Starting on the Right Track

Contract negotiations require that the terms be spelled out and thoroughly understood

• By Sherleen H. Mahoney
• Jan 01, 2007

We're all familiar with the light bulb joke: How many insert group does it take to change a light bulb? Here's a real question: How many companies will it take to reduce

• materials use by 465,874 tons;
• water use by 60.7 billion gallons;
• greenhouse gas emissions by more than 81,000 metric tons of carbon dioxide equivalent;
• discharges to water by more than 18,000 tons; and
• hazardous and nonhazardous waste by nearly 418,000 tons?

Answer: 464 U.S. Environmental Protection Agency Performance Track members. Those targets are just some of the Performance Track members? most recent commitments, and that's no joke.

EPA understands it's not easy being green. That's why the agency created the Performance Track program in 2000. The voluntary program only accepts facilities with established records of compliance, which participate in community outreach activities, and believe that meeting mere regulatory compliance isn't enough. The program recognizes and rewards members by providing exclusive regulatory incentives, low inspection priority, public recognition, access to a network of other high performers, and more.

"Our goal is to not let poor performers in this program but rather to permit entities who have demonstrated a high level of performance," said Israel Anderson, Region 6 voluntary program coordinator. Each member sets ambitious, three-year goals for improving its environmental performance and must submit a performance report every year, detailing progress and accomplishments.

Public Appeal
Despite an impressive membership count and inspiring accomplishments, all achieved in a mere six years, the program strives for more. Performance Track staff hope to enlist more public entities. "With over 400+ members, only three are local municipalities. There's obviously a need to expand that membership," said Craig Weeks, EPA Region 6 Performance Track coordinator.

One reason for the low turnout may be due to the fact that municipalities do not interface as much with EPA, as compared to private sector facilities, and therefore, receive more intrinsic benefits, such as recognition and credibility from program participation, rather than regulatory and administrative benefits. To appeal to more municipalities, EPA is working closely with states to implement complementary performance-based programs. The state programs are modeled after the federal program but offer benefits that apply to the county and state level, such as streamlined membership between the state program and the federal Performance Track, low priority for routine state inspections, reduced permit fees, and expedited permitting.

The city of Scottsdale, Ariz., is a prime example of how a state program greatly benefits its members. The Arizona Environmental Performance Track program provides tools and strategies to complement existing programs in order to protect people and the environment, as well as reduce cost and encourage technological innovation. Incentives include reduced inspection frequency, enforcement notice, enforcement discretion for nonsignificant violations, inspection notice, reporting consolidation, recognition, permit flexibility, and more.

"Arizona has the only municipality that is a city-wide member of Performance Track. We have a corporate culture of environmental innovation and a willingness to try innovative things like Performance Track. Because we also joined the Arizona Performance Track program, the benefits are really substantive and we really appreciate what the state of Arizona, in cooperation with EPA Region 9, has done to offer benefits to make membership in Performance Track a lot more meaningful," said Larry Person, senior environmental coordinator for the city of Scottsdale.

EPA is working hard to drive the future direction of Performance Track toward the state level, which will be a motivating force for more municipalities to join the program. So far, Arizona, Colorado, Delaware, Georgia, Kentucky, Maine, Michigan, Missouri, New Mexico, North Carolina, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia, and Wisconsin have state programs.

Performance Track is working with states on a number of projects and initiatives, including:

• developing and delivering incentives to reduce administrative burdens and encourage current and prospective program participants to boost their environmental performance.
• developing comparison tools to show potential members how Performance Track criteria compare with those of state programs.
• entering into Memoranda of Agreement to document intentions to work in tandem to recognize and reward top environmental performers.
• working with EPA's Office of Congressional and Intergovernmental Relations, EPA regional offices, and states to integrate Performance Track and similar state performance-based programs into Performance Partnership Grants.
• co-leading workgroups to incorporate performance-based programs into EPA?s planning and budgeting processes.
• exploring additional opportunities for states to receive credit for developing and implementing performance-based programs.
• identifying ways to streamline and facilitate Performance Track and state program application and reporting processes.

The Performance Track program requires companies to have an environmental management system (EMS) in place for at least one year prior to applying for membership.

What is an EMS?
"An EMS is the personification of the plan/do/check/act cycle," said Anderson. The management system uses set policies and procedures to identify how a company's operation impacts the environment and then determines the significance of those impacts.

An environmental management system helps companies in:

• defining roles and responsibilities,
• identifying and prioritizing environmental impacts,
• setting measurable objectives and targets,
• verifying and establishing operational controls,
• monitoring and measuring activities and progress, and
• committing to continuous improvements.

Why Does My Wastewater Treatment Facility Need One?
The mission of public entities is to serve the public well-being and to conduct their operations in an environmentally responsible manner, by not only meeting or exceeding federal, state, and local regulations but also their customers' needs and expectations. An EMS helps facilities comply with all those objectives. What better way to establish credibility and measure success than to accomplish all mission-critical aspirations?

According to the Public Entity Environmental Management Resource (PEER) Center, wastewater treatment facilities use EMSs to:

• better comply with environmental laws and regulations,
• improve management of environmental responsibilities,
• improve environmental operations,
• identify and manage risks more effectively,
• improve public image,
• reduce inefficiencies for cost-savings,
• improve teamwork, communication, and environmental understanding, and
• improve competitiveness and reduce the risk of privatization.

Wastewater utility managers are starting to realize the value of an EMS. According to EPA, more than 50 wastewater utilities are in the process of implementing an EMS under the National Biosolids Partnerships program.

Because nothing lasts forever, many drinking water treatment and wastewater treatment plants are now facing issues with their infrastructure. EPA estimates the plants will be reaching the end of their life cycles in the next 20 to 40 years. Organizations -- such as the Water Environment Federation -- agree that implementing a sustainable, management system, like an EMS, ensures long-term viability for water and wastewater utilities.

Performance Track administrators are currently in discussions with the EPA Office of Water staff about forming a mentoring program in which members of Performance Track will help struggling entities implement an EMS and provide technical assistance.

The EMS does not have to be ISO 140001-certified, but developing one can still be a challenging process for public entities due to time and financial constraints. Those who have done it, however, agree that an EMS has yielded many beneficial returns that make the adoption worthwhile. In order to attract more public entities to the program, EPA is offering its assistance in developing an EMS. This spring, EPA regions 6 and 9 will sponsor workshops and seminars to bring local municipalities together with other public institutions from all over the country that have successfully implemented an EMS and have been accepted into Performance Track. The interaction will allow participants to learn from others in the field, share and reflect upon their experiences, explain the process, and collect with tips on what to do and what not to do.

Time is Money
Deciding to implement an EMS requires a commitment of time and financial resources, mainly the investment of employee labor and consultant time. Many utilities have found that those costs were offset by consistent returns on investment through improved time efficiencies and cost savings. "There's a lot of work involved but once implemented, it really is a better way of doing business," said Person.

The PEER Center has tracked data from eight wastewater and drinking water utilities and found that the average resource commitments to implement an EMS include:

• 2,900 hours of total staff time and 24 months are required from project start to first management review;
• 2,100 hours are required from an environmental management representative (EMR);
• 30 hours are required from senior management;
• 2,050 hours are required from EMS core team;
• 315 hours are required from a consultant; and
• 10 to 12 hours per year are required for each employee to maintain an EMS after initial implementation.

In 2006, Performance Track was recognized as a top-50 Innovation in American Government by the Ash Institute for Democratic Governance and Innovation at Harvard University's Kennedy School of Government. This is no surprise.

Since the program's inception in June 2000, Performance Track members have reduced their water use by nearly 1.9 billion gallons, conserved close to 9,000 acres of land, and have increased their use of recycled materials by 120,000 tons and they're not stopping there.

The program and its members will continue to lead the environmental community by example, collectively offering one simple lesson: Together, we can make a difference.

Case Studies
Skeptics who say businesses have lost their moral high ground should take a lesson from members of Performance Track. Obviously businesses want to be successful, but there are those who also choose to make a big difference in the world by committing to being environmentally conscious. Here are some top performers.

City of Eugene, Wastewater Division, Eugene, Ore.

Performance Track member since 2004.
Number of employees: 50-99.
48 pump stations.
850 miles of regional sewer line.

Program benefit: "The main benefit is the credibility of being a member of Performance Track and the access to EPA staff and other members to get information and gain from their experiences." -- Peter Ruffier, City of Eugene Wastewater Division director

Commitment 1: To reduce total solid waste.

How was the commitment achieved?
A program was established for reducing solid waste through recycling, composting, purchasing guidelines, disposal procedures, and reusing packaging materials.

Commitment 2: To reduce sulfur dioxide emissions.

How was the commitment achieved?
The reduction in sulfur dioxide emissions was achieved by installing a gas filter for the engine generator. This filter removes both siloxane as well as hydrogen sulfide.

Commitment 3: To reduce total water use.

How was the commitment achieved?
An environmental management program was established to reduce water use through staff education and awareness, identification of water leaks, and alternative irrigation strategies.

Kent County Regional Wastewater Treatment Facility, Milford, Del.

Performance Track Member since 2006.
Number of employees: fewer than 50.
69 pump and lift stations.
Nearly 40 miles of various diameter sewer pipes.
Program benefit: "The most important benefit is the participation in an exclusive group of facilities committed to reducing their environmental footprint. It offers positive publicity for the plant and shows to the community just how responsible the facility is to environmental improvement." -- James Newton, environmental program manager.

Commitment 1: To reduce nitrous oxide emissions.

How was commitment achieved?
A distributed emergency generator is used to power the third and fourth blowers for the aeration basin. A selective catalytic reactor will be added to reduce nitrous oxide emissions from the generator by 90 percent. This will result in a facility-wide reduction of approximately 20 percent.

Commitment 2: To reduce total (non-transportation) energy use.

How was commitment achieved?
The city invested in energy efficient pumps, lighting, employee education, and other energy conservation programs. Equipment will be installed to automatically control the amount of air fed into the aeration basins using a supervisory control and data acquisition system. In addition, fuel will be switched for the biosolids dryers from fuel oil #2 to natural gas, and vehicle fuels from diesel to B20 biodiesel (20 percent biodiesel and 80 percent petroleum diesel).

Commitment 3: A long-term goal to build a wind/solar/biomass system to provide a minimum of 25 percent of the facility's energy needs by 2010.

City of Scottsdale Water System Facilities, Scottsdale, Ariz.

Performance Track member since 2000-2003, 2006-2009.
Number of employees: more than 1,000.
Pumpback and sewer lift stations: 43.
Sewer pipe: 1,330 miles.

Program benefit: "The obvious main benefit is honor and recognition, but what organizations really value are concrete, regulatory relief-type benefits. The 'payback' for an organization's hard, extra work to establish and implement an EMS needs to go beyond recognition. Organizations want to feel that EPA is truly a partner. Through an EMS and National Environmental Performance Track commitments, organizations are ensuring compliance and improving environmental performance in a different way than the old command-and-control relationship days." -- Larry Person, senior environmental coordinator for the city of Scottsdale.

Commitment 1: Land and habitat conservation.

How was commitment achieved?
Scottsdale citizens voted six times to tax themselves to generate revenue that would be used to purchase and preserve land that might otherwise be developed.

Commitment 2: Land and habitat conservation.

How was commitment achieved?
The facility recharges several thousand acre feet of treated effluent into the underground aquifer per year. Environmental benefits include replenishing a partially depleted underground aquifer, increasing sustainability by retaining local resources, minimizing the possible risk of subsidence, and reusing treated effluent rather than disposing of it.

Commitment 3: To reduce air emissions that contain particulate matter 10 micrometers in diameter.

How was commitment achieved?
The city is using biodiesel fuel in its fleet of diesel vehicles. City fuel tanks that are more than 5,000 gallon capacity are using 20 percent biodiesel.

Commitment 4: To reduce energy use.

How was commitment achieved?
The city plans to build future buildings to the Leadership in Energy and Environmental Design standard, incorporating energy efficiency into design and construction, and adding solar energy options.

This article originally appeared in the 01/01/2007 issue of Environmental Protection.