EcologyI’m the manager of the Industrial Section- a group of 25 people with multi-media responsibility. We regulate the largest industries in the state- pulp and paper/ aluminum smelting/ oil refining. We do all the environmental regulation – air/water/waste/cleanup and all the functions are done by one engineer- permitting / inspections/ enforcement. In addition, I’ve recently taken on management of the state’s PBT program, which is just in its infancy, but was put in my group because it is a multi-media activity as well. This project came out of our experiences in the cross program world
2 Regulatory Performance Advisors, November 13, 2003 What’s a footprint?A holistic measure of the impacts of a facilitySocialEconomicEnvironmentalConceptually, not very complicated- in practice, we expect it to be a little more difficult
3 Regulatory Performance Advisors, November 13, 2003 Why a footprint?The current regulatory system often frustrates progressHigh cost, often for small returnGlobal and local problems persistPermits become a battlefieldPriorities are driven by piecemeal laws, not environmental needsImportant concerns aren’t addressed; e.g. global warming, resource depletion, energy and water conservation, habitat/ species loss, local issues such as odorsNo framework for prioritizing among issues, impactsMuch of focus is on administrative mattersRules are prescriptive, lack flexibility
4 Regulatory Performance Advisors, November 13, 2003 With Limited Resources…Footprint ApproachTraditional RegulationStart with Footprint MeasurementStarts with Laws, StandardsWhat a facility's “footprint” encompasses and how to measure it are not simple questions, as we’ll see later.We started out with the idea that it might be measured much like sticking a thermometer in it – this idea has been used in other contexts, e.g. to quantify the footprint of nations or other human populations on the earth’s resources and waste assimilative capacity, with many simplifying assumptions. To attempt this for an industrial facility, where we might be concerned with such disparate types of impacts as cancer risks from air emissions to odors, to greenhouse gas emissions, so many assumptions would have to be made, and subjective judgments as to their relative significance, that it became clear that a participatory, consensus-driven process is needed to address them.Results:Compliance, and Maintenance +/- of Facilities Regulated Environmental FootprintHypothesis:Greater Reduction in Facility’s Overall Environmental Footprint is Possible
5 Regulatory Performance Advisors, November 13, 2003 If you want to reduce the footprint,which do you measure?RegulationsLawsOR?HereHere’s another way of looking at it.“What You MeasureisWhat You Get”RegulationsLaws
6 Facility Reporting Project Regulatory Performance Advisors, November 13, 2003Facility Reporting ProjectThe Facility Reporting Project (FRP) is a multi-stakeholder initiative to develop a generally-accepted facility-level economic, environmental and social sustainability reporting framework.We looked at a lot of multi-media measurement schemes and settled on the FRPWe are participating in the pilot of the FRP and have access to Ceres for help with stakeholders, etc.FRP was designed for facilities to report, so we are using the indicators for a different purpose, but we believe it will serve our purposes well, plus it’s being vetted by industry now, so it helps with credibility.
7 What should be measured? Economic IndicatorsPurchase of local goodsTotal payrollTaxes and subsidiesDonationsLocal infrastructure investment
8 What should be measured? Social IndicatorsLabor practices and decent workEmploymentManagement relationsHealth and safetyTraining and educationDiversity and opportunityHuman RightsSociety
9 What should be measured? Environmental IndicatorsMaterialsEnergyWaterBiodiversity and natural habitatsEmissions, effluents and wasteComplianceNuisance and quality of life
10 How will we get the data? Start with data we already have Other publicly available dataData directly from facilitiesUse grant funding for a contractor to assist in data collection and analysis
11 How would a footprint approach work ? Collaborate with stakeholdersChoose indicatorsMeasure industry’s footprintUse the measurement to drive priorities, actions
12 How can the footprint be used? Provide a performance measurement tool for individual facilitiesProvide a baseline for sectorsProvide a basis of comparison between facilitiesAssist regulatory agencies in prioritizing workServe as a building block to a more effective regulatory framework
13 Short term goalsFind out if the process of developing agreed upon indicators leads to a credible footprintFind out if footprint measurement tells us more than we knew beforeFind out if footprint measurement makes priority setting easierFind out if footprint measurement is sensitive enough to measure progress
14 Possible benefits for industry Regulatory Performance Advisors, November 13, 2003Possible benefits for industryPublic and peer recognitionMore flexibility to accommodate changesReduced administrative burden in non-target areas in exchange for better-than-required performance in target areas.Increased competitiveness and viabilityImproved relations with stakeholdersThere’s a lot of work to be done in this arena, we have been focused on figuring out how to do the measurement. To get companies to share data, we will…. Develop a stakeholder involvement plan
15 Possible Benefits to Regulators Better Environmental ResultsConserve valuable resourcesMore responsive processAddress issues of concern to community, workers, interest groups, etc.Make industry, community more sustainable
16 Possible Benefits to Communities Save local jobsKeep local economy strongReduce confrontation, costly appealsGet things done
17 Stakeholder Involvement Local communitiesInput regarding selection of indicatorsInput regarding prioritiesEducation about the millFacilitiesFocus on pulp and paper industryPursue consensus regarding indicatorsEducation about community needs
18 Regulatory Performance Advisors, November 13, 2003 Success MeasuresCredible measureBroadRobustCost-effectiveSafeTransferableInformative
19 Success Measures Substantial environmental improvement Facility performance does not regress in any areaProgress is measurableGood faith/partnering is essential
20 Regulatory Performance Advisors, November 13, 2003 ExampleA couple examples of what it might look like in visual summary form:Profile aggregates impacts of similar types, e.g. several types of greenhouse gasses. Relative heights aren’t comparable but facilities can be compared with each other.
21 Some Likely Concerns Current Laws & Rules won’t go away EPA won’t allow itWe’ll get suedWe’ll lose our ability to sueIt’ll cost too muchIt’ll allow industry to back off on protectionsIt’ll start a bad precedentCongress and the legislature already set policyEcology has no business…
22 Long term possibilities Develop a single permit for air, water and wasteIdentify facility specific prioritiesConsider community needsConsider facility opportunitiesDevelop incentivesPursue changes in state and federal laws to improve flexibility and performance
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