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EPA’s Performance Track:
An Opportunity for Leadership
Chuck Kent, Director
USEPA Office of Business and Community Innovation
SUNY Environmental Health and Safety Association
Fall Conference
November 14, 2005
What Is Performance Track?
• Differences in environmental performance
• Recognized in EPA-State actions and policies
• Carrots may work in addition to sticks
• Strive for collaboration with accountability
• Goal is to continually improve performance
Performance Track: Key Facts
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Facility based, for private & public sectors
Launched in June 2000
Currently more than 370 members (1 University)
Two application periods annually (Feb-Apr; Aug-Oct)
Work in close collaboration with States
Application & reporting systems are online
Involves benefits & obligations for members
Site visits with a sample of members each year
Criteria for PT Membership
• Working environmental management system
(EMS)
• Commitment to continuous improvement
– set four goals for the three-year period
– report annually on results
• Record of sustained compliance
• Commitment to public outreach
Performance Indicators
• Upstream
-supplier’s performance; material procurement
• Inputs
-energy, water, & materials use; habitat conservation
• Downstream
-product impacts
• Non-product outputs
-air & water discharges; wastes generated
PT Member Results Through 2004
• Water Use: reduced by more than 1.3 billion gallons
• Solid Waste: amount generated has declined by nearly
600,000 tons
• Energy Use: Decreased by over 8.4 trillion British
Thermal Units (BTUs)
• Habitat Conservation: set aside 7,871 acres of land, an
area larger than 7,000 football fields
• NOx: reduced by almost 3,900 tons
Some Members’ Achievements
• Washington State University (Washington)
-reduced NOx emissions by 69%
-restored 4.25 acres of wetlands
• Johnson & Johnson Research & Development (Pennsylvania)
-offset 8,052 metric tons of CO2 through purchase of wind & biomass
energy.
-cut solid waste by 8 tons
• Bridgestone-Firestone (South Carolina)
-improved energy efficiency by 19%
-avoided generation of 22 million pounds of solid waste
Member Locations
• Accepted in 2001 - August 2004
• Accepted in February 2005
Distribution of Members
Size of Performance Track Facilities
Number of Employees
Number of Members
49
Fewer than 50
50 - 99
31
109
100 - 499
500 - 1,000
More than 1,000
72
90
Performance Track & Small Business
• Fewer than 50 employees
• Criteria
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Show one past achievement
Commit to two future improvements
EMS evaluation considers size and scope
Sustained compliance record
• Represent 14 percent of members
• Members include a printer, dry cleaner, lumber mill,
among others
EPA Sectors Program
• An EPA program to work collaboratively
with Colleges and Universities (C&U) to
– Encourage Environmental Management
Systems (EMS) and environmental stewardship
initiatives
– Improve environmental performance of the
sector as a whole
– Reduce regulatory burdens
Overview of Proposed Rule for
College and University Laboratories
• New regulations for laboratories at colleges and
universities
– Subpart K
• Rule will be optional
– satellite area regulations OR new Subpart K
• Proposed Rule maximizes flexibility while
maintaining equivalent protection
• Performance-based management standards
• Laboratory Management Plan (LMP)
Management in the Laboratory
• Performance-based Standards:
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Container labeling
Container management
Training for laboratory workers
Instruction for students
Training to ensure safe movement
Develop a regular schedule for identifying and removing “unwanted
material”
– Making hazardous waste determination
– Conducting laboratory clean-outs
– Emergency prevention, notification, and response procedures
• Laboratory Management Plan
– Describes HOW the performance-based standards will be implemented
EMS & Environmental Stewardship
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Letter promoting
Environmental
Stewardship and
EMS
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Sent by ACE (The
American Council on
Education) and EPA
Sent to all college and
university Presidents
and Chancellors
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December 2004
EMS & Environmental Stewardship
• EMS web site
http://www.campusEMS.org/
• A one page business case
“Fact Sheet for Senior
Administrators
http://www.c2e2.org/ems/tool
s.htm#getstarted
• Case Studies on different
EMS approaches
EPA Audit Policy and
Environmental Results Program (ERP)
Objective: To get as many schools on the right
track to compliance and towards EMSs
• Encouraging schools implementing EMSs to
take advantage of the Audit Policy
• Exploring ERP for Colleges and Universities
Comprehensive Strategic Plan
• In order for colleges and universities to accommodate
growth on their campuses, institutions need integrate
environmental sustainability into every aspect of campus
life: planning, environmental quality and education.
• Requires an approach that is interdependent & integrated;
conscious & visible; linking all organizations’ &
operations’ sustainable efforts to the formal curriculum; and
communicating everything we’re doing to everyone.
What is the Comprehensive Strategic
Plan (CSP)?
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One approach to developing a more sustainable campus
A comprehensive checklist
A resource guide
A database of best management practices
Ties plan to the budget
Incorporates “Plan-Do-Check-Act” model
Benefits of the CSP
• Implement sound conservation practices
into planning and design of capital
improvements on campus
• Incorporate environmental safety
practices
• Provide baseline for measuring change
• Identify priorities for environmental
improvement
• Conserve resources
• Minimize environmental impacts,
including impact on cultural resources
Next Steps
• Develop comprehensive checklist / guide in
coordination with EPA Programs, trade
associations, and interested stakeholders
• Collaborate with trade associations and interested
stakeholders to create a national challenge
program for colleges & universities
• Launch challenge program by July 2006 at joint
APPA/NACUBO/SCUP Conference
EPA Sector Strategies Division
Peggy Bagnoli
(202) 566-2957
[email protected]
http://www.epa.gov/sectors
Why Join Performance Track?
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Recognition for environmental results
A different relationship with government
Lower regulatory transaction costs
More regulatory flexibility
Being a part of a “green club”
Exposing students to top environmental
practices
Why Join? Recognition
• EPA and state agencies
-website
-national & regional events
-publications
• Communities
• Investors/Alumni
• Employees/Students
Why Join? Relationships
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Low inspection priority
Dialogue with EPA and States
Priority on administrative issues
Addressing problems in different ways
Why Join? Reduce Costs &
Gain Flexibility
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Reduced routine compliance reporting
Extension in the 90-day storage rule
Preference for NPDES permit renewals
Attention in flexible air permitting
Streamlined requirements in RCRA
Why Join? A “Green Club”
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Recognized community of high performers
Promote the value of the PT “brand”
Tele-seminars/learning opportunities
Leadership Practices Database
Performance Track Participants Association
Access to resources on program criteria
Why Join? Expose Students to
Top Environmental Practices
• Onsite EMS provides opportunities for
student involvement
• Students of environmental studies get a
better understanding of the benefits and
limitations of an EMS through hands-on
experience
Working with States
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Joint effort with ECOS
MOAs set terms for close collaboration
Annual conference and regular consultation
Advise on application reviews
States With EPA Agreements
ME - 6
WA - 9
NH - 8
OR - 7
VT - 1
ND - 0
MT - 0
MN - 4
ID - 1
MA - 12
SD - 4
WI - 2
MI - 8
WY - 2
CT - 5
IA - 10
PA - 15
NE - 2
NV - 3
UT - 3
OH - 14
IN - 8
KS - 1
VA - 10
MO - 2
NM - 4
OK - 4
MD - 1
KY - 6
NC - 3
TN - 6
AZ - 6
NJ - 15
DE - 2
WV - 1
CO - 10
CA - 26
RI - 1
NY - 15
AR - 5
SC - 7
MS-4 AL - 7
GA - 15
Existing MOAs
TX-24
MOAs in Progress
LA - 6
FL - 13
AK - 0
PR - 15
HI - 0
States With Performance Based Programs
ME - 6
WA - 9
NH - 8
OR - 7
VT - 1
ND - 0
MT - 0
MN - 4
ID - 1
MA - 12
SD - 4
WI - 2
MI - 8
WY - 2
CT - 5
IA - 10
PA - 15
NE - 2
NV - 3
IL - 15
UT - 3
OH - 14
IN - 8
KS - 1
VA - 10
MO - 2
NM - 4
OK - 4
MD - 1
KY - 6
NC - 3
TN - 6
AZ - 6
NJ - 15
DE - 2
WV - 1
CO - 10
CA - 26
RI - 1
NY - 15
AR - 5
SC - 7
MS - 4
AL - 7
GA - 15
Active State Program
Developing State Program
No State Program
TX - 24
LA - 6
FL - 13
# - # of PT Members
AK - 0
PR - 15
HI - 0
* Map includes
facilities
accepted
through Round 9
Where Do We Want to Go?
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Growth in number and range of members
Increased environmental value
Enhanced business value
Transform relationships
Institutionalize in EPA and State programs
www.epa.gov/performancetrack
(888) 339-PTRK
www.epa.gov/region02/p2/univ.htm/
EPA Region 2 Regional Coordinator
Judy-Ann Mitchell
(212) 637-3721