**MODULE 1: Mapping the EMS Project**

The following questions are designed to help evaluate the outcomes that
result when environmental management systems (EMSs) are used in a
regulatory program. In April 2004, EPA issued a *Strategy for
Determining the Role of EMSs in Regulatory Programs,* which can be found
at:

(<http://www.epa.gov/ems/policy/EMS_and_the_Reg_Structure_41204F.pdf>).
The Strategy provides guiding principles and a framework to assess what
role, if any, EMSs should play in regulatory programs. Evaluation of the
EMS projects is critical to the Strategy and to help EPA weigh future
policy decisions on the use of EMSs in regulatory programs.

## I. Summary and Purpose of the EMS Project

*Project Name:*

*Innovative Concept (if applicable):*

1.  Why was the EMS project developed or proposed?

2.  What problem or opportunity does the project address?

3.  To what extent and does the project focus on the following:

    a.  Individual facilities

    b.  Economic sectors or groups of sectors

    c.  Other regulated entities

    d.  Communities

    e.  Tribes

    f.  Other

4.  To what extent is the project intended to:

    a.  Improve technology

    b.  Streamline state/federal regulations

    c.  Improve organizational management/operations

    d.  Make more efficient use of state/local/federal resources

    e.  Improve stakeholder involvement

    f.  Foster organizational change, especially with respect to
        organizational culture

    g.  Improve environmental management practices (e.g., pollution
        prevention, environmental stewardship, environmental data, etc.)

    h.  Consider cross-media impacts or multi-media strategies

    i.  Other

5.  In what way(s) does the project involve new ideas and approaches
    when compared to the current/existing approach?

6.  What programs or policies are impacted by the project, and how?

7.  What are the key resources that your innovation uses?

8.  What are the key activities that you undertake in your innovative
    program?

9.  What are the key outputs of your innovative program?

## Identifying Customers, Partners and Stakeholders of the EMS Project

9.  Who are the key regulated entities in the project?

10. Who are the key partners of the project?

11. Who are the key customers of the project?

12. Who are the key stakeholders in the project?

13. Who has primary responsibility for designing, overseeing, and
    implementing the EMS project or using the innovative approach or
    tool?

14. Does the project involve delegation of regulatory responsibilities
    from EPA to a tribe or state or from the state to a local
    government? (Y/N). If yes, how?

##  Identifying Outcomes

16. Please list and describe all intended or anticipated short-term
    outcomes.

17. Please list and describe all intended or anticipated intermediate
    outcomes.

18. Please list and describe all intended or anticipated long-term
    outcomes.

## 

## IV. EMS Project---Tools, Drivers, Barriers

19. What additional tools are employed to supplement the EMS (e.g.,
    economic incentives, regulatory reform, smart permitting, pollution
    prevention, performance-based compliance assistance, information
    management and access, risk-based cleanup standards)? Please
    describe.

20. Describe the motivating factors for undertaking the project and
    explain how such factors promote the EMS project (e.g., market
    forces, law or policy that promotes the project).

21. Describe all challenges to the project and explain how such
    challenges may present barriers.

# V. Describing the Logic of the EMS Project

Many programs and projects often run into trouble because they lack a
well-articulated road map describing the logic of the program or
project. A logic model is a tool that is used to graphically depict and
explain the logical relationships that exist between inputs, outputs and
outcomes. It graphically illustrates what must occur in order for the
project to accomplish its goals. Please use the answers from the
questions above and Table 1 below to develop a logic model of the
innovative program or project. Chapter 1 of the User's Guide provides
guidance on the steps needed to develop a logic model of the project.

## Contextual Factors

22. Describe all contextual factors that are *outside of your control*
    that can effect the implementation of your innovation.

23. Describe the underlying assumptions of your program.

+-------+-------+------+-------+-------+--------------+--------------+
| ####  | **Act | ###  | **C   | **    | **           | **Long-term  |
| Resou | iviti | Outp | ustom | Short | Intermediate | e            |
| rces  | es/** | uts  | ers** | -term | outcomes**   | nvironmental |
|       |       |      |       | Outco |              | outcomes**   |
|       | **    |      |       | mes** |              |              |
|       | Progr |      |       |       |              |              |
|       | ams** |      |       |       |              |              |
+-------+-------+------+-------+-------+--------------+--------------+
|       |       |      |       |       |              |              |
+-------+-------+------+-------+-------+--------------+--------------+
|       |       |      |       |       |              |              |
+-------+-------+------+-------+-------+--------------+--------------+

Exhibit 1

MODULE 2: Assessing the Environmental Results of the EMS Project

# Identifying Environmental Goals of the EMS Project 

1.  What are the specific **environmental goals** that the EMS project
    intends to achieve? Please describe.

2.  Do the goals of the project include improving the **environmental
    performance of third parties** (e.g., customers, suppliers, etc.)?

3.  Do the **goals of the project match** the expected/intended outcomes
    of the project?

4.  Do the goals of the project include **cross-media transfers**? If
    yes, how many and what types of cross-media transfers are being
    considered?

# Measuring the Environmental Results 

## *Environmental Indicators*

5.  For each environmental goal, what qualitative and quantitative
    environmental indicators (i.e., EMS objectives and targets) are
    being used by individual facility EMSs to measure progress/impacts?
    (*Examples include releases---wastewater, air, pollutants,
    greenhouse gases; resource consumption---nonrenewable energy use,
    water use; habitat conditions---area of land converted/developed;
    significant impact areas versus disinvested areas.)* *Note: The
    indicators should cover both compliance measures [and]{.underline}
    those indicators of environmental performance integrated in the
    EMS.*

6.  What project-wide indicators are being used to measure EMS
    effectiveness? *(Examples include: increased management review and
    attention to environmental outcomes, increased P2 as a result of
    EMS)*

7.  Does the adoption of an EMS change the organization's use of
    environmental indicators (e.g., organization pays more attention to
    additional unregulated indicators)?

8.  What is the measurement approach that will be used to measure
    progress for each environmental goal (e.g., modeling data, in-situ
    experiment, historical data extrapolation, real-time, one-time
    observations)?

9.  For each environmental indicator, what is the pre-project "baseline"
    against which progress is measured (e.g., baseline is 5 percent loss
    of product in facility waste streams---the EMS project is to only
    have 1 percent material loss in three years) in the EMS?

    a.  Baseline compliance indicators (e.g., frequency of
        noncompliance)?

    b.  Baseline process indicators (e.g., adoption of pollution
        prevention techniques, increase in senior management review of
        facility environmental footprint, consideration of local
        environmental issues)?

10. For each of the environmental indicators listed above, what is the
    schedule for data collection (e.g., daily, weekly, quarterly,
    annually, etc.) and how is it reflected in each entity's EMS or in
    the EMS project?

11. Based on the indicators provided through EMS objectives and targets,
    what have been the environmental impacts of the project (e.g., 100
    tons of volatile organic compounds emissions have been eliminated to
    date)? *Note: Provide both qualitative and quantitative outcomes.
    The project may be of too recent origin for environmental impacts to
    be observable. Provide qualitative outcomes if possible---e.g.,
    increase in senior management review, etc.*

> *Environmental Results*

12. To what extent are the environmental impacts of the project
    consistent with what was expected at the time of design and
    implementation?

13. Are sufficient data available to determine if the project has met
    its environmental goals (e.g., are the data qualitative or
    quantitative or both)?

14. To what extent has the project been an improvement over the
    prior/traditional approach with regard to:

    i.  Human health

    ii. Organizational management

    iii. Community based protection

    iv. Quality of life

    v.  Ecosystem health

    vi. Tribal management

    vii. Environmental Justice communities

    viii. Others

15. How are environmental results verified and who is responsible for
    verifying results? How is this reflected in the EMS project or in a
    facility's EMS?

16. How often are environmental results verified? How is this reflected
    in the EMS project or in a facility's EMS?

*Cross-Media Performance---please answer if applicable.*

17. What is the analytical basis used for cross-media shifts for
    facilities with EMSs (e.g., comparative risk based on acute and/or
    chronic toxicity)?

18. Has a cross-media analysis been performed? Does the analysis help
    provide a baseline to measure cross media performance?

19. What are the anticipated effects of the cross-media transfers?

20. How do the intended goal and indicators compare to the results of
    the cross-media transfers?

21. Have any new multimedia strategies been identified based on the
    cross-media analysis?

Table 2 -- Environmental Results Table

***Project:***

**Problem the project is trying to solve:**

+---------------+----------+----------+-----------+--------+---------+
| Project       | In       | Pre      | Output    | S      | Impact/ |
| Objectives    | dicators | -project | Metrics   | ources |         |
|               | (EMS     |          |           | of     | Outcome |
| with Goals    | ob       | Base     |           | info   |         |
|               | jectives | St       |           | and    |         |
|               | and      | atistics |           | Calcul |         |
|               | targets) |          |           | ations |         |
+===============+==========+==========+===========+========+=========+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+
|               |          |          |           |        |         |
+---------------+----------+----------+-----------+--------+---------+

MODULE 3: Assessing the Cost and Cost Savings of the EMS Project

I.  Measuring the Costs and Cost Savings of the EMS Project

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1.  What is the measurement approach that will be used to estimate the
    costs and cost savings of the project? What indicators will be used
    (e.g., compliance measures, materials use, numbers of spills, etc.)?

2.  Does the adoption of an EMS change the organization's use of
    economic performance indicators (e.g., identification of
    environment-related costs and benefits more explicitly for
    management attention)?

3.  What are the pre-project baselines against which costs and cost
    savings are measured?

    a.  Costs of compliance

    b.  Costs of EMS (i.e., design, training, implementation, and
        certification)

    c.  Cost savings of streamlined permitting system

    d.  Cost savings of reallocation of personnel

    e.  Other (e.g., new investments, time to market, competitiveness)

4.  What data sources will be used to measure costs and cost savings?

5.  To what extent has the project resulted in costs or cost savings?

**II Cost Savings of the EMS Project**

6.  What significant **time savings/savings** has the organization
    derived as a result of the EMS project? *(Please describe the key
    types of time savings incurred including staff time and contractor
    savings involved in activities including project development,
    implementation, monitoring, reporting and record keeping, rule
    revisions, time to market, permit administration, and inspections.)*

    a.  Savings to the regulator

    b.  Savings to the regulated

    c.  Local community or other stakeholder group savings

7.  What **significant cost savings in capital, operation, and
    maintenance of new equipment, operation and maintenance of existing
    equipment, materials, or energy** has the organization derived as a
    result of the EMS project?

8.  What **other savings** (e.g., insurance, worker compensation,
    creation of jobs etc.) has the organization derived as a result of
    the EMS project?

9.  What **economic activity**, if any, has been generated by
    implementation of the EMS project (e.g., jobs may be created if a
    brownfields site is redeveloped)?

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III. Costs of the EMS Project

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10. What significant **time costs/investments** has the organization
    incurred as a result of the EMS project? *(Please describe the key
    types of costs incurred including staff time and contractor costs
    involved in activities including project development,
    implementation, monitoring, reporting and record keeping, rule
    revisions, permit administration, and inspections.)*

    a.  Costs to the regulator

    b.  Costs to the regulated

    c.  Costs to the local community or other stakeholders

11. What significant **costs/investments in capital, operation, and
    maintenance of new equipment, operation, and maintenance of existing
    equipment, materials, or energy** has the organization incurred as a
    result of the EMS project?

12. What **other significant costs** (e.g., insurance, worker
    compensation, creation of jobs etc.) has the organization incurred
    as a result of the EMS project?

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II. Relative Cost Advantage

    13. If the EMS project were used more widely in the future, how
        would the **marginal (i.e., per EMS project) savings and costs**
        of the project change for **the organization**?

        a.  For the regulator

        b.  For the regulated

        c.  For the local community and other stakeholders

    14. What is the **difference** between the actual project costs and
        baseline costs (i.e., costs associated with current regulatory
        framework)?

##### Table 3

+------------------+---------------+-----------------+-----------------+
| Costs/Cost       |               |                 |                 |
| Savings Model    |               |                 |                 |
| Table            |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Category of      | Baseline      | Costs of the    | Net Change:     |
| Costs            | Costs         | Project         |                 |
|                  |               |                 | Costs or Cost   |
|                  |               |                 | Savings         |
+------------------+---------------+-----------------+-----------------+
| Real-Resource    |               |                 |                 |
| Compliance Costs |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Project          |               |                 |                 |
| Development      |               |                 |                 |
| Costs            |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Capital Costs    |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Operation and    |               |                 |                 |
| Maintenance      |               |                 |                 |
| Costs            |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Government       |               |                 |                 |
| Regulatory Costs |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Permit Review    |               |                 |                 |
| Costs            |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Inspection Costs |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Social Costs     |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Cost of goods    |               |                 |                 |
| with recycled    |               |                 |                 |
| materials        |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Transitional     |               |                 |                 |
| Costs            |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
|                  |               |                 |                 |
+------------------+---------------+-----------------+-----------------+
| Indirect Costs   |               |                 |                 |
+------------------+---------------+-----------------+-----------------+

MODULE 4: Enforcement and Compliance Assurance

I.  **Reporting to State Agencies, EPA, or Stakeholders**

*Design Questions*

1.  What is the **legal implementing mechanism** for the project?

2.  What **standard permit conditions or regulatory requirements**, if
    any, will require/have been modified?

3.  What are the specific **requirements for environmental monitoring**
    of this project? Clarify those requirements by law and regulation
    between requirements of the EMS project? To what extent are these
    requirements addressed in the EMS?

4.  What are the specific **requirements for keeping records** of this
    project? Clarify those requirements by law and regulation between
    requirements of the EMS project? To what extent are these
    requirements addressed in the EMS?

5.  What are the specific **requirements for reporting to regulatory
    organizations** regarding this project? Clarify those requirements
    by law and regulation between requirements of the EMS project? To
    what extent are these requirements addressed in the EMS?

6.  What are the specific **requirements for reporting to stakeholders**
    regarding this project? To what extent are these requirements
    addressed in the EMS?

7.  Do the reports have a **required audience(s)**? (Y/N) If yes, please
    identify the audience(s).

###### Implementation Questions

8.  To what extent have the specific **requirements for environmental
    monitoring** of this project been met?

9.  To what extent have the specific **requirements for keeping
    records** been met?

10. To what extent have the specific **requirements for reporting to
    regulatory organizations** been met?

11. To what extent have the specific **requirements for reporting to
    stakeholders** addressed in been met?

12. Have reports been delivered to the required audiences identified in
    Question 7? (Y/N) If yes, please list dates and method of
    communication (e.g., Web site, email, public notice). If no, please
    provide explanation.

# Verification

13. How do users ensure that the parties to the EMS project comply with
    the provision(s) of the EMS project?

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a.  How will the organization's performance under the project be
    compared to the performance that could have been obtained under the
    normally applicable regulatory structure?

b.  Who is responsible for verifying compliance and environmental
    performance results and how will it be done?

# III. Practical Enforceability

14. What is the **pre-innovation "baseline"** (e.g., emissions
    inventory, sector compliance rate, enforcement activity) against
    which progress will be (is) measured?

15. Can an inspector visiting the project site **determine** **historic
    and current compliance** from the records maintained on site?

16. Does the EMS permit, if applicable, **contain a legal obligation**
    for the source to adhere to the terms and conditions of the
    limitation?

17. Does the permit **rely on the** **efficiency of a control
    technology** for compliance with a permit limit? If so, how is that
    efficiency determined and shown to be accurate?

18. Does the EMS project agreement **require the correct type and amount
    of information** (in logs, notices, monitoring data, etc.) to
    determine the number and duration of any deviations?

19. How will regulators determine---prior to and throughout the
    project---that the facility is continuing to **maintain its EMS**?

20. Who will audit **EMS conformance**?

21. Does the project include required **self or third-party compliance
    auditing**? If yes, explain.

22. Do the terms of the project potentially obligate a regulator to
    **waive or amend environmental requirements** (if so, explain)?

23. Does the regulator preserve the requisite statutory **inspection and
    enforcement authority** to satisfy EPA-state delegations of
    authority?

24. How, and for what reasons, will the **organization return to
    standard permit terms** should it become necessary to terminate the
    organization's participation in the EMS project?

**IV. Redirecting Regulatory Oversight**

25. What **screening criteria** (e.g., compliance history or
    participation in leadership programs) are used to ensure that good
    facility partners participate in the EMS project?

26. If applicable, what combination of **EMS conditions and facility
    characteristics** is being used to establish the confidence or
    analytical basis for redirecting resources (e.g., compliance
    history, transparency of decision-making, quality and degree of
    public involvement, third-party auditing, reporting, etc.)?

27. What is the analytical basis being used for **determining the
    relative priority or risk of agency activities** (for the purpose of
    targeting staff time and resources)?

28. What are the **net resource implications** to compliance and
    enforcement personnel/programs of substituting EMS terms for permit
    conditions or linking them to the permit conditions?

V. Results and Relative Advantage

29. Has the project **improved compliance rates** and/or reduced the
    length or severity of noncompliance?

30. To what extent **can the source** with the innovation **be more/less
    easily inspected** to determine compliance than a similar source
    operating under conventional approaches? How does this compare to
    what is expected?

31. Does the innovation **improve on enforcement or enforcement
    practices** over the current system (e.g., redirection of oversight
    resources)?

32. Does the adoption of an EMS allow organizations to **remove
    regulatory burdens** by moving down in "regulatory status" (e.g.,
    moving from large quantity generator to small quantity generator
    status)? If yes, describe.

Table 4

+---------+----------+---------+-------+---------+---------+--------+
| Model   |          |         |       |         |         |        |
| Table   |          |         |       |         |         |        |
| for     |          |         |       |         |         |        |
| Moni    |          |         |       |         |         |        |
| toring, |          |         |       |         |         |        |
| Rep     |          |         |       |         |         |        |
| orting, |          |         |       |         |         |        |
| and     |          |         |       |         |         |        |
| Record- |          |         |       |         |         |        |
| Keeping |          |         |       |         |         |        |
| (MRR)   |          |         |       |         |         |        |
+---------+----------+---------+-------+---------+---------+--------+
| Enviro  | Mo       | Ma      | Data  | Re      | Record- | Comp   |
| nmental | nitoring | terials | Colle | porting | Keeping | liance |
| Media   | Approach | Use and | ction | Requi   | Requi   | Notes  |
| and     | (con     | Op      | Freq  | rements | rements |        |
| Pol     | tinuous, | erating | uency | for     |         | (s     |
| lutants | par      | Pa      |       | Reg     |         | pecify |
| of      | ametric, | rameter |       | ulatory |         | date   |
| Concern | an       | Requi   |       | Auth    |         | of     |
|         | alytical | rements |       | orities |         | report |
|         | testing, | (e.g.,  |       | and     |         | and    |
|         | c        | appl    |       | Stake   |         | note   |
|         | omposite | ication |       | holders |         | any    |
|         | sample,  | rate,   |       |         |         | devia  |
|         | grab     | per     |       |         |         | tions) |
|         | sample)  | centage |       |         |         |        |
|         |          | by      |       |         |         |        |
|         |          | weight) |       |         |         |        |
+---------+----------+---------+-------+---------+---------+--------+
| Air     |          |         |       |         |         |        |
| Em      |          |         |       |         |         |        |
| issions |          |         |       |         |         |        |
| by      |          |         |       |         |         |        |
| Po      |          |         |       |         |         |        |
| llutant |          |         |       |         |         |        |
| (tons   |          |         |       |         |         |        |
| per     |          |         |       |         |         |        |
| year)   |          |         |       |         |         |        |
+---------+----------+---------+-------+---------+---------+--------+
| Average |          |         |       |         |         |        |
| E       |          |         |       |         |         |        |
| ffluent |          |         |       |         |         |        |
| Concent |          |         |       |         |         |        |
| rations |          |         |       |         |         |        |
| by      |          |         |       |         |         |        |
| Cons    |          |         |       |         |         |        |
| tituent |          |         |       |         |         |        |
| (mg/L)  |          |         |       |         |         |        |
+---------+----------+---------+-------+---------+---------+--------+
| Ha      |          |         |       |         |         |        |
| zardous |          |         |       |         |         |        |
| Waste   |          |         |       |         |         |        |
| Ge      |          |         |       |         |         |        |
| nerated |          |         |       |         |         |        |
| (       |          |         |       |         |         |        |
| pounds) |          |         |       |         |         |        |
+---------+----------+---------+-------+---------+---------+--------+

MODULE 5: Public Involvement and Stakeholder Feedback

Before addressing the questions below, it is important to briefly
discuss issues related to public involvement and an EMS project. For
some projects, a high degree of public input may have been required to
develop the projects, for others, none at all. In some instances, even
when a high degree of public involvement was required, those responsible
for developing or implementing the project may have been less than
successful at obtaining the desired levels. In other cases, irrespective
of whether public involvement was a requirement for the project
development, the public may have played a significant role in shaping
the project. Knowing this information is necessary to understand how
well a particular public involvement process worked, and/or what type of
outcome (environmental or other) public involvement had in shaping the
innovation. However, for the purposes of understanding whether an EMS
project would make a good candidate for broader application, the most
pertinent information involves the project=s ability to maintain (or
enhance) the base amount of involvement required under traditional
programs.

# 

## I. Stakeholder Participation

1.  Who are the key stakeholders?

2.  Have state, tribal, and local government partners been consulted?

3.  Have stakeholders and partners been consulted in the development
    and/or implementation of the EMS project? If yes, describe the
    extent of the participation.

4.  How did stakeholder involvement change as a result of the adoption
    of the EMS or the implementation of the EMS program?

5.  What benefits does this involvement provide (e.g., ideas not
    otherwise considered, more positive community relations)?

6.  What effects does this involvement have on the decisions made by
    organizations or by the program?

7.  If applicable, what specific strategies are being considered to
    ensure the participation of low-income and minority communities?

8.  What is the **pre-project "baseline"** for public involvement and
    accountability against which progress will be measured?

9.  How does the project address **regulatory requirements**
    (federal/state/local/tribal) for public involvement?

10. What changes to the **transparency in decision-making** (for the
    regulator and/or the regulated) and the degree of stakeholder/public
    leverage result from the EMS project?

II\. Constructive Dialogue Approaches

11. What are the best means of involving stakeholders in the development
    of the EMS project?

12. What types of collaborative processes or other participatory
    practices will be used to solicit input?

III\. Availability of Information

13. Is information regarding the project readily available to
    stakeholders? If yes, how will it be shared?

14. What changes to the type, scope, amount, quality (accuracy,
    relevance), and timing of information available to the public result
    from the project?

# IV. Stakeholder Feedback

15. At what stage in the project process will stakeholders be involved
    to ensure participation and an opportunity to incorporate feedback?

16. To what extent have users been successful in obtaining feedback from
    the public about the project's design and/or implementation?

# V. Responsiveness to Stakeholder Priorities and Concerns

17\. How will the major concerns of stakeholders be addressed?

18\. Is technical or financial assistance available to facilitate the
participation of particular groups of stakeholders?

19\. Are stakeholders likely to consider their involvement in the
project a positive experience? Why or Why not?

MODULE 6: Assessing the Potential Transferability of the EMS Project

The purpose of the module is to help reduce the uncertainty about an EMS
project=s expected consequences and determine its rate of adoption. In
1962, Everett Rogers wrote the pioneering work, *Diffusion of
Innovations*[^1], which presents a workable framework for diffusing
innovations or innovative thoughts over time. Rogers= work provides us
with a systematic approach to understanding the nature of innovations
and the existing conditions and culture necessary for accepting,
adopting and implementing innovations. This transferability module is
based upon Rogers= innovation-diffusion model, which has five
components: 1) relative advantage, 2) compatibility, 3) complexity, 4)
trialability, and 5) observability.

# I. Relative Advantage

1.  Compared to the traditional way of doing business, what has been the
    measurable impact (positive and/or negative) of the EMS project with
    regard to:

    a.  Environmental protection

    b.  Organizational management

    c.  Economic impacts

    d.  Expedited action

    e.  Public involvement

    f.  Accountability

    g.  Environmental Justice

    h.  Administrative burden

    i.  Other areas

2.  Who benefits from the EMS project?

    a.  What do they gain?

3.  Who incurs costs as a result of the EMS project?

    a.  What costs do they incur?

4.  What additional data are necessary to inform determination of the
    relative advantage of the project?

5.  To what extent does the adoption of an EMS change an organization's
    use of advanced environmental and materials accounting techniques?

**II. Compatibility**

6.  To what extent is the EMS project consistent with existing
    organizational beliefs, values, and/or management approaches?

    7.  What is the level of support for the EMS project from:

        a.  Within EPA

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    a.  The affected entity or entities

    b.  Other regulated entities

    c.  State agencies

    d.  Federal agencies

    e.  Local community

    f.  Environmental non-governmental organizations (NGOs)

    g.  Environmental Justice groups

    h.  Local government

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8.  To what extent has a similar EMS project been tested before?

    a.  Different sector or industry

    b.  Different media

    c.  Different state, EPA region, local government, tribe

    d.  Different community

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    9.  Among existing users, to what extent does the EMS project
        support organizational goals, (i.e., department, office or
        divisional goals, community goals)?

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10. Among existing users, to what extent are organizational changes
    necessary to enable widespread use of the EMS project (what specific
    changes are necessary)?

11. Among potential users, to what extent does a broader user market or
    audience exist for the EMS project?

12. Among potential users, to what extent does the EMS project need
    modifications to be used more broadly (what specific changes are
    necessary)?

13. Who else might use or be interested in the EMS project (e.g.,
    regulated entities not originally contemplated as users of the EMS
    project, or regulators who might be able to transform the EMS
    project in a creative way for other purposes)?

    a\. Other regulated entities

    b\. Other regulators (tribes, local state, EPA region, EPA
    Headquarters)

    c\. Communities

    **III. Ease of Adoption**

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14. How readily understood is the EMS project?

15. To what extent is assistance necessary, and available, to understand
    and use the EMS project?

16. If the EMS project needs to be brokered, what assistance products
    are available?

    a\. Are they in development?

    b\. Do they need to be created?

## IV. Trialability

17. To what extent can the EMS project be tried on a temporary basis
    (i.e., one month, one year, etc.)?

18. To what extent can the EMS project be tried on a limited scale
    (i.e., fewer facilities initially or with fewer regulatory
    authorities)?

    **V. Observability**

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19. To what extent are the EMS project results apparent to others?

# VI. Personal Experience and Observations

20. To what extent do users consider the EMS project to be an
    improvement over the traditional way of doing business? In what
    way(s) was the innovation an improvement?

21. Is the EMS project mature enough to have a full understanding of its
    advantages and disadvantages?

    a.  If not, when will it be possible to gain a full understanding of
        the advantages and disadvantages of the EMS project?

22. What are the primary lessons learned from testing and analyzing the
    EMS project that pertain to its broad-scale application?

23. What is the potential for broader application of the EMS project?

    a.  Could the EMS project be used to address another problem?

24. What are the primary barriers to broader application of the EMS
    project?

25. What are the critical implementation elements needed to overcome the
    barriers to broader application of the EMS project?

26. How would the EMS project best be applied?

    a.  What steps could be taken to facilitate more widespread
        application of the EMS project?

    b.  What steps could reduce the transaction costs of the diffusion?

    c.  What elements should be scaled-up?

    d.  What elements should be changed?

    e.  How might other users be identified?

    f.  Are there unique circumstances that could impact broader
        application of the EMS project (e.g., window of opportunity)?

27. Are there resource limitations, if any, which would constrain
    broad-scale application?

28. At what level---national, state, or local---should the EMS project
    be applied?

    a.  What are the appropriate mechanisms for such application?

29. How do users feel about the voluntary incorporation of EMSs with the
    regulatory system?

## Innovation-Diffusion Model: Using a Transferability Scale

The ranking table should be used to emphasize the strengths of the EMS
project and to continue to improve on the weaknesses in order to help
transfer the EMS project. The table can also be used to help identify
priority projects for scale-up. If the user has multiple projects, but
limited resources, the ranking table can help assist decisions to
scale-up those projects which are highly transferable first.

Table 6: Transferability Scale

  ------------------------ ----------------- ----------------- -----------------
  **Innovation-Diffusion   **High**          **Moderate**      **Low**
  Components**                                                 

  **Relative Advantage**                                       

  **Compatibility**                                            

  **Ease of Adoption**^1^                                      

  **Trialability**                                             

  **Observability**                                            

  ^1^ For ease of                                              
  adoption, \"high\"                                           
  responses are positively                                     
  related to an                                                
  innovation\'s rate of                                        
  adoption; whereas                                            
  \"low\" responses are                                        
  negatively related).                                         
  ------------------------ ----------------- ----------------- -----------------

[^1]: Rogers, E. *Diffusion of Innovations.* 4^th^ Edition. The Free
    Press, New York: 1995.