n

United States Office of the EPA 130-R-92-001 

Environmental Protection Administrator October 1992 

Agency (A-101 F6) 

EPA	 Improving Technology

Diffusion For Environmental 

Protection 

Report And Recommendations

Of The Technology Innovation

And Economics Committee 

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The National Advisory Council 

For Environmental Policy and Technology 

NACEPT 

Recycled/Recyclable 

Printed on paper that contains 

at least 50% recycled fiber 
1 

CENTER FOR TECHNOLOGY, POLICY AND INDUSTRIAL DEVELOPMENT CAMBRIDGE. MASSACHUSETTS 02139 

October 1992
 

To the Reader:
 

This report represents the first comprehensive attempt to investigate, in
 

depth, the present and future role of the Environmental Protection Agency
 

(EPA) in the diffusion of environmentally beneficial technologies. Diffusion
 

processes are insufficiently used or encouraged as complements to regulation,
 

permitting and enforcement activities in the environmental management system.
 

This represents an underutilized opportunity to introduce innovative
 

technological solutions into wider use that, in turn, could expand
 

environmental progress in the U.S. and improve economic competitiveness.
 

In issuing this report, the National Advisory Committee for Environmental
 

Policy and Technology (NACEPT), through the efforts of its Technology
 

Innovation and Economics (TIE) Committee, has adopted a series of
 

recommendations whose implementation is necessary to bring about significant
 

changes in federal regulatory policy. The report strongly recommends that EPA
 

take actions to make innovative technological solutions, especially those that
 

prevent rather than control or treat pollution and waste, more widely
 

disseminated and readily accessible through improved diffusion initiatives.
 

We would like to thank EPA's Administrator William K. Reilly and Deputy
 

Administrator F. Henry Habicht II for giving the TIE Committee the direction
 

and encouragement to undertake this study, and all those in industry;
 

federal, state and local government; academia; and the environmental community
 

who provided information and perspectives in presentations at Diffusion Focus
 

Group meetings and through other mechanisms. The Focus Group that prepared
 

this document deserves the highest commendations for its contribution of time
 

and effort, its thoughtful deliberations, and its creative and challenging
 

recommendations. In particular its chair, William W. Carpenter and EPA
 

committee management staff David R. Berg and Morris Altschuler should be
 

recognized for their outstanding leadership and support.
 

Sincerely,
 

Nicholas A. Ashford
 

Professor of Technology and Policy
 

Chair, TIE Committee
 
NOTICE 

The following report and its recommendations have been written in conjunction

with the activities of the National Advisory Council for Environmental Policy and

Technology (NACEPT), a public advisory committee providing extramural policy

information and advice to the Administrator and other officials of the Environmental 

Protection Agency (EPA). The Council is structured to provide balance, expert assessment

of policy matters related to the effectiveness of the environmental programs of the United

States. This report has not been reviewed for approval by the EPA. Hence, the contents of

this report and recommendations do not necessarily represent the views and policies of the

EPA, nor of other agencies in the Executive Branch of the federal government. 
ABSTRACT

 

The United States' potential to improve the environment is directly related to our ability to 

produce and apply technological solutions. The Technology Innovation and Economics 

(TIE) Committee, a standing committee of EPA's National Advisory Council for 

Environmental Policy and Technology (NACEPT), concluded that the environmental 

regulatory system could expand environmental progress and improve economic 

competitiveness if processes that diffuse environmentally beneficial technologies are used 

to effectively complement regulations. Enhanced EPA technology diffusion programs, 

especially those involving pollution prevention technologies and techniques, are essential to 

the achievement of EPA's mission. Federal, state and local regulators, technology 

developers, technology users, the financial community, environmental groups, and 

academia together identified and assessed potentially practical approaches. In this report, 

the Committee analyzes several critical policy issues affecting EPA's essential diffusion 

roles and makes five major policy recommendations, including: 

1. Making technology diffusion a major supporting mission for EPA. 

2. Building a stronger partnership with technology diffusion providers and users. 

3. Making diffusion and incentives the emphases of EPA's pollution prevention 

programs. 

4. Expanding support for the international diffusion of environmental technologies to 

help meet U.S. environmental and competitiveness objectives. 

5. Increasing the support of diffusion provided by EPA's environmental technology 

research programs. 
TABLE OF CONTENTS 

Note to the Reader 

I.	 Executive Summary i 

II.	 Preface 1 

III. Introduction	 5 

IV.	 Members of the Technology Innovation and 

Economics Committee 13 

V.	 Findings 15 

VI.	 Recommendations for Action and Commentary 29 

Summary of Recommendations	 29 

Detailed Recommendations and Commentary	 31 

• Recommendation 1	 31 

• Recommendation 2	 57 

• Recommendation 3	 74 

• Recommendation 4	 88 

• Recommendation 5	 97 

APPENDICES 

1 .	 Presenters and Participants at Diffusion Focus 

Group Meetings 123 

2.	 Recommendation 4 from the TIE Committee's 1991 

Report & Recommendations, "Permitting and Compliance

Policy: Barriers to U.S. Environmental Technology 

Innovation" 12 5 

' 3.	 TIEC s Recommendations to EPA on Technology

Cooperation, Technology Innovation, and Trade and 

the Environment, September 1991 13 9 
EXECUTIVE SUMMARY 

Background The mission of the U.S. Environmental Protection Agency 

(EPA) is to preserve and improve the quality of the 

environment and to protect human health. EPA has made a commitment to ensure that 

"U.S. policy, both foreign and domestic, fosters the integration of economic development 

and environmental protection so that economic growth can be sustained over the long term" 

(Strategic Direction for the U.S. Environmental Protection Agency: EPA . . . Preserving 

Our Future Today. 1991). The Agency indicates that it will develop and apply incentives 

that "stimulate . . . firms and consumers to take actions that serve their economic interests 

while spurring progress towards environmental goals." To this end, EPA has announced 

that it is: 

• Initiating programs for promoting incentives and technology. 

• Developing a role as a catalyst for technological innovation. 

• Expanding efforts to seek technological cooperation and trade 

promotion. 

• Supporting the use of cross-media and cross-jurisdictionally 

coordinated approaches to environmental management. 

• Undertaking interagency cooperation at the federal level. 

• Ensuring a level playing field through strong enforcement. 

Several recent reports, including Permitting and Compliance Policy: Barriers to U.S. 

Environmental Technology Innovation (1991, National Advisory Council for 

Environmental Policy and Technology [NACEPT] [EPA 101/N-91-001]) and "EPA Must 

Help Lead An Environmental Revolution in Technology" by James Gustave Speth (in 

Hazardous Materials Control, November/December 1991), stress that EPA must play a 

strong role in fostering the development and use of environmentally beneficial technologies 

to accomplish its goals. NACEPT noted that "the United States' potential to improve the 

environment is directly related to the nation's ability to produce and apply technological 

solutions." NACEPT concluded that "fundamental changes to the environmental regulatory 

system" are needed "to create incentives encouraging the process of (environmentally 

beneficial) technology innovation." 

i 
Speth stated the challenge: "to reduce pollution while achieving expected economic 

growth, societies must bring about a wholesale transformation in the technologies that 

dominate the world economy." He described the implications of this challenge to EPA as 

"far-reaching. They extend from devising new regulatory approaches to moving beyond 

regulation and forging new patterns of cooperative interaction among business, 

government, and environmental experts.... A basic need is for technology transfer and 

development of assistance policies ... " 

The Diffusion In late 1990, EPA Administrator William K. Reilly 

Focus Group requested that NACEPT develop advice on two major areas: 

trade and the environment, and pollution prevention. The 

Technology Innovation and Economics (TIE) Committee was charged with considering the 

role of EPA's technology transfer programs in enhancing the effectiveness of the U.S. 

environmental management system, and to focus particularly on the diffusion of 

environmentally beneficial technologies in the U.S. economy. Specifically, the Committee 

was asked to examine "EPA's role in technology transfer, including transfer of products, 

services, research, and management systems information among EPA and other public and 

private sector entities." The TIE Committee's eighteen person Diffusion Focus Group of 

experts was chaired by William W. Carpenter, Vice President for Technology Applications 

for Martin Marietta Energy Systems, Inc. (see Section IV). The members have a wide 

range of interests and expertise related to the conduct and management of technology 

development and commercialization programs, and significant experience on national 

committees evaluating technology programs and technology transfer activities in the public 

and private sectors. 

Approach Over a period of sixteen months, the Focus Group held four 

two-day public meetings and convened through a number of 

conference calls. It heard the views of more than forty experts, including representatives of 

EPA; other federal, state, and local agencies; industry; public/private consortia; research 

institutes; universities; and environmental advocacy groups. The Focus Group visited two 

EPA laboratories and extended its work through subcommittees. 

ll 
The Focus Group assessed the role of governmental technology diffusion programs in 

the environmental management system, which today primarily consists of regulations, 

permitting and compliance systems, and diffusion mechanisms. The Group examined eight 

policy topics that are crucial to determining the strategic role of governmental programs for 

the diffusion of environmentally beneficial technologies: 

•	 The relationship between EPA's roles in technology diffusion and its
 

success in meeting its primary environmental protection objectives.
 

•	 The unique quality of barriers to the diffusion of environmental
 

technologies.
 

•	 The identity, methods, and motivations of those who diffuse
 

environmental technologies.
 

•	 The adequacy of EPA's diffusion organizations and activities. 

•	 The impact of EPA's diffusion strategies on environmental investment
 

decisions by the private sector.
 

•	 The need to use unique approaches in EPA's role in the diffusion of
 

technologies that prevent pollution.
 

•	 The keys to a successful EPA effort in international technology
 

diffusion.
 

•	 The opportunities for EPA to make better use of the Federal
 Technology Transfer Act.
 

The Focus Group defined the diffusion of technology as the spread and adaptation of a 

technical idea following its first successful commercial use. Diffusion activities include 

technical assistance, information management and transfer, training, publications, licensing 

policies, marketing, education, and technology transfer programs. 

Major Findings The Technology Innovation and Economics (TIE) 

And Committee concluded that enhanced EPA technology 

Recommendations diffusion programs are essential to the achievement of 

EPA's environmental protection mission (see the Findings 

and Recommendations sections of this report). The lack of strong diffusion programs in 

the U.S. environmental management system -- and the limited coordination among existing 

programs within EPA and between EPA's programs and those outside EPA -- hinders the 

development, evaluation, and use of innovative environmental solutions. This increases 
costs and reinforces a tendency in regulatory mechanisms to overspecify technology. Such 

a pattern is particularly detrimental to the pollution prevention and international 

environmental goals of the agency. To remedy these problems, the TIE Committee 

recommends that EPA integrate technology diffusion into the environmental management 

system. The agency should establish the climate, culture, and incentives necessary to 

encourage the widespread use of improved technology solutions that enable environmental 

progress in a sustainable economy. 

The TIE Committee's Diffusion Focus Group focused on three key barriers hindering 

the widespread use of innovative technologies in environmental applications. 

1. The way in which best available technology-based regulations are 

implemented and enforced. 

2. Permitting and compliance policies and practices that do not foster 

technology innovation and pollution prevention. 

3. Barriers to information and technology transfer. 

EPA and other environmental agencies could gain significantly from increasing their 

emphasis on strategies that encourage technology diffusion, such as the "Green Lights" and 

the SARA Title 3 release reporting programs. The benefits of enhanced technology 

diffusion include: 

• Increased domestic and international environmental quality. 

• Wider availability of lower cost solutions to environmental problems. 

• Gains from the export of technological improvements. 

• Increased use of pollution prevention technologies and techniques that 

co-optimize for productivity and environmental results. 

• A less adversarial relationship with regulated organizations. 

A more competitive U.S. economy. •

 

The TIE Committee recommends several specific strategic and structural changes to 

help EPA to realize its mission by making cost-effective use of technology diffusion 

mechanisms. The Committee's central findings and recommendations are: 

iv 
1 

FINDING: EPA, which perceives itself as primarily a regulatory agency 

has a mission to protect human health and the environment. 

RECOMMENDATION: Make technology diffusion a major supporting 

mission for EPA. The agency has moved in the right direction with its focus on themes 

in the planning process and its increased attention to relative risk. It will need to reinforce 

its new emphases with enhanced programs for the diffusion of technology. The TIE 

Committee recommends that EPA take several critical actions: 

1. Establish a high level position to advocate the role of 

diffusion in accomplishing the agency's mission, to promote	 

changes in EPA's culture to support diffusion activities, and to	 

coordinate the agency's diffusion programs.	 

2. Redeploy EPA's diffusion resources to increase their	 

effectiveness and efficiency.	 

3. Develop the diffusion support tools that Agency employees 

require, including career enhancements, training, performance	 

standards, information, and rotational assignments.	 

4. Include in EPA's approach to regulation incentives that

 

encourage innovation and emphasize diffusion as a major 

contributing element of the environmental management 

system. 

Among the key specific actions recommended by the Committee are: 

Modifying the agency's culture and incentives to support the concept 

that the diffusion of technology can catalyze environmental 

improvement. 

•­ Adopting a requirement that all agency program plans contain a	 

technology diffusion component.	 

•­ Expanding agency resources to support increased programs for	 

technology diffusion.	 

•­ Creating new partnership relationships and strengthening existing ones	 

to enhance the effectiveness of agency diffusion programs.	 

•­	 Learning from other agencies' diffusion programs. 

•­ Broadening the sources of information contained in EPA's diffusion	 

programs.	 

v 
2 

FINDING: Coordination is lacking between EPA and its potential partners 

in planning and conducting activities to diffuse technological information. 

RECOMMENDATION: Build a stronger partnership with technology 

diffusion providers and users. The "command and control" based environmental 

management system increases the adversarial, non-supportive nature of relationships 

between groups whose cooperation is needed to accelerate environmental improvement. 

Increased cooperation is critical to the success of EPA in its mission and is particularly 

essential in the diffusion of environmental information. Although a wide variety of 

organizations fill one or more roles in the diffusion of technology, EPA could work more 

systematically with many of these potential partners to make the system to diffuse 

information work effectively and efficiently. The potential partners include regulated 

organizations, state and local governments, entrepreneurs, research consortia, consulting 

engineers, universities, information providers, and other federal agencies. EPA should: 

1. Work more effectively with the full range of diffusion

 

partners, including information developers, diffusion providers, and	 

diffusers, to actively promote the increased use of innovative	 

environmental solutions.	 

2. Increase its collection and generation of credible

 

information about environmentally beneficial technologies. 

3. Take advantage of the full range of diffusion mechanisms, 

including its own and others' research, information systems, technical 

assistance programs, publications, training, trade shows, professional 

conferences, and cooperative research and , licensing programs. 

4. Define, collect, and analyze environmental business data to 

understand diffusion partners and information users. 

5 . Support university curriculum development to increase literacy	 

in environmentally beneficial technology.	 

Among the key specific actions recommended by the Committee are: 

•­ Leveraging EPA's limited diffusion resources by actively seeking out	 

diffusion partners and promoting others' diffusion activities.	 

•­	 Expanding efforts to understand the needs of information users. 

•­ Working with state and local governments as critical channels of	 

technology diffusion.	 

•­	 Establishing a bureau of environmental statistics. 

vi 
3 

FINDING: EPA has not recognized that success in pollution prevention 

depends on the success of diffusion and incentive-based approaches. 

RECOMMENDATION: Make diffusion and incentives the emphases of 

EPA's pollution prevention programs. The unique factors that motivate pollution 

prevention are particularly responsive to diffusion and incentive approaches. Pollution 

prevention requires a continuing commitment that is proactive, internally maintained, and 

culturally different in nature. If a "level playing field" is created by applying underlying 

requirements and enforcing them against all polluters, pollution prevention can be driven by 

information and incentives. The agency should: 

1. Preferentially increase its use of data-based, non-

regulatory drivers, including diffusion programs, as a 

feature of EPA's pollution prevention strategy. 

2. Create incentives, including multi-media approaches, that

favor the choice of pollution prevention by regulated and 

non-regulated organizations. Improved regulatory, permitting,	 

and compliance practices can place emphasis on the increased	 

availability of information about pollution prevention methods brought	 

about by stronger diffusion programs. A combination of regulatory 

and non-regulatory incentives can best influence the development and 

application of pollution prevention approaches, and information sharing 

about them. 

3. Introduce new steps to diffuse the pollution prevention 

ethic within EPA and to establish a system of incentives 

and support for diffusion efforts by EPA personnel. Such	 

support includes agency policy direction and an increased use of	 

incentives, rewards, training, and information.	 

4. Increase resources for EPA's own technology R&D efforts 

focusing on pollution prevention. 

Among the key specific actions recommended by the Committee are: 

•­ Strengthening and expanding the use of such successful data-based	 

drivers of pollution prevention as Section 313 of SARA, the 33 - 50	 

program, and the Green Lights program.	 

•­ Strengthening programs to diffuse pollution prevention research and	 

development results, operating experience, and accounting methods to	 

regulated organizations.	 

•­ Designing regulations and regulatory processes to encourage the use of	 

the widest possible range of solutions, including pollution prevention	 

techniques.	 

vii 
4 

FINDING: EPA's international diffusion activities are focused almost 

exclusively on developing and Eastern European nations; a much stronger 

and broader role is needed to enhance U.S. competitiveness. 

RECOMMENDATION: Expand support for the international diffusion of 

environmental technologies to help meet U.S. environmental and 

competitiveness objectives. EPA has made important progress in expanding 

international diffusion activities (working in conjunction with traditional federal lead 

agencies), particularly in its new pilot efforts in Eastern Europe, Latin America, and 

Southeast Asia. Working with these partners, EPA should significantly increase support 

for the diffusion of environmentally beneficial technologies ] h into and out of the U.S. 

within the overall goal of environmental improvement. This direction is extremely 

important to the pursuit of both sustainability and competitiveness. EPA should: 

1. Increase support for the diffusion of environmental 

technologies out of the U.S. This step may lead to greater	 

environmental improvements overseas, especially in developing	 

countries where little pollution reduction has occurred.	 

2. Strengthen support for U.S. exports of environmentally 

beneficial technologies to the major world markets in the 

industrialized nations. 

3. Enhance EPA's technology diffusion efforts aimed at 

expanding the range of environmental technology solutions 

available domestically. An increased effort to gather information	 

on state-of-the-art environmentally beneficial technologies developed	 

abroad is needed. There is insufficient cooperation to this end between	 

industry and government and among governmental agencies.	 

Among the key specific actions recommended by the Committee are: 

•­ Encouraging the harmonization of international environmental	 

awareness and standards.	 

•­ Supporting business development centers overseas for U.S.	 

environmental firms.	 

•­ Collecting information on international environmental markets and	 

environmental regulations, and making that information generally	 

available.	 
5 

FINDING: EPA's research programs do not adequately support the 

agency's diffusion mission. 

RECOMMENDATION: Increase support for the diffusion of technology 

provided by EPA's research programs on environmentally beneficial 

technologies. Because the resources invested by EPA in research, development, 

demonstration, and evaluation (R&D) on environmentally beneficial technologies comprise 

a small fraction of the total U.S. R&D investment, EPA will have to focus its limited 

efforts on the most important technology opportunities emphasize other major roles for 

its environmental technology research programs. EPA's current technology research 

activities should be refocused to take on a major role in the diffusion of information about 

credible environmentally beneficial technologies. To accomplish this, EPA should: 

1. Adopt a leadership position in environmental innovation 

throughout the R&D life cycle. The R&D life cycle includes	 

R&D planning, the conduct of R&D (including research, development,	 

demonstration, testing, and evaluation), and the dissemination of the	 

results of these activities among all participants in the environmental	 

management system (including industry, other federal agencies, state	 

and local governments, universities, and research consortia).	 

2. Build and expand EPA coordination efforts in 

environmental R&D programs across the public and private 

sectors. 

3. Use EPA's technology R&D programs to improve the 

quality of environmentally beneficial technology data 

generated by others. 

4. Emphasize the commercialization endpoint in 

environmental technology R&D programs -- whether they are	 

EPA's or those that EPA influences in its leadership role.	 

Among the key specific actions recommended by the Committee include: 

•­ Taking a leadership position to increase interagency cooperation in	 

environmental technology R&D.	 

•­ Involving industry, consortia, state and local governments, and other	 

important players in planning EPA's technology R&D.	 

•­ Requiring EPA to attract private sector co-funding for a portion of its own 

technology R&D. 

•­ Expanding the new program to encourage testing of environmentally beneficial 

technologies at federal facilities. 

ix 
5 (continued) 

FINDING: EPA's research programs do not adequately support the 

agency's diffusion mission. 

RECOMMENDATION: Increase support for the diffusion of technology 

provided by EPA's research programs on environmentally beneficial 

technologies. 

Additional key specific actions recommended by the Committee are: 

Increasing EPA's cooperative research and testing efforts. 

Instituting an industrial user facility program at EPA to enable outside 

parties to make use of unique EPA facilities.	 

Establishing programs for the use of EPA laboratories to test and	 

evaluate technologies developed outside the agency.	 

Strengthening EPA's FTTA effort, which is already growing rapidly.	 

Increasing ORD's efforts, working with EPA's diffusion partners, to	 

disseminate information about environmentally beneficial technologies.	 

Promoting the harmonization of technology testing and reporting, so	 

that performance data are useful to a broader range of users.	 

•­ Building EPA's expertise in economics, marketing, and 

commercialization. (Expanding these areas of expertise would also be 

valuable in other EPA programs.) 

x 
II. PREFACE
 

The U.S. environmental management system was developed to protect human health 

and the environment. The environmental management system includes all legislative 

authorities, regulatory processes and regulations, regulatory administrative systems 

(permitting, compliance, and certification), technology transfer and other support 

programs, and federal, state, and local environmental research programs. This system has 

achieved significant progress toward these goals, but much greater progress is needed to 

meet remaining objectives and the new needs that will surely arise. A particular challenge 

for the future is to combine further environmental progress with sustainable economic 

growth. 

The National Advisory Council for Environmental Policy and Technology (NACEPT) 

was formed in 1988 as a source of outside policy advice to the Administrator of the U.S. 

Environmental Protection Agency (EPA) on improving U.S. environmental management, 

with a special focus on technology. NACEPT's mission is "bridging the gap from problem 

identification to environmental solutions through successful program implementation, 

cooperation, and consensus-building by business, government, educational institutions, 

and private organizations." 

NACEPT has established five standing committees. One is the Technology Innovation 

and Economics (TIE) Committee, which advises on ways to encourage the development, 

commercialization, and use of optimal environmentally beneficial technologies. Such 

technologies, include those that reduce the cost of performance, improve overall 

performance, reduce waste, or increase productivity. They include source reduction, waste 

minimization, and other pollution prevention measures, recycling technologies, 

environmental control technologies, cleanup technologies, monitoring and measurement 

technologies, analytical techniques, and information management systems. The TIE 

Committee recognizes a hierarchy of technology approaches to environmental 

improvement, with pollution prevention in general being the preferred option. It also 

believes that EPA is unlikely to accomplish its goals unless the nation's ability to produce 

and apply environmentally beneficial technologies is improved. 

Technology diffusion is one critical element of the environmental management system. 

Diffusion includes technology transfer, technical assistance, training, education, and 

1	 
information management and transfer. Through diffusion, environmentally beneficial 

technologies become more accessible and more responsive to the needs of users and 

government at all levels. 

NACEPTs January 1990 TIE Committee report observed that simultaneously 

improving environmental protection and economic competitiveness requires the 

development and use of innovative technologies. Citing, lagging investment in technology 

innovation, NACEPT pointed out that further study was needed of how regulation, tax 

policy, and corporate decision making affect the development and commercialization of 

environmentally beneficial technologies. NACEPT recommended that EPA assume 

leadership in fostering environmentally beneficial technology innovation and that the 

Administrator take three key steps: 

Evaluate the degree to which U.S. environmental programs stimulate 

technology innovation. 

Issue a policy statement expanding the Agency's mission to include the 

fostering of technology innovation. 

Develop and implement a strategy for fostering technology innovation. 

NACEPT's 1991 report on the effects of permitting and compliance policies on 

environmentally beneficial technology innovation argued that the current environmental 

regulatory system does not systematically address the creation and diffusion of technology. 

The report identified five general areas of needed improvements: 

•­ Modifying permitting systems to aid the development and testing of	 

innovative environmental technologies.	 

•­ Implementing permit processes to aid the commercial introduction of	 

innovative technologies.	 

•­ Encouraging the use of innovative environmental technologies in	 

compliance programs	 

•­ Maximizing the effectiveness of permitting and compliance	 

improvements by supporting stakeholders.	 

•­ Identifying and removing regulatory obstacles to the use of innovative	 

environmental technologies.	 

2 
Deliberate encouragement of all three processes of the technology R&D life cycle -­

innovation, invention and diffusion -- is crucial to governmental success in promoting 

optimal environmental solutions. To help the Agency learn how to be most successful in 

encouraging technology diffusion, the TIE Committee formed the Diffusion Focus Group 

and charged it with answering the following questions: 

•­ What should EPA's role be in a market-dominated diffusion system? 

•­ How can technology and other information be diffused more effectively	 

by EPA and industry?	 

The Focus Group organized its 16-month investigation to address the following 

eight specific issues: 

•­ Should there be a policy defining the relationship between EPA's role	 

in the diffusion of environmentally beneficial technologies and the	 

achievement of EPA's major objective of protecting human health and	 

the environment?	 

•­ Are there unique barriers to the diffusion of technology for	 

environmental purposes?	 

•­ Who diffuses technology for environmental purposes, why, and how? 

•­ Should the organizations and activities of EPA and others be improved	 

with respect to environmentally beneficial technology diffusion?	 

•­ What are the influences of EPA diffusion strategies on private sector	 

environmental investment decisions?	 

•­ What are the differences and/or similarities between EPA's role in the	 

diffusion of pollution prevention technologies and its role in the	 

diffusion of other technologies for environmental purposes (notably,	 

for pollution control and remediation)?	 

What are the differences and/or similarities between EPA's domestic 

and international roles in diffusion? 

What is needed to make better use of the Federal Technology Transfer 

Act of 1986? 

The Focus Group held four two-day meetings and convened through a number of 

conference calls between January 1991 and April 1992. It heard the views of a wide range 

of interested parties, including representatives of EPA and other federal, state, and local 

agencies, industry, public/private consortia, research institutes, universities, and 

3 
environmental advocacy groups (see Appendix 1). The group solicited and received 

comments on the report from every involved office at EPA. 

The Diffusion Focus Group unanimously approved the report on April 15, 1992 and 

forwarded it to the TIE Committee for review and approval. Approval was granted by the 

TIE Committee in May, 1992. The report was then forwarded to NACEPT for 

concurrence and submission to the Administrator of EPA. 

This report may contain unintended omissions due to the limited time and resources 

available to the Diffusion Focus Group for the preparation of this report. As stated 

previously, the Group made every attempt to include all of the relevant EPA offices and 

outside stakeholders in the process of gathering facts and conducting analysis. Beyond the 

limits of time and resources, it should be noted that other omissions may be examples of 

failures in the diffusion system. When a significant diffusion resource was not found and 

studied by the Group, that omission may be may be representative of a failure in the 

diffusion process. 

4	 
III. INTRODUCTION	 

Although great environmental progress has been made in recent decades, there are still 

significant shortcomings in the quality of America's environment today. The U.S. 

environmental management system, in which EPA is a key player, has reached a point 

where it has become unlikely that in their traditional adversarial roles, polluters and 

regulators can work together to efficiently solve the county's current environmental 

problems. A new, more cooperative approach to environmental management must be 

adopted in order to simultaneously improve, i.e., co-optimize, environmental quality, 

economic productivity, and international competitiveness. How can EPA adopt such a 

program and still accomplish its mission of protecting human health and the environment? 

One method the agency should use more of is the diffusion of environmental 

technologies throughout the world. In a world of rising populations and economic 

expectations, the widespread application of new and innovative technologies would seem to 

be the natural answer. For example, rather than reducing the amount of light available, we 

could apply new lighting methods. Rather than eliminating plastics, we might look at new 

ways of recycling them into their component parts and find more environmentally benign 

plastics. Rather than shutting down a refinery, we could apply advanced pollution 

prevention techniques that not only reduce pollution, but also produce economic value for 

the refinery owner. 

The diffusion of environmental technologies world-wide is a relatively low cost way to 

make global environmental improvements. Sharing an environmental technology with the 

rest of the world multiplies its value. For example, if a foreign polluter can adopt an 

environmental technology that is ten million dollars less expensive than the current 

technology he is considering, we have in effect given that polluter a ten million dollar 

subsidy to reduce pollution. Such incentives can have a powerful effect on regulated 

organizations in third world countries where economic concerns often outweigh 

environmental concerns. 

The global diffusion of environmental technologies has two additional benefits. First, 

it makes available foreign technologies to U.S. regulated organizations, potentially 

lowering costs and/or reducing pollution. Second, because the U.S. is the world's leading 

environmental product and service producer, global diffusion may lead to increased U.S. 

exports of environmentally beneficial technologies. This may, in turn, lower the unit costs 

5	 
of U.S. environmental product and service providers and attract more capital to field. This 

increased capital should result in additional environmental R&D in the U.S. 

The same benefits that are received from international diffusion can be obtained on the 

domestic front. Making more environmentally beneficial technologies available to regulated 

organizations may reduce their costs and/or reduce pollution. Shortening the time it takes 

for a new environmentally beneficial technology to get to market and be broadly adopted 

may attract new capital to the field. Any time there is a lack of reliable, credible information 

there is a barrier to employing a new technology, environmental or otherwise. Diffusion 

reduces the barriers and encourages the use of new and innovative technologies because it 

helps create and spread information about the technology. 

One of the best things about diffusion is that it is relatively inexpensive for EPA. 

There are no large costs for additional R&D facilities, no d irect subsidies needed for users, 

no restrictive regulations or long legal battles. In fact, the agency has a wide variety of 

diffusion programs underway right now, some of them doing exactly what is needed. This 

is the good news. 

However, EPA's diffusion efforts need to be coordinated. They need to be a higher 

priority for agency personnel and to be supported by agency policies and resources. 

Moreover, the agency should reach out to potential diffusion partners to share the message 

and the burden. There are a great many ways for EPA to get more value out of its current 

diffusion programs and resources, not to mention the serious need for additional resources 

in certain areas. 

The remainder of the Introduction discusses what technology diffusion is and who the 

diffusion "stakeholders" are: those who are in some way involved in or impacted by 

diffusion. The rest of the report examines in detail the policy instruments that EPA can use 

to increase the pace and probability of any environmentally beneficial technology gaining 

widespread use and the findings which led to these recommendations. 

6	 
What is Technology Diffusion? 

"Diffusion" is the spread and adoption of an idea following its first successful 

commercial use. When environmentally beneficial technologies are put into widespread 

use, all environmental stakeholders gain -- technology developers, technology users, the 

public, the environmental management agencies, and the investment community. Making 

more effective use of diffusion as an element of the environmental management system is 

necessary if EPA is to achieve its goal of protecting human health and the environment. 

The development, innovation, and diffusion of environmentally beneficial technologies 

are critical to improving environmental protection and to simultaneously promoting 

environmental and productivity efficiency. Technology innovation refers to the first 

commercial use of a new technical idea. Technology diffusion is the spread and adoption 

of a technical idea following its first successful commercial use. Clearly, the use of 

innovative environmental solutions (notably technologies and approaches that achieve 

greater environmental protection or lower costs) depends on their adequate diffusion. 

Diffusion can also be the most cost-effective approach to environmental protection, since it 

allows the full exploitation of the best technologies already available. 

The TIE Committee chose the term "diffusion" (rather than technology transfer) for 

two reasons: 

•­ Throughout the 20-year history of the federal environmental program,	 

technology transfer has been regarded by many people as a stepchild	 

program, in which the federal role held a lower priority when compared	 

to other elements of the environmental management system. Federal	 

technology transfer efforts were viewed by many to be of secondary	 

value and competitive with commercial technology transfer efforts and	 

were often criticized as jeopardizing the federal government's	 

objectivity when compliance failures occurred. The TIE Committee	 

believes that this view fails to recognize the critical role of diffusion	 

programs in the environmental management system.	 

•­ The term "technology transfer" does not capture the set of activities that	 

constitute technology diffusion. In popular parlance, technology	 

transfer means moving a technology from government labs to industry,	 

or from one community to another. Diffusion is the process of getting 

technologies that are ready for commercial use into widespread 

practice, within and between different industries and institutions. 

Diffusion is the third phase of the technology life cycle and is preceded 

by "invention" -- the birth of a technology concept -- and "innovation" 

7 
-- the development of a technology concept into a commercial product 

and the first uses of that product. During the diffusion phase, a 

product's use expands and it is adapted to fill other commercial needs. 

Diffusion activities include at least the following: technical assistance, 

information management and transfer, training, publications, licensing 

policies, marketing, education at the college and graduate levels, and 

technology transfer programs. Technology transfer is only one subset 

of the activities that are relevant to diffusion. 

The diffusion of a technology is supported by a wide range of groups, including those 

with a proprietary interest, the government (in pursuit of its environmental protection 

interest), professional groups, trade groups (in the interest of solving common problems), 

consulting engineers (whose advice is used by regulated organizations), and environmental 

organizations (who seek to educate the public and polluters, and to influence regulators). 

Along with regulation, permitting and compliance programs, certification, grant 

assistance, and research, diffusion is an important part of the environmental management 

system. Diffusion receives an inadequate amount of agency attention, resources, and 

perceived value. 

The diffusion process embraces all types of information about environmentally 

beneficial technologies, including conventional approaches, best practices, innovative 

technologies, and pollution prevention methods. Strong diffusion efforts are especially 

critical to the spread of pollution prevention methods, which encompass technologies and 

techniques that effect changes in production activities and product designs. Diffusion is 

also vital to the employment of other innovative environmental technologies. The use of 

The use of both pollution prevention methods and environmental technologies is 

information-intensive, depending on state-of-the-art technical knowledge, intimate 

knowledge of industrial processes, and an understanding of regulatory flexibilities. 

The Stakeholders 

There are several groups of stakeholders involved in the diffusion of environmental 

information, who benefit from the process in various ways: regulated organizations; new 

(and possibly not yet regulated) entrants to a manufacturing or production market; federal, 

state, and local regulators; providers of environmental products and services; investors; and 

the public. Organizations may fall into more than one stakeholder category. They may be 

producers or consumers of environmental information, and not infrequently they are both. 

8	 
All stakeholders stand to gain from the freest flow -- the greatest diffusion -- of 

information possible, within the constraints of protecting confidential business information. 

Regulated organizations. Because they must comply with regulatory 

requirements, regulated organizations are uniformly concerned with obtaining accurate 

information to assist their own compliance. All regulated organizations require sufficient 

information on the environmental requirements, policies, and practices, at federal, state, 

and local levels, with which they must comply. All are concerned with obtaining credible 

information about regulatory requirements and processes, and with receiving reliable 

results from their choice of environmental solutions. Many organizations choose a 

compliance strategy that entails minimal risks and disrupts production the least-- often an 

end-of-pipe solution. Others are willing to consider a broader range of options to cooptimize productivity and environmental results. These organizations especially require 

ready access to full information about all available options. 

The diffusion of information about environmentally beneficial technologies and 

technical assistance are particularly important for industries dominated by small to mediumsized firms. Such firms are less likely to be technically self-sufficient or to possess the 

resources needed to access the best technical advice. Firms in these industries may prefer 

to rely on "good services" third parties. 

Actually, firms in all industries often choose to rely on "good services" third parties, 

as well as (or instead of) government, to learn of their options. Such sources of 

information include other similar firms, state commerce departments, trade and professional 

associations, and university-based consortia. 

Regulated organizations are both generators and diffusers of information. While firms 

are naturally concerned with protecting information that provides them with a competitive 

advantage (such as that embodied in special production processes), they are often willing to 

share information when the result may be of mutual benefit. In some notable cases, they 

have even shared information on environmentally beneficial technologies to avoid 

regulators' imposition of more stringent measures, whether immediately or in the future. 

In some cases, firms may establish a new profit center by selling their specialized 

environmental expertise. 

9	 
The lack of adequate information on environmentally beneficial technologies clearly 

adversely affects regulated firms. Aspects of diffusion systems of particular concern for 

these stakeholders include: communication and cooperation with regulators about 

environmental technology information; understanding regulatory, permitting, and 

compliance processes and requirements; and accessibility of state-of-the-art 

environmentally beneficial technology information, with concern for confidentiality. 

New entrants to the areas of manufacturing or production also need accurate information 

similar to that required by regulated organizations. These new entrants typically 

manufacture products that are environmentally benign, but can also compete with 

environmentally harmful products (e.g., carbon dioxide charging systems for aerosol cans, 

silicones that substitute for PCBs in transformers). They need information about 

environmental trends regarding competing products and how the competition is to be 

regulated. These new entrants' products are usually unregulated by EPA because of their 

benign nature. 

Regulators (federal, state, and local government). Regulators, including 

rulemakers, permit writers, and compliance personnel, require access to information and 

also provide mechanisms to disseminate information. To fulfill their role as regulators, 

they must understand and be able to communicate regulatory requirements and processes. 

They must also be technically competent and understand the perspectives of regulated 

communities. The latter expertise can be gained through academic training and, more 

critically, from appropriate contacts within regulated organizations and their 

representatives, such as trade and industry organizations. Rulemakers need ready access to 

information on state-of-the-art technologies and their performance, cost, and reliability 

characteristics to write regulations. Similarly, permitting and compliance personnel need 

such information to perform their functions, although their ability to share it is sometimes 

compromised by the regulatory nature of their contact with users. 

Through regulations, permits, and compliance actions, regulators announce to all 

stakeholders the availability of approved technologies and techniques. They can also 

encourage the use of advanced technologies, such as pollution prevention techniques and 

innovative technologies, and therefore future development and investment in new 

technologies through direct and indirect means. By providing predictability, consistency, 

and cross jurisdictional coordination through regulations, permit approval processes, and 

compliance actions, regulators can create a powerful incentive to search for improved 

10	 
solutions. This, in turn, fuels the need for diffusion services and makes more information 

available to include in them. 

Through their research programs, government agencies are also important developers, 

collectors, evaluators, standardizers, compilers, and diffusers of environmentally beneficial 

information. These roles make government research agencies critical players whose 

credibility and neutrality are essential foundations for information and technology transfer. 

It is a major diffusion concern for members of this community are that they be well 

informed about the regulatory system. They also need to know the characteristics of 

environmentally beneficial technologies and techniques, including those representing the 

state-of-the-art. Finally, they require mechanisms to make useful information widely 

available to those who need it. 

Providers of environmentally beneficial products and services. 

Developers and marketers of environmentally beneficial technologies are major generators 

and diffusers of information, though they also require access to information to fulfill their 

roles. They provide technology and associated information to regulators, users, investors 

and the public, on performance, costs, reliability, and risks. Results of technology 

development, testing, and demonstration provide the basis for regulations, the actions of 

investors and users, and the actions of the public, who may, for example, allow the siting 

of technologies depending on testing and demonstration results. (Trade and professional 

associations provide a trusted mechanism for the diffusion of such results.) 

Technology providers are central to technology diffusion. They have large 

information needs, because of their need to gauge market risks, and to satisfy regulatory 

requirements. They need to develop and provide adequate information so that users, 

regulators, and the public can evaluate the applicability and acceptability of technologies. 

For their part, developers must anticipate environmental problems, user needs, and public 

acceptability. These are the major diffusion concerns for this community. 

investors. Investors support technology developers and the entire provider 

community, as well as regulated organizations. They are major stakeholders in the 

diffusion process, but are minimal direct diffusers of technology. Their own diffusion 

needs ultimately revolve around their interest in measuring and ultimately reducing risk. 

The availability of information about environmental regulations, permitting and compliance 

11
policies and practices, and markets is important to their measurement of risks, as is the 

availability of performance, cost of performance, and reliability data derived from testing 

and demonstration. Finally, investors are concerned that diffusion systems will help carry 

the message about technologies they have supported to users, regulators, and the public. 

Thepublic. The public and its representatives, the public interest groups, are large 

consumers of diffusion services. They need access to credible information about the 

performance, costs, reliability, and risks of innovative environmental solutions and their 

alternatives, as well as about regulations and regulatory processes, so they can decide 

whether solutions that are proposed are the best choices (or an acceptable choice) for a local 

environmental problem. Peoples' fear about what they do not understand is universal, and 

the public's lack of trust is only reinforced in the absence of information that is not 

credible. The public interest groups are important providers of information on the 

acceptability of technologies to the public and to other stakeholders. Public acceptability, 

which depends on the good functioning of these information channels, is a major 

determinant of decisions by developers, investors, and users in developing and 

commercializing technologies. Regulations and permits in significant measure reflect such 

public acceptance, as do the statutes that underlie them. Thus, elected officials are another 

important consumer of well functioning information channels. 

12
solutions. This, in turn, fuels the need for diffusion services and makes more information 

available to include in them. 

Through their research programs, government agencies are also important developers, 

collectors, evaluators, standardizers, compilers, and diffusers of environmentally beneficial 

information. These roles make government research agencies critical players whose 

credibility and neutrality are essential foundations for information and technology transfer. 

It is a major diffusion concern for members of this community are that they be well 

informed about the regulatory system. They also need to know the characteristics of 

environmentally beneficial technologies and techniques, including those representing the 

state-of-the-art. Finally, they require mechanisms to make useful information widely 

available to those who need it. 

Providers of environmentally beneficial products and services. 

Developers and marketers of environmentally beneficial technologies are major generators 

and diffusers of information, though they also require access to information to fulfill their 

roles. They provide technology and associated information to regulators, users, investors 

and the public, on performance, costs, reliability, and risks. Results of technology 

development, testing, and demonstration provide the basis for regulations, the actions of 

investors and users, and the actions of the public, who may, for example, allow the siting 

of technologies depending on testing and demonstration results. (Trade and professional 

associations provide a trusted mechanism for the diffusion of such results.) 

Technology providers are central to technology diffusion. They have large 

information needs, because of their need to gauge market risks, and to satisfy regulatory 

requirements. They need to develop and provide adequate information so that users, 

regulators, and the public can evaluate the applicability and acceptability of technologies. 

For their part, developers must anticipate environmental problems, user needs, and public 

acceptability. These are the major diffusion concerns for this community. 

Investors. Investors support technology developers and the entire provider 

community, as well as regulated organizations. They are major stakeholders in the 

diffusion process, but are minimal direct diffusers of technology. Their own diffusion 

needs ultimately revolve around their interest in measuring and ultimately reducing risk. 

The availability of information about environmental regulations, permitting and compliance 

11
IV. MEMBERS OF THE TECHNOLOGY INNOVATION

AND ECONOMICS (TIE) COMMITTEE 

Members of the Diffusion Focus Group: 

Mr. William W. Carpenter, Chair 

Mr. Dag Syrrist, Co-Chair 

Mr. John W. Adams 

Dr. Edgar Berkey 

Dr. David Bodde 

Dr. Samuel I. Doctors 

Mr. Gary Dwoskin 

Dr. Robert E. Finnigan 

Mr. James Hall 

Mr. Richard Kibler 

Ms. Cherri J. Langenfeld 

Dr. Gerald Nehman 

Dr. Lawrence Ross 

Mr. William Sonntag 

Dr. J. Kenneth Wittle 

Dr. Alan Lloyd 

Mr. David G. Sobers 

Dr. David Thomas 

Contributors to the Diffusion Focus Group: 

Martin Marietta Energy Systems, Inc. 

Technology Funding, Inc. 

National Defense Environmental Corporation 

National Environmental Technology Applications Corporation 

Midwest Research Institute 

California State University, Hayward 

National Academy of Sciences 

Finnigan Corporation/Thermo Instrument Systems 

U.S. Department of Agriculture 

U.S. Department of Defense 

U.S. Department of Energy 

University of Texas at Arlington 

American Institute of Chemical Engineers 

National Association of Metal Finishers 

Electro-Pyrolysis, Inc. 

South Coast Air Quality Management District (CA) 

Montgomery County (MD) Department of 

Environmental Protection 

Illinois Hazardous Waste Research & Information Center 

Dr. John Ehrenfeld 

Ms. Diane Cameron 

Staff: 

Mr. David R. Berg, TIEC Director 

Mr. Morris Altschuler 

TIE Committee Members: 

Dr. Nicholas A. Ashford, Chair 

Mr. Thomas Devine, Vice Chair 

Mr. Paul Arbesman 

Dr. R. Darryl Banks 

Dr. David Bodde 

Dr. Paul Busch 

Mr. William W. Carpenter 

Mr. William Haney III 

Dr. John W. Liskowitz 

Gen. James McCarthy 

Mr. John Palmisano 

Mr. Frank Pope 

Dr. Walter R. Quanstrom 

Dr. Robert Repetto 

Mr. Martin E. Rivers 

Dr. Manik "Nikki" Roy 

Dr. Lawrence Ross 

Mr. Dag Syrrist 

Ms. Linda Stuntz 

Mr. L. Mead Wyman 

Massachusetts Institute of Technology (MIT) 

Natural Resources Defense Council (NRDC) 

Office of Cooperative Environmental Management 

Office of Cooperative Environmental Management 

Massachusetts Institute of Technology 

RMT, Inc. 

Allied Signal Corporation 

N.Y. Department of Environmental Conservation

Midwest Research Institute

Malcolm-Pirnie, Inc.

Martin Marietta Energy Systems, Inc.

Molten Metals Technology, Inc.

New Jersey Institute of Technology

U.S. Air Force

AER*X, Inc.

Technology Funding, Inc.

Amoco Corporation

World Resources Institute

Air and Waste Management Association

Environmental Defense Fund

American Institute of Chemical Engineers

Technology Funding, Inc.

Department of Energy

Hambrecht & Quist Venture Partners

13 
V. FINDINGS 

The findings in this section are based on an analysis by the TIE Committee of EPA's 

role in the diffusion of environmentally beneficial technologies. These findings lead 

directly to the TIE Committee's recommendations for improving EPA's diffusion activities 

presented in the following section. 

Finding 1 

EPA, which perceives itself as primarily a regulatory agency, 

has a mission to protect human health and the environment. 

Since its founding, EPA's mission has been to protect human health and the 

environment. No other department or agency of the federal government has this function 

as a primary mandate. 

The environmental management system, as designed in legislation, regulations, 

policies, and practices, has a primarily regulatory focus. EPA's organization, activities, 

budgeting, culture, and external relations have all been defined by its historical and 

fundamental perception that it is primarily a regulatory agency. EPA's organization is 

based on media-specific program offices, corresponding to the major pieces of federal 

environmental legislation determining EPA's functions. Other EPA offices, including its 

Office of Research and Development (ORD), largely support the regulatory functions of the 

media-specific program offices. EPA's perception of its role as regulator permeates the 

Agency's culture and external relations; EPA is deeply concerned with procedure, 

compliance, documentation, avoidance of conflict of interest, and assurance of equal 

treatment. Its relationships with regulated organizations can usually be characterized as 

adversarial, with little or no reliance on incentives to motivate innovation for environmental 

improvement. 

Historically, technology diffusion has played a limited and subordinate role to 

regulation, permitting, and compliance in the regulation-based environmental management 

system. The "best available technology" (BAT) approach to regulation optimally offers 

mixed incentives for the development and use of improved environmental and production 

15
technologies. Technologies must await the uncertain recognition by rulemakers before their 

niches in the marketplace are assured. After regulatory requirements are imposed, 

compliance with BAT-based rules requires the quick use (and diffusion) of a technology 

with the requisite performance. However, this provides no rewards for the subsequent 

development and use of better performing technologies, regardless of the environmental 

and public health risk remaining after the use of BAT. The incentive to diffuse is largely 

restricted to the BAT, and only innovation to achieve lower costs is encouraged. EPA's 

and regulated organizations' adoption of innovative approaches to environmental 

improvement are hindered by EPA's inadequate emphasis on supporting technology 

innovation and technology diffusion. 

This is ironic, because EPA determines the stringency, applicability, timing, and 

longevity of environmental requirements. The environmental marketplace is largely defined 

by these environmental requirements and their enforcement. Thus, federal decision making 

provides critical signals for regulated communities and technology developers. Finding 

regulatory signals that enhance the marketplace is a critical step. 

The environmental permitting process is another important impediment to innovation, 

with confusion about the federal, state, and local permitting processes seen both outside 

and within EPA. Both permit applicants and regulatory staffs report they are often 

confused by permitting procedures, by the different permitting requirements of different 

acts and agencies, and by permitting practices that are inconsistent between media. Testing 

and evaluation is significantly restricted by current permitting authorities and practices to 

the point that innovation is being slowed in the U.S. These problems present obstacles to 

the diffusion of new technologies. 

The TIE Committee found in its 1991 report and recommendations (and reiterates this 

finding here) that the lack of predictable and consistent permitting and compliance programs 

at all levels of government dampens the expectation of the need to comply with 

environmental requirements and, therefore, lowers the perceived need to purchase 

environmental products and services. Similarly, the lack of predictable enforcement 

discourages permittees from using innovative technologies, which inherently expose them 

to greater risk. The lack of flexibility in permitting and compliance systems reduces the 

incentive to innovate and to use innovative (and therefore more risky) solutions. All of 

these factors, along with the difficulty of predicting future regulatory requirements, 

increase the long-term development risks associated with environmentally beneficial 

16
technologies, diminishing the relative attractiveness of investment. They therefore 

discourage entrepreneurs from investing money and effort in the innovation process and 

dissuade regulated organizations from using the technologies and techniques that result. 

Thus, the potential for the diffusion of new or newly developed technologies to support 

national environmental goals is reduced. 

The clients of EPA's information transfer efforts have been, by design, mostly 

internal, although some efforts have been directed to attract external clients. EPA's limited 

information transfer efforts, whether for internal or external audiences, have emphasized 

the publication of written reports and computerized data based on the results of its own 

research, the sponsorship of conferences, training courses, and seminars, and hot lines. 

The program of the Technology Innovation Office (of EPA's Office of Solid Waste and 

Emergency Response) is one of the notable exceptions to this rule. 

EPA manifests its low priority on the diffusion of environmentally beneficial 

technologies in a number of ways: 

•­ Having limited collaboration and coordination with other potential

partners in the diffusion of information.

•­ Failing to adequately integrate the objective of the diffusion of

information and to sufficiently emphasize diffusion programs in

regulatory policies and programs. These include permitting and

compliance policies as they relate to tests, evaluations, and use of

innovative and pollution preventing technologies and techniques.

•­ Failing to support the diffusion of information goal adequately in

planning and programs.

•­ Failing to adequately coordinate and lead efforts to diffuse information

both within and beyond the agency.

The low priority given to technology diffusion is also seen in inadequate employee 

incentives to diffuse technology (e.g., financial rewards, recognition, performance 

evaluation credit); inadequate training of personnel; unspecified, nonexistent, or inadequate 

budgets for diffusion; a single media character in most diffusion programs; a lack of 

attention to pollution prevention in diffusion programs; and the lack of internal expertise 

assigned to deal with diffusion. EPA's organizational structure also appears to discourage 

accountability and coordination in technology diffusion. 

17 
The TIE Committee believes that, while EPA's mission is unchanged, the means for 

accomplishing this mission must change. An exclusive reliance on regulatory methods is 

no longer sufficient for EPA to achieve its goals. EPA's failure to fully integrate 

technology diffusion into the environmental management system hinders the achievement 

of its mission. EPA must reverse the pattern that technical information often does not get to 

those who need it. 

Finding 2 

Coordination is lacking between EPA and its potential partners 

in planning and conducting activities to diffuse technological 

information. 

EPA is not now working closely with its potential partners to make the information 

diffusion system work effectively and efficiently. These partners include: (1) those who 

understand user needs, (2) information developers, (3) information providers, and (4) 

users or consumers. 

Many organizations play one or more of these diffusion roles, and if each did its part 

effectively, the diffusion system would work more efficiently to expand the availability of 

credible information to those who need it. Within EPA, for example, there is little 

coordination of diffusion efforts across the media offices and with the research program. 

With the exception of the Technology Innovation Office (in the office of Solid Waste and 

Emergency Response) EPA has not built a diffusion partnership on behalf of the 

environment. The resulting lack of strength in this system is a significant barrier to 

innovation and to the environmental improvement that can result from the diffusion into 

widespread use of innovative solutions. 

Importantly, EPA should provide leadership to the diffusion partners, but it now does 

not, with some exceptions. One of the barriers to working together derives directly from 

the adversarial nature of regulatory relationships. EPA's credibility, on the other hand, is 

not being fully exploited as an asset in the information transfer system of environmentally 

beneficial technologies. Many other developers of information and providers of diffusion 

services are seen by users as lacking EPA's credibility. Yet, EPA is not taking full 

advantage of its credibility to improve the volume and availability of credible information, 

18
including information about regulatory systems and processes (e.g., permitting and 

compliance systems). 

EPA plays a relatively small part in any of the four diffusion roles, as it should. Yet, 

its diffusion services appear to lack wide input in their planning, contain predominantly 

EPA-generated data, and apply a limited range of diffusion mechanisms. The fact that 

federal and state agencies account for less than 20 percent of all U.S. investment in 

environmental technology innovation (and EPA only a few percent) reveals the need for 

partnering in planning, generating, and disseminating technology information. 

There is also no systematic EPA effort to document information about the businesses 

that provide products and services used for environmental purposes. Without 

understanding both the purchase and the sale sides of environmental transactions 

domestically and internationally (i.e., the environmental market), EPA cannot clearly 

understand the impacts of current environmental policies on the nation's ability to meet 

environmental goals. Nor can it measure the national capability to innovate and adapt, and 

to remain competitive internationally. 

Finding 3: 

EPA has not recognized that success in pollution prevention 

depends largely on the success of diffusion and incentive-based 

approaches. 

EPA's efforts to encourage pollution prevention have made a good start in the right 

direction. The tendency in EPA to think first of regulation has already been noted. The 

Committee is concerned that pollution prevention programs will depend too much on 

regulations. The encouragement of pollution prevention, however, requires a different 

approach for success, one that emphasizes diffusion of information and incentives. 

The Committee believes it is important to recognize that the motivations which drive 

pollution prevention are not the same that motivate a compliance-based, end-of-pipe 

strategy. Pollution prevention requires a continuing commitment that is proactive, 

internally maintained, and culturally different in nature. In some organizations pollution 

prevention is closely related to a commitment to total quality management. Pollution 

19
prevention can be information and incentive driven because of this unique culture, but only 

if there is a "level playing field" created by underlying requirements that apply to all 

regulated organizations. 

The Pollution Prevention Act of 1990 requires EPA to promote pollution prevention. 

This undertaking is vast, affecting both small and large firms. Thousands of small U.S. 

businesses could benefit from pollution prevention techniques, but do not have technical 

staff trained to identify and apply technological opportunities. In the case of large firms 

that use complex production processes, multiple changes throughout the production system 

often lead to a pollution prevention result. In small and large firms, a great deal of 

information is required to carry out such changes -- often far more than required by an 

end-of-pipe pollution control solution. 

Still, even firms seeking low-cost pollution prevention approaches to environmental 

compliance -- information that EPA may have -- distrust EPA because of its regulatory role, 

fearing that information about pollution prevention solutions revealed to EPA 

representatives will be used to expand the regulatory grip. Fear that proprietary 

information may be revealed also restricts data sharing. It will be necessary to consider the 

impact of such factors that inhibit the direct flow of pollution prevention technology 

information between EPA and firms. 

The diffusion process for pollution prevention thus differs from the diffusion of other 

environmental purposes. Pollution prevention technologies and techniques are often 

information-intensive, requiring extensive knowledge of a plant's processes, feedstocks, 

and products. Pollution prevention often requires the close collaboration of highly 

knowledgeable partners and trust that the sources of competitive advantage within industrial 

processes will not be revealed. Some types of pollution prevention, in the areas of 

industrial hygiene, general housekeeping, lighting, grounds maintenance, and commuting, 

are less threatening to competitive advantage and more general across industry groups. 

These considerations bear directly on EPA pollution prevention R&D; EPA's potential for 

success is dependent on an active partnership with the ultimate users of pollution 

prevention solutions. 

20
Cost-accounting systems that clarify the relative costs of pollution prevention and 

pollution control are needed. The cost of pollution control may be underestimated if full 

accounting is not made of disposal, exposure to liability, and other expenses. Full 

knowledge of costs, including those incurred and avoided across the various media, might 

encourage regulated organizations to choose pollution prevention solutions more often. 

Media-specific legislation, regulations, permits, and organizational structures pose 

special obstacles to pollution prevention. The benefits of a multimedia approach can be 

significant, because this approach can better encourage the absolute reduction of unwanted 

byproducts. In power plants, for example, sulfur dioxide emissions from the burning of 

high-sulfur coal are often reduced by the use of wet flue gas scrubbers. However, these 

scrubbers generate solid wastes that must be landfilled and effluent discharges that must 

undergo treatment. A multimedia approach would encourage whatever pollution prevention 

and control measures led to the greatest byproduct reductions considering costs. For 

example, performance-based standards applied site-wide would facilitate diffusion of 

effective technology by allowing more flexibility to reduce pollution. 

EPA, state, and local field personnel are too often unaware of technical information 

that would help them encourage pollution prevention in their permitting, compliance, and 

other interactions with firms. (Of course, they may not be in the best position to encourage 

pollution prevention anyway.) This problem results from the lack of programs to collect 

and provide this information (through sources the regulated organizations will trust and 

work with readily), and from the lack of adequate technical competence on the part of 

regulators. Moreover, local government agencies have problems evaluating and 

implementing EPA pollution prevention guidance because of a lack of information and 

expertise. They look to EPA as the provider of information on testing and evaluation, and 

a partner in developing incentives, training, and other support systems. 

21
Finding 4 

EPA's international diffusion activities are focused almost 

exclusively on developing and Eastern European nations; 

a much stronger and broader role is needed to enhance U.S. 

competitiveness. 

The Committee supports the expansion of EPA's new international environmental 

programs that emphasize the diffusion of environmentally beneficial technologies to the 

developing world and to Eastern Europe. There are large environmental gains to pursue in 

the nations of these parts of the world, as well as opportunities to influence the direction of 

environmental institutions and policies at an early stage. EPA's activities seem to be "right 

on target" here. 

Minimal EPA effort is allocated to the support of U.S. environmentally beneficial 

technology exports to the major world markets (the other industrialized nations). These 

markets together exceed the U.S. market, which is the largest in the world. Moreover, 

these countries are the home to the major competitors to the U.S. environmental industry, 

many of whom are active in the U.S. It is very important to the health of the U.S. 

environmental industry that EPA expand its activities in this part of the world. The 

Committee believes that this is the case because (1) there is benefit to being able to solve 

most domestic environmental problems domestically, (2) producing industries that are most 

competitive are often the cleanest (in part because they waste the least), and (3) the world 

environmental market is one of the fastest growing and presents significant opportunities 

for exports. 

A good example of valuable government-industry cooperation has been seen in 

activities of the International Organization for Legal Metrology (OIML), a treaty-based 

organization whose Secretariat is the National Institute for Standards and Technology 

(NIST). A NIST-led U.S. delegation secured international agreements on standards -- for 

gas chromatography, atomic adsorption, high-pressure liquid chromatography, field 

instruments, and mass spectrometry applied to measuring pollutants (pesticides) in water, ­

- standards all based on U.S.-made instruments. The cooperation of industry and 

government was crucial to the international acceptance of these standards. 

22 
Minimal EPA effort is also directed toward gathering information on technologies 

developed overseas that could offer environmental and competitive benefits in the United 

States. To further U.S. environmental objectives, it is important for EPA to help identify 

environmentally beneficial technologies overseas for potential use in the U.S. Better 

technologies, wherever they come from, help hold down the costs of environmental 

improvement and of production. 

EPA could contribute to higher environmental standards worldwide and to the nation's 

competitiveness by being a more active partner in such areas as harmonization of 

environmental standards and boosting environmentally beneficial trade. To do so, 

however, the Agency must have improved coordination with other appropriate government 

agencies, including the Departments of State and Commerce, the U.S. Trade 

Representative, the Export-Import Bank, and the Overseas Private Investment Corporation 

(OPIC), which have greater responsibility and experience in international relations and can 

provide legitimacy to EPA's involvement. EPA can, in turn, lend them its central focus on 

environmental improvement and its reputation and credentials as a worldwide 

environmental leader. 

Finding 5 

EPA's research programs do not adequately support the agency's 

diffusion mission. 

EPA's environmentally beneficial technology research programs have three major roles 

to play that relate directly to EPA's capacity to perform its key function in the diffusion 

system. The first role is in planning and conducting environmentally beneficial technology 

research, the results of which are a major source of credible information that can be shared 

through diffusion programs. The second concerns influencing the R&D performed by 

others so that the data they generate will be of enhanced quality. The third is EPA's own 

role in the diffusion of credible environmentally beneficial technology information. In 

general, the Committee believes that, in order for EPA to derive major support from 

diffusion, ORD's role in diffusion must be sharpened and focused in each of these three 

areas. 

23
Some of ORD's research and diffusion programs are very good. The Pollution 

Prevention Information Clearinghouse and the new federal facilities testing program are 

examples of a new activism by ORD in collecting and developing credible data that are 

needed by EPA's diffusion partners. EPA's sponsorship of the National Environmental 

Technology Applications Corporation (NETAC) represents its first venture to foster 

directly the commercialization of environmental technologies (without endorsing any one 

technology). 

As noted earlier, EPA's environmental technology R&D spending constitutes less than 

five percent of the national total, and EPA's R&D is primarily aimed at obtaining data to 

support the regulatory process. The agency's environmental technology research primarily 

provides baseline data to establish new regulatory standards. While there is no question 

that EPA's R&D activities directly influence industry R&D decisions, the reverse is not so 

clear. With the exception of what amounts to ex post facto approval from Science 

Advisory Board committees, EPA R&D planners receive no direct and very little indirect 

input from industry and other major players in the field. Without any R&D planning input 

from regulated organizations and technology developers, EPA risks repeating research, 

applying older-generation approaches to scientific problems, or otherwise inefficiently 

allocating R&D resources. Compounding the lack of formal direct R&D planning input 

from industry is a complete lack of trained, dedicated market research personnel who could 

generate complementary information by gauging markets. 

These facts ensure that EPA cannot play a leading role as a direct sponsor of 

environmentally beneficial technology R&D. Broadening the base for planning its 

environmental technology R&D programs would help EPA fill a serious need: that some 

organization coordinate governmental environmental technology R&D. EPA's own 

programs lack a clear ability to anticipate significant trends that will influence environmental 

technology problems and opportunities, and to understand markets. Similarly, EPA has 

only begun to implement mechanisms that ensure that the maximum leverage will be 

obtained from its own technology R&D programs and has not emphasized the 

commercialization end point in these programs. Co-planning and leverage will be 

especially necessary for EPA to support improved industrial technology and low-polluting 

products. (The Committee notes the real progress EPA has made in implementing the 

Federal Technology Transfer Act, although there is a real need to expedite the process for 

establishing CRDAs [cooperative R&D agreements].) 

24 
To assess federal agencies' FTTA activities and performance, the Focus Group 

established a special task force which met with representatives of EPA, DOE, USDA, and 

the U.S. Army. The task force found that EPA has entered into fewer CRDAs than these 

other agencies. The Department of Energy and/or its laboratories have entered into 190 

CRDAs. USDA has entered into roughly 215 CRDAs, and the Army 171. EPA's current 

total is 31. EPA has also signed three licensing agreements. 

Many factors account for the disparities described above, the two most important being 

EPA's regulatory nature and the relative size of EPA's R&D budget (e.g., the Army's 

research budget is roughly four times that of EPA's). Due to EPA's regulatory nature, an 

adversarial relationship has existed between EPA and its potential cooperative partners. 

This mutual antagonism has only recently begun to change and is in part responsible for the 

agency's slow start in developing CRDAs and licensing agreements. Five CRDAs were 

finalized by EPA in 1989, 12 by 1990, and 31 by 1991. Roughly 25 EPA CRDAs are in 

some stage of negotiation at the present time. EPA is to be commended for the accelerated 

pace at which CRDAs have been signed over the past year. 

Also owing to EPA's regulatory nature, numerous offices review CRDAs at both the 

letter of intent and draft CRDA stages. (Some agencies do not even require letters of 

intent.) Coordinated by EPA's ORTA, the Office of Technology Transfer and Regulatory 

Support, CRDAs must be approved by EPA's Office of General Counsel, Grants 

Administration Division, Inspector General, and Office of Enforcement. To qualify, the 

industry CRDA partner must not be subject to sanctions resulting from a violation of a 

fiduciary duty or to any EPA enforcement action. These extra approvals are not required 

by agencies that play no regulatory role. 

In the case of the Army, many individual laboratories have their own ORTAs and legal 

support, so approval authority is close to the negotiations process. Industry has worked 

closely for decades with USDA, and the transition to the CRDA format was relatively 

simple. EPA currently has only one ORTA, located at headquarters. The current EPA 

system may be inadequate to enter the number of CRDAs its potential suggests. 

DOE, USDA, and the Army all have developed standardized CRDA documents that 

accelerate the internal review process. While the work statements vary considerably from 

CRDA to CRDA, clauses on licensing and confidentiality are generally non-negotiable. 

EPA has just introduced its own standardized CRDA format, which should accelerate EPA 

25
review, and has dedicated new legal support for CRDA review. It is also preparing a draft 

manual describing the review process. All of these recent steps are reflected in EPA's 

improved CRDA performance and are to be commended. 

In general, however, the extra approval steps required by EPA have slowed its review 

and also required more resources from the industrial partner. The TIE Committee believes 

that any changes lowering the transaction costs of establishing CRDAs, including the 

speeding of negotiation times, will benefit industry's efforts to bring new environmental 

technologies to market. 

There appears to be a learning curve on both federal agency and industry sides of 

CRDA negotiations. USDA and Army results indicate that the first CRDA signed with a 

particular firm takes the longest time. Subsequent negotiations are far shorter. The first 

step in negotiations involves the preparation of a three-page work statement by the 

interested scientific or engineering personnel. Legal deliberations follow. In EPA's case, 

legal questions still play a significant role early in most negotiations. 

The TIE Committee believes that lack of information about the potential benefits of 

FTTA cooperation is a key barrier to its expansion and ultimately to the development and 

commercialization of innovative technology. Education programs to explain the procedures 

for establishing CRDAs and licensing agreements and to stimulate the awareness of 

benefits and possibilities derived from the FTTA could better attune EPA researchers to the 

potential commercial applications of their work. The task force notes that EPA has hired a 

contractor to prepare internal education materials. Similarly, efforts to diffuse information 

on FTTA opportunities could inform potential industrial partners and increase their interest. 

The results of such internal and external awareness campaigns would be measured by the 

increase in CRDAs and licensing agreements signed by EPA and industrial partners. 

Out of the group of agencies studied, the FDA appears to most closely resemble EPA 

in its regulatory and technology transfer mission. The FDA's implementation of FTTA 

includes the following features: 

•­ CRDAs received final approval from the FDA Commissioner. 

•­ A five member CRDA Review Board reviews all CRDAs before they

are submitted to the Commissioner. Minutes of this review board are

not published.

26 
•­ The FDA principal investigator certifies the lack of a conflict of interest

in the CRDA.

•­ The CRDA is reviewed by the division of Staff Ethics and Program

Integrity, and simultaneously the CRDA is circulated to other FDA labs

and staff offices for review. This all takes place after the lab director

signs the CRDA and before it is presented to the Review Board.

•­ Conflict of interest investigations and Review Board actions are

completed before the 30-day mandatory review period starts. This

means that the review period is only used to obtain final approval from

the FDA Commissioner.

The task force has found that the starting point of the 30-day review period mandated 

by FTTA legislation is arbitrarily determined by each of the agencies examined. For 

example, the FDA defines the starting date as the date the CRDA is ready for the FDA 

Commissioner's approval. The task force therefore believes that focusing on meeting the 

30-day mandatory review period is not an effective measure of EPA's FTTA success. The 

focus should be on the total time required to obtain CRDA approval, because environmental 

technologies have a short period during which owners can profit from their use, sometimes 

as little as one year. Therefore, it is imperative that EPA work to shorten the CRDA 

approval process as much as possible. 

Currently, when EPA research plans are developed, there are no formal requirements 

to plan for subsequent diffusion and use of the research results. Valuable findings often 

languish once their intended purpose (often of supporting the regulatory efforts of a 

program or regional office) is achieved. This is an additional concern. 

An EPA emphasis on maximizing opportunities to improve the quality of information 

generated by others is important. Increasing joint or coordinated planning will help, as will 

jointly conducted research. Inadequate attention is being paid to standardizing test 

protocols, analysis procedures, and performance reporting. 

The role of EPA's research program in the diffusion of credible environmental 

technology information requires considerable rethinking. ORD appears to rely primarily on 

its own R&D for information that it diffuses. Given its role as a minor developer of this 

information, this practice limits the effectiveness of ORD information bases and diffusion 

efforts. Another factor limiting ORD's diffusion success is its tendency to be a direct 

source of information, rather than to be an indirect source. One example of this is an 

27
otherwise excellent ORD training program that is fully subscribed all year, but which only 

reaches a small percentage of the potential audience. 

The government's role is critical. As the TIE Committee's 1991 report points out, 

most innovations trigger regulatory oversight during research, development, and/or 

demonstration, and all require regulatory approvals for purposes of compliance. The 

government roles of gatekeeper, overseer, and diffuser transcend that of investor in 

environmental technology innovation. Thus, while added government financial support 

would be helpful, improved regulatory and administrative processes are vital. These would 

include incentives to encourage diffusion. 

28
VI. RECOMMENDATIONS FOR ACTION AND

COMMENTARY

SUMMARY OF RECOMMENDATIONS, 

1.Make technology diffusion a major supporting mission 

for EPA. 

2.Build a stronger partnership with technology diffusion 

providers and users. 

3.Make diffusion and incentives the emphases of EPA's 

pollution prevention programs. 

4.Expand support for the international diffusion of 

environmental technologies to help meet U.S. environmental 

and competitiveness objectives. 

5.Increase the support of diffusion provided by EPA's 

environmental technology research programs. 

Introduction 

The TIE Committee's recommendations are centered on two major areas of 

environmentally beneficial technology diffusion. First, there are actions EPA can take 

which will have a direct effect on the diffusion of environmentally beneficial technologies. 

Second, there are actions EPA can take in other parts of the environmental management 

system that support diffusion activities. 

Some of the first group of recommendations will increase environmentally beneficial 

technology diffusion because they promote the diffusion of environmentally beneficial 

technologies, either inside or outside the agency. These actions are covered in 

Recommendations 1, 2, 3, 4, and subrecommendations 5.1 and 5.2. Recommendation 1 is 

the most important recommendation. The other recommendations are not prioritized in any 

order other than the grouping noted herein. 

29 
The second group of recommendations identifies actions EPA can take that lead to the 

diffusion of environmentally beneficial technologies by making changes in other parts of 

the environmental management system. These actions will indirectly lead to increases of 

environmentally beneficial technology diffusion because activities which are related and 

critical to diffusion -- but are not diffusion activities in and of themselves -- will be 

promoted. For example, it is recommended that EPA foster technology testing and the 

development of credible performance data by others, which it can do by increasing its 

efforts to standardize test protocols. That will lead to increased diffusion because more and 

better data can be made available through diffusion systems. These recommendations are 

covered in primarily in subrecommendations 1.5, 5.1, 5.2, and 5.3. 

The Diffusion Focus Group has reviewed and now offers its support to 

Recommendation Four of the January 1991 TIE Committee Report, "Permitting and 

Compliance Policy: Barriers to U.S. Environmental Technology Innovation." 

Recommendation Four specifically addresses the support (diffusion) required for all 

stakeholders if recommendations about how to encourage innovation through permitting 

and compliance policy are to be effective. It is reproduced in Appendix 2 of this report. 

The Diffusion Focus Group has also reviewed and now offers its support to the 

recommendations from the TIE Committee to EPA's Committee On Technology 

Cooperation, made in September 1991. These recommendations, which deal with 

technology cooperation, technology innovation, and trade and the environment, are 

reproduced in Appendix 3 of this report. 

Each major recommendation listed in the "Summary of Recommendations" is 

discussed fully in the "Detailed Recommendations and Commentary" section. The 

"Detailed Recommendations and Commentary" section contains decimal-level 

subrecommendations (e.g., 1.1, 1.2, 1.3) describing the types of changes needed to 

implement each major recommendation. Letter subpoints (1.1 "a", 1.1 "b", 1.1 "c") under 

each subrecommendation describe specific implementation actions for EPA. The items 

listed in the subrecommendations and letter subpoints are a starting point for future actions 

and are not intended to be an all-inclusive list. 

30
DETAILED RECOMMENDATIONS AND COMMENTARY,

Recommendation 1:

Make technology diffusion a major supporting mission for EPA.

1.1

Create a high-level position to advocate and coordinate

EPA's technology diffusion programs. 

1.2

Modify and expand EPA's role and funding support for 

technology diffusion. 

1.3

Create an internal system of support for agency employees 

that will promote and assist technology diffusion. 

1.4

Improve the current partnership between the agency and 

users and providers of diffusion services. 

1.5

Change the regulatory system to allow the diffusion 

system to operate more effectively. 

Commentary 

Technology solutions are essential to EPA's ongoing success in accomplishing its 

mission of environmental protection. The diffusion process involves the set of 

mechanisms that make technological solutions more useful and accessible: diffusion gives 

impetus and direction to the development and commercialization of environmentally 

beneficial technologies. Strong government diffusion programs play a necessary role in 

the environmental management system, ensuring that the widest range of technology 

solutions is available to regulated organizations and enabling them to find environmentally 

and economically efficient ways to comply with and exceed environmental requirements. 

The environmental management system includes regulations; administrative practices 

and policies supporting the regulations; permitting programs; compliance and enforcement 

programs; technology diffusion programs; EPA grants to state programs; and federal, state, 

and local research programs supporting environmental objectives. The Committee believes 

that it is imperative for the agency to recognize and highlight diffusion programs as cost31
effective and efficient mechanisms that play a key and unique role in achieving EPA's 

mission. This role is unique in its ability to influence, rather than command, the activities 

of other environmental stakeholders. 

The set of tools available in diffusion programs enables government to be an active, 

positive partner with environmentally beneficial technology providers and users. Through 

diffusion, EPA is able to influence a broad range of environmental stakeholders in a 

cooperative manner, without having to resort to the command and control authority given it 

by statute. The '11E Committee commends the agency for recognizing the need to 

incorporate non-adversarial approaches in its environmental protection strategy. 

Diffusion is particularly important to EPA's effort to reach regulated parties that are not 

technologically sophisticated. These organizations have an intense need for diffusion 

support because they lack the in-house technical and financial resources to either generate 

technological solutions to solve their environmental problems or to fully evaluate the claims 

of vendors. They are often in industries that have poor compliance records. These parties 

require credible, trustworthy, and objective sources of technology information, such as 

trade associations, consulting engineers, or government. 

There are two different needs that environmentally beneficial technology diffusion can 

satisfy on the part of regulated organizations. The first need is for environmental , 

technologies that allow and enhance efficient compliance with environmental permits and 

standards. The second need is for environmentally beneficial technologies that cooptimize 

both environmental and economic outcomes. The technologies that satisfy these two needs 

are often quite disparate. The first need is typically satisfied by end-of-pipe technologies 

that are evaluated on their ability to meet minimum requirements (e.g., emissions) and their 

total cost. The second need can be satisfied only with technologies that are integral to the 

production process. These technologies are often more innovative and complex than 

conventional environmental solutions and can affect choices from raw materials to 

production processes to finished products. The user of cooptimizing technologies is able to 

apply environmental solutions to do more than meet regulatory standards, since the 

cooptimizer perceives innovative compliance as a competitive advantage that can convey 

economic gain. Satisfying both of these needs is the ultimate task of a successful diffusion 

system. 

32
How EPA approaches regulated organizations depends on their environmental 

position, namely: leader, follower, or laggard. Leaders are at the forefront of 

environmentally beneficial technology use and understanding. They are willing to apply 

innovative technologies even if there are significant risks, given the expectation of a 

reasonable reward. Leaders are technologically adept and are usually the larger members of 

their industry. They need to get good information and support for their use of innovative 

technologies, and often see innovative environmental compliance as a competitive 

advantage. Leaders can often be reached directly by regulators and are often interested in 

examining new technologies. 

Followers are at the middle ground of the use of environmentally beneficial 

technologies. They usually use technologies that are widespread and commonly available, 

and are often most concerned about an environmental technology's cost. Followers often 

use outside firms (e.g., engineering firms, consultants) for advice about the new use of a 

technology, including evaluation and installation. They tend to be grouped at the middle 

range in size when compared to the other two groups. Their interest in a new 

environmentally related technology is usually based on changes in legal requirements, and 

then only if the technology is well proven. 

Laggards are the final group of regulated organizations in the technology arena. They 

are usually the last to use innovative environmentally related technologies because they are 

interested only in staying out of the legal entanglement which threatens when they are not in 

compliance. Laggards tend to be much smaller firms than leaders or followers. Although 

there may be many more laggards than leaders or followers, they often represent a very 

small proportion of total discharge. The laggards are often single-site, privately owned 

operations that usually lack the ability to absorb any complex or unique environmental 

solutions. 

EPA's technology diffusion role is particularly important in two areas of more recent 

concern to EPA: international competitiveness and pollution prevention. The TIE 

Committee concludes that it is in EPA's interest to support the international diffusion of 

environmental technologies to help meet U.S. environmental and economic objectives (see 

Recommendation 4). Diffusion is needed to not only increase the export of domestic 

environmental technologies and the competitiveness of all U.S. producer industries that 

pollute, but also to make the best environmental technologies in the world available to U.S. 

polluters. 

33 
Technology diffusion activities are critical to the successful implementation of 

pollution prevention strategies (see Recommendation 3). The TIE Committee notes that the 

motivation to apply pollution prevention techniques and technologies is different from the 

motivations that drive regulated organizations to comply. Government's ability to influence 

the decision to prevent, rather than control, pollution can be most effective through the 

creative use of diffusion programs. These programs would increase the range of choices 

available to regulated organizations, offer incentives that reward pollution reduction beyond 

regulatory minimums, and increase flexibility in permitting and compliance programs that 

encourage innovation and experimentation (as identified in the TIE Committee's report and 

recommendations on how to foster environmentally beneficial technology innovation 

through permitting and compliance policy). If the agency is to be successful in its pollution 

prevention efforts, it must feature the vigorous promotion of environmentally beneficial 

technologies through diffusion programs. 

The following subrecommendations describe the major steps EPA must take if it is to 

mount a successful diffusion program. These steps include: establishing a person or 

group responsible for coordinating and advocating strong diffusion programs in the 

agency, the redeployment of resources needed to strengthen diffusion EPA activities, the 

creation of a system of internal diffusion support for agency professionals, the 

improvement of partnerships with outsiders to promote diffusion, and the changes needed 

in agency regulatory programs to make them compatible with the agency's diffusion 

programs. 

34
1.1 Create a high-level position to advocate and coordinate 

EPA's technology diffusion programs. 

Commentary 

The establishment of a high-level diffusion position in EPA is needed to correct a 

variety of critical problems the Diffusion Focus Group found in EPA's diffusion programs 

and throughout the diffusion system: 

•­ The technology diffusion leader would need to address the low

priority, inefficiency, and lack of internal coordination of existing EPA

diffusion activities.

•­ The diffusion leader would help address the need for the agency to

actively promote (through diffusion activities) multi-media

environmental approaches, pollution prevention, and environmentally

beneficial innovation.

•­ Since EPA originates only a small number of environmentally

beneficial technologies and generates only a small portion of the total

environmentally beneficial technology information base, a critical

function of the diffusion leader must be to pursue stronger technology

diffusion partnerships.

Since EPA is only one of a large number of players in the field, and the other players 

have a wide variety of motivations and modes of participation, it is important that EPA take 

a leadership role, coordinating disparate activities so that the diffusion system operates as 

effectively as possible as a part of the environmental management system (see 

Recommendation 2). 

a. ROLES OF THE DIFFUSION COORDINATOR: The TIE Committee 

recommends that EPA create a high level position reporting to the Administrator with 

responsibility to provide agency-wide advocacy, strategic guidance, and coordination to 

upgraded diffusion efforts. The diffusion leader should also provide coordination for the 

agency's widely dispersed, usually single media, and disparate types of technology 

diffusion activities. This diffusion leader should: promote a multi-media perspective, 

provide coordination for technology diffusion activities among the program offices, 

35
increase the agency's gathering of credible information about innovative and pollution 

prevention technologies and techniques, establish within EPA a function to aid the 

collection of foreign information about environmentally beneficial technologies, and be a 

primary player in building partnerships with others involved as providers and consumers of 

diffusion activities in both the public and private sectors. The diffusion leader could also 

provide outside parties interested in technology diffusion with an initial point of contact that 

could direct them properly. The diffusion leader's first action should be to prepare a clear 

statement of agency policy for the Administrator's signature identifying technology 

diffusion as a major agency program supporting and complementing other agency 

programs. 

b . MODIFY THE AGENCY'S CULTURE: If EPA is to meet the challenges 

of protecting human heath and the environment in the 1990's, a culture change is needed in 

the agency that reflects and encourages EPA taking a leading role in diffusion. This change 

will affect training, support, and incentives for employees, as well as their understanding 

of the relationship they have with other environmental stakeholders. A first step involves 

changing the conceptualization of EPA's role from that of environmental regulator to that of 

catalyst for environmental improvement, using the full range of tools in the environmental 

management system, including regulation. The diffusion coordinator should be at the 

center of this culture change. 

This culture change should accompany and support improvements in the technology 

competence, training and retention of personnel. As described in Recommendation 4 of the 

1991 TIE Report, improved data and technical information resource support is required 

(perhaps from ORD) to improve the technical competence of rule writers, permit staffs, 

compliance staffs, and technical assistance groups. Similarly, policy, job standards, 

reward systems, and other tools will be needed to modify the agency's culture so that EPA 

staff perceive their role as being that of catalyst for environmental improvement, rather than 

merely that of regulator. 

As described in Recommendation 3, the TIE Committee believes that strong support 

for pollution prevention, innovation, and experimentation is a part of the necessary new 

culture. All of its employees need to think of, suggest, and be rewarded for working 

towards a new culture that involves these concepts. Subrecommendation 1.3 below 

describes the system of support that EPA staff will need, if the agency's appropriate role in 

diffusion is to be effected and the new culture installed. 

36 
1.2 Modify and expand EPA's role and funding support for

technology diffusion. 

Commentary 

EPA's diffusion role needs to be modified and expanded to correct a variety of 

underemphasis, gaps, and inefficiencies the TIE Committee found throughout EPA's 

diffusion activities. The agency's diffusion programs are largely uncoordinated and singlemedia in nature, and are not designed to gain sufficient leverage from those knowledgeable 

about the need for environmentally beneficial technologies, from other developers of 

credible diffusion information, and from providers of diffusion services. Statutes, 

regulations, permits and the resulting EPA organizational structure are all single media 

oriented with little or no coordinated activity. There are numerous examples of how 

pollutants are chased from one media to the next. One example is the sulfur dioxide limits 

on coal fired power plants. The sulfur in the coal, combined with the coal and as iron 

pyrite, produces sulfur dioxide on combustion. Flue gas scrubbers are installed to reduce 

the sulfur dioxide emissions to satisfy the Clean Air Act and associated regulations, which 

results in a sludge byproduct that must be landfilled. In addition, it should be noted that 

current regulations do not encourage pollution prevention techniques, which might promote 

the use of low sulfur coal. 

EPA could also reap significant gains by modifying its role in the technology diffusion 

system to recognize and take advantage of others' diffusion resources. EPA has made this 

adjustment in the area of remediation technologies. Here, EPA has identified the key 

stakeholders involved in making remediation decisions and strengthened its diffusion 

relationship with the consulting engineering community -- the group that most supports the 

responsible parties in choosing remedies. Another example, but one where EPA has not 

acted consistently, involves working with the Departments of Defense and Energy. The 

data produced in these programs are not systematically coordinated with EPA's testing 

protocols, data quality requirements, and reporting systems to assure that they can be 

directly input into EPA's information management systems. Here, and in other cases, 

EPA's unique position is not being fully exploited to take advantage of the benefits 

diffusion can offer. 

37 
Expanding EPA's diffusion effort with additional resources is also needed to allow the 

agency to achieve its environmental goals through the application of new and innovative 

technologies to environmental problems. As discussed earlier, an historic underutilization 

of diffusion programs in the environmental management system cannot be reversed merely 

through better coordination, advocacy, and policy encouragement. 

a. EPA AS THE ULTIMATE FACILITATOR OF ENVIRONMENTAL 

TECHNOLOGY DIFFUSION: The agency's unique role at the apex of the 

environmental management system pyramid requires it to be the ultimate facilitator of 

technology diffusion, but does not require it to conduct all diffusion activities. EPA's 

wide-ranging roles in the diffusion of information about environmentally beneficial 

technologies (e.g., regulator, promoter, educator, researcher, buyer, approver, and 

certifier) give the agency the ability to encourage communications (a key element of any 

technology diffusion activity) across the broad spectrum of players that includes almost all 

environmental stakeholders. The agency's influence can be used both internally and 

externally as a powerful tool to support and promote technology diffusion, which in turn 

can strongly contribute to EPA's success in its environmental improvement mission. 

b . EPA'S FIRST STEPS TO EXPAND AND PROMOTE 

TECHNOLOGY DIFFUSION: As a start, the Administrator should require 

that all agency program plans have a technology diffusion component that clearly identifies 

the users of the information contained in and generated by the program, the mechanisms for 

communication, and the program's technology diffusion component(s). The role of 

diffusion relative to other elements of the environmental management system should be 

clearly stated in the program plan. The technology diffusion component should be clearly 

labeled and have sufficient, earmarked resources. Both the labeling and the funding should 

be explicitly connected with overall agency objectives in diffusion. This would make 

diffusion efforts a standard part of EPA's activities, as well as make it easier to monitor, 

assess, and reward successful diffusion. 

In working with many potential users of diffusion services, the agency should find 

ways to facilitate third-party information exchanges. These exchanges are particularly 

useful in communicating with untrusting and/or uninterested regulated parties. Their 

receptiveness to technology information will be greater if the diffusion process occurs 

through organizations with whom the regulated organizations are comfortable. 

38 
c .­ REDEPLOY EPA'S CURRENT DIFFUSION ASSETS TO 

INCREASE SUPPORT FOR TECHNOLOGY DIFFUSION: The TIE 

Committee recognizes the agency's wide variety of diffusion programs, which should be 

redeployed since they are largely uncoordinated and single-media. Moreover, sufficient 

leverage is not gained from other developers and providers of diffusion information. 

The Committee believes that EPA can create additional support for the transfer of 

environmentally beneficial technology information by increasing the efficiency of 

technology diffusion activities inside and outside the agency. Agency personnel, facilities, 

policies, and practices can all be managed more efficiently to this end. Increased support 

can therefore come at little or no cost to the agency, because it can come from the better use 

of current agency resources. 

The TIE Committee recommends that EPA begin to examine the possibility of 

redeployment by conducting a total quality management exercise for diffusion programs. 

This exercise should include benchmarking with other federal, state, and local government 

agencies to find out how they shape their diffusion programs. 

d . PROVIDE ADDITIONAL RESOURCES TO SUPPORT INCREASED 

TECHNOLOGY DIFFUSION: The TIE Committee also concluded that the 

agency should provide additional resources for its environmentally beneficial technology 

diffusion efforts. This increase is needed for two reasons: (1) the current resource level 

for diffusion activities reflects a significant and long-term lack of emphasis on government 

diffusion programs as contributors to environmental progress, and (2) the incorporation of 

multi-media, pollution prevention, international, and other understated elements of EPA's 

diffusion programs will require new resources. 

As discussed previously, the TIE Committee believes that technology diffusion is an 

appropriate, efficient, and cost effective method of fostering the application of advanced 

technologies and techniques for environmental improvement. Consideration should be 

given to shifting, agency resources to technology diffusion activities or to seeking additional 

resources, if EPA determines that agency resource levels will be inadequate, even 

considering the beneficial effects of redeployment decisions. Such consideration should be 

made in the context that diffusion is one of the major, interrelated elements of the 

environmental management system. 

39 
1.3 Create an internal system of support for agency employees

that will promote and assist technology diffusion. 

Commentary 

The diffusion of environmentally beneficial technologies is people dependent. The 

diffusion effort will ultimately succeed or fail solely based upon the efforts of agency 

participants. Two key tools are essential to mobilizing people for the diffusion effort: 

employee support systems and encouragement. Support systems are needed to provide the 

technical expertise, training, information systems, job hierarchy, and exposure to other 

organizations that are currently not sufficiently available to mobilize the diffusion effort. 

EPA's people also need additional encouragement (in the form of job standards and 

rewards) so that they will believe contribution to the agency's diffusion effort is in EPA's 

and their interest. The TIE Committee developed a clear perception that EPA staff do not 

feel that a strong diffusion role is required for success in the agency's mission. 

The TIE Committee has found an additional EPA employee requirement for successful 

diffusion: the technical competence of regulatory, permitting, compliance, and other 

agency personnel must be improved. The Committee heard from multiple sources that 

there is a widespread lack of technical competence in EPA. This problem was attributed to 

two factors: a lack of technical background and the short tenure (and experience) of these 

individuals, particularly in permitting and compliance programs. If diffusion is to take 

place through these channels and be encouraged by them, it is important that these 

problems be resolved. The TIE Committee recommends that EPA institute or strengthen 

several employee support activities to advance EPA's diffusion programs and culture. 

These should be made to apply to rulewriters, permit writers, compliance personnel, 

diffusion staff, researchers, and others. 

The rest of subrecommendation 1.3 discusses how to institute the system of support 

for agency personnel that will enable them to carry out an appropriate diffusion program, 

working with other environmental stakeholders. 

40
a.

ESTABLISH A HIERARCHY OR JOB LADDER AND 

INCORPORATE CRITERIA IN PERFORMANCE EVALUATIONS 

ALONG THAT PROMOTIONAL LADDER TO ADDRESS THE 

DEVELOPMENT OF EXPERTISE (SINGLE MEDIA, CROSSMEDIA, OR TECHNOLOGY-SPECIFIC, INCLUDING POLLUTION 

PREVENTION): The TIE Committee's report and recommendations, titled 

"Permitting and Compliance Policy: Barriers to U.S. Environmental Technology 

Innovation," describes on pages 87 - 88 how EPA might establish a hierarchy or job ladder 

that would create incentives and support for permit writers involved in innovation. This 

elements of this hierarchy, expanded to cover all agency personnel, has great applicability 

to the support of a diffusion program, as well. The Committee reiterates its support for this 

approach. 

b.PROVIDE TRAINING AND MODEL TEMPLATES, BASED ON 

THE PRIOR TESTING AND USE OF INNOVATIVE AND 

POLLUTION PREVENTION TECHNOLOGIES AND 

TECHNIQUES, TO ALL PERMIT WRITERS: A concise, yet 

comprehensive, training program should explain the permit writers' role in fostering the 

successful use of these technologies and techniques for environmental purposes and 

identify information sources and networks with technical information. The training 

program should also educate regulators on how the motivation to innovate and to prevent 

pollution work in industry. It should describe the roles of government and other 

technology diffusion groups, with the goal of helping permit writers network to extend the 

use of environmentally beneficial technical information. 

c . STRENGTHEN ORD'S ROLE AS IDENTIFIER AND CONVEYER 

OF TECHNICAL INFORMATION TO PERMIT WRITERS: ORD's 

roles in research and diffusion are discussed in detail in Recommendation 5. In general, 

ORD should undertake a more systematic approach in its diffusion role to help permit 

writers obtain performance data about the applicability of innovative and pollution 

prevention technologies and techniques. ORD should also assist permit writers frame 

permit conditions for unfamiliar technologies and techniques. 

41
d. ESTABLISH PERFORMANCE EVALUATION STANDARDS AND 

REWARD SYSTEMS THAT PROMOTE GREATER SUPPORT AND 

CONSIDERATION FROM PERMIT WRITERS FOR INNOVATIVE 

POLLUTION PREVENTION AND POLLUTION CONTROL 

TECHNOLOGIES: EPA should highlight the diffusion role by including in 

performance standards and credits ("bean counting") the need and success of permit 

writers' work to achieve the goals set forth in the diffusion policy statement. The TIE 

Committee recognizes that extra time and risk are involved in processing permit 

applications for innovative alternatives. Extra risk is associated with supporting 

approaches that involve uncertainties, such as those associated with changes in standard 

technologies and in performance projections for innovative solutions. Financial incentives 

should be a part of this improvement, as well as recognition and merit awards. For 

example, DOE labs have recognition programs including awards banquets, and a DOE 

employee received "Lifetime Technology Transfer Achievement Award" at the NASA 2001 

Exposition this past December. EPA might consider programs such as this one. 

e. IMPROVE DATA AND TECHNICAL INFORMATION SOURCES 

TO AID PERMIT WRITERS IN THEIR JOB OF REVIEWING 

PERMIT APPLICATIONS INVOLVING INNOVATIVE AND 

POLLUTION PREVENTING TECHNOLOGIES AND 

TECHNIQUES, PERHAPS THROUGH AN EXPANSION OF THE 

"ATTIC" DATA BASE, WHICH NOW CONTAINS INFORMATION 

ABOUT INNOVATIVE REMEDIATION TECHNOLOGIES: As 

discussed elsewhere in this report, EPA should collect credible information from the widest 

possible range of sources and assemble the data and information in on-line databases for 

PC/Mac users. Information should be collected and assembled in information retrieval 

systems that are easily accessible to all permit writers. Information should include: 

•­ Media affected by the technology. 

•­ Emission/effluent/hazardous waste reductions achieved by the

technology.

•­ Process descriptions. 

•­ Location and results of tests, demonstrations, and early commercial

uses.

•­ Level of cleanup (remedial technologies) achieved. 

42 
•­ Contact owner or licensee, and ORD technical experts. 

•­ Existence of patents covering the technology and the availability of

licenses.

•­ Key words; similar technologies; terms of art. 

•­ Known limitations. 

•­ Potential site incompatibilities. 

f .­ FACILITATE THE MOVEMENT OF PEOPLE WITH ROTATIONAL 

OPPORTUNITIES BETWEEN EPA, OTHER FEDERAL 

AGENCIES, STATE AND LOCAL AGENCIES, AND THE 

PRIVATE SECTOR: Environmental managers should understand the factors 

that influence the decisions of all stakeholders involved in solving an environmental 

problem. Rotational assignments are the best way for professionals involved in the 

diffusion effort to gain insight into the value structures and thought processes of others. 

They also increase the technical knowledge of EPA's scientific and engineering staffs. 

EPA regulatory, permitting, compliance, research, and diffusion personnel need 

exposure to a variety of environments so they can better understand the perspectives, 

needs, and requirements of other organizations. Rotations need to include assignments: 

Between and within the regulatory, research, and diffusion programs 

within the agency. 

•­ Between the agency and other federal, state, and local government

agencies.

•­ Between public and private organizations. 

The creation of several endowed chairs to attract senior scientists who are leaders in their 

fields is a step in the right direction. 

g . EXPAND THE RESIDENT RESEARCH ASSOCIATESHIP 

PROGRAM: One program already facilitates the movement of scientific and 

technical people to EPA. Incentives should be added that increase the attractiveness EPA's 

Resident Research Associateship Program to senior-level scientists from private industry, 

academia, and other federal agencies. These reforms include: streamlining the paperwork 

process, increasing compensation, and assisting in the visiting scientist's relocation, as 

needed. 

43 
1.4 Improve the current partnership between the agency and

users and providers of diffusion services. 

Commentary 

The TIE Committee found that the requirement for technology diffusion exceeds 

EPA's limited resources. Moreover, a solely EPA-based diffusion effort would not be 

efficient, even if the necessary resources were available; in some situations, such as 

diffusing proprietary information, an EPA-based diffusion effort would be inappropriate. 

The TIE Committee has concluded, therefore, that EPA must emphasize working with 

others to leverage its diffusion resources and to improve the efficiency of the entire 

diffusion system. Four categories of diffusion partners were identified: 

•­ Those who understand user needs (e.g., state and local regulators,

engineering firms, consultants, users, trade associations).

•­ Developers of information about environmentally beneficial

technologies (e.g., consortia, universities, research programs of other

federal agencies, equipment and service providers).

•­ Providers of diffusion services (e.g., engineering firms, trade

associations, information clearinghouses, state and local regulators,

other federal agencies).

•­ Users or consumers of diffusion services (e.g., regulated

organizations, state and local regulators, engineering firms and

consultants, equipment and service providers).

Leveraging agency resources through the efforts of outsiders has additional benefits. 

Outsiders have different perspectives from which EPA could benefit. They have different 

relationships that also work towards environmental improvement (e.g., with consulting 

engineers, who advise regulated organizations on the best solutions to their environmental 

problems). Outsiders have information that EPA does not possess, but which would 

benefit the environment protection effort if shared more widely (e.g., through trade 

associations). Their motivations (e.g., the profit motive) differ from EPA's and are 

complementary to EPA's technology diffusion goals. Some outsiders operate in a less 

constrained environment than government regulatory agencies (which cannot endorse a 

technology without regulatory and legal implications) and can act more quickly. 

44 
Finally, there is the issue of credibility; people need information that is credible. 

Government, particularly EPA, is widely seen as a credible source of technology 

performance data. The problem is that while government is usually seen as credible, it may 

also be distrusted due to its regulatory role. If EPA's diffusion programs are to be 

successful, the actual diffusion of information should sometimes be carried out by EPA's 

diffusion partners. Thus, mutually supportive diffusion efforts can be used to overcome 

the distrust of EPA's regulatory position. 

a . CREATE NEW AND STRENGTHEN EXISTING PARTNERSHIP 

RELATIONSHIPS: Efforts should be made to use and optimize new and 

existing mechanisms for the diffusion of information. ORD and the Office of Air and 

Radiation (OAR) provide technical support and guidance on air pollution control 

technology through the jointly supported Control Technology Center (CTC). It describes 

air emission factors and air pollution control technology for all air pollutants, including air 

toxics emitted by stationary sources. The Technology Innovation Office in the Office of 

Solid Waste and Emergency Response (OSWER) has a successful program that has greatly 

expanded EPA's relationship with key diffusion partners in the remediation technology 

field, e.g., the consulting engineering community. Consulting engineers advise 

responsible parties about their technology choices in site remediations. 

The Technology Innovation Office (TIO) makes information available in various 

forms, including software, reports, newsletters, and seminars. These sources inform the 

public and users of remediation technologies about available innovative treatment 

technology products and services. TIO also provides a developers' guide to support 

services, which describes regulatory requirements, assistance programs (financial and 

technical), technology incubators, test and evaluation facilities, and technical expertise in 

basic and applied research. In addition, TIO has user friendly software that describes the 

availability and performance of a variety of innovative technologies. Another major 110 

publication is the Citizen's Guide on Innovative Technologies. 

Some of TIO's other efforts to reduce impediments to the use of innovative 

technologies include: 

45
Institutional Methods: 

•­ Award of a cooperative research agreement to the American Academy 

of Environmental Engineers to develop monographs containing 

operating parameters for eight innovative and established technologies. 

•­ Organization of a users group of Fortune 500 companies to collaborate 

with the Air Force, Army, and EPA to evaluate innovative technologies 

at federal facilities that are applicable to corporate cleanup problems 

(see subrecommendations 5.1 and 5.2 "h"). 

•­ Development of a quick reference fact sheet on the regional experience 

with the procurement of innovative technologies at Superfund sites. 

Regulatory Methods (see subrecommendation 1.5); 

•­ Delegation of the authority to issue site specific treatability variances for 

contaminated soils to the regions. 

•­ Authorization to additional states for the treatability exclusion rule, 

RD&D permit authority, and Subpart X permit authority to allow more 

flexibility for testing and demonstrating innovative treatment 

technology. 

Training (see subrecommendation 1.3 "b"): 

•­ Development of a series of satellite video conferences (the first on 

bioremediation). 

•­ Development of teaching modules (one semester) on innovative 

technologies for use by graduate environmental engineering 

departments. 

•­ Provision of two training sessions for states that are taking the lead in 

innovative technology development. 

Development Activities: 

•­ Development of ten "citizen fact sheets" to educate the public about 

innovative technologies. 

•­ Development of a vendor information system for innovative treatment 

technologies (VISITT) that makes information available on hotline and 

user friendly software. 

•­ Miscellaneous newsletters, publications and workshops. 

46
EPA will need to work with the diffusion partners to receive information on the needs 

of regulated organizations for environmentally beneficial technologies. This work will help 

guide the cooperative development of diffusion systems and programs. The input of state 

and local governments, trade and professional associations, consortia, and other 

organizations should be brought into the agency's diffusion planning processes as early as 

possible. 

State and local governments, for example, have networks in place for the diffusion of 

information to local regulated organizations. These networks have been developed through 

direct regulatory contact with local polluters. State and local agencies can be particularly 

knowledgeable about local air and water pollution problems. They can help regulated 

organizations by aiding in the diffusion of information about available technology 

performance data and information management systems. These agencies may be strongly 

motivated to help regulated organizations comply or become more efficient producers while 

complying, because of their interest in the local economy. EPA could strengthen the 

diffusion capability of local and state agencies by enhancing its efforts to provide 

information to STAPPA/ALAPCO's (State and Territorial Air Pollution Program 

Administrators/ Association of Local Air Pollution Control Officials) and others' networks. 

State economic development administrations are also very important potential sources of 

information that are independent of environmental regulatory organizations. 

Similarly, trade and professional associations enable the agency to make quick and 

efficient contact with those whom it wishes to impact through workshops, seminars, 

conferences, publications, and personnel exchange programs. Consortia and institutes, 

e.g., the National Environmental Technology Application Corporation (NETAC), the New 

Jersey Institute of Technology, and the National Center for Manufacturing Sciences, also 

can provide strong connections between EPA and technology users and producers. 

b . LEARN FROM OTHER AGENCIES' DIFFUSION PROGRAMS: 

EPA should use other agencies' technology diffusion efforts as potential models for its 

own. Several agencies, such as the Departments of Defense (DOD), Energy (DOE), 

Agriculture (DOA), the Food and Drug Administration (FDA), and NASA, have 

cooperative research and development programs with the private sector and non-profit 

organizations. They have also established long-term, successful diffusion relationships 

with the private sector. EPA could valuably "benchmark" with other agencies' technology 

47
diffusion programs to gain from their experiences. This type of learning can also come 

through other types of formal and informal relationships with other agencies. 

c . BROADEN THE SOURCES OF INFORMATION CONTAINED IN 

EPA DIFFUSION PROGRAMS: The TIE Committee has found that EPA is 

not taking full advantage of external sources of credible performance data about 

environmentally beneficial technologies in its diffusion programs. There is a considerable 

amount of performance data that can be evaluated, and if it is found to be credible, gathered 

and input into EPA's information management systems. Increased EPA efforts, 

particularly by ORD, to standardize the protocols and procedures for developing, 

collecting, and analyzing data to make it more acceptable to EPA and more useful would be 

beneficial (see Recommendation 5). The TIE Committee commends EPA for establishing a 

Federal Facilities Testing and Demonstration Program with the Departments of Energy and 

Defense (in response to an earlier TIE Committee recommendation). This program should 

expand the availability of credible performance data about environmentally beneficial 

technologies. 

48
1.5 Change the regulatory system to allow the diffusion 

system to operate more effectively. 

Commentary 

The TIE Committee found that the regulation-based environmental technology demand 

system, with its current uncertainty and unpredictability, poses major barriers to technology 

innovation and diffusion. Regulators, technology developers and users, investors, and the 

public will perform their roles better when the regulatory system gives clear, predictable 

signals regarding objectives, processes, timing, risks, rewards, and uncertainties, and 

when it creates incentives to develop and apply innovative solutions. As discussed in the 

TIE Committee's report and recommendations on permitting and compliance policy, 

regulations and their strong, predictable enforcement "trigger and define the environmental 

marketplace. The federal signals dominate in the minds of regulated communities and 

technology developers. . . ." (Permitting and Compliance Policy: Barriers To U.S. 

Environmental Technology Innovation, page 27). 

Uncertainty and unpredictability can be reduced, and greater flexibility introduced, in 

regulations and in permitting and compliance systems without compromising enforceability 

and assured compliance. The incorporation of these concepts in the environmental 

management system will encourage technology risk taking and experimentation, providing 

a constant incentive to innovate and to apply innovative technologies and techniques in the 

choice of environmental solutions. Both investment in the development of innovative and 

pollution preventing solutions and the widespread diffusion of environmentally beneficial 

technologies will thereby be encouraged. 

The TIE Committee believes that the following very important steps should be taken in 

rulemaking, permitting policy, compliance systems, and support for regulatory personnel 

and non-regulatory partners. These steps suggest how EPA can encourage risk taking and 

experimentation, and make optimal use of diffusion among the tools available in the 

environmental management system. 

49
a. INTEGRATE TECHNOLOGY DIFFUSION CONCERNS INTO 

RULEMAKING: Regulations can encourage the diffusion of innovative and 

pollution preventing technologies and techniques if they are cast in terms that specify 

performance, rather than technology. These performance standards need to include floors 

that prescribe regulatory minimums for all polluters, and offer incentives to those who 

successfully develop and/or apply approaches that exceed requirements (see 

Recommendation 3). In the long run, multi-media approaches to rulemaking should be 

developed. 

Market-based approaches, such as the emission trading policies, being pioneered by 

EPA, South Coast Air Quality Management District, and others, may prove to be 

successful in encouraging regulated organizations to exceed minimum standards and in 

increasing the market for innovative and pollution preventing technologies and techniques. 

Full cost pricing of environmental services is another market based approach that is aimed 

at the consumer. In general, by creating win-win situations, market-based approaches are 

thought to provide encouragement for efficient environmental solutions, innovation, and 

cooptimization of environmental and productivity results. 

Regulations can encourage the diffusion of advanced environmental practices when 

they are both predictable and flexible. The regulatory process can become more predictable 

by giving an earlier and clearer goal-setting signal, by making known earlier in the 

rulewriting process when regulations will become effective, and by having a known 

schedule for regulatory revisions. The technique of negotiating regulations has increased 

predictability in some cases. EPA's recent regulatory innovation -- "regulatory clusters," 

under which the consideration of all pending regulatory actions related to a single industrial 

category are linked -- will increase predictability by focusing attention on the most 

important environmental problems. 

b . DESIGN DIFFUSION CONCERNS INTO PERMITTING 

PROGRAMS: The TIE Committee has concluded that current permitting 

policies are strongly at odds with the initiative and risk taking that are necessary for 

innovation and pollution prevention. This conclusion pertains both to the permitting of 

tests and evaluations of these technologies, and to the permitting of proposed use of these 

technologies for compliance purposes. The TIE Committee report, Permitting and 

Compliance Policy: Barriers to U.S. Environmental Technology Innovation, enumerates 

and discusses in detail the suggested specific improvements. The TIE Committee reiterates 

50
these recommendations, noting that EPA has made some progress in their implementation. 

The inflexibility of present federal, state, and local permitting practices also restricts the 

diffusion of innovative and pollution preventing solutions to environmental problems. 

The flexibility to evaluate the capability of promising technologies under safe testing 

conditions is not adequately provided under current permit and associated administrative 

processes related to testing and demonstration. The Committee heard several examples 

where the time and the cost of testing became exaggerated by permit procedures, while the 

range of conditions tested was limited. One company told the Committee that it maintains a 

money-losing international operation primarily because of the lack of a reasonable, 

predictable testing process in the U.S. The inability to test sufficiently to define the useful 

range of performance limits knowledge about innovative approaches to environmental 

improvement, and in so doing, restricts the data available for diffusion programs. 

The Committee recommends that permitting programs be modified to create specialized 

permit processes for the testing and demonstration of innovative environmentally beneficial 

technologies. Permitting processes for tests and demonstrations of innovative technologies 

should be instituted, expanded, and streamlined, and designed to encourage technology 

innovation under each of the major "media" statutes. At a minimum, existing statutory 

provisions should be fully employed to increase opportunities for and flexibility in 

permitted tests. The Committee recommends coordination of these specialized permitting 

programs across the environmental media. In addition, a new permitting process for tests 

and demonstrations might be created under a single authority. These processes should be 

designed to yield a predictable and timely process for regulatory oversight of testing, one 

that protects human health and the environment and simultaneously affords flexibility 

during testing. 

The risk associated with early commercial uses for compliance purposes of an 

innovative technology is greater than risks associated with using known technologies in 

similar applications. Uncertainty about the capability of a newly-available innovative 

environmentally beneficial technology is greatest when it is first proposed for use in 

gaining compliance. At this time, permit writers and the public are unfamiliar with the 

technology and have a higher level of concern about it than about a well-proven 

technology. In some cases this concern may be well founded. In other cases it may not 

be. The record shows that the lack of public confidence and trust stands as a major 

impediment to the development and use of innovative technologies. This leads to 

51
difficulty, delays, and extra expense associated with reviews of applications for operating 

permits. These problems are made worse by the need to satisfy, simultaneously and 

without coordination mechanisms, the requirements of various levels of government in 

potentially more than one of the environmental media. 

These uncertainties combine to create a perception of excess risk that deters investors 

and technology developers from innovating, which in turn inhibits the introduction of 

innovative technologies into commercial use. The extra cost, time, and uncertainty 

associated with application drafting, negotiation of permit terms, and pre-permit data 

gathering for a proposed use of an innovative technology are so excessive as to discourage 

innovation and the use of innovative technologies Consulting engineers and prospective 

users of the innovative technologies thus tend not to recommend or use these technologies. 

The TIE Committee recommended that permitting requirements must simultaneously 

protect human health and the environment, and be sufficiently flexible to encourage 

regulated facilities to cooptimize for environmental and productivity objectives. Several 

"characteristics of permitting systems that encourage technology innovation for 

environmental purposes" were identified by the TIE Committee: 

•­ Flexibility: Permitting processes should authorize the permit writer

to incorporate a greater degree of flexibility into each permit for testing

or use of an innovative technology. The developer of innovative

technology needs sufficient flexibility to define the performance 

envelope of a new technology. Facility operators should have the 

flexibility to focus on the result, rather than on the means used to 

achieve it. 

•Compliance: People need to be confident that compliance will be

required during testing, demonstration, and early commercial use of

innovative technologies. Compliance efforts must therefore be

consistent, predictable, and systematic. This is vital to allowing

markets to develop for technologies, as well as for assuring that testers

and users operate responsibly, knowing that enforcement programs

will assure compliance. The need to protect human health and the

environment during testing and early commercial use is considered

paramount by the TIE Committee.

•­ Enforceability: Permit conditions must be enforceable. Introducing

flexibility into permit conditions in the interest of technology innovation

cannot be allowed to diminish the enforceability of their terms.

•­ Predictability: The schedule for processing permit applications for 

testing and early commercial uses of innovative environmental

technologies needs to be consistent and predictable. The lack of

predictability reinforces investors' perception of excess risk.

52 
•­ Clarity: Clarity in permitting processes and in permit conditions are

important to the testing and early commercial use of innovative

technologies. Clarity is important to technology developers,

technology users, regulators, and the public.

•Confidentiality: To encourage early discussions with regulators and

other interested parties, assurance must be provided that secret

information about innovative technologies will be protected.

Confidentiality is particularly important when approaches that prevent

pollution are involved, because they may involve the key competitive

advantages that differentiate and sustain businesses.

The TIE Committee also recommends revitalized waiver authorities, greater flexibility 

to innovate without triggering facility repermitting, a two-phase permitting process, multimedia coordination and innovation in permitting programs, and top priority status for the 

review of permit applications involving innovative and pollution prevention technologies 

and techniques. 

The TIE Committee recognizes that there is a pressing need to map the permitting 

process because how it works in practice is unclear both to applicants and to EPA 

employees who are part of the process. EPA should first develop detailed flow charts 

describing the permitting process and then seek input from applicants and EPA staff 

involved on streamlining measures. Appropriate measures should then be implemented. 

c.

DESIGN DIFFUSION CONCERNS INTO COMPLIANCE 

PROGRAMS: The TIE Committee has called for the coordination of permitting 

and compliance policies to encourage the diffusion of innovative environmentally beneficial 

technologies. 

c (1). THE NEED FOR FIRM AND PREDICTABLE 

ENFORCEMENT: The Committee stresses that it is important that 

industrial, commercial, and other facilities subject to environmental requirements expect 

routine and rigorous enforcement of permit requirements. Otherwise, most will not 

purchase and use pollution prevention or innovative technologies. Without the expectation 

of the need to comply with environmental permit requirements, the market stability and 

consistency necessary to promote the use of innovative environmental technologies and 

pollution prevention solutions will be lacking. Consistent and predictable environmental 

compliance systems provide an incentive for the development and diffusion of both 

pollution control and pollution prevention technology because they assure that a market for 

53
such technologies will exist (and be of predictable size and character). As is the case under 

EPA's current policies, penalties must be sufficient to remove any economic benefits that a 

facility might gain from non-compliance. 

Such an approach to enforcement and compliance is fully consistent with the flexibility 

inherent in providing limited time delays in permit conditions, in the form of waivers for 

genuine, good-faith efforts, to develop and implement innovative technology. But it is 

important that the criteria for such waivers be clear and consistent, so that they cannot in 

any way be used as vehicles for avoiding compliance by facilities which are not genuinely 

attempting to implement an innovative approach and/or provide an overall, multi-media 

environmental benefit. 

c(2). STATE EXPERIMENTATION WITH PREDICTABLE 

ENFORCEMENT: EPA can promote the necessary market consistency 

both through firm and predictable enforcement actions, and through support for and 

coordination with state and local enforcement efforts. One role which EPA is in an 

especially strong position to play, and which the Committee believes would be of great 

value, is to track innovative programs in state and local enforcement agencies. New 

approaches are being tried to provide consistency and predictability, to test multi-media 

inspection and permitting of entire facilities, and to stimulate information exchange between 

programs in different parts of the country. A number of new experiments in enforcement 

are currently underway in various states and localities, e.g., Minnesota, Massachusetts, 

and the South Coast Air Quality Management District (in California). EPA should promote 

the sharing of information on the results of these efforts. 

The Committee notes that, with most compliance activities taking place at the state and 

local levels, it is imperative that EPA, State and local agencies coordinate their enforcement 

strategies to encourage experimentation, innovation, and wide use of improved solutions. 

c(3). FLEXIBILITY IN MEETING ENVIRONMENTAL 

COMPLIANCE REQUIREMENTS IS ESSENTIAL: The agency 

must provide the freedom necessary to make the initial commercial applications of 

promising innovative pollution control or pollution prevention technologies. The TIE 

Committee believes strongly, however, that flexibility only works in a context of strong 

enforcement and meaningful penalties, so that there is no reward for making perfunctory 

efforts to comply. 

54 
Within a strong enforcement context, the Committee believes that flexibility is essential 

when innovative and pollution prevention technologies and techniques are involved. 

Approaches which may provide long-term environmental benefits often cannot meet shortterm compliance deadlines. In addition, multi-media benefits which might result from 

innovative environmentally beneficial technology are not addressed by EPA's and states' 

media-specific programs. Further, the potential for a risk management strategy that is 

multi-media in scope can only be possible if greater flexibility is instituted in operating 

guidance and, potentially, statutory language. Flexibility in compliance situations is 

necessary when innovative and pollution prevention technologies and techniques are 

involved because they are inherently less certain than conventional technologies. A multimedia approach to compliance would include the development of multi-media inspection 

teams. 

The TIE Committee has recommended that in order to deal with these factors, it is 

important to have effective programs for environmental waivers and variances (as 

discussed in subrecommendation 1.5 "b"). These programs should contain provisions for 

soft landings and for the creative use of compliance penalties, to the extent consistent with 

legal and regulatory requirements protecting human health and the environment, and for 

good-faith efforts which fall minimally short of compliance requirements. Flexibility has 

theoretically been introduced into EPA's enforcement programs in the "Interim Policy on 

Pollution Prevention and Recycling in Settlement Agreements" and the "Policy on 

Supplemental Environmental Projects." 

These new policies allow the partial abatement of penalties and fines in exchange for 

the development of pollution prevention plans, along with the implementation of these 

plans and/or of innovative solutions at violators' facilities. In particular, where the agency 

and/or a state deems that an attempt to implement an innovative technology has met clearly 

delineated criteria for a good-faith effort, the punitive portion of penalties might be reduced 

for some predetermined period. During this period, the facility would be required to come 

into compliance by improving the performance of innovative technologies, or through the 

use of more traditional technologies. To the extent that these policies are highlighted in 

operating policies, training, and data base support, they are potentially important tools for 

encouraging flexibility through compliance policy. 

55
The Committee commends the EPA Office of Enforcement for its National 

Enforcement Training Institute (which is diffusing information on pollution prevention), 

multi-media inspection encouragement to states, training for compliance officers, and 

penalty assessment reduction programs to encourage pollution prevention, which maintain 

a floor to insure that economic benefit from non-compliance is fully recovered. 

It is important that support of various types be provided to compliance personnel in 

federal, state, and local agencies. Subrecommendation 1.3 discusses a system of support 

that is recommended by the TIE Committee. 

d. IMPROVE THESYSTEM OF SUPPORT FOR REGULATORY 

PERSONNEL TO ENCOURAGE DIFFUSION: The TIE Committee 

recognizes that EPA personnel are the most important component of the agency's 

regulatory programs. In order to encourage diffusion, the agency must provide additional 

support for staff, which should include: job hierarchy, training, performance evaluation 

standards and reward systems, data and technical information sources, expansion of the 

Resident Research Associate Program, and rotational opportunities (within and outside the 

agency). These recommended actions are covered in detail under subrecommendation 1.3. 

56
Recommendation 2: 

Build a stronger partnership with technology diffusion providers 

and users. 

2. 1Work with the full range of partners to actively promote 

the widespread diffusion of environmentally beneficial 

technologies. 

2.2

Collect and generate credible information about

environmentally beneficial technologies. 

2.3Strengthen and use the full range of technology diffusion 

mechanisms, and help make them widely available to 

other diffusers. 

2.4Define, collect, and analyze environmental business data 

to understand diffusion partners and information users. 

2.5Collect international environmental business and 

technical data to help U.S. firms compete domestically 

and abroad. 

2.6.

Support university curriculum development to increase 

literacy in environmentally beneficial technology. 

Commentary 

Recommendation 1.4 calls on EPA to strengthen its partner relationship with diffusion 

users and providers. The "Commentary" section of Recommendation 1.4 describes the 

critical need to strengthen relationships among the diffusion partners. Recommendation 2 

describes how EPA can act to address this need. 

EPA's historic role as regulator in a command and control based regulatory system has 

led to an adversarial, arms-length relationship between the agency, regulated organizations, 

and providers of environmental products and services. The historic nature of this 

relationship, and the resulting barriers between the players, makes it difficult for federal, 

state, and local regulators and regulated organizations to work together, even when it is in 

their mutual interest. These barriers must be reduced and the possibility enlarged for 

cooperation if the agency and regulated organizations are to work most effectively and 

efficiently for environmental improvement. 

57
Diffusion programs play a key role in building this cooperation in that they expand the 

availability of information helpful to regulated organizations and regulators. Expanded 

information about environmentally beneficial technologies is essential to an expanded range 

of choices of solutions for regulated organizations and, therefore, to a more efficient market 

for environmental solutions. Regulated organizations should be apprised of environmental 

concerns, and regulatory requirements and procedures. Regulatory personnel should 

become aware of industrial concerns. Above all, the two groups need to communicate 

effectively. This will ultimately advance regulators' primary objective of protecting human 

health and the environment. 

Regulators must build a partnership with those who can help them understand the 

environmental information needs of regulated organizations, those who develop 

environmentally beneficial technologies, those who develop credible information, and 

provider industries. EPA should become an active partner in the diffusion of 

environmentally beneficial technology to ensure the maximum use of improved these 

technologies within the shortest time frame. A stronger partnership relationship will help 

reduce the currently existing barriers to the diffusion of environmentally beneficial 

technologies and increase the availability of such information to those who need it. 

Clearly, EPA will not be the direct source of all such information, but it should work with 

the diffusion partners to their mutual advantage. EPA's environmental goals can be 

furthered by the increased availability of information about a wide range of choices of 

environmental solutions. The diffusion system is key to increasing choice. 

One commendable example of agency-industry partnership building is the Green 

Lights program. In this program, EPA facilitates cooperation between users and providers 

of efficient lighting technologies. The diffusion efforts in EPA's Green Lights program 

also directly and indirectly help make potential users aware of cost-effective opportunities 

for lighting improvements. EPA's support for the project gives lighting technology 

providers extra legitimacy in dealing with potential users. There are now over 200 

participants in each of the Green Lights user program and supplier programs. 

There are not enough training programs available at the university level that teach 

tomorrow's managers and technologists how to effectively employ environmentally 

beneficial technologies. These programs would reach a wide range of individuals and 

affect the way environmentally beneficial technologies are used in the future. EPA should 

support these programs, like the one at the University of Michigan. 

58 
2.1

Work with the full range of partners to actively promote 

the widespread diffusion of environmentally beneficial 

technologies. 

Commentary 

The TIE Committee found that the need for technology diffusion is simply too large 

for EPA's limited resources, even if they were redeployed to maximize results. EPA 

cannot understand all diffusion user needs, nor develop all credible diffusion information, 

nor provide comprehensive diffusion services to all consumers. EPA cannot rely on its 

own resources to generate the data to be diffused because its resource base is so small. 

Moreover, an EPA-dominated diffusion effort would be inefficient even if the resources 

could be made available because other technology diffusers have unique capabilities that 

enable them to perform some diffusion roles more effectively than EPA. 

In this subrecommendation, the TIE Committee suggests with whom EPA should 

forge a diffusion partnership, and how cooperative efforts can make the system work most 

efficiently and effectively. Notwithstanding the need for excellence in the agency's own 

diffusion activities, the Committee believes that it is essential for EPA to emphasize 

working with others to gain leverage (see subrecommendation 1.4 for list). 

Thus, EPA should build and utilize a strong partnership for the widespread 

dissemination of environmentally beneficial technology. The TIE Committee believes that 

if it does, the technology options available to regulated organizations will increase, 

environmental efficiency gains will be obtained, and the marketplace for environmental 

products and services will work better. 

a .­ LEVERAGE EPA'S LIMITED DIFFUSION RESOURCES BY 

ACTIVELY SEEKING OUT DIFFUSION PARTNERS AND 

PROMOTING DIFFUSION ACTIVITIES: EPA must seek out as wide a 

range of diffusion partners as possible. It must work with the diffusion partners to define 

the various routes by which valuable information gets to those who make environmental 

decisions and those who influence those decisions. EPA and its diffusion partners must 

also consider the various motivations of each information receiver to tailor the information 

59
to their individual needs. The pathways for the transfer of information must be considered, 

and feedback loops installed, so that EPA and its diffusion partners will know if the 

information is being received and utilized. 

It is critical for EPA to recognize at the outset that it will rarely be the logical choice as 

the lead technology diffuser (for reasons previously explained in subrecommendation 1.4). 

The actual diffusion, when done by others, can still be greatly assisted by EPA, making 

EPA a key player in the diffusion process. 

The TIE Committee commends the EPA's Office of Air and Radiation for sponsoring 

the "Clean Air Marketplace Conference." The conference was an open forum for a wide 

range of environmental stakeholders to learn about environmental issues, including newly 

available environmental and environmentally beneficial technologies. 

b .WORK WITH STATE AND LOCAL GOVERNMENTS AS 

CHANNELS TO DIFFUSE TECHNOLOGICAL INFORMATION: 

State and local governments have identified diffusion support as a primary component for 

an improved relationship with and support from EPA. State and local agencies are in an 

excellent position to be main sources of information for a wide variety of technology users 

because they are the principal regulatory contact for most regulated organizations. The 

close relationship of these agencies with local regulated organizations and others interested 

in environmentally beneficial technology information has been described above. EPA 

should strengthen its working relationship with the technology diffusion parts of state and 

local agencies, and should seek to help them diffuse credible environmental information 

and information services. 

c .­ WORK WITH OTHER MAJOR POTENTIAL AND CURRENT 

PROVIDERS TO DIFFUSE ENVIRONMENTAL INFORMATION: 

To be effective, EPA needs to work with other technology diffusers, such as engineering 

firms, other federal agencies, state and local governments, public-private technology 

consortia, trade and professional associations and academia. EPA should actively seek out 

diffusion partners through a variety of channels to ensure the widest range of available 

potential partnerships. The search for diffusion partners would be led by the EPA's 

diffusion leader, as explained in subrecommendation 1.1. 

60
EPA must examine the role of each technology diffuser and tailor EPA's support of 

individual users to simultaneously advance the agency's diffusion (and environmental) 

goals with those of the diffuser. In a few cases, EPA will be the lead diffuser, but more 

often it will find itself supporting the activities of its diffusion partner. This support can 

take many forms, including technical assistance, publication, technical review, promotion, 

contacts, access to data, and money among the many support tools available. 

Relationships with many diffusion partners will be new and unique to EPA and may 

require extreme patience and understanding before EPA's diffusion agenda can be 

advanced with those partners. 

61
2.2 Collect and generate credible information about 

environmentally beneficial technologies. 

Commentary 

Technology users have a variety of biases against using a new technology. In the 

environmental arena, these biases are difficult to discern from real problems or willful noncompliance. These biases can include: concern about costs, lack of understanding about 

processes, lacking information about the existence of technology options, cultural attitude 

against change, and bias against the technology supplier (e.g., "I won't use any technology 

that was developed in Japan!"). A relatively easy way to overcome resistances expressed 

by technology users is through the dissemination of credible information. 

Credible information about environmentally beneficial technologies can overcome 

many of the biases expressed by technology users when they consider a new technology 

for installation. The desired data includes detailed analysis of the cost of performance, 

process and engineering details, case studies showing how prior users obtained significant 

benefits from the new technology, and announcements about newly available technologies. 

By overcoming these biases, diffusion can allow new technologies to gain acceptance. 

EPA can also supply testing protocols, arrange physical inspections, provide technical 

reviews, and conduct user polling and case study research to ensure that the information 

about a new technology will be credible. 

The TIE Committee recommends that EPA undertake two critical activities to build a 

strong diffusion program: (1) understand the pollution problems and environmental 

technology needs of regulated organizations, and (2) collect credible information about 

needed technologies and disseminate it through appropriate diffusion mechanisms. The 

Committee found that EPA is not taking advantage of the full range of sources of 

understanding about problems and needs in its diffusion programs. Indeed, the agency 

should do more to increase the credibility of information developed by potential partners 

(see subrecommendation 5.3). This subrecommendation, 2.2, discusses how EPA can be 

most successful in collecting and generating credible information, and emphasizes that 

EPA's most important role is in collecting information, rather than in generating it. 

62
The TIE Committee's perspective about EPA's role in increasing the pool of credible 

performance data about environmentally beneficial technologies is discussed in detail in 

Recommendation 5. The Committee believes that the critical focus for EPA should be on 

collecting credible information developed by others on working with others to expand 

their generation of credible data. An outstanding example of how EPA accomplish this 

exists in the new program, conducted cooperatively among EPA, DOD, DOE, and the 

private sector, to test and evaluate innovative technologies and techniques at DOD and DOE 

facilities (see subrecommendation 5.1 and 5.2 "h"). 

a . IDENTIFY AND WORK WITH THOSE WHO UNDERSTAND 

INFORMATION USERS' NEEDS: There are a wide variety of groups that 

have particularly good "windows" on the technology information needs of regulated 

organizations and others. It is extremely important for EPA to identify each of these 

groups and understand its special perspective, form a systematic working relationship with 

each, and apply the insight gained to the design and information contents of diffusion 

mechanisms. This information can also be valuable in the ORD research planning process. 

For illustrative purposes, the sections below discuss some of the groups with special 

"windows." 

a( 1). WORK WITH STATE AND LOCAL GOVERNMENTS TO 

IDENTIFY INFORMATION USERS' NEEDS: State and local 

governments are particularly aware of the diffusion needs of regulated organizations and 

others. This awareness is derived from their direct role in helping solve local pollution 

problems, their understanding of stakeholder perspectives and information needs, their 

understanding of permit and compliance status and schedules, and their appreciation of 

local economic conditions and trends. 

a(2). WORK WITH CONSULTING ENGINEERS TO IDENTIFY 

INFORMATION USERS' NEEDS: Consulting engineers have a unique 

position in the diffusion system that can be particularly useful to EPA. Consulting 

engineers are often called in by regulated organizations as a "third party" to assist in the 

application of technical solutions to pollution problems. They have great insight into the 

environmental problems of regulated organizations, and can supplement this insight with 

their special knowledge about a regulated firm's proprietary manufacturing processes and 

competitiveness considerations. Consulting engineers often are the outside technical 

experts supporting in-house design, production, and/or environmental engineering staffs. 

63
As noted in the commentary to Recommendation 1, consulting engineers play a particularly 

important role in reaching environmentally beneficial technology followers. 

EPA should work closely with consulting engineers to identify information user's 

needs. Their special insight into the technology concerns of regulated organizations make 

them extremely valuable diffusion partners. The TIE Committee commends the 

development of a diffusion strategy by EPA's Technology Innovation Office (TIO) that is 

founded in large part on forming a working relationship with consulting engineers to help 

them give better advice to their clients. This relationship is a two-way street, with the 

insights of the consulting engineering community being brought to bear on the diffusion 

systems EPA is establishing to support faster, lower cost, more effective cleanups. Other 

areas of EPA could benefit from similar diffusion programs. 

a(3). WORK WITH OTHERS TO IDENTIFY INFORMATION USERS ' 

NEEDS: A broad range of other organizations possess insight about the 

information needs of technology users. These groups include: trade associations, research 

consortia, state technical assistance programs, other federal agencies, and universities. 

Research consortia, such as the National Center For Manufacturing Sciences, and the 

Center for In-Process Analytical Chemistry (CPAC), can be useful for reaching a large 

number of firms simultaneously. 

The TIE Committee commends EPA's diffusion work with the National 

Environmental Technology Applications Center (NETAC), and believes that this program 

may be a useful model for future EPA diffusion partnerships. Through a 4-year 

cooperative agreement that emphasizes a partnership arrangement, EPA/ORD, through its 

Office of Environmental Engineering and Technology Demonstration (OEETD), and the 

University of Pittsburgh Trust, created NETAC in 1988 to assist in the commercialization 

of environmental technologies. Since then, NETAC has worked closely with industry, 

government, and academia to help guide environmental technologies to the marketplace. 

Two factors that make NETAC attractive to industry are its ability to engage in 

confidentiality agreements and its ability to help companies overcome the regulatory and 

other hurdles of the commercialization process. NETAC offers industry services in the 

following areas: technical and commercial assessments; technology development 

assistance; permitting and regulatory assistance; and patent, royalty, and licensing 

agreements. It is most helpful to small to medium sized businesses that do not have this 

capability in-house. 

64 
b .

WORK WITH OTHERS WHO GENERATE AND COLLECT 

CREDIBLE INFORMATION ABOUT ENVIRONMENTALLY 

BENEFICIAL TECHNOLOGIES: Since EPA's environmental technology 

research resources constitute only a small fraction of the nation's total investment, the 

agency cannot become a self-sufficient generator of information. Therefore, EPA's 

principal roles are to help others: (1) improve the quality of data they generate (see 

subrecommendation 5.3) and (2) collect information on environmentally beneficial 

technologies. Just as EPA must work to identify users' information needs, it must form 

partnerships with others who generate and collect the needed information. This will give 

the agency the technological information it needs to aid the diffusion process. The 

diffusion partners discussed in subrecommendation 2.1 "c" are all potential sources of 

information for the diffusion system. 

65
2.3

Strengthen and use the full range of technology diffusion 

mechanisms, and help make them widely available to 

other diffusers. 

Commentary 

As discussed above, a major role for EPA is to improve the quality of data included in 

diffusion mechanisms (and the quality of the vehicles for diffusion themselves), help make 

credible technology information available on a timely basis, and promote the use of the full 

range of available technology diffusion mechanisms, including its own and those of other 

diffusion partners. A wide variety of technology diffusion mechanisms is available today, 

including: 

•­ Automated and non-automated technical information systems of various

kinds (e.g., design manuals, expert systems, databases,

clearinghouses, interactive videos).

•­ Technical assistance programs (from a variety of sources). 

•­ Training programs based in universities, government, industry, and

other places. These programs include seminars, forums, training

courses, society meetings, short courses, workshops).

•­ Educational programs at the graduate and undergraduate level (covered

in 2.3e).

•­ Publications. 

•­ "Hot lines" (phone lines from which people can get quick answers and

assistance).

•­ Trade fairs and conferences. 

•­ Peer to peer matching programs. 

•­ Rotational assignments. 

•­ Licensing programs. 

•­ Libraries. 

66
Subrecommendation 2.1 enumerates the diffusion partners and suggests how EPA 

could work with them to strengthen and promote the widest possible use of the diffusion 

mechanisms. This subrecommendation (2.3) discusses what methods are available to 

accomplish diffusion and outlines suggestions for EPA's relationship with them. All types 

of credible environmental information should be addressed, including environmental 

business data (see subrecommendation 2.4) and international environmental business and 

technical data (see subrecommendation 2.5). 

EPA should develop and maintain technology diffusion systems that contain the widest 

possible variety of credible information about environmentally beneficial technologies, and 

support others as they develop technology diffusion efforts. This support should include 

helping others disseminate information through all available means. EPA's position of 

credibility is a strength, but as noted in the Findings, EPA is so limited in the information it 

collects and in its ability to improve the quality of data produced by others (see 

subrecommendation 5.3) that its efforts in this area are insufficient and not adequately 

leveraged. It is similarly not possible for EPA to understand all users' needs for diffusion 

services, nor can it provide all services. 

a. EXPAND EPA'S CURRRENT DIFFUSION MECHANISMS: The 

Committee believes that the agency's current diffusion programs should be reviewed and 

revised. The value and impact of ORD's efforts can be increased. ORD's emphases now 

are publications, information systems, and training-based diffusion programs. The agency 

also has a number of hot lines. Libraries are available in regional offices. In addition, the 

agency, and particularly ORD, coordinates and participates in trade fairs. Many of these 

activities are high in quality. Some of them, however, reach only a small percentage of 

their intended audiences. 

b . NEW AND IMPROVED DIFFUSION MECHANISMS MUST BE 

INCLUDED IN EPA'S PROGRAMS: To reach a larger audience and make 

a greater impact, the Committee suggests that ORD become less insular and more of a 

partner, expanding the impact of its programs through leveraging of the efforts of the many 

other groups who have a diffusion interest and possess diffusion capabilities. ORD should 

work with its partners to broaden its use of less-emphasized diffusion methods and 

broaden the informational content of its diffusion data bases. For example, EPA has 

undertaken a valuable effort, in conjunction with DOD and DOE as part of the Strategic 

Environmental Research and Development Program (see subrecommendation 5.3 "a") to 

67
expand the reach and impact of federal environmental technology research by coordinating 

federal approaches to producing and transferring environmental technology related data. 

Similar efforts should be made to extend this type of coordination. The Committee has 

suggested that more attention be paid to a variety of steps to enhance the expertise of EPA 

personnel, such as rotational assignments, peer-to-peer matching programs, and 

educational programs (see subrecommendation 1.3). These types of effort would improve 

the ability of EPA personnel to communicate with their counterparts in industry and 

elsewhere. As discussed in subrecommendations 5.1 and 5.2 "1", expansion of CRDA's 

and licensing agreements would provide benefits. Also, as discussed in 

subrecommendation 3.1, ORD diffusion programs need to particularly support the 

agency's pollution prevention program. In order to accomplish this, the PPIC 

clearinghouse needs to be given a higher profile both inside and outside the agency. 

68
2.4 Define, collect, and analyze environmental business data 

to understand diffusion partners and information users. 

Commentary 

There are two major types of environmental business data: (1) data documenting the 

national expenditure for pollution abatement, capital investment, and operating costs, and 

(2) data documenting the business that provides products and services used for 

environmental purposes, from consultants to equipment supplies to clean-up services to 

research laboratories. In short, these two types represent the two sides of environmental 

transactions: the purchase and the sale. 

Taken together, collecting and analyzing the two types of data would add a missing 

piece necessary for EPA to clearly understand the impacts of current environmental 

programs and policies on the nation's ability to meet environmental goals, to innovate and 

adapt, and to remain competitive internationally. This understanding is critical to our ability 

to predict the impact of future policies. It is also important to have an understanding of the 

limits of the national economy to reduce pollution and the need for efficiencies in specific 

sectors of the economy in meeting environmental objectives. It is, after all, the private 

sector in the U.S. that provides most of the products and services that clean up 

environmental problems. 

EPA has little data characterizing the industries that provide these products and 

services (e.g., data on the markets for environmental products and services in the U.S. and 

internationally, data on the financial health of these industries, or data on research and 

development investment for better technology). Without these data, EPA is restricted to 

interpreting the national ability to abate pollution in terms of scientific (or technological), 

statutory, or political limitations. 

69
a. ESTABLISH A BUREAU OF ENVIRONMENTAL STATISTICS: A 

Bureau of Environmental Statistics should be created. The Bureau would serve to 

coordinate planning, execution, analysis and diffusion of environmental data, including the 

necessary collection, analysis, and dissemination of environmental business data described 

below. 

b . DETERMINE HOW ENVIRONMENTAL BUSINESS DATA CAN BE 

USED EFFECTIVELY FOR POLICY PURPOSES, WHAT DATA 

ARE NEEDED, AND IN WHAT FORM: EPA should organize an effort to 

work with the potential information sources, analyzers, and users, as well as with its other 

environmental partners, to determine how environmental business data can best be used by 

government and industry to select policies that support a successful partnership. This 

effort should include an evaluation of what kinds of data and analyses are required and how 

the results will be used. Partners should include the Census Bureau, the National Science 

Foundation, and other organizations to develop a concept for an ongoing system for 

environmental data gathering, analysis, and dissemination. The effort should also address 

a means for sharing data with industry and other interested parties. 

Studies should be conducted both domestically and abroad to determine the major 

users of environmental business data (e.g., federal, state and local government, users and 

developers of technologies). Surveys and other data collection efforts should be conducted 

to determine the needs of EPA and other users, to determine what data are available, and to 

understand how to obtain data that are not available. The above research should be carried 

out keeping in mind the confidentiality requirements of business. 

At a minimum, data should be obtained on: markets, the financial health of the 

environmental industry, who is doing what R&D, how much is being spent on R&D in 

various sectors, and the purposes of the R&D. To accomplish this, a breakdown of data 

among the categories of technologies, e.g., pollution prevention, pollution control, 

remediation, is required. This information should be generated for the recent past and 

present time and continue to develop trends. Data should be related to SIC codes to the 

extent possible. 

In an alliedeffort, an analysis of the role that EPA's R&D funds have played in 

stimulating and supporting private sector environmental spending should be conducted for 

all categories of environmentally beneficial technology. An effort should be made to 

70
quantify expenditures (absolute and as a percentage of R&D) on diffusion by EPA and 

others (e.g., federal agencies, private industry), and to measure of their impact on 

technology application both domestically and abroad. 

c . WORK WITH OTHERS TO COLLECT NEEDED DATA: EPA should 

determine what required information has already been collected and how to access it. EPA 

should also determine where additional required data are located or can be collected. 

Moreover, the agency should create and implement a cost-effective plan to collect it, using 

existing data-gathering sources to the extent possible (e.g., publications, survey 

organizations). In doing this, EPA should take advantage of all existing sources of 

information and data-gathering services, including the National Science Foundation and the 

Bureau of the Census of the Department of Commerce. EPA should consider going 

beyond these sources as needed to develop its own data gathering resources. This can be 

done through contracting agencies or universities. On-going reviews and modifications of 

the data collected, the data collection process, and data dissemination systems should be 

made. 

d . IMPLEMENTA PLAN TO ANALYZE AND APPLY THE DATA FOR 

POLICY MAKING AND TO SUPPORT DIFFUSION PROGRAMS: 

EPA should develop and implement a plan to analyze environmental business data and to 

disseminate the data and the results of analyses. Data analysis should include reviews of 

the business strategies of different firms to determine the relative technology posture of 

each. Additional analysis tasks will be identified as a result of subrecommendation 2.4 

"b" „ 

71
2.5

Collect international environmental business and 

technical data to help U.S. firms compete domestically 

and abroad. 

Commentary 

American business has a strong interest in more active support from EPA and other 

government agencies (e.g., the Departments of State and Commerce) in the international 

environmental arena. Government's role has two elements: 

•On the one hand, the export of U.S. environmental values and 

technologies can be a significant factor favoring both an improved 

world environment and an improved trade balance. Working with 

others in and out of government to help collect environmental business 

data about foreign markets is an important and underemphasized role. 

•On the other hand, governmental efforts to collect and disseminate

information about environmentally beneficial technologies that exist in

foreign countries can be helpful to U.S. firms in a competitive world

market.

EPA should expand its diffusion activities internationally. The TIE Committee's 

recommendations in this area are discussed specifically in Recommendation 4. 

72
2.6. Support university curriculum development to increase 

literacy in environmentally beneficial technology. 

EPA should expand its work with universities under the Environmental Education Act 

of 1990 to expand environmental technology literacy. This recommendation applies to at 

least business, engineering, scientific, and political science curricula. Curriculum 

development support should be aimed at expanding the perspective of future technologists 

and managers so that they understand the cultural and technological implications of: (1) the 

concepts of cooptimization of productivity and environment (in other words, that 

productivity and environmental outcome are related), (2) multi-media (or comprehensive) 

approaches to environmental management, (3) pollution prevention, and (4) alternative 

ways to set environmental priorities. 

The TIE Committee commends the University of Michigan and EPA for the new 

pollution prevention course development program, and recommends that similar programs 

be supported by EPA at other leading universities to develop courses at the undergraduate 

and graduate levels. EPA should also support the efforts of business, science, 

engineering, and political science schools to develop and teach courses on the management 

of technology, including government-industry relations. These schools should also be 

assisted in their efforts to design exercises that improve students' cooperative skills. In 

addition, public policy departments should be aided in their efforts to educate students on 

the policy aspects of technology as it relates to the environment and the economy. By 

reaching students at the early stages of professional development, the agency can ensure a 

long term awareness of the techniques and benefits of the roles and uses of technology in 

environmental management by future technologists and managers. 

73
Recommendation 3: 

Make diffusion and incentives the emphases of EPA's pollution 

prevention programs. 

3.1Increase the use of data-based, non-regulatory drivers, 

including diffusion programs, in EPA's pollution 

prevention strategy. 

3.2Create pollution prevention incentives, including 

multi-media approaches, for regulated and non-regulated 

organizations. 

3.3Diffuse the pollution prevention ethic within EPA, and 

establish a system of incentives and support for diffusion 

efforts by EPA personnel. 

3.4Increase resources for EPA's pollution prevention 

technology research and development. 

Commentary 

The TIE Committee has long felt that pollution prevention is the preferred approach to 

environmental improvement. Preventing pollution is preferable to correcting it after it is 

generated. Further, cooptimizing environmental and productivity objectives can lead to the 

lowest overall costs of production and pollution reduction, and often lead to competitive 

advantages. 

The Committee is concerned that conventional regulation will become the 

government's predominant approach to encouraging pollution prevention. It is important to 

recognize that a continuing commitment for pollution prevention has unique drivers; these 

are internally maintained and cultural in nature, and in some organizations are related to a 

commitment to total quality management. Compliance-based environmental management 

strategies by regulated organizations, on the other hand: (1) are usually motivated most by 

the threat of penalties associated with non-compliance, (2) do not benefit from incentives to 

exceed required performance (and are therefore usually merely compliance oriented), and 

(3) usually do not involve technological risk taking (outside the application of the best 

available technologies on which the regulatory requirements were based). 

74 
Regulated parties that take a pollution prevention approach involve a different in-house 

team than do organizations taking a compliance-oriented approach. This is because the 

identification of prevention approaches requires the collaboration of process and product 

design engineers with environmental staffs. Together, they design products and 

production processes that waste less, are more efficient, and produce fewer toxic wastes 

(and less of them). Waste treatment has a greatly reduced role in the pollution prevention 

approach. Regulated parties that do not look first to pollution prevention focus on the 

measurement and control of production wastes; they rely primarily on separate 

environmental staffs. 

The TIE Committee found that many regulated organizations and others believe that 

additional fundamental problems exist that doom a regulation-first pollution prevention 

strategy by government. 

•First, this strategy is considered by many to contain regulations and

permitting and compliance policies that are too rigid. Experimentation,

innovation, and the use of innovative solutions are all perceived to be

bad risks, particularly as a result of inflexibility in permitting and

compliance policies and the lack of diffusion support.

•Second, many regulated organizations perceive a pattern that

government agencies, including EPA, require the application of best

practices used at any one site at many or all sites. Thus, regulatory

requirements are seen by many to be ratcheted, capturing every

advance, in an ad hoc manner that makes the regulatory process even

more unpredictable. This practice constitutes a major disincentive to

innovation and pollution prevention.

•Third, government staff is criticized by others as lacking technical

competence, both in general and especially with respect to production

processes and industrial decision making practices. In combination

with the second problem, this perception generates great fear in

regulated communities about the potential extension of regulatory

intervention beyond the end of the pipe into production processes and

product design.

It should be noted that the protection of confidential business information will become 

an even more prominent issue as environmental agencies increase their involvement in 

pollution prevention. This will be the case in both regulation-based and in diffusion and 

incentive-based programs. The public disclosure of environmental information already 

creates a window on businesses that can be used to gain competitive advantage. To the 

extent that government agencies become more knowledgeable about confidential business 

information, there will need to be greater care taken that it is not inadvertently revealed. 

75
As discussed in subrecommendation 1.5, the Committee believes that regulations and 

their strict, predictable enforcement trigger and define the environmental marketplace. 

While the Committee believes that relying on regulatory approaches to encourage pollution 

prevention can work against the internally motivated drivers involved in pollution 

prevention, weak and/or inconsistent enforcement undermines the drivers of pollution 

prevention in permitted organizations. Federal regulatory and enforcement signals are 

critical in setting a baseline for the minimum environmental performance that helps level the 

playing field in the minds of regulated communities and technology developers. To make 

pollution prevention work, government will also need to make credible information as 

widely available as possible to increase options and create incentives to go beyond 

regulatory minimums. 

Uncertainty and unpredictability can be reduced, and greater flexibility introduced, in 

regulations and in permitting and compliance systems without compromising their 

enforceability and the assurance of compliance. The incorporation of these concepts in the 

environmental management system will allow greater risk taking and experimentation, 

providing a constant incentive to innovate and to apply innovative technologies and 

techniques in the choice of environmental solutions. Both investment in the development 

of innovative and pollution preventing solutions and the widespread diffusion of 

environmentally beneficial technologies will thereby be encouraged. Support and 

collaboration from EPA's research and development program on pollution prevention 

technologies and techniques can also provide encouragement. 

Based on this analysis, the TIE Committee recommends that EPA's pollution 

prevention programs have a diffusion and an incentive focus. As discussed above, though, 

the establishment of regulatory minimums and their strict, predictable enforcement are 

considered critical to create a level playing field of across-the-board improvement for all 

regulated organizations. An internal system of incentives and support for this focus is 

needed to ensure that the pollution prevention ethic is understood and practiced by 

regulatory, permitting, and compliance personnel at the federal, state, and local levels. The 

subrecommendations below describe how to use data-based, non-regulatory drivers, 

including diffusion programs and incentive strategies, to foster pollution prevention. 

76
3.1

Increase the use of data-based, non-regulatory drivers, 

including diffusion programs, in EPA's pollution 

prevention strategy. 

Commentary 

Information-based, non-regulatory approaches to pollution prevention are important 

when seen from the perspective of leaders, followers, and laggards. As discussed in 

subrecommendation 1.5, leaders are usually the larger, more successful, and more 

technologically sophisticated regulated organizations. They are also more self-sufficient 

than other organizations. Followers, the middle ground organizations, are cost-conscious, 

and are compliance oriented. They usually use technologies that are widespread and 

commonly available, and use third parties for technology advice and procurement. 

Laggards are usually the last to use innovative technologies and often comply under 

duress. They are typically the small firms in an industry and usually lack in-house 

technological capability. Followers and laggards generally outnumber leaders. 

If EPA seeks to encourage pollution prevention successfully, data-based, nonregulatory drivers are particularly important for the followers and the laggards. In each 

case, a regulatory "push" is seen as needed by the Committee to create a market "pull." 

But, because followers and laggards seek help from third parties that are credible 

information sources, the ability of EPA to increase the availability of information through 

its own and others' diffusion systems and to establish drivers that make people want to 

improve environmental outcome is important. 

This subrecommendation discusses how EPA can succeed with this approach. It 

should be noted that the need to create support systems for rule writers, permit staffs, and 

compliance personnel is discussed in subrecommendation 3.2; such support systems are 

critical if environmental agency personnel are to consider their diffusion role to be 

important on a daily basis. The role of the diffusion coordinator which is discussed in 

subrecommendation 1.1, also has great value in promoting pollution prevention. 

77
a. STRENGTHEN THE USE OF DATA-BASED, NON-REGULATORY 

DRIVERS TO FOSTER WIDESPREAD ADOPTION AND USE OF

POLLUTION PREVENTION CULTURE AND APPROACHES TO

ENVIRONMENTAL IMPROVEMENT: In the past few years, federal,

state, and local governments have initiated trials of data-based, non-regulatory drivers of 

environmental improvement. These include the SARA Section 313 release reporting 

requirements, facility planning requirements that are now in place in nearly half of the 

states, the "33 - 50" program, the "Green Lights" program, and expanded training 

programs and information clearinghouses. The Committee believes that most of these 

either already have or will prove to have been valuable expansions of traditional 

government interventions on behalf of the environment. 

•Section 313 of SARA (the Superfund Amendments and

Reauthorization Act) requires regulated organizations who release

certain toxic substances to make an annual report giving an inventory of

the amount of each released. This toxic release inventory has proven to

be a significant driver of industrial change and pollution prevention-

based environmental improvement because it creates accountability

through internal data management and public reporting. Since SARA

Section 313, regulated organizations can no longer operate on the

theory that what cannot be measured can be ignored. Regulated

organizations now have a clear knowledge of their waste of certain raw

materials, and many are taking steps to prevent some or all of that

waste. Thus, SARA 313 encourages pollution prevention through

environmental accounting and reporting, rather than through regulation.

•Facility plans are now required in at least fifteen states. This

requirement obligates facilities to undertake a series of pollution

prevention evaluative steps as a condition of continued operation.

Some programs emphasize planning for toxics use reduction, rather

than just reductions in generation or release of hazardous wastes or

toxics. Whether planning is linked to more extensive pollution

prevention permitting requirements or enforcement actions depends on

the individual program, but even in those where there is no "hammer,"

these facility plans are an effective tool to focus facility designers and

operators on the toxicity and hazardousness of feedstocks, processes,

and waste. The exercise of writing a plan allows these managers to

identify opportunities to improve their productivity and environmental

performance.

•

The 33 - 50 program encourages voluntary participation by

industry to reduce toxic releases and off-site transfers of seventeen

specific chemicals from all media. The program has targeted reductions

of 33 percent by 1992 and 50 percent by 1995. Begun as a national

effort, it is now augmented by several regional programs. The 33 - 50

program is "back stopped" by regulatory carrots and sticks and is

78 
therefore only partially non-regulatory in nature. However, it has 

produced significant results: over 600 companies have agreed to 

eliminate 290 million pounds of emissions. 

•Green Lights is a voluntary EPA program that encourages industry

and states to install high efficiency lighting. The agency also works

with suppliers under the Green Lights Ally Program to promote the

benefits of energy efficient lighting. There are over 200 participants in

each of these programs. In this program, EPA has successfully

encouraged significant capital investment in environmentally beneficial

lighting technology. If this program can help increase the market

penetration of high efficiency lighting significantly, environmental

contaminants associated with the production of electricity will be

proportionately reduced.

b . STRENGTHEN PROGRAMS TO DIFFUSE POLLUTION 

PREVENTION R&D RESULTS, OPERATING EXPERIENCE, AND 

ACCOUNTING METHODS TO REGULATED ORGANIZATIONS. 

USE MECHANISMS SUCH AS THE POLLUTION PREVENTION 

INFORMATION CLEARINGHOUSE (PPIC): For data-based, nonregulatory drivers to successfully foster pollution prevention practices, credible information 

from a wide variety of sources should be made available. EPA's diffusion functions 

should have prominence in the Office of Pollution Prevention and Toxics (OPPT), ORD, 

and the media-specific programs, where pollution prevention opportunities should be an 

area of emphasis and multi-media information should be provided. EPA regional offices 

should become more visible and aggressive in support of pollution prevention, and EPA 

should continue, but upgrade, its work with the states. 

Credible information on contacts, costs, techniques, technologies, as well as impacts, 

should be made available, whether originated by EPA or not. EPA has begun a potentially 

major program to disseminate pollution prevention information. This system is called the 

Pollution Prevention Information Clearinghouse (PPIC), which offers users several 

services at no charge, including a pollution prevention hot line, a 24-hour on-line electronic 

information system ( called PIES), a repository of pollution prevention research data, and 

an outreach program. The TIE Committee supports PPIC, and believes that it should be 

given a higher profile both inside and outside the agency. The section of the electronic 

database dealing with industrial case studies should be showcased. Credible data from a 

wide number of sources should be added. 

79
An effort should be made to develop standardized accounting procedures to determine 

true costs and to calculate whether a pollution prevention approach is more cost effective 

than pollution control and remediation technology options. Costs associated with pollution 

control are relatively simple to ascertain, based upon the cost of the control and costs 

associated with the disposal of waste materials. Costs associated with pollution prevention 

are more difficult to ascertain, since they may involve process changes, feedstock changes, 

efficiency savings, and savings associated with avoiding the need for additional permits. 

The agency should develop specific initiatives for technology diffusion within its 

program offices that include at least the following three elements: (1) targeting specific 

technologies and techniques, and potential users, based on the severity of environmental 

hazards associated with production processes and products, and multi-media opportunities 

for improvement, (2) providing multi-media information on costs and economic benefits, 

and (3) linking providers of technology and potential users. The agency should also 

facilitate the early use of pollution prevention techniques. To this end, R&D performance 

data (both favorable and unfavorable) on pollution prevention technologies and techniques 

should be documented and made available to information diffusers and regulated 

organizations. Additionally, the agency should continue to sponsor conferences and 

workshops on pollution prevention. The more EPA promotes successful pollution 

prevention technologies and techniques, the more these technologies will become available, 

and the more the agency's goal of increased pollution prevention will be advanced. 

c . USE OTHER ORGANIZATIONS TO DISSEMINATE 

INFORMATION: To repeat an earlier point, EPA cannot be the sole or even 

the major diffuser of environmentally beneficial technologies, especially pollution 

prevention technologies and techniques. It should share the effort with consulting 

organizations, professional associations, trade associations, and state and local 

governments. The users of diffusion services are in many cases reluctant to work closely 

with regulatory agencies. It is therefore very important that the agency redirect its diffusion 

efforts to take advantage of partnerships with these other organizations. 

State and local governments are today much closer to most regulated organizations, 

and are in truth the regulating arm of the system. The agency should make a special effort 

to assure that it works closely with state and local agencies in planning diffusion programs, 

that it satisfies state and local government needs, and uses the diffusion paths they already 

have in place. 

80 
3.2

Create pollution prevention incentives, including 

multi-media approaches, for regulated and non-regulated 

organizations. 

Commentary 

In moving the environmental management system towards strategies that encourage 

pollution prevention, the TIE Committee recommends that EPA apply both regulatory and 

incentive approaches. Together, these two approaches establish a foundation of progress 

that levels the economic "playing field" for all regulated organizations and reinforces 

management philosophies and practices that seek continuous improvement in productivity 

and environmental outcomes. Significantly, the combination of regulations and incentives, 

supported by diffusion, encourages regulated organizations to gain the greatest economic 

and environmental results most efficiently. What is needed is for EPA to define, promote, 

and implement an environmental management system that demonstrates the benefits of 

pollution prevention. 

The Committee therefore recommends that careful consideration be given by EPA and 

other environmental agencies to instituting in all parts of the regulatory system incentives 

for the encouragement of pollution prevention. Incentives reward a desired behavior, and 

can work in conjunction with a regulatory/compliance-based approach. Effective 

incentives introduce flexibility and foster innovation. As discussed in subrecommendation 

3.1, the TIE Committee believes that EPA's pollution prevention strategy should feature 

data-based, non-regulatory drivers, especially diffusion. The following sections 

recommend specific steps that EPA should take to incorporate incentives in the 

environmental management system. The sections on support (see subrecommendation 1.3) 

and multi-media offer a more complete discussion. 

a . EXPAND MULTI-MEDIA APPROACHES TO ENVIRONMENTAL 

MANAGEMENT: The Committee emphasizes that although EPA is organized 

on a media-specific basis through legislation and the administration of regulatory programs, 

pollution prevention would be best supported by a multi-media approach. The multi-media 

perspective should be built into regulatory, permitting, and compliance programs, as well 

as diffusion programs. 

81 
Several experiments are underway within EPA and state and local authorities to 

expand multi-media thinking. In regulations, the Office of Water is exploring how to build 

pollution prevention into the effluent guidelines by considering how to bring to bear the 

concepts of multi-media, innovation, and flexibility. The agency's efforts to work with 

three "model states" in an experiment with multi-media, facility-wide (or coordinated) 

permits that encourage pollution prevention has been discussed earlier. Nearly half of the 

states have been exploring the idea of a multi-media approach to enforcement, and EPA 

enforcement policies now are beginning to encourage pollution prevention planning by 

non-compliers. 

b. PROVIDE POLLUTION PREVENTION INCENTIVES, TRAINING, 

AND OTHER SUPPORT TO REGULATORY PERSONNEL: Support 

for the people involved in the regulatory system is also critical. Subrecommendations 3.3 

and 1.3 discuss the need for a system of incentives and support for regulatory agency 

personnel to play an effective role in implementing a pollution prevention approach. Both 

general technical and pollution prevention training should be provided to EPA's (and other 

environmental agencies') rulemakers, permit writers, and compliance personnel. Allowing 

the use of pollution prevention approaches requires regulatory personnel to have a better 

understanding of industrial processes and other technical areas. Similarly, better 

technically trained personnel are needed to write regulations and permits and to evaluate 

compliance options that encourage pollution prevention. Recommendation 5 discusses an 

increased role for ORD in providing technical support rulemakers, permit writers, and 

compliance personnel. 

c .DESIGN REGULATIONS AND REGULATORY PROCESSES TO 

ENCOURAGE POLLUTION PREVENTION: Regulations and regulatory 

processes should be designed to encourage pollution prevention. Technology-based 

regulations provide a foundation for environmental improvement, but may not encourage 

wide choices of approach to compliance, pollution prevention, continuous improvement, or 

going beyond the minimum. Where possible, regulations should encourage the use of 

pollution prevention procedures to meet the regulatory requirements. 

As discussed in subrecommendation 1.5, there is a need to increase regulatory 

certainty and predictability to encourage technology innovation and diffusion. This same 

point applies to pollution prevention. The ability to anticipate regulatory targets, 

82 
promulgation dates, and compliance dates is critical to all technology developers and 

regulated organizations that seek improved manufacturing technologies and techniques to 

meet environmental objectives. The ability to anticipate regulations is equally important to 

regulated organizations seeking environmental solutions that cooptimize between 

environmental and productivity objectives. Effective regulatory encouragement of the use 

of pollution prevention solutions will facilitate the application of innovative and efficient 

technologies and techniques to environmental problems. 

Technology-based standards have an important role to play in encouraging pollution 

prevention in that they establish a base for environmental improvement. Thus, these 

standards can create a level playing field for all regulated organizations. A total reliance by 

regulators on the "best" available technology approach, however, can reduce the incentive 

to find innovative technology solutions that prevent pollution, both with respect to cost of 

the same performance and of improved performance. In this approach, technology tends to 

become frozen with respect to environmental performance. 

Moreover, media-specific requirements for industrial categories have been developed 

independently of regulations for the same industrial categories in other media. In some 

cases, more important environmental problems associated with that industrial category have 

gone unaddressed, while regulatory requirements are set for less important problems. 

EPA's recent regulatory innovation -- "regulatory clusters," under which the consideration 

of all pending regulatory actions related to a single industrial category are linked -- is a 

strong step in the right direction. 

d . BUILD ENCOURAGEMENT FOR POLLUTION PREVENTION IN 

PERMIT AND COMPLIANCE POLICIES AND PROGRAMS: As 

discussed in the Commentary and in subrecommendation 1.5, permitting and compliance 

approaches are widely seen as being strongly at odds with the initiative and innovation that 

are necessary for pollution prevention. This conclusion pertains both to the permitting of 

tests and evaluations, and of proposed uses of these technologies and techniques. Because 

the development and use of pollution preventing approaches is reduced by existing 

permitting and compliance policies and programs, data is not generated that can be made 

available through diffusion systems. The TIE Committee reiterates its conclusions and 

recommendations in its report, Permitting and Compliance Policy: Barriers to U.S. 

Environmental Technology Innovation. 

83 
The Committee further recommends that permitting and compliance systems should be 

modified to increase flexibility. Greater flexibility aimed at encouraging regulated 

organizations to consider alternatives to best available technology in permit applications is 

particularly important. In some locations, the use of best available technology has become 

a de facto requirement. Multi-media approaches to permitting and compliance programs 

and policies are important to the encouragement of facility-wide environmental planning, 

which in turn provides greater opportunities to discover pollution prevention approaches. 

Permitting and compliance policies also need to be coordinated across federal, state, and 

local jurisdictional lines to maximize the effort to favor pollution prevention. An easy step, 

discussed in subrecommendation 1.5, would be to assign top priority status for the review 

of permit applications involving innovative and pollution prevention technologies and 

techniques. 

Flexibility with respect to compliance schedules and penalties should also be provided. 

Flexibility features might include the possibility of compliance waivers and extensions for 

bona fide efforts to comply using pollution prevention and other innovative solutions. In 

subrecommendation 1.5, the TIE Committee commends the supplementary enforcement 

policy which encourages a non-complier to institute pollution prevention techniques in lieu 

of fines or penalties. This policy change is a step in the direction of encouraging pollution 

prevention options in compliance systems. 

In addition, efforts to achieve compliance through pollution prevention techniques 

should be encouraged through "soft landings." Soft landings can take the form of 

postponement or reduction of penalties for a specified period to allow the regulated 

organization, acting in good faith, to make the necessary changes to bring the new 

equipment and/or procedures into compliance or to use conventional approaches to comply. 

These modifications will send clear signals to all environmental stakeholders that the 

agency supports pollution prevention solutions to environmental problems. 

Pollution prevention training for permit writers and compliance staff to improve their 

technical competence and to provide a better understanding of pollution prevention practices 

is necessary. The Committee notes that EPA has initiated pollution prevention education 

programs, one at the American Institute of Chemical Engineers and the other at the 

University of Michigan. Technical support should be provided on a standby basis by ORD 

and/or others to assist permit writers and compliance staffs involved in reviewing pollution 

prevention techniques. 

84 
3.3

Diffuse the pollution prevention ethic within EPA, and 

establish a system of incentives and support for diffusion 

efforts by EPA personnel. 

Commentary 

As discussed in subrecommendation 1.3, the diffusion of environmentally beneficial 

technologies is peopledependent. Whereas diffusion is critical to the success of 

pollution prevention, so too pollution prevention success depends on the activities of the 

people of EPA. Many of the actions needed to support this recommendation have already 

been discussed in detail in subrecommendation 1.3. To gain the full support of EPA's 

personnel for its pollution prevention diffusion effort, the TIE Committee recommends the 

following additional actions: 

a .

CREATE SUPPORT SYSTEMS FOR RULE WRITING, 

PERMITTING, AND COMPLIANCE PERSONNEL INCLUDING 

POLLUTION PREVENTION INCENTIVES, TRAINING AND 

OTHER SUPPORT: EPA should provide its personnel with incentives to 

demonstrate their support of pollution prevention activities. The pollution prevention 

support activities should be clearly measurable and rewarded in a public and timely manner. 

Awards should be provided both within and outside the agency to those personnel who 

surpass agency standards. Pollution prevention should be built into agency personnel 

evaluations. EPA should consider methods of extending this support to state and local 

regulatory personnel. 

Both general technical and pollution prevention training should be provided to EPA 

rulemakers, permit writers, and compliance personnel. The nature of pollution prevention 

procedures requires a better understanding of the industrial processes than pollution control 

and remediation technologies. Therefore, better technically trained EPA personnel are 

needed to write regulations and permits and to evaluate compliance options. Such training 

could be provided by a number of organizations familiar with industrial processes and 

pollution prevention techniques (e.g., AIChE). In addition, technical support should be 

provided to EPA rulemakers, permit writers, and compliance personnel from within the 

85
agency (e.g., ORD). The additional training will allow the agency to increase the use of 

pollution prevention technologies. 

b . USE THE DIFFUSION COORDINATOR POSITION TO PROMOTE 

POLLUTION PREVENTION: As mentioned in subrecommendation 1.1, the 

diffusion leader would actively promote pollution prevention through his/her diffusion 

activities. The diffusion leader would steer EPA's gathering and dissemination of credible 

information about pollution prevention technologies and techniques, inside and outside the 

agency. In addition, the diffusion leader would be a key supporter of action item "c", 

which follows. 

c . MAKE A STRONG POLICY STATEMENT IN SUPPORT OF 

TECHNOLOGY DIFFUSION: The agency has made a strong policy 

statement favoring pollution prevention. EPA should make a similar statement about the 

future role of technology diffusion, and use this policy statement to encourage its 

employees to increase the use of diffusion and incentive approaches that prevent pollution. 

One step is to ask for suggestions about how to implement pollution prevention procedures 

agency-wide. 

The Diffusion Focus Group recognizes the recent organizational change involving the 

Pollution Prevention Office. It hopes that this will raise the visibility of pollution 

prevention within the agency and place greater emphasis on promoting pollution 

prevention. A policy statement related to technology diffusion should reinforce the 

pollution prevention focus within EPA's environmental management strategy. 

86
3.4 Increase resources for EPA's pollution prevention 

technology research and development. 

This new area of R&D is an important one for EPA, but EPA's potential for success is 

dependent on an active partnership with industry and others who will be the ultimate users 

of the prevention solutions. A partnership is needed at the planning stage, in the conduct of 

R&D, and in developing and carrying out a diffusion strategy for promising prevention 

technologies and techniques. The need for these partnerships is so great in this program 

that EPA should seriously consider requiring that private sector co-funding be obtained for 

any pollution prevention technology and technique R&D project (see subrecommendations 

5.1 and 5.2 "f'). EPA resources to support pollution prevention R&D are also a potentially 

important incentives to be used in conjunction with other aspects of an overall agency 

approach to encourage pollution prevention, as suggested elsewhere in Recommendation 3. 

Other recommendations made in this report are important to the success of this EPA 

R&D program. These include the need to (1) increase the technical expertise of EPA staff 

in areas that are relevant to pollution prevention technologies and techniques, such as the 

design and operation of manufacturing processes and products (see subrecommendation 

1.3), (2) focus on the commercialization end point in this research (see subrecommendation 

5.4), (3) protect proprietary information EPA acquires about the processes and operations 

of its R&D partners (see subrecommendation 1.5 "b"), and (4) require careful plans for the 

diffusion of R&D results to be developed during the design of research programs and 

updated throughout the R&D life cycle (see subrecommendation 5.1). 

87
Recommendation 4: 

Expand support for the international diffusion of environmental 

technologies to help meet U.S. environmental and 

competitiveness objectives. 

4.1Help U.S. firms market environmental technologies in 

developing countries. 

4.2'Help U.S. firms market environmental technologies in 

developed countries. 

4.3Assist in gathering information on state-of-the-art 

environmentally beneficial technologies developed abroad. 

Commentary 

A complete international "technology cooperation" program at EPA requires two 

complementary parts: (1) support for the diffusion of domestically developed 

environmental technologies into foreign markets, and (2) making information on innovative 

technologies developed overseas available to U.S. regulated organizations. The diffusion 

of domestically developed environmental technologies in new markets will promote 

domestic investment in these technologies. This will make more environmental 

technologies available for domestic and international application, and help improve the 

environment locally and globally. The expanded availability of environmentally beneficial 

technologies from overseas will give U.S firms a broader range of production and 

environmentally beneficial technologies to choose from, resulting in increased efficiency 

and possible competitive advantage. 

Technology diffusion depends both on demand (technology pull) and supply 

conditions (technology push). Attempts to promote environmentally beneficial U.S. 

technologies overseas may be ineffectual without the strong demand created by effective 

environmental regulations and strong public awareness. 

EPA recently initiated an international diffusion ("technology cooperation") program to 

diffuse information about environmental technologies to developing nations and Eastern 

Europe. This pilot program is coordinated with other relevant federal agencies. The 

increase in EPA's international efforts is a positive step (although since they are only pilots, 

88 
they are not sufficient); EPA is doing more than ever to help other countries build 

institutional systems for the environment. These systems support sustainable economies 

with strong environmental values, and help create a lasting demand for U.S. environmental 

products and services where the need for them is acute. 

Unfortunately, these pilots highlight a significant gap in EPA's international diffusion 

effort. There is insufficient aid to the diffusion of U.S. technologies to developed 

countries, working with the private sector and others. Developed countries represent the 

majority of the international market for environmental products and services and the homes 

of the major competition for U.S. environmental technology developers. By ignoring these 

markets, EPA fails to help U.S. companies make the diffusion connection with the largest 

international markets. The largest export opportunities for U.S. firms exist in these 

markets. The TIE Committee believes that it is in the U.S. interest to have strong domestic 

providers of environmentally beneficial products and services, and to involve and 

strengthen U.S. firms in these markets. 

The TIE Committee has found, however, that smaller and medium sized firms lack the 

resources to promote their environmental products and services internationally. Most 

environmental firms with over $100 - 150 million in annual sales appear to have sufficient 

resources. Firms with sales under $10 million appear to be unlikely to have a commercial 

technology. Their first priorities are usually commercialization and the pursuit of 

undeveloped domestic markets. Firms between $10 and $100 - 150 million in annual sales 

probably have environmental products or services of interest to international markets, but 

they lack the resources to reach those markets. Aiding them should be a particular focus of 

the activities recommended herein. 

Since EPA is the only federal government agency with the protection of the 

environment as its highest priority, it should act as a national leader to advance 

environmental aspects of the international agenda. Other federal agencies have competing 

goals, so if EPA does not take the leading role, no other agency will. The TIE Committee 

recognizes, however, that the several agencies -- the Departments of State and Commerce, 

along with AID, the U.S. Trade Representative, the Export-Import Bank, and the Overseas 

Private Investment Corporation -- all have leading roles in various aspects of international 

environmental activities. EPA will need to work closely with these organizations in the 

technology diffusion arena, on both imports and exports. 

89 
4.1 Help U.S. firms market environmental technologies in

developing countries. 

4.2 Help U.S. firms market environmental technologies in

developed countries. 

Note to the Reader: Subrecommendations 4.1 and 4.2 are very similar, and therefore 

share many of the actions recommended by the TIE Committee. In the interest of brevity 

the action items for these two subrecommendations are listed together. Their applicability 

to developing and developed countries where appropriate, and a concluding reference to the 

appropriate subrecommendation(s) is included with each action item. 

Commentary 

EPA's current international diffusion efforts in support of the export of environmental 

products and services are focused on the developing countries, and very little effort is being 

expended on the developed country markets. The TIE Committee is very supportive of 

EPA's new international activism with respect to technology diffusion (in the broadest 

sense) to developing communities (although large unmet needs associated with severe 

environmental problems in these communities will not be fully addressed by EPA's new 

international programs.) The TIE Committee believes, in addition, that the lack of 

significant effort in the developed countries constitutes a severe deficiency in EPA's 

international diffusion program (see Recommendation 4). 

As discussed in the Commentary for Recommendation 4, the TIE Committee 

commends EPA for its efforts in the international diffusion of environmental technologies. 

It believes that the international diffusion of environmental institutions and environmental 

technologies to developing countries carries with it the potential for large environmental 

gains. There is a large need associated with sometimes severe environmental problems for 

which a large number of potential applications of technological solutions exists. Other 

countries need help building institutional systems that are supportive of a sustainable 

economy, and possess strong environmental values that could create a lasting demand for 

environmental products and services. 

90 
The TIE Committee recommends that EPA, in conjunction with traditional lead 

agencies in some of these areas, take the following actions to help build environmental 

institutions abroad and to support U.S. firms in the marketing of their environmental 

technologies overseas: 

a. PROMOTE ENVIRONMENTAL CONCERNS INTERNATIONALLY: 

EPA should promote environmental concerns in other countries to help improve 

environmental quality worldwide and to "level the playing" field for U.S. industry. Both 

steps will help establish new markets and expand existing ones for U.S. environmental 

technologies because U.S. environmental requirements are stronger than those in most 

countries. Moreover, these requirements are associated with environmental technology 

leadership and industrial competitiveness. EPA has enormous technical knowledge on the 

fundamentals of running environmental protection programs (monitoring, permitting, risk 

assessment, source inventorying, etc.) which could strengthen programs in other countries 

and build the demand for clean technology. The U.S. Environmental Training Institute and 

the Asia Environmental Partnership are steps in the right direction. 

As noted above, EPA's promotion activities should be coordinated with all other 

federal agencies which have international operations. The expansion and elevation of 

environmental concerns has the potential to reduce pollution in a large number of areas of 

the world where environmental problems have a low priority. In several newly democratic 

countries of Eastern Europe and South America, laws have been passed expanding the 

public's right to know of environmental risks and decisions. Duly recognizing 

international differences in political philosophies and systems, EPA should stand ready to 

cooperate with other countries when asked, and provide technical assistance in the design 

of regulatory procedures. This would ensure public participation and rights to information. 

Although, this is a long range effort with an uncertain outcome, it represents the best 

chance for world environmental improvement. This action item particularly supports 

subrecommendation 4.1. 

b . ENCOURAGE INTERNATIONAL HARMONIZATION OF 

ENVIRONMENTAL STANDARDS: EPA could simultaneously promote 

environmental improvement and U.S. firms through the international harmonization of 

environmental standards. As noted in the Commentary, there is a strong relationship 

between stringent standards and environmental improvement, and between stringent 

91
standards and technology leadership, both with respect to productivity and environmental 

outcome. NACEPT's Trade and Environment Committee has developed recommendations 

on this subject. 

EPA recently established the U.S. Environmental Training Institute, which is training 

foreign technology experts in U.S. environmental management standards, practices, and 

technologies. EPA should take additional actions to encourage exports, such as by helping 

trade associations and others promote the use of U.S. measurement standards and 

technology protocols worldwide. Importantly, EPA's work to encourage exports should 

complement the work of the private sector; it is in the interest of U.S. firms to work 

together to establish a unified position on environmental technology specifications and to 

encourage the harmonization of environmental standards worldwide. These firms should 

lead the effort to have the U.S. standards formally adopted worldwide. For example, 

ICOLP (the Industry Cooperative for Ozone Layer Protection), a voluntary industry effort 

to diffuse technology on CFC (chlorofluorocarbon) substitutes, embodies an effective 

pioneering approach that has received EPA support and encouragement. EPA could 

beneficially expand its successful cooperation with ICOLP to allow it to expand its 

operations internationally. Action item "b" supports subrecommendations 4.1 and 4.2. 

c . HELP DEVELOP INFORMATION ON INTERNATIONAL 

MARKETS: EPA and other agencies should gather, disseminate, and deploy 

information on foreign environmental technology developments, markets, and barriers to 

competition. "Environmental Attaches," similar in function to Agricultural Attaches, are 

valuable. One of their roles should be to promote the use of U.S. environmental products 

and services abroad. With the help of other agencies and the private sector, assessments 

should be conducted to develop data on overseas needs and markets, as well as to evaluate 

areas where the U.S. is a global technology leader. Information should also be gathered 

and transmitted on the performance and cost of state-of-the-art environmentally beneficial 

technology. Information of value would be sent throughout EPA and other environmental 

agencies and made available to American firms. Increased information availability to U.S. 

firms will reduce the risks and/or costs associated with their own environmentally 

beneficial technology investment, thereby encouraging increased investment in this area. 

This action item supports subrecommendations 4.1.and 4.2. 

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d. PROVIDE SUPPORT FOR TRADE SHOWS SHOWCASING

DOMESTICALLY DEVELOPED ENVIRONMENTAL

TECHNOLOGIES: In the past few years EPA has begun to co-sponsor trade 

shows for U.S. environmental products and service firms. The TIE Committee commends 

this action, and believes it should be expanded to help U.S. firms compete internationally. 

EPA should expand relationships with other government agencies to help promote the sale 

of U.S. environmental technologies in foreign markets through conferences, trade shows, 

and other means. These shows should be held as closely as possible to the target market of 

the conference or trade show. The presence of EPA in all-industry trade shows and 

conferences will indirectly provide a boost for U.S.-made products and services because of 

EPA's international credibility. This activity is not to be confused with an endorsement for 

the use of any individual environmental technologies. This action item supports 

subrecommendations 4.1 and 4.2. 

e . PROVIDE SUPPORT FOR BUSINESS DEVELOPMENT CENTERS: 

As noted in the Commentary, small and medium-sized firms lack the resources to 

independently develop international markets for their environmental products or services. 

These firms are large enough to develop and commercialize innovative technologies. 

However, they lack the resources to market them overseas. One goal of these firms, for 

example, may be to test and demonstrate technologies overseas, in light of severe testing 

constraints in the U.S. EPA and other federal agencies can help address this problem by 

supporting the establishment of business development centers. 

These centers could provide three general types of assistance for firms that want to 

develop an international market for their environmental technologies: (1) technology 

brokerage, (2) project management, and (3) financial services. The technology broker 

function would include some or all of the following activities: (1) gathering and 

disseminating information on U.S. environmentally beneficial technologies developed by 

small and medium firms with promising overseas applications: (2) gathering and 

disseminating information on overseas market opportunities in the application of 

environmentally beneficial technologies, and (3) bringing together potential importers and 

U.S. technology exporters. The project management function could help lower the costs 

and risks to small and medium sized technology exporters and importers, by (1) providing 

information and assistance on meeting foreign regulatory, technology licensing and 

patenting, and investment requirements; (2) facilitating negotiations; (3) providing services 

93
in monitoring license agreements; and (4) assuming or reducing some of the risks of 

technology transfers through arranging or providing tests, demonstrations, insurance, and 

performance bonds. The financial services function could help assemble private and public 

capital for investment projects and joint ventures, including participation from such sources 

as OPIC and the EXIM Bank. This action item supports subrecommendation 4.2 and 4.1. 

f . ENCOURAGE PERSONAL INTERACTION WITH FOREIGN 

TECHNOLOGISTS: EPA should expand opportunities for direct contact 

between U.S. and foreign environmental stakeholders, including technologists, technology 

users, and government and business managers. EPA's establishment of a U.S. training 

institute for foreign environmental managers, technologists, and business operators will 

help create these opportunities. The institute could promote U.S. environmental 

perspectives and institutional systems (see action item a), help establish marketing contacts 

for U.S. environmental product and service vendors (see action item c), and encourage 

harmonization of environmental standards (see action item h). These contacts will increase 

the diffusion of technologies across international boundaries and make cooperative 

activities on an international level more likely. This action item supports 

subrecommendations 4.1 and 4.2. 

g . HELP U.S. SELLERS OF ENVIRONMENTAL TECHNOLOGY 

DEVELOP MARKET CONTACTS: EPA has a broad range of contacts that 

should be made available to U.S. environmental technology vendors. (Additional contact 

mechanisms are suggested in action items a, b, c, e, f, and g). There should be a central 

area established for these contacts, so that firms do not have to become engaged in long and 

costly searches for contact persons. The agency needs to create a foreign contact reporting 

system to gather contact data, coordinate it within the agency, and make it easily available 

to outsiders. This action item supports subrecommendations 4.1 and 4.2. 

h . OBTAIN ADDITIONAL EXPORT PROMOTION ASSISTANCE 

FROM OTHER FEDERAL OFFICES: EPA should also work with the 

Export-Import Bank and the Overseas Private Investment Corporation to provide 

additional financial support for U.S. environmental technology firms. These agencies 

provide loan guarantees, investment insurance, and pre-feasibility studies to U.S. firms to 

promote U.S. exports. The Export-Import Bank is currently limited to developing 

countries. However, its mission should be expanded to developed countries, where the 

largest environmental products and services markets currently exist. The Trade and 

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Development Program at the Department of State provides market studies and reverse trade 

missions. This program should be asked by EPA to focus on the markets for 

environmental technologies and services. The resulting studies should be shared 

throughout the domestic environmental industry. The diffusion coordinator (mentioned in 

Recommendation 1) should have responsibilities that include promoting U.S. 

Environmental exports. This action item supports subrecommendations 4.1 and 4.2. 

i. SUPPORT PROTECTION OF INTELLECTUAL RIGHTS TO 

TECHNOLOGY: With respect to a relatively small number of countries, one 

problem with U.S. technology exports is protecting them from intellectual theft and reexport by unscrupulous parties. While this is not the major problem in exporting to most 

developing nations and to nations complying with international agreements on this subject, 

it can be an impediment to exports to certain areas of the world. EPA should encourage 

other agencies (such as the U.S. Trade Representative and the Department of Commerce) to 

provide legal and structural support to discourage piracy of environmental technology 

overseas. One use of data gathered and made available on foreign environmental 

technology developments, markets, and barriers to competition is helping to protect U.S. 

technology firms from patent or license infringements. This action item supports 

subrecommendations 4.1 and 4.2. 

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4.3 Assist in gathering information on state-of-the-art 

environmentally beneficial technologies developed abroad. 

Commentary 

The U.S. has a tremendous need for new and innovative solutions to environmental 

problems. EPA has not emphasized in its programs the potential to find better 

environmental solutions overseas. The developed world, however, has been successful in 

developing innovative technologies to improve environmental quality and sustain industrial 

activities. EPA must now increase its efforts to help make technologies developed overseas 

available to domestic regulated organizations so that they can reduce their waste and 

emissions, and remain competitive. The task of forming business relationships to bring 

these environmentally beneficial technologies to the U.S. must remain in the private sector, 

but it is in the interest of both government and industry to identify and bring to the U.S. 

technologies that may convey environmental and productivity benefits. The TIE Committee 

therefore recommends that EPA: 

a.­ COOPERATE WITH OTHER AGENCIES IN GATHERING STATEOF-THE-ART INFORMATION ABOUT ENVIRONMENTALLY 

BENEFICIAL TECHNOLOGIES : As explained in the Commentary for 

Recommendation 4, other federal agencies have overseas activities that could gather data on 

EPA's behalf. Both the National Science Foundation and the Agency for International 

Development have established environmental technology institutes overseas that could help 

gather information. Since these institutes are funded by the United States, they could 

provide a ready conduit for information about environmentally beneficial technologies. 

EPA should expand its international technology information gathering activity to cooperate 

with federal agencies that possess the necessary resources for cooperation. 

b .INCLUDE CREDIBLE FOREIGN ENVIRONMENTALLY 

BENEFICIAL TECHNOLOGY INFORMATION IN U.S. 

INFORMATION SYSTEMS: The data gathered should be made widely 

available through the diffusion system described in Recommendation 2.3. The data should 

also be used to guide U.S. governmental R&D efforts and other policies. 

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Recommendation 5 

Increase support for the diffusion of technology provided by 

EPA's research programs on environmentally beneficial 

technologies. 

5.1Adopt a leadership position with respect to U.S. 

environmental technology R&D throughout the research 

and development life cycle. 

5.2

Build and expand efforts to coordinate environmental 

technology R&D among all participants (including 

industry, federal agencies, state and local governments, 

universities, and research consortia). 

5.3Use EPA's R&D program to improve the quality of data 

generated by others about environmentally beneficial 

technologies. 

5.4Emphasize the commercialization end point in EPA's 

and in EPA-led R&D on environmentally beneficial 

technologies. 

Commentary 

The TIE Committee has concluded that EPA's research program, centered in the Office 

of Research and Development (ORD), should become a primary focal point for increased 

support of the diffusion of technology by EPA. As the Committee previously noted, ORD 

should become "a more systematic provider of credible information about environmentally 

beneficial technologies." The Committee believes that if EPA intends to make the diffusion 

of technology a major element of the environmental management system, it will need to 

focus and sharpen ORD's activities throughout the technology life cycle. The terms 

"technology life cycle" and "R&D life cycle" includes R&D planning, the conduct of R&D 

(including research, development, demonstration, testing, and evaluation), and the 

dissemination of the results of these activities. 

There is no EPA office other than ORD that has a technology-neutral, multi-media 

perspective about environmental problems and their technological solutions. Thus, while 

the media-specific regulatory offices build a stimulus for experimentation, innovation, and 

pollution prevention into regulations, permitting programs, and compliance policies, the 

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Committee recommends that ORD become the operating spearhead of EPA's diffusion 

activities, working closely with the high-level diffusion advocate/coordinator (discussed in 

subrecommendation 1.1). 

EPA, whose environmental technology R&D spending comprises a very small 

percentage of the national total, cannot play a leading role as a direct sponsor of 

environmental technology R&D. EPA's environmental technology R&D spending ranks 

at most as the fourth largest among the federal agencies. The Departments of Defense and 

Energy (DOD and DOE) and the National Aeronautics and Space Administration (NASA) 

each has a much larger program in this area than EPA. All told, federal environmental 

technology R&D spending is less than one-fourth of the national total. If spending on the 

development and demonstration of technologies that prevent pollution are included, the 

federal percentage declines even further. 

This leads the TIE Committee to conclude that EPA must concentrate on two important 

areas of emphasis in its R&D programs on environmentally beneficial technologies: 

•­ Maximizing the impact of ORD's technology research, in large part by

leveraging and influencing the much larger R&D spending of others

inside and outside of government through an increased coordination

role.

•­ Sharpening and emphasizing ORD's role in the technology diffusion

partnership.

There are very specific steps that EPA and ORD can take to realize the first emphasis. They 

include modifying the research planning process to incorporate more input from 

knowledgeable and affected groups outside EPA, leveraging its research spending by 

increasing cooperation with non-EPA researchers, improving the quality of information 

about environmentally beneficial technologies generated by others, and emphasizing the 

commercialization end point in ORD's environmental technology research program. 

Similarly, there are specific steps EPA and ORD can take to realize the second emphasis, 

that ORD become a more systematic provider of credible information on environmentally 

beneficial technologies. Unless the agency takes these or equivalent steps, the Committee 

believes that EPA will remain a minor "player" in the environmental technology field and 

will lose a major opportunity to increase its effectiveness as the leader of the environmental 

management system. 

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The Committee notes that EPA's lack of understanding about the marketplace and of 

industry needs and perspectives is particularly acute in the research program (although it is 

also apparent in other programs). This shortcoming, among other factors, dulls ORD's 

ability to anticipate market needs and trends, and has hampered that office's ability to 

maximize the value of its environmental technology research programs. Customer-oriented 

organizations work with consumers to understand their needs and with suppliers to 

understand their capabilities. In R&D, projects that contain some degree of "market pull" 

are more readily successful than those that are driven by "technology push." The planning 

of these programs must take into account such factors as changing socioeconomic trends -­

including shifts in industrial patterns, technologies, consumption, and products -- to 

anticipate future environmental opportunities and problems. EPA's R&D on 

environmentally beneficial technologies of all types must be anticipatory, precisely targeted, 

and leveraged. Its R&D will have to be carefully designed to fill critical technology niches, 

have a high rate of commercial success in development efforts, and become a primary force 

in EPA's diffusion programs as a collector, developer, and provider of credible 

performance information. 

The Committee is optimistic that, after getting a slow start, EPA is accelerating its 

program to establish CRDAs (cooperative R&D agreements with non-governmental 

organizations) and licensing agreements. These agreements lead to the commercialization 

of proprietary products emerging from EPA's environmental technology R&D. 

The Committee is favorably impressed with the breadth of EPA's environmental 

technology research program, with the energy and talent of its researchers, and with the 

value, and in some cases, the uniqueness of its facilities and expertise. The Committee 

believes that ORD should continue its R&D program in pollution prevention (see 

Recommendation 3) and in other areas (without commenting on any individual research 

projects or the overall strategic approach of the individual programs, which it did not 

review). It is important, however, that when EPA becomes a developer or co-developer of 

innovative environmental solutions, it emphasize the commercialization end point (see 

subrecommendation 5.4). Subrecommendations 1.3 and 5.4 describe the value to EPA of 

building expertise in marketing, economics, and commercialization, and of increasing the 

overall technical competence of its staff through a variety of means, including rotational 

assignments in the public and private sectors. 

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The Committee wishes to reemphasize, however, that EPA should not intend to 

become a major developer of environmental technologies. Further, the agency has no 

significant independent role to play in developing industrial technology improvements that 

are useful to preventing pollution. EPA's primary role will be to foster and to influence the 

technology development and commercialization efforts of others, and to increase the rate at 

which better technological solutions gain wide use for environmental improvement. 

Assuming this role requires ORD leadership. This is the case regardless of ownership or 

whether technologies prevent, control, remediate, measure, analyze, or process 

information. 

Recommendation 5 focuses on actions that ORD can take throughout the technology 

life cycle so it can carry out an expanded diffusion role: (1) adopting a leadership position 

in planning and conducting R&D on environmentally beneficial technologies and in 

reporting credible results, (2) building and expanding efforts to coordinate R&D on 

environmentally beneficial technologies with all participants, (3) enhancing the quality of 

technology performance data generated by others, and (4) emphasizing the 

commercialization end point in EPA's and in EPA-led R&D on environmentally beneficial 

technologies. The recommendation thus describes how EPA can play a more effective role 

in the diffusion of credible information about environmentally beneficial technologies from 

all sources. 

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5.1

Adopt a leadership position with respect to U.S. 

environmental technology R&D throughout the research

and development life cycle. 

5.2Build and expand efforts to coordinate environmental 

technology R&D among all participants (including 

industry, other federal agencies, state and local 

governments, universities, and research consortia). 

Note to the Reader: Subrecommendations 5.1 and 5.2 are closely related, and 

therefore share many of the actions recommended by the TIE Committee. In the interest of 

brevity, actions recommended by the Committee for these two subrecommendations are 

listed together. These two subrecommendations are closely linked in that they outline 

actions the Committee believes would optimize EPA's leadership and coordination role 

throughout the R&D life cycle process so that the agency is better positioned to emphasize 

its diffusion role. Proposed actions cover all integral components of the R&D life cycle -­

the areas of planning, conducting, and coordinating research in the public and private 

sectors, and disseminating technology information. 

Commentary 

If EPA is to emphasize technology diffusion in its environmental management 

strategy, the TIE Committee believes that it is necessary for the agency to adopt a 

leadership and coordinating role in R&D on environmentally beneficial technologies. As 

noted above, EPA is a small-scale player in the world of environmental technology R&D, 

even within the federal government. There is no federal or national environmental 

technology leader throughout the R&D life cycle -- in planning and conducting R&D, and 

in the reporting of results. This anarchic condition operates to the clear detriment of the 

overall federal effort. It also represents a major missed opportunity for federal leadership 

in fostering environmental and economic gains from improved technology. Ultimately, 

EPA's influence in environmental technology R&D must transcend the immediate power of 

its resources. 

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The Committee did not seek out examples of duplicative or other wasteful practices 

that could result from this lack of coordination, and is confident that EPA managers attempt 

to avoid them. It did hear, however, of results of federal R&D on environmentally 

beneficial technologies that had limited value because protocols, data quality requirements, 

and reporting were too different. The Committee also heard examples in which a lack of 

EPA leadership contributed to a lengthened, more costly technology development processes 

in both the public and private sectors -- even cases of total failure. While recognizing that 

Cabinet status would perhaps convey more "clout" to EPA, the Committee notes that EPA 

has not visibly attempted to take on a leadership role throughout the R&D life cycle for 

environmentally beneficial technology, to the detriment of the overall federal program. 

The TIE Committee is concerned that environmental technology R&D programs at 

EPA, DOD, DOE, and NASA are not coordinated at the planning stage, and that 

coordination during research and the reporting of results is sporadic. A critical need exists 

for EPA's ORD to spearhead an effort within the federal government to coordinate the 

planning and conduct of environmental technology R&D and the diffusion of R&D results. 

To accomplish this, EPA must make the most efficient application of its own scant 

resources toward realizing its most important priorities. EPA's must extend its influence 

beyond its limited resources with respect to both public and private sector R&D on 

environmentally beneficial technology. EPA should begin to prepare ORD for its 

leadership role by redirecting agency resources toward broadening the scope of ORD's 

planning process. 

ORD's planning is focused around the "research committee" process, in which EPA's 

media regulatory programs and, to a lesser extent, regional offices help ORD plan future 

research agendas. In addition, for many years the external reviews of the Science Advisory 

Board have been invaluable in commenting on ORD research strategies from the 

perspective of scientific excellence. The limits of this planning process give rise to the TIE 

Committee's concern that ORD's planning has focused on providing support to regulatory 

offices, without also fostering a technology partnership on behalf of the environment 

among EPA, the providers and users of environmentally beneficial technologies, and the 

regulators who oversee the application of these technologies for environmental 

improvement. Even in working with in-house clients, it is difficult for ORD to draw 

general and multi-media lessons from the separate planning inputs received from each 

media regulatory office. Except in a few programs, such as the remediation technologies 

research program, there remains a great need for ORD to put in place feedback loops with 

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non-EPA sources. Feedback loops should be constructed with consulting engineers, trade 

associations, state and local environmental authorities, and others who are knowledgeable 

about the technology needs of polluters, today and in the future, and the productivity and 

environmental R&D developments of external research programs. 

The best opportunity for EPA to establish a leadership and coordination role in the 

performance of environmental technology R&D is through pursuit of a strategy of 

partnership and leveraging involving all participants. The Committee will recommend that 

EPA apply a variety of approaches to accomplish this objective, including: the institution 

of a co-funding requirement for a portion of its technology research, broadening avenues of 

cooperative research, expanding its use of the Federal Technology Transfer Act (FTTA), 

and aiding others' R&D through the establishment of a formal industrial user facility 

program. Through such mechanisms as increasing co-planning of research with other 

sponsors of environmentally beneficial technology and expanding its support for research 

consortia (sponsored by universities, other federal and state agencies, and trade groups or 

others), EPA can establish a leadership role and gain a significant leveraging effect on its 

own resources. 

The Committee believes that a major purpose of the new approaches discussed above 

is to enable ORD to become a more systematic provider of credible information about 

environmentally beneficial technologies. ORD's leadership and coordination roles in 

planning and conducting R&D will create opportunities to collect and compile credible 

performance information -- most of it generated outside of EPA's R&D program -- and to 

work with EPA's diffusion partners to facilitate its dissemination. The Committee believes 

that ORD's current technology transfer efforts require significant reorientation and 

redeployment to achieve this goal. 

The Committee suggests that ORD's new effort to engage in cooperative research 

through joint planning, leveraging, cooperating, testing, and evaluating will directly 

encourage others to generate credible information about environmentally beneficial 

technologies. The Committee also believes that ORD's activities to help others improve the 

credibility of data they generate are important to the effort to sort "good" from "bad" 

information; the standardization of protocols, QA/QC, analysis procedures, analytic 

procedures, and reporting requirements will ease the effort to distinguish what information 

is credible. Additionally, the Committee notes that by increasing its understanding about 

the marketplace, EPA can learn to focus its data sorting efforts, attending earliest to areas of 

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greatest need, controversy, or opportunity. EPA's greater anticipatory ability will also be 

very useful here. 

In summary, the specific action items recommended below propose how EPA's 

environmental technology research program should change to (1) maximize its impact on 

the much larger spending of others and thereby become a more effective partner with the 

broader research community in the public, private, and non-profit sectors and (2) address 

how EPA's research program can sharpen its effectiveness in the technology diffusion 

partnership, becoming the operating spearhead of EPA's diffusion activities: 

a . INVOLVE INDUSTRY IN THE PLANNING OF EPA'S 

TECHNOLOGY RESEARCH: EPA should create direct mechanisms for 

meaningful exchange with industry in the planning process for its R&D on environmentally 

beneficial technologies. Both users and providers of environmentally beneficial 

technologies should be involved. In the case of users, EPA should establish contact to 

ascertain what problems they feel most need better technology solutions. In the case of 

providers, EPA should develop close R&D relations so that reported research results are 

compatible and, when possible, complementary. Subrecommendation 5.3 discusses the 

need for EPA to work with others who conduct research to improve the quality of the data 

about environmentally beneficial technology they generate. This subrecommendation, on 

involving others in EPA's R&D planning, discusses how EPA can better target its R&D, 

build relationships with other research organizations, and establish a better basis for a 

strong EPA role in diffusion activities. 

By working more closely with industry and other major technology developers, ORD 

could also better anticipate future technology and societal trends that affect the environment, 

along with the industrial and environmental technology fields. The ability to provide a 

warning about emerging environmental threats associated with socioeconomic and 

technology trends is essential to managing EPA's technology R&D programs. A closer 

working relationship with the private sector and others during R&D planning will help in 

this regard by influencing the research of others and by guiding the direction of EPA's own 

research. 

Involving industry in EPA research planning can be accomplished in a variety of 

ways, which include establishing joint R&D advisory committees with industry and trade 

associations, holding R&D planning workshops, directly consulting industry experts, and 

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establishing more CRDAs. Research planning relationships with university-based and 

other consortia (e.g., the National Center for Manufacturing Sciences) constitute another 

important vehicle. Technology user and provider input should be sought for both longterm planning and current year planning. For example, the National Institute of Standards 

and Technology (NIST) uses an "Assessment Board" of outside advisors (academia, 

industry and researchers) that meets at least annually to review the programs at each NIST 

Center. 

EPA should also expand and upgrade its Resident Research Associateship Program, 

making it more attractive to senior-level private sector scientists, who can then provide 

insight valuable for EPA's R&D planning and create other opportunities for the exchange 

of professionals, as discussed in subrecommendation 1.4. 

b . INCLUDE CONSORTIA AND OTHERS IN EPA RESEARCH 

PLANNING: In the past several years, EPA and other federal and state agencies 

have helped establish research and commercialization consortia, often university-based. 

Examples of these include the Hazardous Waste Institute at the New Jersey Institute of 

Technology, and the National Defense Environmental Corporation at Johnstown, 

Pennsylvania. Although they differ in mode of operation, membership and contributors, 

and area of technology focus, in general they combine governmental, university, and 

industrial and other polluters as co-sponsors. Dedicated to finding technical solutions to 

mutually identified environmental problems, they are natural and neutral places where all 

parties can come together to identify R&D needs, co-sponsor R&D, and share results by 

some formula. These centers arc potentially extremely valuable to EPA R&D planning, and 

EPA should devise a systematic approach to working with them in the planning process. 

c . INCREASE THE ROLE OF STATE AND LOCAL GOVERNMENTS 

IN EPA RESEARCH PLANNING: EPA should work more closely with 

state and local agencies in its R&D planning. These agencies today play a leading role in 

the environmental regulatory system in that the administration of about eighty percent of the 

regulatory programs are delegated to the states. Accordingly, states write most permits and 

initiate most compliance actions. Thus, it is the states that have a "hands on" relationship 

with most regulated parties. 

The state and local regulatory role establishes a unique level and character of 

communication with polluters sited in their areas. As discussed in Recommendation 2, 

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state and local agencies are most aware of the pollution problems and technology needs of 

local polluters. They are concerned that cost-effective solutions be found to help the local 

environment improve and the local economy to thrive. It is therefore in the mutual interest 

of EPA and state and local agencies to make use of these regulatory networks to identify 

R&D needs (and to work through them to disseminate needed information on 

pollution preventing and other environmental technologies). 

EPA should take maximum advantage of the STAPPA/ALAPCO network, its own 

networks, and other information distribution channels to determine needs and supply the 

needed information. This new intergovernmental coordination of R&D planning will help 

EPA play the leadership role it should in environmental technology R&D and lead to 

increased technology diffusion involving the wide variety of stakeholders. 

d . REQUIRE DIFFUSION PLANS IN EPA ENVIRONMENTAL 

TECHNOLOGY R&D PLANS: EPA environmental technology R&D plans 

should explicitly describe what the expected commercialization end point is for each 

research project, and how the end point will be reached. In addition, EPA's research 

project plans should be required to state the market objective, the clients (or anticipated 

users), what the clients' intended uses are, and most importantly, EPA's approach to 

diffusing the information to clients, and in what form, so it is most useful and accessible. 

In order for EPA planners to accomplish this, EPA should either develop in-house, or 

obtain contracted, expertise to understand clients' orientations and needs. This new 

emphasis on commercialization will increase the value of agency R&D results by focusing 

R&D resources on market needs and requirements (see subrecommendation 5.4). 

e . TAKE A LEADERSHIP POSITION TO INCREASE INTERAGENCY 

COOPERATION IN ENVIRONMENTAL TECHNOLOGY R&D: As 

discussed in the Commentary, EPA is a small-scale player in the world of environmental 

technology R&D, even within the federal government. Far larger programs exist at DOD 

and DOE and at NASA. As noted in the Commentary, there is no federal, or national, 

environmental technology R&D leader -- in planning, conducting, or reporting results from 

environmental technology R&D. This anarchic condition operates to the clear detriment of 

the overall federal effort. 

The TIE Committee is concerned that the various federal programs are coordinated 

only to a limited extent at the planning stage, and that coordination during research and the 

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reporting of results is sporadic, at best. The Committee believes that EPA will become 

more effective in its diffusion focus if ORD undertakes to facilitate cooperation among 

federal agencies' R&D programs on environmental technologies. 

The Committee recommends that EPA (ORD) take the leadership position in 

coordinating federal environmental technology research throughout the R&D life cycle. 

EPA should spearhead the formation of an "R&D cooperation council" for environmentally 

beneficial technology that would be made up of representatives of all sponsoring agencies. 

This council should have as its purpose the steady increase of federal-wide coordination 

and cooperation throughout the R&D life cycle. 

f .­ REQUIRE PRIVATE SECTOR CO-FUNDING FOR PART OF 

EPA'S TECHNOLOGY R&D: The TIE Committee recommends that, to 

ensure that its efforts to develop environmental solutions be focused on specific market 

needs, a portion of ORD's research on environmentally beneficial technology be subject to 

a requirement for co-funding by the private sector. While it does not suggest a specific 

percentage of this research for a mandatory co-funding requirement, the Committee 

suggests that the percentage be significant and that it be reviewed and revised, depending 

on the success of this strategy. The increased resources recommended for EPA's pollution 

prevention technology R&D program (see subrecommendation 3.4) are a prime candidate 

for the co-funding requirement because the need for partnering is so great in carrying out 

this program successfully. 

Mandatory leveraging requirements between government and industry for 

development, testing, and demonstration should help increase the currently low level of 

investment in environmental technology because risks will be spread. This requirement 

will also support the idea that EPA's selection of R&D projects should be market-focused 

and needs-based. It should be noted that it is important to recognize in any management 

design that mandates leveraging to distinguish between the risk levels associated with stage 

of development (i.e., to recognize that early stage technologies are the most risky). 

g . EXPANDSUPPORT FOR THE ENVIRONMENTALLY

BENEFICIAL TECHNOLOGY R&D OF OTHER FEDERAL

AGENCIES: As discussed previously in this report, EPA's resources for R&D 

on all environmentally beneficial technologies stand in a poor fourth place, at best, among 

the federal agencies. EPA should therefore become directly involved in other agencies' 

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environmentally beneficial technology R&D throughout the R&D life cycle, even to the 

point of co-funding research with them. 

It is important here to draw attention to the large government programs that support the 

development of advances in a variety of technologies that have potentially large positive or 

negative environmental implications. DOE, for example, in addition to having a larger 

program than EPA's for R&D on environmental control and remediation technologies, has 

large R&D programs to advance a number of environmentally significant technologies, 

including clean coal combustion, fuel cells, solar energy, wind energy, electric cars, 

industrial energy conservation, solar energy, and energy efficient buildings. It is very 

important for EPA to become involved in and supportive of these R&D programs, both to 

ensure that environmental problems and opportunities are considered and to promote the 

use of environmentally beneficial technologies that emerge. The "Green Lights" program, 

which promotes the use of energy efficient lighting in industrial and commercial buildings, 

is an example of the environmentally positive diffusion that can result from successful 

energy technology research. The Committee believes that EPA will be better able to 

develop programs that are analogous to the Green Lights program if it becomes more 

involved with these R&D programs. Such involvement will also be important to the 

success of EPA's expanded R&D program on pollution prevention technologies and 

techniques (see subrecommendation 3.4). 

h .

EXPAND EPA'S PROGRAM WITH THE DEPARTMENTS OF 

DEFENSE AND ENERGY FOR THE TESTING OF 

ENVIRONMENTALLY BENEFICIAL TECHNOLOGIES AT 

FEDERAL FACILITIES: The TIE Committee commends EPA for 

establishing an important new program with the Departments of Defense (DOD) and 

Energy (DOE) to facilitate the testing of environmentally beneficial technologies at federal 

facilities. Private parties, as well as government researchers, are allowed to conduct 

cooperative technology trials at some federal sites in this new program. Rigorous, but 

expedited, regulatory oversight is provided, and cost sharing is encouraged. Using federal 

sites accelerates the testing of innovative technologies because EPA and states work closely 

with DOD and DOE to assure compliance with environmental requirements, while 

encouraging the testing and evaluation of better environmental solutions. Some potential 

sites have facilities or other conditions that would enhance the safety of testing and 

evaluation with respect to environmental and public health protection. 

108 
The first federal facility has been designated a "testing center" under this program 

(McClellan Air Force Base in California). EPA hopes to establish others. At a recent 

meeting, EPA invited major private parties to participate in the program, and several tests 

and evaluations are already being conducted or negotiated. 

This program is a model for several of the recommendations being made in this report. 

EPA will be working jointly with other federal agencies and the private sector on joint R&D 

on environmentally beneficial technologies. Leveraging of EPA's resources will be 

obtained. Results of tests and evaluations will be shared to the greatest extent possible 

while protecting confidentiality, and credible performance data will be made available 

through the widest possible set of information management systems. 

i . CONTINUE AND EXPAND COOPERATIVE ENVIRONMENTAL 

TECHNOLOGY R&D EFFORTS: Over the past five years, EPA and other 

federal agencies have used a new mechanism to bring government, academia, and industry 

together to work on environmental problems in a neutral setting. Among the most 

successful of these are research consortia, or institutes, that may involve federal or state 

sponsorship, university or other neutral institutional bases, and participation by public and 

private sector organizations, including technology developers and industrial polluters. 

These institutes have great value as a venue for the cooperative support of research on 

environmentally beneficial technologies. 

The TIE Committee supports this approach, and encourages EPA to exploit this 

mechanism further. Recently, for example, the agency signed a memorandum of 

understanding (MOU) with the National Center for Manufacturing Sciences (NCMS), a 

consortium of industrial and government organizations (with Department of Defense 

support) that is involved in improving U.S. manufacturing technology. This MOU is 

designed to enable EPA to become involved with the NCMS partners in their R&D on 

environmentally beneficial technology advances, including pollution controls and 

manufacturing advances that prevent or reduce the formation of pollution. Because one 

criterion for NCMS resource support for any project is the partnership and co-support of at 

least two companies on a common problem, EPA will be assured of joint planning with 

industry and another federal agency, a commercial end point for the R&D, significant 

leveraging of any EPA resources supporting the project, and diffusion of the results, 

subject to the protection of the proprietary interests of the developers. 

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j . INSTITUTE AN INDUSTRIAL USER FACILITY PROGRAM: EPA 

should also institute an industrial user facility program. Under this program, EPA would 

invite industrial and other outside organizations to use the agency's unique and specialized 

facilities (e.g., containment facilities) for testing, evaluation, and/or demonstration. Such a 

program would provide an excellent opportunity for government/industry and 

government/university cooperation. This concept creates a routine and systematic process 

to allow outside organizations to make use (whether fees are charged or not) of EPA's 

unique and specialized facilities that they otherwise would have to duplicate at potentially 

great expense and delay. EPA would have to impose reasonable constraints (e.g., time of 

use, suitability of activity) on the use of its facilities so that government use will be 

unhindered. If fees are charged, EPA could at least cover the costs of external use, if not 

gain a small source of revenue. 

Opening up agency testing facilities is more than a new source of funds to the agency. 

It also represents a significant opportunity for the agency to clearly demonstrate its support 

for private sector technology investment and innovation. The ability to share facilities, and 

thereby costs, with the private sector is an additional efficiency benefit derived from this 

recommendation. 

This program could be similar to the extensive and successful user facility program 

described to the Diffusion Focus Group by representatives of the Department of Energy's 

Oak Ridge National Laboratory (ORNL). Many companies have located their facilities 

nearby ORNL to take advantage of the user facility program, which has resulted in 

extensive government-industry, person-to-person technical exchange. 

To turn the concept of an industrial user facility program into a reality, EPA will need 

to develop guidance about at least the following: criteria for selecting facilities to be 

included in the program, the types of use that are contemplated; the legal mechanisms (e.g., 

contract, CRDAs) for use agreements with EPA; the required relationship of outside uses, 

if any, to EPA's mission; the basis for determining fees; and the basis, if any, for abating 

fees. Further, the lessons learned from other agencies' programs should be examined and 

a program should be developed to make potential users aware of the availability and 

capability of EPA's facilities. 

110
EPA should establish a joint EPA/industry team to identify facilities that should be 

considered for inclusion in the program. Among the possible ORD facilities that could be 

included in this program are the Edison underground storage tank leak detection test 

apparatus, the air testing chamber in Research Triangle Park, the test and evaluation facility 

at the City of Cincinnati's sewage treatment works, the Center Hill stabilization research 

facility in Cincinnati, and the incineration research facility near Pine Bluff. EPA should 

also determine the availability and procedures for using other federal agencies' facilities for 

industrial environmental R&D. 

k . ESTABLISH PROCEDURESFOR THE USE OF EPA 

LABORATORIES FOR THE TESTING AND EVALUATION OF 

TECHNOLOGIES DEVELOPED OUTSIDE EPA: There is a great 

demand for EPA to provide a testing and evaluation function for environmentally beneficial 

technologies, but not necessarily a technology or approval function. EPA is currently 

performing both a testing and evaluation role and a certification function (in the test and 

measurements areas), but is not certifying technologies. The TIE Committee recommends 

that EPA should establish procedures defining how private parties can obtain testing and 

evaluation services at ORD's and other EPA laboratories. 

The TIE Committee found that there is a strong demand for credible data about the 

performance of environmentally beneficial technologies and that this demand is not being 

satisfied. Indeed as discussed earlier, the Committee believes that the deficiency in the 

availability of credible performance data is a serious problem and that an important role of 

ORD's research programs is to help satisfy this need, directly and indirectly. 

Both providers and users of diffusion services are attracted to ORD's objectivity about 

technology performance and to its capability to develop its own and to guide the 

development of others' credible performance data. These people want EPA to publish (and 

make otherwise available) performance results of technologies under a variety of operating 

conditions, without giving them a "stamp of approval." This increased availability of 

credible data would facilitate decision making about use. An expanded testing and 

evaluation function would benefit U.S. industry and other polluters both domestically and 

internationally by clarifying and verifying performance claims. , 

111
1.

CONTINUE AND EXPAND ON CURRENT IMPROVEMENTS IN 

EPA'S IMPLEMENTATION OF THE FEDERAL TECHNOLOGY 

TRANSFER ACT OF 1986 (FTTA): The TIE Committee has found that 

time is a critical element in the development of Cooperative Research and Development 

Agreements (CRDAs) and licensing agreements. In the environmental field many, though 

not all, innovations experience a rapid loss of value because they have a short product life 

cycle. 

In light of this conclusion, the TIE Committee is optimistic that, after a slow start, 

EPA's FTTA performance has improved over the past year. The agency is to be 

commended for this turnaround. It should take immediate steps, however, to further 

streamline and expand the use of the CRDA and licensing negotiation processes. EPA 

should look for efficiency-enhancing measures, and implement them. For example, the 

Committee found that the disbursement of "reward" dollars to the originators of EPAlicensed technologies has been very slow, sometimes taking up to one year or even more. 

These disbursements appear to be low in priority, and are not made in a timely manner. 

Correcting this practice would create a positive incentive for EPA researchers to participate 

in the FTTA program and, more importantly to EPA's mission, to concern themselves with 

commercially and therefore environmentally beneficial innovation. 

EPA should also launch outreach programs which invite industry to establish CRDAs 

and licensing agreements. Many institutions (such as universities) offer to license 

technologies and establish joint projects. EPA should view its licensing and CRDA efforts 

as a marketing opportunity with other technology providers. The Committee expects the 

agency's expansion of current FTTA activities to yield increased CRDAs and additional 

R&D funding from the private sector. 

1(1) . CONTINUE AND EXPAND CRDA TRAINING AND 

PROMOTION ACTIVITIES: EPA should continue to develop and launch 

its comprehensive, agency-wide, ongoing internal training on the processes and benefits of 

FTTA CRDAs and licensing. To create a positive motivation for the researchers, 

laboratories, and the agency to use the FTTA, an understanding of the benefits is 

particularly important, along with an understanding of how to prevent conflicts of interest 

and other abuses. EPA has engaged a contractor to develop internal training materials for 

ORD laboratory personnel on the benefits and mechanisms for CRDAs and licensing 

agreements. Training should occur at all EPA laboratories (not only at ORD's), with 

112
particular emphasis on laboratories involved with technology research. Training should 

include success stories and other motivational elements, as well as detailed descriptions on 

how EPA personnel can participate in FTTA. There should be an effort to compare the 

EPA's FTTA activities to those of other federal agencies. 

Similarly, EPA should launch a campaign to make U.S. firms aware of the 

possibilities for beneficial cooperation with EPA through CRDAs and licensing 

agreements. This campaign could take the form of successful efforts made by universities 

and other federal agencies to attract cooperation with industry. For example, the U.S. 

Army reports that its FTTA representatives advertise in industry publications, undertake 

direct mailing campaigns, and participate in conferences and trade fairs. 

1(2) . MAKE THE CRDA APPROVAL PROCESS FAST: EPA has made 

numerous strides to improve the speed of CRDA and license negotiation and approval. For 

example, a standardized CRDA format which should speed negotiation and approval times 

was recently introduced. As reported by USDA representatives, the closer the final 

agreement is to the standard document, the quicker the approval process will be. As 

discussed above in 5.2 "1" above, however, time is very important to EPA's 

commercialization partners; it is therefore essential that EPA continue efforts to expedite the 

process as much 

as possible. 

The Committee believes that EPA should continue gathering performance data, 

including numbers of CRDAs signed, licenses issued, fees paid to the agency, numbers of 

training sessions held, and length of time from first contact to final agreement. Analysis of 

this data will point out areas for streamlining and improvement. Another valuable step 

would be to "benchmark" with other agencies' active FTTA programs. 

To further speed the CRDA review process, EPA should delegate approval authorities 

to one office, consistent with the need to prevent conflicts of interest and other abuses. For 

example, the Grants Administration Division could delegate its authority to the Office of 

General Counsel, which could then make all rulings, except in extraordinary cases. EPA 

should also increase the Office of General Counsel staff available for CRDA review. 

113
1(3) . EXPAND THE CAPACITY OF THE CRDA APPROVAL 

SYSTEM: The agency expects the expansion of current FTTA activities to 

yield increased CRDAs and additional R&D funding from the private sector. If this 

happens, EPA's current organization of having one Office of Research and Technology 

Applications (ORTA) for the entire agency could become a bottleneck. EPA should 

consider establishing ORTAs in major laboratory complexes like Research Triangle Park 

and Cincinnati. The creation of additional ORTAs will create the capacity needed for this 

expected increased level of FTTA effort. 

m.­ STRENGTHEN EFFORTS BY ORD TO COLLECT AND REPORT 

CREDIBLE INFORMATION ABOUT ENVIRONMENTALLY 

BENEFICIAL TECHNOLOGIES: Previous sections of Recommendation 5 

and subrecommendation 2.2 have discussed that wide range of potential EPA R&D 

partners on environmental technologies. The interests of nearly all of these groups make 

them willing to engage now with EPA -- whether in co-planning; in cooperatively 

conducting R&D, testing, and evaluation; or in collecting and reporting credible 

performance data. Moreover, the motivational structures of the remaining groups make 

them potential diffusion partners. EPA's Technology Innovation Office in OSWER has 

recognized this potential and designed programs to take advantage of their mutual interests 

with EPA. In particular, TIO's diffusion programs target a partnership with the consulting 

engineers who advise responsible parties on cleanup technology options. 

The Committee noted that EPA's efforts to collect and report this information are not 

well coordinated. This is the case across the agency, throughout the major offices 

(although with a few notable exceptions, as noted above). It is also the case within ORD, 

which has a number of disparate data bases, many of which do not have a cross-media 

perspective. Some data bases contain information that is reported as anecdotal but which 

actually has broader applicability. Moreover, ORD's data reporting is usually not 

coordinated with efforts outside EPA, such as those of DOE, DOD, professional 

associations, state and local networks, consulting engineers, and consortia. The 

Committee recommends that ORD assign responsibility to a small group to sort out its data 

collection and reporting programs, discover what is working well and what could use the 

most improvement, and take action to improve ORD's efforts. 

114
n . INCREASE

ORD'S EFFORTS, ,WORKING WITH EPA'S 

DIFFUSION PARTNERS, TO DISSEMINATE INFORMATION 

ABOUT ENVIRONMENTALLY BENEFICIAL TECHNOLOGIES: 

As discussed in subrecommendations 2.3 and 5.3, a major role for EPA is to work with its 

partners to improve the quality of data included in diffusion mechanisms (or vehicles) and 

the effectiveness of the vehicles for diffusion themselves. Further, EPA should promote 

the use of the full range of available technology diffusion mechanisms, including its own 

and those of other diffusion partners. The wide variety of available technology diffusion 

mechanisms is listed in subrecommendation 2.3. As the operating spearhead of EPA's 

technology diffusion programs and the technology neutral, multi-media oriented part of 

EPA, ORD has a special and key role to play with the diffusion partners inside and outside 

of EPA to strengthen and broaden U.S. information dissemination patterns. 

The Committee believes that ORD's diffusion efforts need to be reviewed and revised 

to increase their value and impact. Its diffusion program incorporates publications, 

information systems, and training. These activities are high quality in every respect. Some 

of them, however, reach only a small percentage of the intended audiences for a variety of 

reasons. To remedy this, the Committee suggests that ORD needs to become less insular 

and to develop its partnership capacity. ORD will then be able to expand the impact of its 

programs through the leverage of the efforts of the many other groups that have a diffusion 

interest. This implies a planning, as well as a performance, involvement with the diffusion 

partners, and a more multi-media approach in its diffusion programs. ORD should also 

work with its partners to broaden its use of less-emphasized diffusion methods and to 

broaden the informational content of its diffusion data bases (discussed in 

subrecommendation 5.3 above). As discussed in subrecommendation 3.1, ORD's 

diffusion programs also need to support the pollution prevention programs of the agency. 

Support by EPA for technology diffusion must be extended to other agencies and 

areas beyond EPA. By encouraging the diffusion of technology across current barriers and 

into these areas, EPA stands to receive the benefit of the technical resources of all of these 

players. Very importantly, it is only by taking this approach that EPA can demonstrate its 

leadership and make diffusion a major part of the environmental management system. As 

noted throughout this report, the benefits of such information sharing are potentially very 

large for environmental improvement. 

115
5.3

Use EPA's R&D program to improve the quality of data 

generated by others about environmentally beneficial 

technologies. 

Commentary 

As discussed earlier, because EPA's environmental technology R&D program is so 

small relative to the total U.S. effort, the agency should adopt a strategy of leveraging its 

efforts whenever possible. The practice of leveraging is crucial to producing useful 

performance, cost, and reliability data. Its importance cannot be overstated; every 

stakeholder group presented itself to the Committee as being limited by the lack of credible 

information about innovative and pollution preventing solutions. In any technology field 

related to the environment -- environmental restoration, environmental compliance, 

hazardous assessment, pollution prevention, etc. -- the usefulness of a technology or 

technique for a compliance purpose (to potential users, regulatory overseers, and other 

stakeholders) requires that acceptable data exist describing performance that meets 

regulatory standards. 

Research results that are not generally accepted as credible have little potential to have 

an impact, to be transferable, to satisfy the needs of potential users, and to thereby meet the 

needs of those who produce them. The Committee heard a number of cases in which data 

provided to EPA by federal agencies and private organizations were not of acceptable 

quality for a variety of reasons. (It has commented in subrecommendation 5.1 and 5.2 

about the need for greater coordination among the federal agencies in planning, conducting, 

and reporting results from environmental technology R&D.) The Committee also heard 

many times that potential users or financiers of innovative or pollution preventing solutions 

were deterred by a lack of data they could trust and the inability to obtain approval from 

federal, state, or local permit writers to use these solutions due to the lack of credible data. 

Finally, the Committee was informed of many situations in which public concerns about 

the capability and safety of a proposed solution could not be allayed using available data, 

because it was not considered credible. 

116
The TIE Committee has concluded that a much greater emphasis should be placed by 

ORD on helping others improve the quality of the data and information they generate about 

environmentally beneficial technologies. In this subrecommendation, the Committee 

emphasizes the value and necessity of this activity to all environmental stakeholders, and 

suggests some of the steps that will help accomplish it. This conclusion is also reflected in 

subrecommendations 5.1 and 5.2 (involving others throughout the life cycle of EPA's 

environmental technology R&D), 5.1 and 5.2 "g" (increasing coordination with other 

federal agencies), 5.1 and 5.2 "h" (expanding the program for coordinated testing and 

evaluation of environmentally beneficial technologies at federal facilities), 5.1 and 5.2 "i" 

(expanding cooperative R&D efforts on environmentally beneficial technologies through 

consortia and other arrangements), 5.1 and 5.2 "k" (establishing procedures for the testing 

and evaluation of privately developed technologies by EPA), and 5.1 and 5.2 "1" 

(expanding cooperative R&D under the FTTA). 

There are two additional points that reinforce the need for ORD to place an emphasis 

on helping others improve the credibility of data they generate. First, the Committee 

believes that the technology conclusions of industrial scientists are often considered by 

regulators to be biased, sometimes with good reason. Second, EPA researchers often look 

upon working with any company as favoritism and hence undesirable. The Committee 

believes that by engaging with the private sector specifically on the point of improving the 

credibility of data they produce, EPA will be performing a task that is important to all 

environmental stakeholders. 

a .­ USE EPA'S R&D PROGRAM TO INCREASE THE 

STANDARDIZATION OF TEST PROTOCOLS, ANALYSIS 

PROCEDURES, AND PERFORMANCE DATA REPORTING: One 

key leadership role that EPA must play is in expanding the pool of data produced by R&D 

on environmentally beneficial technology that have mutually acceptable quality, 

comparability, and transferability. It is in the interest of the credibility of the agency to seek 

and gain a consensus about data quality, comparability, and transferability. It is extremely 

important for EPA to lead an effort to reach agreement about the approaches for planning 

and conducting technology tests and demonstrations, for gathering and analyzing test data, 

for producing predictive models, for quality assurance and quality control (QA/QC), for all 

associated assumptions, and for reporting results. This task could be undertaken by the 

"R&D cooperation council" for environmentally beneficial technology that would have as 

117 
its purpose the steady increase of federal coordination and cooperation throughout the R&D 

life cycle (see subrecommendation 5.1 and 5.2 "e"). 

The Committee was informed that EPA plans to initiate an effort to increase the 

standardization of approaches to R&D, in conjunction with DOD and DOE, as a part of the 

Strategic Environmental Research and Development Program (SERDP). This important 

effort, if successful, would immediately expand the reach and impact of federal research on 

environmental technologies and environmentally beneficial technologies by coordinating 

federal approaches to producing and transferring environment-related data. The Committee 

commends its staff and the Office of Cooperative Environmental Management for 

spearheading this effort. Analogous efforts should be made to extend this coordination to 

include other public sector R&D partners and the private sector. 

b . ESTABLISH PROCEDURES FOR THE USE OF EPA 

LABORATORIES FOR THE TESTING AND EVALUATION OF 

TECHNOLOGIES DEVELOPED OUTSIDE EPA: In subrecommendation 

5.1 and 5.2 "k", the TIE Committee points to the need for EPA to provide a testing and 

evaluation function -- or service -- for environmentally beneficial technologies developed 

outside EPA, but not necessarily a technology certification or approval function. EPA is 

currently performing both a testing and evaluation role and a certification function (in the 

analytic testing and measurements areas), but is not otherwise certifying technologies. An 

expanded testing and evaluation role would benefit the U.S. by helping technology 

developers produce better and more credible performance data about their technologies, as 

well as by helping clarify and verify performance claims. EPA has taken on just this role at 

the underground storage tank leak detection test center in Edison, N.J., to the great 

advantage and plaudits of all concerned. 

This suggestion relates to the need to leverage EPA's scarce environmental technology 

R&D resources. It will contribute to realizing the data quality recommendations in this 

section, which are critical to EPA's ability to play amore successful role in diffusion. 

118 
5.4­ Emphasize the commercialization end point in EPA's

and in EPA-led R&D on environmentally beneficial 

technologies. 

Commentary 

As discussed earlier in Recommendation 5, EPA's resources supporting technology 

innovation represent only a small portion of the total national investment for this purpose. 

Within the federal government alone, EPA is at best the fourth largest financing source. It 

is therefore critical for EPA to get a large "bang for the buck" in its R&D programs on 

environmentally beneficial technologies. One key way to do this throughout the R&D life 

cycle is to increase EPA's focus on the commercialization end point. 

Improving the productivity of its environmental technology R&D is a management 

issue of significant dimension to EPA. The lack of credible cost of performance 

characteristics for some environmental technologies, whether EPA has a proprietary interest 

in them or not, limits the nation's ability to meet its declared environmental objectives. 

Accordingly, it is important for the agency to focus its efforts on the commercialization 

end point when it plays the role of technology developer, when it acts as a tester and 

evaluator of new technologies, and when it functions as a designer or certifier of test 

methods and protocols. The following discussion suggests some specific steps that EPA 

should take to build the commercialization end point into its technology R&D activities: 

a. BUILD THE COMMERCIALIZATION END POINT INTO EPA'S 

TECHNOLOGY R&D EFFORTS: Commercialization potential should 

become an explicit consideration in R&D planning, targeting, and funding decisions; in 

decisions about whether to continue support for individual lines of research; as a factor in 

designing test protocols; and as a focus of data analysis and reporting. The agency should 

think of the internal transfer of technology information as a "first use" of the information, 

and plan for subsequent uses by permitted organizations. EPA should similarly encourage 

the "R&D cooperation council" for environmentally beneficial technology to focus on the 

commercialization end point throughout the R&D life cycle (see subrecommendation 5.1 

and 5.2 "e"). 

119 
The trend for EPA to support university-based consortia, combining the efforts of 

government, industry, and academia to develop and commercialize environmentally 

beneficial technology, has been an important development over the past several years. This 

trend should continue, because it encourages cooperation, leveraging, and 

commercialization potential (see subrecommendations 5.1 and 5.2 "i"). The proposal of a 

mandatory leveraging requirement for a significant portion of EPA's annual investment in 

technology-related R&D is made in large part to encourage EPA to focus on high potential 

technologies (see subrecommendation 5.1 and 5.2 "f'). Further, as discussed in 

subrecommendation 5.1 and 5.2 "d", EPA's environmental technology R&D plans should 

explicitly describe what the expected commercialization end point is for each research 

project, how progress towards the end point will be evaluated, how the end point will be 

reached, and how the results will be diffused. This new emphasis on commercialization 

will increase the value of agency R&D results by focusing its R&D resources on market 

needs and requirements. 

b. BUILD EXPERTISE IN ECONOMICS, MARKETING, AND 

COMMERCIALIZATION: To become a partner with industry, EPA will have 

to become more knowledgeable about market trends and behavior, and develop the skills 

necessary to recognize what is commercially relevant. EPA should develop expertise in 

market planning, product development, and the dynamics of supply and demand in 

regulated industries. These skills should be widespread and decentralized. All parts of 

EPA will need to increase their capacity in this area, including the regulatory programs 

which will find these skills particularly useful in light of their experimentation with 

incentive based environmental management strategies. Every technology laboratory should 

have these skills in house, as well as ORD headquarters and the media offices. 

This expertise can enhance the agency's R&D efforts on environmentally beneficial 

technologies throughout the R&D life cycle by making them more able to detect and more 

responsive to market needs. The expertise is needed to help strengthen EPA's 

effectiveness as a key player in the diffusion system, as well as in conducting R&D and in 

writing regulations. It is also important to the efficient allocation of resources for the 

diffusion of EPA-owned technologies, which requires knowledge of what regulated 

industries are demanding and what provider industries can do. 

120 
Although EPA is not a major developer of environmentally beneficial technologies, the 

agency should be careful that what it does develop meets real world needs. Careful marketbased planning and a strengthened relationship with industry can increase EPA's ability to 

anticipate these needs in R&D programs. Commercializing promising technologies 

requires expertise in market analysis and product development. Even if EPA does not 

actually commercialize and market technologies itself (which is not recommended by the 

TIE Committee), the ability to engage in systematic, mutual feedback with technology 

developers and users will enhance and focus all environmentally related technology 

development, testing and evaluation, data collection, and commercialization efforts, both 

public and private. This ability will therefore enable EPA to increase the leverage it gains 

with its research resources. 

This new expertise will enhance the agency's environmentally beneficial technology 

diffusion efforts by making them more responsive to market needs and requirements. 

c .­ MAXIMIZE THE USE OF FTTA TO ENSURE

 

COMMERCIALIZATION OF EPA'S ENVIRONMENTAL 

TECHNOLOGY RESEARCH SUCCESSES: In subrecommendation 5.1 

and 5.2 "1", the TIE Committee suggests steps that EPA should take to make greater use of 

the Federal Technology Transfer Act (F1 -

1'A) to enhance the commercialization chances of 

EPA's environmental technology research successes. These suggestions are important to 

the realization of the commercialization recommendations in this section. 

d . REQUIRE PRIVATE SECTOR CO-FUNDING FOR PART OF 

EPA'S TECHNOLOGY R&D: In subrecommendation 5.2 "f", the TIE 

Committee points to the necessity of leveraging EPA's scarce environmental technology 

R&D resources through the requirement of private sector co-funding for part of EPA's 

program. These suggestions are also important to realizing the commercialization 

recommendations in this section. 

121 
122

 
Appendix 1: Presenters and Participants at

Diffusion Focus Group Meetings 

Presenters' and Participants at the Diffusion Focus Group Meeting, January 

15-16, 1991 Research Triangle Park, North Carolina 

Mr. John W. Adams 

Mr. Benjamin Bochenek 

Mr. William W. Carpenter 

Mr. John Convery 

Mr. James Hall 

Ms. Margaret Kelly 

Mr. Calvin Lawrence 

Mr. Blair Martin 

Mr. Michael Mastracci 

Mr. Bruce Mattson 

Mr. Scott McMoran 

Mr. Michael Moore 

Mr. Ronald Patterson 

Ms. Francis Richards 

Dr. Jon Soderstrom 

National Environmental Technology Applications Corp. 

EPA Office of General Counsel 

Martin Marietta Energy Systems, Inc. 

EPA Risk Reduction Engineering Laboratory 

U.S.D.A. Agricultural Research Service 

EPA Office of Solid Waste and Emergency Response 

EPA Center for Environmental Research Information 

EPA Air and Energy Engineering Research Laboratory 

EPA Office of Environmental Engineering and Technology 

Demonstration 

National Institute of Standards and Technology 

EPA Grants Administration 

EPA Office of Technology Transfer and Regulatory Support 

EPA Atmospheric Research and Exposure Assessment 

Laboratory 

EPA Research Triangle Park Grants 

Martin Marietta Energy Systems, Inc. 

Presenters and Participants at the Diffusion Focus Group Meeting, July 29­

30, 1991, Cincinnati, Ohio 

Mr. John W. Adams 

Mr. Frank Altmayer 

Mr. Jay Benforado 

Mr. William W. Carpenter 

Ms. Patricia Cook 

Mr. William Copa 

Dr. Robert Detroy 

Mr. Charles (Ed) Gross 

Ms. Katherine Hain 

Mr. Richard Kibler 

Mr. Calvin Lawrence 

Mr. Michael Moore 

Dr. Peter Preuss 

Mr. John Schofield 

Mr. Joel Szabat 

Mr. Thomas Zosel 

National Environmental Technology Applications Corp. 

Scienfic Control Laboratories, Inc. 

EPA Office of Technology Transfer and Regulatory Support 

Martin Marietta Energy Systems, Inc. 

EPA Office of Research and Development 

Zimpro-Passavant 

Allied Signal Corporation 

EPA Office of Water 

Department of Energy Technology Development Office 

Department of Defense 

EPA Center for Environmental Research Information 

EPA Office of Technology Transfer and Regulatory Support 

EPA Office of Technology Transfer and Regulatory Support 

IT Corporation 

EPA Committee on Technology Cooperation 

3M Corporation 

Presenters and Participants at the Diffusion Focus Group Meeting, October 

22-23, 1991, Washington, D.C. 

Mr. John W. Adams National Environmental Technology Applications Corp. 

Mr. John Cross EPA Office of Pollution Prevention 

123 
Presenters and Participants at the Diffusion Focus Group Meeting, October 

22-23, 1991, Washington, D.C. (continued) 

Dr. Samuel Doctors 

Mr. Robert Finnigan 

Dr. Bruce Guile 

Mr. Brent M. Haddad 

Mr. Alan Hecht 

Mr. Michael Mastracci 

Mr. Richard Marczewski 

Ms. Jan McAlpine 

Mr. Rodney Sobin 

Mr. Donald Walukas 

California State University, Hayward 

Finnigan Corporations 

National Academy of Engineering 

Technology Transfer Consultant 

EPA Office of International Activities 

EPA Office of Environmental Engineering and Technology 

Demonstration 

General Motors Advanced Engineering Staff 

EPA Office of Cooperative Environmental Management 

World Resources Institute 

National Center for Manufacturing Sciences, Inc. 

Presenters and Participants at the Diffusion Focus Group Meeting, January 

22-23, 1992, Washington, D.C. 

Mr. Keith Betton 

Mr. John Cross 

Mr. Alan Ehrlich 

Mr. Daniel Esty 

Mr. Robert Finnigan 

Mr. Tom Gorman 

Mr. Peter Green 

Mr. Brent M. Haddad 

Mr. Mark Joyce 

Mr. Steve Lingle 

Dr. Alan Lloyd 

Mr. Jim Lund 

Mr. Michael Mastracci 

Ms. Emma McNamara 

Mr. David Osterman 

Ms. Kathy Porter 

Mr. Alex Ross 

Mr. Ronald Slotkin 

Mr. Joel Szabat 

EPA Office of General Counsel 

EPA Office of Pollution Prevention 

EPA Office of General Counsel 

EPA Office of Policy Planning and Evaluation 

Finnigan Corporations 

EPA Office of General Counsel 

Department of Energy 

Technology Transfer Consultant 

EPA Office of Air and Radiation 

EPA Office of Research and Development 

South Coast Air Quality Management District 

EPA Office of Water 

EPA Office of Environmental Engineering and Technology 

Demonstration 

EPA Office of Administration and Resources Management 

EPA Office of Administration and Resources Management 

Kerr & Associates 

EPA Office of Environmental Engineering and Technology 

Demonstration 

EPA Office of Technology Transfer and Regulatory Support 

EPA Committee on Technology Cooperation 

124 
APPENDIX 2: Recommendation 4 from the TIE 

Committee's 1991 Report &

Recommendations, "Permitting and

Compliance Policy: Barriers to U.S.

Environmental Technology

Innovation" 

Recommendation 4: 

Support regulators and other involved communities to maximize

the effectiveness of improvements recommended in permitting and

compliance systems. 

4.1	 Institute a system of incentives, training, and support to

retain experienced state and federal permit writers who

participate in permitting decisions involving the testing or

early commercial use of innovative environmental technologies. 

4.2	 Institute a system of incentives, training, and support to

retain experienced state and federal inspectors and compliance

staff who participate in decisions involving innovative

environmental technologies. 

4.3	 Provide support to prospective innovative technology

permittees (including technology developers and technology

users). 

4.4	 Emphasize the role of EPA's Office of Research and 

Development (ORD) as consultant to federal, state, and

local government permit writers and inspectors to provide

information on innovative technologies for environmental 

purposes. 

4.5	 Institute systems to provide the public with information

and support related to the testing and use of innovative

environmental technology. 

125
 
4 . 1 Institute a system of incentives, training, and support to 

retain experienced state and federal permit writers who 

participate in permitting decisions involving the testing or 

early commercial use of innovative environmental technologies. 

Commentary 

The TIE Committee recommends that a systematic program be institutedfor the 

purpose of retaining experienced permit writers. and to encourage. support. reward. and 

train those permit writers to be better prepared. and more favorably disposed. to 

processing permits involving testing and/or introduction of innovative technology. Both 

increased continuity and specialized support and training are critical to the success of 

permitting systems to encourage testing and implementation of new technologies because, 

at present, there is little or no incentive for permit writers (who often have limited 

experience) to take the risk of recommending or authorizing testing or use of a new 

technology. 

a. THE IMPORTANCE OF RETAINING PERMIT WRITERS: The TIE 

Committee believes that improving the continuity of permit writers would be an important 

step towards ensuring the timely and consistent permitting of innovative environmental 

technologies. The Committee heard evidence of cases where, in attempting to permit a 

new technology, technology developers had to deal with a seemingly constant stream of 

new permit writers. All of the hard-won verbal agreements that were reached with the old 

permit writer were nullified when the new permit writer came on board. Other developers 

presented case studies of how the rapid turnover rate of permit writers had protracted the 

permitting of a new technology to such a degree that the expected market niche 

disappeared by the time the technology finally received permits. Regulatory agencies 

indicated that the turnover rate problem damaged their ability to adequately consider permit 

applications on a timely basis, both in terms of staff and their knowledge base. 

b . ENCOURAGING FEDERAL AND STATE PERMIT WRITERS: 

Comments heard during the Fact Finding meetings indicated, however, beyond the issue 

of experience, that permit writers are often discouraged, by unwritten policy, by the lack 

of guidance, or by other factors, from writing permits for testing and/or implementation of 

new technology. The results were often counterproductive to the development and use of 

innovative technology. For example, in those cases where RCRA permits were 

126 
entertained for testing new technology, the regulators pushed for full permitting -- e.g., 

for RCRA technology testing, essentially a complete Part B -- that limited testers' ability to 

define performance envelopes, restricting the value of testing and increasing its cost. This 

situation must be reversed, so that permit writers are encouraged to and rewarded for 

issuing permits for safe testing of innovative technology for environmental purposes. 

It should be noted that changes at the federal level will have little actual impact if there 

are not corresponding changes in state programs. State laws and regulations for the 

various programs are generally modelled on those of EPA -- but there can be significant 

differences, such as California's "permit by rule" for mobile treatment units for treating 

non-RCRA wastes. Permit writers in state programs will also have to be brought into the 

incentives "loop." State and local participation in the permit team strategy outlined in 

subrecommendation 2.3 should be encouraged. 

c . INCENTIVES SUPPORTING PERMIT WRITERS: As one possible 

model of an incentives program aimed at encouraging, supporting, and training permit 

writers at federal, state, and local agencies, the TIE Committee recommends the following: 

1.­ Establish a hierarchy or job ladder for permit writers and incorporate criteria in 

performance evaluations along that promotional ladder to address the permit 

writers' development of expertise (either single media, cross-media, or 

technology-specific). The ladder might include the following elements: 

Single-media permit writers. Single media permit writers should be 

networked to facilitate information sharing within regions. These 

media representatives could serve as team members on the coordinated 

permit review teams described in subrecommendation 2.3. 

National expert single-media permit writers. A national expert permit 

writer program could be established within each of the single media 

areas as a next step in the ladder. National single-media experts could 

serve as a nationwide information (both technical and regulatory) 

resource locus in dealing with innovative technologies. They would 

also provide institutional memory in cases where local conditions favor 

high turnover rates. (State experts might also be eligible for this 

program.) 

Cross-media permitting experts within each region,. A rung in the 

ladder could be for permit writers who obtain expertise across the 

media. In designing the cross-media permit expert role, much use 

could be made of the experience gained in current EPA and state (e.g., 

Massachusetts, New Jersey) cross-media inspection and integrated 

permitting pilot projects. Team leaders for the coordinated permit 

reviews discussed in subrecommendation 2.3 should be drawn from 

this pool. 

127 
•­ Regional liaison permit writers. Regional liaison permit writers would

 

serve as coordinators, facilitating access to regional and state single-

media and cross-media expertise. 

2. Provide training and model templates, based on the prior testing of innovative 

technologies, to all permit writers. A concise, yet comprehensive, training 

program should explain the permit writers' role in fostering the successful use of 

innovative technologies for environmental purposes and on information sources 

and networks for identifying technical information. The training program should 

also educate the regulators on how industry innovation works, and on the role of 

ORD and technology groups within other federal agencies, with the goal of 

improving the permit writers potential networking base for technical information. 

3. Strengthen ORD's role as identifier and conveyer of technical information to permit 

writers. Establish a centralized clearinghouse where permit writers can easily 

access needed information. ORD should help permit writers sift through the 

technical details of newly proposed technologies, explaining how, and if, the 

innovation will be beneficial, and under what conditions, and help the permit 

writer frame permit conditions for unfamiliar technologies. ORD might also be the 

Agency lead for the ombudsman function (see subrecommendations 1.3 and 4.4). 

4. Establish performance evaluation standards and reward systems that promote 

greater support and consideration from permit writers for innovative pollution 

prevention and pollution control technologies. The first step, as mentioned 

elsewhere throughout this report, would be develop a clear, strong policy 

statement about EPA's role in promoting technology innovation. Other steps 

could include modifying performance standards and credits ("bean counting") to 

reflect the degree to which a permit writer works to achieve the goals set forth in 

the technology innovation policy statement. The TIE Committee recognizes that 

extra time and risk are involved in processing permit applications for innovative 

alternatives, and for the risk associated with supporting approaches which involve 

the uncertainties in changes in standard technologies and the uncertainties in 

performance projections for innovative solutions. Financial incentives should also 

be considered, as well as recognition and merit awards. 

5. Improve data and technical information sources to aid permit writers in their job of 

reviewing permit applications involving innovative technologies, perhaps through 

an expansion of the "ATTIC" data base, which now contains information about 

innovative remediation technologies. EPA should collect the information from 

federal, state, and other sources and assemble the data and information in on-line 

databases for PC/Mac users. Information should be collected and assembled in 

information retrieval systems easily accessible to all permit writers. Information 

should include the following: 

• Media affected by the technology 

• Emission/effluent/hazardous waste reductions achieved by the technology 

• Process descriptions 

• Location and results of tests, demonstrations, and early commercial uses 

• Level of cleanup (remedial technologies) achieved 

• Contact persons, including owner or licensee, plus ORD technical experts 

• Existence of patent covering the technology and the availability of licenses 

• Key words; similar technologies; terms of art 

• Known limitations 

• Potential site incompatibilities. 

128 
4.2 Institute a system of incentives, training, and support to 

retain experienced state and federal inspectors and 

compliance staff who participate in decisions involving 

innovative environmental technologies. 

Commentary 

The TIE Committee recognizes that the need to both maintain continuity of personnel 

and promote a more positive approach to innovative environmental technology applies to 

inspectors and compliance staff, as well as to permit writers. Asa result. the TIE 

Committee recommends that measures to train and support compliance and inspection 

personnel be undertaken by EPA and the states. 

a . THE SUPPORT ROLE OF FEDERAL AND STATE COMPLIANCE 

POLICIES: IfEPA and state agency compliance staffs and their respective 

compliance policies are not supportive of measures to promote innovation in pollution 

prevention or pollution control technology, compliance requirements will remain a barrier 

to efforts to innovate. The Committee therefore recommends that EPA open discussions 

with state enforcement officials on how best to promote such changes. Some state 

programs (e.g., New Jersey and Massachusetts) are already in the first stages of 

implementing compliance programs to promote multi-media pollution prevention. The 

Committee also recommends that EPA provide support for evaluation, implementation and 

expansion of existing state efforts, and for communication between the states on the 

success of alternative approaches. Coordination with state efforts to implement HSWA 

land disposal phaseout provisions consistent with their SARA corrective action plan 

responsibilities are of particular importance from a technological perspective. 

b . THE NEED TO REFORM REWARD PRACTICES: Standard beancounting approaches to measuring the performance of inspection and enforcement officials 

are a disincentive for these officials to support innovative responses to compliance 

requirements. Few compliance officials have experience with multi-media approaches to 

evaluating facility compliance options. In addition, working with facilities with the 

opportunity to develop or implement innovative alternatives presents potential significant 

risks and few potential rewards for the compliance official. Reviewing an innovative 

approach, or working with a facility to develop such an approach, is almost certain to 

require more time than imposing a standard compliance requirement and may involve 

129 
increased scrutiny by managers. Evaluation of an innovative approach is intrinsically 

more difficult, since operational capabilities and parameters are generally more uncertain 

than standard alternatives, whether for innovative manufacturing evolutions or innovative 

pollution control methods. This poses the risk that the compliance official will be held 

responsible for blessing an alternative that fails. 

c . ELEMENTS OF A SUPPPORT SYSTEM FOR COMPLIANCE 

PERSONNEL: ifcompliance officials are to be willing to undertake the greater 

difficulties posedbyinnovative alternatives. there must be clear policy direction. support, 

and rewards for their efforts. Three mutually reinforcing elements are key: 

1. First and foremost. EPA or the relevant state agency must have articulated a 

compliance policy which clearly establishes promotionofenvironmentally 

beneficial innovation as a major goal. Once such a clear policy is established, 

many of the necessary tools are available. For example, the Agency could 

more effectively implement the innovation waiver tools which it has largely 

neglected in the past. The TIE Committee reiterates its January 1990 

recommendation (1.4.h) that EPA expand the use of existing statutory provisions 

which trade compliance delays for improvements in technology (e.g., CWA 

Sections 301(k) and 301(n); CAA Sections 111(j) and 113(d)). The Office of 

Water has plans to draft revised guidance for the Section 301(k) waiver process, 

but in most cases the authorities carry little practical guidance and are seldom 

used. (See a further discussion of waivers under subrecommendations 2.1 and 

3.3.) The Enforcement in the 1990s Project describes several innovative 

enforcement approaches that the Committee believes are compatible with the 

greater risk-taking necessary to encourage technological innovation. 

2. Second, the performance evaluation and reward system must be amended to 

provide special credit for the compliance official who takes the risk of seriously 

evaluating and encouraging such approaches. 

3. Third. in order to promote attention by compliance officials to innovative 

technology alternatives and to promote the retention of inspectors and compliance 

staff knowledgeable of and favorably disposed to considering the use of 

innovative technologies. the TIE Committee recommends a parallel incentives 

program to that outlined above for permit' writers. The major headings below 

identify the basic program content (see subrecommendation 4.1 for details): 

• Establish a hierarchy or job ladder for compliance staffs and

 

incorporate criteria in performance evaluations along that promotional 

ladder to address the staffs' development of expertise (either single 

media, cross-media, or technology-specific). 

• Provide training and model templates, based on the prior testing of 

innovative technologies, to all compliance personnel. Such training 

should include explanation of the role of inspectors and compliance 

staff in promoting technology innovation for environmental purposes. 

130 
•

 Strengthen ORD's role as identifier and conveyer of technical 

information to compliance personnel. 

• Improve data and technical information sources to aid compliance 

personnel in compliance situations involving innovative technologies. 

4.3­ Provide support to prospective innovative technology

permittees (including technology developers and technology

users). 

Commentary 

The TIE Committee has previously recommended (January 1990, recommendations 

1.2 and 1.7) that the Agency should build into its technology innovation promotion 

strategies comprehensive approaches to inform regulated parties, particularly small and 

medium-sized businesses, about (a) applicable environmental requirements; (b) the 

advantages of developing and using innovative technologies to meet these requirements; 

and (c) EPA's specific programs to foster innovative problem solving. The current 

recommendation builds on the January 1990 recommendations and provides some 

concrete details on possible informational approaches, some of which are being used 

today and all of which can be put to greater use in cost-effective fashion. Many of the 

support functions for prospective permittees which follow might be carried out by the 

"technology advocate" (see 1.3 and 4.4). These functions include the following: 

1.­ Outreach seminars on innovative technology permit and compliance policies and 

processes. 

2.­ Information dissemination programs related to innovative technologies. These 

can involve coordinated efforts by EPA offices (especially ORD [see January 

1990 recommendation 1.5.b]), industry associations, state agencies, economic 

development authorities, local authorities, professional associations, and others. 

Opportunities to assist executive branch organizations and non-governmental 

organizations inform their memberships have particular potential. Examples of 

potential dissemination mechanisms are: 

• Newsletters 

• Press releases 

• Reports 

• Seminars. 

3. Access to the on-line database to be developed under subrecommendation 4.1 

(item 9). Additional information relevant to technology users and potential permittees might be added to the database, including permit requirements used in 

similar technologies and other permit application informational needs. Technical 

131 
information might also be added to the RCRA/CERCLA "Hotline." Similar 

mechanisms could also be found for water and air. Consideration should be 

given to enlisting the cooperation of a private service (e.g., DIALOG) to ensure 

wide access to the information. Among the advantages of an environmental 

technology clearinghouse are that it would help innovators track the state of the art 

and it would promote selection of appropriate technologies and invention of new 

ones. 

4.­ Utilization of ORD personnel for technical assistance and subsidized testing. This 

would coincide with establishing an ombudsman function, as described in 

subrecommendations 1.3. and 4.4. Subsidized testing should be increased, 

although note should be taken of the January 1990 recommendation 1.5.a, which 

calls for expanding testing protocols in the SITE program and analogous testing 

efforts to define performance envelopes. 

5.­ Assure that the confidentiality of applicants' trade secrets is maintained. The TIE 

Committee notes that the statutory language for trade secret protection varies from 

statute to statue in terms of the procedure for asserting trade secrets. This can 

create confusion among technology owners, licensees, and users, and 

complicates the role of permit writers and compliance personnel involved in the 

consideration of tests and uses of innovative technologies. Trade secret 

protection information and procedures should be readily available, and to the 

extent that there are substantive differences among the environmental media 

statutes, these should be normalized. 

132 
4.4­ Emphasize the role of EPA's Office of Research and

Development (ORD) as consultant to federal, state, and

local government permit writers and inspectors to provide

information on innovative technologies for environmental 

purposes. 

Commentary 

The TIE Committee reiterates its previous recommendation (January 1990 TIE 

Recommendation 1.5.b) that the Agency should investigate ways to strengthen ORD's 

roles in fostering technology innovationas (a) identifier and conveyer, with the regulatory 

offices, of information about present and future technology gaps; and (b) a non-regulatory 

forum that works closely with technology user communities, as in the SITE program, to 

evaluate and guide technology development efforts. An analogous role for ORD within 

the federal government, the need for which has become more prominent, is to maximize 

the flow of environmental technical information among all parts of the government, 

including the Departments of Energy and Defense and the national laboratories. 

a. "TECHNOLOGY ADVOCATE": Subrecommendation 1.3 calls for EPA to 

consider establishing a "technology advocate." Its function would provide a single point 

of contact for technology developers, prospective users of innovative technology, permit 

writers and compliance officers at all levels of government, and the public so that people 

can find out information about: 

1.­ The policies relating to technology innovation 

2.­ Permitting processes relevant to proposed tests, demonstrations, or uses of an 

innovative technology 

3.­ The status of permit applications -- for individual tests and demonstrations, 

testing centers, and early commercial uses -- at both federal and state agencies 

4.­ The results of tests, demonstrations, and early commercial uses of innovative 

technologies, including information about the performance envelopes of 

individual technologies. 

133 
The function could also profitably include the ability to intervene to encourage timely 

consideration of permit applications or even to mediate between permit applicant and 

permit writer. 

Currently, the EPA office most closely matching the requirements for the ombudsman 

role is ORD. ORD has strengths in its knowledge of and objectivity about technology, 

and in its multi-media orientation, and would need to strengthen its knowledge with 

respect to permit processes and permit status. 

b . ORD ROLE WITH PERMIT TEAMS: ORD also should play a 

complementary and significant role in the permit team concept propounded in 

subrecommendations 1.3 and 23. Other roles for ORD in fostering technology 

innovation in this document include (a) developer of guidance documents on permitting 

technology testing centers and (b) collator of information (e.g., clearinghouses, on-line 

databases) discussed under incentives for permit writers and compliance staff 

(subrecommendations 4.1 and 4.2). These roles should be made prominent within the 

ORD system and integrated with existing technology transfer and regional scientist 

processes. 

134 
4.5 Institute systems to provide the public with information 

and support related to the testing and use of innovative 

environmental technology. 

Commentary 

The Committee believes that one of the most significant barriers to implementation of 

innovative environmental technology is lack of public trust in the information presented 

during the permitting process. as well as in the actual process of permit review and 

approval, As a result, siting of new facilities, or use of new technologies in existing 

facilities, often faces insurmountable public resistance. 

a. THE­NEED FOR AN EARLY, SUBSTANTIVE ROLE FOR THE 

PUBLIC WITH RESPECT TO INNOVATION: The public concern and 

fear of things that are new, whether associated with innovative technology or not, must be 

understood and addressed. It is important to realize that no study can prove the absence of 

an adverse effect. Every effort must be made to supply the public with as much data as is 

available (with understandable explanatory information) and to involve the public in the 

permitting process as early as possible. If this is done, by the time permits are issued for 

a facility it may not seem as "strange" or "new" but, in fact, very familiar. In addition, for 

this reason, care should be taken in the permitting processes with the designation "new", 

whether with reference to entire facilities, production processes, or changes to facilities 

and processes. 

b . STEPS FOR PUBLIC PARTICIPATION: The Committee recommends 

two measures which EPA should undertake to improve the quality of public participation 

in permitting. Implementing these measures may involve statutory, as well as 

administrative, changes: 

1. Provide detailed information on all facets of a new technology for which a permit 

is sought, and provide (or require the applicant to provide) substantial information 

on all known risk factors relevant to any permit application. 

2. Redesign permitting processes to afford the public an early and more substantive 

role in the actual design requirements for facilities that affect them. An improved 

use of public hearings should be considered, but it should be noted that public 

involvement can occur in other ways, as well. 

135 
c . TECHNICAL SUPPORT TO LOCAL COMMUNITIES: One way 

would be to address the limited resources available to communities that are wrestling with 

the problem of how to respond to proposals for environmental compliance made by local 

regulated organizations. In particular, communities find it difficult to obtain adequate 

technical expertise to assist the community in evaluating the potential contribution of a new 

technology and in developing a confident understanding of the level of safety being 

provided. Communities often lack knowledge about the regulatory and administrative 

processes associated with innovative technologies. 

Environmental policy makers must consider how to provide neutral technological and 

regulatory process advice beyond that provided by the regulated organization involved or 

the governmental authorities who must approve permits. The Committee notes that some 

communities are now entering into agreements to purchase neutral expert advice, using 

funds provided by the regulated organization and, in some cases by governmental units. 

EPA, for instance, can provide such support under the "Technical Assistance Grant" 

authority of CERCLA (Superfund). Such community-chosen experts may provide the 

confidence bridge necessary for having a fair and equitable decision making process. The 

Committee suggests that environmental policy makers consider how to make it possible 

for local communities to obtain such neutral advice as a matter of routine and on demand, 

whenever the use of an innovative technology for environmental purposes is proposed. 

One suggestion to this end is that EPA consider the idea that an independent foundation be 

established, with partial government funding, to provide communities with access to 

independent expert technical and process support. 

d. THE TWO-TIERED PERMIT PROCESS: The two-tiered permitting 

process recommended earlier could help achieve positive public involvement. Under such 

a process (see subrecommendation 2.2), phase one -- a screening step -- would consider 

the basic principles and parameters for a potential facility permit, and phase two -- the 

detailed consideration step -- would weigh detailed technical information and result in the 

issuance or denial of permits. Phase two would commence on if issues identified in the 

phase one have been resolved. 

The public would be involved deeply in each phase. Use of the two-tiered process 

could reduce the time and investment required to explore permits for innovative 

technologies, either by identifying and resolving basic issues (e.g., characterization of 

wastes produced, environmental and health risks, and process efficiency) early in the 

process, or by reaching the point during phase one that no agreement is possible. In this 

136 
latter case, public input to the project could be made earlier, and the project modified or 

abandoned before regulators, applicants, and the public have expended as much time and 

resources as they would have to if a complete permit application has to be provided. 

Importantly, by involving the public in the process early and in a substantive way, the 

two-tiered process allows all parties to build the confidence necessary for a successful 

dialogue. 

137 
Appendix 3: Recommendations to EPA on

Technology Cooperation,

Technology Innovation, and Trade

and the Environment 

Recommendation 1: Adopt as a major supporting mission of EPA fostering 

efforts by the industrial and academic communities to develop and evaluate 

environmentally beneficial technology (to improve environmental quality 

and also to improve the competitiveness of U.S. firms in the domestic and 

international marketplace). 

Commentary: Technology solutions are essential to the successful execution of EPA's 

mission. EPA needs to recognize its role in maintaining the viability of the environmental 

technology industry, in its broadest sense, by supporting its competitiveness in domestic 

and international markets. Some of EPA's programs present barriers to innovation and to 

the use of innovative technologies; these need to be addressed, if technology solutions are 

to be developed and applied to meet domestic goals. Further, advancing economic wellbeing should be a part of the environmental mission. This can best be accomplished and, 

indeed, gains efficiency when cooperation and teamwork are established, without 

sacrificing desired environmental results. 

Working relationships must be strengthened between governments at the federal, 

state, and local levels, and with industry, academia, and environmental groups. To this 

end, regulatory and regulatory administrative systems (e.g., permitting, compliance, 

certification programs) must encourage regulated entities to consider the widest possible 

range of technology options for maintaining compliance and, more broadly, for solving 

environmental problems. (The term "widest range of technology options" is meant to 

include pollution prevention, pollution control, remediation technology, measurement and 

analytic technology, and information management technology.) Further, the technical 

competence of government personnel, a system of incentives and support for these people, 

and technical assistance programs must be improved for regulated entities and others who 

need information about technology. 

Actions: 

•­ Draft statement for Administrator's signature stating the objectives of this 

recommendation. 

•­ Establish the technology advocate function, the function of which is to: 

Be a spokesperson for EPA regulations, and supporting policies and 

programs that encourage the development and use of innovative 

technologies to solve environmental problems and maintain compliance. 

Act a as single point of contact for all EPA activities relating to 

technology innovation and diffusion (e.g., regulations, permit 

programs, guidance, R&D, technology performance and availability). 

• Foster information transfer. 

139 
Encourage industry/government interaction (i.e., dialogue, exchange of 

personnel). 

Maintain clearinghouse on innovative technologies and techniques. 

•­ Implement regulations and supporting programs that enable environmentally 

beneficial innovation to occur domestically. 

Write regulations and regulatory administrative actions that encourage 

innovation and diffusion. 

Provide opportunities (e.g., facilities, regulations, permits, compliance 

policies) for testing, demonstration, evaluation, and communication of 

innovative technology. 

•­ Create a performance evaluation and a reward system to encourage and 

recognize­ government personnel who take actions to promote 

environmentally beneficial innovation, a system that recognizes the risk 

taking associated with some innovation. 

•­ Establish TIE Committee activity to maintain a long term 

industry/government/public dialogue on innovative technology. 

Recommendation 2: Promote professional competence and technical 

capability of EPA and state and local rulemakers, permitters, and

compliance staffs. 

Commentary: Industry has consistently and pointedly informed the TIE Committee that 

EPA staff lacks adequate technical competence and has an insufficient understanding of 

industrial processes and outlook. Strengthening technical capability will be important to the 

efficiency of transactions between regulators and regulateds, whether about rules, pending 

regulations, permit applications, permits, and compliance situations. The Committee notes 

that, in response to its previous recommendations on this point, the American Institute of 

Chemical Engineers (AIChE), working with EPA, UCLA, and MIT, has begun to develop 

training courses that will help elevate the technology competence of federal, state, and local 

staffs. 

Actions: 

•­ Strengthen technical training programs for existing EPA staff involved in 

rule writing, permitting, and compliance activities, and provide on-site 

industrial experience for rulemakers, permit writers, and compliance staffs. 

•­ Implement exchange programs for EPA staff and industrial personnel so 

that each has a better idea of the other's outlook and experience. 

•­ Strengthen programs that provide technical information to governmental 

personnel and make them readily available to rule writers, permit writers, 

and compliance staffs. 

•­ Provide the flexibility to change career paths between Agency divisions. 

140 
•­ Create a reward system to recognize improved technical competence (and 

risk taking associated with the encouragement of innovative solutions, 

including pollution prevention). 

•­ Create a system for detailing ORD staff into programs that write rules, issue 

permits, and perform compliance functions to provide technical support and 

to raise their level of technical competence. 

•­ Establish and strengthen technical and industrial criteria for employment and 

continuing training of rule writers, permit writers, and compliance staffs. 

•­ Work with the Pollution Prevention Education Committee of NACEPT to 

establish standards for technical education and criteria for evaluation at the 

K-12 grade levels and beyond to increase the pool of technically competent 

personnel. 

•­ Provide environmentally oriented education for scientists and engineers. 

Recommendation 3: Clearly define and map the process required to obtain 

permits for testing and demonstration, and for operation (for compliance 

purposes) of innovative technology. 

Commentary: The risks faced by investors, developers, and users of innovative 

environmental technology are amplified by the lack of general availability of knowledge 

about permitting processes. The unpredictability of these processes compounds these 

risks. This situation is not in the public interest, because it stifles the development and 

availability of innovative technology for environmental purposes. Further, it weakens the 

domestic environmental industry by increasing the cost of innovation. By making the 

permitting process explicit, this risk would become more predictable, would be reduced, 

and development would be encouraged. 

Actions: 

•­ Each EPA program should map its permit processes and make the "maps" 

widely available. 

•­ Improve the clarity of permit processes and more clearly state the 

information required of the permittees. 

•­ Clarify the roles/responsibilities of all parties. 

•­ Analyze the processes to streamline them and make them more predictable. 

Consider the TIE Committee's recommendation of a "two-tiered" permit 

process when innovative technologies, and (therefore) greater risk, are 

involved in a permit application. 

•­ Build into the process encouragement to choose from among the widest 

range possible of applicable technologies, including innovative technology 

and pollution prevention solutions. 

•­ Assign high priority to permit applications involving innovative 

technologies. 

141 
•­ Establish a program to encourage and facilitate "benchmarking" among 

regional, state, and local permit programs. 

•­ Assign responsibility within EPA to one group to track the progress of EPA 

in implementation of the 1991 NACEPT recommendations on permitting 

and compliance policy. 

Recommendation 4: Adopt policies in EPA research and other programs

that ensure that EPA resources devoted to enhancing the nation's 

technology base for environmental purposes will gain leverage from private 

and other supporters of technology innovation, will be targeted more 

frequently to technologies that are successfully commercialized, and will 

more frequently achieve significant market impact. 

Commentary: EPA's resources supporting technology innovation represent only a small 

portion (perhaps 5%) of the total national investment for this purpose. Within the federal 

government alone, EPA is only the third largest financing source. These scarce funds 

should be applied more effectively by EPA to leverage private sector funds. Improving the 

"bang for the buck" is a management issue of significant dimension to EPA: the (lack of) 

availability and cost of performance characteristics of some available technologies limit the 

nation's ability to meet its declared environmental objectives, and increasingly the 

international environmental marketplace represents a "lost opportunity." Serious 

consideration should be given to a mandatory leveraging requirement for a significant 

portion of EPA's annual investment in technology-related RD&D. The trend for EPA to 

support university-based consortia, combining the efforts of government, industry, and 

academia to develop and commercialize environmentally beneficial technology, has been an 

important development over the past several years. This trend should continue, because it 

encourages cooperation and leveraging. The leveraging effect also could be created with 

federal investment support for the testing, development, and demonstration of innovative 

environmental technologies (perhaps in the form of a public-private investment fund), with 

required matching non-governmental sources in each case. This approach might require 

new resources, however. It should be noted that it is important to recognize in any 

management design that mandates leveraging to distinguish between the risk levels 

associated with stage of development (i.e., to recognize that early stage technologies are the 

most risky). 

Actions: 

•­ Establish mandatory leveraging requirements for a substantial portion (e.g., 

25 percent) of EPA's technology related spending. 

•­ Institute planning processes for EPA technology programs that involve 

industry, university-based consortia, and other technology experts who are 

concerned about commercialization and market impact. 

•­ Assure data compatibility between EPA, DOE, and DOD environmental 

technology RD&D products to enhance the efficiency of federal 

environmental management efforts and to speed the availability of 

innovative solutions developed in whole or in part with federal support for 

private applications. 

142 
•­ Increase the technology market and commercialization expertise within EPA 

and introduce an evaluation of commercialization potential as one criterion in 

RD&D funding decisions. 

•­ Study investment fund experience of other governmental entities, and 

consider establishing a public-private investment fund. 

•­ Assure that EPA policies involving CRADAS seek that greatest reasonable 

degree of commercialization, assure confidentiality, and properly handle 

intellectual property, patents, licenses, and royalties. 

Recommendation 5: Establish an industrial user facility program at 

specialized EPA facilities. 

Commentary: Establishing a mechanism for the private sector or other outside 

organizations to avail themselves of the cost-effective use of specialized EPA facilities is a 

strong opportunity for government/industry cooperation. EPA has built and operated 

several unique and/or specialized facilities that other organizations might find useful for 

research, for developing performance data, or for other purposes. These potential outside 

users might be willing to pay user fees for the opportunity to conduct trials at these 

facilities, of course within the constraints that a reasonable person might impose (e.g., 

limiting outside use to times and types of activity that do not interfere with EPA's 

programmatic use of the facility). Their use could also be subsidized as part of EPA's 

support mission. 

Actions: 

•­ Study how other government agencies operate such programs. 

•­ Establish EPA/ industry team to study EPA facilities, especially those in 

ORD, to determine usefulness and availability for industrial use. 

•­ Develop necessary procedures and management systems to guide such 

activity. 

143 
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1.	 AGENCY USE ONLY (Leave blank) 2. REPORT DATE 3. REPORT TYPE AND DATES COVERED 

October 1992
 Final
 

4. TITLE AND SUBTITLE 

' Improving Technology Diffusion for Environmental
 " Protection.
 Report and Recommendations of the Technology Innovation
 

and Economics Committee 

6. AUTHOR(S)

David R. Berg, Ronald Vaughn, Morris Altschuler,
 

Camille Richardson for the TIE Committee
 

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES)

National Advisory Council for Environmental
 Policy and
 

Technology/ Technology Innovation and Economics Committee
 

U.S. Environmental Protection Agency (A 101-F6)
 

401 M Street, SW
 

Washington, DC 20460
 

9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 

U.S. Environmental Protection Agency
 

Office of Cooperative Environmental Management
 

499 South Capitol Street, SW Rm. 115 (A101—F6)
 

Washington, DC 20460
 

11. SUPPLEMENTARY NOTES 

12a. DISTRIBUTION/AVAILABILITY STATEMENT 

13. ABSTRACT (Maximum 200 words) 

5. FUNDING NUMBERS 

8.	 PERFORMING ORGANIZATION 

REPORT NUMBER 

EPA/OA/OCEM
 

EPA 130-R-92-001
 

10. SPONSORING/MONITORING

AGENCY REPORT NUMBER 

12b. DISTRIBUTION CODE 

The United States' potential to improve the environment is d i

rectly related to our ability to produce and apply technological 

solutions. The Technology Innovation and Economics (TIE) Committee, a standing committee of EPA's National Advisory 

Council for Environmental Policy and Technology (NACEPT), concluded that the environmental regulatory system could 

expand environmental progress and improve economic competitiveness if processes that diffuse environmentally beneficial 

technologies are used to effectively complement regulations. Enhanced EPA technology diffusion programs, especially those 

involving pollution prevention technologies and techniques, are essential to the achievement of EPA's mission. Federal, state 

and local regulators, technology developers, technology users, the financial community, environmental groups, and academia 

together identified and assessed potentially practical approaches. In this report, the Committee analyzes several critical policy 

issues affecting EPA's essential diffusion roles and makes five major policy recommendations, including: 

1.­ Making technology diffusion a major supporting mission for EPA. 

2.­ Building a stronger partnership with technology diffusion providers and users. 

3.­ Making diffusion and incentives the emphases of EPA's pollution prevention programs. 

4.­ Expanding support for the international diffusion of environmental technologies to help meet U.S. environmental 

and competitiveness objectives. 

5.­ Increasing the support of diffusion provided by EPA's environmental technology research programs. 

14. SUBJECT TERMS 

National Advisory Committee for Environmental Policy and Technology (NACEPT), 

Technology Innovation and Economics (TIE) Committee, Diffusion Focus Group, technology 

innovation, technology diffusion, technology transfer, technical assistance, (continued) 

17. SECURITY CLASSIFICATION 

OF REPORT 

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OF THIS PAGE 

19. SECURITY CLASSIFICATION 

OF ABSTRACT 

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16. PRICE CODE 

20. LIMITATION OF ABSTRACT 

_ -01-280-55	 Standard Form 298 (Rev. 2-89)

Prescribed by ANSI Std. 239 . 18 298. 102 
14. SUBJECT TERMS (Key Words) continued: information management and transfer, training, education,

environmental publications, R&D process, environmental technology research and development (R&D),

pollution prevention, environmental permits, compliance, environmental enforcement, environmental

incentives, non-regulatory environmental approaches, environment, environmental management system,

environmental regulations, technology advocate, environmental partnerships, multi-media, competitiveness,

environmental technology markets, environmental technology imports and exports, technology

commercialization, Federal Technology Transfer Act (FTTA), licensing and royalty policies, cooperative

research and development agreements (CRDAs), environmentally beneficial technologies, environmental

business data, public private partnerships, leveraging, state and local environmental agencies, research

consortia, coordinating environmental technology research and development (R&D), industrial user facility

program, Environmental Protection Agency (EPA), environmental stakeholders