Impact of BODs on Fish

Report
Impact of BODs on Fish
8 ppm
8 ppm
NPEDES
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Rulemaking Process
Regulatory Output
Abatement Costs
Compliance
Environmental Impact
Perverse Incentives
Permitting
• “Permits are the legally binding terms that a
control authority imposes on a pollution sources as
a conditions for building or operating the sources.
Permits are designed to reconcile what the source
emits with what standards allow. Permits are the
basis for compliance, the key to pollution control,
the nexus between the control authority and the
pollution sources.”
– Davies, Reforming Permitting
Permitting Process
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Expensive
Complex, Long
Many agencies,
Separate permit for each media
– CAA, Title V
– CWA
– RCRA
• Dynamic nature of process
Regulatory Impact
• Permits = Bargaining
• Consent of regulated Success
• New facilities versus Renewal
Compliance
• Bethlehem Steel, MD
– 48th biggest toxic metal
polluter
– CWA permit expires 1985
• Fragmentation- Frigidaire
Power!
• Administrative
Discretion = Power!
the initial
– Manchester Sewer
Overflow
– Permit requirements
are in “policy
guidance” to states
– No one sues, it is legal
A Better Way?
“Cheaper, Faster, Better”
• “Goals of the program are to achieve a cleaner
environment at the lowest cost.”
– President Clinton
• "The old way of doing business was that
government dictates every move a business must
take to protect the environment. The new system,
envisioned by Project XL, is to work
cooperatively and focus on the results: a cleaner
environment; a faster, less costly system; with
more input from the local community."
– Intel CEO, Gordon Moore
Project XL
• Flexibility for
Superior
Environmental
Performance (SEP)
• Site-specific plans
• Stakeholder
negotiations
• Voluntary
Intel
• Why go XL?
• Deliver SEP?
• Stakeholders?
SEP
• Intel trades
– 50% less air pollutants
– Conserve water
– Reduce Chemical
waste 60%
– Pretty Campus
• EPA
– Modest flexibility
• Sound good?
Weyerhaeuser, GA
• 500 jobs, $75 million
• 320,000 mton of
bleached softwood
kraft market fluff pulp
Weyerhauser
• SEP
– 60% air emissions
– Renewable forest mgmt
practices 300k acres
– Stricter h2o effluents limits
• Innovation
– Closed loop
– No bleach dumping
– Reduce hazardous waste 90%
Merck Stonewall Plant
• Trading Ozone for Smog
Substantive Issues
• What is “superior environmental performance”
– What’s the baseline, Kenneth?
– “Clear reduction in risk” ?
– Whose environmental priorities– habitat, green
space, parks
– Okay to trade for social/political benefits
Procedural Issues
• Role of “outside stakeholders”
• Power of stakeholders, veto?
– Absolute conesnes
• Expertise
• Time Consuming
• Legal?
– No protection from citizen suits
Big ?s
• Goals of Reinvention?
– Balance between environmental quality and
reducing compliance costs
– When to trade-off
– Who makes trade off?
• What if no-one wanted to reinvent the
process?

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