On the Right Track
EPA's National Environmental Performance Track program provides incentives and opportunities to facilities that go beyond mere regulatory compliance
Facilities in the United States and Puerto Rico that consistently achieve outstanding environmental results may be eligible for recognition and regulatory incentives through a voluntary program of the U.S. Environmental Protection Agency (EPA). The National Environmental Performance Track, launched by EPA in June, 2000, recognizes and rewards top environmental performers and is designed to encourage continual improvement. The program recognizes achievements in a variety of areas, including water conservation and the reduction of toxic discharges to water.
Performance Track complements existing environmental programs with incentives to go beyond simple compliance. The program also helps facilities capture opportunities for reducing costs and spurring technological innovation. In order to be considered for membership, eligible facilities set specific goals to further improve their environmental performance in areas such as water use, energy use, habitat conservation, the use of recycled materials, and the generation of hazardous waste. Through these efforts, Performance Track members have reduced water use by 775 million gallons, toxic discharges to water by 6,800 tons, energy use by 31 trillion British thermal units (BTUs), hazardous materials use by 18,000 tons, hazardous waste by 6,560 tons, solid waste by 176,100 tons, and greenhouse gas emissions by more than 40,000 tons.
EPA places Performance Track members at a low priority for routine inspections, offers them regulatory and administrative flexibility, provides public recognition through news releases and features, gives them access to information sessions with senior EPA officials, and invites them to exclusive conferences where members can network and share successful environmental practices. Performance Track works with states to ensure that members are recognized in state regulatory processes and to coordinate Performance Track benefits with those provided by similar state-level environmental performance programs.
A Growing Array of Regulatory and Administrative Incentives
In April 2004, EPA Administrator Mike Leavitt signed a new rule that makes Performance Track even more valuable to existing and potential members. The rule gives members reduced reporting requirements for air sources under the Clean Air Act's Maximum Achievable Control Technology (MACT) provisions and allows them to accumulate hazardous waste on-site for longer periods of time without requiring a permit under the Resource Conservation and Recovery Act (RCRA). Leavitt says the new rule "recognizes the complexities involved in achieving environmental excellence while maintaining organizational capacity, administrative flexibility, and a competitive edge."
The National Environmental Performance Track program recognizes achievements in a variety of areas, including water conservation and the reduction of discharges to water.
EPA is developing additional incentives for Performance Track members, including benefits related to water conservation and water quality. The agency is exploring options to expedite the renewal of water permits and to reduce related monitoring and reporting for Performance Track members. EPA also recently began encouraging states to make Performance Track members more competitive in the eligibility process for Clean Water State Revolving Fund (CWSRF) assistance. CWSRF loans would help Performance Track members achieve environmental commitments that may be important to local and state environmental priorities. The support also would encourage facilities to increase community involvement, perhaps linking facilities with watershed groups.
What Does Performance Track Mean for Its Members?
Chuck Kraske, PhD, department engineer at International Paper's Androscoggin Mill in Jay, Maine, says that membership in Performance Track has been valuable to his facility. Since joining the program, this integrated pulp and paper mill has seen improved public relations with its local community, a better working relationship with EPA, and a stronger relationship with state and local regulatory bodies.
According to Kraske, being a Performance Track member also changes the greater context of regulatory inspections. He says that as a Performance Track member these inspections are geared more toward identifying areas of improvement rather than strictly looking for violations. Moreover, he points out that federal recognition for environmental excellence also may carry over to state and local regulators. "Our local municipality has a whole suite of environmental regulations that essentially carry the same weight of law as state regulations," Kraske says. "So our improved relationship with EPA and the state has also helped to improve the relationship with the town."
More Benefits on the Horizon
Having a better relationship with the town helped the mill work out a difficult situation when it experienced some process upsets and modifications in 2003. While the mill remained in compliance with federal and state requirements, it had some conflicts with town wastewater discharge permit requirements. The mill's status as a Performance Track member and a recognized environmental leader helped the facility to work cooperatively with the town to resolve these issues. Moreover, Kraske says the experience has set up the facility for even more success as it now has improved processes, monitoring, and reaction plans.
Androscoggin Mill has been able to make significant environmental improvements during its tenure as a Performance Track member. For instance, the facility has developed ways to reduce its chemical oxygen demand and color discharge to the wastewater treatment plant. Now, the mill is working to reduce its phosphorous discharge into the Androscoggin River. At first, the mill was releasing 298 pounds of phosphorus per day. After voluntarily agreeing with the state to reduce this to 248 pounds per day, the mill managed to reduce its phosphorous discharge to about 195 pounds per day. Kraske is quick to say that although this is still a work in progress, the initial results are favorable.
Greg Narum, environmental manager of Simpson Tacoma Kraft Company LLC, in Tacoma, Wash., reports similar benefits from his facility's membership in Performance Track. Narum says that Performance Track status helps inspections run much more smoothly. His facility finds Performance Track membership to be even more attractive because it can be viewed as an investment with both long-term and short-term benefits.
"We have hopes that eventually there will be some recognition of Performance Track among our customers," Narum says, "so that when it comes time to make buying decisions that they will give some preference to suppliers who are recognized as environmental leaders."
Like other Performance Track members, the Simpson Tacoma Kraft Company has made many significant environmental improvements. For instance, the mill now uses 56 percent less water per ton of production than it used in 1989. When the mill enrolled in Performance Track in 2001, it set an ambitious three-year goal of reducing water use by 5 billion gallons and achieved it in the second year of its membership.
Simpson Tacoma also beat its Performance Track goals for air emissions associated with pollution control device maintenance and emissions of hazardous and odorous air pollutants. Finally, while it is not part of its Performance Track commitments, the facility also reduced net greenhouse gas emissions by about 40,000 tons per year by substituting renewable biomass fuels for fossil fuels.
Sanjay Patel, environmental manager at International Engine in Melrose Park, Ill., which manufactures diesel engines for trucks and school buses, says his facility joined Performance Track because it believed the program was a great way for the company to receive national recognition for its continual environmental improvements.
What Are Performance Track Members Doing to Reduce Water Use?
The program also helps facilities capture opportunities for reducing costs and spurring technological innovation.
Like other members, Patel says some of the benefits his facility receives include networking with other environmental leaders, a better understanding of EPA, regulatory flexibility, and an opportunity to improve the environment. Since 1995, the facility has reduced water consumption by 35 million gallons per year (33 percent), while simultaneously experiencing increases in production.
Who Can Join Performance Track?
Performance Track is open to facilities of all types, sizes, and complexities, public or private, manufacturing or service-oriented, in the United States and Puerto Rico. Facilities with fewer than 100 employees account for one-fifth of the membership. Once accepted, participants remain in the program for three years, as long as they continue to meet the program criteria. After three years they may reapply.
Facilities applying to Performance Track must have:
- A comprehensive environmental management system
- A record of sustained compliance with environmental laws
- A commitment to continual environmental improvement
- A community outreach component
Applicants are asked to demonstrate past environmental achievement and commit to four quantitative goals (small facilities with fewer than 50 employees may commit to two goals) for improving their environmental performance.
There are two open application periods each year -- February 1 through April 30 and August 1 through October 31. If your facility is considering Performance Track membership, it may find the Performance Track Mentoring Program useful. Whether your facility needs an occasional telephone consultation or a much closer relationship, the program matches potential and current members with top-performing Performance Track facilities. Mentors offer new perspectives on environmental concerns as well as guidance for setting performance goals and their corresponding measurements.
A New Approach to Environmental Protection
Performance Track reflects EPA's philosophy that top performers should be treated differently. The program helps close an incentive gap, providing a clear signal that facilities can be rewarded for improving their environmental performance continuously, rather than just maintaining levels required by current standards. The results to date show that this strategy works, and EPA intends to use Performance Track as a model for other innovative approaches to protecting public health and the environment.
If your facility is committed to continuous environmental improvement, we encourage you to consider applying to Performance Track and becoming one of EPA's preferred customers. We think you'll agree that the benefits are well worth it.
For More Information
For more information on the Performance Track Mentoring Program, visit www.epa.gov/performancetrack/mentoring.htm. For more information on the application process, visit www.epa.gov/performancetrack or contact the Performance Track Information Center at email@example.com or (888) 339-7875.
More Benefits on the Horizon
To bolster the "business case" for joining Performance Track, EPA is exploring the possibility of cutting the number of self-inspections for Performance Track members under RCRA from 52 to 12 per year, as well as implementing expedited MACT reviews. The agency also is developing a rule that would allow flexible air permits for Performance Track members that are major sources and will propose a new Performance Track RCRA initiatives rule that will include streamlined permit processes, performance-based tank and generator standards, and improved efficiency between RCRA and Clean Air Act standards.
What Are Performance Track Members Doing to Reduce Water Use?
Facilities are reducing water use though measures such as water conservation programs and process improvements. Water can be conserved in manufacturing processes and in facility operations, such as plumbing and irrigation. To conserve water, Performance Track members are:
In some industries, initial investments in water conservation can pay for themselves in three years or less. Some of the benefits resulting from enhanced water management can include:
This article originally appeared in the January/February 2005 issue Water and Wastewater Products, Vol. 5, No. 1.
This article originally appeared in the 01/01/2005 issue of Environmental Protection.
Daniel J. Fiorino is the director of EPA's Performance Incentives Division and program manager for the National Environmental Performance Track. He is a principal architect and first director of EPA's National Environmental Performance Track. Previously at EPA, Fiorino managed the agency's process for regulatory development and directed analytical projects on waste, pesticides, and toxic substances issues. He is author of an environmental policy text, coauthor of a book on environmental management in public and non-profit organizations, and has been published widely in journals in the fields of public policy, social science, and environmental law. Fiorino holds a PhD in political science from Johns Hopkins University. In 2001, he was elected a fellow of the National Academy of Public Administration.