1996 Electronics Industry Environmental Roadmap - Civil and ...

Strategic Business Opportunities
Prototype Facilities: Companies could collaborate in establishing prototype programs and
facilities for managing significant environmental issues. For example, several pilot
product disposition programs, such as the American Plastic Council’s research program
on plastic recycling are currently underway, most with some industrial involvement.
Research programs, equipment development, process improvement, infrastructure
development—all of these lend themselves to collaborative initiatives, and many are
ideally suited for cross-industry cooperation or public/private partnerships.
Model Permitting Processes: In some states, electronics and computer companies have
worked with state regulators to develop model permitting processes that would accelerate
permit approval. This occurs by specifying certain standards that are mutually acceptable
to industry and regulators. To the extent an individual permit applicant meets the stated
standards, permit approval would be expedited and substantial cost savings could accrue
to the company. Proposals for the elements of these standard permits could be developed
on a national basis and made available to regulators through professional channels in an
effort to promote consistency among jurisdictions.
Several models exist that could form the basis for innovative model permitting proposals.
For example, the “Dutch Covenant System” encourages self-regulation within a
framework developed and agreed upon jointly by industry and government. The
framework includes performance-based, quantitative objectives, with emission targets for
priority substances apportioned among industry sectors. Industry is then responsible for
determining the best approach to meeting the standards, and documents its strategies and
tactics in company environmental management plans. These plans are incorporated in
company-specific licenses and permits, and updated regularly. A major benefit of the
covenant approach is increased communication and understanding among parties
involved in the regulatory process, which yields lower barriers to cooperation in the long
run. Another approach is EPA’s model-permitting program, which develops a spirit of
partnership in the permitting process. An example of this approach is the Intel
Corporation’s P4 Project.
Intel Case: P4 Project
In late 1993, Intel Corporation, the U.S. EPA, and the Oregon Department of
Environmental Quality entered into a partnership to evaluate opportunities to
incorporate flexibility and pollution prevention into permits issued under Title V
of the 1990 Clean Air Act Amendments. The Pollution Prevention in Permitting
Pilot (P4) Project was undertaken to develop a facility-specific permit that
incorporates pollution prevention as a model permit condition for achieving
regulatory compliance. The project’s goals are to develop an implementable
permit, identify regulatory barriers affecting pollution reduction alternatives,
document the process, and develop options and alternatives that can be useful to
others.
The project demonstrated that pollution prevention performs equally well in the
reduction of air emissions as do traditional, regulatory-specific, end-of-pipe
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