PPI | Briefing | May 1, 1999
Second Generation of Environmental Stewardship
Improve Environmental Results and Broaden Civic Engagement
By Debra Knopman and Emily Fleschner
It would be sheer coincidence if the first generation of national environmental laws
and
regulations conceived 30 years ago would fit all of our needs at the start of the 21st
century.
Back then, most Americans lived in cities. The economy was dominated by heavy
industry.
Smokestack factories and big city sewers were Public Enemy No. 1 when it came to the
environment. The Clean Air Act, the Clean Water Act, the Superfund abandoned waste
site
law, and other laws passed between 1970 and 1986 were focused mostly on controlling
large sources of pollution.
Thirty years later, the post-World War II heavy industrial economy has grown
into a new service economy marked by rapid technological change, globalization, and
high-speed communications.1 A predominantly
urban and rural America in the 1970s is now a suburban America in the 1990s,
consuming
more land and commuting greater distances.2
Environmental concerns have shifted from a single-minded focus on big sources of air
and
water pollution to more diffuse issues of region-wide smog, watershed degradation,
habitat loss, and global warming.3 Instead of just
reacting to pollution control mandates, some leading businesses are now redesigning
their
production and products to create less pollution and use fewer natural resources in the
first
place.4
Environmental policy must be modernized to keep pace with the dramatic
transformations in the environment, economy, and population. The first generation of
rules
simply cannot get the job done:
- Two-fifths of smog-causing nitrogen oxides come from factories and power plants.
The
rest comes from cars, trucks, railroads, airplanes, and other miscellaneous
non-industrial
sources whose actual emissions are difficult to control under Clean Air Act rules.5
- Agricultural run-off--not included in the Clean Water Act permitting program--is
now
the most extensive source of water pollution, affecting 70 percent of rivers and streams
failing to meet water quality standards.6
- More than two-thirds of greenhouse gas emissions--totally unregulated under the
Clean Air Act--come from electricity consumed to heat, cool, and light homes and
buildings, and from fossil fuels for transportation; industry energy use accounts for the
remaining third.7
- More than two-thirds of threatened and endangered species reside on private lands
where the
Endangered Species Act is least effective.8
- Of the approximately 3000 high-production chemicals in commercial use as
feedstock,
pesticides, or consumer products, the most basic information about their effects on
human
health is unavailable for about 75 percent of them, a striking sign of dysfunction in the
23-
year old Toxic Substances Control Act.9
With varying degrees of conviction and success, the Clinton Administration has
worked the edges of existing rules to cope with these problems. Their
"reinvention" initiatives--modest by design and constrained by their own
rules
and bureaucratic cultures --are neither broad nor deep enough to make a big difference
in
environmental quality or the cost of compliance with the old rules.
Congress should bring environmental policy into line with the new economy and
changed environmental conditions. A second generation of policies should build on
past
success, capitalize on advances in information and monitoring technologies, and thrive
on
progressive governance. Here are the three core ideas of a second generation strategy:
Better information will drive innovation and improve accountability.
When
first generation policies were initiated, public information about air and water quality
was
sparse and anecdotal. Public disclosure of the pollution arising from municipalities and
companies was virtually nonexistent and technologically impractical. Access to the
sparse
information that did exist about chemical and other environmental risks was highly
centralized in filing cabinets and mainframe computers buried in government offices.
When the federal government increased its role in environmental protection in the early
1970s, Congress chose to mandate technologies for pollution control, in part because the
information needs of a more customized approach were beyond technical and financial
capacities.10
Capitalizing on new monitoring and information technologies, "trust
but
verify" is within reach in a second generation strategy. Companies, states, and
communities can be granted flexibility to meet air, water, and other standards in
their own
way, but they need to back their commitments with timely, accurate, publicly
available data
from air, water, and other environmental monitoring. For example, company
websites could
post daily, weekly, and monthly monitoring reports and relate the incoming
information to
the pollutant levels allowed by the state and the Environmental Protection Agencey
(EPA).
11 This information also could prove valuable
to
investors, insurers, and bankers who are in the business of assessing company
management.
The financial sector could make it similarly advantageous for states and communities
to
provide comparable information.12
Civic engagement is vital for solving place-based environmental
problems. In first
generation policies, federal and state regulatory actions--often taken piecemeal, one
agency and law
at a time--have tended to trump citizen-led environmental problemsolving. Designing
solutions for
specific places has traditionally been viewed as impractical with such a weak base of
environmental
information and too few technical experts to go around.
In a second generation strategy, problem-solving at the community and
regional
level--known as "civic environmentalism"13 --is a must for dealing with endangered species,
urban redevelopment, and sprawl-related land-use issues. For civic
environmentalism to
work, citizens, communities, and businesses must be willing to take responsibility for
the
environmental consequences of their actions. In return, government has an
obligation to
create effective regulatory tools, support research, and provide resources to ensure
that civic
responsibilities are understood, fair, and fulfilled.
Market-based incentives and regulatory flexibility will improve performance
and spur
innovation. First generation regulations may begin as environmental performance
standards,
but they tend to morph into de facto mandates to use a specific technology to control
pollution--
usually at the end of the pipe when the pollution enters the air or water. In the old,
more stable, and
less diverse economy, uniform "command and control" rules were not the
barrier to
innovation and adaptation that they are in today's fast-paced and growing economy. It
is an
anachronism that government regulators are still trying to pick technological winners in
pollution
control.
Instead of measuring success by compliance with prescribed technologies, second
generation
approaches focus on environmental results and make responsible behavior pay off. To
reduce
pollution--and better yet, prevent it--federal and state regulators should routinely offer
economic
incentives such as caps on emissions that apply not just to a single smoke stack but
across an entire
facility; emission and discharge trading; and expedited permitting. New approaches
should provide
incentives for pollution prevention, product redesign, and environmental performance
agreements
between manufacturers and suppliers. The right kind of incentives will improve the
environment,
stimulate technological innovation, and reduce transaction and compliance costs. For
example,
trading in sulfur dioxide emissions has reduced emissions more than 35 percent below
allowable
levels, encouraged the switch to low sulfur fuels, and reduced costs of regulation by
about $2
billion.14
The sharply partisan political climate in Washington has stifled constructive
national debate on
modernizing environmental policy, despite a plethora of think tank and academic
consensus building
and policy prescriptions for modernization.15 In
1995 and
1996, the 104th Congress demonstrated how not to change environmental regulation:
agency-bashing,
undermined enforcement, and budget cuts for environmental science. The 105th
Congress remained
mostly in gridlock. Now, the 106th Congress has gotten off to a discouraging start in
the House by
passing two bills, one aimed at blocking the full debate of environmental, health, and
safety
measures, and another intended to undermine enforcement of reporting
requirements.16
In reaction to retrograde challenges to the status quo, some in the environmental
community and the Administration continue to play defense, suggesting that second
generation
legislation is unnecessary and even dangerous in this sharply partisan climate. In fact,
EPA is busy
with dozens of reinvention initiatives.17 The
states are
proceeding with many creative innovations of their own.18
Federal environmental law is loaded with flexibility that only now is being fully
explored.19 Beyond these reasons, the road between Capitol
Hill and
the White House is littered with failed attempts to amend existing environmental laws.
Congress has
revamped and updated only two major environmental laws in the last eight years.20
All these reasons to just say "no" to legislation have some short-term
political merit, but none meets the need for a legal framework to guide modernization.
Second generation legislation would overcome persistent barriers to innovation and
ratify the
good efforts now underway in the states and the EPA. Here is what the legislation
should do:
Legalize Reinvention. Murky legality has hamstrung the Clinton
Administration's
reinvention efforts from the start. Take the flagship Project XL as an example: Project XL
(standing
for excellence and leadership) was intended to point the way to "cleaner, cheaper,
faster"
regulatory approaches by focusing on environmental results, not process. Since its
inception, EPA
has relied on time-consuming, Houdini-like legal contortions to give XL agreements
with industry
a firm legal basis. While most of the other reinvention projects underway at EPA are
commonsense
fixes to ossified agency practices (like writing new regulations in "plain
English"),
bolder initiatives have been inhibited by existing rules. Further, EPA employees have
yet to hear
Congress speak in law (outside of appropriations report language) about the
importance of
reinvention. Without a congressional stamp of approval, business as usual rules the
day and the
agency's commitment to change remains uneven--from top political appointees down to
regional
office managers. Leading state innovators are often caught in the web of EPA's
ambivalence to
change.
Second generation legislation would clear the ambiguity over reinvention
efforts
that are now stretching the legal limits of existing law and regulation. The ground
rules
would be laid for how innovative strategies would be enforced, and the public could
begin
to see working examples of a more transparent and more effective regulatory
approach.
Under an umbrella of environmental priorities, states, companies, trade groups,
communities,
and others could advance their ideas to achieve better environmental outcomes than
are
possible under current regulation without the cloud of legal uncertainty. The
legislation,
while retaining congressional authority to change the underlying laws, should clarify
that
the EPA administrator has the authority to waive regulations if necessary.
Congressional actions should be guided by recommendations from the EPA
Administrator about which changes would result in more environmental benefits
achieved with greater efficiency.
Target Environmental Priorities. At last count, the EPA had no fewer than
40
reinvention initiatives underway--from paperwork reduction to the more profound
paradigm-shifting
ideas of Project XL and the Common Sense Initiative (CSI). CSI is designed to solve
regulatory
problems affecting whole industrial sectors like metal finishers and iron and steel
companies.21 States have even more pilot programs on the
burner.22 Notwithstanding the strategic planning process
now
required under the Government Performance and Results Act, EPA has yet to make
clear how its
choice of initiatives, pilot programs, and other experiments fit into a larger picture of
environmental
priorities.
Second generation legislation would require EPA to set environmental priorities for
innovative
strategies. The focus should be on new strategies to solve problems still lingering under
conventional
regulation, like run-off from large animal feeding operations and regional smog, as well
as emerging
problems now outside of current law and regulation like habitat conservation and
climate change.
EPA needs to choose the reinvention activities that are likely to have the biggest
environmental
payoffs. EPA is currently reviewing its reinvention activities, but it needs to broaden its
view beyond
the fence of existing law, and set priorities that are publicly transparent and politically
durable.
Turn Good Ideas Into Systemwide Change. Pilot programs are fine if the
good ones
are ramped up to nationwide use. With some important exceptions,23 there are too few signs that EPA's major
reinvention efforts
will ever make it to the big time. State innovations tied to their implementation of
federal programs
are similarly constrained.
Second generation legislation would push EPA and the states to think early
and often
about how to move a successful pilot program into national use. It would also push
EPA to
continually assess its own performance, learn from its mistakes, and build on its
successes.
Program evaluation is another place that better environmental and economic
information
could make a big difference. EPA would need to restore its economic and policy
analysis
capacities to rise to this challenge.24
Equip citizens, regulators, and investors with better environmental
information.
Modernizing regulation depends on modernizing collection, management, and access
to timely and
accurate environmental information. Clear and simple statements about how we're
doing on air,
water, and other indicators of environmental quality--"performance
measures" in the
parlance of management gurus--are only now coming into use, led by states like
Florida, New Jersey,
and Oregon. In spite of the size and breadth of the EPA and state data holdings, much
of the
available information, like the number of permits and enforcement actions, is ill-suited
to judging
whether regulations are working and the environment is getting cleaner.25 EPA is presently making a big push to improve
their
management of information, but they have miles to go.26
Even with the Internet, public access to comprehensible information about
environmental
performance can still be extraordinarily difficult.27
Congress should provide EPA and other federal agencies with the
authority--and
additional funding, if necessary--to invest in timely, accurate, and reliable
environmental
information for the public. This effort should include a major overhaul of
environmental
reporting requirements to sharpen the focus of data collection and make better use of
public
resources. Public reporting should hone in on key performance measures. That
means that
some redundant or marginal reporting now required by law should be dropped and
replaced
with more useful measures for the public and regulators. States are a critical piece of
the
action. They should be provided with funds to make their systems compatible with
federal
systems, and penalized down the road if they fail to avail themselves of aid to
modernize
their systems in the next few years.
Environmental groups and others already have taken government
information and
packaged it in useful ways for the public.28
Still,
the imprimatur of objective and trusted data is necessary to render value to these
private
sources. Better information will both drive and be driven by innovative
environmental
strategies. For example, the sulfur dioxide trading program was made possible by
continuous
emissions monitors on smoke stacks.
Increase incentives to innovate. Most of our economic growth is now
fueled by
technological innovation and human capital.29
Regulation
needs to take advantage of this major economic force, not inhibit it.
Congress should send a clear signal to EPA and the states to use market
incentives
to spur higher environmental performance. Incentives could include ways to reduce
regulatory transaction costs through quick permit reviews, longer permit periods,
third-party
certification of performance, as well as facility-wide caps on emissions and
discharges,
emissions trading, and changes in monitoring requirements. To be credible and
effective,
these incentives must be accompanied by strong and consistent enforcement, not just
the old
legal sticks but innovative approaches that similarly leverage market forces like
bonding and
insurance.
Support the growth of civic environmentalism. Throughout the nation,
citizens and
communities are engaged in collaborative efforts to solve environmental problems
particular to their
own place.30 Leaders in many of these efforts are
frustrated by the fragmentation of federal and state authorities and resources available
to help them
solve their own problems. Existing laws and regulations may not necessarily mount
serious barriers,
but their application varies widely from place to place, preventing them from working
effectively.
Second generation legislation would signal federal agencies that supporting civic
efforts to solve
environmental problems is part of their job. To its credit, the Clinton Administration
has far
surpassed its predecessors in tackling high profile regional environmental conflicts.
Still,
communities, regions, and states need new tools--not just flexibility in outdated
regulatory schemes--
to solve these place-based problems, including one-stop shopping for regulatory advice,
and
technical support to succeed. In the Bay-Delta project in California, four federal
agencies wrestled
among themselves and the state for over a decade until they finally found their way to a
comprehensive and coordinated approach to solving the region's serious water supply,
water quality,
and endangered species problems.31
Encourage risk-taking. Experimentation in environmental regulation can
be risky.
Companies and communities with innovative ideas have to weigh the prospects of
success against
the costs of regulatory uncertainty and the possibility of failure. Working outside the
box of
conventional regulation can be a big headache and cost a fair penny: 3M spent over $1
million in an
unsuccessful effort to obtain a Project XL permit from EPA.32 The project had merit and its failure clearly
discouraged
others in the business community from entering the program.
Legislation would give EPA and the states the license to be bold in experimenting
with new and
potentially better means to solve environmental problems. Employees and agencies
would be
rewarded for efforts to advance innovative strategies. Technological leaders in the
private sector
should know that they, too, will be rewarded for finding better ways to reduce air and
water pollution
and leave a smaller footprint on natural resources. To cope with occasional failure,
Congress should
provide a safety net of contingencies.
Invest in change. Constructive change costs money up front, if current
law is to be
enforced as new approaches are developed, tested, and pushed into wider use. Now,
most EPA
employees view reinvention as desirable, but not necessarily part of their job
description.
Welfare reform was accomplished when Congress agreed to spend more money per
recipient for
child care, transportation, and other services to move people from welfare to work.
Congress should
authorize such sums as necessary to give innovation a chance to succeed without
undermining the
foundation of existing environmental law and siphoning resources needed for
permitting, compliance
assistance, and enforcement. The payoffs will begin to flow after the investments in
modernization
begin.
Second generation legislation engenders ambivalence among battle-scarred
veterans of the 1990s
green wars. Some still hope for old-style benefit-cost analysis to control the costs of
regulation.
These critics say that the second generation agenda doesn't go far enough to fix the
inefficiencies of
the current system. Others say that until improvements are made in the quality of
information and
critical gaps are filled, measures to inject more flexibility are at best premature and at
worst
subversive.
Stalemate is an effective political tactic, but ultimately makes for bad politics
when the
public sees through the game. The public has spoken at the ballot box for strong
environmental
protection. Yet, defense of the status quo cannot become a permanent campaign.
Ultimately, the
public will measure success by deeds and a judgement that the environment is better off
than before.
With challenging public expectations for progress but the absence of near-term
crisis,
Congress and state leaders on both sides of the aisle should seize the opportunity to
give EPA and
the states the green light to conduct controlled experiments in environmental problem
solving. If
the experiments succeed, they should be moved into widespread practice. If they fail,
innovators
must learn from the mistakes and try a better way.
Rewarding results, encouraging civic engagement, stimulating innovation, and
providing
public accountability are the ways to achieve more environmental benefits in the New
Economy.
These are also the ways to build public trust and confidence that as regulation is
modernized, public
health will be well protected and our natural heritage conserved.
1.For an excellent overview of what's new in the New Economy, see Robert D.
Atkinson and Randolph H. Court, The New
Economy Index:
Understanding America's Economic Transformation, Progressive Policy
Institute,
Washington, DC, November 1998.
2. Council on Environmental Quality, Environmental Quality,
Washington, DC.,
1996, Part III, Table 1.4, p. 241. http://www.ceq.eh.doe.gov/reports/1996/tables.pdf
3. Ibid.
4. This phenomenon goes by the name of "industrial ecology." For
more information,
see T.E. Graedel and B.R. Allenby, Industrial Ecology, Prentice Hall, New
York, 1995.
5. U.S. Environmental Protection Agency, National Air Pollutant Emissions
Trends, 1900-
1996, Office of Air Quality, Planning, and Standards, EPA-454/R-97-011,
December 1997.
6. U.S. Environmental Protection Agency, The Quality of Our
Nation's
Waters, http://www.epa.gov/OW/resources/9698/chap2.html
7. Energy Information Administration, Emissions of Greenhouse
Gases in the United States
1997, DOE/EIA-0573(97) (Washington, DC, October 1998), p. 16.
8. David S. Wilcove, Michael J. Bean, Robert Bonnie, and Margaret McMillan,
Rebuilding
the Ark:
Toward a More Effective Endangered Species Act for Private Land,
Environmental
Defense Fund report, December 5, 1996.
www.edf.org/pubs/Reports/help-esa/index.html#4. U.S. General Accounting
Office,
Endangered Species Act: Information on Species Protection on Nonfederal
Lands.
GAO/RCED-95-16. U.S. General Accounting Office, Washington, DC, 1994.
9. David Roe, William Pease, Karen Florini, and Ellen Silbergeld, Toxic Ignorance:
The Continuing
Absence of Basic Health Testing for Top-Selling Chemicals in the United
States, Environmental
Defense Fund, Washington, DC, 1998. Www.edf.org/pubs/Reports/ToxicIgnorance.
10. Norman J. Vig and Michael E. Kraft, "Environmental Policy from the
1970s to the
1990s: An Overview," Chapter 1 in Vig and Kraft (eds.), Environmental
Policy in the
1990s, Third Edition, CQ Press, Washington, DC, 1997; National Academy of
Public
Administration, Setting Priorities, Getting Results: A New Direction for
EPA, NAPA,
Washington, DC, April 1995, pp. 13-16; J. Clarence Davies and Jan Mazurek,
Pollution Control
in the United States, Resources For the Future, Washington, DC, 1998.
11. For an example of what such a site could look like, see Investor Responsibility
Research
Center, Environmental Information Services,
Corporate Environmental Profiles Survey at
http://www.irrc.org/eisweb/samplep.htm. Intel
also posts a quarterly report on environmental performance at its newest facility in
Chandler, Az.,
www.intel.com/intel/other/ehs/projectxl/Q498www/Q498rpt.htm
12. Investor Responsibility Research Center, op. cit.
13. All credit for the term "civic environmentalism" should go to
DeWitt John of
the National Academy of Public Administration. DeWitt John, Civic
Environmentalism, Congressional Quarterly Press, Washington, DC, 1994.
14. U.S. General Accounting Office, GAO/RCED-95-30, Air Pollution Trading
Offers An
Opportunity to Reduce Emissions At Less Cost, December 1994.
15. National Academy of Public Administration, Setting Priorities, Getting
Results: A New
Direction for EPA, NAPA, Washington, DC, April 1995; NAPA, Resolving
the Paradox of
Enviornmental Protection: A New Direction for EPA, Washington, DC, 1997;
Aspen Institute,
The Alternative Path: A Cleaner, Cheaper Way to Protect and Enhance the
Environment, Aspen,
Colorado, 1996; Center for Strategic and International Studies, Enterprise for the
Environment,
The Environmental Protection System in Transition: Toward a More Desirable
Future,
Washington, DC, 1998; Marian Chertow and Daniel Esty (eds.), Thinking
Ecologically: The Next
Generation of Environmental Policy, Yale University, New Haven, 1997;
President's Council for
Sustainable Development, Sustainable America, Washington, DC, 1996;
Debra S. Knopman,
"Easier to be Green: A Second Generation Strategy to Improve the
Environment," Chapter
11 of the Progressive Policy Institute's book Building the Bridge: Ten Big Ideas to
Transform
America, January 1997; Debra S. Knopman, Second Generation: A
New Strategy for Environmental Protection, Progressive Policy Institute, April 1996.
16. U.S. Congress, 106th Congress, Mandates Information Act of 1999 (H.R. 350) and Small Business Paperwork Reduction Act
Amendments of 1999 (H.R. 391). Both bills passed the House on February 11, 1999.
17. U.S. Environmental Protection Agency, Reinventing Environmental Protection: 1998 Annual Report, Office of the Administrator, EPA
100-R-99-002, March 1999. www.epa.gov/reinvent.
18. Environmental Council of the States,1997 Annual Meeting State Innovations Report, ECOS, Washington, DC, September 21, 1997
http://www.sso.org/ecos/innovate.htm.
19. U.S. Department of Interior Secretary Bruce Babbitt has found more flexibility
in the
Endangered Species Act than any of his predecessors or detractors in Congress were
willing to
acknowledge was available under the Act. For a summary of DOI's policies, see
testimony of Jamie
Rappaport Clark, Director of the U.S. Fish and Wildlife Service, before the Senate
Environment and
Public Works on S. 1180 (105th Congress), The Endangered Species Recovery Act of
1997, September
23, 1997. For an overview discussion of the strengths and weaknesses of the
Endangered Species Act,
see "The Endangered Species Act At 25: What Works?" in The
Environmental
Forum, Environmental Law Institute, September/October 1998, pp. 48-57.
20. U.S. Congress, 104th Congress, Public Law 104-182, Safe Drinking Water
Act Amendments
of 1996 (110 Stat. 1613), and Public Law 104-170, the Food Quality
Protection Act of
1996.
21. The Common Sense Initiative (CSI) was designed to address sector-wide
regulatory
problems within a particular industry. U.S. Environmental Protection Agency,
Reinventing
Environmental Protection: 1998 Annual Report, Office of the Administrator,
EPA 100-R-99-002,
March 1999, pp. 44-48.
22. Environmental Council of the States, op. cit.
23. Stimulated in part by a Weyerhauser XL project, EPA recently issued a rule that
encourages
pollution prevention in the pulp and paper industry. This rule also increased flexibility
in how mills
reduce air emissions. Discussions from the Common Sense Initiative have led to
proposed rule
changes to make recycling of metals easier for metal finishers and reclycling of cathode
ray tubes
easier for electronics manufacturers. U.S. Environmental Protection Agency, Reinventing Environmental Protection:
1998 Annual
Report, Office of the Administrator, EPA 100-R-99-002, pp. 46-47, March
1999.
www.epa.gov/reinvent.
24. Richard D. Morgenstern, "Introduction to Economic Analyses at
EPA", Chapter
1 in Richard D. Morgenstern (ed.), Economic Analyses at EPA: Assessing
Regulatory Impact,
Resources for the Future, Washington, DC, 1997. EPA has reorganized out of existence
most of its
economic analysis functions previously in the Office of Policy, Program and Evaluation.
25. Remarks by David Gardiner, Assistant Administrator for the Office of Policy,
U.S.
Environmental Protection Agency, to the Common Sense Initiative Council, Arlington,
Virginia,
December 17, 1998. As reported by The Reinvention Report, January 1,
1999, Gardiner
said: "Nine out of 26 environmental problems, analyzed as part of an EPA effort
to address
'gaps' in data availability, have 'significant unmet data needs'"
26. U.S. Environmental Protection Agency, Memorandum from Administrator
Carol M.
Browner, Meeting the Information Challenge, October 14, 1998.
27. John D. Howay, Warren R. Muir, and Barbara F. Bass, Existing
Reporting vs.
Needs for Public Environmental Performance Data about Toxic Chemicals at
Industrial
Facilities, Hampshire Research Institute, Alexandria, Virginia, September
1997,
p.1. The authors note: "Practically none of the current reporting
requirements
are intended to serve environmental performance purposes, other than
compliance
with regulations."
28. A virtual walk through Environmental Defense Fund (EDF) Chemical
Scorecard clearly
shows how broad and deep are the gaps in environmental information. www.edf.
scorecard.org
29. Robert D. Atkinson and Randolph H. Court, op. cit.
30. Marc K. Landy, Megan M. Susman, and Debra S. Knopman, Civic Environmentalism in Action: A Field Guide to Regional and Local
Initiatives ,Progressive Policy Institute, Washington, DC, January 1999.
31. Ibid., pp. 11-14 and 47-56.
32. Personal communication, Theresa Hooper, 3M Corporation,
Government
Relations Representative, Washington, DC, April 29, 1999. Allen Blackman
and Janice Mazurek, The Cost of Developing Site-Specific
Environmental
Regulations: Evidence from the EPA's Project XL, Discussion Paper
99-35,
Resources for the Future, Washington, DC, April 1999.
Debra Knopman is director of the Progressive Policy Institute's (PPI) Center for Innovation & the Environment. Emily Fleschner is a program associate with PPI.
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