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Drivers of environmental innovation - Vinnova

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oth in the regulated industry and outside with, for example, suppliers. Often<br />

firms outside the regulated industry develop the <strong>innovation</strong>s (Kemp,<br />

Forthcoming).<br />

Product regulations tend to call forth product <strong>innovation</strong>, whereas component<br />

or pollutant regulations elicit process regulations. Process regulations can<br />

stimulate process as well as product <strong>innovation</strong> (Ashford et al, 1985). Standards<br />

can stimulate <strong>innovation</strong> to reduce energy consumption (Hemmelskamp,<br />

Forthcoming).<br />

A distinction in the regulating pressure placed upon the firms can be made<br />

between Permit Based Regulation (PBR) and Incident Based Regulation (IBR).<br />

PBR firms are those that release certain amounts <strong>of</strong> regulated substances and<br />

have to seek permission from <strong>environmental</strong> regulators before releasing<br />

polluting media to the atmosphere, land or water. IBR firms are the majority <strong>of</strong><br />

firms and they have very limited interaction with <strong>environmental</strong> regulators.<br />

They will only come in contact with the regulators if an <strong>environmental</strong> problem<br />

has been traced back to the firm in question. A British study showed that IBR<br />

firms lag behind PBR firms in all <strong>of</strong> the key motivators to <strong>environmental</strong><br />

<strong>innovation</strong>. PBR firms are likely to be stimulated by both external and internal<br />

motivations, whereas IBR firms are more likely to be prompted by external<br />

factors alone such as legislation which do not significantly affect them.<br />

Generally the PBR firms surveyed could see more benefits from making<br />

<strong>environmental</strong> improvements than IBR firms could (Connell and Flynn, 1999).<br />

Theoretical observations associate several disadvantages with regulation.<br />

Mostly it is pointed out that requirements constitute the most expensive option<br />

for society, since all polluters are treated on an equal basis, irrespective <strong>of</strong> their<br />

individual avoidance costs. Thus emissions below the fixed level do not result<br />

in costs for the emitter, and consequently the emitter is no longer interested in<br />

the more far-reaching emission-reducing measures. Tightening <strong>of</strong> the standards<br />

makes steady development possible (Hemmelskamp, 1997).<br />

There are other disadvantages. Inefficiencies arise out <strong>of</strong> the varying costs <strong>of</strong><br />

individual firms and from increasing marginal costs <strong>of</strong> avoidance. Lock-in<br />

effects may also be a result, if new production installations are subject to lower<br />

limiting values or to new technology standards adjusted to the current level <strong>of</strong><br />

development that may also entail increased costs. This will decrease firms'<br />

incentives to invest in new equipment. Updating state-<strong>of</strong>-the-art technology<br />

lists is a lengthy procedure and there is a risk <strong>of</strong> the lists lagging behind new<br />

technology developments (Hemmelskamp, 1997).<br />

On the other hand, there are also theoretical advantages. As long as there is<br />

adequate monitoring and enforcement, regulatory instruments provide<br />

certainty <strong>of</strong> the policy outcome. This is necessary in case <strong>of</strong> toxic pollutants,<br />

which should be banned or rigorously controlled. Another advantage is that the<br />

authorities have longstanding experiences <strong>of</strong> this approach (OECD, 1994).<br />

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