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Implementing Environmental Protection with a Sector Approach

Conclusions and Recommendations

While this document is intended to shed light on a particular aspect -- implementation -- of a particular approach to environmental protection -- the sector approach -- it has unavoidably confronted more general issues.  Our concluding overview of the roadmap therefore begins on a wide scale, encompassing some fundamental issues for environmental protection policy.  Within this broader context, the full potential of sector approach can best be realized.

The implications of the preceding sections can be summarized in the following propositions:

• The environmental protection mission is changing.  It is evolving from crisis confrontation to continuous improvement.  Approaches which worked well in the past may need to be modified or supplemented for the challenges to come.
• The greatest threat to the environment is no longer the result of a few bad actors engaging in illegal activity.  It is a by-product of many well-motivated organizations and individuals pursuing their legitimate interests in a vibrant economy.
• The expertise and the motivation for improving overall environmental performance resides within the regulated community.
• A collaborative approach is the most effective, and the most cost-effective way to enlist that potential in the service of environmental improvement.
• The performance of environmental regulatory agencies (national, state, and local) must be evaluated according to their effectiveness in advancing environmental improvement as a whole.  Performance measurement must be based on a fully developed environmental cost-benefit framework.

The cost-benefit standard is the linchpin of the system.  If regulators are still accountable for meeting the old standards, they will excel at accomplishing the old mission.

We should emphasize that the cost-benefit framework is recommended here on its own merits, not because it intrinsically favors any one approach over any other.  Indeed, there may well be situations, today and in the future, where a command-and-control attitude, coupled with vigorous enforcement and an adversarial stance, is the most effective way to deal with a recalcitrant problem.  

That said, the above propositions indicate that a sector approach has much to offer environmental regulatory agencies as they adapt to the evolving requirements for effective environmental protection.

• Of all the alternative ways to approach environmental regulation, the sector approach provides the best opportunities for collaboration.  Collaboration that mobilizes industry's latent ability to improve environmental performance is likely to be more cost-effective than command-and-control rule making and adversarial enforcement.
• The sector approach can also contribute information needed to develop a sound cost-benefit framework:
  • On the cost side, sector-based programs are well suited to develop compliance cost information.
  • On the benefit side, co-implementers already receive much of the information needed to measure environmental impact from ongoing operations.  In addition, co-implementers and companies working in collaboration are well suited to develop information regarding potential benefits to be expected from process improvements in a particular sector.  

With this context and motivation, and with the findings of the previous sections, the path forward for sector-based programs is clear:

1. Continue involving sectors in collaborative efforts.  A good way to start activities in a new sector may be to initiate regulatory awareness programs for sectors for whom the rules are changing.  Involve local co-implementers, particularly in localities where the sector is concentrated.
2. Continue supporting voluntary "beyond compliance" programs in appropriate sectors.  Documentation of economic incentives associated with pollution prevention and process improvement may be a particularly effective way to stimulate further participation in such programs.  Similarly, documentation of environmental benefits resulting from program activities can be particularly useful for evaluating the program in a cost-benefit framework.
3. Work with successful facility-based programs to extend their reach.  Develop templates to help spread environmental management systems and other tools beyond the pilot stage to facilities throughout a sector.
4. Encourage the replication of successful sector-based programs at the state and local level.
5. Promote the development of sector expertise networks, and the means for providing co-implementers convenient access to sector experts in other localities. 
6. Promote the development of the cost-benefit approach to measuring environmental performance.  

Thus, the ideal sector-based program might involve a collaborative effort with a trade organization working to develop compliance cost information and co-implementers working to develop environmental impact information, a synthesis of these efforts into a model cost-benefit analysis for potential environmental improvement activities relevant to the sector, and follow-on efforts to adapt the model to related sectors.  Many of these elements already exist in ongoing programs.  Knitting them into a coherent framework, with the ultimate objective of providing a sound cost-benefit framework while exemplifying successful collaboration, might be the best contribution that the sector approach can provide for the environmental protection enterprise as a whole.

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