Industrial Footprint Project Carol Kraege Washington State Department of Ecology May 9, 2006

The Problem We’re at a plateau; many reissued permits achieve little or no environmental improvement but cost/time is substantial The objective of permitting is compliance, not environmental improvement, per se Some contemporary environmental issues are not addressed by regulations Local issues are often not addressed Global problems persist

More Problems Permits become a battlefield Priorities are driven by piecemeal laws, not environmental needs “stovepipe” regulation has led to “stovepipe” compliance and opportunities to improve performance can be overlooked

From the Washington Competitiveness Council’s findings “Washington's current environmental regulatory system is a tangled structure that evolved in piecemeal fashion, resulting in an uncoordinated and inefficient regulatory regime. This contributes to regulatory problems that damage Washington's competitiveness.”

Is there a better way?

What’s a footprint? A holistic measure of the impacts of a facility Social Economic Environmental

Project Purpose To test a non-traditional approach to measuring facility performance Long term goals Achieve greater reduction in industry’s environmental footprint Similar level of effort and resources

With Limited Resources… Starts with Laws, Standards Traditional Regulation Compliance, and Maintenance +/- of Facilities Regulated Environmental Footprint Results: Footprint Approach Start with Footprint Measurement Hypothesis: Greater Reduction in Facility’s Overall Environmental Footprint is Possible

How would a footprint approach work ? Collaborate with stakeholders Choose indicators Measure industry’s footprint Use the measurement to drive priorities, actions

Project to date PPIS grant from EPA $20,000 Evaluate how much of the environmental footprint could be generated from data already submitted

FRP Environmental Indicators Readily available data –Criteria air pollutant emissions –Amount of hazardous waste generated and transported –Significant discharges to water –Significant spills to water –Compliance with air, water and hazardous waste permits

FRP Environmental Indicators Data available with some effort Total purchased energy Water used Water sources affected by the facility Annual withdrawals of ground and surface water Amount of impermeable surface and open space Greenhouse gas emissions Solid waste generated

FRP Environmental Indicators Data not publicly available Materials used Percentage of recycle material used Energy generated Energy used for transport and travel Water recycle and reuse Habitat effects due to facility Ozone depleting substance releases

PPIS Grant Status Some air and water data compiled and organized Waste and cleanup data to be compiled and organized this sprint Publicly available economic data still to be compiled Final report to EPA by fall ‘06

SIG Grant $ 182,105 Will be awarded in the next few weeks Provides funding for staff and contractor support Targeting agreements with several pulp mills by the end of the summer Contractor in place by the end of summer as well Three year project time line

Industrial Footprint Project Major Deliverables Sector footprint for pulp and paper industry Baseline footprints for each participating mill Energy challenge to the sector Comparison of mills with and without an EMS in place

Short term objectives Find out if the process of developing agreed upon indicators leads to a credible footprint Find out if footprint measurement tells us more than we knew before Find out if footprint measurement makes priority setting easier Find out if footprint measurement is sensitive enough to measure progress

Stakeholder Involvement Local communities –Input regarding selection of indicators –Input regarding priorities –Education about the mill Facilities –Pursue consensus regarding indicators –Input regarding priorities –Education about community needs

To Succeed, We Believe Collaborative problem-solving with stakeholder input is needed Substantial environmental improvement should be the goal The facility’s performance shouldn’t regress Progress should be measurable Good faith is essential

Qualities of a Successful Measure Credible Cost-effective Transparent Transferable Informative

Short term possibilities Provide a performance measurement tool for individual facilities Provide a baseline for sectors Provide a basis of comparison between facilities Assist regulatory agencies in prioritizing work Serve as a building block to a more effective regulatory framework

Long term possibilities Develop a single permit for air, water and waste Identify facility specific priorities –Consider community needs –Consider facility opportunities Develop incentives Pursue changes in state and federal laws to improve flexibility and performance

Some Likely Concerns Current Laws & Rules won’t go away EPA won’t allow it We’ll get sued We’ll lose our ability to sue It’ll cost too much It’ll allow industry to back off on protections It’ll start a bad precedent Congress and the legislature already set policy Ecology has no business…