UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

 WASHINGTON D.C. 20460 

OFFICE OF THE ADMINISTRATOR 

 SCIENCE ADVISORY BOARD 

November 25, 2008 

EPA-SAB-09-005 

The Honorable Stephen L. Johnson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460 

Subject: Consultation on Pollution Prevention Measures 

Dear Administrator Johnson: 

EPA’s Office of Pollution Prevention and Toxics (OPPT) currently uses a suite of 

measures to evaluate the effectiveness of EPA’s pollution prevention (P2) programs. 

OPPT requested the Science Advisory Board (SAB) provide consultative advice on 

sound methodologies for measuring P2 program performance results, particularly 

recurring results. In response to OPPT’s request, the SAB Environmental Engineering 

Committee (EEC), augmented with additional SAB members, conducted a consultation

on this subject at a public meeting on September 3-4, 2008. (See Enclosure 1 for the 

Committee’s roster.) 

The Committee commends OPPT on the creative development and substantial 

progress of the seven P2 programs. These programs have resulted in avoidance of 

emissions, energy consumption, and resource depletion and have provided other benefits 

documented by the metrics developed by OPPT. The P2 programs are among the most 

forward-looking and important programs of the EPA, defining a new model for 

environmental protection and restoration based on voluntary initiative that is prompted by 

incentives for cost savings and higher product and process performance. These are also 

among the most difficult programs to implement, as they are based on voluntary 

participation by partner organizations, the appropriate data to assess the individual 

programs are not readily available, the information can be sensitive as it may provide a 

competitive advantage to competing organizations, and effective approaches are often

specific to the particular product or process. Measuring progress achieved at the program

level is challenging because, for a variety of good reasons, results are measured in 

different ways, and on different time scales. As a consequence, results are often difficult 

to compare and aggregate. Nevertheless, the P2 programs of OPPT have made 
significant progress, and the metrics developed to date at least partially document this 

success. 

An SAB consultation is a mechanism for individual technical experts to provide 

comments for the Agency’s consideration early in the development of a technical 

product. A consultation does not require achievement of consensus among the 

Committee members or preparation of a detailed report. In this consultation, however, 

the Committee would like to highlight key points that were developed in the discussions 

in response to the five charge questions (Enclosure 2) which are summarized in the 

document enclosed with this letter (Enclosure 3). 

The Committee would like to thank EPA presenters for their expertise, 

perspectives, and insights that assisted the Committee’s understanding of the P2 

programs. Thank you for the opportunity to provide early advice on this important topic. 

As this is a consultation, the SAB does not expect a formal response from the Agency. 

 Sincerely,

 /Signed/ 

 David A. Dzombak, Chair 

 Environmental Engineering Committee 

 Science Advisory Board

cc: Deborah L. Swackhamer, 

 Chair, Science Advisory Board 

2
Enclosure 1 

U.S. Environmental Protection Agency 

Science Advisory Board 

Environmental Engineering Committee Augmented for Pollution 

Prevention Measure Consultation 

CHAIR 

Dr. David A. Dzombak, Walter J. Blenko Sr. Professor of Environmental Engineering, 

Department of Civil and Environmental Engineering, College of Engineering, Carnegie 

Mellon University, Pittsburgh, PA 

MEMBERS 

Dr. Viney Aneja, Professor, Department of Marine, Earth, and Atmospheric Sciences, 

School of Physical and Mathematical Sciences, North Carolina State University, Raleigh, 

NC, USA 

Dr. James Boyd, Senior Fellow, Director, Energy & Natural Resources Division, 

Resources for the Future, Washington, DC 

Dr. John C. Crittenden, Richard Snell Presidential Professor , Department of Civil and 

Environmental Engineering, Ira A. Fulton School of Engineering, Arizona State 

University, Tempe, AZ 

Dr. T. Taylor Eighmy, Assistant Vice President for Research and Director of Strategic 

Initiatives, Office of the Vice President for Research, University of New Hampshire, 

Durham, NH 

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, 

University of Illinois at Urbana-Champaign, Urbana, IL 

Dr. Cindy M. Lee, Professor, Department of Environmental Engineering and Earth 

Sciences, Clemson University, Anderson, SC 

Dr. Reid Lifset, Director of the Industrial Environmental Management Program and a 

member of the faculty, Industrial Environmental Management Program, School of 

Forestry and Environmental Studies, Yale University, New Haven, CT 

Dr. Jill Lipoti, Director, Division of Environmental Safety and Health, New Jersey 

Department of Environmental Protection, Trenton, NJ 

Dr. Michael J. McFarland, Associate Professor, Department of Civil and 

Environmental Engineering, Utah State University, Logan, UT 
Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, State of Florida 

21st Century World Class Scholar, University of South Florida, Tampa, FL 

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer 

Science, and Technology, California State University, Los Angeles, CA 

Dr. Catherine Peters, Associate Professor, Department of Civil and Environmental 

Engineering, Princeton University, Princeton, NJ 

Dr. Susan E. Powers, Associate Dean and Professor, Department of Civil and 

Environmental Engineering, Wallace H. Coulter School of Engineering, Clarkson 

University, Potsdam, NY 

Dr. Mark Rood, Professor, Department of Civil and Environmental Engineering, 

University of Illinois, Urbana, IL 

Dr. Bryan Shaw, Commissioner, Texas Commission on Environmental Quality, Austin, 

TX 

Dr. John R. Smith, Division Manager, Environmental Science and Sustainable 

Technology, Alcoa Inc., Alcoa Technical Center, Alcoa Center, PA 

SCIENCE ADVISORY BOARD STAFF 

Ms. Kathleen White, Designated Federal Officer, 1200 Pennsylvania Avenue, NW, 

Washington, DC, Phone: 202-343-9878, Fax: 202-233-0643, (white.kathleen@epa.gov) 
Enclosure 2 

Charge for the Consultation on 

Pollution Prevention Program Measures 

with the 

Environmental Engineering Committee 

of the 

EPA’s Science Advisory Board 

EPA Office of Pollution Prevention and Toxics 

September 3, 2008 
 

 

Pollution Prevention Program Measures 

The Pollution Prevention (P2) Program seeks feedback from the SAB on considerations 

associated with technical elements for the development of a sound methodology for measuring 

recurring performance results for P2 Program Centers. It seems like there are a variety of 

measures that could be used, some of which are depicted in the illustration, below. 

Generic Depiction of Performance Results

1999 2000 2001 2002 2003 2004 2005

Fiscal Year

Amount of Toxic Material 

Baseline without P2 Program

Intervention

With Pollution Prevention Program

Annual Recurring Results

Cumulative Recurring Results

New Annual Result

 from P2 Program FY2004

This illustration addresses a single hypothetical P2 Program Center which may undertake one or 

more activities in any given year. It presents a baseline curve of toxic materials generated over a 

period of years without any P2 Program intervention; then a separate curve depicting generation 

over the same span of years as a result of P2 Program interventions. One measure of results 

would be to capture new annual results, the measure of new interventions in a year, which is 

calculated by taking the difference between the pounds of toxic materials generated in one year 

from the previous year. Many P2 Center interventions can also generate results over a span of 

years. One could consider an annual recurring result which is the vertical distance between the 

curves during any single year. Alternatively, cumulative recurring results are depicted by the 

shaded area between the curves. It is the recurring results measures that are the focus of this 

consultation with the Science Advisory Board. 

In developing sound methodology for measuring different performance results, the P2 Program 

is particularly interested in understanding technical factors that are important to consider when 

measuring recurring results. This understanding should help us, for example, to decide on 

appropriate modifications to the methodology when facing constraints on the collection of results 

data, particularly on a year-after-year basis. The P2 Program has developed some understanding 

for counting recurring results in certain contexts, and is seeking additional input in order to 

develop sound methodology for counting recurring results across P2 Program Centers. The 

methodology will need to meet the following technical parameters: 
Page 2 

1) completeness – a methodology for recurring results must work for all Centers because all 

Centers must report performance results into a unified Agency reporting system; and 

2) comparability – a methodology for recurring results must support the ability to generate 

time-series data to analyze changes in performance over time, must support performance 

comparisons between Centers, must be sufficiently flexible to accommodate the design 

and implementation differences among Centers, and must be sufficiently neutral and 

transparent so that report users can understand the factors that may contribute to 

differences in performance among Centers. 

 

Key Terms

Please refer to the Annex 1 (Glossary) for a list of key terms that will be used throughout this 

document. 

Background 

The P2 Program has a number of reasons for wanting to improve its measures of performance. 

The P2 Program is guided by statute to measure and report its performance. The Pollution 

Prevention Act (PPA) of 1990 directs the Agency to develop an approach to measuring P2 (42 

USC 13101). The Government Performance and Results Act (GPRA) directs federal agencies to 

develop strategic plans outlining what programs intend to accomplish, how they measure their 

progress, and how they communicate that information about their performance to Congress and 

to the public, among other requirements. In response to GPRA, the Office of Management and 

Budget (OMB) developed the standardized Program Assessment Rating Tool (PART) to 

evaluate the effectiveness of program performance in budget submissions for individual 

programs and program groupings. Beyond these statutory reasons for measurement, in this age 

of results orientation it is important to be able to measure performance to demonstrate the value 

of P2 Programs to government and private sector stakeholders to foster support and participation. 

Supporting Materials

Additional information on the P2 Program, its Centers, and other topics relevant to performance 

measures and recurring results is provided in a supporting materials document. The additional 

information includes: 

− a narrative overview of the seven P2 Centers and their streams of results, and 

− a table on data management within the P2 Centers. 

In addition, weblinks are provided for the following: 

− the Pollution Prevention Act of 1990,1

− Executive Order 13423, Strengthening Federal Environmental, Energy, and 

Transportation Management,2

 

1

 http://www.epa.gov/oppt/p2home/pubs/p2policy/act1990.htm 2

 http://www.ofee.gov/eo/EO_13423.pdf 
Page 3 

− the Pollution Prevention Program PART Program Assessment (Fall 2006).3

 

Please keep in mind that some of these materials (e.g., PART assessment questions and answers) 

are provided as background only and are not directly relevant to this consultation. 

Charge to the SAB

The P2 Program is seeking the consultative input of the SAB Engineering Committee on the 

technical elements necessary to consider in the development of a sound methodology for 

measuring P2 program performance results, particularly recurring results. The Program is at a 

fairly early stage of methodological development, and is seeking the benefit of Committee 

members’ thinking and expertise at this stage of the process. The Program is specifically 

interested in receiving input from the SAB on the questions presented below on the technical 

elements identified thus far. 

1. Over what time period is it appropriate to count recurring results? 

It is generally accepted that entities adopting a pollution prevention practice will frequently 

keep such a practice in place for more than a year, generating pollution reduction results over 

a span of years. The life span over which it is appropriate to count these results likely varies 

by industry. What technical elements should be considered when determining how long to 

count recurring results? What data sources exist to estimate the typical lifecycle of a 

commercial technology and how might this typical lifecycle vary by industry? 

Are there other factors that are relevant to consider when identifying the end of a benefits 

stream of results from a P2 practice? 

2. What are appropriate data sources? 

What data sources are appropriate for substantiating recurring results from P2 Centers whose 

technical assistance activities are referral driven, and facility driven, but not sector driven? 

Discussion: Could innovation rates, and/or the birth and death rate of firms, be used towards 

building a basis for counting recurring results from Centers that work with small- and 

medium-sized businesses broadly across sectors on a technical assistance basis? What data 

sources exist to estimate the typical length of time an innovation is retained in small U.S. 

businesses, and for medium-sized U.S. businesses? What other factors can be considered 

when determining how to substantiate recurring results for technical assistance programs that 

work broadly across sectors? 

What should we do with data source gaps over time for producing time-series data? 

Discussion: See Table 3 in the supporting materials comparing our data sources and 

literature search data sources and identifying gaps to explore. 

 

3

 http://www.whitehouse.gov/omb/expectmore/summary/10004304.2006.html 
Page 4 

3. How should aggregation issues be addressed? 

Assuming practices have different life cycles, thus different time periods over which results 

would presumably be counted, what are the technical issues faced when aggregating results 

for all practices at a center or across all centers? 

4. How do other programs and organizations consider or measure 

recurring results, and can we benchmark and learn from their 

experience? 

The experiences of other programs and organizations regarding recurring results may be 

informative to the P2 Program’s decision on a path forward on its own methodology 

development. The P2 Program would like to understand how other programs or 

organizations considered or measured recurring results and, if so, whether there are existing 

benchmarks that the P2 Program can utilize. The Program has conducted an initial 

benchmarking exercise and is interested in expanding the scope and depth of information 

searched and compiled. The Program is particularly interested in additional information on 

the following: 

Are there other programs and organizations that count recurring results? What is the scope 

and purpose of these programs and are they similar to the voluntary P2 Program? 

− What data do these programs collect and what is (are) the source(s) of the data? 

− What are the typical performance results that are measured and what is the methodology 

used to compute the performance results? 

− Do any of their experiences relate to specific P2 Program Centers? 

− Are there other indicators as to how recurring benefits are viewed (regardless whether 

they are reflected in measurement approaches)? 

See Section III in the supporting materials for the P2 Program’s initial findings from a 

benchmark literature search summarized in Table 2 organized by program/organization with 

a description of each approach to recurring results. Section III provides a discussion of the 

P2 Program’s initial benchmark literature search findings, including the relevance of specific 

findings to the individual seven P2 Program Centers as well as across the P2 Program. 

Information gathered includes government programs (state and federal), some industry 

practices (at the individual company level), as well as global environmental measurement 

principles. The benchmark information in Section III is provided solely as a source of ideas 
Page 5 

building on the experience of others who have addressed similar performance measurement 

questions OPPT is facing. It is not intended that they will be part of this consultation in any 

other manner. 

5. How can we best use the initial benchmark literature search findings to 

help us further inform our investigation on recurring results and begin 

methodology development? 

The P2 Program is seeking to relate findings of the initial benchmark literature search to the 

data sources that differentiate our Centers and are relevant to resolving how to approach 

recurring results across the P2 Program. Additionally, the Program is interested in how to 

use the initial findings to further focus and prioritize our investigation on recurring results for 

the purpose of methodology development. The P2 Program has identified the following 

preliminary list of task-related considerations on which we are seeking consultative advice. 

See also Section IV of the supporting materials for more information. 

− In analyzing the current data sources for each Center, how does the availability or 

limitations in data sources for an individual Center (such as publicly available market 

data or statutory barriers to data collection) affect P2 Program options for measuring 

recurring results program-wide? Table 3 in Section IV of the supporting materials 

compares P2 Program data sources with data sources inferred from examples in the 

literature. 

− Where data gaps exist for certain Centers, are there other data sources that the Centers 

could consider (such as economic, market trends, market demographics) in 

methodology development to allow for measuring recurring results consistently across 

the P2 Program? 

− In continuing a benchmarking exercise, are there other benchmarks we might 

consider? 

 
Page 6 

ANNEX 1 - Glossary

P2 Centers. The P2 Program has seven Centers or distinct program units that produce 

performance results. Each P2 Center has its own program design, targets, and goals. All P2 

Centers use common outcome performance measures – pounds of hazardous materials 

reduced, BTUs of energy/million metric tons of carbon equivalent reduced (program is 

switching from BTUs to MMTCE), gallons of water reduced, dollars saved. Not every 

center reports to all four measures, but all of them report to at least three of these measures. 

Details on the Centers appear in attached background documents, identified immediately 

below. 

Program intervention (or P2 intervention). This is a Center activity that produces a specific 

environmental outcome (pounds reduced, energy saved, etc.) at a point in time. There is also 

a view that it includes the ongoing administrative investments in building and/or maintaining 

the overall project which produces the series of specific environmental outcomes. 

Results. For purposes of this consultation, “results” refers to program performance results 

expressed in terms of specific indicator measures. These specific P2 Program indicator 

measures are pounds of hazardous materials (releases to air, water, land, and material inputs) 

reduced, billion BTUs of energy reduced (this measure is being changed to million metric 

tons of carbon equivalent reduced), gallons of water reduced, and dollars saved from P2 

interventions. Provided on the following pages is a graph that further illustrates how a P2 

Center may represent annual and recurring results. Equations and examples are also 

provided to illustrate how the various types of results may be interpreted from the example 

graph. 

Baseline Year. The baseline year is the year from which results in following years are 

measured. In the example below, there are no Annual Results in the baseline year (FY2000). 

(New) Annual Results. New Annual Results or simply Annual Results refer to one year’s worth 

of performance results from a program intervention that occurred in a given year. 

Example: To calculate the New Annual Result in FY2004 in the graph below, subtract the 

amount of toxic material generated in FY2004 (with the P2 Program in place) from the 

amount of toxic material generated in FY2003. 

 e.g. New Annual ResultFY2004 = 16,500 – 15,000 = 1,500 lbs of toxic materials reduced 

Annual Recurring Results (Cumulative Annual Results). Annual Recurring Results are 

benefits that occur in a single year from P2 interventions initiated in previous years. The P2 

Programs include any New Annual Results in this total as well. Note: Annual Recurring 

Results are equivalent to Cumulative Annual Results which are the sum of New Annual 

Results year-after-year, starting from a baseline year of measurement. 

Assuming a baseline year of FY2000, New Annual Results begin to occur in FY2001 and 
Page 7 

continue every year through FY2004. Then the Annual Recurring Results for the P2 Center 

in FY2004 would be: 

∑=

=

2004

k 2001

FY2004 Annual ResultsFYk Annual Recurring Results 

Example: To calculate the Annual Recurring Result in FY2004 in the graph below, add the 

Annual Results in each year. This calculation can be simplified to subtract the total 

amount of toxic waste generated with the P2 Program in place from the baseline level of 

waste. 

e.g. Annual Recurring ResultFY2004 = 20,000 lbs – 15,000 lbs = 5,000 lbs of toxic 

materials reduced. 

Cumulative Recurring Results. Cumulative recurring results are the sum of recurring results 

over two or more years, starting from the baseline year of measuring. 

Starting with a baseline year of FY2000, the cumulative recurring results for the P2 Center in 

FY2004 would be: 

∑=

=

2004

k 2001

FY2004 Annual Recurring ResultsFYk Cumulative Recurring Results 

(Note: In FY2001, annual recurring results are equivalent to new annual results.) 

Example: To calculate the Cumulative Recurring Results in FY2004 in the graph below, add 

the Annual Recurring Results in each year. 

e.g. Cumulative Recurring ResultsFY2004 = (20,000-19,000) + (20,000-17,800) + (20,000-

 16,500) + (20,000-15,000) = 11,700 lbs of toxic materials reduced. 
Page 8 

Depiction of Performance Results

17.8

16.5

15

19

20

12

13

14

15

16

17

18

19

20

21

22

1999 2000 2001 2002 2003 2004 2005

Fiscal Year

Thousand Pounds of Toxic 

Material 

Baseline without P2 Program

Intervention

With Pollution Prevention Program

Annual Recurring Result FY2004

Cumulative Recurring Results FY2004

New Annual Result 

from P2 Program FY2004

∑=

=

2004

k 2001

FY2004 Annual Results FYk Annual Recurring Results 

∑=

=

2004

k 2001

FY2004 Annual Recurring Results FYk Cumulative Recurring Results 
Enclosure 3 

EPA SAB Consultation on Pollution Prevention Program Measure 

Methodology 

September 3-4, 2008 

Summary of Key Points 

Charge Question 1: Over what time period is it appropriate to count recurring results? 

1. It is appropriate to count results over the life of a technology (product or process), 

when the technology use is stable and not largely displaced by a new technology. 

An argument can be made for only counting results during the time period of 

technology distribution in the marketplace, but the majority opinion on the 

committee favored counting results over the life of the technology use. 

2. Appropriate time periods depend on the particular technology. For example, a 

time period relevant for some devices could be the mean time to failure and its 

replacement with a new technology. 

3. By focusing on the technology rather than the company, OPPT can avoid 

counting problems associated with the birth and death of companies. 

4. The baselines or benchmarks used for counting are extremely important, they 

should be carefully selected and the reasoning for their selection should be both 

clear and defensible. Because EPA P2 programs are not the only source of 

innovation, defining a baseline needs to account for the conventional innovation 

rate and ranges of outcomes. 

5. OPPT currently uses amounts of materials that are not emitted to the environment 

and reduction in energy consumption as measures. Resources not expended and 

cumulative impacts avoided could also be used as measures of results that 

consider preservation of natural capital more broadly. 

Charge Question 2: What are appropriate data sources? 

6. OPPT has chosen appropriate data sources and evaluated them. OPPT also has 

opportunities to use other EPA data sources not directly related to P2 programs, 

e.g., air and water permitting data, and TRI data. 

7. OPPT should continue to strengthen processes for data validation. 

8. OPPT should continue to develop uniform methods of data collection across the 

P2 centers. 
2

9. The EEC recognizes that, because of the government’s interest in not overburdening individuals and organizations with requests for information and the 

need to limit barriers to voluntary participation in P2 programs, collection of 

additional data is neither a simple question nor is it a choice fully within the 

domain of OPPT or EPA. However, if it was possible, it would be useful to 

collect data that document how EPA is accelerating innovation and economic 

competitiveness. The acceleration of innovation and related economic 

competitiveness are also measures of the P2 programs’ results. 

10. Ideally and over the long-term, more meaningful measures of the results of 

programs, including pollution prevention programs, should incorporate risk 

averted in addition to chemical releases averted. Unfortunately, the data required 

to implement this measure for all EPA P2 programs do not exist and will not exist 

any time soon. Similarly, measures of energy conservation could be improved by 

weighting energy sources by human health and environmental impacts because 

not all amounts of energy have equal impacts on resources and the environment. 

11. To support better analyses when complete suites of data are lacking, OPPT should 

examine the scientific literature on missing data and develop methodologies based 

on this literature, e.g., the use of proxy data for particular facilities or processes. 

Charge Question 3: How should aggregation issues be addressed? 

12. While aggregation makes it difficult to convey the influence of P2 programs on 

systems, it is acceptable if similar data that describe, for example, source 

reductions or changes in consumption, are being aggregated. As noted in (1), 

health risks averted could be a valuable common measure, but it is not yet 

possible to determine this for the range and variety of technologies in the P2 

programs. This is primarily due to the lack of available data, the constraints on 

collecting the relevant data, and the lack of resources with which to do so. 

13. Work to segregate product and process impacts because a process that produces a 

product can have a different lifetime than its product. Also, the duration and 

degree of the impact to the environment by the process can be quite different than 

its product. 

14. If OPPT considers different ways of normalizing results, e.g., per unit of 

production or per functional unit (per action, facility, household, etc), it is likely 

to find a measure robust enough that changes of production can be considered 

more realistically when describing the impact of results from P2 activities over a 

wide range of programs. 
3

Charge Question 4: How do other programs and organizations consider or measure 

recurring results? 

15. Companies track performance to change behavior, with objectives for the 

behavior change desired. Using this model, OPPT could consider setting specific 

targets for P2 programs. 

16. Experience with other organizations demonstrates that, for P2 metrics to be 

effective, they need to be clear and simple. 

17. OPPT should establish metrics only for activities that can be clearly and 

defensibly influenced by the P2 programs. 

18. Experience with other organizations demonstrates that it really matters what is 

measured, as performance metrics motivate and demotivate behavior. 

19. OPPT may find it helpful to examine the Global Reporting Initiative 

(www.globalreporting.org) and how this organization handles recurring results 

and includes life cycle considerations. 

20. The Intergovernmental Panel on Climate Change has developed methods of 

accounting for recurring and cumulative emission reductions achieved by control 

measures for greenhouse gases. The IPCC methods may serve as useful models 

for counting recurring results for P2 programs. 

21. Industrial trade associations have developed methods for counting recurring and 

cumulative results of pollution prevention activities, e.g., the Aluminum 

Association, the American Chemistry Council, and the World Business Council 

for Sustainable Development. 

22. The U.S. Center for Disease Control and the World Health Organization track 

recurring results from interventions for disease prevention. The methodologies 

developed may be useful in determining methods for counting recurring results 

from P2 program interventions. 

Charge Question 5: How can EPA best use the initial benchmark literature search 

findings to help further inform recurring results method development? 

23. Information in peer-reviewed journals should be explored in much greater depth. 

24. It would be useful to explore how other organizations (e.g., IPCC) reflect 

uncertainty in new or recurring results from interventions. 
4

25. The EPA should examine international sources to inform recurring results method 

development, e.g., emission accounting compendia developed by the Institute for 

International Studies and Training (IIST) and by the European Union. 

Other Key Observations

26. There are multiple audiences for the P2 program metrics: Measures of P2 can be 

used to evaluate OPPT’s programs, as OMB does in PART evaluations. Another 

important audience is the companies/organizations being solicited to participate in 

the program. While EEC recognizes that development of metrics to document 

performance is a priority, it suggests some thought be given to development of 

additional metrics that capture innovation, economic competitiveness, and the 

evolution of the P2 discipline that should be directed to the participants in these 

voluntary programs. 

27. It is important to convey the barriers to data collection faced by the P2 programs. 

The programs involve voluntary participation and data submittal by the 

organizations that partner with EPA. Too much pressure for data submittal could 

result in the loss of participation by the partner organizations. Further, the EPA is 

limited in the surveys it can conduct by federal information collection request 

(ICR) regulations. 

28. OPPT has been careful to be conservative in its estimates of impacts of P2 

program interventions. This care is commendable, but the Committee encourages 

the OPPT to be less conservative in its data compilation and analysis in order to 

demonstrate more clearly the range of benefits. The current bias toward 

underestimating benefits is counterproductive with respect to attracting more 

organizations as participants in the P2 programs. In this respect there is harm in 

underestimating benefits. Defensible approaches to estimation of benefits that are 

not so conservative could help expand P2 program participation more rapidly.