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#112 - What We Must Do -- Part 12: Industrial Pollution Prevention, 16-Jan-1989

Everyone agrees that pollution prevention makes more sense than
pollution cleanup or control. If you never make pollution to begin
with, you don't need an army of scientists and engineers figuring out
what to do about it, you don't need state and federal government
"protecting" you with their feeble and bumbling environmental police,
you don't need to spend $80 billion per year (which is what industry
and government together are spending each year now in the U.S.) on
"pollution control." Industry would have fewer black eyes, the health
of the American people would be improved, the earth would be relieved,
and thousands of Americans now locked in mortal combat with their
neighborhood poisoners could go back to leading normal lives or could
focus on other public problems.

What will it take to make it happen?

There are two different kinds of polluting wastes:
industrial/commercial (the stuff industry throws away or lets leak
out), and trash/garbage (the stuff consumers throw away). They two
types of waste must be considered differently. This week we'll focus on
industrial wastes.

When speaking about industrial pollution, the term "pollution
prevention" means the same thing as waste reduction, waste avoidance,
or elimination of the generation of pollutants or wastes. Waste
management and pollution control mean recycling, treating, or
neutralizing wastes, or destroying the hazardous properties of wastes,
after they have been generated.

The fundamental basis of every industrial pollution prevention program
will have three parts:

(a) defining exactly what "pollution prevention" means. Unfortunately,
the EPA [U.S. Environmental Protection Agency] likes to cloud the
picture by speaking of "waste minimization." Congress's Office of
Technology Assessment, in two reports, has described the paralyzing
confusion caused by EPA's definition, and has clarified nicely how
"pollution prevention" should be defined. See RHWN #33.

(b) establishing general, industry-specific and plant-specific
pollution reduction goals;

(c) requiring detailed industrial reporting on pollution production and
releases. Such reporting should include total pounds, types, and
environmental impacts of pollution generated per unit of finished
product. It should report all releases to air, water and soil. It
should also include a discussion of past performance and future plans.
Accurate data reporting could be assured by holding company executives
personally responsible for the reports, and providing automatic jail
sentences for false reporting. (We use automatic jail sentences for
crimes with a gun, and for selling drugs near schools, in New Jersey
right now, so don't let anyone tell you such things are untried or are
unconstitutional. They're in use and they work.)

Those are the fundamental requirements of any industrial pollution
prevention program. There are other policies that could be used as
well:

(1) Waste reduction (pollution prevention) performance standards. This
would say, for example, you've got to produce 5% less waste per unit of
production each year, compared to the previous year. Such a performance
standard says what you've got to achieve, but doesn't say anything
about what you must do to achieve it.

(2) There could be fines (and, for repeat offenders, jail terms) for
not meeting the pollution reduction goals established in part (b)
above.

(3) There could be tax concessions offered to industries for capital
equipment, increased labor or material costs, etc. that might be needed
to prevent pollution. Currently, many laws offer tax concessions and
loans for pollution control equipment; such tax concessions work
against pollution prevention but this situation could be turned around.

(4) Liability insurance could be denied to firms that don't have
pollution prevention plans that they are adhering to. States regulate
the insurance industry differently, so this idea would not work in all
states today it would in some.

(5) Pollution production could be required as part of normal financial
reporting. Any reasonable investor trying to make an informed
investment decision has a right to pollution production data because
pollution production materially affects a company's (a) waste cleanup
liability, criminal liability, and involvement in third-party lawsuits
under Superfund; (b) liability associated with worker exposures and
transportation accidents; (c) regulatory compliance costs.

(6) In a few cases, companies might be offered "regulatory relief"--
delays in enforcement of effluent standards could be used occasionally
to encourage industries to pursue pollution prevention. Such regulatory
relief would be based on demonstration that the environmental and
health benefits of pollution prevention exceed the benefits foregone by
regulatory delay.

(7) Stricter waste disposal regulations, to increase the cost and
liabilities of pollution, to make the alternative (pollution
prevention) more attractive. To make this work, it would have to be
combined with strong incentives for, and assistance in, achieving
pollution prevention. Simply making waste disposal more expensive,
without offering alternatives, might simply increase illegal dumping.

(8) Technology transfer programs. State governments can help industries
learn how to prevent pollution. Among other things, such programs could
train and certify "pollution auditors" to help industry plan and carry
out pollution prevention programs. Such auditors could also (along with
the company's top executives) certify a company's compliance with
mandatory pollution prevention regulations.

(9) A combined pollution tax/pollution prevention subsidy could be
established. The idea would be to establish an "acceptable" level of
pollution for companies in a given industry. Companies producing
pollution at that level would not be taxed and would not be subsidized.
Somewhere above the "acceptable" level would be a "control level."
Companies producing pollution in amounts between the "acceptable" level
and the "control" level would be taxed at progressively higher rates
per unit of pollution as they got up toward the control level.
Pollution above the control level would be entirely unacceptable and
would be subject to strict enforcement.

Companies producing less pollution than the "acceptable" level would
receive a progressively larger subsidy as their pollution approached
zero. These subsidies would be paid for by taxes collected from
companies polluting above the "acceptable" level. Smaller firms might
be given larger subsidies for a given amount of pollution prevention
because technical information and capital financing are harder for them
to acquire.

These ideas are almost all taken from the excellent report by Elliott
Zimmerman, SOLID WASTE MANAGEMENT ALTERNATIVES: REVIEW OF POLICY
OPTIONS TO ENCOURAGE WASTE REDUCTION. Springfield, IL: Illinois
Department of Energy and Natural Resources [325 West Adams, Room 300;
zip: 62704-1892], Feb., 1988. Available from: National Technical
Information Service, Springfield, VA 22161; order PB 88-188-560;
$15.95. Phone (703) 487-4650.

--Peter Montague

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Descriptor terms: waste reduction; waste avoidance; pollution
prevention; public policy; sensible public policies; regulation;
taxation;