United States Office of Pollution 

 Environmental Protection Prevention and Toxics October 2008 

 Agency 

Final Report 

 

An EPA Self Assessment 

Evaluation of EPA Efforts to Integrate Pollution 

Prevention Policy throughout EPA and at Other 

Federal Agencies 

Prepared by the Pollution Prevention Division in 

EPA’s Office of Pollution Prevention and Toxics 

for the 

Multimedia Pollution Prevention (M2P2) Office Directors’ Forum 
 2
 3

Pollution Prevention (P2) Integration 

Executive Summary 

 

EPA has undertaken a self-evaluation of its efforts, under the Pollution Prevention Act 

(P2 Act) of 1990, to integrate pollution prevention policy into its environmental 

programs, including air, water, toxics and hazardous waste. This evaluation also looked 

at the Agency’s efforts to promote pollution prevention approaches at other Federal 

agencies, which is also authorized by the P2 Act. 

The P2 Act established a national policy that pollution should be prevented or reduced at 

the source whenever feasible. The P2 Act also directs EPA to consider the effects of its 

existing and proposed programs on source reduction, and to promote source reduction 

practices at other federal agencies. 

In this evaluation we focused on P2 Act provisions that address integrating P2 policy into 

Federal programs, and we use these provisions to shape our evaluation questions. 

P2 is the basis for many sustainability efforts, whether or not the term is used. This 

evaluation makes the connections between pollution prevention integration activities and 

stewardship and sustainability policy developments. 

Overall, we found that most Agency program activities and efforts to promote P2 at other 

federal agencies are in basic conformance with Pollution Prevention Act provisions for 

P2 integration, although there is clearly room for continual improvement. The key areas 

that could benefit from additional attention to P2 integration are described below. 

Major Conclusions 

1) EPA’s review of regulations and programs for their effect on source reduction 

efforts is close to conformity with Pollution Prevention Act provisions, although 

there is clearly room for continuing improvement. 

The Agency tracks how often regulatory workgroups consider the effects of 

individual rulemakings on source reduction efforts, which is nearly a fourth of the 

time. This may be closer to half the time when two proposed air program actions 

affecting a broad class of regulatory standards are taken into account. Better quality 

data are needed to verify the impediments to more routine consideration of P2 in 

rules. 
4

Although the P2 Act does not mandate that the Agency take a particular approach in 

considering the effect of regulations on source reduction, the Agency uses its review 

of regulations to identify opportunities to create compliance approaches based on P2 

practices. 

In the past decade, many of the opportunities for developing P2 compliance 

approaches have been in the air program, which has a large regulatory agenda. To 

promote P2 approaches, the air program often relies on standards and actions 

affecting an entire class of rules, rather than a single rule. P2 practices used as a basis 

for compliance have included: 

• Use of greener materials (such as cleaners, coatings, chlorine dioxide) 

• Process changes (such as fume suppressants, extended cookouts, chemical 

recovery) 

• Work practices (such as a schedule of activities and prohibited practices), and 

• Controls with lighter environmental footprints (such as baghouses using less 

water and energy than wet scrubbers). 

Current Agency guidance on analyzing the economic impacts of P2 aspects of rules 

could be more clear in addressing the potential cost-saving aspects of P2. 

Since 1996, the Agency has continued to emphasize P2 opportunities in permitting, 

compliance, and enforcement programs. Most major permitting programs have P2 

components, except for the underground injection program. Evaluation data on the 

air program’s pilot approach to integrating P2 in permits is positive, and the air 

program has developed two rules to implement the piloted approach on a broad basis. 

Data gaps for the water and waste permitting programs make it difficult to evaluate 

the effectiveness of their approaches to fostering P2, although limited data are 

positive for the water office’s pretreatment program. 

EPA Regions use strategic co-location of P2 programs with other programs to 

leverage P2 resources and promote collaboration. One Region uses cross-program 

teams and P2 planning and reporting for media offices. 

Non-regulatory programs also take opportunities to integrate P2 into their operations, 

such as the Office of Research and Development (which has focused on P2 and 

sustainability for years), the voluntary components of the new chemicals program, 

and EPA grant programs. Numerous untapped opportunities exist in a variety of nonregulatory programs for fostering pollution prevention. 

 

2) Current Agency coordination on source reduction activities is in general 

conformance with the relevant Pollution Prevention Act provisions. However, there 

is room for greater use of coordinated efforts to forge practical P2 integration 

solutions. Some examples of coordination include: 
5

• The Innovations Action Council coordinates environmental stewardship 

partnership programs across the Agency, many of which address source 

reduction activities. The IAC produced Everyday Choices, a report for the 

Administrator earlier this year on environmental stewardship, which cites P2 

as an integral part of environmental stewardship and sustainability 

approaches. 

• The Office Directors’ Multimedia and Pollution Prevention Forum 

coordinates source reduction activities relating to regulations and other 

programs. The M2P2 Forum has facilitated several multi-office P2 solutions 

(e.g., mercury switches, unleaded racing fuel), and greater use of the Forum’s 

problem-solving capacities would be a real plus. 

• The Environmental Assistance Network (EAN) coordinates source reduction 

activities of Agency technical assistance programs. An issue that the EAN 

could address is some staff’s perception that compliance technical assistance 

programs could be better coordinated with P2 program technical assistance 

programs. 

• The Office of Research and Development coordinates research activities on 

source reduction approaches. 

To promote source reduction practices in other federal agencies, EPA offices 

coordinate with each other, and with the Federal Environmental Executive, and with 

other lead federal departments to assist federal agencies generally in adopting source 

reduction practices in their operations. Many of these working relationships are 

structured by Federal Executive Orders 13148 (Greening the Government) and 

13423 (Strengthening Federal Environmental Management), and focus on achieving 

the goals of these directives. 

3) Current Agency practices for collecting data under federal environmental 

statutes help measure the impact of source reduction practices on a national scale, 

but more can be done to address data gaps and coordinate data collection. Further 

investigation would be needed to assess Agency performance relating to the P2 Act 

provision directing the Agency to improve methods of coordinating, streamlining, 

and ensuring public access to data collected under federal environmental statutes. 

Toxic Release Inventory (TRI) waste generation trends show national waste 

generation rising more slowly than economic growth and population, suggesting that 

P2 measures have contained the growth in volume of annual total production wastes 

over time. TRI source reduction data count activities, not quantities of pollution 

reduced, yet are still informative on trends in use of P2 approaches among states and 

sectors. Municipal solid waste data show a steadily rising volume in waste generated 

over four decades; however, recent data suggest that source reduction may finally be 

making its presence felt. 

Greenhouse gas (GHG) emissions and energy trends show GHG emissions rising 

slower than economic growth, and the industrial sector achieving an absolute 
6

reduction in GHG emissions. GHG emission reductions achieved from direct Agency 

interventions are easily correlated to national GHG emission data. 

EPA national pesticide market surveys from 1982-2001 show a drop then leveling off 

in quantity used, but may reflect a shift to lower-volume substitutes. Although EPA 

stopped collecting market data in 2001, California data since then show a trend 

towards higher quantity use of what may be lower-risk pesticides. USDA fertilizer 

data show fertilizer use leveling off in the past decade. 

Some gaps in media-program data exist for wastes generated. The gaps are 

sometimes due to the delegated nature of the media program and sometimes due to 

methodological changes that make trends difficult to track. Data gaps also exist for 

trends in the relative risk of releases. 

4) Agency goal setting is partially in accord with the P2 Act provision that directs 

EPA to identify, where appropriate, measurable goals reflecting P2 policy. The 

Agency has measurable goals for direct P2 activity, including various partnership 

activities across the Agency. Yet it would also seem appropriate to have measurable 

goals for P2 integration activities so EPA can track the total impact of P2 policy 

within the Agency. In earlier days, the Agency had some P2 integration goals in its 

published Pollution Prevention Strategy and in Strategic Plans. Now, P2 is 

discussed as a voluntary-only activity in Strategic Plans. Even though some 

partnership programs essentially set P2 goals, there is no widely accepted Agency 

methodology for setting up and tracking P2 goals across programs. Region 4 is an 

exception, where media programs have been setting P2 goals for a number of years. 

The Agency’s high-level planning documents show a trend away from emphasizing 

or even acknowledging P2 integration activities. The Agency has measurable 

environmental outcome goals for direct P2 activities, but very few measurable goals 

related to P2 integration activities. The only measurable goals related to P2 

integration activities are in Region 4 (where media programs have been setting P2 

targets for years), and in some Federal partnerships in which OSW and OPPT directly 

intervene. This leaves nearly all programs without P2 goals and targets. 

5) The Agency has established standard methods of measuring pollution 

prevention, which is in conformance with the Pollution Prevention Act. 

The Agency’s standard methods for measuring P2 consist of environmental outcome 

measures and some behavioral change measures tailored to individual project needs. 

The Agency developed its methodology in consultation with States, so there is basic 

consistency between Agency and state measurement methodology. The Agency has 

used its methodology for several years, and reviews it for continuous improvement. 

The Agency uses this methodology mostly for measuring results of direct P2 

activities, although Region 4 and the Federal Electronics Challenge use this same 

methodology to measure P2 integration activities. The Agency will need to examine 
7

which methodologies to employ for measuring its P2 integration results on a broader 

basis. 

Recommendations 

1. We recommend that the Agency take short-term actions in several areas to 

improve the implementation of pollution prevention policy. 

Update key Agency policy documents to renew the Agency commitment to 

integrating pollution prevention across the Agency. 

− Update the Agency P2 policy to reaffirm P2 as an Agency priority and to 

articulate its relationship to sustainability, environmental stewardship, and 

chemical security. 

− Strengthen the role of P2 integration in the Agency semi-annual Regulatory 

Agenda, annual Performance Accountability Reports, and annual National 

Program Manager Guidance for various programs. 

Reaffirm existing procedures for prompting regulatory workgroups to consider 

source reduction during regulatory development and for the way the Agency 

tracks the P2 aspects of regulatory development. This includes use of a 

manager’s charge to address source reduction options, workgroup consideration 

of source reduction in the analytic blueprint for each regulatory development 

action, and identification of P2 steps in the RAPIDS database, EPA’s regulatory 

tracking system. 

2. Review the Agency’s information collection practices pertaining to P2, with the 

aim of improving overall ease of data collection, coordination between information 

systems, and availability of information once collected. 

(a) Examine options for removing some constraints on Agency use of surveys 

to enhance the implementation of pollution prevention policy. 

(b) Conduct a thorough overview of information collection efforts pertaining 

to waste generation and pollution prevention to identify options for increasing our 

understanding or P2 progress. Consider: (i) Why do we have national waste 

generation trend data for some programs and not for others? (ii) How can EPA 

create scalability between national data and EPA program data? (iii) Should TRIstyle data collection be expanded beyond the industrial sector to provide a fuller 

picture of chemical releases and reductions? 
8

(3) Address the need for meaningful P2 guidance in the Agency’s Economic Impact 

Analysis Guidance. 

It would be helpful to the implementation of pollution prevention policy if 

economic impact analysis guidance more fully addressed P2 options, and were 

structured to allow the economic benefits of P2 to be fully accounted for. 

(4) We recommend that the Agency begin in the short term two processes for more 

thoroughly improving the implementation of pollution prevention policy: 

 

(a) Begin an inclusive headquarters and regional Agency process to choose 

methodologies for measuring P2 integration activities, using tools such as internal 

behavior change measures, office scorecards, and laying groundwork for tracking 

P2 results in media programs. 

(b) Begin a multi-office consultative process on the development of the Agency 

2009-2014 Strategic Plan for the purpose of strengthening the role of P2 

integration, and the harmonization of P2 policy with stewardship, sustainability, 

and chemical site security policies in the 2009 Plan and its strategic goals. 

(5) We recommend that the Agency also begin longer-term processes to address 

more far-reaching positive improvements in the implementation of pollution 

prevention policy. We recommend taking action on two or more of the following 

issues. 

(a) Explore whether there is a transferability of the air program’s regulatory 

approaches – that remove at least one regulatory barrier to P2 for a broad class of 

standards at a time – to the water or waste programs. 

(b) Explore options for measuring environmental outcome results from P2 integration 

efforts Agency-wide. It would be helpful for establishing the relevance of the P2 

policy tool if a fuller set of P2 outcome results were available annually to inform 

Agency planners, to provide important results feedback to state and tribal coregulators, and to provide a broader basis for assessing the effectiveness of this 

legislative policy tool unequaled for its attempt to create policy cohesion across 

Agency programs. 

(c) Explore ways to assess the effectiveness of NPDES (National Pollution Discharge 

Elimination System) Inspection Manual guidance on conducting on-site P2 

assessments, and of P2 options in “waste” programs. 

(d) Explore whether there are ways to assess the effectiveness of NPDES permitting 

provision on best management practices for P2 and the effectiveness of the 

Pretreatment Program in fostering P2 approaches.
9

Chapter 1 Introduction 

Why is EPA doing this self-evaluation? 

− The National Pollution Prevention and Toxics Advisory Committee1 asked the 

Agency to re-evaluate its P2 integration efforts. 

− For the Agency, it is also a matter of good program management. It has been nearly 

12 years since our last self-assessment of Agency P2 integration activities, and that 

assessment covered only a subset of the total activities, albeit a very important subset. 

It has been nearly seven years since the U.S. Government Accounting Office reported 

on EPA P2 integration efforts. 

− A self-evaluation gives us a needed Agency-wide view of our subject, which is an 

unusually broad undertaking of policy integration. 

What are we evaluating? (scope) 

− We are evaluating EPA pollution prevention integration activities conducted 

internally and with other federal agencies. For this evaluation, we are defining P2 

integration activities as efforts to integrate national P2 policy into the implementation 

of Federal programs and operations authorized under other statutes. The scope of 

EPA activities affected is not contained within a program, or even several programs, 

but spans the Agency. 

− The authority for these P2 integration efforts is the Pollution Prevention Act, which 

directs EPA to consider the effects of its existing and proposed programs on source 

reduction, to promote source reduction practices at other federal agencies, and 

conduct several other related functions. Our evaluation questions on page 10 and our 

discussion on pages 12 and 13 provide links to the specific P2 Act provisions that 

guide our evaluation. 

− We are limiting the focus of the evaluation to P2 integration activities as we have 

defined them to help us reach one of our desired endpoints, which is to examine 

options for measuring the progress and the effectiveness of these activities. The 

issues associated with this inquiry are already complex. It will help us in this inquiry 

if the scope of activities under consideration is sufficiently well defined. 

− Activities that we are not evaluating on their own merits fall into two groups. 

• The first are the direct P2 activities that EPA conducts under just the authority of 

the P2 Act, without relying on the authority of another governing statute. These 

are the activities that foster the adoption of P2 techniques by businesses (through 

grants, outreach, and technical assistance), distribute P2 information nationally, 

and give P2 awards. We do evaluate, however, the aspects of direct P2 activities 

 

1

 The Office of Pollution Prevention and Toxics obtained a charter for the National Pollution Prevention 

and Toxics Advisory Committee as a Federal Advisory Committee in 2002. The NPPTAC consulted with 

and advised OPPT on its pollution prevention and toxics programs from 2003 – 2005. 
10

that contribute to EPA P2 integration efforts, or that have aspects of both direct 

P2 and P2 integration. 

• The second are the broad class of activities done in the name of national P2 policy 

that are undertaken by others with no EPA intervention involved. 

What methodology are we using? 

− We have used a year-long consultation process involving a broad spectrum of EPA 

headquarters and regional offices to discuss how they have integrated P2 into their 

programs and operations, and to solicit their views on the current state of P2 

integration. This cross-office group provided many data sources in the form of 

document links and interviews, and helped draft and review the document, which was 

aimed at capturing the current state of P2 integration. 

− The P2 Program facilitated the cross-office consultation group. After it received 

comments on the initial draft document, the P2 Program decided to employ program 

evaluation principles to develop evaluation questions, analyze data sources, and link 

data sources to responses. The program also provided final editing of the evaluation. 

− We analyze our data sources for their utility, their limitations, and their biases, and 

provide our conclusions on these factors. For transparency, we also describe how we 

used the data sources to answer evaluation questions. Since we have so many data 

sources, we briefly summarize this analysis and description in Chapter 2, and provide 

the full version in tables in Appendices A and B. 

− To maintain readability, we summarize our evaluation results in Chapter 3, and 

provide recommendations in Chapter 4. 

What are the evaluation questions? 

The consultation group focused on the Agency’s current state of P2 integration, so this 

served as the basis for the evaluation. The evaluation examines the Agency’s current 

state of P2 integration, whether it aligns well with the P2 integration functions laid out for 

EPA in the Pollution Prevention Act and, if applicable, whether the current state of P2 

integration is consistent with the recommended state described in previous Federal 

assessments. For a few questions, the scope is a little narrower than the corresponding 

provision from the P2 Act due to the scope of the consultative process. 

EVALUATION QUESTIONS 

1) How does the Agency currently consider the effect of its programs and regulations on 

source reduction efforts? 

(a) Does current Agency review of regulations and programs for their effect on 

source reduction efforts conform with the Pollution Prevention Act provision, 

“Ensure that the Agency considers the effect of its existing and proposed 

programs on source reduction efforts and reviews regulations of the Agency prior 

and subsequent to their proposal to determine their effect on source reduction”? 

(b) Is current Agency review of regulations for their effect on source reduction 

efforts consistent with prior federal recommendations in this area? 
11

2) What is the current state of internal Agency coordination on source reduction 

activities? What is the current state of Agency coordination with appropriate offices 

to promote source reduction practices in other Federal agencies? 

(a) Does this current state of Agency coordination on source reduction activities 

conform with the Pollution Prevention Act provision, “Coordinate source 

reduction activities in each Agency Office and coordinate with appropriate offices 

to promote source reduction practices in other Federal agencies, and generic 

research and development on techniques and processes which have broad 

applicability”? 

3) What is the current status of data collected under Federal environmental statutes and 

related sources, and what does current analysis of these data reveal about the impacts 

of pollution prevention? 

(a) Does this evaluation provide the right information for determining whether the 

Agency’s current activities conform with the Pollution Prevention Act provision, 

“Develop improved methods of coordinating, streamlining, and assuring public 

access to data collected under Federal environmental statutes? 

4) What is the current status of the Agency’s measurable goals for pollution prevention, 

especially pertaining to P2 integration? 

(a) Does the current state of Agency goal-setting conform with the PPA 

provision, “Identify, where appropriate, measurable goals which reflect the policy 

of this chapter, the tasks necessary to achieve the goals, dates at which the 

principal tasks are to be accomplished, required resources, organizational 

responsibilities, and the means by which progress in meeting the goals will be 

measured”? 

5) What is the Agency’s current methodology for measuring P2, especially with respect 

to P2 integration? 

(a) Do Agency methods for measuring P2 conform with the Pollution Prevention 

Act provision, “Establish standard methods of measurement for source 

reduction”?

What is the relevance of the evaluation? 

− P2 remains relevant as an approach to achieving environmental stewardship and 

sustainability – P2 is the basis for many sustainability efforts, whether or not the term 

is used. This evaluation makes the connections between pollution prevention 

integration activities and stewardship and sustainability policy developments. 

− There is a growing demand for assessing the results of government. This evaluation 

takes a comparative look at Agency-wide P2 performance results and national P2 

results, and at national P2 results and total national environmental results. 
12

− There is also growing demand for evaluating government programs. This evaluation 

examines an unusually broad effort at policy integration across an entire agency. This 

policy integration effort is not contained within a program, or even several agency 

programs. Earlier assessments of this policy integration effort occurred years ago and 

were narrower in scope. This evaluation addresses recommendations from these 

earlier assessments. 

Background on the P2 Act and EPA P2 integration activities 

The Pollution Prevention Act of 1990 establishes a national policy of the United States – 

that preventing pollution at the source is the option of first choice for protecting the 

environment. 

The Act equates P2 with source reduction, which it defines as, “any practice which 

reduces the amount of any hazardous substance, pollutant, or contaminant entering any 

waste stream or otherwise released into the environment (including fugitive emissions) 

prior to recycling, treatment, or disposal, and reduces the hazards to human health and the 

environment associated with the release.”2

 In 1992, EPA issued a formal definition of P2 

which clarified that “in-process” recycling may qualify as P2, that P2 approaches can be 

applied to all pollution-generating activities, including those found in the energy, 

agricultural, Federal, consumer, and industrial sectors, and that energy and water 

efficiency and conservation practices which reduce the creation of pollutants conform to 

the P2 Act’s definition of source reduction.3

 Subsequently, Executive Orders likewise 

defined energy and water efficiency/conservation as within the definition of source 

reduction and pollution prevention. 

The P2 Act directs EPA to develop and implement a strategy to translate this policy 

mandate (making P2 first among waste management practices) into action. This is a 

considerable challenge, for while the Act creates a small grant authority, it creates no new 

regulatory authority except added TRI reporting, offers no provisions to bring EPA’s 

other governing statutes into conformance with this new policy (with the exception of the 

TRI reporting), and offers little authority for Congressional appropriation of funds 

towards implementing this policy. 

A lot depends on EPA’s ability to improve this situation by its own efforts. This is a 

demanding task, because prevention is not something that can simply be added on to 

 

2

 42 U.S. Code Chapter 133, Section 13102 (5). 

3

 P2 Policy Statement. http://www.epa.gov/p2/pubs/p2policy/policy.htm

Pollution Prevention Act of 1990 

...The Congress hereby declares it to be the national policy of the United States that 

pollution should be prevented or reduced at the source whenever feasible; pollution that 

cannot be prevented should be recycled in an environmentally safe manner, whenever 

feasible; pollution that cannot be prevented or recycled should be treated in an 

environmentally safe manner whenever feasible; and disposal or other release into the 

environment should be employed only as a last resort and should be conducted in an 

environmentally safe manner. 
13

existing practices and systems. It involves identifying the root causes of pollution and 

figuring out ways to minimize its creation, often by using materials and energy more 

efficiently, and by creating environmentally preferable materials, alternative processes, 

and considering alternate sources of energy. It also involves using governing statutes to 

grapple with the synergistic effects of complex environmental problems that are 

frequently not accounted for by these statutes. It means executing Agency operations in 

ways that don’t reinforce piecemeal approaches. It involves finding ways to motivate 

businesses/industries, government programs, and the public at large to change behaviors 

and adopt these alternative approaches, which can be particularly challenging under 

prescriptive statutes. One-size-fits-all approaches are not that common in P2. 

The P2 Act delineates functions for EPA that are more or less of two types. One type are 

things the Agency can do directly under P2 Act authority, and the other type requires 

internal Agency coordination to influence the execution of other statutory authorities. 

Some activities are gray areas, such as direct P2 activities that a program uses to meet its 

non-P2 Act goals, or using federal procurement opportunities, and some simply apply to 

both direct and P2 integration activities, like measurement and goal setting. But overall, 

functions can mostly be classified as one type or the other. 

We consider the direct P2 functions under the Act to be mostly the following: 

− Facilitate the adoption of source reduction techniques by businesses. This strategy shall 

include the use of the Source Reduction Clearinghouse and State matching grants 

provided in this chapter to foster the exchange of information regarding source reduction 

techniques, the dissemination of such information to businesses, and the provision of 

technical assistance to businesses. The strategy shall also consider the capabilities of 

various businesses to make use of source reduction techniques; 

− Establish an annual award program to recognize a company or companies which operate 

outstanding or innovative source reduction programs; 

− Establish a training program on source reduction opportunities, including workshops and 

guidance documents, for State and Federal permit issuance, enforcement, and inspection 

officials working within all agency program offices; and 

− Identify opportunities to use Federal procurement to encourage source reduction.

We consider these functions to apply to both direct and integration functions: 

− Establish standard methods of measurement of source reduction; and, 

− Identify, where appropriate, measurable goals which reflect the policy of this chapter, the 

tasks necessary to achieve the goals, dates at which the principal tasks are to be 

accomplished, required resources, organizational responsibilities, and the means by 

which progress in meeting the goals will be measured. 

We consider the P2 integration-only functions under the Act to be primarily these: 

− Ensure that the Agency considers the effect of its existing and proposed programs on 

source reduction efforts and [reviews] regulations of the Agency prior and subsequent to 

their proposal to determine their effect on source reduction; 

− Coordinate source reduction activities in each Agency Office and coordinate with 

appropriate offices to promote source reduction practices in other Federal agencies, and 
14

generic research and development on techniques and processes which have broad 

applicability; 

− Develop improved methods of coordinating, streamlining and assuring public access to 

data collected under Federal environmental statutes. 

Short history of P2 integration work at EPA 

In 1991, pursuant to the P2 Act, EPA established an independent P2 office, wrote an 

agency-wide P2 Strategy (56 Fed. Reg. 7849 February 1991), and began training 

personnel on developing P2 guidance for State and Federal permitting and enforcement 

officials. To further implement the Act, the Administrator directed the P2, media, and 

research programs to promote P2 through the development and implementation of 

specific air, water, and hazardous waste rules. Rule development teams were to consider 

P2 at every stage of the process, and to consider P2 options equally with control options. 

Mirroring the language of the Act, this collaborative effort was called the Source 

Reduction Review Project (SRRP). 

In 1992, the Deputy Administrator issued a 

clarifying P2 definition memo. In 1993 the 

Administrator issued a P2 Policy Statement.4

The media, P2, and research programs briefed 

the Administrator routinely on SRRP progress. 

In1994, EPA began assessing its integration of 

P2 into rules, using multi-office consultation 

and internal media program studies of 

incentives and barriers to P2 integration.5 In 

SRRP, P2 was considered at every step of rule 

development – from initial tiering, charge to the workgroup, budget allocations to some 

degree, information collection, economic impact analysis, options analysis, to the 

development of proposed rules – and for the rules furthest along – final rules and 

implementation guidance and workshops. Appendix C provides a chart of all regulatory 

development stages where P2 can be considered. 

In its SRRP findings, EPA found positive lessons as noted in the text box Positive 

outcomes such as integrated air and water pulp and paper rules were resulting from strong 

in-the-trench efforts. Yet EPA also found obstacles, as noted in a text box below, and the 

challenge of implementing a sweeping statutory policy directive without correlative 

mandates was becoming apparent. The Agency created an Office Directors’ Pollution 

Prevention Forum to consider the SRRP recommendations. They selected another round 

of rulemakings for special P2 attention in early 1997. Programs were increasingly selfreliant in creating P2 options in rules, especially where the source category had relatively 

uniform, proven P2 options that it could switch to (such as switching from volatile 

 

4 http://www.epa.gov/p2/pubs/laws.htm. 5

 At the time, these studies included the Compendium of Pollution Prevention Barriers and Incentives 

(1993), and Industrial Pollution Prevention – Incentives and Disincentives (1994). 

Positive SRRP lessons from promoting P2 

through air, water, and waste regulations: 

(1) Focus on multimedia data collection and 

analysis of regulatory options; 

(2) Write the standard to be flexible; 

(3) Test new territory with stakeholders; 

(4) Coordinate agenda-setting; 

(5) Use preambles and development documents 

to explain P2 multimedia approaches; 

(6) Use statute-specific approaches developed 

in SRRP; and 

(7) Use program-tailored P2 training. 1996 SRRP Assessment
15

organic compounds to aqueous product formulations). In many other cases, the obstacles 

to creating P2 compliance options in rules remained pretty much the same. 

To address these, the Agency began requiring regulatory workgroups to report on 

whether they considered 

P2 options during rule 

development. In 1996, the 

Agency established a 

Permits Improvement 

Team, which partially 

addressed the integration 

of P2 into the permitting 

and inspections processes. 

In 1998, the Office 

Directors group became 

the Office Directors’ 

Multimedia Pollution 

Prevention Forum (M2P2 

Forum), and began 

administering the crossoffice P2 budget initiative 

on Persistent 

Bioaccumulative and 

Toxic Chemicals (PBTs). 

During this PBT effort 

(known as the cross-Agency PBT Program until disbanding in 2005), it was seen that 

sharing budget decisions among 10 headquarter and regional offices was a strong 

incentive for keeping programs involved in cross-office planning and implementation. 

In the late 1990’s, external groups commented6

 on the barriers industry faced in acting on 

P2 opportunities, and the barriers EPA faced in implementing P2 integration policy. In 

Pathways to State P2 Regulatory Integration: The SPRINT Compendium (1998), Tellus 

Institute observed that conventional cost accounting methods obscured the true costs of 

chemical use and wastes, and that technology-based, end-of-pipe regulations continued to 

dominate. Other common observations included items listed in the table below. 

 

6 See also Geiser, Ken. "Can The Pollution Prevention Revolution Be Restarted?" Pollution Prevention 

Review, Summer 1998, pp. 71-80; Tellus Institute. “What Gets Measured May Get Prevented: P2 

Measurement and Regulatory Integration” (ca 1998)

SRRP participants generally agreed these institutional obstacles 

interfered with promoting P2 through rules. 

(1) Single-media planning and budgeting make it hard to find 

resource allocations to pay for cross-media data-sharing and 

analysis, and without these staff cannot compare the multimedia 

impacts of P2 and non-P2 regulatory options. 

(2) Air, water, and waste rules for a given industry are developed at 

different times, as reinforced by various court-ordered regulatory 

deadlines, which constrains the time available for multimedia 

analysis and option development. 

(3) Defining an industry sector broadly for rulemaking means P2-

based industrial processes cannot be a basis for a performance 

standard, since these processes then vary too much plant to plant. 

(4) Technology-based performance standards require a reliable track 

record for the technology. Staff found it hard to get reliable 

track records on innovative technologies. 

(5) Paperwork Reduction Act policy makes it difficult to get OMB 

approval to collect source reduction data through industry 

surveys, which may be the only way to get specific data needed 

to defend source reduction options. 

(6) Without P2 mandates, there is some uncertainty at the leadership 

level over how far to go for P2 in the face of other legal 

mandates affecting program planning and management. 

 1996 SRRP Assessment 
16

Common external observations 

Authority: There is little in the way of P2 mandates under statutes that address P2 – the P2 Act, 

the Clean Air Act, and RCRA. 

Organization: The division of the Agency into single media offices has made it very difficult to 

adopt the multimedia framework to problem solving that is called for by a P2 approach. 

Resources: P2 integration activity has remained a fairly small-scale activity at EPA, in terms of 

budget and staffing. 

Information: There is a lack of measurement and assessment information by which to gauge what 

does or doesn’t work well in the P2 arena. 

Goals and Accountability: There are few targets for P2. P2 is not a measure by which most staff 

performance is gauged, nor it a measure for program progress. As such, neither EPA staff nor 

programs are held accountable for P2, which is thereby easily ignored. 

Leadership: As P2 has filtered through EPA, it is no longer the purview of innovators and 

leaders, and has thereby lost considerable momentum. This is exacerbated by turnover, 

unwillingness to take risks or reward risk-takers, and the sheer inertia of the status quo. 

In 2001, the U.S. Government Accounting Office published a report on barriers to 

industry adopting P2 techniques, “EPA Should Strengthen Its Efforts to Measure and 

Encourage Pollution Prevention.” It found one factor influencing company decisions on 

P2 to be within the purview of government policy, namely regulatory design. GAO 

evaluated Agency performance based on the SRRP Assessment and staff interviews in 

light of the P2 Act’s directive for EPA to review rules before and after proposal for their 

effect on source reduction. It encouraged the agency to keep better track of whether it 

was considering the effect on source reduction in all appropriate rulemakings. It is 

unclear whether GAO knew that EPA entered this information into a tracking database at 

that time. GAO also encouraged EPA to amend TRI Section 8 for more consistent 

reporting and new reporting on quantities of emissions reduced. 

P2 Integration Progress 

Through it all, offices have taken numerous opportunities to work around some of the 

institutional obstacles to integrating multimedia pollution prevention into programs, when 

they couldn’t be addressed head on. Chapter 3 will examine the current state of P2 

integration progress in detail. 
17

Chapter 2 Data Sources and Evidence for Conclusions 

This very brief chapter outlines the methodology we are using to characterize the data 

sources used in this evaluation, and to relate these data sources to the evaluation 

questions and the report’s conclusions. We have applied this methodology to each of the 

nearly 100 data sources used in this evaluation, and are providing the details of the 

applied methodology in Appendices A and B, so as to maintain the readability and flow 

of the main document. The purpose of characterizing the data sources and relating them 

to our conclusions is to provide some measure of transparency and quality assurance for 

readers of our self-evaluation. 

Appendix A is in table form, and summarizes some key characteristics of the data. The 

characteristics we focus on for each data source are: 

• Time frame – when the data were collected; 

• Number of data points – the number of usable observations in the data. 

• Biases – any actual or potential biases that will affect the data. 

• Utility – how the data source can be used in this evaluation; and, 

• Limitations – any lack of certainty about the completeness or reliability in the data. 

Appendix B is also in table form, and summarizes how the data sources can be used to 

answer the evaluation questions. We use one table for each of our conclusions, to list the 

data sources relevant to the conclusion and identify the elements within the data source 

that provide evidence in support of the conclusion. 
18

Chapter 3 Evaluation Results 

This chapter of the report summarizes the results for each of the five evaluation questions 

and their sub-questions. Each main question discusses the current state of an aspect of P2 

integration that has a corresponding provision in the Pollution Prevention Act. For each 

main question, there is a sub-question that directly addresses the relationship between 

current state as evaluated and the relevant statutory provision. We answer each question 

with a summary statement followed by a series of conclusions, and take the questions in 

order. As we begin the evaluation summary, we note as a general reminder that the 

Agency does not have the means to address every constraint on P2 that flows from its 

governing statutes. Individual statutes can constrain regulatory design and timing, and 

collectively they dominate the structure and operations of the Agency. 

Evaluation Question 1. How does the Agency currently consider the effect of its 

programs and regulations on source reduction efforts? 

In comparison to the 1990’s, the current state of P2 integration in Agency regulations and 

programs is generally one of lower profile but expanding dimensions. There is a variety 

of P2 integration activity underway, and some offices are using previously untried tools 

and collaborations to achieve P2 integration. At the same time, there have been no recent 

high-level Agency endorsements for integrating P2 into regulatory and other nonvoluntary programs, and no repeat of the integrated 

multimedia rulemaking the Agency once 

accomplished for the pulp and paper industry. 

Collectively, current P2 integration efforts appear to 

be expanding their reach, although this evaluation 

does not attempt to quantify that impression. There is 

noticeable variability in the extent to which various 

programs employ the range of P2 integration 

approaches in use. There is room for continually 

greater utilization of the full range of these approaches across EPA programs. 

In this evaluation, we begin with our analysis of available data to characterize Agency 

compliance with the Pollution Prevention Act’s regulatory review function (noted in the 

box above), which was the focus of GAO recommendations in 2001. We will then 

evaluate the fuller range of Agency programs with respect to this statutory provision, 

making observations about prior Agency recommendations as well as current trends. 

Conclusion (1) The Agency tracks how often regulatory workgroups consider the effects 

of individual rulemakings on source reduction efforts, which is nearly a fourth of the 

time. This may be closer to half the time when two proposed air program actions 

affecting a broad class of regulatory standards are taken into account. Better quality data 

are needed to verify what impedes more routine consideration of P2 in rules, to confirm 

or revise the internal obstacles to promoting P2 through regulations that the Agency 

identified in 1996. 

“Ensure that the Agency considers 

the effect of its existing and 

proposed programs on source 

reduction efforts and review 

regulations of the Agency prior and 

subsequent to their proposal to 

determine their effect on source 

reduction.” PPA, Section 13103.
19

Regulatory workgroups since 1993 have been using an analytic blueprint process for 

mapping the stages of regulatory development. In one section they discuss the potential 

P2 options to be considered (performance-based, technology-based or other), or explain 

why these are not applicable. Since 1996, the Agency has been using the RAPIDS 

database to store continuous records of significant rule development decisions by 

workgroups, including their consideration of P2 during regulatory development. 

RAPIDS stands for the Rule and Policy Information and Development System. Through 

RAPIDS, the Agency collects simple Yes/No/N/A responses to the question, “Will 

source reduction or pollution prevention options be considered in the development of this 

action?” To illustrate the range of rules that consider P2 options, here are the 12 “yes” 

rules out of the total 87 rules for 2005. 

o National Volatile Organic Compound Emission Standards for Aerosol Coatings

o NESHAP for Area Sources: Paint Stripping and Misc. Surface Coating Operations

o New Source Performance Standards: Equipment Leaks o NESHAP: Acrylic/Modacrylic Fibers, Chemical Manufacturing, Chromium Compounds, Flexible 

Foam Fabrication and Foam Production, Carbon Black Production, Lead Acid Battery Manufacturing, 

Wood Preserving

o Petroleum Refineries - New Source Performance Standards 

o NESHAP for Area Sources: Polyvinyl Chloride/Copolymers Production, Primary and Secondary 

Copper Smelting, Primary Nonferrous Metals 

o Significant New Use Rule for Mercury Switches in Motor Vehicles

o Oil P2; Amendments to Spill Prevention, Control, and Countermeasure Requirements

o Criteria for Safe and Environmentally Protective Use of Granular Mine Tailings

o 2006 Effluent Guidelines Program Plan 

o Effluent Limitations Guidelines/Standards for Chlorine/Chlorinated Hydrocarbon Mfg. Process 

In our data analysis, we considered two data sources – the RAPIDS data from 1996 to 

2006, and actions that apply to a broad class of industry standards. The RAPIDS 

database has quantifiable data with some limitations. We have only begun to estimate the 

impact on individual standards from actions affecting a class of standards. 

Our initial analysis of RAPIDS data indicate that the Agency considers the effect of 

applicable rules on source reduction about 22 % of the time. This is based on taking the 

data points at face value, accepting workgroup descriptions that source reduction was not 

applicable to the development of a rule, and eliminating those data points from the total 

pool of data points. The limitations of this conclusion are that Not Applicable answers do 

not document their reasons, 34% of the remaining data points were blanks, and the Yes 

and No data points were not transparent enough to understand the reasons why source 

reduction could or could not be considered. A greater transparency in these data would 

allow the Agency to update its understanding of obstacles workgroup face in considering 

P2 in rulemaking. The Agency’s existing list of obstacles is given in the text box on page 

15 of this document, which summarizes Agency findings from its 1996 assessment of P2 

in regulations. 

Our initial analysis of proposed rules applying to a broad class of industry standards 

began with two data points – a 2007 proposed flexible air permitting rule, and 2003 

proposed amendments to the general provisions for national emission standards for 
20

hazardous air pollutants (NESHAP). Both of these propose to allow the kind of 

flexibility that promotes source reduction approaches and eliminates a prescriptive 

regulatory obstacle to source reduction. But upon considering the additional 2007 

proposed amendment to the general provisions for NESHAP, we conclude that it changes 

the mix of incentives being proposed, and we are no longer sure that the specific source 

reduction incentive in the 2003 proposal will still have meaning, and are unclear whether 

incentives counter to source reduction may have unintentionally been created. Thus, we 

will discount the proposed amendments to the general provisions for the NESHAP, and 

consider only the 2007 proposed flexible air permitting rule. For this latter proposed rule, 

we note that it would apply to facilities covered by many individual air emission 

standards. Further evaluation will be required to assess and quantify the degree to which 

it will help make these individual standards more conducive to source reduction. 

A summary of our quantitative analysis of RAPIDS data appears below. From 1996 

through August 2006, there were 492 rules in the RAPIDS database, of which 297 were 

air rules. Appendix C provides the annual results in aggregate and by office, showing yes, 

no, NA, blank, and total. 

− Raw aggregate responses to the source reduction question, in rounded percentages. 

• 15 % Yes. 

• 31 % Not Applicable. 

• 24 % blank. 

• 30 % No. 

− Our review of EPA’s regulatory agendas suggest that the 31 % checked Not 

Applicable may be reasonable, given the number of rule subjects that are of a 

technical or procedural nature that do not set standards for industry (a sample range of 

these rules is provided in Appendix C). We computed adjusted aggregate responses 

for the 340 rules remaining (with Not Applicable answers subtracted), shown in 

rounded percentages. 

• 22 % Yes. 

• 44 % No 

• 34 % blank 

− Blank answers account for 24 % of total data entries. Adjusting for blanks would 

require more research. Blanks could represent confusion between Not Applicable and 

No, or represent a bias towards No (lower motivation to answer when not a yes). It 

would be easier to understand the reasoning of the workgroups if reasons were 

associated with their answers, and if they increased their overall response rate. 

− “No” answers account for 40% of total data entries, and 44% of adjusted responses. 

“No” in its present form is not transparent as to the reason No was selected. It would 

be much more informative if the multiple answers the workgroup chooses from 

included several No’s, with a different reason provided for each No, and an extra No 

available for a fill-in-the-blank reason. 
21

Conclusion (2) Although the P2 Act does not mandate that the Agency take a particular 

approach in considering the effect of regulations on source reduction, the Agency uses its 

review of regulations to identify opportunities to create compliance approaches based on 

P2 practices. In the past decade, most opportunities for developing P2 compliance 

approaches have been in the air program, which has a large regulatory agenda. To 

promote P2 approaches, the air program uses individual standards and actions affecting 

an entire class of rules, which in principle can be very effective if carefully done. The 

smaller regulatory agendas of other programs have presented fewer opportunities for 

promoting P2 compliance approaches. In a few cases, partnership activity has worked to 

enhance P2 compliance approaches for a given rule. There is room for expanding the use 

of all Agency methods for facilitating the adoption of P2 through rules. 

There is a clear difference between considering the effect of a regulation on source 

reduction, and successfully incorporating a P2 compliance option into a regulatory 

standard. The Agency does look in its review for opportunities to include compliance 

approaches based on P2 practices, but regulatory workgroups can face significant 

constraints in this regard. The text box on page 15 lists various obstacles workgroups can 

face.7

 Acknowledging these institutional constraints is not intended to excuse any 

reluctance to entertain any extra work associated with developing P2 options. 

In the past five to ten years, the air program has had the greatest share of opportunities to 

integrate P2 into a regulation, because it has had the most rules to develop. Opportunities 

for the water and waste programs have been far fewer. Background on how major 

environmental laws address P2 is in Appendix C. 

Agency development of P2 compliance approaches in individual environmental 

standards. 

− The air program. Major source categories in the surface coatings group have 

presented the most consistent P2 opportunities for regulatory workgroups. The air 

program has issued 12 final rules addressing surface coatings since 1996 that 

incorporate compliance approaches based on P2 practices. 

 

7

 The text box on page 15 describes findings from the Agency’s 1996 assessment of P2 in regulations. . 

Developing P2 options almost always takes more time, and regulatory workgroups still face court-ordered, 

consent-decree deadlines signed in the absence of P2 Act considerations. Getting industry surveys on 

source reduction approved is still challenging. Also, industrial sectors can still be defined broadly, and 

innovative technologies can still lack track records. 

Surface Coating Processes 

Aerospace Industries (1995) 

Auto and Light Duty Truck (2004) 

Large Appliance (2002) 

Magnetic Tapes (1994) 

Metal Can (2003) 

Metal Coil (2002) 

Metal Furniture (2003) 

Miscellaneous Coating Manufacturing 

(2003) 

Miscellaneous Metal Parts and Products 

(2004) 
22

Paper and Other Webs (2002) 

Plastic Parts and Products (2004) 

Printing, Coating, and Dyeing of Fabrics 

(2003) 

Printing/Publishing (1999) 

Shipbuilding and Ship Repair (1995) 

Wood Building Products (2003) 

Wood Furniture (1995)

Many of these surface coatings for major sources offer a menu of compliance options 

based either on use of individually compliant materials (P2 product reformulation, 

typically shifting from volatile organic compound to water-based formulation), 

collectively compliant materials, or emission rate using add-on controls with work 

practices (schedules of activities, prohibited practices, etc.). 

The air program has also developed compliance approaches based at least in part on 

P2 practices in rules addressing major and area sources in the categories of coke 

ovens, polymer and resin products, organic chemicals, miscellaneous processes, and 

categories with area sources only. The air program has issued nine final rules for 

major sources in these categories since 1996 that offer one or more compliance 

approaches based on P2. 

Boat Manufacturing (2001) (reduces waste) 

Chromium Electroplating (1995) (uses chemical fume suppressors to stop product volatilization) 

Combustion sources at Kraft, Soda, and Sulfite Pulp and Paper Mills (2001) 

Halogenated Cleaning Solvents (1994) (process and work practice changes to reduce solvent consumption) 

Dry Cleaning (1993) (equivalent P2 technology may be used, replaces perchloroethylene) 

Friction Material Manufacturing (2002) (solvent recovery, solvent substitution) 

Iron and Steel Foundries (2004) (work practices to keep mercury switches out of scrap, bag houses reduce 

water and energy use) 

Leather finishing Operations (2002) (can meet HAP loss limit without controls) 

Miscellaneous Organic Chemical Manufacturing (2003) (can use P2 demonstration plan to reduce 

production-indexed HAP consumption factor by 65%)
23

Polyether Polyols Production (1999) (can use “extended cookout” to reduce unreacted epoxide emissions) 

Pulp and Paper Production (1998) 

Group 1 Polymers and Resins (1996) (product recovery encouraged) 

Group 3 Polymers and Resins (Amino/Phenolic Production) (2000) (reduce purge rate on reactor vessel, use 

P2 practice with process condenser mode for batch operations) 

Group IV Polymers and Resins (1996) (range of P2 process and material recovery and substitution options)

The air program is also developing three emission standards that cover four minor 

area sources which will have P2 options in the rules – boilers in two sectors, auto 

refinishing (developed in collaboration with OPPT’s P2 Program), and iron and steel. 

Other emission standards for minor area sources may also be candidates for 

incorporating P2 approaches. 

− The waste program. The program has a relatively small regulatory agenda, which 

typically deals with issues of pre-existing wastes. However, the general regulatory 

program for hazardous waste has led to significant decreases in the amount of 

hazardous waste generated. In the past 10 years, the program has pursued a number 

of regulatory and policy actions that affect source reduction in some manner. The 

program addresses handling various wastes and materials for reuse in certain 

applications to reduce the pollution and high energy use associated with mining and 

processing virgin material. The program considers the impacts of regulations, 

policies, and partnerships on beneficial reuse activities. For granular mine tailings 

(“chat”) left from mid-century mining activities, the program published a rule in July 

2007 establishing criteria for beneficial reuse, and is working with states to develop 

safe approaches to reuse of recovered mineral materials, as an alternative to virgin 

materials. In the industrial setting, the program had been developing a regulation for 

solvent-based industrial wipes based on certain source reduction practices, although 

this effort has been overtaken by a final air rule that is reinforcing industry’s shift to 

using aqueous wipes (a P2 product substitution practice). The program is adjusting 

that proposed regulation again to accommodate these changes. The program has also 

been revising its rule for oil pollution prevention. 

− The water program. The program has a small regulatory agenda. In December 1999 it 

issued Final Stormwater Regulations Phase 2, which requires small municipal 

separate storm sewer systems and construction sites to have a pollution prevention 

plan for storm water runoff as a component of NPDES permits. In 1998 the program 

co-issued final integrated air and water standards for pulp and paper mills, providing 

compliance incentives for the use of advanced P2-based technology, which a 2006 

study shows that six of 72 mills employed. 

− The toxics program. In the last several years, the program issued three significant 

new use rules (SNURs) which limit industry’s ability to re-introduce chemicals uses 

of concern into the market now that they have been removed. The program 

negotiated with industry for the removal from the market of a class of perfluorinated 

chemicals, consisting of perfluoroalkyl sulfonates (PFAS) and perflurooctanoic acid 

(PFOA) used as nonstick coatings for fabric and in teflon. The program also 

negotiated with the sole manufacturer of polybrominated diphenylethers (PBDE), a 

class of brominated fire retardants, to remove them from the market. The program 
24

followed up with a SNUR affecting 271 PFAS chemicals (2002 as amended through 

2007) and a SNUR for the six PBDE chemicals in 2006. The program also issued a 

SNUR for automotive mercury switches in October 2007, as a follow-up step to the 

phase out of mercury switches in automobiles at the end of model year 2002.. 

Agency development of P2 incentives in actions affecting a broad class of rules. 

 

− The air program. At the urging of states, the air program took the initiative to 

propose an amendment to general provisions affecting all national emission standards 

for hazardous air pollutants, to change the unintended P2 disincentive in the air 

program’s “once in, always in” policy.8 The air program proposed an amendment in 

2003 that would allow any affected source subject to any national emission standard 

for hazardous air pollutants to be exempted from the relevant standard in exchange 

for a facility limiting air emissions from the source to near-zero amounts. In their 

July 14, 2003 comments, the State air programs (STAPPA/ALAPCO) were very 

supportive of this proposal as reflecting the principles they had set forth, allowing 

exemptions only for sources that reduce emissions through pollution prevention. The 

States made a few suggestions on clarifying the rule’s definition of source reduction, 

its interface with Title V permits, and its requirements pertaining to resumption of 

HAP use. 

Then, in 2007, the Agency issued another proposal, this time stating that a major 

source can become a minor source at any time by limiting its emissions to below the 

major source threshold of 10 tons per year of an individual hazardous air pollutant 

(HAP) or 25 tons per year of any combination of HAPs. Major sources (which can be 

made up of multiple affected sources) must meet “maximum achievable” standards, 

whereas minor sources must meet “generally achievable” standards. This proposal is 

not supported by State air programs (now NACAA) or by Congress, who moved in 

January 2007 to block implementation funding for the rule. States oppose the 2007 

proposal, disagreeing with the EPA assumption that facilities once controlled by 

Maximum Achievable standards will always maintain that level of control, and 

finding nothing in the rule to prevent a facility from letting its emissions drift up just 

shy of the emission threshold that defines a major source. The States maintain that an 

exemption from the “once in always in” policy should only be available for facilities 

that reduce source emissions through pollution prevention. 

The progress that the 2003 proposed amendment represented for EPA P2 integration 

would be hard to overestimate – it provided a strong industry incentive for P2 (the 

only possibility of earning an exemption from permitting requirements for Maximum 

Achievable Control Technology was through P2) and affected sources regulated by 

 

8

 A facility that must comply with one or more individual national emission standards for hazardous air 

pollutants which base performance on non-P2 technology must usually comply within a few years of the 

final standard being issued. The facility may lack time to research and implement a proven alternative P2 

approach, which may have broader implications across the whole facility, within that time frame. Once the 

facility comes into compliance, current Agency policy has the facility always subject to the standard’s 

permitting requirements. The facility has less incentive to switch to a P2 approach after a control 

technology is installed if it can never get out of the permitting process. 
25

over 180 rules (some of them yet to be written), and applied to many large, medium, 

and small industrial businesses in the country. 

− The air program has also developed a proposed flexible permitting rule that proposes 

to remove an obstacle to adopting source reduction practices for facilities affected by 

many air emission standards. We discuss this more fully on page 26 below. 

− The pesticides program. The program uses a general policy incentive for source 

reduction in its pesticides registration process. Source reduction here involves 

reducing the hazard or toxicity presented by the pesticide. The program offers 

expedited review for any pesticide registration that meets the criteria for a reduced 

risk. Over the past six years, nearly 19% of conventional pesticide registrations have 

been for reduced risk pesticides, plus use of reduced risk biopesticides. 

Partnership agreements used to promote P2-based compliance or P2-based beyondcompliance behavior with respect to a particular rule. 

− EPA Region 5 started the Hospitals for a Healthy Environment (H2E) partnership 

program in 1998 to help medical facilities eliminate their use of mercury and to 

reduce waste generally. EPA issued an air emission standard for medical waste 

facilities in 1997 which addresses mercury and other emissions. Some stakeholders 

were interested in the rule promoting mercury P2 measures for medical facilities. 

While the rule did not take this approach, the H2E partnership did. The air program’s 

web site for the rule has a working link to the H2E web site, where technical 

assistance is made available to support its goal of virtual elimination of mercury at 

healthcare facilities. Twenty percent of healthcare facilities were members of H2E 

(and even more participated) by the time the management of H2E transitioned in 

2006 from being financially supported by EPA to an independent not-for-profit 

organization. 

− The Offices of Policy, Economics and Innovation, Pollution Prevention and Toxics, 

Solid Wastes, and Air Quality Planning and Standards collaborated on reaching an 

agreement in 2006 with the Big Three auto manufacturers, junkyards/recyclers, 

scrapyard shredders, steel mills, and States, which provides for the removal of 

mercury switches from junked cars before they are shredded and sold as scrap metal 

to steel mills. This agreement allows steel mills to satisfy a work practice standard in 

the Iron and Steel MACT rule, which can be met by certifying the scrap supplier has 

implemented procedures to remove mercury switches from auto scrap. The 

regulatory option in the proposed Iron and Steel area source rule refers specifically to 

this EPA approved agreement. 

Conclusion (3) In cases where regulatory workgroups can develop a P2 option for a 

regulatory standard, current Agency guidance on analyzing economic impacts of P2 

regulatory options could be more clear on addressing the possible cost-saving aspects of a 

P2 option.

To encourage the adoption of P2 approaches, it is important to assess any economic 

benefits of such approaches. In the regulatory setting, where economic analysis of 
26

regulatory options is expected, it is important for economic analysis to create an even 

playing field for P2 options. In the Agency’s guidance on conducting economic impact 

analysis, the discussion on estimating responses to regulatory policy observes that 

estimating responses is often the most difficult for P2 policies where options tend to be 

process- and site-specific. The guidance cautions that detailed information on industrial 

processes may be needed to predict costs and benefits, and advises that economic analysis 

should at least include qualitative discussion of potential P2 responses. Perhaps there is 

an implicit presumption that economists may need to proceed without the more detailed 

information. 

Whether the responses are characterized in quantitative or qualitative terms, there is still 

the issue of how to handle the possible cost-saving aspects of a P2 option in relation to 

the costs of a P2 option. It would seem legitimate to offset the costs of a P2 option with 

the savings of a P2 option, but it does not appear that was done in the 2001 Economic 

Impact Analysis for the Boat Manufacturing NESHAP (air emission standard). In the 

analysis, costs savings for P2 were counted as zero, on the assumption that a facility 

would chose to switch to a cost-saving process after capital depreciation. Greater clarity 

in the guidance on capturing the cost saving aspect of P2 options seems to be needed. 

 

Conclusion (4) P2 integration efforts in Agency permitting, enforcement, and 

compliance programs grew out of training and guidance the Agency developed for EPA 

and State personnel in the 1990’s. Major permitting programs (except for the 

underground injection program) have P2 components. Evaluation data from 2001 on the 

air program’s pilot approach was positive, and the program has developed two rules to 

implement the pilot approach on a widespread basis. Data gaps for the water and waste 

permitting programs make them difficult to evaluate, although limited data are positive 

for the water pretreatment permitting approach to P2. Recent data shows nearly a sixth of 

enforcement complying actions have a P2 component. The compliance program offers 

several P2 incentives, and has survey data showing the regulated community takes P2 

action based on the Agency’s compliance resources. 

EPA’s permitting, enforcement and compliance assurance programs at headquarters and 

in the regions, together with delegated state programs who co-manage permitting, all 

recognize the considerable opportunity to promote P2 in regulatory implementation 

activities. P2 integration efforts in these programs grew out of the training and guidance 

the Agency developed in the 1990’s for EPA and State permitting, compliance, and 

inspection personnel, in accordance with the P2 Act. Generally, guidance resources 

continue to be expanded and updated. 

− The air program. In 1995, the program considered options for encouraging source 

reduction through permits, and chose permitting flexibility as its primary approach. 

Flexibility within proper constraints is seen as a P2 incentive in that facilities are freer 

to consider process changes without going through permit review. Flexibility also 

makes change easier even when P2 is not involved, unless flexibility is limited to P2 

situations. The program’s currently proposed flexible permitting rule builds on years 

of effort to harmonize the Clean Air Act permitting policy framework with both 
27

market demands and P2 policy. The air program began with a flexible permitting 

pilot, which it evaluated in 2001. In 2002, it issued a final rule modifying New Source 

Review requirements, providing for, among other things, use of plantwide 

applicability limits for triggering New Source Review. Plant-wide applicability limits 

are a bubble concept which focuses on increases in plant-wide emissions and not 

emission increases at individual units within the plant. This technique is used as a 

limit on flexibility in air permitting. The proposed flexible permitting rule would 

apply to both clean air operating permits (Title V) and new source review programs. 

− The water program. The program encourages source reduction in direct discharge 

permits through a combination of mandatory P2 planning and best practices for storm 

water runoff, related sector guidance, and inspection guidance on integrating P2 

opportunity assessments into onsite inspections.. There is little data available on how 

often inspectors use P2 opportunity assessments. The water program also fosters P2 

in its pretreatment program for indirect dischargers through guidance to states and the 

thousands of municipal treatment works who administer the program. The guidance 

addresses integrating P2 into pretreatment permits, inspections, training, outreach, 

and recognition. A sample POTW annual report from California indicates the 

issuance of thousands of P2 permits issued to dischargers into the district sewer 

system. North Carolina permits collect descriptions of current P2 activities from 

industrial users of treatment works. A broader sampling of data points would be 

needed to evaluate the effectiveness of pretreatment guidance for states and municipal 

treatment works. 

No examples of encouraging source reduction in underground injection permits were 

identified during the course of this evaluation. The Underground Injection Control 

program in the water office regulates a major pathway for waste disposal in the U.S., 

with more than 800,000 injection wells covered by the program, and more than nine 

billion gallons of hazardous waste disposed annually in these underground wells. In 

conversations with staff and managers in the water office, it was clear that the 

prevention aspects of underground injection are focused on preventing contamination 

through leaks, rather than promoting the reduction of pollution at its source. 

− The waste program. There is a statutory requirement for certifying that a P2 (waste 

minimization under the statute) plan is in place. The program produced an excellent 

compendium of P2 options in the permitting process in 1998, but the extent to which 

has been put to use is not clear. No assessment of the effectiveness of the statutory 

certification requirement was found during this evaluation. In at least one case, 

regional efforts to strengthen waste minimization provisions of RCRA permits were 

deemed unenforceable by regional counsel, and not pursued. Instead, OSW has 

determined that the most effective strategy is to identify the highest generators of 

priority chemicals in industrial processes and waste, and to work with them 

individually. 

− The Office of Enforcement and Compliance Assurance (OECA). OECA, in 

conjunction with all the regulatory programs, has integrated P2 approaches into all its 
28

major tools – enforcement, compliance monitoring, compliance incentives, and 

compliance assistance. They have integrated P2 elements into seven policy and 

guidance documents, three outreach vehicles, two initiatives and incentives, and four 

measurement and reporting systems. A table of all these tools with web site, date, 

and description references appears in Appendix C, along with other supporting 

materials for the rest of this OECA discussion. 

The enforcement office conducts tens of thousands of inspections annually, many of 

which lead to follow-up actions. Facilities are also encouraged to audit their own 

activities to identify and correct any environmental noncompliance in the absence of 

inspection. While OECA has long integrated P2 into the correction of noncompliance 

situations, in recent years it has modified its data collection systems to actually 

quantify the application of P2 practices. In FY 2005, 20% of concluded enforcement 

actions that resulted in a compliance action had a P2 component, and FY 2006 nearly 

11% of concluded enforcement actions that resulted in compliance action had a P2 

component. Of the enforcement cases that included a negotiated supplemental 

environmental project (SEP), voluntarily undertaken for possible penalty mitigation, 

an average of 33% had a P2 component for all years FY 1999 through FY 2006. 

Details on OECA’s SEP Policy, and tables showing the number and percent of SEPs 

under each of eight statutes for these eight years, appears in Appendix C. In this 

evaluation we have not examined the case experiences behind these numbers to assess 

the nature and quality of the P2 components undertaken. 

Number of 

Concluded 

Enforcement 

Actions 

# of Concluded 

Enforcement Actions with 

Any Complying Actions 

# of Concluded 

Enforcement Actions 

with P2 Complying 

Actions 

FY 2005 4,845 4,021 (83%) 823 (17%) 

FY 2006 6,228 5,524 (88%) 648 (10%) 

Source: ICIS data, as generated by OECA in July 2007 

OECA guidance for compliance monitoring has, since 1998, strongly emphasized the 

development of coordinated multimedia, whole-facility, and pollution prevention 

oriented compliance assurance strategies. A 1999 inspection resource guide and 2004 

inspection guidance related to the Clean Water Act further that emphasis. 

Compliance monitoring in EPA’s Federal Facilities Enforcement Program routinely 

checks for green purchasing. In this evaluation we have not examined experiences in 

the field to assess the extent to which field inspectors routinely follow up on OECA’s 

approach to compliance monitoring. 

For P2 compliance incentives, OECA points out P2 cost savings in self-audit 

guidance, gives small businesses longer compliance timeframes when they identify 

P2 options in self-audits, and gives developers enforcement-related incentives when 

they take a sustainable approach to cleaning up and redeveloping contaminated sites. 
29

For compliance assistance, OECA uses web-based tools and onsite assistance. The 

electronic compliance assistance clearinghouse established in 2001 has a P2 resource 

listing. The 15 web based, sector-oriented compliance centers that OECA maintains 

in partnership with stakeholders each have P2 information. Based on a nonrepresentative sample, 55 % of 2006 survey respondents from the regulated 

community, and 53% of 2007 survey respondents reported reducing or eliminating a 

pollutant as a result of a Center resource. Three sectors are especially oriented around 

P2 – the healthcare center, which can be entered through either a compliance 

assistance portal or a P2 program portal, the chemical center, which has an interactive 

facility tour with case studies and best management practices, and the federal center, 

which maintains online services for enhancing the sustainability of facility operations. 

OECA’s online Sector Notebook series profiles top P2 opportunities and P2 success 

stories. There are 35 sector notebooks and each has a P2 chapter. On-site assistance 

for federal facilities helps them meet obligations under Executive Order 13423, which 

requires many federal facilities to have environmental management systems in place 

that incorporate P2 strategies. 

Conclusion (5) Agency Regional offices use strategic co-location of P2 programs with 

other programs to leverage P2 resources and promote collaboration. Regions 

occasionally reach out beyond their co-located offices to promote P2 integration in other 

regional offices. One Region uses P2 planning and results reporting for media offices, 

supported by cross-office P2 teams. There is variability among Regions in the extent to 

which they coordinate regional multimedia and regional P2 efforts. There is room for 

expanding the contribution of Regions to P2 integration. 

In Agency Regional offices, Regional P2 programs are strong advocates for P2 

integration. Yet these programs are small, mostly consisting of two full-time staff with 

substantial direct P2 grant duties, and sometimes direct P2 project duties. Since 

individual Regions choose where these staff are placed and whether staff can be 

configured with similarly-oriented staff to coordinate their approaches and leverage their 

effectiveness, there is regional variation in how much effort P2 regional staff can devote 

to integrating P2 into other regional programs and how much integration is achieved. 

Compliance and enforcement staff are more numerous in the regions, and they too place 

an emphasis on P2. In several regions, P2 and compliance assistance are in a common 

organizational unit. In other regions, P2 is combined with air, toxics, and/or waste 

programs. 

These various configurations have produced such P2 integration results as helping with 

P2 options on regulatory workgroups, producing a compilation of workable P2 

integration techniques (Region 8), encouraging P2 approaches in state implementation 

plans for non-attainment areas for criteria air pollutants, working on P2 supplemental 

environmental projects negotiated during enforcement settlements, and joint projects with 

co-located media programs, such as Region 1’s joint targeting of enforcement and 

compliance assistance/P2 efforts on the university sector. 
30

The most comprehensive approach to P2 integration is in Region 4 which, for the past 

decade, has had a public P2 Strategy that commits Region 4 to integrating P2 into all 

major areas of activity. First administered by the Air, Pesticides and Toxics Management 

Division, and now managed by the Office of Policy and Management, the strategy aims 

to (1) make P2 the first consideration for all Region 4 media program activities, (2) 

advance multimedia planning throughout R4, (3) support partners doing P2 with flexible 

program management and direct assistance, and (4) make R4 a role model for adopting 

P2 in government operations. The Strategy calls for the air, water, and waste programs to 

prepare P2 implementation plans and report annual P2 accomplishments. 

A 2005 P2 Program Logic Model for Region 4 lists media P2 teams and cross-office P2 

teams as resources, and organizes activities by the same four goals of the R4 Strategic 

Plan. Activities include (1) advocating P2 as cross-goal strategy in EPA Strategic Plans, 

(2) partnering with regional planners to include P2 measures in plans, (3) engaging media 

and enforcement programs in P2 measurement, and (4) supporting links with P2 and 

sustainability and stewardship. The Logic Model also lists such short-term results as 

number of States with environmental leadership programs and such long-term results as 

P2 becomes the cornerstone in stewardship and sustainability, increasing mention of P2 

in EPA Strategic Plans and media programs, and improving air, land, and water metrics. 

In FY 2005, the Region 4 air and water programs reported quantified P2 outcomes that 

were counted towards Agency P2 Program targets, and in FY06, of the eight Region 4 

States reporting P2 outcome results, six States reported results from environmental 

leadership programs. 

To evaluate whether practice in Region 4 lives up to the expectations of its strategy and 

logic model would involve more work than we have done. Yet the continuity expressed 

in having a public strategy on its web site and a working logic model that supports it 

shows in concept what might be done for the Agency as a whole, since a Region is a 

microcosm of the Agency. 

Conclusion (6) More programs are using partnerships to work towards some program 

goals, and this is expanding opportunities for P2 integration. 

Programs increasingly use partnerships to achieve goals. While EPA has long used 

partnerships as an important adjunct to non-voluntary programs, such as the Radon 

Program’s extensive use of voluntary programs since 

1985, this trend has accelerated in face of the growing 

need for EPA to encourage and enable desired 

behaviors. Narrower limits would constrain the 

Agency’s ability to promote environmental 

stewardship, prevention, and sustainability. EPA staff 

have increasingly found innovative partnership 

approaches for providing information to technical 

assistance providers and the public, delivering technical and financial assistance, and 

recognizing and sharing best practices. 

EPA Partnership Programs 

OAR 23 

OPPT 11 

OSWER 7 

OW 7 

Others 4 
31

The Office of Policy, Economics and Innovations made a preliminary standard list of the 

principle partnership programs, which appears in Appendix C. The appendix shows their 

relationship to P2 – most actively encourage source reduction. There are now dozens of 

major, national partnership programs across EPA, and many more with a regional and 

local community emphasis, that promote taking responsibility for environmental quality. 

EPA’s statutory programs use partnerships to promote P2 and sustainability, even though 

EPA’s goal structure leads to Agency web sites and documents categorizing many of 

these activities as though they were separate from P2 and sustainability. As one example, 

the Climate Change Program in the air office relies heavily on public/private partnerships 

– Energy Star works with over 9000 public and private sector organizations to improve 

energy performance (which reduces greenhouse gas emissions through source reduction), 

manufacture, sell, and promote Energy Star products, and build Energy Star qualified 

homes. As another example, the solid waste office relies on various partnerships to 

achieve waste reduction and sustainable use of resources, including a 2003 partnership 

with McDonough Braungart Design Chemistry (MBCD) to issue a design challenge for a 

sustainable packaging system that would recover value and eliminate waste. As a result 

packaging industry professionals formed the Sustainable Packaging Coalition, which 

today with 90+ members educates industry decision-makers and distributes design tools 

for moving toward a fully sustainable packaging system. 

Agency partnership programs contribute to integrating P2 in other EPA programs and 

other Federal agencies. The Office of Compliance collaborated with Hospitals for a 

Healthy Environment (then an Agency partnership program) on an integrated, dual-portal 

website on P2 and compliance issues for healthcare facilities. The Office of Air Quality 

Planning and Standards is collaborating with the P2 Program to use voluntary best 

practice standards in area source rules. OAQPS included P2 best practices promoted by 

the Design for the Environment Program in the January 9, 2008 area source regulation for 

miscellaneous surface coatings and auto refinishing operations. OAQPS also included a 

discussion of P2 opportunities to use safer alternative chemicals in the final area source 

regulation for iron and steel foundries. Energy Star is a joint effort of EPA and the US 

Department of Energy, and Energy Star success in affecting procurement influenced the 

first Executive Order on greening the Federal government (1993), which also emphasized 

procurement. The Agency’s Coal Combustion Products Partnership is a collaborative 

effort of four Federal agencies. The Agency’s Green Suppliers Network is a partnership 

with the National Institute for Standards and Technology (US Department of Commerce), 

which is also now involving the Department of Energy and States, for the purpose of 

integrating P2 into, and harmonizing, government technical assistance on helping 

businesses green and lean their operations. The Federal Electronics Challenge (FEC) 

partnership, which took direction from the greening the government executive orders, in 

turn has influenced the most recent such Executive Order, which now makes participation 

in the FEC virtually mandatory for Federal agencies. 

Conclusion (7) EPA statutory implementation programs also take opportunities to 

integrate P2 into operations other than regulations. These include activities in the 
32

children’s health, indoor air, pesticides, research, solid waste, toxics, and water programs. 

There is room for more of these opportunities to be utilized. 

The Office of Children’s Health and Environmental Education and the Indoor Air 

Program collaborate on the Healthy School Environments Assessment Tool 

(HealthySEAT) which helps schools with P2 approaches and directs them to such 

Agency efforts as the integrated pest management, green chemistry, and clean bus 

programs. 

The Office of Pesticide Programs collaborates with the U.S. Department of Agriculture 

(USDA) to promote the targeted use of biopesticides as environmentally safer substitutes 

for conventional, broad-spectrum chemical pesticides. Together, EPA and USDA fund 

biopesticide demonstration projects. Biopesticides include such techniques as phenomebased insect mating disruption, use of common soil bacteria with natural fungicidal 

properties to combat molds and mildews on a variety of agricultural crops, and use of 

sesame and other natural oils to combat powdery mildew on pumpkins. 

The Office of Research and Development published a Pollution Prevention Research 

Strategy in 1998 as one of its 13 completed research strategies. The P2 Research Strategy 

represents an important piece of the research focus on sustainable development. The P2 

Research Strategy focuses on delivering broadly applicable tools for P2 and 

sustainability, developing and transferring P2 technologies, verifying specific P2 

technologies, and researching economic, social and behavioral aspects of P2. A current 

internal Draft Sustainability Research Strategy continues some focus areas from the P2 

Research Strategy and further develops the areas of: (1) interconnections, resilience, and 

vulnerabilities over time of natural systems, industrial systems, the built environment, 

and human society; (2) collaborative decision-making (needed for policy coherence); 

and, (3) metrics and indicators for sustainability. In its 2006 report on the past decade of 

cutting-edge sustainability and P2 grant results of broad applicability, ORD observes that 

sustainability is not possible without innovations in pollution prevention. 

The Office of Solid Waste has developed a variety of tools to assist managers of 

municipal and industrial solid waste programs choose source reduction options. These 

tools include a source reduction manual for solid waste managers, a related free software 

program called ReduceIt, and a guide for industrial waste management. 

The new chemicals program within the Office of Pollution Prevention and Toxics, which 

helps manage the potential risk from chemicals new to the marketplace, offers expedited 

pre-manufacturing review of new chemical submissions that demonstrate reduced risk 

(through some combination of reduction in toxicity, persistence, unintended by-products, 

etc.). The program also shares a set of tools for designing and evaluating chemicals with 

industry, to help them recognize and avoid problem chemical formulations on their own. 

Similarly, OPPT has also launched the Chemical Assessment and Management Program 

(ChAMP) as part of an international commitment to develop broad, screening-level 

assessment of the risks posed by chemicals in commerce, with the aim of setting 
33

priorities for management, and assess the need for action, including pollution prevention, 

to mitigate these priority risks. 

The Office of Water has developed an approved P2 option that Tribal Nations can use to 

administer a water quality program under Clean Water Act Section 106 grants. This 

option is included in the program’s grant guidance for FY 2007 and beyond. The 

program has also included a P2 chapter in its 2005 guidance for municipalities and 

citizens on managing nonpoint source pollution from urban areas. The P2 chapter covers 

the handling of household chemicals, lawn and garden activities, turf management in 

recreational areas, and commercial activities such as parking lots and gas stations. 

Evaluation Q1, sub-question 1. Does current Agency review of regulations and 

programs for their effect on source reduction conform with the P2 Act provision: 

“Ensure that the Agency considers the effect of its existing and proposed programs 

on source reduction efforts and review regulations of the Agency prior and 

subsequent to their proposal to determine their effect on source reduction”? 

Conclusion (8) Agency review of regulations and programs for their effect on source 

reduction efforts is in basic conformity with the relevant Pollution Prevention Act 

provision, but there is room for continuing improvement. 

Based on Conclusions 1 through 7, as supported by evidence identified in Appendix B, 

we conclude that the Agency is in basic conformity with this provision of the Pollution 

Prevention Act. As noted in the discussions on these conclusions, there is room for 

continuing improvement in Agency review of programs and regulations for their effect on 

source reduction, and we make several recommendations in Chapter 4 for continual 

improvement in this area. There is also clearly room for improving the P2 outcomes 

achieved from this review. Although the P2 Act does not mandate particular outcomes 

from the prescribed Agency review, a need for improving those outcomes is nonetheless 

felt, especially by those who have significant expectations for the feasibility of 

preventing pollution – the P2 Act establishes a national policy that pollution should be 

prevented or reduced at the source whenever feasible. Along these lines, it is felt that the 

review of programs and regulations should result in all programs finding a way to put P2 

first, and having that reflected and tracked in their outcome results. We make several 

recommendations in Chapter 4 that go to improving the P2 outcomes achieved by 

Agency P2 integration interventions. 

Evaluation Q1, sub-question 2. Does current Agency review of regulations for their 

effect on source reduction conform with prior federal recommendations on this 

topic?

Two sets of prior federal recommendations pertained to Agency review of regulations for 

their effect on source reduction. 

First were recommendations from the 1996 EPA Assessment of the Source Reduction 

Review Project, a self-assessment of Agency efforts from 1991-1995 to consider P2 
34

during pilot rule developments. The assessment focused on underlying statutory and 

administrative factors that constrained Agency consideration of P2 options during rule 

development. Recommendations focused on what the Agency could try on its own to do 

to overcome the obstacles posed by the media-by-media statutory framework defining its 

operations. The recommendations were ambitious – no institutional mechanism in the 

Agency compelled individual programs to consider these broad recommendations when 

setting their own program goals and targets, and nothing in the P2 Act overrides other 

statutory, policy, or court mandates affecting regulatory development, making it often 

difficult to maintain a P2 position. Major recommendations from the SRRP Assessment 

were: 

1. Reinvent the planning and budgeting processes to enhance multimedia and 

pollution prevention outcomes, and emphasize the link between multimedia and 

P2 solutions. 

2. Continue to place special attention on targeted rules, especially during their 

implementation phases, and apply some of the positive lessons learned. 

3. Broaden the flexibility of regulatory requirements. 

4. Address/focus on Paperwork Reduction Act concerns about collecting source 

reduction data from industry. (OMB plays a large role.)

Second as a source of recommendations was the January 2001 Report of the U.S. General 

Accounting Office, EPA Should Strengthen Its Efforts to Measure and Encourage 

Pollution Prevention. GAO stated: 

1. “GAO recommends that the Administrator systematically determine the extent of 

the agency’s compliance with the Pollution Prevention Act’s requirement that 

EPA ‘review regulations of the Agency prior and subsequent to their proposal to 

determine their effect on source reduction.’ If warranted by the results of the 

agency’s analysis, GAO further recommends that the Administrator develop a 

plan to improve the agency’s compliance.” 

Conclusion (9) The two steps of having an Agency system to track regulatory workgroup 

consideration of source reduction during rule development, and making recommendations 

for improving the consistency of that consideration (as we do in this evaluation), are in 

line with the 2001 recommendations of the U.S. General Accounting Office. 

Based on Conclusion 1, the Agency is tracking the extent to which it considers the effects 

of its rules on source reduction efforts, which, when counting two proposed rules that 

each affect a broad class of regulatory standards, may be up to about half the time. Better 

quality data are needed to verify this conclusion, and to identify what impedes more 

routine consideration of the effect of rules on source reduction. The combined steps of 

tracking the extent of regulatory review and making recommendations to improve 

tracking and regulatory review conform with the 2001 GAO recommendation. 

Conclusion (10) Currently, high-level planning and budgeting tends to be silent on 

encouraging multimedia P2 outcomes through regulations, which is not consistent with 

the Agency’s 1996 Assessment on P2 in Regulations. The current state is strongly 
35

influenced by GPRA-related PART program reviews, which place emphasis on 

individual program planning and budgeting, not on cross-program planning and 

budgeting. EPA Region 4 has integrated P2 into media office planning for the past ten 

years, which is consistent with the 1996 recommendations. From 1998-2003, 

Headquarters placed some emphasis on cross-program planning and budgeting (in the 

targeted area of persistent, bioaccumulative and toxic chemicals) which, on a limited 

scale, was consistent with the recommendations of the 1996 Assessment. 

The SRRP Assessment saw high-level planning and budgeting as influencing the 

development of P2 regulatory options. Here we rely on our discussion of Conclusion 27 

under Question 4 (on goal setting) for concluding that high-level planning and budgeting 

tend to be silent on encouraging multimedia P2 integration approaches. The two 

exceptions are Region 4 planning (described in Conclusion 5) and Headquarters planning 

and budgeting from 1998 to 2003 in the targeted area of persistent bioaccumulative and 

toxic (PBT) chemicals. For that time interval, for some defined PBT groups of 

chemicals, 12 agency programs collaborated in planning and budgeting to take a 

multimedia and whenever possible P2 perspective on regulations, other statutory 

programs, international activities, voluntary activities, and research and outreach 

activities. The opportunity to function in this way arose from a multimedia P2 budget 

initiative on PBTs proposed by multiple offices and accepted by the Administrator. 

Conclusion (11) The Agency is still using specially targeted rules to promote source 

reduction, as recommended by the EPA 1996 Assessment on P2 in Regulations. The 

Agency is paying particular attention to P2 in the regulatory implementation phases of 

permitting, inspection, enforcement and compliance, consistent with the 1996 

recommendations. 

For this conclusion, we rely on the discussion under Conclusions 2 and 3. 

Conclusion (12) The Agency’s current emphasis on broadening the flexibility of 

regulatory requirements is consistent with the 1996 Assessment recommendations, 

although there is always room for continuing improvement. 

For this Conclusion, we also rely on the discussion under Conclusions 2 and 3. In 

particular, we are referring to three air program actions (the plantwide applicability limits 

of the final new source review rule, and the draft flexible permitting rule and the 2003 

draft amendments to the NESHAP general provisions), and the flexibility of the current 

Enforcement Office guidance on Supplemental Environmental Project Guidance (which, 

in layman not legal terms, allows alleged violators to conduct P2 SEPs that generate a 

profit, an exception to the general unacceptability of profitable projects). 

Conclusion (13) Constraints on Agency use of industry surveys for gathering data 

needed for regulatory and programmatic performance remain at a level that was of 

concern in 1996. The current state of data gathering through surveys is not consistent 

with 1996 Assessment recommendations. 
36

In the past decade, the media programs have largely not submitted (due to past 

experience) or not had success in submitting source reduction questions in Information 

Collection Requests (ICR’s) to the Office of Management and Budget, as required under 

the Paperwork Reduction Act for surveys involving more than nine entities. 

The constraint on Agency use of surveys is affecting voluntary programs as well. 

Heightened measurement expectations from the GPRA and Program Assessment Rating 

Tool Guidance have generally made it harder (or at least not any easier) for partnership 

programs to collect survey information as a way to document outcome results. There is 

seemingly a need for a voluntary program to establish a satisfactory causal link between 

its program intervention and the ensuing environmental results in order to get OMB 

approval for this kind of survey. This ICR issue tends to be a bigger roadblock for 

voluntary programs whose partners choose diverse P2 approaches than it is for programs 

whose partners adopt a sector-wide approach, since case studies plus market data can 

help document results for the latter type of program. 
37

Evaluation Question #2. What is the current state of internal Agency coordination 

on source reduction activities? With appropriate offices to promote source 

reduction practices in other Federal agencies? 

 

The Agency’s source reduction activities are quite diverse, and several working 

arrangements exist for coordinating groups of these activities. As needed, coordinating 

bodies also confer with each other, as the M2P2 Forum 

and the IAC have done. Agency coordination for 

promoting P2 practices at other Federal agencies 

involves several parts of EPA working with the Federal 

Environmental Executive and other lead Federal 

departments in the implementation of Federal Executive 

Orders, assisting federal agencies generally to integrate 

P2 into their daily operations. The Office of Federal 

Activities also reviews Environmental Impact 

Statements of Federal agencies. 

Conclusion (14) The Innovations Action Council (IAC) coordinates environmental 

stewardship partnership programs across the Agency, many of which address source 

reduction activities. The IAC produced the report to the Administrator on environmental 

stewardship, which cites P2 as an integral part of environmental stewardship and 

sustainability approaches. 

The Innovations Action Council, comprised of Deputy Assistant Administrators and 

Deputy Regional Administrators, has overall responsibility for formulating and 

advancing the Agency’s innovation agenda. Established in the Fall of 1996, the IAC has 

played an active role in giving new innovative approaches, which includes many 

addressing source reduction activities, the attention and support they need to flourish, and 

has provided a venue to share innovation efforts more broadly. 

Conclusion (15) The Office Directors’ Multimedia and Pollution Prevention (M2P2) 

Forum coordinates some source reduction activities that relate to regulatory integration 

and other multimedia program activities. On several occasions, the Forum has brought 

offices together to forge concrete multi-office P2 solutions to environmental problems. 

There is room for greater utilization of the M2P2 Forum in this problem-solving capacity. 

The Office Directors’ Multimedia and Pollution Prevention Forum, comprised of Office 

Directors and Regional Office Directors, serves to advance multimedia and pollution 

prevention approaches across a wide range of programs. Established in the Fall of 1996, 

the same time the Innovations Action Council began, the Forum came into existence to 

focus on the SRRP Assessment recommendations and coordinate P2 regulatory 

integration activities. In 1998, it took on a broader coordination role among 12 Agency 

programs in conjunction with the budget initiative on persistent, bioaccumulative and 

toxic (PBT) chemicals, described in the discussion under Conclusion 10. Cross-office 

consultation in the M2P2 Forum during the six-year PBT effort led to a Toxics Release 

Inventory rule on PBTs, a TSCA new chemicals policy on PBTs, the eventual elimination 

“Coordinate source reduction 

activities in each Agency office and 

coordinate with appropriate offices 

to promote source reduction practices in other Federal agencies, and 

generic research and development on 

techniques and processes which have 

broad applicability;” PPA, Section 

13103.
38

of lead in car racing fuel through an agreement with NASCAR, the Mercury Roadmap, 

and a heightened focus on chemical clean-outs in schools, pesticide clean-outs, wood 

stove change-outs with better technology, and burn barrels projects that promoted local 

ordinances to stimulate more centralized waste collection. 

In 2004, the M2P2 Forum brokered the collaboration between the air office and the 

Design for Environment partnership program on developing a few area source rules. In 

2005, the M2P2 Forum brokered a collaboration among the Office of Policy, Economics 

and Innovation, the Office of Pollution Prevention and Toxics, and the Office of Air 

Quality Planning and Standards on reaching an agreement in 2006 with the Big Three 

auto manufacturers, junkyards, scrapyard shredders, steel mills, and environmental 

organizations, which provides for the removal of mercury switches from junked cars 

before they are shredded and sold as scrap metal to steel mills. This complements the 

Iron and Steel MACT rule and will also complement the Iron and Steel Area Source Rule 

when it is final. 

Conclusion (16) The Environmental Assistance Network provides a forum for 

coordinating Agency technical assistance activities, including those with P2 components, 

of the compliance, prevention, innovation, research, and American Indian programs. 

There is room for utilizing this forum to continually improve the coordination of 

compliance and P2 technical assistance. 

In 2004, programs reporting under Agency Goal 5 established the Environmental 

Assistance Network to identify collaborative opportunities to improve their collective 

results. Goal 5 aims to improve environmental performance through compliance, P2, 

environmental stewardship incentives, and innovative approaches. As its first substantive 

focal area, the EAN has drafted a strategy for measuring behavior change and 

environmental outcomes in the construction sector. The strategy focuses on green 

building practices, environmentally preferable materials, construction and demolition 

debris management, diesel air emissions, storm water compliance, and energy use and 

greenhouse gas emissions. 

During this evaluation, some staff mentioned the desirability of improving the 

coordination of compliance and P2 technical assistance. The EAN may be an appropriate 

forum to look into this issue. 

Conclusion (17) The Office of Research and Development coordinates research 

activities on source reduction approaches. 

 

EPA’s Office of Research and Development consults with other EPA offices on their 

priorities for P2 research, and consults with various other research-oriented organizations 

and panels on P2 research, including the EPA Science Advisory Board, the National 

Science Foundation, and the National Academy of Sciences. 
39

Evaluation Q #2, sub-question 1: What is the current state of Agency coordination 

with appropriate offices to promote source reduction practices in other Federal 

agencies?

Conclusion (18) Currently, Agency offices coordinate with each other, with the Federal 

Environmental Executive, and with other lead Federal departments to assist Federal 

agencies generally to adopt source reduction practices in their operations. Many of these 

working relationships are structured by Federal Executive Order 13423, which 

consolidates related executive orders that preceded it. Working relationships focus on 

achieving specific EO 13423 goals and related partnership goals. EPA also reviews the 

environmental impact statements (EIS) of other Federal agencies; further evaluation 

would be required to understand the current state of promoting P2 through EIS review. 

Presidents have issued Federal Executive Orders (EO’s) since 1993 to strengthen the 

integration of P2 into daily federal operations. The first (EO 12873) required federal 

agencies to begin using their acquisitions to grow 

the market for environmentally preferable 

products, using criteria for waste prevention, 

multimedia, and life cycle impacts. EO 13101 

(1998) required agencies to set environmentally 

preferable acquisition goals. EO 13123 (1999) set 

numeric goals for energy and water conservation. 

In 2000, EO 13148 set numeric goals for reducing 

releases of various chemicals of concern and directed agencies to advance the national P2 

policy, while EO 13149 set numeric goals for reducing fleet consumption of petroleum. 

EO 13423 (2007) sets numeric goals for greenhouse gas reductions, water consumption 

intensity, fleets, sustainable buildings, and electronic purchases, and requires agencies to 

acquire bio-based, environmentally preferable, energy-efficient, water-efficient, and 

recycled-content products. 

Four parts of EPA coordinate with the Federal Environmental Executive at the White 

House Council on Environmental Quality, which oversees implementation of EO 13423 

through interagency coordination. These four offices are the Waste program, the P2 

program, the Energy Star program, and the Office of Administration and Resources 

Management. EPA, the Department of Energy, and the Department of Agriculture each 

have facilitative roles for assisting Federal agencies generally in following the EO 

mandates. 

As noted under Conclusion 6, partnership programs sometimes coordinate directly with 

other Federal agencies on promoting P2 approaches. The Green Suppliers Network 

(GSN), a partnership program, developed its design around collaborating with the 

Manufacturing Extension Partnership Centers (MEPs) of the National Institute for 

Standards and Technology (Dept. of Commerce). GSN has since also invited the 

involvement of the US Department of Energy and state P2 technical assistance providers, 

each technical assistance program adding its expertise, further integrating P2 into the 

governmental network of technical assistance providers, adds more policy coherence to 

EO 13148:... 

Each agency shall advance the national 

policy that, whenever feasible and costeffective, pollution should be prevented 

or reduced at the source. Funding for 

regulatory compliance programs shall 

emphasize P2 as a means of 

compliance. 
40

the network, and builds capacity for helping suppliers move forward with sustainable P2 

practices. 

Another aspect of EPA interaction with other Federal agencies is EPA review of 

environmental impact statements (EIS) prepared by Federal agencies before undertaking 

a major action that would have a significant impact on the environment. In 1993, EPA’s 

Office of Federal Activities (now in OECA) prepared guidance for EPA reviewers of EIS 

submissions on how to promote P2 during EIS review. This guidance was developed 

pursuant to EPA’s 1991 P2 Strategy and 1992 Draft Federal Sector P2 Strategy. The 

guidance identifies P2 approaches for a wide variety of federal actions, covering 

agriculture and land management, airports, dredging, energy and water supply projects, 

general construction, habitat rehabilitation, highways and mass transit, housing, 

hydropower generation, mining, natural gas pipelines, oil and gas, rocketry and missile 

projects, and wetlands. 

Evaluation Q #2, sub-question 2. How does this current state of Agency coordinaion on source reduction activities align with the Pollution Prevention Act provision, 

“Coordinate source reduction activities in each Agency Office and coordinate with 

appropriate offices to promote source reduction practices in other Federal agencies, 

and generic research and development on techniques and processes which have 

broad applicability”? 

Conclusion (19) Current Agency coordination on source reduction activities is generally 

aligned with the relevant Pollution Prevention Act provision. Further evaluation of 

Agency research and development activities would be needed to address the part of the 

relevant PPA provision that focuses on coordination with appropriate offices to promote 

generic research and development on P2 techniques of broad applicability. 

Evaluation Question #3: What is the current status of data collected under Federal 

environmental statutes and related sources, and what does current analysis of these 

data reveal about the impacts of pollution prevention? 

Among national-level data sets, those that track total waste generation are better suited 

for evaluating the impact of P2 than those that track post-treatment emissions. We have 

found at least some usable trend data on pollution generated that is being collected under 

TRI and RCRA (for solid waste, less so for hazardous waste). We also found usable 

trend data in EPA’s Greenhouse Gas Inventory and Energy Use Inventory (based on 

surveys and modeling), in USDA Fertilizer Use Tables, and in EPA market studies on 

pesticide use (although these were discontinued after 2001). The current picture presented 

by this combination of data is that of levels of pollution being generated are generally 

rising, but rising slower than the rise in population and gross domestic product. 

Generally it is difficult to relate the Agency’s P2 environmental results to national results, 

except in the case of greenhouse gases, where Agency results can be placed in the context 

of national results. Some data gaps exist for wastes generated for specific environmental 
41

media, which is sometimes attributable to the delegated nature of the media program, and 

at other times attributable to methodological changes that makes trends difficult to track. 

While we will not attempt to analyze trends in the relative risk of releases, this kind of 

data would provide more insight on the impact of pollution prevention. 

Conclusion (20) TRI waste generation data trends show national waste generation rising 

more slowly than economic growth and population. Taken together, these data sources 

suggest that P2 measures have been successful in containing the growth in volume of 

annual total production wastes. 

Here we examine trends in national TRI data on waste generation (prior to treatment). 

We also compare TRI trends with national domestic product and population trends to see 

whether waste generation is moving up or down in relation to economic activity and 

population. 

The Toxics Release Inventory tallies releases reported from the national industrial sector. 

TRI-reported environmental releases have fallen dramatically over nearly two decades, 

although the trend in transfers is more complicated, due to changes in reporting 

requirements. Releases can fall for various reasons – paper reporting changes, transfers, 

switching to chemicals not listed on TRI, and so on. How can the impact of source 

reduction be known? Our primary approach is to compare TRI’s total waste generation 

data with national productivity data. As a secondary matter we have also analyzed the 

directly reported source reduction data (a first for the agency), although we find these 

data more informative about sub-trends than national trends. 

We will compare TRI data on total waste generation (total production-related wastes 

managed) with national productivity data to see the relationship between pollution 

prevention policy and this downward trend in TRI releases. TRI data on total productionrelated wastes managed (TPWM) measure total waste generation for a facility, which is 

the sum of TRI releases, transfers of waste offsite, managed wastes, and wastes burned 

for energy recovery, as reported by the facility. Source reduction should lower TPWM, 

especially amounts other than energy recovery (sometimes regarded as P2). We conclude 

that TPWM data alone are not enough to discern the impact of P2 practices at TRI 

reporting facilities because total TPWM has gone up since 1988. From 1998 to 2004 

TPWM rose 2.5 %, even though releases and disposal dropped 36 %. From 2003 to 

2004, TPWM rose about 4 %, even though releases and disposal dropped 4 %. 

Source: TRI Public Data Release, 2004 

 www.epa.gov/tri/tridata/tri04/ereport/2004eReport.pdf 
42

We conclude that adding Gross Domestic Product data to the longer-term picture allows 

the impact of source reduction can be seen. From 1992 to 2004, GDP is up 48 percent, 

and TPWM is up only 2 percent! These comparative data suggest that P2 measures have 

been successful in containing the volume of total production wastes that are generated 

each year. 

Conclusion (21). Municipal solid waste data show a steady rise in the volume of waste 

generated over four decades, with recent data suggesting that source reduction may 

finally be making its presence felt.

Waste office data represent one of the longest trend records of waste generation available, 

dating back to 1960. The data reveal a seemingly inexorable rise in the volume of 

municipal solid wastes generated in the United States, increasing at a rate of about 4 

percent per year. A possible flattening of this trend is suggested by the 2005 data, which 

decreased slightly from the prior year. On a per capita basis, the solid waste data show 

an increase of about 1.5 percent annually four decades in a row, with a similar slow 

down, or even reversal, of the increase in the most recent 

year. The 2005 data suggest that source reduction—a 

priority in EPA’s solid waste management plan—may 

finally be making its presence felt, since total generation 

and per capita generation have both decreased slightly. 

Source: Municipal Solid Waste in the United States: 2005 Facts and Figures 

www.epa.gov/msw/pubs/mswchar05.pdf

There is also a trend in the handling of MSW, which appears as a steady or declining 

state for disposal and a steadily increasing state for recovery. Recovery includes 

recycling, composting, and combustion for energy. This trend provides a solid reminder 

that the recycling and recovery steps in the P2 hierarchy also produce environmental 

benefits. 

Conclusion (22). Greenhouse gas emission and energy trends show GHG 

emissions rising slower than economic growth, and the industrial sector achieving 

Solid waste generation rates 

have risen rapidly in the past 

decades, but the trend may be 

reversing in recent years. 
43

an absolute reduction in GHG emissions. EPA GHG emission reduction data can 

be correlated to national GHG emission data. 

In 1990, EPA added an inventory of greenhouse gas emissions that covers all sectors of 

the economy, not just the industrial sector. EPA also produced a study in 2007 that 

analyzes trends in energy use since 1970 for many of the same sectors. Both of these 

data sources can be analyzed at a national and a sector level. Comparing each of these 

indicators with Gross Domestic Product data gives a sense of whether a sector has 

reduced GHG emissions and/or energy use relative to GDP. Comparing these data sets to 

each other could also point to whether a sector is using greener energy sources, as can be 

inferred from same-year data points showing a trend of GHG emissions down but energy 

use up. 

Electricity generation, transportation, and industry have consistently accounted for the 

bulk of the nation’s GHG emissions. The following two tables shows trends in all 

greenhouse gases expressed as carbon dioxide equivalents, and comparisons with Gross 

Domestic Product data. 

Greenhouse Gas Emissions Allocated to Economic Sectors

Economic Sector Measured in Tg CO2 Eq

1990 1995 2000 2001 2002 2003 2004 2005

Electricity 

Generation 1859.7 1989.5 2329.9 2292 2300.9 2330.3 2363.5 2429.9 

Transportation 1523 1677.2 1903.2 1876.4 1931.2 1928.2 1982.6 2010.5 

Industry 1470.9 1478.4 1443.5 1395.5 1380 1372.2 1403.8 1347.6 

Agriculture 585.3 589.2 614.3 618.4 602.6 575.5 566.7 600.7 

Commercial 417.8 420.5 415.5 406.6 413.7 433.5 432.6 431.4 

Residential 351.3 375.1 393.6 383.6 382.7 404.8 391.6 380.7 

US Territories 34.1 41.1 47.3 54.5 53.6 60 63.2 61.5 

Total Emissions 6242.1 6571 7147.3 7027.1 7064.8 7104.4 7203.9 7262.3 

Source: Trends in Greenhouse Gas Emissions, Table 2-14 

www.epa.gov/climatechange/emissions/downloads07/07Trends.pdf
44

Comparison of Sector GHG Emissions with GDP 

1990 2005 Change 

GDP 7112.5 GDP 11,003.4 Up 54 % 

Ind (G) 1470.9 Ind (G) 1,347.6 Down 8 % 

Com (G) 417.8 Com (G) 431.4 Up 3 % 

Res (G) 351.3 Res (G) 380.7 Up 8 % 

Tran (G) 1523.0 Tran (G) 2010.5 Up 32 % 

Elec (G) 1859.7 Elec (G) 2429.9 Up 31 % 

Agri (G) 585.3 Agri (G) 600.7 Up 3 % 

US Ter.(G) 34.1 USTer (G) 61.5 Up 80 % 

Total (G) fill in Fill in Up 16 % 

 Source: GDP from x source, GHG emissions from table above. 

Based on these trends, the industrial sector has the clear lead in lowering GHG emissions, 

having been the only sector to achieve an absolute 

reduction in emissions. The commercial and agricultural 

sectors follow next, having clearly slowed their increase in 

emissions relative to growth in GDP. Then comes the 

residential sector, also showing a pace of emission 

increases slower than economic growth. The 

transportation and electricity generation sectors show 

relatively less progress in slowing their rate of emissions. 

U.S. Territories show an increase in emissions that is 

greater than the overall growth of the economy. Further research would be needed to 

evaluate whether economic growth has impacted these sectors differently. 

Energy use. The following tables show energy use across four of the above 

sectors from 1970 to 2006, and comparisons with Gross Domestic Product data. 

The industrial sector has 

decreased its greenhouse gas 

emissions, even as the rest of 

the economy has increased 

emissions. Understanding how 

these reductions came about 

could provide insights to apply 

to other sectors. 
45

Energy Trends 

Source: March 2007 EPA report on “Energy Trends in Selected Manufacturing Sectors ”

Comparison of GDP and Energy Use [need to verify estimation from graph] 

1970 2006 Change 

GDP 3,771.9 GDP 11,319.4 Up > 200 % 

Ind (E) 30,000 Ind (E) 32,500 Up 8 % 

Com (E) 8,500 Com (E) 17,500 Up > 100 % 

Res (E) 13,500 Res (E) 21,500 Up < 60 % 

Tran (E) 16,000 Tran (E) 28,000 Up 75 % 

These trends are longer term, but can be directly compared from 1990 onward. As with 

the prior trends, further research would be needed to evaluate whether economic growth 

over the last 35 years has impacted these four sectors differently. From this snapshot 

view, though, it appears that all sectors have reduced their overall energy use relative to 

economic growth. The industrial sector appears to have an even more solid lead over 

other sectors in reducing relative energy use over the long term. 

Reasons for changes in GHG emissions and energy use. While these data points alone 

cannot answer what caused these reductions, it would be no surprise if economic 

incentives and P2 policy converged as causes. 

• There is a naturally close relationship between energy conservation/efficiency and 

economic incentives, since energy conservation and efficiency practices usually save 

on costs. 

• A possible inference from all four data sets above is there may be some kind of direct 

relationship between economic competitiveness and energy use reductions. 

• On average, most of EPA P2 outreach efforts over the past 17 years have been 

strongly directed at industry, moderately directed at the commercial and agricultural 
46

sectors, and less directed at the residential and transportation sectors. There may be 

some kind of correlation between outreach efforts and national trends. 

• A case which illustrates how P2 and economic incentives can converge is the story of 

sulfur hexafluoride (SF6), the most potent greenhouse gas known (about 22,000 times 

more potent than CO2). The small amounts of SF6 used mostly as an arc-suppressing 

insulator in the electric transmission industry make disproportionately large 

contributions to national GHG emissions. SF6 emissions from the electric power 

sector fell from 26.8 Tg CO2-equivalent in 1990, to 12.5 Tg in 2005, a 53 percent 

reduction. 

A large portion of the reductions occurred in the 

mid-1990’s, as costs for SF6 were rising. At the 

same time, EPA was entering into dialogues with 

the electric power industry about SF6 impacts, and 

this led to the creation of a formal partnership 

program in 1999, the SF6 Emission Reduction 

Partnership for Electric Power Systems. The 

partnership aimed to increase awareness of the 

environmental impact of SF6 emissions, and further 

encourage the adoption of cost-effective leak 

prevention and best management practices. Partners 

join by signing a Memorandum of Understanding

with EPA, and agreeing to establish metrics, baselines and numerical reduction goals 

for their operations. Here the economic incentives and P2 incentives for change 

converged. 

Connections between national trend data and direct program results data. GHG 

provide a case where national trend data and direct program results can be 

connected. 

• The Energy Star Program reported avoiding 35 million metric tons of 

greenhouse gases—35 teragrams or Tg—from energy 

conservation measures in 2005. This equates to 

approximately 0.5 percent reduction in the national GHG 

inventory, a small but significant fraction. 

• SmartWay, a voluntary P2-based effort to reduce GHG 

emissions and other pollutants from trucking and trains 

anticipates CO2 reductions of 1.75 million metric tons in 

2007, or 1.75 Tg of CO2—about 0.1 percent of emissions 

from the transportation sector. The program is targeting 

reductions of 33-66 million metric tons by 2012, roughly on 

par with current Energy Star results. 

• The WasteWise program, which encourages source reduction and recycling of solid 

wastes, electronic goods, and construction materials, has created a preliminary 

methodology for estimating GHG reduction results. Estimates for 2004 are 8.16 

million tons of CO2 equivalents, or another 0.1% reduction in overall emissions. 

P2 in the form of 

energy conservation makes a 

small contribution 

to slowing the 

increase of 

greenhouse gas 

emissions. 

SF6 emissions from electric power systems (Tg CO2 

Eq)

1990 26.8 

1995 21.3 

2000 14.5 

2001 14.4 

2002 13.7 

2003 13.2 

2004 12.9 

2005 12.5 

Source: Table 4-70 

www.epa.gov/climatechange/emissions

/downloads07/07Industrial.pdf
47

Conclusion (23). Interpreting trends in pesticide pollution, in particular, requires 

an understanding of both quantity and relative risk of pesticides being used. EPA 

national pesticide market surveys from 1982-2001 show a drop then leveling off 

in quantity used, but may reflect a shift to lower-volume substitutes. EPA stopped 

collecting market data in 2001. California data from 2001 to 2005 show a trend 

toward higher quantity use of lower-risk pesticides. 

The Office of Pesticide Programs published annual market studies of pesticide use from 

1982 to 2001. This data set captures national trends in waste generation, since pesticides 

are released into the environment. National pesticide use fell about 17 % between 1982 

and 1987, which predates any formal P2 programs at EPA. Some observers speculate the 

drop reflects a shift from organochlorine chemicals to lower-volume substitutes, though 

the actual reasons are not well documented. From 1987 to 2001, national usage held 

fairly constant. 

Source: Pesticides Industry Sales and Usage--2000 and 2001 Market Estimates 

www.epa.gov/oppbead1/pestsales/01pestsales/market_estimates2001.pdf 

The national usage picture ends in 2001. California, the 

largest state user of agricultural pesticides, notes in 

recent materials on its web site there is a trend towards 

using more lower-risk pesticides, based on the California 

Pesticide Use Reporting System. The box on the right 

shows only total volume of CA pesticide use. 

Source reduction for pesticides in particular needs to be 

understood in dimensions of both volume and risk. 

Source reduction is indeed a key environmental 

management option underlying OPP’s Integrated Pest Management program and the 

closely-related Pesticide Environmental Stewardship Program. Reductions in national 

pesticide use could indicate either actions to minimize pesticide use or a switch to lowerTotal pesticide use in CA 

( in million pounds) . 

2001 151 

2002 172 

2003 175 

2004 180 

2005 194 

Source: 

www.cdpr.ca.gov/docs/pur/pur97rep/

pur_anal.htm
48

volume substitutes with possibly higher risk profiles. Increases in pesticide use might 

indicate a switch to high-volume substitutes with lower risk profiles. 

Conclusion (24). Fertilizer data from USDA show fertilizer use leveling off in 

the past decade. 

EPA’s Office of Water does not maintain a national 

database of nutrient budgets from agricultural sources, 

but USDA data are available to document national 

trends in fertilizer use since 1991. The USDA data 

reflect national trends in waste generation since 

fertilizers, like pesticides, are applied directly to the 

environment. As such, efforts to minimize pollution 

from fertilizer use aim for pollution prevention. As 

stated in the Office of Water’s 2003 publication, 

National Management Measures to Control Nonpoint 

Source Pollution from Agriculture: 

While the nutrient management plan may have many 

components, the principle is simple: minimize total 

losses. . . .Effective nutrient management abates nutrient 

movement by minimizing the quantity of nutrients 

available for loss (source reduction). This is usually 

achieved by developing a nutrient budget for the crop, 

applying nutrients at the proper time with proper 

methods, applying only the types and amounts of 

nutrients necessary to produce a crop, and considering the 

environmental hazards of the site. 

The reasons underlying the leveling-off of fertilizer use are not well-established, 

but the trends suggest another example of pollution prevention practices 

contributing to holding the line on overall increases. 

Conclusion (25). TRI source reduction data are helpful to understand sub-trends in 

relative use of source reduction among states and sectors, but in their current state are not 

usable to interpret quantitative national environmental trend data. 

In its 2001 Report, GAO analyzed TRI source reduction reports filed from 1991–1998. It 

found that the [slow but] steady decline in the number of facilities reporting P2 activity 

did not necessarily indicate a decline in the use or impact of P2 measures. GAO noted 

that companies may have begun with simple activities and moved on to more complex 

activities, that the amount of emissions reduced through P2 may not have gone down, and 

that P2 efforts tend to have ongoing emission reduction effects once implemented. 

GAO observed a decline in source reduction reporting from about a third of facilities 

reporting P2 activities in 1991 to about a fourth of facilities reporting P2 activities in 

1998. 

U.S. Fertilizer 

Consumption 

(thousands of tons) 

1991 47,290 

1992 47,794 

1993 49,197 

1994 52,319 

1995 50,744 

1996 53,604 

1997 55,017 

1998 54,954 

1999 53,409 

2000 53,540 

2001 52,258 

2002 52,999 

2003 53,045 

2004 57,830 

2005 55,313 

Source: USDA Economics Research 

Service 

www.ers.usda.gov/Data/FertilizerUs

e/Tables/Table3.xls
49

We have updated this analysis and can now observe that P2 reporting has continued to 

become less frequent since 1998, dropping down now to about 10% of facilities reporting 

annually. Our P2 Integration Assessment workgroup found three possible interpretations: 

industry is less focused on P2, industry is still focused but the easiest P2 steps have 

already been taken, or industry is just less avid in reporting P2. 

 

We sorted TRI source reduction data by state, chemical, and sector to make some 

additional observations. Some of the states with the highest rates of source 

reduction reporting have mandatory P2 reporting/planning programs. Nine of the 

ten chemicals with the highest reporting frequency are high-volume organic 

chemicals. For styrene, over 20% of TRI forms indicate source reduction. Only 

chromium compounds is inorganic. For industry sectors, the range is from a high 

of 20 % in the instruments sector, to less than 5 % for paper, and for metal and 

coal mining.

Conclusion (26) Some gaps in media-specific environmental data exist for 

wastes generated, which is sometimes attributable to the delegated nature of the 

media program, and at other times attributable to methodological changes that 

makes trends difficult to track. Data gaps also exist for trends in the relative risk 

of releases. 

Other data sets from the 1980’s or earlier – inventories of post-treatment air emissions, 

water discharge data, and water quality data – do 

not account for total wastes generated. While the 

National Biennial RCRA Hazardous Waste Report 

reports nationally on hazardous waste generated, 

periodic administrative changes to reporting 

parameters make meaningful comparisons of 

annual data difficult. As just one example, the 

substantial change between 1995 and 1997 stems 

from reclassifying waste waters containing 

hazardous wastes as materials to be regulated 

under the Clean Water Act rather than RCRA. 

While we will not attempt to analyze trends in the relative risk of releases, this kind of 

data would provide more insight on the impact of pollution prevention. Substituting less 

hazardous chemicals for more hazardous ones is a pollution prevention activity. 

Year Haz Waste 

(tons) 

1991 305,708,881 

1993 258,449,001 

1995 214,092,505 

1997 40,676,075 

2001 40,026,050 

2003 30,176,118 

2005 38,347,011
50

1980 1985 1990 1995 2000 2005

National Trends Summary 

Between 1990 

and 2000: 

GDP increased 

38% 

Population 

increased 

12.9% 

MSW increased 

15.8% 

Fertilizer use 

increased 

12.2% 

GHG emissions 

increased 

14.5% 

MSW/capita 

increased 2.9% 

Pesticide use 

decreased 1.2% 

TPWM 

decreased 1.9% 

(from 1992-

2004) 

Industrial GHG 

decreased 2.1% 

SF6 from 

electric power 

industry 

decreased 53% 
51

Evaluation Question #4: What are the Agency’s current measurable goals for 

pollution prevention, especially pertaining to P2 integration? 

Agency goal setting is partially in accord with the P2 Act provision that directs EPA to 

identify, where appropriate, measurable goals reflecting P2 policy. The Agency has 

measurable goals for direct P2 activity, including various partnership activities across the 

Agency. Yet it would also seem appropriate to have measurable goals for P2 integration 

activities so EPA can track the total impact of P2 policy within the Agency. .In earlier 

days, the Agency had some P2 integration goals in its Pollution Prevention Strategy and 

in Strategic Plans. Now, P2 is discussed as a voluntary-only activity in Strategic Plans. 

Even though some partnership-based programs (such as the Climate Change Program) 

essentially set P2 goals, there is no widely accepted Agency methodology for setting up 

and tracking P2 goals across programs. Region 4 is an exception, where media programs 

have been setting P2 goals for a number of years. 

Conclusion (27) The Agency’s Strategic Plans, where Agency goals are presented, show 

a trend away from emphasizing or even acknowledging P2 integration. This affects goals 

relating to P2 integration. 

Recent Agency Strategic Plans characterize EPA as taking a fundamentally voluntary 

approach to P2, yet this represents something of a disconnect from the ongoing P2 

integration activities that occur within the Agency. Before 2002, there were more explicit 

endorsements of P2 integration in Strategic Plans. Since then, the explicit endorsements 

have waned to the point that the Agency has now declared that it meets it P2 Act 

obligations through voluntary P2 approaches, although effective P2 integration work and 

further innovation have continued in some measure to enhance multimedia P2 outcomes, 

expanding into additional realms.

The expansion of partnership programs plus the influence of GPRA/PART may be 

contributing to the Agency depicting in its Strategic Plans that P2 as a voluntary-only 

activity in the Agency, even at a time when Region 4 is doing planning and reporting for 

P2 integration.. The partnership programs have a substantial enough presence and 

provide a simpler planning model for establishing causation between activity and results, 

simpler than P2 integration would provide, which could involve sharing causation. 

In 1994, the strategic plan was full of promise for integrating P2 into all Agency 

programs, and over time that assertion has diminished to its present form, which is a 

statement that EPA intends to meet its P2 goals through voluntary partnerships. There 

have been five strategic plans, and the trend is like a straight line that moves in a steady 

progression from one end of the spectrum to the other. The plans themselves are 

sufficiently detailed to make this progression tellingly clear. The 1994 plan in particular 

is rich in detail, which we present here. 

At one end of the spectrum is the first strategic planning document in response to GPRA, 

the 1994-1999 Strategic Plan. This plan plainly states the Agency’s intention to integrate 

P2 into all Agency activities. EPA will work to prevent pollution by: incorporating 
52

prevention into the Agency's mainstream environmental programs. . .During the next five 

years, EPA will lead the nation in reorienting efforts to reduce and eliminate pollution at 

the source. [P2] will be the first strategy considered for all programs at EPA. The 

Agency meant “all programs” to be inclusive, as clearly portrayed in the specific 

headquarter and regional details in the plan. Similar entries to those below appear in the 

plan for other regions, ORD, OECA, OCEPA (Public Affairs), OIA, OPPE (Policy), 

OPPTS, OSWER, and OW. 

• OAR will emphasize P2 throughout its programs as the first choice in environmental 

protection, taking into account health and environmental impacts. The CAAA provides 

opportunities for making P2 a routine consideration in carrying out air programs and 

reinforcing the major efforts already underway. [Example] a strategy of flexible permits 

will enable . . .sources to commit to P2 as part of compliance strategy. 

• OARM will provide the tools and infrastructure to implement the ecosystem and P2 

approaches to environmental protection. [OARM will facilitate removing institutional 

barriers] in the budget, information systems and data, organizational structures, and 

assistance programs. 

• OGC continues to provide a critical role in identifying the flexibility within EPA's 

statutory authorities to adopt P2 opportunities in EPA regulations, policies, permits, 

guidance documents, and compliance activities.

• OPP [will reduce] the use of pesticides by removing higher-risk pesticides from the 

market, and accelerating regulatory decisions on safer pesticides and promoting increased 

use of integrated pest management techniques....the pesticides program’s P2 priorities 

will focus on promoting sustainable agriculture. 

• Region 1's P2 strategy mandates annual division workplans of new and ongoing efforts to 

integrate P2 into all EPA activities, flexible negotiation of state and tribal grants, and 

development of prevention measures. 

• Region 4 will incorporate P2 into its internal regulatory operations through opportunities 

identified by the Region 4 P2 network. With a separate regional office P2 focus group, 

Region 4 will build P2 into daily office activities and work with the Government Service 

Administration to make the new Atlanta Federal Building a model of environmental 

efficiency.

The trend to the other end of the spectrum began slowly. The 1997-2002 plan still placed 

P2 prominently as a guiding principle for senior management, and as a specific goal (P2 

and reducing risk in communities, homes, workplaces and ecosystems) with a numeric 

outcome target and a numeric behavioral target (e.g., all states would have strong P2 

programs). The 2000-2005 plan maintains Goal 4 on P2 with similar numeric outcome 

targets and a new behavioral target specifically for P2 integration, emphasizes tackling 

high-priority pollutants through P2 and other means, and flags “cost-effective P2 options 

and control options” as ways to address indoor and urban air pollution. 

The 2003-2008 plan is a turning point, the first to present P2 as primarily a voluntaryonly activity, largely limited to a discrete set of P2 programs. It collapses the previous ten 

goals into five, and P2 is subsumed under the emerging concept of environmental 

stewardship (which covers both compliance and beyond compliance behavior like source 

reduction). The disbanding of the high-level P2 Policy Staff in late 2001, which had a 

strong mission-oriented focus on developing P2 language for high-level planning 
53

documents, may have contributed to the lack of consistency between this plan and 

previous plans. The growing GPRA and PART demand on programs to show a causal 

link between activities and outcomes may also have unwittingly created a bias in favor of 

a planning model relying on causality between voluntary P2 activities and outcomes, and 

away from a more complex causal arrangement where P2 results and other program 

results could overlap due to P2 integration. Agency 2004 and 2005 Performance and 

Accountability Reports focus mostly on P2 Program results rather than agency-wide P2 

results. 

The 2006-2011 plan continues the theme of P2 as a set of voluntary-only activities, and 

introduces the notion of “self-directed” P2: To achieve [P2] goals, we will work with 

industrial, governmental, and non-governmental partners to increase the effectiveness of 

voluntary and self-directed approaches that minimize or eliminate the generation of 

pollution. The one exception to this singularly voluntary approach is a Great Lakes 

Program commitment to use “voluntary and regulatory pollution prevention tools” to 

target pollutants of greatest concern. During the public comment period on the draft plan, 

a few states had urged EPA to have the strategic plan indicate that P2 strategies would be 

used under each EPA goal. 

Strategic 

Plan 

Characterization 

1994 plan Pollution prevention will be the first strategy considered for all programs at EPA

1997 plan 1997-2002 Guiding Principle on P2. We will structure our approaches to create incentives 

for preventing pollution and [its transfer across air, water, and land]. The Agency will use a mix 

of tools—including performance standards, economic incentives in national pollution controls, 

and voluntary reductions and other innovative alternatives—in furtherance of EPA's goals. 

1997-2002 Outcome goal. Reduce by 25% (half of this through P2) the amount of toxic 

pollutants released/treated/disposed or combusted for energy.

2000 plan By 2007, EPA will promote the use of P2 by... increasing integration of P2 into EPA's 

regulatory, enforcement, and compliance programs

2003 plan EPA intends to achieve its pollution prevention goals through voluntary partnerships.

2006 plan Theme: The P2 Act of 1990 establishes P2 as a national objective and the P2 hierarchy 

as national policy. EPA intends to achieve its P2 goals through voluntary partnerships. 

EPA will promote partnerships to achieve our [P2] goals and encourage responsible 

stewardship, sustainability, and accountability. 

Approach: The Agency's work is almost entirely dependent on voluntary partnerships, 

collaboration, and persuasion, since there are few environmental regulations that set 

specific source reduction requirements. As P2 activities are voluntary programs, private 

industries will only participate if they expect to find ways to reduce their costs and/or 

improve their profitability.

For a review of Agency Regulatory Plans, as they characterize P2, see Appendix C. 

Regulatory Plans are not a goal-setting activity, but are indicative of what the Agency 

perceives as its most important regulatory and deregulatory actions reasonably expected 

to be accomplished in a given year. 

Conclusion (28) The Agency’s current measurable goals for P2 consist of measurable 

environmental outcome goals for direct P2 activities (including various partnership 

activities cross the Agency), but few measurable goals related for P2 integration 
54

activities. Even though several program use a common indicator for greenhouse gas 

emission reductions, there are generally no other common indicators for use in setting P2 

integration goals across the Agency. Region 4 is an exception, where media programs 

have been setting P2 goals for a number of years. 

EPA’s 2006-2011 Strategic Plan contains quantified P2 outcome goals for the P2 

Program, OSW’s National Partnership for Environmental Priorities, and OECA 

Supplemental Environmental Projects. (See Sub-objective 5.2 -- Prevent pollution and 

promote environmental stewardship). 

Evaluation Question #5. What is the Agency’s current methodology for measuring 

P2, especially with respect to P2 integration? 

The current methodology for measuring P2 has been developed primarily for direct P2 

activities, and is based on measuring reduced quantities of environmental stressors such 

as pounds of pollution (to all media), million metric tons of carbon equivalent (MMTCE) 

reduced (for greenhouse gases, an important sub-category of pollutants), gallons of water 

saved, and costs saved from the adoption of P2 practices. Of these indicators, only the 

greenhouse gas indicator (inherently P2-based) is widely used in the Agency. The other 

indicators are not broadly used in Agency media programs, except in Region 4. 

Conclusion (29) The methodology for measuring results from direct P2 activities is 

based on pounds of hazardous pollutants and materials reduced, million metric tons of 

carbon equivalent reduced, BTUs of energy reduced, gallons of water saved, and dollars 

saved from P2 practices. The methodology for measuring the results from P2 integration 

activities is generally not yet established, except for greenhouse gas emission reductions, 

and in cases where some voluntary programs and Region 4 media programs use the same 

P2-based measures for certain activities. 

Environmental results for direct P2 actions are measured as reductions in pollutant 

releases to all media, and in water and energy conserved. P2 results are basically not 

measurable in ambient environmental terms, because monitoring costs would be 

prohibitive. It is generally accepted that the highest available level in EPA’s hierarchy of 

indicators for measuring P2 results is at the level of measuring changes in quantities of 

environmental stressors – that is, pounds of pollutants reduced, tons of greenhouse gases 

reduced, gallons of water saved, and cost savings from the adoption of P2 practices. 

Relative risk can be factored into pounds of pollution reduced only to the extent of 

distinguishing between pollutants that are regulated (being the more hazardous) and those 

that are not (municipal and industrial solid waste). Pounds of pollution prevented are not 

consistently reported on a chemical-by-chemical basis. An exception to this rule is a list 

of priority pollutants identified for voluntary reductions by the waste program that are 

measured as a subset of pollutant reductions. 

Baselines for measuring environmental results from direct P2 actions are generally 

accepted as needing to start at zero (zero pounds of pollutants reduced, zero gallons of 
55

water conserved, etc.), with each succeeding year adding a quantity of pollutants reduced 

or cost-savings achieved. The alternative – of trying to quantify total national pollution 

from which to subtract pollutant reductions – is generally not feasible because current 

reporting is inadequate for this purpose, modeling costs would be prohibitive, and 

causality links to Agency P2 efforts would be too indirect. An exception to this 

conclusion is that total national greenhouse gas (GHG) emissions are modeled and 

Agency GHG results can easily be correlated to national GHG figures. 

Turning to P2 integration results, the methodology used for measuring direct P2 results is 

generally not replicated in programs where P2 integration occurs, and the differing 

program methodologies make it difficult to identify their P2 integration results. Several 

exceptions exist where programs do employ methodologies based on reducing quantities 

of environmental stressors, and this provides some basis for identifying P2 integration 

results. These exceptions include the broad Agency use of a standard GHG emission 

reduction measure, the use by various partnership programs of pollutant reduction and 

water conservation measures (partnership programs sometimes present a gray area 

between direct P2 activities and P2 integration activities), the use of a solid-wastegeneration rate measure by the waste program (although not easily linked to direct P2 

integration activities), and the use of pollutant reduction and water gallons conserved by 

Region 4 air and water programs. But generally speaking, pollutant reductions 

attributable to media programs’ P2 regulatory options, P2 permitting incentives, P2 

guidance materials and tools, and P2-oriented grants are either lumped together with nonP2 emission reductions, or are not reported because program measures are focused on a 

different level of environmental indicator. 

An example of the former are air toxics emissions, where the measurement methodology 

uses a comparable indicator (reduced quantities of environmental stressors), but doesn’t 

distinguish between control-based and pollution-based emission reductions (total reduced 

tons of air toxics emissions). An example of the latter is the water program’s general 

lack of stressor-based indicators (except for nitrogen and phosphorous nutrient loadings) 

and general use of health-based and ecological-based indicators (e.g., raising the 

percentages of shellfish-growing acres approved for use, raising the percentage of 

communities with drinking water meeting health-based standards),and ambient-based 

indicators (e.g., increasing the number of watersheds whose assessed water segments 

meet water quality standards). Another example of the latter is the waste program’s 

administrative indicator for hazardous waste management, which is to increase the 

number of facilities with hazardous waste permits. 

Evaluation Q #5a. Do Agency methods for measuring P2 conform with the P2 Act 

provision, “Establish standard methods of measurement for source reduction”?

Conclusion (30) The Agency has established standard methods of measuring pollution 

prevention, but they are mostly applied to direct P2 activities, and not P2 integration 

activities, with the exception of the greenhouse gas reduction measure, and pollutant 

reduction and water gallons conserved measures used by some partnership programs and 

the Region 4 air and water programs. The Agency’s measurement methodology for P2 is 
56

based on reductions in environmental stressors, with supplemental administrative 

behavior change measures to solidify the credibility of Agency P2 results. The Agency 

developed its methodology in consultation with States, which strengthens the 

standardization of Agency methodology.. The Agency will need to examine which 

methodologies to employ for measuring its P2 integration results broadly. 

The Agency has used this methodology for several years, and reviews it for continuous 

improvement. This methodology has been used by the Agency mostly for measuring the 

results of direct P2 activities, and the similar State methodology has been used to 

measure a range of P2 activities, including some that could be characterized as P2 

integration.
57

Chapter 4 Recommendations 

Based on the results of this Agency self-evaluation, we have found a variety of possible 

recommendations for Agency managers. Any or all of these suggestions could be set in 

motion now, with some being achievable in the short term, some requiring more steps 

towards achievement in the longer term. 

Before going into these recommendations, we would like to underscore the perennial 

value of pollution prevention in the ongoing evolution of Agency policy goals. As the 

Agency embraces a stewardship policy, on the path from pollution control to pollution 

prevention and sustainability, pollution prevention retains its vitality as a policy goal. 

Stewardship emphasizes the role played by each individual person and organization in 

bringing about environmental improvements, sustainability emphasizes the importance of 

simultaneously achieving environmental, social, and economic goals – and there’s also 

chemical site security, which as a piece of homeland security emphasizes achieving the 

security of hazardous chemicals stored in large quantities, in part through shifting to less 

hazardous chemicals – through them all, pollution prevention has a constant and vital 

policy presence. 

The environmental challenges that remain, even after the substantial progress achieved in 

recent decades, appear bigger in scale and scope than challenges of the past. The choices 

made thus far have taken us a long way towards keeping many waste materials, 

especially industrial waste, out of our air and water. But these same choices have only 

tinkered at the margins of the waste generation processes themselves. 

The focus on chemical security will continue shaping materials handling decisions for 

years to come. If hazardous materials can be minimized – or even eliminated – from an 

industrial process through P2 measures, then potential security concerns regarding the 

material are minimized or eliminated as well. 

 

As new and increasingly exotic materials and nano-materials are introduced into 

commerce, both the opportunities for and the importance of preventing waste at the 

source will likely increase. 

Tackling greenhouse gases calls for shifting to green energy sources and using energy 

more efficiently and, as possible, more conservatively. The G8 group of national leaders 

recently announced a goal for “substantial cuts” to greenhouse gas emissions by 2050, a 

goal clearly beyond slowing down the rate of increase or even holding a straight line, a 

goal that seemingly can only be achieved through very ambitious pollution prevention 

efforts. 

Without a large dose of P2, we are unlikely to make substantial enough changes to our 

“wasteful ways” to bring about a notably more materials-efficient and energy-efficient 

society. 
58

Recommendations 

1. We recommend that the Agency take short-term action on several steps to 

improve the implementation of pollution prevention policy. 

(a) Update key Agency policy documents to renew the Agency commitment to 

integrating pollution prevention across the Agency. An updated expression of 

why P2 integration matters to not only the implementation of the P2 Act but also 

to the implementation of stewardship, sustainability, and chemical site security 

policies would go a long way toward harmonizing Agency policies, and bringing 

coherence to a set of operating principles. Even a few simple statements in the 

policy documents easiest to amend now would set the stage for later, more 

thorough and detailed harmonization of policies. 

− Update the Agency P2 policy to reaffirm P2 as an agency priority and to 

articulate its relationship to sustainability, environmental stewardship, and 

chemical security. 

− Strengthen the role of P2 integration in the Agency semi-annual Regulatory 

Agenda, annual Performance Accountability Reports, and annual National 

Program Manager guidance for various programs. 

(b) Reaffirm existing procedures for prompting regulatory workgroups to consider 

source reduction during regulatory development and to the way the Agency tracks 

the P2 aspects of regulatory development. This includes use of a manager’s 

charge to address source reduction options, workgroup consideration of source 

reduction in the analytic blueprint for each regulatory development action, and 

identification of P2 steps in the RAPIDS database. 

2. Review the Agency’s information collection practices pertaining to P2, with the 

aim of improving overall ease of data collection, coordination between systems, and 

availability of information once collected. 

(a) Examine options for removing some constraints on Agency use of surveys to 

enhance the implementation of pollution prevention policy. The hurdles for 

getting approval of survey questions on source reduction practices are still high 

for the Agency. In the regulatory setting, inability to gather data on source 

reduction practices from industry can eliminate the opportunity for developing a 

P2 option for the performance standard. In the non-regulatory setting, inability to 

gather measurement data on source reduction outcomes which resulted from 

Agency intervention inhibits the implementation of pollution prevention policy in 

program planning and program management. 

(b) Conduct a thorough overview of information collection efforts pertaining to 

waste generation and pollution prevention to identify options for increasing our 
59

understanding or P2 progress. Consider: (i) Why do we have national waste 

generation trend data for some programs and not for others? (ii) How can EPA 

create scalability between national data and EPA program data? (iii) Should TRIstyle data collection be expanded beyond the industrial sector to provide a fuller 

picture of chemical releases and reductions? 

3. Address the need for meaningful P2 guidance in the Agency’s Economic Impact 

Analysis Guidance. 

Where P2 regulatory options would lead to highly variable compliance responses 

based on site-specific, process-specific needs of a facility, predicting compliance 

responses is difficult for purposes of estimating the economic impacts of a rule. 

But not all P2 regulatory options would lead to highly variable compliance 

responses – a less difficult case would be the substitution of flowcoater 

technology for spray gun technology for applying surface coatings. It would be 

helpful to the implementation of pollution prevention policy if economic impact 

analysis guidance addressed the type of P2 regulatory options that will likely have 

sufficient uniformity of compliance responses to enable their estimation. It 

would be further helpful to the implementation of P2 policy if these estimated 

economic impacts of P2 options attributed the economic savings associated with 

the P2 option to the rule, instead of disregarding them on the assumption that 

facilities implement all cost-saving options on their own. Counting the P2 option 

savings would be especially important for offsetting P2 option costs. 

 

4. We recommend that the Agency begin in the short term two processes for more 

thoroughly improving the implementation of pollution prevention policy.

(a) Begin a multi-office consultative process on the development of the Agency 

2009-2014 Strategic Plan, for the purpose of strengthening the role of P2 

integration, and the harmonization of P2 policy with stewardship, sustainability, 

and chemical site security policies, in the 2009 Plan and its strategic goals. 

(b) Begin an inclusive headquarters and regional Agency process to choose 

methodologies for measuring P2 integration activities, since P2 integration is 

important enough to measure. Given the near-term challenge in measuring P2 

outcomes from activities that report to various strategic goals, consider using the 

PPA provisions on P2 integration as a checklist, using internal behavior change 

measures, using an office scorecard, and laying groundwork for tracking P2 

results in media programs. 

5. We recommend that the Agency also begin longer-term processes for addressing 

more far-reaching positive improvements in the implementation of pollution 

prevention policy. 

We recommend taking on two or more of the following issues. 
60

(a) Explore whether there is any transferability of the air program’s regulatory 

approaches – that remove at least one regulatory barrier to P2 for a broad class of 

standards at a time – to the water or waste programs. Three rules of the air 

program, one final and two proposed, apply to broader classes of industry than 

covered in individual industry-based emission standards. In particular, the 

proposed flexible permitting rule and the proposed amendments to general 

provisions of national emission standards for hazardous air pollutants would, 

when final, remove some degree of regulatory inflexibility, a barrier to P2, for 

many of the nation’s industrial businesses emitting hazardous air pollutants. The 

scale of positive impact on source reduction practices will be potentially much 

greater than the Agency has been able to achieve through individual 

environmental performance standards. It would be worth exploring whether there 

is any potential for likewise creating P2 incentives on a broad scale in the water or 

waste regulatory programs. 

 

(b) Explore options for measuring the environmental outcome results from P2 

integration efforts Agency-wide. Environmental outcome measures are more 

relevant to the public, yet most P2 integration environmental results are currently 

tracked under Agency goals like Clean Air and Clean Water (and not under the 

Agency’s Pollution Prevention goal), so they are not distinguishable from the 

non-P2 integration results also reported under these goals. 

− Possible advantages to tracking outcome results for the aggregate of Agency 

P2 integration efforts include: (i) better establishing the relevance of the P2 

policy tool; (ii) providing a fuller set (in combination with P2 Program results) 

of EPA P2 outcome results; (iii) providing a basis for comparing P2 

integration results and P2 Program results, and comparing P2 integration 

results and Agency results broadly; (iv)helping establish a basis for assessing 

the effectiveness of this unequaled legislative policy tool for designing 

consistent policy across EPA programs; (v) providing cyclical feedback for 

planning and managing P2 integration, and providing Agency planners a solid 

reference point for P2 integration for use during high-level and mid-level 

planning operations; (vi) providing important results feedback to state and 

tribal co-regulators, and agency partners and stakeholders; (vii) possibly 

providing a link, depending on other factors, to national environmental 

outcomes. 

(c) Explore ways to assess the effectiveness of NPDES Inspection Manual guidance 

on conducting on-site P2 assessments, and P2 options in “waste” programs. 

(d) Explore whether there are ways to assess the effectiveness of NPDES permitting 

provision on best management practices for P2 and the effectiveness of the 

Pretreatment Program in fostering P2 approaches. 
61

Appendix A 

This appendix lists all data sources used as evidence in the evaluation. Links to web sites 

or electronic files for these data sources are in Appendix B, whose tables provide more 

room for these references. 

Data Source Timeframe 

# of 

Data 

Point

s 

Potential Bias Utility/Limitations 

CONCLUSION 1 

 

Rule and Policy Info. 

Development System 

(RAPIDS) database 

1996-

2006 

492 

There are a large # of 

Not Applicable checkoff’s and blanks in 

response to the P2 

question. Possible 

bias towards No’s, 

from including the 

N/A’s with No’s. 

Allows for a comparison between the number 

of rule developments that considered P2 and 

the total number of rule developments, in a 

relevant time period. 

Limitation: RAPIDS just provides a simple 

Yes/No/N/A on whether P2 will be considered 

during rule development. Potential biases may 

influence comparison results. 

Pollution Prevention in 

Regulations: The Source 

Reduction Review Project 

– An Assessment 

1996 1 Potential bias toward 

internal perspective 

due to having been 

conducted internally, 

although several 

independent sources 

have cited its value. 

Allows for a baseline understanding of what 

the Agency has perceived as the obstacles to 

promoting P2 through regulations. Also allows 

for a comparison between these 1996 

assessment recommendations and the 

Agency’s subsequent P2 integration 

performance. 

Proposed Flexible Air 

Permitting Rule 

9/12/20

07 

1 Bias not a factor. Contributes to quantifying how often EPA 

considers P2 in rulemaking; provides a view 

on the issue not captured in the RAPIDS 

database approach of asking how often 

regulatory workgroups consider source 

reduction. Also provides a view of a 

comprehensive way to promote P2 through 

rules, and contributes to tracking a step-wise 

progression towards policy coherence 

between air permitting and P2. 

2003 Proposed 

Amendment to General 

Provisions of the National 

Emission Standards for 

Hazardous Air Pollutants 

2003 

1 

Bias not a factor Similar utility as the 2007 proposed flexible 

permitting rule in helping to quantify how often 

EPA considers P2 in rulemaking. Also 

provides a view of a comprehensive way to 

promote P2 through rules. 

Limitation: It is not clear how the P2 incentives 

in the 2003 proposal would be intact if the 

2007 proposal went forward. 

2007 Proposed Rule, 

National Emission 

Standards for Hazardous 

Air Pollutants, General 

Provisions 

2007 1 Bias not a factor. Similar utility as the 2003 proposal in helping 

to quantify how often EPA considers P2 in 

rulemaking, and in providing a view of 

proposed comprehensive change.. 

Limitation: It is not clear how the P2 incentives 

in the 2003 proposal would be intact if the 

2007proposal went forward. 

Examples of technical and 

procedural rule-makings 

that set no emission 

standards, extrapolated 

from the Fall 2006 

2006 Potential bias towards Allows initial corroboration of “Not Applicable” 

answers to tracking question, “Has P2 been 

considered in this rulemaking?”. 

Limitations – based on generalized knowledge, 

not in-depth review of example rules, so may 
62

Data Source Timeframe 

# of 

Data 

Point

s 

Potential Bias Utility/Limitations 

Regulatory Agenda. be limited in reliability. More research would 

increase the reliability of this data source. 

CONCLUSION 2 

 

Prevention Pollution 

Through Regulations: The 

SRRP Project – an 

Assessment 

See 

Conclusion 

1 

1 See Conclusion 1 See Conclusion 1 

Federal Register Notices 

for 30 Air Emission 

Standards – EPA’s 

Technology Transfer 

Network, Air Toxics 

Website, 

1993 - 

2004 

30 Bias not a factor. These identify P2 options integrated into 

regulatory emission standards and together 

provide a significant portion of the bigger 

picture view of how the air program integrates 

P2 into its regulatory activities.. Those 

pertaining to the past decade are so indicated. 

Coal Combustion 

Products Partnership Web 

Site 

2003 1 with 

multip

le 

links 

Bias not a factor. Contributes to bigger picture view of how the 

waste program integrates source reduction 

into its management of wastes. And promotes 

source reduction activities at other Federal 

agencies, in a relevant time period. 

Regulatory Determination 

on Wastes from the 

Combustion of Fossil fuels 

2000 1 Bias not a factor. Contributes to bigger picture view of how the 

waste program integrates P2 into its regulatory 

activities in a relevant time period. 

Final rule for Criteria for 

the Safe and 

Environmentally 

Protective Use of Granular 

Mine Tailings Known as 

"Chat" 

2007 1 Bias not a factor. Contributes to the bigger picture view of how 

the waste program integrates source reduction 

into its management of wastes in a relevant 

time period. 

Pulp and Paper 

Rulemaking Actions 

1998 1 Bias not a factor. Provides reference point for 2006 study of 

industry compliance choices for pulp and 

paper water rule. 

Final Report: Pulp, Paper, 

and Paperboard Detailed 

Study 

2006 1 Bias not a factor in 

the part of the study 

cited. 

Provides the number of mills that chose the P2 

option in the rule. 

Stormwater Phase 2 Final 

Rule 

1999 1 Bias not a factor. Contributes to the bigger picture view of how 

the water program integrates source reduction 

into its regulatory activities in a relevant time 

period. 

Federal Register Notices 

for three Significant New 

Use rules 

2002-

2007 

3 Bias not a factor. Provides the bigger picture view of how the 

toxics program integrates P2 into its regulatory 

activities in a relevant time period. 

2003 Proposed 

Amendment to General 

Provisions of NESHAP 

See 

Conclus

ion 1 

 See Conclusion 1. See Conclusion 1. 

2007 Proposed Rule, 

NESHAP General 

Provisions 

See 

Conclus

ion 1 

 See Conclusion 1. See Conclusion 1. 

State comments on 2003 

and 2007 proposed 

amendments to the 

NESHAP General 

Provisions 

2003, 

2007 

2 Bias not a factor. Provides the co-regulator view of the 

regulatory options in both proposals. 

Conventional Reduced 

Risk Pesticide Program 

Web Site 

Current 1 Bias not a factor. Shows that the Food Quality Protection Act 

(1996) mandated that the Agency continue this 

P2-based effort. 

 
63

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

Multi-Year Workplan 

for the Registration of 

Conventional 

Pesticides 

2001, 2003-

3006 

5 Bias not a factor. Provides the raw data for calculating the 

percentage of pesticide registrations that 

are for reduced-risk use of pesticides. This 

allows the impact of the program’s source 

reduction incentive for pesticide 

registrations to be assessed. 

D.C. Circuit Court 

opinion on the 

Hospital/Medical/ 

Infectious Waste 

Incineration Rule. 

1999 1 Bias not a factor. Provides an independent view of 

stakeholders’ interest in having P2 steps 

for mercury addressed in the medical 

waste incinerator rule, which tends to 

verify the relevance of the Hospitals for a 

Healthy Environment partnership program 

to the rule. 

Air program’s web 

site for the medical 

waste incineration 

rule (linkage to 

Hospitals for a 

Healthy Environ-ment 

(H2E) web site). 

Current 1 Bias not a factor. “Related web site” link on the air 

program’s web site for the medical waste 

incineration rule goes to the Memorandum 

of Understanding supporting the H2E 

partnership program, providing another 

indication of the relationship of the 

program to the rule. 

Memorandum of 

Understanding to 

Establish the National 

Vehicle Mercury 

Switch Recovery 

Program 

2006 1 Bias not a factor. Reveals an intention by EPA and other 

parties to coordinate the agreed-to P2 

activity with regulatory requirements. 

National Vehicle 

Mercury Switch 

Recovery Program 

web site 

Current 1 Demonstrates the maintenance of the 

agreement achieved by EPA and other 

parties to jointly conduct a P2 activity that 

is coordinated with regulatory activity. 

CONCLUSION 

3 

 

EPA Guidelines for 

Preparing Economic 

Analyses 

2000 1 Can be compared with the application of 

these guidelines in the Economic Impact 

Analysis of the Boat Manufacturing 

NESHAP. 

Environmental Impact 

Analysis (EIA) for the 

Boat Manufacturing 

NESHAP 

2001 1 Limited data set 

may be biased 

towards not 

counting P2 cost 

savings; yet 

representative of 

P2-technologyspecific data sets. 

Demonstrates an interpretation of the 

2000 Guidelines on Preparing Economic 

Analyses. 

A limitation is the small size of the data 

set. 

CONCLUSION 

4 

 

State Experience 

Integrating Pollution 

Prevention into 

Permits 

1995 1 No apparent bias, 

prepared by an 

EPA contractor. 

Provides a view of an early point in the air 

program’s consideration of how to 

integrate P2 into permitting. 

It is not a totally comprehensive study of 

all state experiences. 

Evaluation of 

Implementation 

Experiences with 

1993-2001 

6 Although data 

may be biased 

towards better 

Shows the air program taking a program 

evaluation step before writing a rule 

approving a technique often used in 
64

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

Innovative Air 

Permits: Results of 

the U.S. EPA Flexible 

Permit 

Implementation 

Review 

performers, 

public 

perceptions are 

included. 

Prepared by two 

offices, in 

consultation with 

3 offices, with 

contractor 

assistance 

tandem with flexible permitting. 

Final Amendments to 

New Source Review 

Rule 

2002 1 Bias not a factor. Can be used as a point of reference 

looking back to the evaluation of flexible 

air permit pilots and forward to the 

proposed flexible air permitting rule. 

Proposed Flexible Air 

Permitting Rule 

See 

Conclusion 1 

 See Conclusion 1 See Conclusion 1 

Guidance Manual for 

Developing Best 

Management 

Practices (water 

program) 

1993 1 Provides an early view of the water 

program direction on P2 in permitting, 

which is to emphasize guidance and the 

use of P2 best management practices. 

Guides to Pollution 

Prevention: Municipal 

Pretreatment 

Program (water) 

1993 1 Developed by the 

research office in 

consultation with 

POTWs. 

Provides an early view of Agency 

outreach to local co-regulators, the 

publicly owned treatment works, on how 

they can promote P2 to facilities that 

discharge to sewer systems. 

This guidance, as well as the guidance 

above and below, can be seen as the 

Agency complying with the P2 Act 

directive to develop guidance for 

permitting, compliance, and enforcement 

personnel at the Federal and State level. 

Local Limits 

Development 

Guidance (water) 

2004 update 

of 1997 

guidance 

1 Bias not a factor. Contributes to the bigger picture of the 

water program’s development of P2 

guidance for States and localities in a 

relevant time period.. 

NPDES Compliance 

Inspection Manual 

(water) 

2004 1 Bias not a factor. Shows that the compliance program has 

contributed a chapter on P2 in their 

guidance on compliance inspections for 

the whole range of water permits 

Developing Your 

Stormwater Pollution 

Prevention Plan: A 

Guide for 

Construction Sites 

2007 1 Bias not a factor. Contributes to the bigger picture of the 

water program’s development of P2 

guidance. 

North Carolina 

Industrial Waste 

Survey 

2005 update 1 Difficult to know if 

bias exists due to 

small sample 

size. 

Allows a view of how a state ensures that 

its POTWs are current in their knowledge 

of dischargers, pollutants, and which 

dischargers may need to become 

significant industrial users. 

East Bay Municipal 

Utility District 

Wastewater 

Department Annual 

Report 

2006 1 Difficult to know 

whether bias 

exists from small 

sample size. 

Allows a view of a NPDES-permit-required 

annual report from a POTW reporting on 

P2 activities. Limited POTW sample size 

restricts knowing whether the level of P2 

activity at this POTW is representative of 

POTWs generally. 

Interview with Mike 

Shapiro, Deputy 

Assistant Admini10/19/2006 1 Bias not a factor. Provides a historical perspective on the 

Underground Injection Control program 

and its relationship to P2. 
65

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

strator (water) 

Waste Minimization: 

Permit Certification 

and Joint Permitting 

(guidance) 

1985 1 Bias not a factor. Provides a view of early P2 guidance to 

permit writers in waste program, where 

statute requires hazardous waste 

generators to have a P2 plan be in place. 

Pollution Prevention 

Solutions During 

Permitting, 

Inspections and 

Enforcement 

(guidance) 

1998 1 Bias not a factor. Additional comprehensive P2 guidance 

from the waste program. A limitation is 

that it is no longer available from an EPA 

web site. 

Email from G. 

Schlicht (Region 7) to 

D. Sarokin, OPPT 

3/21/2007 1 Difficult to know if 

bias due to small 

sample size, 

involvement of 

general counsel 

would offset bias. 

Involved 

Allows a view of an effort to strengthen 

waste minimization in hazardous waste 

permit was deemed unenforceable by 

general counsel. 

Integrated 

Compliance 

Information System 

Database 

1996-2006 1000’s Bias not a factor. Allows quantitative comparison of annual 

totals for enforcement violation actions 

with and without P2, and annual totals of 

enforcement supplemental environmental 

projects with and without P2. 

Role of the EPA 

Inspector in Providing 

Compliance Assistance (report) 

1996 1 Bias not a factor. Allows a view of an options development 

step by the compliance program in the 

shift to a more prevention-oriented 

approach to compliance assurance. 

Inspector’s Compliance Assistance 

Resources Guide 

1999 1 Bias not a factor. Allows a view of a follow-up step that 

equips the compliance inspector with 

needed P2 compliance assistance 

resources. 

Protocol for Conducting Enforcement 

Compliance Audits 

Under the Stormwater 

Program 

2005 1 Bias not a factor. Allows a view of continuing guidance 

development by the enforcement program 

– here for the regulated community – in a 

relevant time period. 

Email from J. 

Berman, OECA, to D. 

Sarokin, OPPT 

11/20/2007 1 Based on a nonrepresentative 

sample of users. 

Provides quantitative data on the annual 

percentage of Compliance Assistance 

Center users that have adopted a P2 

practice as a result of visiting an online 

Center. Can be used as an indicator of 

how effective the Centers are in delivering 

P2 information to target audiences. 

The survey results are based on a nonrepresentative sample of users. 

OECA Sector 

Notebooks 

current 35 Bias is not a 

factor. 

Allows a view of continuing guidance 

materials developed by the compliance 

assurance program in a relevant time 

period. 

CONCLUSION 

5 

 

Region 4 Pollution 

Prevention Strategy 

and Action Plan 

1997 1 There is little 

potential bias for 

comparison at the 

regional level, as 

Regions are 

inherently similar. 

Allows for a comparison of P2 integration 

models within the Agency; provides a 

working example of P2 planning being 

done by media programs. 

Region 4 is generally representative of the 

basic regional structure within the Agency, 
66

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

There is perhaps 

some potential 

bias for 

comparison with 

Headquarters, 

although regional 

& HQ 

organizations are 

not dissimilar. 

although regional organization is flexible 

region to region. Region 4 is nearly 

representative of Agency headquarters 

structure. 

Region 4 Draft P2 

Program Logic Model 

2005 1 Same as above. Allows for a comparison of P2 integration 

models within the Agency; provides a 

working example of P2 planning being 

done by media programs. 

The degree to which Region 4 represents 

the organization of other Regions and 

Headquarters is the same as above. 

Region 8 Report: The 

Keys to Success: A 

Compilation of 

Workable P2 Integration Techniques 

2001 1 Bias is not a 

factor 

Allows a view of guidance developed 

specifically on the topic of P2 integration. 

CONCLUSION 

6 

 

Inventory of EPA 

Partnership Programs 

2007 1 Bias is not factor. Allows a view of the scale and scope of 

partnership programs within the Agency 

today. 

Energy Star web site 2007 1 Bias is not a 

factor. 

Allows a view of a voluntary program that 

collaborates with another federal agency 

and has a vast number of partners 

Healthcare 

Environmental 

Resource Center web 

site 

2007 1 Bias is not a 

factor. 

Constitutes direct evidence of a 

collaboration between a then-partnership 

program and the compliance assurance 

program. 

Federal Electronics 

Challenge web site 

2007 1 Bias is not a 

factor. 

Provides basic information on the 

partnership program. 

Executive Order 

13423, Strengthening 

Federal Environmental, Energy, and 

Transportation 

Management 

2007 1 Bias is not a 

factor. 

Allows for a comparison of the Executive 

Order requirement and the Federal 

Electronics Challenge partnership 

program. 

Instructions for 

implementing 

Executive Order 

13423 

2007 1 Bias is not a 

factor. 

Allows for a comparison of the Executive 

Order requirement and the Federal 

Electronics Challenge partnership 

program. 

CONCLUSION 

7 

 

Healthy School 

Environments 

Assessment Tool 

Current 1 Bias is not a 

factor. 

Contributes to the bigger picture view of 

P2 approaches that EPA programs other 

than regulatory and partnership programs 

employ. 

Biopesticide 

Demonstration 

Program 

 1 Bias is not a 

factor. 

Contributes to the bigger picture view of 

what the pesticide program does to 

promote source reduction. 

Pollution Prevention 1998 1 Peer reviewed. Allows a view of the accountability and 
67

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

Research Strategy budget-based approach that the research 

and development program took to 

integrating P2 into its programs. 

Provides a basis for comparison with 

Region 4’s P2 integration approach, which 

also employs a strategy and work plan 

that could be viewed as accountability and 

budget based. 

Report: Technology 

for a Sustainable 

Environ-ment Grant 

Program: a Decade of 

Innovation 

2006 1 Provides accountability for the P2 

Research Strategy in terms of research 

results. 

Source Reduction 

Program Potential 

Manual 

1997 1 Contributes a view of non-regulatory P2 

steps to the total picture of what the waste 

program does to promote source 

reduction. 

ReduceIt software 1997 Contributes a view of non-regulatory P2 

steps to the total picture of what the waste 

program does to promote source 

reduction. 

Guide for Industrial 

Waste Management 

unknown 1 Contributes a view of non-regulatory P2 

steps to the total picture of what the waste 

program does to promote source 

reduction. 

Sustainable Futures 

Initiative (tools) 

2002 1 Contributes to the bigger picture view of 

how the toxics program integrates P2 into 

its program activities in a relevant time 

period. 

Final Guidance on 

Awards of Grants to 

Indian Tribes under 

Section 106 of the 

Clean Water Act 

2006 1 Bias not a factor. Contributes to the bigger picture view of 

how the water program integrates P2 into 

its program activities in a relevant time 

period. 

National Management 

Measures to Control 

Nonpoint Source 

Pollution from Urban 

Areas 

2005 1 Bias not a factor. Contributes a view of non-regulatory P2 

steps to the total picture of what the water 

program does to promote source 

reduction. 

CONCLUSION 

8 

 

Preventing Pollution 

Through Regulations: 

The SRRP Project – 

An Assessment 

See 

Conclusion 1 

 See Conclusion 1 See Conclusion 1. 

CONCLUSION 

9 

 

U.S. GAO Report, 

EPA Should Strengthen its Efforts to 

Measure and 

encourage Pollution 

Prevention 

2001 1 GAO Reports are 

considered 

independent 

evaluations. 

Allows for a reduction in the potential bias 

of the 1996 Assessment, since GAO relies 

on some these 1996 conclusions as 

reinforcement for its own conclusions. 

Also allows for a comparison between its 

main recommendation and EPA’s 

subsequent P2 integration performance. 
68

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

CONCLUSION 

10 

 

Region 4’s P2 

Strategy and Action 

Plan 

See 

Conclusion 5 

 See Conclusion 5 See Conclusion 5. 

Persistent, Bioaccumulative and Toxic 

(PBT) Chemicals 

Planning and 

Budgeting Document 

For FY 2004 1 Small potential 

for bias; there 

were 5 more 

years where 

similar crossprogram budgets 

were prepared. 

Generally 

representative of 

other PBT 

planning budget 

documents. 

Allows a view of an integrated annual 

budget and planning document covering 

ten offices for multimedia and P2 activities 

affecting persistent, bioaccumulative, and 

toxic chemicals. 

CONCLUSION 

11

 

Targeted P2 Rules See 

Conclusions 

2 & 3 

 See Conclusions 

2 & 3 

See Conclusions 2 & 3 

CONCLUSION 

12

 

Flexible rules See 

Conclusions 

2 & 3 

 See Conclusions 

2 & 3 

See Conclusions 2 & 3 

CONCLUSION 

13

 

Information Collection 

Requests 

 Not a factor. 

CONCLUSION 

14 

 

Report: Everyday 

Choices: 

Opportunities for 

Environmental 

Stewardship 

2005 1 Bias not a factor. Allows a view of the coordination function 

that the Innovative Action Council plays 

for partnership programs regarding 

source reduction. 

CONCLUSION 

15 

 

Office Directors’ 

Multimedia Pollution 

Prevention Forum 

Charter 

1998 1 Bias not a factor. Allows 

NASCAR Agreement 

on Unleaded Fuel 

 Not a factor. 

Memorandum of 

Understanding to 

Establish the National 

Vehicle Mercury 

Switch Recovery 

See 

Conclusion 2 

 See conclusion 2. See Conclusion 2. 
69

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

Program 

CONCLUSION 

16 

 

Email attachment 

describing 

Environmental 

Assistance Network 

 Not a factor. 

CONCLUSION 

17 

 

Pollution Prevention 

Research Strategy 

See 

Conclusion 7 

 See Conclusion 

7. 

See Conclusion 7. 

CONCLUSION 

18 

 

Incorporating EPA’s 

P2 Strategy into the 

Environmental 

Review Process 

1993 1 Not a factor. 

Executive Order 

13423 and 

Instructions for 

Implementation 

See 

Conclusion 6 

 See Conclusion 

6. 

See Conclusion 6. 

CONCLUSION 

19 

 

P2 Coordination Not a factor 

CONCLUSION 

20 

 

Toxics Release 

Inventory 

1998, 2004 2 Bias towards TRIlisted chemicals 

and sectors and 

companies with 

more than 10 

employees. 

Provides a national view of total 

production wastes generated, and a basis 

for comparing wastes generated to 

economic growth. 

There are limitations on the data because 

not all wastes are required to be reported. 

Statistical Abstracts 

of the United States 

1992-2004 24 None. Viewed as 

the authoritative 

and 

comprehensive 

summary of 

statistics on the 

social, political, 

and economic 

organization of 

the United States. 

Provides the authoritative national 

statistics on economic growth, which 

provide a basis for comparing economic 

growth with total national wastes 

generated. 

CONCLUSION 

21 

 

Municipal Solid 

Waste in the U.S: 

2005 Facts, Figures 

1960-2005 8 The materials 

flow methodology 

used is preferred 

The consistency of the Agency’s 

methodology and scope over time for 

measuring municipal solid waste makes 
70

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

over a sitespecific 

methodology 

(site-specific can 

be skewed by 

atypical 

circumstances 

during sampling). 

this report useful for tracking trends over 

time. 

Virtually no limitations; the only thing not 

accounted for are residues left in such 

things as jars and cans. 

CONCLUSION 

22 

 

Inventory of U.S. 

Greenhouse Gas 

Emissions and Sinks: 

1990-2005 

2007 None. These are official 

data sub-mitted to the UN, 

following UN methodology 

guidance, reviewed by 

experts and public at 

large. 

Provides GHG emission trend data for the 

major sectors of the economy, allows for 

indexing data to Gross Domestic Product 

so GHG emissions by major economic 

sector an be compared to economic 

growth by major economic sector. 

Statistical Abstracts 

of the U.S. 

See 

Conclusion 

20 

 See Conclusion 20. See conclusion 20. 

Energy Trends in 

Selected 

Manufacturing 

Sectors 

2007 None for trends of major 

sectors of economy, which 

are from an authoritative 

source (Energy 

Information 

Administration). 

Provides energy use trend data for the 

major sectors of the economy, allows for 

indexing data to Gross Domestic Product, 

so energy use by major economic sector 

can be compared to economic growth by 

major economic sector 

SF6 Emissions 

Reduction 

Partnership for 

electric Power 

Systems web site 

Current 1 Bias is not a factor. The partnership is illustrative of the 

convergence of economic and P2 

incentives. 

Data Source Timeframe # of 

Data 

Point

s 

Potential Bias Utility/Limitations 

Energy Star – 

Overview of 2005 

Achievements 

(report) 

2005 1 No known bias. Quantifies greenhouse gas (GHG) 

emission reductions from Energy Star 

activities in 2005. Allows a view of the 

common measurement methodology used 

at the program and national levels. 

Toward a Cleaner 

Future: Office of 

Transportation and 

Air Quality Progress 

Report 

2005 1 No known bias. Contributes a quantified target of GHG 

emission reductions from the SmartWay 

program to total Agency results for GHG 

emission reductions; allows a comparison 

of measure methodology for GHG 

emission reductions. 

Waste Wise 2005 

Annual Report 

2005 1 No known bias. Contributes a quantified result of GHG 

emission reductions from the WasteWise 

program to total Agency results for GHG 

emission reductions; allows a comparison 

of measure methodology for GHG 

emission reductions. 

Federal Electronics 

Challenge (FEC): 

Measurement 

Spreadsheet 

2007 1 No known bias. Contributes a quantified result of GHG 

emission reductions from the FEC 

program to total Agency results for GHG 

emission reductions; allows a comparison 

of measure methodology for GHG 

emission reductions. 
71

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

Electronic Product 

Environment 

Assessment Tool 

(EPEAT): 

Measurement 

Spreadsheet 

2007 1 No known bias. Contributes a quantified result of GHG 

emission reductions from the EPEAT 

program to total Agency results for GHG 

emission reductions; allows a comparison 

of measure methodology for GHG 

emission reductions. 

CONCLUSION 

23 

 

Pesticide Industry 

Sales and Usage 

2000 and 2001 

Market Estimates 

1982-2001 19 Difficult to assess bias. Allows a view of national pesticide sales 

and use (quantities of active ingredient) 

on an annual basis. Uses best available 

information from the public domain and 

proprietary sources. The numbers in the 

report represent approximate values 

rather than precise values. 

Contributes to big picture view of national 

data that can be assessed for the impact 

of source reduction practices. 

California Department 

of Pesticide 

Regulation: Analysis 

of Pesticide Use 

Trends 

2001-2005 5 Bias as a surrogate stems 

from limited data set. 

Provides a surrogate for national pesticide 

use trends. Limitations on data 

methodology are stated in the reports. 

Contributes to big picture view of national 

data that can be assessed for the impact 

of source reduction practices. 

CONCLUSION 

24 

 

USDA Economic 

Research Service 

Data Set – U.S. 

Fertilizer Use and 

Price 

1990-2005 15 Allows a view of national trends in fertilizer 

use. Contributes to big picture view of 

national data that can be assessed for the 

impact of source reduction practices. 

National Management 

Measures to Control 

Non-point Source 

Pollution from 

Agriculture 

2003 1 No known bias. Allows an interpretation of efforts to 

minimize pollution from fertilizer use 

necessarily involving a P2 orientation. 

Data Source Timeframe # of 

Data 

Points 

Potential Bias Utility/Limitations 

CONCLUSION 

25 

 

US GAO, 2001 

Report 

2001 8 None. GAO reports are 

viewed as independent. 

Allows for a comparison in analyzing 

earlier and later reporting trends for TRI 

source reduction reporting 

ics Release Inventory 

– Source Reduction 

Data 

1991-2005 14 Bias towards TRI-listed 

chemicals and sectors 

and companies with more 

than 10 employees. 

Allows for a comparison of year-to-year 

reporting trends, and sub-trends within 

sectors and States. There are limitations 

on the data because not all wastes are 

required to be reported. 
72

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

CONCLUSION 

26 

 

Biennial Reporting 

System 

1991-2005 7 Inconsistent 

methodologies make 

detecting bias difficult. 

Does not allow for a meaningful 

comparison of annual national quantities 

of hazardous wastes generated, due to 

inconsistencies in reporting parameters. 

CONCLUSION 

27 

 

EPA Strategic Plans 1994-2006 5 No apparent bias. Allows for the comparison of formal 

Agency-wide planning guidance and 

goals, as an indicator of policy coherence, 

in the baseline years of P2 integration 

efforts and later years of P2 integration 

efforts. 

CONCLUSION 

28 

 

EPA Strategic Plan 

2006 

See 

Conclusion 

27 

1 

See Conclusion 27 See Conclusion 27 

Region 4 draft P2 

Program Logic Model 

See 

Conclusion 

5 

1 

See Conclusion 5 See Conclusion 5 

CONCLUSION 

29 

 

EPA Strategic Plan 

2006 

See 

Conclusion 

27 

1 

See Conclusion 27 See Conclusion 27 

EPA’s Hierarchy of 

Measurement 

Indicators 1 

Bias is not a factor Allows a characterization of direct P2 

measures and P2 integration according to 

the levels of measures outlined in EPA’s 

hierarchy of indicators. 

Region 4 actual 

results submitted to 

P2 Program for 

FY2005 

2005 

1 

 Confirms that Regional media programs 

reported FT 2005 P2 results 

CONCLUSION 

30 

 

EPA Evaluation of 

Implementation 

Experiences with 

Innovative Air 

Permits: 

1993-2001 6 

Although data may be 

biased towards better 

performers, public 

perceptions are included. 

Allows a view of an incremental EPA 

planning step in the evolution of air policy 

on aligning the regulatory framework with 

increasingly competitive market demands 

and pollution prevention policy. 

New Source Review 

Improvement Rule 2002 

? 

Is there at data set on 

implementation 

experience? 

Portrays an incremental EPA regulatory 

step of broad applicability to use Plantwide Area Limits for determining 

applicability of New Source Review 

requirements, an important technique 

often used in tandem with flexible air 
73

Data Source Timeframe # of Data 

Points 

Potential Bias Utility/Limitations 

permitting approaches, which reduce 

barriers to P2. 

Proposed Flexible Air 

Permitting Rule 2007 1 

Still in proposal stage Portrays a proposed version of a 

conclusive EPA regulatory step of 

broadest applicability to allow flexible 

operating air permits. Allows for tracking 

a progression of planning steps towards 

achieving policy coherence between air 

permitting and P2. 

 
74

Appendix B 

Evaluation Question 1: How does the Agency currently consider the effect of its 

programs and regulations on source reduction efforts?

Conclusion 1. The Agency tracks how often regulatory workgroups consider 

the effects of individual rulemakings on source reduction efforts, which is 

nearly a fourth of the time. This may be closer to half the time when two 

proposed air program actions affecting a broad class of regulatory standards 

are taken into account. Better quality data are needed to verify what 

impedes more routine consideration of P2 in rules, to confirm or revise the 

internal obstacles to promoting P2 through regulations the Agency identified 

in 1996. 

Data Element 

Evidence Evaluated to Reach 

Conclusion 

Rule and Policy Information Data System 

(RAPIDS database) 

Provides evidence that the Agency tracks 

whether regulatory workgroups consider the 

effect of their rules on source reduction, and 

provides the percentage of rulemakings from 

1996 to 2006 where regulatory workgroups 

considered source reduction. 

Pollution Prevention in Regulations: The 

Source Reduction Review Project – An 

Assessment (1996) 

http://www.epa.gov/oppt/p2home/pubs/docs/srrp.txt

Provides the Agency’s previous assessment of 

obstacles that regulatory workgroups face 

when considering the impact of rules on source 

reduction. 

Proposed Flexible Air Permitting Rule 

9/12/07 

http://www.epa.gov/fedrgstr/EPAAIR/2007/September/Day-12/a17418.pdf

Provides evidence of: (1) the number of air 

rules affected by the proposed flexible 

permitting rule, to show that the impact of 

these air rules was considered on source 

reduction; and, (2) the regulatory option 

provided that is beneficial for source reduction 

practices (the use of advance permitting 

approvals and alternative [reasonably 

anticipated] operating scenarios, allowing P2 

projects to be undertaken without the delay and 

uncertainty of future case-by-case approvals). 

2003 Proposed Amendment to General 

Provisions of the National Emission Standards 

for Hazardous Air Pollutants 

http://www.epa.gov/ttn/atw/gp/fr15my03.pdf

Provides evidence of: (1) the number of air 

rules affected by the proposal, which helps to 

quantify the extent to which EPA considers P2 

in rulemaking; and, (2) the regulatory option 

provided for affected sources, from which a 

conclusion can be reached about the effect the 

proposal would have on source reduction. 

2007 Proposed Rule, National Emission 

Standards for Hazardous Air Pollutants, 

General Provisions 

Provides evidence of: (1) the number of air 

rules affected by the proposal, which helps to 

quantify the extent to which EPA considers P2 
75

Data Element 

Evidence Evaluated to Reach 

Conclusion 

http://www.epa.gov/fedrgstr/EPAAIR/2007/January/Day-03/a22283.htm in rulemaking, and (2) the regulatory option 

provided major sources, from which a 

conclusion can be reached about the effect the 

proposal would have on source reduction. 

Examples of technical and procedural 

rulemakings that set no emission standards, 

extrapolated from the Agency’s Fall 2006 

Semi-Annual Regulatory Agenda. 

Provides preliminary evidence that tends to 

corroborate the 34% of “Not Applicable” 

answers from regulatory workgroups 

responding to the RAPIDS question, “Will 

source reduction options be considered in the 

development of this action?” 

Conclusion 2.. Although the P2 Act does not mandate that the Agency take a 

particular approach in considering the effect of regulations on source 

reduction, the Agency uses its review of individual regulations to identify 

opportunities to create compliance approaches based on P2 practices. In the 

past decade, most opportunities for developing P2 compliance approaches 

have been in the air program, which has a large regulatory agenda. To 

promote P2 approaches, the air program uses individual standards and 

actions affecting an entire class of rules, which can be very effective if 

carefully done. The smaller regulatory agendas of other programs present 

relatively fewer opportunities for promoting P2 compliance approaches. In a 

few cases, partnership activity has worked to enhance P2 compliance 

approaches for a given rule. There is room for expanding the use of all 

Agency methods for facilitating the adoption of P2 through rules. 

Data Element Evidence Evaluated to Reach Conclusion 

Preventing Pollution Through Regulations: 

The Source Reduction Review Project (SRRP): 

An Assessment (1996) 

http://www.epa.gov/oppt/p2home/pubs/docs/srrp.txt

Provides the Agency’s previous assessment of 

obstacles that regulatory workgroups face 

when considering the impact of rules on source 

reduction. 

Air program: Federal Register Notices for 30 

emission standards – EPA’s Technology 

Transfer Network, Air Toxics Website, 

National Emission Standards for Hazardous 

Air Pollutants 

http://www.epa.gov/ttn/atw/mactfnlalph.html

Click on source category, find original final rule. 

Web site provides links to all final air 

standards listed on pages 23-24 of our 

evaluation. Preamble language (often under 

“what are the emission limits?”) and rule 

language (often under “what limits must I 

meet, what work practices must I meet?”) 

provides evidence of the quantity and quality 

of effects of air rules on source reduction. 

Waste program: Coal Combustion Products 

Partnership 

http://www.epa.gov/epaoswer/osw/conserve/c2p2/i

ndex.htm

Regulatory Determination on Wastes from the 

The partnership materials and the regulatory 

determination provide evidence that the waste 

program pursues a policy of beneficial reuse of 

coal combustion wastes to reduce mining and 

processing virgin material and their associated 
76

Data Element Evidence Evaluated to Reach Conclusion 

Combustion of Fossil Fuels (2000) 

http://www.epa.gov/epaoswer/other/fossil/ff2ffr.pdf

pollution and GHG emissions. 

Waste program: Final rule for Criteria for the 

Safe and Environmentally Protective Use of 

Granular Mine Tailings Known as ``Chat'' 

(2007)

http://www.epa.gov/fedrgstr/EPAWASTE/2007/July/Day-18/f13544.htm

The rule provides evidence that the waste 

program pursues a policy of beneficial reuse of 

“chat” granular mine tailings to reduce mining 

and processing virgin material and their 

associated pollution and GHG emissions. 

Water program: Pulp and Paper Rulemaking 

Actions 

http://www.epa.gov/waterscience/guide/pulppaper/c

luster.html

Water program report: Final Report: Pulp, 

Paper, and Paperboard Detailed Study (2006) 

http://www.epa.gov/waterscience/guide/304m/pulpfinal.pdf

The follow-up study on the pulp and paper rule 

provides evidence of the effect this significant 

P2-oriented rule of the water program has had.. 

Water program: Stormwater Phase 2 Final 

Rule (Dec. 1999) 

http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=1999_register&docid=fr08

de99-11.pdf

see Federal Register page 68736 

This rule, which requires small municipal 

separate storm sewer systems to have 

stormwater management programs, with P2 

being a mandatory component of such a 

program, provides evidence of the water 

program integrating P2 into rulemaking. 

Toxics program: Federal Register Notices for 

three Significant New Use Rules 

http://www.epa.gov/fedrgstr/EPATOX/2007/October/Day-09/t19828.htm

(PFAS/PFOA, 2007) 

http://www.epa.gov/fedrgstr/EPATOX/2006/June/Day-13/t9207.htm (PBDE, 2006) 

http://www.epa.gov/fedrgstr/EPATOX/2007/October/Day-05/t19705.htm (mercury, 

2007)

These three final significant new use rules 

(which limit the ability to reintroduce chemical 

uses of concern back into the marketplace once 

removed from the marketplace) provides 

evidence of how the toxics program integrates 

P2 into regulations. 

Air program: 2003 Proposed Amendment to 

General Provisions of the National Emission 

Standards for Hazardous Air Pollutants 

http://www.epa.gov/ttn/atw/gp/fr15my03.pdf

2007 Proposed Rule, National Emission 

Standards for Hazardous Air Pollutants, 

General Provisions 

http://www.epa.gov/fedrgstr/EPAAIR/2007/January/Day-03/a22283.htm

The 2003 proposed amendment provides 

evidence of the air program pursuing the 

creation of a P2-only incentive for a broad 

class of regulatory standards. 

The 2007 proposed amendment provides 

evidence of the air program proposing a 

contrasting approach affecting the same broad 

class of regulatory standards. 

State comments on the 2003 and 2007 

proposed amendments to the General 

Provisions of the NESHAP cited above. 

http://www.4cleanair.org/Documents/OIAIrulecom

ments5307.pdf

http://www.4cleanair.org/Documents/OIAIP2comm

ents.pdf

Provides contextual evidence concerning the 

air program’s 2003 and 2007 proposed 

amendments to the General Provisions of the 

NESHAP. 

Pesticides program: Conventional Reduced 

Risk Pesticide Program Website - 

Provides evidence of the pesticides program 

using a broad P2 policy incentive for all 
77

Data Element Evidence Evaluated to Reach Conclusion 

http://www.epa.gov/opprd001/workplan/reduc

edrisk.html

pesticide registration applications. 

Pesticides program: Multi-Year Workplan for 

the Registration of Conventional Pesticides - 

http://www.epa.gov/opprd001/workplan/

Provides the total number of registrations for 

pesticides and reduced-risk pesticides for 2001 

and 2003-2006; used to calculate the 

percentage of registration decisions on 

reduced-risk pesticides during those years. 

DC Circuit Court opinion on the Hospital/ 

Medical/Infectious Waste Incinerator rule 

http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html

see rule information, litigation update, for court opinion

Provides evidence that stakeholders were 

interested in having the medical waste 

incinerator rule adopt a pollution prvention 

approach to reduce mercury emissions. 

Technology Transfer Network, Air Toxics 

Website (Hospital/Medical/Infectious Waste 

Incinerators – click “related web sites,” then 

Memorandum of Understanding, then link to 

Hospotials for Healthy Environment (H2E) 

website, About H2E, Goals)

http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html

The working web link between the medical 

waste incinerator rule and the voluntary 

Hospitals for a Healthy Environment Program 

(and its goal of virtual elimination of mercury 

at healthcare facilities) provides evidence of 

how P2 partnership programs can complement 

regulatory standards. 

Memorandum of Understanding to Establish 

the National Vehicle Mercury Switch 

Recovery Program 

http://www.epa.gov/mercury/pdfs/switchMOU.pdf

National Vehicle Mercury Switch Recovery 

Program website

http://www.epa.gov/hg/switchfs.htm

This partnership agreement (on the removal of 

automotive mercury switches) and the fact 

sheet explaining the agreement’s relationship 

to air rules for steel mills provides evidence 

that partnership programs can be developed to 

complement regulatory standards. 

Conclusion 3. To assist regulatory workgroups that develop P2 options for 

regulatory standards, Agency guidance on analyzing the economic impacts of 

regulatory actions could more clearly address how to handle cost savings 

associated with responses to P2 options. 

Data Element Evidence Evaluated to Reach Conclusion 

EPA Guidelines for Preparing Economic 

Analyses (2000) 

http://yosemite/epa/gov/ee/epa/eed.nsf/webpages/G

uidelines.html/$file/Guidelines.pdf

See page 27 

The discussion of estimating responses for P2 

policy options on page 27 provides evidence of 

a possible gap in guidance on how to address 

cost savings associated with responses to P2 

policy options. 

Environmental Impact Analysis for the Boat 

Manufacturing NESHAP (2001) 

http://www.epa.gov/ttnecas1/regdata/EIAs/boateia.

pdf

See page 3-2, and page 3-5. 

The discussion of assumptions indicates that 

savings from P2 options were counted as zero 

in this rulemaking on the assumption that 

facilities change to cost-saving processes on 

their own once capital depreciation occurs. 

Conclusion 4. P2 integration efforts in Agency permitting, enforcement, and 

compliance programs grew out of training and guidance the Agency 

developed for EPA and State personnel in the 1990’s. Major permitting 

programs (except for the underground injection program) have P2 

components. Evaluation data from 2001 on the air program’s pilot approach 
78

was positive, and the program has developed two rules to implement the pilot 

approach on a widespread basis. Data gaps for the water and waste 

permitting programs make them difficult to evaluate, although limited data 

are positive for the water pretreatment permitting approach to P2. Recent 

data shows nearly a sixth of enforcement complying actions have a P2 

component. The compliance program offers several P2 incentives, and has 

survey data showing that the regulated community takes P2 action based on 

Agency compliance resources. 

Data Element Evidence Evaluated to Reach Conclusion 

Air program report, State Experience 

Integrating Pollution Prevention Into Permits 

(1995) 

http://www.epa.gov/ttn/oarpg/t5/memoranda/permit

s.pdf

This report identified various approaches for 

integrating P2 into permits, including flexible 

air permits. This provides evidence that the air 

program scoped out its options for integrating 

P2 into the air permitting process. 

Air program report, Evaluation of 

Implementation Experiences with Innovative 

Air Permits: Results of the U.S. EPA Flexible 

Permit Implementation Review (2001) 

http://www.epa.gov/ttn/oarpg/t5/memoranda/iap_ei

er.pdf

This report evaluates a several-year air 

program pilot in flexible permitting. This 

provides evidence of continuing steps by the 

air program to develop its approach to 

promoting P2 and accommodating market 

demands in permits. 

Final air rule: Prevention of Significant 

Deterioration and Nonattainment New Source 

Review Baseline Emissions Determination, 

Actual-to-Future-Actual Methodology, 

Plantwide Applicability Limitations, Clean 

Units, Pollution Control Projects (2002)

http://a257.g.akamaitech.net/7/257/2422/14mar200

10800/edocket.access.gpo.gov/2002/pdf/02-

31899.pdf

This rule amended the New Source Review 

program to, among other things, allow plantwide applicability limits (PAL), a bubble 

approach often used in tandem with flexible 

permitting. This shows the air program laying 

part of a regulatory foundation for governing 

flexible air permit development to facilitate P2. 

Legal challenges to the rule have not affected 

the PAL. 

Proposed air rule: Proposed Flexible Air 

Permitting Rule (2007) 

http://www.epa.gov/fedrgstr/EPAAIR/2007/September/Day-12/a17418.pdf

This proposed rule would allow the use of 

advance permitting approvals and alternative 

operating scenarios by all Clean Air Act Title 

V permit holders and State new source review 

programs. This provides evidence that the 

Agency has followed up on its 1996 

recommendations to broaden the flexibility of 

regulatory requirements to advance P2, and to 

emphasize permitting as a means of promoting 

P2. 

Water program permitting guidance: Office of 

Water Guidance Manual for Developing Best 

Management Practices (1993) 

http://yosemite.epa.gov/water/owrccatalog.nsf/065c

a07e299b464685256ce50075c11a/e563877d0cd4b5

7785256b0600723b4d!OpenDocument

This early guidance for the regulated 

community and citizens shows the water 

program emphasizing early on the use of P2 

best management practices as a basis for 

complying with pretreatment permits.. 

Water program permitting and inspection 

guidance: Guides to Pollution Prevention: 

Municipal Pretreatment Program (1993) 

This early guidance for publicly owned 

treatment works on promoting P2 to industrial 

dischargers through inspections, outreach, and 
79

Data Element Evidence Evaluated to Reach Conclusion 

http://www.p2pays.org/ref/01/00738.pdf permits, together with other 1993 guidance 

above, shows in provides evidence similar to 

that just above. 

Water program permitting guidance: Local 

Limits Development Guidance (2004) 

http://www.epa.gov/npdes/pubs/final_local_limits_

guidance.pdf

(update to 1987 guidance; see section 6.6 for 

discussion of P2 best management practices as a 

basis for local limits)

This updated guidance for States and POTWs 

addresses the development of local limits 

which, together with national categorical 

standards, make up pretreatment limits. P2 

best management practices are discussed as 

allowable bases for local limits. Provides 

evidence that the Agency continues to 

emphasize permitting as a means to promote 

P2.. 

Compliance monitoring guidance: NPDES 

Compliance Inspection Manual (2004) 

http://www.epa.gov/compliance/resources/publicati

ons/monitoring/cwa/inspections/npdesinspect/npdes

manual.html

Provides evidence that the compliance 

monitoring program has developed guidance 

on building a P2 opportunity assessment into 

NPDES (water) inspection activities, which 

cover POTWs, stormwater industrial and 

construction sites, pretreatment facilities, and 

so on. 

Water program permitting guidance: 

Developing Your Stormwater Pollution 

Prevention Plan: A Guide for Construction 

Sites (2007) 

http://www.epa.gov/npdes/pubs/sw_swppp_guide.pdf

Provides evidence that the water program 

continues to develop P2 guidance – here, 

sector-specific guidance on writing a 

stormwater P2 plan, as required in a 

construction general permit. 

North Carolina Industrial Waste Survey (IWS) 

http://h2o.enr.state.nc.us/percs/Pretreatment/Industr

ialWasteSurvey.htm

Provides limited evidence of the effectiveness 

of the water program’s 1993 pretreatment 

guidance in promoting P2 practices. 

East Bay Municipal Utility District Wastewater 

Department 2006 Annual Report

http://www.ebmud.com/about_ebmud/publications/

annual_reports/default.htm 

Provides limited evidence of the effectiveness 

of the water program’s 1993 pretreatment 

guidance in promoting P2 practices. 

October 19, 2006 Interview with Mike 

Shapiro, Deputy Assistant Administrator, 

Office of Water, about underground injection 

program permits. 

Provides confirmation that P2 approaches were 

not actively integrated into the underground 

injection program for deep wells (chiefly 

industrial hazardous waste disposal). 

Waste program guidance: Waste Minimization: 

Permit Certification and Joint Permitting 

(1985) 

http://yosemite.epa.gov/osw/rcra.nsf/document

s/21AF6AEAD724FFA6852565DA006F09D5

Provides evidence of longstanding waste 

program guidance to permit writers to ensure 

that a hazardous waste permit includes a 

certification that the waste generator has a P2 

plan in place. 

Waste program guidance: Pollution Prevention 

Solutions During Permitting, Inspections and 

Enforcement (1998) 

http://www.p2pays.org/rf/03/02278.pdf

or search document on p2 pays homepage

This thorough compendium of P2 options in 

the waste permitting process, although no 

longer available on an EPA web site, provides 

evidence that the waste program continued to 

develop P2 guidance. 

March 21, 2007 email from Gary Schlicht, 

Region 7, to David Sarokin, Pollution 

Prevention Division, Office of Pollution 

Documents an instance where efforts to 

strengthen waste minimization in RCRA 

permits were deemed unenforceable by 
80

Data Element Evidence Evaluated to Reach Conclusion 

Prevention and Toxics regional counsel. 

Enforcement data: Integrated Compliance 

Information System (ICIS) Database 

These ICIS data on compliance violations 

provide annual numbers of enforcement 

actions with a P2 component, and annual 

numbers of enforcement Supplemental 

Environmental Projects (SEPs) with a P2 

component. This evidence was used to 

calculate annual percentages of enforcement 

actions and SEPs with a P2 component. 

Compliance assistance program report: Role of 

the EPA Inspector In Providing Compliance 

Assistance (1998) 

http://www.epa.gov/compliance/resources/policies/

monitoring/inspection/roleinspect.pdf

This report, written by a workgroup tasked 

with assessing innovative roles for EPA 

inspectors, provides evidence that the program 

methodically considered the implications of 

emphasizing multimedia, whole-facility, and 

P2-oriented compliance assurance strategies. 

The traditional role of the inspector was 

compliance monitoring; the innovation would 

be adding in onsite compliance assistance.. 

Compliance assistance program guidance: 

Inspector’s Compliance Assistance Resources 

Guide (1999) 

http://intranet.epa.gov/oeca/oc/campd/inspector/refe

renc/ca-resources.pdf

Provides evidence that the compliance 

assistance program provides EPA inspectors 

with resources to use when engaging in an 

onsite compliance assistance role. 

Compliance assistance program guidance: 

Protocol for Conducting Environmental 

Compliance Audits Under the Stormwater 

Program (2005) 

http://www.epa.gov/compliance/resources/policies/i

ncentives/auditing/apcol-stormwater.pdf

Provides evidence that the compliance 

assistance program continues to develop 

guidance that promotes P2 approaches – here, 

to help the regulated community develop selfaudit programs to improve environmental 

performance and identify P2 opportunities. 

Compliance Assistance Clearinghouse 

(current) 

http://cfpub.epa.gov/clearinghouse/

Provides evidence that he compliance 

assistance program provides P2 resource 

materials on its web-based clearinghouse. 

11/20/07 email from Joann Berman, Office of 

Enforcement and Compliance Assistance 

(OECA), to David Sarokin, OPPT regarding 

2006 and 2007 results of the Compliance 

Assistance Customer Satisfaction Survey 

Provides quantitative evidence, based on a 

non-representative sample of Compliance 

Assistance Center users, of the annual 

percentage of users achieving pollutant 

reductions as a result of using a Compliance 

Assistance Center (15 total Centers). 

OECA Sector Notebooks 

http://www.epa.gov/compliance/resources/publicati

ons/assistance/sectors/notebooks/index.html

35 web-based notebooks, each with a P2 

chapter, provide evidence of OECA’s 

continuing efforts to integrate P2 into its 

resources for the regulated community. 

Conclusion 5. Agency Regional offices use strategic co-location of P2 

programs with other programs to leverage P2 resources and promote 

collaboration. Regions occasionally reach out beyond their co-located offices 

to promote P2 integration in other regional offices. One Region uses P2 

planning and results reporting for media offices, supported by cross-office P2 
81

teams. There is variability among Regions in the extent to which they 

coordinate regional multimedia and regional P2 efforts. There is room for 

expanding the contribution of Regions to P2 integration.. 

Data Element Evidence Evaluated to Reach Conclusion 

Region 4: Pollution Prevention Strategy and 

Action Plan (1997) 

www.epa.gov/Region4/p2

This strategy and action plan of 10-years’ 

duration provide evidence that Region 4 plans 

for integrating P2 throughout its programs. 

This demonstrates a potential roadmap for P2 

integration. 

Region 4: Draft P2 Program Logic Model 

(2005) 

(available as a Powerpoint file) 

Provides information on the activities Region 4 

is using to achieve its 1997 strategic plan. 

This demonstrates a potential roadmap for P2 

integration. 

 Region 8 report: The Keys to Success: A 

Compilation of Workable P2 Integration 

Techniques (2001) 

http://www.tellus.org/b&s/publications/Keys%to%

Success-P2%20Practices.pdf

This report provides evidence that Region 8 

has documented guidance on P2 integration. 

Conclusion 6. More programs are using partnerships to work towards some 

program goal, and this is expanding opportunities for P2 integration. 

Data Element Evidence Evaluated to Reach Conclusion 

Inventory of EPA Partnership Programs 

http://www.epa.gov/partners/programs/index.htm

Provides an inventory and description of the 

partnership programs at EPA. 

Energy Star web site 

http://www.energystar.gov/

Under “About Energy Star,” partner 

information is available. 

Healthcare Environmental Resource Center 

Website 

http://www.hercenter.org/

This integrated compliance and P2 web site 

provides direct evidence of the collaboration 

between the compliance program and the P2 

program to create an integrated web site for the 

healthcare sector. 

Federal Electronics Challenge Website 

http://www.federalelectronicschallenge.net/ind

ex.htm

Provides general information about the Federal 

Electronics Challenge and its activities. This 

demonstrates how EPA partnership programs 

can be used to promote P2 integration. 

Executive Order 13423, Strengthening Federal 

Environmental, Energy, and Transportation 

Management 

http://www.epa.gov/greeningepa/practices/eo13423

.htm

Instructions for implementing executive 

Order 13423 

http://www.ofee.gov/eo/eo13423_instructions.pdf

Provides information on the executive order 

and its implementing instructions which 

requires agencies to meet goals similar to the 

program goals of the FEC. 

Conclusion 7. EPA statutory implementation programs also take 

opportunities to integrate P2 into operations other than regulations. These 
82

include activities in the children’s health, indoor air, pesticides, research, 

solid waste, toxics, and water programs. There is room for more of these 

opportunities to be utilized. 

Data Element 

Evidence Evaluated to Reach Conclusion 

Children’s health, indoor air programs: 

Healthy School Environments Assessment 

Tool 

http://cfpub.epa.gov/schools/top_sub.cfm?t_id=43

&s_id=47

Provides evidence of a P2 tool developed by 

these programs. 

Pesticide program: Biopesticide Demonstration 

Program 

http://www.epa.gov/oppbppd1/pesp/publications/20

05report/biopesticide.htm

Provides evidence of a P2 initiative undertaken 

in the pesticides program. 

Research program:: Pollution Prevention 

Research Strategy (1998) 

http://www.epa.gov/ord/htm/documents/p2.pdf

This peer-reviewed 1998 strategy provides 

evidence that the Office of Research and 

Development (ORD) took an accountabilitybased and budget-based approach to 

integrating P2 into its program 

Research program: Technology for a 

Sustainable Environment Grant Program: A 

Decade of Innovation (2006) 

http://es.epa.gov/ncer/science/tse/decade_innovatio

n.pdf

This 2006 report of P2/sustainability research 

successes co-funded by ORD and the National 

Science Foundation provides evidence that 

ORD continues integrating P2 into its 

activities. From the report: “Sustainability 

cannot be achieved without innovations in 

pollution prevention—the reduction or 

elimination of pollutants at the source.” 

Solid waste program: Source Reduction 

Program Potential Manual (1997) 

www.epa.gov/epaoswer/non-hw/reduce/source.pdf

Provides evidence of a P2 tool developed by 

the program for local solid waste managers to 

assess the impact of various source reduction 

options. 

Solid waste program: ReduceIt software 

(1997) 

www.epa.gov/epaoswer/non-hw/reduce/reduceit

Used in conjunction with the manual described 

above. 

Solid waste program: Guide for Industrial 

Waste Management 

http://www.epa.gov/epaoswer/nonhw/industd/guide/index.htm

Program experience. 

Toxics program: Toxics Substances Control 

Act new chemicals program: Sustainable 

Futures Initiative 

Http://www.epa.gov/oppt/newchems/pubs/sustainab

lefutures.htm

This set of tools for industry on designing and 

evaluating chemicals, announced in a 2002 

Federal Register Notice available on the web 

site, provides evidence that the TSCA new 

chemicals program has transferred its chemical 

risk screening methodologies to industry to 

promote the design of greener chemicals.. 
83

Water program grants: Final Guidance on 

Awards of Grants to Indian Tribes under 

Section 106 of the Clean Water Act (2006) 

www.epa.gov/owm/cwfinance/final-tribalguidance.pdf

Chapters 2 and 5 of this grant guidance provide 

evidence that the water program created an 

approved P2 option for Tribes receiving grant 

funds to implement water quality programs. 

Water program guidance: National 

Management Measures to Control 

Nonpoint source Pollution from Urban 

Areas (2005) 

http://www.epa.gov/nps/urbanmm/

Chapter 9 of this guidance provides evidence 

that the water program integratedP2 into 

guidance for municipalities and citizens on 

controlling nonpoint source runoff. 

Evaluation Q1, sub-question 1: How does the Agency currently consider the effect 

of its programs and regulations on source reduction efforts?

Conclusion 8. Agency review of regulations and programs for their effect on 

source reduction efforts is in basic conformity with the relevant Pollution 

Prevention Act provision, but there is room for continuing improvement. 

Data Element Evidence Evaluated to Reach Conclusion 

See data elements for Conclusions 1 through 8. This data, in total, supports this conclusion. 

 

Evaluation Q1, sub-question 2: Does current Agency review of regulations for their 

effect on source reduction conform with prior federal recommendations on this topic?

Conclusion 9. Currently, the Agency tracks how often regulatory 

workgroups consider source reduction during rule development in a manner 

that is fairly consistent with the 2001 recommendation of the U.S. General 

Accounting Office. The Agency has a system in place to prompt workgroup 

consideration of source reduction and to account for whether they considered 

P2 or not. There is some room for improving the use of the system. 

Data Element Evidence Evaluated to Reach Conclusion 

Preventing Pollution Through Regulations: 

The Source Reduction Review Project (SRRP): 

An Assessment (1996) 

 http://www.epa.gov/oppt/p2home/pubs/docs/srrp.txt 

Provides one source of federal 

recommendations on Agency review of 

regulations for their effect on source reduction. 

 

U.S. Government Accountability Office 

Report, EPA Should Strengthen Its Efforts to 

Measure and Encourage Pollution Prevention 

(January 2001) 

http://www.gao.gov/new.items/d01283.pdf

Provides the second source of federal 

recommendations on Agency review of 

regulations for their effect on source reduction. 

See data elements for Conclusion 1. This data, in total, supports this conclusion. 

 

Conclusion 10. Currently, high-level planning and budgeting tends to be 

silent on encouraging multimedia P2 outcomes through regulations, which is 

not consistent with the Agency’s 1996 Assessment on P2 in Regulations. The 
84

current state is strongly influenced by GPRA-related PART program 

reviews, which place emphasis on individual program planning and 

budgeting, not on cross-program planning and budgeting. EPA Region 4 has 

integrated P2 into media office planning for the past ten years, which is 

consistent with the 1996 recommendations. From 1998-2003, Headquarters 

placed some emphasis on cross-program planning and budgeting (in the 

targeted area of persistent, bioaccumulative and toxic chemicals) which, on a 

limited scale, was consistent with the recommendations of the 1996 

Assessment. 

Data Element Evidence Evaluated to Reach Conclusion 

See data elements for Conclusion 27. This data, in total, supports this conclusion. 

 

Region 4’s Pollution Prevention Strategy and 

Action Plan (1997) 

www.epa.gov/Region4/p2

Provides evidence that, on some scale, Region 

4 acts on the 1996 Agency recommendation to 

use planning and budgeting to promote 

multimedia P2 outcomes. 

Persistent Bioaccumulative and Toxic (PBT) 

Chemicals multi-office multimedia and P2 

planning and budgeting (1998-2003) 

http://www.epa.gov/pbt/pubs/pbtstrat.htm

PBT Revised FY2004 multi-office budget 

(XL spreadsheet available upon request)

Provides evidence that, on a limited scale, the 

Agency acted on its 1996 recommendation to 

promote multimedia P2 outcomes in high-level 

planning and budgeting – this multi-office 

initiative on PBTs conducted Agency-wide 

annual planning and budgeting for six years. 

Conclusion 11. The Agency is still using specially targeted rules to promote 

source reduction, as recommended by the EPA 1996 Assessment on P2 in 

Regulations. The Agency is paying particular attention to the regulatory 

implementation phases of permitting, compliance, and licensing, consistent 

with the 1996 recommendations. For this conclusion, we rely on the 

discussion under Conclusions 2 and 3. 

Data Element Evidence Evaluated to Reach Conclusion 

See data elements for Conclusions 2 and 3. This data, in total, supports this conclusion. 

Conclusion 12. The Agency’s current emphasis on broadening the flexibility 

of regulatory requirements is consistent with the 1996 Assessment 

recommendations, although there is always room for continuing 

improvement. 

Data Element Evidence Evaluated to Reach Conclusion 

See data elements for Conclusions 2 and 3. This data, in total, supports this conclusion. 

Conclusion 13. Constraints on Agency use of industry surveys for gathering 

data needed for regulatory and programmatic performance remain at a level 

that was of concern in 1996. The current state of data gathering through 

surveys is not consistent with 1996 Assessment recommendations. 

Data Element Evidence Evaluated to Reach Conclusion 
85

See data elements for Conclusions 2 and 3. 

Evaluation Question 2: What is the current state of internal Agency coordination on 

source reduction activities? 

Conclusion 14. The Innovations Action Council coordinates environmental 

stewardship partnership programs across the Agency, many of which 

address source reduction activities. The IAC produced the report to the 

Administrator on environmental stewardship, which cites P2 as an integral 

part of environmental stewardship and sustainability approaches. 

Data Element Evidence Evaluated to Reach Conclusion 

Everyday Choices: Opportunities for 

Environmental Stewardship (2005) 

http://www.epa.gov/epainnov/pdf/rpt2admin.pdf 

This report provides evidence that the IAC 

plays a coordinating role for partnership 

programs that promote source reduction. 

Conclusion 15. The Office Directors’ Multimedia and Pollution Prevention 

(M2P2) Forum commissions and coordinates source reduction activities that 

relate to regulatory integration and other multimedia program activities. On 

several occasions, the Forum has successfully shown that it can bring offices 

together to forge concrete multi-office P2 solutions to environmental 

problems. There is room for greater utilization of the M2P2 Forum’s 

problem-solving capabilities. 

Data Element Evidence Evaluated to Reach Conclusion 

Office Directors’ Multimedia Pollution 

Prevention (M2P2) Forum Charter (1996) 

(available as a Word file) 

Provides evidence of the role the M2P2 plays 

in coordinating source reduction activities in 

the Agency. 

NASCAR agreement on unleaded fuel for 

racing cars 

Memorandum of Understanding to Establish 

the National Vehicle Mercury Switch 

Recovery Program 

http://www.epa.gov/mercury/pdfs/switchMOU.pdf

This partnership agreement (on the removal of 

automotive mercury switches) provides 

evidence of the practical solution to an 

environmental problem that the M2P2 Forum 

helped bring about. 

Conclusion 16. The Environmental Assistance Network coordinates source 

reduction activities of Agency technical assistance programs.

Data Element Evidence Evaluated to Reach Conclusion 

Email/attachment Provides evidence of the role the EAN plays in 

coordinating source reduction activities in the 

Agency. 

Conclusion 17. The Office of Research and Development coordinates 

research activities on source reduction approaches. 
86

Data Element Evidence Evaluated to Reach Conclusion 

Pollution Prevention Research Strategy 

(1998) 

Http://www.epa.gov/ord/htm/documents/p2.pdf

. 

The Executive Summary of this 1998 Strategy, 

under “strategic rationale” and 

“implementation,” indicates entities that ORD 

engages with and partners with in conducting 

research activities. 

Evaluation Q2, sub-question 1: What is the current state of Agency coordination 

with appropriate offices to promote source reduction practices in other Federal 

agencies?

Conclusion 18. Currently, Agency offices coordinate with each other, with 

the Federal Environmental Executive, and with other lead Federal 

departments to assist Federal agencies generally to adopt source reduction 

practices in their operations. Many of these working relationships are 

structured by Federal Executive Order 13423, which consolidates related 

executive orders that preceded it. Working relationships focus on achieving 

specific EO 13423 goals and related partnership goals. EPA also reviews the 

environmental impact statements (EIS) of other Federal agencies; further 

evaluation would be required to understand the current state of promoting 

P2 through EIS review.. 

Data Element Evidence Evaluated to Reach Conclusion 

EPA Office of Federal Activities (OFA) 

guidance: Incorporating EPA’s P2 Strategy 

into the Environmental Review Process (1993) 

Http://www.epa.gov/compliance/resources/policies/

nepa/pollution-prevention-strategy-pg.pdf

 

This guidance, which helps OFA personnel 

review environmental impact statements of 

Federal agencies in a manner that promotes P2, 

provides evidence that OFA identified P2 

approaches for a wide variety of major federal 

actions significantly affecting the environment. 

Executive Order 13423, Strengthening Federal 

Environmental, Energy, and Transportation 

Management 

Http://www.epa.gov/greeningepa/practices/eo1

3423.htm

Instructions for implementing executive 

Order 13423 

Http://www.ofee.gov/eo/eo13423_instructions.

pdf

Provides information on the executive order 

and its implementing instructions. This 

demonstrates how P2 programs are being 

integrated into other Federal Agencies. 

Evaluation Q2, sub-question 2: How does this current state of Agency coordination 

on source reduction activities conform with the P2 Act provision, “Coordinate source 

reduction activities in each Agency Office and coordinate with appropriate offices to 

promote source reduction practices in other Federal agencies, and generic research 

and development on techniques and processes which have broad applicability”?

Conclusion 19. Current Agency coordination on source reduction activities 

generally conforms with the relevant P2 Act provision. Further evaluation of 

Agency research and development activities would be needed to address the 
87

part of the relevant PPA provision that focuses on coordination with 

appropriate offices to promote generic research and development on P2 

techniques of broad applicability. 

Data Element Evidence Evaluated to Reach Conclusion 

See data elements for Conclusions 14 – 18. The data elements for Conclusions 14-18 in 

total provide the evidence for Conclusion 19. 

Evaluation Question 3: What is the current status of data collected under Federal 

environmental statutes and related sources, and what does current analysis of these data 

reveal about the impacts of pollution prevention?

Conclusion 20. TRI waste generation data trends show national waste 

generation rising more slowly than economic growth and population. Taken 

together, these data sources suggest that P2 measures have been successful in 

containing the growth in volume of annual total production wastes. 

Data Element Evidence Evaluated to Reach Conclusion 

Total Production-Related Wastes Managed 

(TPWM) in 1998 and 2004 

www.epa.gov/triexplorer/trends.htm

 

This data is a combination of the releases, 

transfers, waste management, and energy 

recovery data elements collected as part of the 

Toxics Release Inventory. This combined 

figure provides a measure of overall waste 

generation that is not accounted for by looking 

at releases and treatment alone. 

2006 Statistical Abstracts of the United States 

www.census.gov/compendia/statab/

Provides information on the U.S. GDP and 

population from 1992 to 2004. This 

information provides context to analyze the 

magnitude of TPWM trends. 

Conclusion 21. Municipal solid waste data show a steady rise in the volume 

of waste generated over four decades, with recent data suggesting that source 

reduction may finally be making its presence felt. 

Data Element Evidence Evaluated to Reach Conclusion 

Municipal Solid Waste in the United States: 

2005 Facts and Figures 

www.epa.gov/msw/pubs/mswchar05.pdf

Provides quantities of cumulative municipal 

solid waste generation in 1960, 1970, 1980, 

1990, 2000, 2003, 2004 and 2005. These data 

demonstrate long and short term trends in 

cumulative waste generation and trends in the 

handling of municipal solid waste. This data 

allows for comparison between municipal solid 

waste disposal and recovery efforts. 

Conclusion 22. Greenhouse gas emission and energy trends show GHG 

emissions rising slower than economic growth, and the industrial sector 

achieving an absolute reduction in GHG emissions. EPA GHG emission 

reduction data can be correlated to national GHG emission data. 
88

Data Element Evidence Evaluated to Reach Conclusion 

Inventory of U.S. Greenhouse Gas Emissions and 

Sinks: 1990-2005 (2007) 

http://www.epa.gov/climatechange/emissions/usin

ventoryreport.html

Provides GHG emissions trend data for the 

electricity, generation, transportation, industry, 

agriculture, commercial, residential, and US 

territories in 1990, 1995, 2000, 2001, 2002, 

2003, 2004, and 2005. Also provides 

quantified SF6 emissions levels in 1990, 1995, 

2000, 2001, 2002, 2003, 2004, and 2005, 

which portray a trend reflective of economic 

incentives and P2 activities. 

2006 Statistical Abstracts of the United States 

www.census.gov/compendia/statab/

Provides information on the U.S. GDP in both 

1990 and 2005. This information provides a 

means to compare greenhouse gas emissions 

trends to economic growth. 

Energy Trends in Selected Manufacturing 

Sectors (March 2007) 

http://www.epa.gov/sectors/energy/index.html

Provides quantified energy use by sector 

(residential, commercial, industrial, and 

transportation) from 1970 to 2005 

SF6 Emissions Reduction Partnership for 

Electric Power Systems Website 

http://www.epa.gov/electricpower-sf6/

Provides quantitative and qualitative 

information about the program’s purpose and 

membership requirements. 

Energy Star – Overview of 2005 

Achievements 

http://www.epa.gov/appdstar/pdf/CPPD2005.

pdf

Provides the quantity of greenhouse gas 

emission reductions from Energy Star 

activities in 2005, and evidence of a common 

measurement methodology at the program and 

national levels. 

Toward a Cleaner Future: Office of 

Transportation and Air Quality Progress 

Report (2005) 

www.epa.gov/oms/about/420r05011.pdf

Provides quantitative information on the 

reduction of CO2 anticipated from 2005 

SmartWay Partner commitments. Provides 

evidence of a common measurement 

methodology for greenhouse gas emission 

reductions.. 

WasteWise 2005 Annual Report 

http://www.epa.gov/epaoswer/nonhw/reduce/wstewise/pubs/report05.pdf

Provides a 2004 data point of CO2 emission 

reductions achieved by WasteWise Partners. 

Provides evidence of a common measurement 

methodology for greenhouse gas emission 

reductions.. 

Federal Electronics Challenge Measurement 

Spreadsheet (Actuals and Targets) 

Provides fiscal year 2005 and 2006 actual 

environmental results and targets for 2007 

through 2011. Provides evidence of a common 

measurement methodology for greenhouse gas 

emission reductions.. 

Electronic Product Environmental 

Assessment Tool Measurement Spreadsheet 

(Actuals and Targets) 

Provides fiscal year 2006 actual environmental 

results and targets for 2007 through 2011. 

Provides evidence of a common measurement 

methodology for greenhouse gas emission 

reductions.. 

Conclusion 23. Interpreting trends in pesticide pollution, in particular, 

requires an understanding of both quantity and relative risk of pesticides 
89

being used. EPA national pesticide market surveys from 1982-2001 show a 

drop then leveling off in quantity used, but may reflect a shift to lower-volume 

substitutes. EPA stopped collecting market data in 2001. California data from 

2001 to 2005 show a trend toward higher quantity use of lower-risk pesticides. 

Data Element Evidence Evaluated to Reach Conclusion 

Pesticide Industry Sales and Usage 2000 and 

2001 Market Estimates 

www.epa.gov/oppbead1/pestsales/01pestsales/

market_estimates2001.pdf

Provides quantitative information indicating 

national trends of use of pesticide active 

ingredients in the US from 1982 to 2001. 

California Department of Pesticide Regulation: 

Analysis of Pesticide Use Trends 

www.cdpr.ca.gov/docs/pur/pur97rep/pur_anal.

htm

Provides quantitative information indicating 

trends in the use of pesticide active ingredients 

in California from 2001 to 2005. This data 

surveys as a surrogate for national trend data 

that ended in 2001 and indicates what may be 

increased use of lower-risk pesticides in 

California. 

Conclusion 24. Fertilizer data from USDA show fertilizer use leveling off in 

the past decade. 

Data Element Evidence Evaluated to Reach Conclusion 

USDA Economic Research Service Data Set – 

U.S. Fertilizer Use and Price 

www.ers.usda.gov/Data/FertilizerUse/Tables/Table

3.xls [unable to open] 

Provides national trends data on fertilizer use; 

data from 1990-2005 was used for the current 

analysis. 

EPA’s Office of Water - National Management 

Measures to Control Non-Point Source 

Pollution from Agriculture 

www.epa.gov/owow/nps/agmm/chap4a.pdf

Provides qualitative information on the value 

of using source reduction techniques to address 

nutrient management issues involved in nonpoint source pollution. 

Conclusion 25. TRI source reduction data are helpful to understand subtrends in relative use of source reduction among states and sectors, but in 

their current state are not usable to interpret quantitative national 

environmental trend data. 

Data Element Evidence Evaluated to Reach Conclusion 

U.S. GAO, EPA Should Strengthen Its Efforts 

to Measure and Encourage Pollution 

Prevention, 2001 

http://www.gao.gov/new.items/d01283.pdf

Provides an analysis of reporting trends of TRI 

source reduction activities from 1991 to 1998. 

TRI Source Reduction Data Provides the total number of TRI forms with 

‘yes’ to the source reduction question from 

1991 to 2005. This information, when 

calculated as a percentage of the total TRI 

forms submitted during those years, 

demonstrates the trends in reporting source 
90

reduction activities. This data was also sorted 

by state, chemical and sector to ascertain 

additional trends in reporting. 

Conclusion 26. Some gaps in media-specific environmental data exist for 

wastes generated, which is sometimes attributable to the delegated nature of 

the media program, and at other times attributable to methodological changes 

that makes trends difficult to track. Data gaps also exist for trends in the 

relative risk of releases 

Data Element Evidence Evaluated to Reach Conclusion 

Biennial Reporting System 

http://www.epa.gov/epaoswer/hazwaste/data/bi

ennialreport/index.htm

Provides quantitative information on hazardous 

waste generation on the national level. This 

information is used as an example of how 

inconsistencies in reporting parameters can 

make annual comparisons difficult. 

Evaluation Question 4: What are the Agency’s current measurable goals for pollution 

prevention, especially pertaining to P2 integration? 

Conclusion 27. Currently, the Agency’s high-level planning documents show 

a trend away from emphasizing or even acknowledging P2 integration. 

Data Element Evidence Evaluated to Reach Conclusion 

The New Generation of Environmental 

Protection: EPA's 5 Year Strategic Plan 

Viewable at http://nepis.epa.gov/

Pub# 200B94002 

This 1994 Strategic Plan provides evidence 

that EPA once had specific P2 integration 

goals for all offices. 

EPA’s 1997-2002 Strategic Plan 

http://www. epa.gov/ocfo/plan/plan.htm

This 1997 Strategic Plan provides evidence 

that EPA strongly emphasized P2 integration 

during this time frame.. 

EPA’s 2000-2005 Strategic Plan 

http://www.epa.gov/ocfo/plan/plan.htm

This 2000 Plan provides evidence that EPA 

still had a reasonably strong emphasis on P2 

integration during this time frame. 

EPA’s 2003-2008 Strategic Plan 

http://www.epa.gov/ocfo/plan/plan.htm

This 2003 Plan provides evidence of a turning 

point in EPA’s characterization of P2 for 

strategic planning purposes during this time 

frame. . 

EPA’s 2006-2011 Strategic Plan 

http://www.epa.gov/ocfo/plan/plan.htm

This 2006 Plan provides evidence of a 

diminished role for P2 in strategic planning for 

this time frame. 

Conclusion 28. Currently, the Agency has measurable environmental 

outcome goals for direct P2 activities, but few measurable goals related for 

P2 integration activities. The only measurable goals related to P2 integration 

activities are for some Federal partnership results in which OSW and 
91

OPPT’s P2 Program directly intervene, and for some P2 integration 

activities in which OPPT’s P2 Program directly intervenes. 

Data Element Evidence Evaluated to Reach Conclusion 

Goals for direct P2 activities: EPA 2006-2011 

Strategic Plan 

http://www.epa.gov/ocfo/plan/2006/goal_5.pdf

In the 2006 Strategic Plan, Goal 5, Objective 

5.2 (Prevent pollution and promote 

environmental stewardship) lists quantified 

2011 goals for the P2 Program, the National 

Partnership for Environmental Priorities, and 

enforcement Supplemental Environmental 

Projects; provides evidence of goals for direct 

P2 activities. 

Will pull from the Strategic Plan Will pull from the Strategic Plan. 

Region 4: Draft P2 Program Logic Model 

(2005) 

(available as a Powerpoint file) 

The logic model shows that Region 4 media 

programs set P2 goals. 

Evaluation Question 5: What is the Agency’s current methodology for measuring P2, 

especially with respect to P2 integration? 

Conclusion 29. The methodology for measuring results from direct P2 

activities is based on pounds of hazardous pollutants and materials reduced, 

tons of CO2 reduced, BTUs of energy reduced, gallons of water saved, and 

dollars saved from P2 practices. The methodology for measuring the results 

from P2 integration activities is generally not yet established, although in 

instances where the P2 Program has directly intervened in P2 integration 

activities, it has used the same methodology to measure these results as it uses 

for measuring results from its direct P2 activities. 

Data Element Evidence Evaluated to Reach Conclusion 

EPA Strategic Plan 2006-2011 

http://www.epa.gov/ocfo/plan/plan.htm

The Plan provides evidence of measures for 

direct P2 activities and all measures for the air, 

water, waste, etc. programs. 

EPA’s Hierarchy of Measurement Indicators 

http://www.epa.gov/indicators/roe/html/roeIntro2.ht

m

EPA’s hierarchy of indicators shows the range 

of measurement indicators that EPA uses, with 

the order of preference being from the highest 

level indicator to the lowest. This provides 

contextual evidence for the evaluation 

discussion of P2 measurement methodology. 

Region 4: Actual results submitted to P2 

Program for FY 2005 

(available as an Excel spreadsheet) 

This excel spreadsheet show that the Region 4 

air and water programs submitted P2 results 

measured in pounds of pollutants reduced, 

BTU’s of energy conserved (BTU’s pre-date 

switch to a GHG indicator), and gallons of 

water conserved. 
92

Evaluation Q5, sub-question 1: Do Agency methods for measuring P2 conform with 

the P2 Act provision, “Establish standard methods of measurement for source 

reduction”?

Conclusion 30. The Agency has established standard methods of measuring 

pollution prevention, but they are mostly applied to direct P2 activities, and 

not P2 integration activities, with the exception of the measure for reductions 

in greenhouse gas emissions. . These methods consist of outcome measures 

and some behavioral change measures tailored to individual project needs. 

The Agency developed its methodology in consultation with States, which 

increases the standardization of the Agency methodology. The Agency has 

used this methodology for several years, and reviews it for continuous 

improvement. This methodology has been used by the Agency mostly for 

measuring the results of direct P2 activities, and the similar State 

methodology has been used to measure a range of P2 activities, including 

some that could be characterized as P2 integration. The Agency will need to 

examine which methodologies to employ for measuring its P2 integration 

results broadly, and would need to tailor any behavioral change measures to 

meet the needs associated with tracking internal Agency behavior change. 

Data Element Evidence Evaluated to Reach Conclusion 

NPPR Results Task Force 

http://www.p2.org/workgroup/Background.cfm

Provides information about the Agency’s effort 

to standardize P2 measures. 

 
93

Appendix C 

This Appendix provides some text from selected data source documents identified in 

Appendix B, plus background material identified in Evaluation Chapters 1 and 4 as 

appearing in Appendix C. We have chosen items for Appendix C that represent special 

preparation of information especially for this evaluation. Factors for selecting text from 

data sources to appear here include particular relevance, effort made to tailor information 

for this evaluation, quantification, frequency of use as evidence, ease of identifying 

evidence within a large source document, and so forth. These data source excerpts are 

organized by Chapter and Evaluation Question. If a data source is used as evidence more 

than once, it will be listed according to where it is used the first time. 

Chapter 1. 

Regulatory development stages where P2 can be considered (reference page 14). 

 Description P2 Opportunity 

Regulatory 

Planning 

Biennial effluent guidelines 

planning process; annual 

Regulatory Plan, Semi-annual 

Regulatory Agenda 

Emphasize P2 in planning focus, 

identify rules with strong P2 potential. 

Charge Senior management directions to 

the regulatory workgroup 

Emphasize P2 as a priority 

consideration 

Initiation/ Tiering Decision on level of participation 

by multiple offices in regulatory 

development. 

Make sure rules with P2 opportunity 

have the involvement of multiple 

offices to improve multimedia analysis. 

Analytic 

Blueprint 

Outline of steps the workgroup 

will follow in rule development. 

Ensure blueprint has a meaningful and 

transparent discussion of how the 

workgroup will or will not consider P2. 

Information 

Collection 

Data collection from and site visits 

to affected sources. 

Collect data on P2 practices used by 

sources. 

Multimedia 

analysis of regulatory options. 

Analysis of options for achieving 

regulatory purpose 

Options considered can include 

pollution prevention 

Economic Impact 

Analysis 

Analysis of estimated responses to 

regulatory options, and economic 

impact these responses will have at 

the facility level and sector level. 

Drafting preamble An EPA regulatory workgroup 

drafts a preamble for the proposed 

and final rules. . 

In preamble, discuss consideration of 

P2 in the rule, P2 options, and solicit 

comments specifically on P2 options. 

Implementation 

guidance and 

outreach 

Guidance and outreach to affected 

sources on compliance with final 

rule. 

Emphasize P2 approaches to 

compliance, hold P2 compliance 

workshops. 

Assessment Evaluations on how rule is 

working, such as water program 

study of industry implementation 

choices in the pulp and paper 

effluent guideline. 

Learn lessons that can be used in future 

rulemaking. 
94

Chapter 4. 

Evaluation Question 1. How does the Agency currently consider the effect of its 

programs and regulations on source reduction efforts? 

Conclusion 1. 

1. Rule and Policy Information Development System 

RAPIDS Data by Office 

 YES NO NA BLANK TOTAL % YES 

All Offices 

1996 1 6 0 14 21 4.76 

1997 3 3 4 7 17 17.65 

1998 4 6 11 11 32 12.50 

1999 2 3 16 13 34 5.88 

2000 3 2 6 5 16 18.75 

2001 3 11 23 11 48 6.25 

2002 14 11 8 9 42 33.33 

2003 7 21 13 5 46 15.22 

2004 19 16 23 18 76 25.00 

2005 12 28 34 13 87 13.79 

2006 6 43 14 10 73 8.22 

Total 74 150 152 116 492 15.04 

OAR 

1996 0 4 0 13 17 0.00 

1997 1 3 1 7 12 8.33 

1998 3 4 7 9 23 13.04 

1999 0 2 9 11 22 0.00 

2000 0 2 4 4 10 0.00 

2001 2 3 10 4 19 10.53 

2002 9 6 5 2 22 40.91 

2003 4 11 10 2 27 14.81 

2004 15 10 19 3 47 31.91 

2005 6 19 22 3 50 12.00 

2006 5 24 13 6 48 10.42 

Subtotal 45 88 100 64 297 15.15 

OW 

1996 0 0 0 0 0 ----------- 

1997 2 0 0 0 2 100.00 

1998 0 0 0 1 1 0.00 

1999 2 0 3 0 5 40.00 

2000 0 0 1 0 1 0.00 

2001 0 1 5 2 8 0.00 

2002 4 2 0 2 8 50.00 

2003 1 5 1 1 8 12.50 

2004 3 0 2 1 6 50.00 

2005 3 2 7 3 15 20.00 

2006 0 3 1 1 5 0.00 

Subtotal 15 13 20 11 59 25.42 

OSWER 

1996 0 0 0 1 1 0.00 

1997 -- -- -- -- -- -- 

1998 1 2 0 0 3 33.33 
95

RAPIDS Data by Office 

 YES NO NA BLANK TOTAL % YES 

1999 0 0 1 0 1 0.00 

2000 2 0 0 1 3 66.67 

2001 0 1 0 2 3 0.00 

2002 1 2 0 5 8 12.50 

2003 0 1 0 1 2 0.00 

2004 1 1 0 3 5 20.00 

2005 2 1 0 3 6 33.33 

2006 0 6 0 1 7 0.00 

Subtotal 7 14 1 16 38 18.42 

OPPTS 

1996 1 2 0 0 3 33.33 

1997 0 0 2 0 2 0.00 

1998 0 0 4 1 5 0.00 

1999 0 0 0 1 1 0.00 

2000 1 0 0 0 1 100.00 

2001 0 3 4 2 9 0.00 

2002 0 0 1 0 1 0.00 

2003 1 2 1 0 4 25.00 

2004 0 1 1 8 10 0.00 

2005 1 3 5 1 10 10.00 

2006 1 4 0 1 6 16.67 

Subtotal 5 15 18 14 52 9.62 

2. Preventing Pollution Through Regulations: The Source Reduction Review 

Project – An Assessment (February, 1996) 

http://www.epa.gov/p2/pubs/docs/srrp.txt

The following excerpt from the Executive Summary identifies the positive lessons 

learned from the pilot SRRP project, the obstacles identified, the effect of those 

obstacles, and the recommendations made to EPA leadership. 

> The Obstacles. A key contribution of SRRP is identifying Agency-wide obstacles to 

more effectively integrate multi-media and P2 approaches into regulatory and other 

mainstream activities, and finding general agreement among SRRP participants that 

the obstacles should be addressed. The fundamental obstacles that participating 

programs encountered are: 

(1) The lack of incentives for inter-office (multi-media) coordination in planning and 

budgeting; 

(2) The piecemeal nature of the statutory framework; 

(3) Challenges in promoting P2 process changes and innovative technologies; 

(4) The lack of understanding about cross-media impacts; 

(5) The lack of resolution about collecting source reduction data through industry 

surveys; and 

(6) Unclear roles for sharing P2 leadership among all parts of the Agency on various 

aspects of P2. 
96

> Effects of Obstacles. These obstacles have had the following effects: 

(1) Resource allocations are not conducive to the coordination and cross-media 

analysis that is beneficial to the development and evaluation of P2 options, and 

information sharing among offices is limited; 

(2) Deadlines for rules affecting the same industry are generally not synchronized, 

and regulatory strategies are not developed on an industry-sector basis; 

(3) P2 process changes and innovative technologies can be difficult to promote; 

(4) Potential cross-media impacts sometimes remain unknown; 

(5) Missing P2 data from surveys sometimes impedes development of source 

reduction options; and 

(6) P2 and cross-media policy issues are not explored as creatively as they might be. 

> Recommendations. To make multi-media and P2 perspectives more central in the 

development and implementation of EPA rules, the assessment recommends: 

1) Emphasizing the key link between cross-media solutions and source reduction; 

2) Continuing to place special attention on targeted rules, especially during their 

implementation through the permitting and compliance phases; 

3) Applying some of the positive SRRP lessons to more rulemakings; 

4) Taking steps to start systematically addressing the obstacles to fostering 

prevention: 

− Reinventing the planning and budgeting processes to enhance cross-media and 

P2 outcomes; 

− Developing a cross-media legislative strategy; 

− Broadening the flexibility of regulatory requirements; 

− Deepening Agency understanding of cross-media impacts; 

− Addressing Paperwork Reduction Act concerns about collecting source 

reduction data from industry; 

− Clarifying P2 roles within the Agency; and 

5) Linking efforts to address these obstacles to full implementation of the Common 

Sense approach and reinvention of EPA. 

3. Proposed Flexible Air Permitting Rule (9/12/07) 

http://www.epa.gov/fedrgstr/EPA-AIR/2007/September/Day-12/a17418.pdf

The following excerpt shows the breadth of the regulated entities this rule would 

apply to. 

A. What are the regulated entities?

Entities potentially affected by these proposed actions are facilities currently 

required to obtain title V permits under State, local, tribal, or Federal operating 

permits programs, and State, local, and tribal governments that are authorized by 

EPA to issue such operating permits. Other entities potentially affected by this 

proposed action are facilities required to obtain major NSR permits under State, 

local, tribal, or Federal major NSR programs, and State, local, and tribal 
97

governments that issue such permits pursuant to approved part 51 major NSR 

programs. Potentially affected sources are found in a wide variety of industry 

groups. In particular, we believe based on our experience in implementing our 

flexible air permit pilot program that these groups will include, but are not limited 

to, the following: 

Industry group SIC a NAICS b 

Aerospace 

Manufacturing 372 336411, 336412, 332912, 336411, 335413. 

Automobile 

Manufacturing 371 336111, 336112, 336712, 336211, 336992, 336322, 336312, 

33633, 33634, 33635, 336399, 336212, 336213 

Industrial Organic 

Chemicals 286 325191, 32511, 325132, 325192, 225188, 325193, 32512, 325199. 

Chemical Processes 281 325181, 325182, 325188, 32512, 325131, 325998, 331311. 

Converted Paper and 

Paperboard Products 267 322221, 322222, 322223, 322224, 322226, 322231, 326111, 

326112, 322299, 322291, 322232, 322233, 322211 

Magnetic Tape 

Manufacturing 369 334613. 

Petroleum Refining 291 32411. 

Other Coating 

Operations 

226, 229, 251, 

252, 253, 254, 

267, 358, 363 

313311, 313312, 314992, 33132, 337122, 337121, 337124, 

337215, 337129, 37125, 337211, 337214, 337127, 322221, 

322222, 322226, 335221, 335222, 335224, 335228, 333312, 

333415, 333319 

Paper Mills.. 262 322121, 322122. 

Pharmaceutical 

Manufacturing 283 325411, 325412, 325413, 325414. 

Printing and 

Publishing 275 323114, 323110, 323111, 323113, 323112, 323115, 323119. 

Pulp and Paper Mills 262 32211, 322121, 322122, 32213. 

Semi-conductors 367 334413. 

Specialty Chemical 

Batch Processes 

282, 283, 284, 

285, 286, 287, 

289, 386 

3251, 3252, 3253, 3254, 3255, 3256, 3259, except 325131 and 

325181 

a Standard Industrial Classification b North American Industry Classification System. 

The following excerpt from the Notice is relevant to explaining the P2-related 

incentive in the proposed rule. 

“The primary purpose of these revisions to parts 70 and 71 is to build upon the 

existing regulatory framework and ensure that the flexible permitting approaches 

with which we have experience are more readily and widely used....We believe that 

these proposed revisions will increase operational flexibility, while ensuring 

environmental protection and compliance with applicable requirements. Moreover, 

based on our pilot experience, we anticipate that these revisions will promote 

improved environmental performance, although we recognize that the nature of the 

improvements will depend on the numbers and types of sources that opt to use the 

flexible permitting approaches described in this document. . . . 
98

[In our evaluation of the pilot flexible permits] we found that the use of advance 

approvals and Alternative Operating Scenarios improved operational efficiency at 

the plants because companies knew in advance what changes were authorized, 

making resource allocation more efficient and accommodating the typically 

incremental, iterative nature of industrial process improvements. We also found that 

P2-related projects became more attractive to the companies when advance 

approved because such projects could be undertaken without the delay and 

uncertainty of future case-by-case approvals. In addition, P2-related projects 

reduced emissions and enabled sources to comply more easily with emissions limits 

such as plant-wide emissions caps. . . . 

 “[O]f the five sources that had operated under their flexible permits for 3 or more 

years, all five achieved 30-to 80-percent reductions in actual plant-wide emissions 

and/or emissions per unit of production. Actual emissions from the sixth source 

were reduced by 27 percent in the first year of operation under its flexible permit, 

but it is difficult to draw conclusions based on a single year of data. One company, 

using P2, lowered its actual volatile organic compound (VOC) emissions by 70% 

(from 190 tons per year (tpy) to 56 tpy), while increasing production. 

4. Proposed Amendments to the General Provisions of the National Emission 

Standards for Hazardous Air Pollutants (May 15, 2003) 

http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2002/

pdf/02-31899.pdf

The following excerpt from the Federal Register Notice of the proposed 

amendments shows the breadth of source categories (each with its own regulatory 

standard) this rule would apply to. The Notice observes that the list is not 

intended to be exhaustive, but a guide for readers regarding entities likely to be 

regulated by this action. 

Industry Group: Source Categories 

With Major and Area Sources 

Fuel Combustion 

Combustion Turbines 

Engine Test Facilities 

Industrial Boilers 

Process Heaters 

Reciprocating Internal Combustion 

 Engines 

Rocket Testing Facilities 

Non-Ferrous Metals Processing 

Primary Aluminum Production 

Primary Copper Smelting 

Primary Lead Smelting 

Primary Magnesium Refining 

Secondary Aluminum Production 

Secondary Lead Smelting 

4E:\FR\FM\15MYP1.SGM 15MYP1 

Ferrous Metals Processing 

Coke By-Product Plants 

Coke Ovens: Charging, Top Side, and 

Door Leaks 

Coke Ovens: Pushing, Quenching, 

Battery Stacks 

Ferroalloys Production: 

Silicomanganese and Ferromanganese 

Integrated Iron and Steel Manufacturing 

Iron Foundries Electric Arc Furnace 

 (EAF) Operation 

Steel Foundries 

Steel Pickling—HCl Process Facilities 

 and Hydrochloric Acid Regeneration 

Mineral Products Processing 

Alumina Processing 

Asphalt Concrete Manufacturing 

Asphalt Processing 

Asphalt Roofing Manufacturing 

Asphalt/Coal Tar Application—Metal 

 Pipes 
99

Clay Products Manufacturing 

Lime Manufacturing 

Mineral Wool Production 

Portland Cement Manufacturing 

Refractories Manufacturing 

Taconite Iron Ore Processing 

Wool Fiberglass Manufacturing 

Petroleum and Natural Gas Production 

and Refining 

Oil and Natural Gas Production 

Natural Gas Transmission and Storage 

Petroleum Refineries—Catalytic 

Cracking (Fluid and other) Units, 

Catalytic Reforming Units, and Sulfur 

Plant Units 

Petroleum Refineries—Other Sources 

Not Distinctly Listed 

Liquids Distribution

Gasoline Distribution (Stage 1) 

Marine Vessel Loading Operations 

Organic Liquids Distribution (NonGasoline) 

Surface Coating Processes 

Aerospace Industries 

Auto and Light Duty Truck 

Large Appliance 

Magnetic Tapes 

Manufacture of Paints, Coatings, and 

Adhesives 

Metal Can 

Metal Coil 

Metal Furniture 

Miscellaneous Metal Parts and Products 

Paper and Other Webs 

Plastic Parts and Products 

Printing, Coating, and Dyeing of Fabrics 

Printing/Publishing 

Shipbuilding and Ship Repair 

Wood Building Products 

Wood Furniture 

Waste Treatment and Disposal 

Hazardous Waste Incineration 

Municipal Landfills 

Off-Site Waste and Recovery Operations 

Publicly Owned Treatment Works 

(POTW) Emissions 

Sewage Sludge Incineration 

Site Remediation 

Solid Waste Treatment, Storage and 

Disposal Facilities (TSDF) 

Agricultural Chemicals Production 

Pesticide Active Ingredient Production 

Fibers Production Processes 

Acrylic Fibers/Modacrylic Fibers 

Production 

Rayon Production 

Spandex Production 

Food and Agriculture Processes 

Manufacturing of Nutritional Yeast 

Cellulose Food Casing Manufacturing 

Vegetable Oil Production 

Pharmaceutical Production Processes 

Pharmaceuticals Production 

Polymers and Resins Production 

Acetal Resins Production 

Acrylonitrile-Butadiene-Styrene 

Production 

Alkyd Resins Production 

Amino Resins Production 

Boat Manufacturing 

Butyl Rubber Production 

Carboxymethylcellulose Production 

Cellophane Production 

Cellulose Ethers Production 

Epichlorohydrin Elastomers Production 

Epoxy Resins Production 

Ethylene-Propylene Rubber Production 

Flexible Polyurethane Foam Production 

Hypalon (tm) Production 

Maleic Anhydride Copolymers 

Production 

Methylcellulose Production 

Methyl Methacrylate-AcrylonitrileButadiene-Styrene Production 

Methyl Methacrylate-Butadiene-Styrene 

Terpolymers Production 

Neoprene Production 

Nitrile Butadiene Rubber Production 

Nitrile Resins Production 

Non-Nylon Polyamides Production 

Phenolic Resins Production 

Polybutadiene Rubber Production 

Polycarbonates Production 

Polyester Resins Production 

Polyether Polyols Production 

Polyethylene Terephthalate Production 

Polymerized Vinylidene Chloride 

Production 

Polymethyl Methacrylate Resins 

Production 

Polystyrene Production 

Polysulfide Rubber Production 

Polyvinyl Acetate Emulsions Production 

Polyvinyl Alcohol Production 

Polyvinyl Butyral Production 

Polyvinyl Chloride and Copolymers 

Production 

Reinforced Plastic Composites 

Production 

Styrene-Acrylonitrile Production 

Styrene-Butadiene Rubber and Latex 

Production 

Production of Inorganic Chemicals 

Ammonium Sulfate Production— 
100

Caprolactam By-Product Plants 

Carbon Black Production 

Chlorine Production 

Cyanide Chemicals Manufacturing 

Fumed Silica Production 

Hydrochloric Acid Production 

Hydrogen Fluoride Production 

Phosphate Fertilizers Production 

Phosphoric Acid Manufacturing 

Uranium Hexafluoride Production 

Production of Organic Chemicals 

Ethylene Processes 

Quaternary Ammonium Compounds 

Production 

Synthetic Organic Chemical 

Miscellaneous Processes 

Benzyltrimethylammonium Chloride 

Production 

Butadiene Dimers Production 

Carbonyl Sulfide Production 

Cellulosic Sponge Manufacturing 

Chelating Agents Production 

Chlorinated Paraffins 

Chromic Acid Anodizing 

Commercial Dry Cleaning 

(Perchloroethylene)—Transfer 

Machines 

Commercial Sterilization Facilities 

Decorative Chromium Electroplating 

Dry Cleaning (Petroleum Solvent) 

Ethylidene Norbornene Production 

Explosives Production 

Flexible Polyurethane Foam Fabrication 

Operations 

Friction Products Manufacturing 

Halogenated Solvent Cleaners 

Hard Chromium Electroplating 

Hydrazine Production 

Industrial Cleaning 

(Perchloroethylene)—Dry-to-dry 

Machines 

Industrial Dry Cleaning 

(Perchloroethylene)—Transfer 

Machines 

Industrial Process Cooling Towers 

Leather Tanning and Finishing 

Operations 

OBPA/1,3-Diisocyanate Production 

Paint Stripping Operations 

Photographic Chemicals Production 

Phthalate Plasticizers Production 

Plywood and Composite Wood Products 

Polyether Polyols Production 

Pulp and Paper Production 

Rubber Chemicals Manufacturing 

Rubber Tire Manufacturing 

Semiconductor Manufacturing 

Symmetrical Tetrachloropyridine 

Production 

ate Jan<31>2003 15:23 May 14, 2003 Jkt 200001 PO 

Categories With Area Sources Only 

Agriculture Chemicals & Pesticides 

Manufacturing 

Autobody Refinishing Paint Shops 

Cadmium Refining & Cadmium Oxide 

Production 

Cyclic Crude and Intermediate 

Production 

Hospital Sterilizers 

Industrial Inorganic Chemical 

Manufacturing 

Industrial Organic Chemical 

Manufacturing 

Lead and Acid Battery Manufacturing 

Medical Waste Incinerators 

Mercury Cell Chlor-Alkali Plants 

Miscellaneous Organic Chemical 

Manufacturing (MON) 

Municipal Waste Combustors 

Other Solid Waste Incinerators (Human/ 

Animal Cremation) 

Plastic Materials and Resins 

Manufacturing 

Plating and Polishing 

Pressed and Blown Glass & Glassware 

Manufacturing 

Secondary Copper Smelting 

Secondary Nonferrous Metals 

Stainless and Nonstainless Steel 

Manufacturing Electric Arc Furnaces 

Stationary Internal Combustion Engines 

Synthetic Rubber Manufacturing 

Wood Preserving 
101

The following excerpt from the Notice is relevant to explaining the P2 option in the rule. 

“We are proposing to amend the NESHAP General Provisions in 40 CFR part 63, subpart 

A. The individual NESHAP (which are frequently referred to as MACT standards) are 

codified as subparts within 40 CFR part 63. We are proposing two options: 

• Option 1: If a facility completely eliminates all HAP emissions from all sources of 

emissions regulated by the subpart, it could request to no longer be subject to that subpart. 

This option would be available only where the subpart does not already require complete 

elimination of HAP emissions from any of the regulated sources of emissions. 

• Option 2: If a facility uses P2 to reduce HAP emissions either to the level required by the 

subpart, or below, it could request ‘‘P2 alternative compliance requirements.’’ The 

alternative compliance requirements would include monitoring, recordkeeping, reporting, 

and/or other requirements which match the P2 measures implemented by the facility. 

Alternative emission limits could not be included. If approved, the alternative compliance 

requirements would replace specified requirements in the subpart. This option would be 

available for any regulated portion of the facility; it would not be necessary for the facility 

to implement P2 on every source of emissions that is subject to the subpart. Under this 

option, the facility would remain subject to the subpart, but some of the requirements would 

be changed. Either option would be effective only as long as the facility continued to use 

the P2 measures and to eliminate or reduce HAP emissions as described in the approved 

request. If the facility discontinued the P2 measures or failed to eliminate or reduce HAP 

emissions as approved, all applicable requirements of the subpart would again apply 

immediately, and the facility would be required to comply beginning on that date. 

We are also proposing additional incentives for sources at facilities that are members of the 

Performance Track program.” 

5. Proposed Rule, National Emission Standards for Hazardous Air Pollutants; 

General Provisions (January 3, 2007) 

http://www.epa.gov/fedrgstr/EPA-AIR/2007/January/Day-03/a22283.htm

The proposed amendments provide that a major source may become an area source at any 

time by limiting its potential to emit hazardous air pollutants (HAP) to below the major 

source thresholds of 10 tons per year (tpy) of any single HAP or 25 tpy of any 

combination of HAP. Thus, under the proposed amendments, a major source can become an 

area source at any time, including after the first substantive compliance date of an applicable 

MACT standard so long as it limits its potential to emit to below the major source thresholds. 

It is important to understand the differences in applicability between the p2 amendments, and 

OIAI and today’s proposal revising that policy. The proposed P2 amendments are targeted at 

the “affected source” as that term is defined in 40 CFR 63.2. “Affected source” describes the 

collection of regulated emission points defined as the entity subject to a specific MACT 

standard. . . .For example, an affected source could be a single production unit or the 

combination of all production units within a single contiguous area and under common 

control, or a single emission point or a collection of many related emission points within a 
102

single contiguous area and under common control. Each MAFT standard defines the 

“affected source” for regulation. 

By contrast, the 1995 OIAI policy and today’s proposed amendments that seek to replace that 

policy focus on “major sources,” as defined in 40 CFR 63.2. As explained above, major 

sources are defined by the total amount of HAP emitted form a stationary source or group of 

stationary sources located within a contiguous area and under common control. A major 

source can include several different affected sources subject to multiple MACT standards. 

6. May 3, 2007 Comments of the National Association of Clean Air Agencies on the 

January 3, 2007 Proposed Rule, National Emission Standards for Hazardous Air 

Pollutants, General Provisions 

The Clean Air Act clearly intends that major sources of hazardous air pollutants achieve 

“maximum” emissions reductions. By mandating specifically that MACT reflect “the 

average emission limitation achieved by the best performing 12 percent of the existing 

sources,” Congress was ensuring that major sources of hazardous air pollutants would be 

well controlled. The proposed OIAI rule, however, removes that level of public health 

protection and, instead, effectively establishes MACT as merely a point just below the major 

source threshold. 

Accordingly, NACAA opposes this proposal and believes EPA should allow exemptions to 

the OIAI policy only for those sources that have reduced emissions through pollution 

prevention (e.g., source reduction as defined in the EPA Pollution Prevention Act of 1990). 

In the proposal, EPA indicates that it is unlikely that sources that currently emit below the 

major source levels would increase their emissions as a result of this rule. Specifically, EPA 

states that the control devices that major sources have installed to satisfy the MACT 

requirements are designed to operate a certain way and cannot be operated such that only 

partial emission reductions result. Therefore, sources that have met a certain emission level 

would maintain that level of control. We do not agree with this assumption. First, control 

devices can be operated at different levels of efficiency. Because the costs related to 

operating controls at less efficient levels can be lower, it is likely that sources will decrease 

the efficiency, thereby allowing emissions to increase. Additionally, since potential-to-emit is 

calculated through the 

use of averages over time, sources could stop controlling emissions for part of the time and 

still remain just below the major source threshold. While EPA expresses confidence that the 

rule will not result in backsliding, there is nothing in the proposal that would prevent sources 

from increasing their emissions. 

NACAA is concerned that allowing sources to be reassigned as minor sources at any time 

would remove affected sources from the Title V program. This would undermine 

enforcement, inspection and monitoring requirements that are part and parcel of the Title V 

program. Additionally, NACAA has recommended that the Air Emissions Reporting 

Requirements rule call for Title V facilities to submit hazardous air pollutant (HAP) 

emissions data and indeed many states already supply some HAP data for major sources. 
103

Allowing sources that are subject to the MACT to become area sources and avoid major 

source permitting requirements will reduce the amount of quality inventory data available to 

EPA for its regulatory decision making. 

Additionally, since minor sources are not required to pay Title V fees, the permitting and 

related costs, which could be substantial, would no longer be supported by fees. 

We are also concerned that sources that are not subject to MACT are also not covered by the 

Residual Risk standards under Section 112(f). A change in the OIAI restrictions would 

provide a loophole that would allow sources that were once major to escape the important 

Residual Risk review. This is even more troubling in the case of a source that used to be 

subject to MACT and then subsequently, because of the relaxation in the regulations, 

increases its emissions to just below the major source cut off. These sources could be the 

source of significant risk, yet they would not be evaluated and regulated for the residual risks 

they pose. 

7. Examples of Technical and Procedural Rules that do not set Emission Limits for 

Industry. 

These examples were extrapolated from a review of the Agency’s Fall 2006 Semi-annual 

Regulatory Agenda. 

• General procedural rules (P2 not applicable) – rules on contract procedures, grant 

procedures, electronic reporting, information privacy, risk assessment guidelines, hiring, 

disposal standards, acquisition financing, and so on. 

• Air rules (where P2 not applicable) – rules on test procedures, technical vehicle 

provisions (gasoline requirements, import rules, recalls), general conformity provisions, 

methodologies (monitoring, modeling, measurement), technical reporting and 

certification requirements, response to petitions, yearly allocation of essential use 

allowances, baseline procedures, explosion protection, air quality definitions, findings on 

state plans, and so on. 

• Pesticide rules (where P2 not applicable) – rules on data requirements, procedural rules 

for hearings, worker protection standards, 

• Toxic substances rules (where P2 not applicable) – rules on chemical test requirements 

and testing agreements, inventory nomenclature, effects of transfer of ownership, 

reporting requirements, disclosure of known hazards, methodologies, and so on. 

• Resource conservation, wastes, contaminated sites, emergency response – leachate 

criteria, test criteria 

• Water rules (where P2 not applicable) 
104

Conclusion 2 

8. Background on role of P2 in major environmental laws. 

Pollution Prevention in Major Environmental Laws

Law Thematic Specific 

Pollution Prevention Act 

of 1990 

-P2 is the waste management option 

of choice, but opportunities are often 

overlooked by industry and EPA due 

to institutional barriers 

Creates a P2 Office; 

Directs EPA to establish P2 metrics, 

create measurable goals, assess program impacts on P2, and disseminate 

P2 information and training; 

Adds P2 section to TRI; 

Establishes P2 grant program 

Clean Air Act 

(as amended in 1990) 

P2 (defined as source reduction) is a 

primary goal. 

P2 is largely a state and local 

government responsibility, based on 

federal assistance and leadership 

P2 is a long-range strategy for acid 

rain and pollution from energy 

production/use 

Directs EPA to emphasize non-regulatory P2 in R&D and focus on highrisk pollutants; to create a ranking 

method for P2 technologies; and, to 

give guidance to States regarding P2 

and permits for small businesses.. 

State programs for P2 assistance for 

small business stationary sources. 

Clean Water Act of 1977 

(and subsequent 

amendments) 

No specific recognition of P2, yet 

repeatedly states need to “prevent, 

reduce, or eliminate” water pollution 

P2 is implied requirement for spill 

prevention planning 

P2 is appropriate strategy for Great 

Lakes, Lake Champlain 

Advisory board to include P2 focus 

Create Lake Champlain P2 strategy 

Federal Food Drug and 

Cosmetic Act 

No specific mention of P2, but 

requires EPA to find a reasonable 

certainty of no harm including using 

extra safety factors when a full set of 

data is not available. 

EPA’s review of nearly 10,000 

tolerances for pesticides in food 

resulted in numerous revocations and 

reductions in allowable limit. 

Food Quality Protection 

Act of 1996 

-No specific mention of P2, but 

emphasizes role of “integrated pest 

management” (IPM), which often has 

a P2 component aimed at reducing 

risks of both pests and pesticides 

Directs USDA and EPA to jointly 

implement an R&D and education 

program for IPM. 

Requires Federal agencies to adopt 

IPM via procurement and regulation. 

Safe Drinking Water Act 

of 1974 (and subsequent 

amendments) 

No specific mention of P2, but 1996 

amendments emphasize source water 

protection 

N/A 

Resource Conservation 

and Recovery Act of 

1976 (and t amendments) 

1976 law had no P2 component; 

1984 amendments add a substantial 

P2 (waste minimization) component. 

Hazardous waste generators and 

operators of treatment, storage, and 

disposal facilities must have a P2 plan 

in place 

Toxic Substances 

Control Act 

-No specific recognition of P2 

approaches 

N/A 
105

9. Multi-Year Workplan for the Registration of Conventional Pesticides.

http://www.epa.gov/opprd001/workplan/

OPP Annual Reports 

Annual Conventional Pesticide Registration New Use Decisions 

 Reduced Total 

Year Risk Registrations 

2006 40 186 

2005 27 164 

2004 40 231 

2003 65 227 

2002 [data not available]

2001 19 204 

TOTAL 191 1,012

Conclusion 3. 

10. Agency Guidelines for Preparing Economic Analyses 

http://yosemite.epa.gov/ee/epa/eed.nsf/webpages/Guidelines.html/$file/Guidelines.pdf

“...Estimating responses is often the most difficult for pollution prevention policies because these 

options are generally more site- and process-specific than end-of-pipe control technologies. 

Predicting the costs and environmental effects of pollution prevention policies may require 

detailed information on industrial processes. As a result, the costs of a pollution prevention policy 

may be overstated and the benefits either over- or understated (depending on the nature of the 

process changes involved). Nevertheless, economic analyses should at least include qualitative 

discussion of potential pollution prevention responses and their effects on costs and benefits.” 

11. 2001 Economic Impact Analysis for the Boat Manufacturing National 

Emission Standard for Hazardous Air Pollutants 

http://www.epa.gov/ttnecas1/regdata/EIAs/boateia.pdf

“. . .The estimated costs of complying with the NESHAP do not consider any potential 

cost reductions from emissions averaging. It is difficult to determine how particular 

facilities will implement the variety of options of emissions averaging or whether they 

will use it to achieve greater operating flexibility at the same regulatory cost. Therefore, 

the estimated compliance costs are an upper-bound estimate in that we assume that no 

facilities will use emissions averaging. . . 

The flowcoaters themselves require an initial outlay and are slightly more expensive to 

operate and maintain. However, EPA estimates that the majority of survey facilities will 

experience overall cost savings when floor covering and resin cost savings are added to the 

flowcoater cost impacts. If the net cost (capital and OM costs less the cost savings) was 
106

negative for a given surveyed facility, the total cost of switching from spray guns to 

flowcoaters was assumed to be zero. 

We assumed that if a facility is expected to see an overall cost saving from changing 

production processes, the facility will make this change voluntarily when the current capital 

associated with the process depreciates. Thus, the cost savings are not directly attributable to 

the regulation and should not be used to offset cost impacts for other regulated materials, 

such as gel coats or adhesives. . . “ 

Conclusion 4. 

12. 2001 Evaluation of Implementation Experiences with Innovative Air 

Permits: Results of the U.S. EPA Flexible Permit Implementation Review. 

http://www.epa.gov/ttn/oarpg/t5/memoranda/iap_eier.pdf

See pages 19-23 for the full discussion under Conclusion 3 of the 2001 evaluation. 

2001 Evaluation Conclusion 3: The flexible permits facilitated and encouraged emissions 

reductions and pollution prevention. 

The flexible permits were designed to bring sharper attention to the current level of actual 

plant-emissions and emissions per unit of production. While the permits generally did not 

require actual emissions reductions during the permit term, they contained provisions to 

facilitate and encourage emissions reductions and P2. The permit implementation 

experience, supported by statements from the sources and permitting authorities, indicates 

that the permits were effective in facilitating emissions reductions and P2. Of sources which 

had been operating under their flexible permits for three or more years, all five 

accomplished a significant lowering of actual plant-wide emissions and/or emissions per 

unit of production. Achieving 

environmental benefits was attributed by the companies to several factors, as discussed 

below. 

Paraphrased summary observations: 

The flexible permits contain mechanisms designed to facilitate and encourage 

emissions reductions and pollution prevention (P2). Five of the sources with 

flexible permits lowered actual plant-wide emissions during their permit terms, 

and the sixth source lowered its emissions per unit of production during the 

permit term. For example, using pollution prevention (P2), Intel lowered actual 

emissions of volatile organic compounds (VOCs) from 190 tons/year to 56 

tons/year while increasing production. After a substantial voluntary reduction of 

VOC emissions from 10,000 tons/year, 3M further lowered its actual VOC 

emissions from 4,300 tons/year to below 1,000 tons/year. This reduction resulted 

primarily from increased pollution control device performance, greater use of 

voluntary controls, P2, and reduced production. DaimlerChrysler lowered its 
107

actual VOC emissions from 1,400 tons/year to less than 800 tons/year, primarily 

through P2 associated with vehicle coatings and plant solvent usage. 

The plant-wide emissions caps focused organizational attention on reducing plant-wide 

emissions. In many cases, the advance approved change provisions reduced the 

administrative "friction" associated with P2 changes, making such changes more attractive 

for sources to undertake. The flexible permits increased internal awareness and focus on 

pollution prevention at the sources through explicit P2 program, reporting, and/or 

performance requirements. 

 

13. Final New Source Review Improvement Rule, December 31, 2002 

http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2002/pdf/02-

31899.pdf 

The following excerpt from the Notice shows the breadth of sources this rule applies to. 

“Entities potentially affected by this final action include sources in all industry groups. The majority of 

sources potentially affected are expected to be in the following groups.” 

Industry Group SIC NAICS 

Electric Services 491 221111, 

221112,2211113, 

221119, 221121, 

221122 

Petroleum refining 291 32411 

Chemical Processes 281 325181, 32512, 

235131, 211112, 

325998, 

331311,325188 

Natural Gas Transport 492 48621, 22121 

Pulp and Paper Mills 261 32211,322121,322122, 

32213 

Paper Mills 262 322121, 322122 

Auto Manufacturing 371 336111,336112, 

336712, 336211, 

226992, 226322, 

336312, 33633, 33634, 

336399, 336212, 

336213 

Pharmaceuticals 283 325411, 325412, 325413, 

325414 

The following excerpt from the Notice shows the P2-related incentive in the rule. 

“ Plantwide Applicability Limitations A PAL is a voluntary option that will 
108

provide you with the ability to manage facility-wide emissions without triggering major 

NSR review. We believe that the added flexibility provided under a PAL will facilitate your 

ability to respond rapidly to changing market conditions while enhancing the 

environmental protection afforded under the program. 

Today we are promulgating a PAL based on plantwide actual emissions. If you keep the emissions 

from your facility below a plantwide actual emissions cap (that is, an actuals PAL), then these 

regulations will allow you to avoid the major NSR permitting process when you make alterations 

to the facility or individual emissions units. In return for this flexibility, you must monitor 

emissions from all of your emissions units under the PAL. The benefit to you is that you can alter 

your facility without first obtaining a Federal NSR permit or going through a netting review. A 

PAL will allow you to make changes quickly at your facility. If you are willing to undertake the 

necessary recordkeeping, monitoring, and reporting, a PAL offers you flexibility and regulatory 

certainty.” 

14. East Bay Municipal Utility District Wastewater Department (EBMUD, 

Oakland, CA) 2006 Annual Report 

http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution_prevention_program/a

nnual_report/ww_pollution_prevention_annualreport/_2006.pdf [unable to open]

EBMUD is required by its NPDES Permit No. CA0037702.to produce an annual report 

that includes P2 information. In the 2006 report, Chapter 6 describes accomplishments of 

its P2 Program. Items mentioned in the report include: 

 During 2006, more than 3,600 permits were in effect under the Pretreatment and Pollution 

Prevention Program including 11 federal categorical minimization permits, 21 Zero Dischargefederal categorical permits, one Zero Discharge-Local permit, 49 non-categorical minimization 

permits, 34 estimation permits and over 3,500 pollution prevention permits. 

 The Environmental Services Division performed 249 inspections with sampling to assess 

compliance by permitted industrial users. District staff also conducted 548 pollution prevention, 

1,716 Business Classification Code (BCC) and 26 Zero Discharge inspections, and participated in 

public outreach activities. 

 Incorporated a “Pollution Prevention Corner” article into each edition of the District Pipeline, a 

water bill insert for all 1.2 million District customers. 

 Expanded implementation of a Regional FOG [fats, oils, grease] program [resulting] in the 

issuance of pollution prevention permits to more than 2,000 food handling facilities. 

 Dental Facilities Pollution Prevention Permit...Continue to determine dental facilities’ 

compliance with permit requirements, including the installation of an ISO 11143 Standard 

amalgam separator (one-time requirement) and the handling of amalgam waste and spent fixer 

solution (annual requirement)...More than 96 percent of permitted dental facilities have installed 

amalgam separators.

15. Characterization of the Underground Injection Control Program for 

Pollution Prevention 
109

UIC permits—the Underground Injection Control (UIC) program regulates a major pathway 

for waste disposal in the United States. More than 800,000 injection wells are covered by the 

program, and more than 9 billion gallons of hazardous wastes are disposed of each year via 

underground wells, (http://www.epa.gov/safewater/uic/) 

along with large volumes of non-hazardous wastes. 

In the course of this assessment project, no recent information was identified that linked the 

activities of the underground injection program to pollution prevention. Neither the 

underground injection permits, nor the guidance materials for the underground injection 

program, include a P2 focus. (http://www.epa.gov/r5water/uic/forms/act-samp.pdf and 

http://www.epa.gov/safewater/dwa/electronic/presentations/uic/uicpermit.pdf) 

In conversations with staff and managers in the Office of Water (October 19, 2006 Interview 

with Mike Shapiro, Deputy Assistant Administrator, Office of Water), it was clear that the 

prevention aspects of underground injection are focused on prevention of contamination—

underground injection is carried out in a manner that minimizes the likelihood of leaks from 

the injection wells, or migration of wastes away from the underground strata into which they 

are injected. 

Since underground injection is protective of the environment, the program does not take 

measures to encourage source reduction of the wastes being injected. Although the P2 Act 

establishes a national policy that “disposal...should be employed only as a last resort”, it is 

difficult to find any suggestion that this policy is at work in this particular program. 

A1989 memo http://www.epa.gov/safewater/uic/pdfs/24892.pdf from the Office of Drinking 

Water urged Regional Division Directors to incorporate P2 into permits for underground 

injection wells, as part of EPA’s commitment to pollution prevention as a top priority for the 

Agency. The memo concludes that underground injection “...is a good candidate through 

which to promote [pollution prevention] because of the large volumes of waste handled by 

this method.” As noted, though, no examples of P2 in underground injection permits were 

identified during the course of this project. 

16. Compliance and Enforcement P2 Integration Materials 

 P2 Integration Opportunities Application 

Policy, Guidance and Executive Orders 

Supplemental Environmental Projects Policy (March 2002) 

http://www.epa.gov/compliance/resources/policies/civil/seps/s

epguide-mem.pdf

Encourages SEPs involving P2 techniques, and provides 

additional incentives for violators who choose to implement 

a P2 SEP as part of an enforcement settlement. 

Role of the EPA Inspector in Providing Compliance 

Assistance (1998) 

http://www.epa.gov/Compliance/resources/policies/monitorin

g/inspection/roleinspect.pdf 

Discusses integrating various approaches to conducting 

inspections including “coordinated multimedia, wholefacility, and pollution prevention oriented compliance 

assurance strategies.” 

Inspector’s Compliance Assistance Resources Guide 

(1999) 

Provides EPA inspectors compliance assistance and P2 

resources to share with facilities during inspections. 
110

National Pollutant Discharge Elimination System (NPDES) 

Compliance Inspection Manual (2004) 

http://www.epa.gov/Compliance/resources/publications/monit

oring/cwa/inspections/npdesinspect/npdesinspect.pdf

Provides basic P2 assessment guidelines of industrial 

facilities and municipalities for inspectors to consider in 

helping regulated entities prevent noncompliance. 

Small Business Compliance Policy (May 2000) 

http://www.epa.gov/Compliance/resources/policies/incentives

/smallbusiness/sbcp2000.pdf 

Encourages small business to self-disclose and correct 

violations identified through business activities including 

pollution prevention assessments in exchange for reduced 

or waived civil penalties. 

Executive Order 13423, Strengthening Federal 

Environmental, Energy, and Transportation Management 

(January 2007) 

http://www.ofee.gov/eo/EO_13423.pdf

EPA helps federal facilities meet their executive order 

requirements by conducting environmental management 

reviews that help identify P2 strategies for renewable 

energy, toxics reductions, and sustainable buildings. 

Framework for Addressing Environmental Problems 

(January 2003) 

http://www.epa.gov/enforcement/resources/policies/assistance

/strategicguide.pdf

Defines an approach to address significant environmental 

problems considering all tools including P2, best 

management practices and voluntary programs. 

Guide for Addressing Environmental Problems: Using an 

Integrated Strategic Approach (March 2007) 

http://www.epa.gov/enforcement/resources/policies/assistance

/strategicguide.pdf

Provides real examples of how to address environmental 

problems using a variety of compliance assurance tools and 

P2 practices to promote sustainability. 

Outreach Vehicles 

Compliance Assistance Centers (1995 - present) 

www.assistancecenters.net

15 sector-specific web-based Centers provide compliance information; some centers share P2 tips, practices. 

National Compliance Assistance Clearinghouse 

(2001- present) 

www.epa.gov/clearinghouse

Provides compliance information to assistance providers 

including 275 federal and state P2 resources s(reports, 

guidance documents, links to P2 web sites). 

Sector Notebooks (1994 - present) 

http://www.epa.gov/compliance/resources/publications/assistanc

e/sectors/notebooks

35 guides describing industry environmental profiles 

including P2 opportunities, operating and process tips, 

relevant initiatives and organizations. 

Initiatives and Incentives 

Protocol for Conducting Environmental Audits Under the 

Stormwater Program (January 2005) 

http://www.epa.gov/compliance/resources/policies/incentives/au

diting/apcol-stormwater.pdf

Provides to facilities the mechanics to conduct an 

environmental audit to determine compliance with 

regulations and, in turn, to help identify pollution 

prevention and cost saving approaches. 

Environmentally Responsible Redevelopment and Reuse (ER3) 

Initiative 

http://www.epa.gov/compliance/cleanup/redevelop/er3/index.ht

ml

Initiative to provide enforcement related incentives to 

developers who incorporate sustainable concepts into 

their cleanup and redevelopment of contaminated sites 

which often take the form of P2. 

Measurement Data Systems and Reporting Tools 

Integrated Compliance Information System 

http://www.epa.gov/compliance/data/systems/modernization/ind

ex.html

The Web-based system enables states and EPA to access 

integrated enforcement, compliance, compliance 

assistance and NPDES data from any desktop connected 

to the Internet including P2 SEPs and activities. 

Case Conclusion Data Sheet (CCDS) and Interactive Guide to 

Using the CCDS (July 2005) 

http://www.erg.com/portfolio/elearn/oeca/site/ccdsform/index.ht

ml

The comprehensive Web-based training is for EPA staff 

to completely and accurately complete the CCDS 

including P2 and calculation of pollution reductions. 

The Compliance Assistance Conclusion Data Sheet (July 2005) 

http://www.epa.gov/compliance/resources/publications/assistanc

e/measures/cadatasheet.pdf

EPA measurement form on compliance assistance visits 

which asks additional purposes of the visit including 

pollution prevention assessments 

Enforcement and Compliance History Online (ECHO) 

http://63.160.3.204/echo/index.html

Publicly accessible EPA database for inspections and 

enforcement actions including P2 SEPs. 
111

Number of SEPs (FY 1999 - FY 2006) 

 1999 2000 2001 2002 2003 2004 2005 2006 Total

CAA 33 31 35 51 40 68 50 71 379

CERCLA 24 20 32 24 10 20 17 17 164

CWA 26 46 21 32 35 50 66 53 329

EPCRA 53 49 42 32 28 41 32 34 311

FIFRA 4 1 1 1 0 3 2 2 14

MPRSA 0 0 0 0 0 0 1 0 1

RCRA 32 22 34 24 29 36 20 25 222

SDWA 3 6 5 2 0 5 3 12 36

TSCA 18 19 15 20 24 35 35 30 196

Total 193 194 185 186 166 258 225 244 1651

Number of P2 SEPs (FY 1999 – FY 2006) 

 1999 2000 2001 2002 2003 2004 2005 2006 Total

CAA 19 21 18 22 16 30 20 31 177

CERCLA 3 6 2 3 3 6 6 3 32

CWA 7 22 8 8 10 8 7 8 78

EPCRA 12 12 10 10 7 10 7 4 72

FIFRA 0 0 0 0 0 1 1 0 2

RCRA 17 15 16 15 11 16 13 14 117

SDWA 2 0 2 1 0 0 1 10 16

TSCA 6 10 6 4 9 4 2 9 50

Total 66 86 62 63 56 75 57 79 544

Percent of P2 SEPs (FY 1999 – FY 2006) 

 1999 2000 2001 2002 2003 2004 2005 2006 Total

CAA 58% 68% 51% 43% 40% 44% 40% 44% 47%

CERCLA 13% 30% 6% 13% 30% 30% 35% 18% 20%

CWA 27% 48% 38% 25% 29% 16% 11% 15% 24%

EPCRA 23% 24% 24% 31% 25% 24% 22% 12% 23%

FIFRA 0% 0% 0% 0% 33% 50% 0% 14%

RCRA 53% 68% 47% 63% 38% 44% 65% 56% 53%

SDWA 67% 0% 40% 50% 0% 33% 83% 44%

TSCA 33% 53% 40% 20% 38% 11% 6% 30% 26%

Total 34% 44% 34% 34% 34% 29% 25% 32% 33%

Source: ICIS data, as generated by OECA in July 2007 
112

Conclusion 6. 

17. List of Partnership Programs 

The list of partnership programs compiled by the Office of Policy, Economics, and Innovatioin is 

as follows. 

OAR 23 

OPPTS 11 

OW 7 

OSWER 7 

 Others 4

Partnership 

Program Name 

Program 

Office 

Program Description Pollution Prevention 

Adopt Your 

Watershed 

OW Encourages local citizen to 

protect watersheds 

Focus is largely on monitoring, cleanup 

and remediation, with little P2 focus 

AgStar OAR Biogas (methane) recovery at 

confined animal feedlots 

There is no source reduction from the 

feedlots, but the program focus on 

waste-to-energy is sometimes 

considered P2 

Best Workplaces 

for Commuters 

OAR Promotes energy savings 

through alternative commuting 

strategies. 

P2 via energy conservation 

Carpet America 

Recovery Effort 

OSWER MOU between EPA and 

industry to promote recovered 

value from used carpets 

Promotes reclamation rather than 

source reduction 

Clean Diesel 

Campaign 

OAR Broad strategy to reduce diesel 

emissions, combining regulatory 

and partnership approaches 

Encourages cleaner fuels, engine 

retrofit, and reduced idling time as key 

reduction strategies. 

Clean Energy 

Environment State 

Partnership 

Program 

OAR Currently works with 15 partner 

states to develop comprehensive 

strategies for saving energy and 

reducing energy-related 

emissions 

Energy efficiency and use of clean 

fuels are key components of reduction 

strategies 

Climate Leaders OAR Participating companies set 

voluntary greenhouse gas 

reduction goals 

P2 in the form of energy efficiency is 

one of the key strategies by which 

greenhouse gases are being reduced 

Coal Combustion 

Products 

Partnership 

OSWER Beneficial use of coal ash in 

roadways and other uses 

The program has a primary 

reuse/recovery focus, which reduces 

raw material and energy demands, 

leading to source reduction. 

Coalbed Methane 

Outreach Program 

OAR Use methane generated during 

coal mining as an energy source 

There is no source reduction from the 

coal mines, but the program focus on 

waste-to-energy is sometimes 

considered P2 

Combined Heat 

and Power 

Partnership 

OAR Encourages simultaneous 

generation of heat and power 

from a single source 

Promotes P2 via energy efficiency 
113

Partnership 

Program Name 

Program 

Office 

Program Description Pollution Prevention 

CommunityBased Childhood 

Asthma Programs 

OAR Outreach and awareness 

campaign to lessen the impacts 

of childhood asthma. 

Focus on avoiding exposures to 

triggers includes advice on P2 

approaches for reducing triggers at the 

source. 

Design for the 

Environment 

OPPTS Incorporates green chemistry 

into product design and manufacturing processes 

The "benign by design" focus of the 

program has an inherent P2 focus 

Diesel Retrofit 

Program 

OAR Incorporates green chemistry 

into product design and 

manufacturing processes 

P2 is incorporated in the cleaner engine 

focus of the program 

Energy Star OAR Focuses on reducing energy 

demand in residential, 

commercial and industrial 

settings. 

P2 in the form of energy efficiency is 

an inherent component of the Energy 

Star program. 

Environmental 

Technology 

Verification 

Program 

ORD Evaluates new technologies for 

potential environmental benefit 

P2 and energy efficiency technologies 

are explicitly included in ETV program 

design 

Environmentally 

Preferable 

Purchasing 

OPPTS Assists federal agencies in 

complying with “green 

purchasing” executive order 

P2 is one of the central “guiding 

principles” of EPP 

Federal 

Electronics 

Challenge 

OW Encourages EPP and life-cycle 

management of federallypurchased electronics 

A strong emphasis on recycling and 

reuse is combined with a P2 focus in 

terms of energy efficiency and reduced 

use of toxic chemicals 

Great American 

Woodstove 

Changeout 

Campaign 

OAR Encourages use of highefficiency and alternatives to 

wood stoves as a means of 

reducing emissions; includes 

financial incentives (rebates). 

Focus on improving efficiency and 

using lower-emission fuels is 

inherently P2. 

Green Chemistry OPPTS Aims to reduce reliance on 

hazardous chemicals in 

designing chemical products 

Program is inherently P2, with an 

emphasis on minimizing reliance on 

hazardous chemicals, and reducing 

wastes at source 

Green 

Engineering 

OPPTS Life cycle approach to 

engineering to produce greener 

products and processes 

Program is inherently P2, with an 

emphasis on minimizing reliance on 

hazardous chemicals, and reducing 

wastes at source 

Green Suppliers 

Network 

OPPTS Applies the principles of lean 

manufacturing to manufacturing 

waste streams 

Improving efficiencies of materials 

handling and energy use can lead to P2 

improvements 

GreenScapes OSWER Encourages landscaping 

practices to reduce the overall 

environmental footprint 

A primary focus is the reduction of 

material and energy inputs, thereby 

encouraging P2 practices 
114

Partnership 

Program Name 

Program 

Office 

Program Description Pollution Prevention 

High Production 

Volume Challenge 

OAR [no information available on 

EPA website] 

There is no direct P2 component to this 

program. Identification of chemical 

effects may lead to P2 activities, 

however 

High Production 

Volume Challenge 

OPPTS Collects data on health and 

environmental effects of highvolume chemicals 

The program has an inherent P2 focus 

aimed at reducing wastes at the source 

Indoor Air Quality 

Tools for Schools 

OAR Encourages improved indoor air 

quality in schools through a 

wide variety of practices. 

P2 is included in emissions reduction 

strategies for improving indoor air 
115

Labs 21 OARM Takes a “whole building” 

approach to making labs more 

sustainable, largely focused on 

energy use 

P2 through energy conservation 

Landfill Methane 

Outreach Program 

OAR Emphasizes the use of methane 

gas from decomposition at 

landfills as an energy source 

There is no source reduction from the 

landfills, but the program focus on 

waste-to-energy is sometimes 

considered P2 

Mobile Air 

Conditioning 

Climate Protection 

OAR Focuses on vehicle air 

conditioners as a source of 

greenhouse gas emissions 

P2 is encouraged via leak prevention, 

proper maintenance, and new 

technologies with less greenhouse gas 

impact 

Natural Gas Star OAR Targets the gas distribution 

sector to reduce losses of 

methane 

Inherently P2, as most of program is 

leak prevention and improved 

efficiency of delivery 

National 

Partnership for 

Environmental 

Priorities (NPEP) 

OSWER Voluntary partnerships with 

public and private organizations 

to reduce or eliminate any of 31 

targeted priority chemicals. 

Promotes an action hierarchy that 

focuses first on source reduction, and 

when not feasible, promotes 

reuse/recycling 

Partnership for 

Safe Water 

OW Partners with drinking water 

treatment facilities to reduce 

microbial contamination 

No conventional P2 components 

identified 

Pesticide 

Environmental 

Stewardship 

Program 

OPP Encourages use of techniques 

that reduce risks of both the pest 

and pesticides that are based on 

principles of Integrated Pest 

Management. 

Integrated Pest Management is a 

sustainable approach to managing 

pests by combining biological, cultural, 

physical, and chemical tools 

to minimize economic, health, and 

environmental risks. Many IPM 

approaches are inherently P2. 

Plug-In to 

eCycling 

OSWER Education and pilot project 

program to increase recycling of 

electronics 

Strong focus on reuse, which is 

inherently P2, and recycling which 

reduces energy use and GHG emissions 

Radon Risk 

Reduction 

OAR Largely focused on reducing 

risks from radon exposures in 

the buildings 

Little P2, since the focus is 

remediation, although new construction 

can be made radon-resistant, a form of 

source reduction 

Reduced Risk for 

Conventional 

Pesticides 

OPPTS Participants submit extra 

information on reduced-risk 

pesticides, in exchange for 

expedited review 

P2 component, in that program 

encourages faster timelines for using 

lower-risk pesticides 

Schools Chemical 

Cleanout 

Campaign 

OSWER Seeks to reduce risks from 

hazardous chemicals at schools 

by encouraging effective 

materials management 

While largely focused on safe handling 

and disposal, program also encourages 

reduced use of hazardous materials. 

Sector Strategies OA Promotes the use of 

Environmental Management 

Systems, and identifies and 

removes regulatory burdens to 

environmental progress 

No active P2 component, though EMS 

may focus attention on source 

reduction opportunities 
116

SF6 Emission 

Reduction 

Partnership for 

Electric Power 

Systems 

OAR Encourages utilities to minimize 

emissions of sulfur hexafluoride, 

a potent greenhouse gas 

Program relies heavily on source 

reduction measures—leak prevention 

and equipment maintenance—as well 

as recycling. Participants set numerical 

reduction goals 

Smart Way 

Transport 

OAR Works with the freight industry 

to reduce emissions of 

greenhouse gases and air 

pollutants 

Program has a substantial P2 focus, 

based on improving energy efficiency, 

and reducing idling time, both forms of 

source reduction 

Sustainable 

Futures 

OPPTS Provides expedited review of 

new chemicals that can 

demonstrated lower risk 

Program adheres to a “Pollution 

Prevention Framework” that uses risk 

screening tools to reduce impacts of 

proposed new chemicals 

The SunWise 

School Program 

OAR Education program to teach 

about protecting oneself from 

overexposure to the sun 

No P2 component 

Voluntary 

Aluminum 

Industrial 

Partnership 

OAR Aims to reduce emissions of 

perfluorocarbon (PFC), a 

greenhouse gas produced during 

aluminum manufacturing 

P2 is inherent in program design, 

which aims to minimize or eliminate 

PFC production at the source, through 

process changes 

Voluntary 

Children's 

Chemical 

Evaluation 

Program 

OPPTS Focuses on improving baseline 

information for 23 chemicals to 

which children are often 

exposed 

No P2 component to the program, 

although information availability may 

lead to actions by producers and 

consumers than include P2 

Volunteer Water 

Monitoring 

Program 

OW Provides opportunities for 

citizen involvement in water 

quality monitoring programs 

Program focuses mostly on spotting 

water quality problems, although P2 is 

referenced as a potential means of 

solving problems 

WasteWise OSWER Program enlists business and 

institutional partners to review 

solid waste generation, and plan 

steps for reducing wastes 

Major focus of the program is 

recycling, although source reduction of 

municipal solid waste and greenhouse 

gases are also encouraged 

WaterSense OW Promotes the use of waterefficient products in the home 

and business 

P2 in inherent in efforts to reduce water 

use. 

Watershed/Water 

Drop Patch 

Project 

OW Watershed and wetlands 

protections program, in 

conjunction with the 

Girl Scouts of America. 

While mostly an educational program, 

P2 is part of the focus of protecting 

water resources. 
117

Evaluation Question 3. 

17. Background on TRI 

Source: TRI Public Data Release, 2004 

 www.epa.gov/tri/tridata/tri04/ereport/2004eReport.pdf 

How did total production-related waste managed change from 2003 to 2004? 

The preferred measure of environmental progress is reduction in TRI releases. To the extent 

that releases are still occurring, another measure of progress may be seen in changes in 

management practices, in a way that limits potential for human exposure and environmental 

contamination. We have seen a shift from 2003 to 2004 in how TRI chemical releases are 

managed. 

Total production related waste increased by 4% (1.10 billion pounds) from 2003 to 2004. This 

included an overall decrease in the quantity disposed of or otherwise released of 4% (188 

million pounds) and increases in some types of other waste managed. 

• Treatment on-site increased by 11% (828 million pounds). 

• Recycling on-site increased by less than 1% (7.8 million pounds). 

• However, energy recovery onsite decreased by 1% (20 million pounds). 

• Recycling off-site increased by 22% (419 million pounds) 

• Treatment off-site increased by 9% (45 million pounds) 

• Energy recovery off-site decreased by less than 1% (1.4 million pounds) 

 Source: TRI Public Data Release, 2004 

 www.epa.gov/tri/tridata/tri04/ereport/2004eReport.pdf 
118

Year TPWM GDP 

 (pounds) (billion $, inflation-adjusted) 

1992 15,827,869,154 7,337 

1993 16,035,677,429 7,533 

1994 17,051,677,356 7,836 

1995 16,269,888,655 8,032 

1996 16,199,740,294 8,329 

1997 16,777,938,063 8,704 

1998 16,797,221,632 9,067 

1999 17,300,772,798 9,470 

2000 21,940,500,957 9,817 

2001 16,345,659,057 9,891 

2002 16,763,964,307 10,075 

2003 15,559,571,275 10,381 

2004 16,122,640,808 10,842 

Source: 

TRI data from TRI Explorer for 1991 core chemicals 

www.epa.gov/triexplorer/trends.htm 

GDP data from 2006 Statistical Abstracts of the United States 

www.census.gov/compendia/statab/ 

P2 practices have not 

reduced TRI total 

production wastes... 
119

% of Forms, 2004 TRI, indicating source reduction activity

by EPA Region

0

2

4

6

8

10

12

14

1 2 3 4 5 6 7 8 9 10

Region

percent
120

18. SmartWay data 
121

19. SF6 Emission Reduction Partnership 

 PARTNER’S RESPONSIBILITIES 

1. Establish a base year from which to begin estimating and reporting SF6 emissions. The base 

year may be the year in which the MOU is signed or up to two years prior; 

2. Submit a report each year on system-wide emissions of SF6 and describe technologies and 

practices implemented to reduce emissions; 

3. Develop and distribute a company-wide policy for the proper handling of SF6 within one year of 

joining the program; 

4. Establish an SF6 emissions reduction goal, after careful consideration of all technically and 

economically feasible options available; and 

5. Communicate to employees and cooperate with EPA efforts to publicize the Partnership. 

Source: www.epa.gov/highgwp/electricpower-sf6/pdf/finalmou.pdf 

20. Municipal Solid Waste 

Municipal Solid Waste in the United States: 2005 Facts and Figures 

www.epa.gov/msw/pubs/mswchart05.pdf
122

Recovery and recycling appear to play the major role in changes to overall patterns of 

MSW management. Some additional perspective on the relative roles of source 

reduction, recycling, and reuse were provided by OSW, as shown below. 

 

Evaluation Question 4. 

Conclusion 27. 

Background: EPA Regulatory Plans 

http://www.epa.gov/opei/orpm.html#agenda

EPA Regulatory Plans, issued each Fall, portray what the Agency perceives as its 

most important regulatory and deregulatory actions reasonably expected to be 

issued in the upcoming year. While these plans are not goal-setting activities, 

they still provide meaningful context as to what the Agency perceives as 

important. Early Regulatory Plans highlight the role of P2 in regulatory and 

Products that enter the waste stream have energy impacts (and associated GHG emissions) at each stage of their life 

cycle. These life cycle stages include: 

 Acquisition of raw materials 

 Manufacture of raw materials into products 

 Product use by consumers 

 Product disposal 

Waste reduction practices, such as reuse and recycling, reduce the demand for raw material and energy inputs to the 

manufacturing stage of the life cycle, thereby conserving energy and reducing GHG emissions. The energy savings 

associated with recycling are driven largely by the difference between manufacturing the material using virgin 

inputs and manufacturing the material using recycled inputs. 

Recycling of waste has a substantial potential for reducing overall greenhouse gas emissions and conserving energy 

use. In 2003, the United States recycled 30.6 percent of the municipal solid waste (MSW) it produced. As part of its 

effort to encourage recycling, waste reduction, and GHG reduction, the EPA has set national recycling goal of 35 

percent by 2008 and has proposed a goal of 40 percent by 2011. 

Using EPA’s WAste Reduction Model (WARM)—a model that was developed to help solid waste planners and 

organizations track and voluntarily report greenhouse gas emissions reductions waste management practices - EPA 

calculated the projected incremental benefits of these goals. The current rate of 30.6 percent gave GHG benefits in 

2003 of 49 MMTCE (million metric tons of carbon equivalents) and energy benefits of 1.5 quadrillion Btu saved 

can be compared to a baseline of no recycling. These calculations assume landfilling 80 percent and combusting 20 

percent of MSW not recycled (the national average rates). Increasing the rate to 35 percent would give GHG 

benefits in 2008 of 57 MMTCE and energy benefits of 1.7 quadrillion Btu saved. The benefits in 2011 of a 40 

percent recycling rate would be 65 MMTCE and 1.9 quadrillion Btu. 
123

permit programs. More recent plans emphasize a role for P2 that falls outside the 

regulatory process: 

1995: ...permitters are paying more attention to pollution prevention and market 

mechanisms...EPA also has established a permits improvement team to streamline permit 

programs, reduce their administrative costs, and enhance pollution prevention. 

1996: EPA will propose an integrated rule for the pulp and 

paper industry that deals with both effluent guidelines and air 

emission standards to control the release of pollutants to both 

water and air. The regulations are being developed jointly to 

provide greater protection to human health and the 

environment, to promote the concept of pollution prevention... 

1997: Currently, chemical manufacturers are required to report the names of the chemicals they 

produce, the quantity produced, and the locations of manufacturing facilities. EPA plans to 

propose expanding this to include information on potential exposure to the chemical and how the 

chemicals are used (e.g., in manufacturing processes). This allows EPA and others to identify the 

chemicals of highest concern so that the Agency can set goals for chemical assessment, risk 

management, and prevention programs. The action will also encourage pollution prevention by 

identifying safer chemical substitutes. 

1998-99: [The plans for 1998 and 1999 included a reiteration of much of the above language 

from the 1995-1997 reports.] 

2000: The National Environmental Performance Track 

Program is being implemented initially with the Achievement 

Track program... One part of this is changes in the regulations 

specifying reporting by facilities covered by the MACT 

provisions of the Clean Air Act. Facilities meeting the criteria 

for membership in Achievement Track would be eligible for 

reduced reporting and some other provisions, and facilities that 

more than meet goals for emissions reductions under MACT 

via pollution prevention means would qualify for some additional reduced reporting. 

2001: We are now changing regulations that set reporting requirements for facilities covered by 

the MACT provisions of the Clean Air Act. Facilities meeting the criteria for membership in 

Performance Track would be eligible for reduced reporting and some other provisions, and 

facilities that more than meet goals for emissions reductions under MACT via pollution prevention 

means would qualify for some additional reduced reporting. 

2002: To encourage the application of pollution prevention 

principles during the development of new chemicals...EPA has 

initiated a new and innovative voluntary pilot project entitled 

Sustainable Futures. The goal of this pilot project is to 

encourage pollution prevention and the development of 

inherently low-hazard chemicals. Also, the Agency seeks to 

gain additional data and experience regarding the pollution 

prevention, risk reduction, and source reduction benefits of use 

of hazard, exposure, and risk screening methodologies such as EPA's Pollution Prevention 

Framework in new product development efforts. 

...EPA is considering modifying RCRA rules that impact the management of solventcontaminated shop towels and wipes. This effort would encourage pollution prevention and 

1995-1999 plans emphasized 

P2 in the context of permits, air 

and water rules, and chemical 

reporting. 

2000-2001 plans emphasized 

P2 in air (MACT) permits via 

the Performance Track 

program. 

The 2002 Regulatory Plan cites 

a mix of voluntary and 

regulatory activities intended to 

promote P2. 
124

recycling of hazardous solvents, make management standards more consistent with the risks these 

materials pose, and clarify existing Federal policies regarding 

these materials. 

 

2003: The science priorities for Compliance and Environmental 

Stewardship are pollution prevention practices; new technology 

development; socioeconomics; and decision-making... 

2004: The Agency works through its headquarters and regional 

offices with over 10,000 industries, businesses, non-profit 

organizations, and state and local governments, on more than 

40 voluntary pollution prevention programs and energy 

conservation efforts. 

2005: [ no mention of pollution prevention.] 

2006: The Pollution Prevention Act cited as the legal 

underpinning for the Toxics Release Inventory Reporting 

Burden Reduction Rule. 

 

2003-2004 Regulatory Plans 

cite P2 as a science and 

voluntary programs priority, 

while the 2005 plan is silent on 

P2. 

The 2006 Regulatory Plan cites 

PPA as the basis for Burden 

Reduction under TRI.