Brainstorming Ideas: Program Concepts

- current compliance as floor for entry into program

- cross-media?

- federal/ state/ local?

- encourage new improvement

- "most improved" category

- tiering

- allow recognition of improvements as they occur

- create incentives to encourage coming into compliance

- tiering

- leaders

- those coming into compliance

- identify ways for company to improve: management plans

- EMS

- some companies hold EMS confidential

- small companies need separate (less specific?) requirement?

- different requirements for different businesses?

- small business: more loosely define "EMS"/ management system

- build in discretion for oversight agency

- have administration of program done by broad-based group (see, e.g., New Mexico program)

- making policy decisions of who/ what qualifies

- different requirements for different sectors?

- governmental v. non-governmental

- big business/ staffed EMS

small business/ policy statement

- special negotiated arrangements or more generalized requirements?

- administrative concerns with negotiated arrangements

- reward actual accomplishments

- idea:

- Tier 1: compliance for three years and development of EMS = logo

- Tier 2: implementation of EMS = regulatory flexibility

- Tier 3: specific P2 improvements = financial incentives

- compliance - current/ past/ ongoing

- how to define?

- how to accommodate?

- agency cost of administering program?

- pilots in first year

- increase number of participants in controlled way

Brainstorming Ideas: Benefits of Participation in Program

- streamline procedures

- economic benefits, e.g.

- reduced cost of waste management

- tax benefits

- recognition

- training component

- referral program

- see, Questar/ certification program

- list of qualifying companies

- public awareness of "symbol"

- streamline permits

- especially for new processes

- train people in community, esp. re: pollution prevention

- give opportunity to speak to regulators outside of office

- give special access to regulators

- save regulatee time and $$

- different size businesses need different incentives/ benefits

- smaller business: reduce cost of permits and services

- smaller business especially: one point of contact

- small business: receive knowledge about additional requirements, especially those at local level

Brainstorming Ideas: Other Components of Program

- peer education/ mentoring

- antitrust issues?

- inter-state or inter-industry training

- higher education as information conduit

- self-disclosure of violations/ problems

- careful of self-incrimination

- stakeholder involvement in process

- how to do it?

- may be negative reaction to having stakeholders involved in design of facility process