Environmental Management: An Integrated Approach Could Reduce Pollution
and Increase Regulatory Efficiency (Letter Report, 01/31/96,
GAO/RCED-96-41).

Pursuant to a congressional request, GAO reviewed: (1) the environmental
management approaches used in Massachusetts, New York, and New Jersey;
(2) state and industry experiences with these integrated management
approaches; and (3) the Environmental Protection Agency's (EPA) role in
state efforts to reduce pollution.

GAO found that: (1) Massachusetts has adopted a single, integrated
inspection approach to assess facilities' compliance with environmental
statutes; (2) New York is using a facility-management strategy to
coordinate medium-specific environmental programs; (3) New Jersey is
testing the use of single, integrated permits for industrial facilities,
rather than issuing separate permits for pollution releases; (4)
although Massachusetts and New York intend to implement their integrated
approaches statewide, New Jersey believes that it is too early to
evaluate the success of its pilot program; (5) state industry officials
believe these integrated management approaches are beneficial to the
environment, achieve regulatory efficiencies, and reduce costs; and (6)
EPA has proposed a new grant program that will help states gain easier
access to funding for multimedia programs, as well as ease the reporting
of multimedia activities.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-96-41
     TITLE:  Environmental Management: An Integrated Approach Could 
             Reduce Pollution and Increase Regulatory Efficiency
      DATE:  01/31/96
   SUBJECT:  Environmental policies
             Pollution control
             Environmental monitoring
             State-administered programs
             Reporting requirements
             Grants to states
             Inspection
             Cost control
IDENTIFIER:  Massachusetts
             New Jersey
             New York
             EPA Toxic Release Inventory
             
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Cover
================================================================ COVER


Report to the Ranking Minority Member, Committee on Environment and
Public Works, U.S.  Senate

January 1996

ENVIRONMENTAL MANAGEMENT - AN
INTEGRATED APPROACH COULD REDUCE
POLLUTION AND INCREASE REGULATORY
EFFICIENCY

GAO/RCED-96-41

Integrated Environmental Management

(160304)


Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency

Letter
=============================================================== LETTER


B-270370

January 31, 1996

The Honorable Max S.  Baucus
Ranking Minority Member
Committee on Environment
 and Public Works
United States Senate

Dear Senator Baucus: 

The nation's environmental programs have traditionally been designed
to control the amount of pollution released to a specific
medium--air, water, or land.  Under the medium-specific approach,
permits are issued and inspections are conducted for pollution
released to each medium.  Although these programs have significantly
improved the condition of the environment, concerns have been raised
that the medium-specific approach encourages "end-of-the-pipe"
pollution controls to treat, store, or dispose of waste, rather than
encouraging pollution prevention.  In addition, some industry
representatives believe that having a different set of requirements
for each medium increases the cost and the complexity of compliance
with environmental programs. 

Environmental agencies in Massachusetts, New York, and New Jersey
have experimented with multimedia, or integrated, approaches to
environmental management as alternatives to the traditional
medium-specific approach.  The integrated approaches used in these
three states focus to varying degrees on a whole industrial facility
and all of its sources of pollution.  Proponents believe that
integrated approaches will encourage pollution prevention, reduce
compliance costs to industry, and make environmental programs more
efficient.  In its recent review of the Environmental Protection
Agency (EPA), the National Academy of Public Administration concluded
that EPA should move toward integrating its responsibilities under
various statutes to provide the maximum flexibility needed to
effectively meet environmental priorities.\1

Because of your interest in environmental management, you asked us to
review (1) the approaches used in Massachusetts, New York, and New
Jersey; (2) state and industry experience with these approaches; and
(3) EPA's role in these efforts. 


--------------------
\1 Setting Priorities, Getting Results:  A New Direction for the
Environmental Protection Agency, National Academy of Public
Administration (Apr.  1995). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Although environmental agencies in Massachusetts, New York, and New
Jersey have made significant efforts to integrate their regulatory
activities and to incorporate pollution prevention into these
activities, each state has approached integration differently. 
Massachusetts has adopted a single, integrated inspection to assess a
facility's compliance with environmental statutes, rather than
conducting separate medium-specific inspections.  New York is using a
facility-management strategy in which a team directed by a
state-employed facility manager is assigned to targeted plants to
coordinate medium-specific environmental programs.  New Jersey is
testing the use of a single, integrated permit for industrial
facilities, rather than separate permits for releases of pollution to
each medium. 

Massachusetts and New York believe that their integrated approaches
have proven to be successful and are implementing them statewide. 
Because permits have only recently been issued as part of New
Jersey's integrated approach, officials in that state believe that it
is too early to evaluate the success of its pilot.  According to
industry officials in these three states, integrated approaches are
beneficial to the environment, achieve regulatory efficiencies, and
reduce costs. 

EPA has supported the three states' efforts primarily through funding
assistance.  However, according to officials from each state,
obtaining funding from EPA's grants for medium-specific programs has
entailed lengthy negotiations that might discourage other states. 
Massachusetts officials also noted that meeting EPA's requirements
for medium-specific reports has been difficult.  However, EPA
recently proposed a new grant program that the agency believes will
provide states with easier access to funding for multimedia programs
and will ease the reporting of multimedia activities.  If this grant
program is successful, it may promote the states' efforts to
integrate environmental management. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The Pollution Prevention Act of 1990 established the national policy
that pollution prevention, as opposed to pollution control, is the
preferred method of addressing the nation's pollution problems.  The
act also specified that reduction of pollution at its source (source
reduction) is the preferred method to prevent pollution and should be
used whenever possible.  Source reduction includes modifying
equipment, technology, processes, or procedures; reformulating or
redesigning products; substituting raw materials; and improving
operations and maintenance. 

EPA generally delegates responsibility for the day-to-day
implementation of environmental programs to state agencies that
perform a variety of regulatory functions.  Examples of regulatory
functions include issuing permits to limit facilities' emissions,
conducting inspections, and taking enforcement actions against
violators.  States may also provide nonregulatory technical
assistance, public education, and outreach activities to industry. 
Because many of the nation's environmental statutes are
medium-specific, state environmental agencies and EPA have
traditionally been organized around separate medium-specific program
offices. 

State program offices receive federal grants under environmental
laws, such as the Clean Air Act, the Clean Water Act, and the
Resource Conservation and Recovery Act.  Each state program office
has traditionally conducted its own regulatory activities and
reported them to EPA.  Program offices within a state may have had
little contact with each other.  For example, an air inspector may
not know whether a facility is complying with hazardous waste or
water regulations or what impact a required remedial action is likely
to have on releases to other media.  Most of EPA's funding for state
environmental programs has also traditionally been medium-specific,
although in recent years EPA has provided some funding for the
states' multimedia activities. 

Managing the states' regulatory functions to cut across
medium-specific program lines is a recent phenomenon.  In 1991, the
New Jersey legislature directed that state's Department of
Environmental Protection to conduct a pilot project.  In 1992, the
New York Department of Environmental Conservation began integrating
its environmental programs by using a facility-management approach,
under which the agency assigned a team and a "facility manager"
employed by the state to coordinate environmental programs at
targeted facilities.  The Massachusetts Department of Environmental
Protection began testing multimedia pollution prevention inspections
in 1989 and in 1993 adopted the approach statewide.  Other states,
such as Oregon, Washington, and Wisconsin, have taken steps to
integrate their regulatory activities, but their efforts have been
either very recent or limited in scope. 

Massachusetts, New York, and New Jersey have moved toward integrating
their regulatory activities to promote the use of pollution
prevention strategies, particularly source reduction, rather than
strategies that rely on pollution control.  Pollution control methods
include installing devices that treat waste after it has been
produced.  The three states have also sought to address problems
arising from fragmented, medium-specific approaches to environmental
management, such as pollution shifting, whereby equipment intended to
control pollution in one medium merely transfers pollutants to
another medium rather than reducing or eliminating them at the
source. 


   EACH STATE HAS CHOSEN A
   DIFFERENT APPROACH TO
   INTEGRATION
------------------------------------------------------------ Letter :3

Each of the three states has taken a different approach to
integrating its regulatory activities (see table 1).  Massachusetts
conducts multimedia, facilitywide inspections instead of numerous
medium-specific inspections.  The state also coordinates its
enforcement activities to address violations in all media.  New York
coordinates the activities of its separate medium-specific
environmental programs and targets its efforts at the firms
generating most of the state's toxic discharges.  New Jersey is
testing the use of facilitywide permits, which would replace a
facility's medium-specific permits with a single permit governing the
facility's releases to all media.  Although the three states have
taken different approaches to integrating regulatory activities, each
state looks at whole facilities and their production processes to
identify opportunities to prevent pollution. 



                                Table 1
                
                 Integrated Environmental Management in
                              Three States

                                                        Targeted
State                         Approach    Start date    facilities
----------------------------  ----------  ------------  --------------
Massachusetts                 Facilitywi  Statewide     All but the
                              de          implementati  largest
                              inspection  on            facilities
                              and         in 1993
                              enforcemen
                              t


New York                      Facility    Statewide     400 facilities
                              management  implementati  that produced
                                          on            95 percent of
                                          in 1992       the hazardous
                                                        waste


New Jersey                    Facilitywi  Pilot in      18 facilities
                              de          1991          that
                              permits                   volunteered

----------------------------------------------------------------------
All three states plan to evaluate the environmental outcomes of
integrating environmental management.  Although they have just begun
to develop evaluation plans, the data needed to fully evaluate their
initiatives will not be available for some time.  On the basis of
their experiences thus far, officials in Massachusetts and New York
generally consider the integrated approaches in their states to be
successful, while New Jersey officials believe that it is too early
to predict the success of that state's permitting test. 


      MASSACHUSETTS USES
      FACILITYWIDE INSPECTION AND
      ENFORCEMENT
---------------------------------------------------------- Letter :3.1

In contrast to the medium-specific inspections most states use to
assess whether a facility's releases to a specific medium comply with
state and EPA regulations, Massachusetts has developed a multimedia
approach that incorporates inspections for all media into a single,
facilitywide inspection that focuses on a facility's production
processes.  Inspectors follow the flow of materials used in the
production processes and the inputs and outputs of each process.  At
each step of a process, an inspector identifies areas of regulatory
concern and opportunities to prevent pollution.  EPA Region I helped
Massachusetts develop the single, unified inspection procedure used
by that state's inspectors. 

Massachusetts began testing its facilitywide approach to inspection
and enforcement in 1989 and then implemented it statewide in 1993. 
The Massachusetts Department of Environmental Protection annually
conducts about 1,000 inspections at the approximately 20,000
facilities in the state that are subject to facilitywide inspections. 
To support this approach, the Department reorganized its Bureau of
Waste Prevention, which had been organized with separate air, waste,
and water sections, each of which had performed its own compliance,
enforcement, and permitting activities.  In field offices, these
sections were replaced by a combined section for compliance and
enforcement and a separate section for permits.  The Bureau did not
eliminate medium-specific units in the central office because the
medium-specific nature of federal environmental statutes necessitated
some corresponding organization.  Instead, the Department established
an Office of Program Integration to coordinate these medium-specific
units and foster pollution prevention. 

Massachusetts's enforcement actions encompass violations in all media
and encourage violators to use source reduction techniques to achieve
compliance.  When notifying a facility of any violation, the state
encourages the facility to implement any specific opportunities for
source reduction that the state inspector has identified and informs
the facility that the state's Office of Technical Assistance can
assist in identifying and pursuing additional opportunities for
source reduction.  The state also forwards a copy of all enforcement
documents to the Office of Technical Assistance, which in turn
contacts the facility to offer free, confidential assistance.  When
serious violations and large penalties are involved, the state may
negotiate agreements requiring facilities to undertake pollution
prevention measures in exchange for reduced penalties. 

In addition to its multimedia inspections, Massachusetts recently
tested facilitywide permits that incorporate pollution prevention by
combining the various permits issued to a facility for each medium
into a single permit.  According to a state official, Massachusetts
ended this test because of a lack of participation by the business
community, which apparently believed that a permit process with a
pollution prevention component would be more complicated than the
existing permit process, which was focused exclusively on pollution
control. 


      ALTHOUGH PROGRAM IS NOT YET
      FULLY EVALUATED,
      MASSACHUSETTS BELIEVES IT IS
      A SUCCESS
---------------------------------------------------------- Letter :3.2

Under a fiscal year 1995 multimedia demonstration grant from EPA,
Massachusetts is required to evaluate the results of its integrated
management efforts.  After fiscal year 1995, Massachusetts plans to
develop and test a number of "environmental-yield" indicators, such
as the number of unregistered waste streams discovered and waste
streams eliminated as well as the amount of emissions reduced. 
During the next few years, the state plans to assess the
effectiveness of its integrated program by measuring the extent to
which pollution has been reduced at its source. 

Massachusetts officials believe that the implementation of the
state's facilitywide inspection approach has improved the state's
enforcement program.  They reported that facilitywide inspections
have successfully found sources of pollution that had not been
registered or permitted, promoted pollution prevention, and
encouraged companies to seek technical assistance from the state. 
According to state officials, facilitywide inspections have
streamlined the regulatory process by replacing numerous
single-medium inspections with one multimedia inspection at most
facilities. 

However, the transition from medium-specific to facilitywide
inspections has been challenging.  It has required inspectors,
previously knowledgeable about a single environmental statute, to
become familiar with multiple statutes, techniques to prevent
pollution, and industry's manufacturing processes.  According to
state officials, inspectors have found it difficult to keep abreast
of regulations in numerous environmental programs, as well as the
latest strategies to prevent pollution.  As a result, some inspectors
are concerned that they may overlook compliance problems outside
their area of expertise.  In a 1994 report on the state's enforcement
program, EPA praised the program's emphasis on pollution prevention
but questioned whether inspectors were focusing on pollution
prevention to the detriment of taking enforcement actions.\2 The
report noted, however, that the state had begun an enforcement
training course that stressed the importance of stronger enforcement
actions. 

In addition, Massachusetts has found that facilitywide inspections
are unworkable at the state's largest, most complex facilities, which
constitute five percent of the firms it inspects.  According to a
state official, the state uses a single-medium approach at these
facilities because facilitywide inspections at these facilities take
too long, require too many inspectors, and demand too much expertise. 


--------------------
\2 Final Multimedia Overview Report on Massachusetts Department of
Environmental Protection Enforcement, EPA Region I (Jan.  14, 1994). 


      NEW YORK USES A
      FACILITY-MANAGEMENT APPROACH
---------------------------------------------------------- Letter :3.3

New York is pursuing integrated environmental management by
coordinating its medium-specific activities.  In 1992, New York
started to target its regulatory activities at the approximately 400
facilities that produced about 95 percent of the state's toxic
discharges.  The state still performs single-medium program
activities, such as inspections and permitting, but state officials
coordinate these activities to provide an integrated approach at
targeted plants.  To coordinate activities at each of these plants,
New York has assigned employees of its Department of Environmental
Conservation as facility managers at 94 plants.  According to a state
official, however, it will likely take more than the originally
planned 10 years before New York will be able to assign a facility
manager to each of its 400 targeted facilities. 

The facility manager serves as the primary point of contact between
the state and a plant.  Working with a team of inspectors and other
technical staff, the facility manager plans and oversees inspections,
enforcement, and other regulatory activities at the facility.  For
example, the facility manager guides team members in developing a
profile of the facility that includes permit data, compliance
history, and other information chronicling the plant's emission and
waste-handling practices.  In doing so, the facility manager can
assess what is needed to enhance the facility's efforts to prevent
pollution. 

Because developing the expertise needed to perform multimedia
inspections is difficult, New York requires its inspectors to perform
only medium-specific inspections.  However, the facility managers
coordinate these inspections to provide an integrated inspection
approach.  As the liaison between the state and the facility, each
facility manager must work closely with company officials.  One
facility manager pointed out that an advantage of this relationship
is that the facility manager can sometimes convince the company to
implement pollution prevention strategies without enforcement
actions. 

New York uses enforcement actions as an opportunity to require a
company to undertake projects to prevent multimedia pollution.  For
example, after identifying environmental violations by a chemical
manufacturer, the state negotiated a multimedia consent order
requiring the manufacturer to adopt air, water, and other compliance
measures and to fund an employee from the Department of Environmental
Conservation to assist the facility manager by serving as a full-time
monitor at that facility.  A consent order at another facility
required the company to fund a monitor and develop a
chemical-specific pollution prevention program with specified
reduction goals.  New York also allows companies to reduce their
penalties for violating environmental laws by performing actions that
provide environmental benefits, such as contributing to emergency
preparedness programs for toxic spills. 

In addition to coordinating inspection and enforcement activities,
New York plans to test the use of integrated permits at 3 or 4 of the
400 targeted facilities.  Initial testing has begun at one facility. 


      ALTHOUGH CHALLENGES REMAIN,
      NEW YORK BELIEVES PROGRAM IS
      A SUCCESS
---------------------------------------------------------- Letter :3.4

According to New York officials, the state's facility-management
approach has improved the efficiency of its regulatory activities
while simplifying the facilities' compliance activities.  New York's
approach operates more efficiently because each facility manager
coordinates all of the state's regulatory activities and the various
inspectors approach each facility as a team.\3 One facility manager
said New York's approach has been effective in bringing problem
facilities into compliance more rapidly because the facility manager
is able to focus on problems in all media at one time.  State
officials report that industry has benefited from having a single
point of contact with the state to coordinate the state's inspection
visits.  Although the facility-management approach is labor-intensive
and challenging for the facility managers--who must develop expertise
in a wide range of federal and state laws, industry processes, and
techniques to prevent pollution--the difficulty in obtaining detailed
knowledge about each environmental program is mitigated by the
presence of single-medium inspectors on each facility's inspection
team. 

As part of a departmentwide review, New York plans to develop
performance measures to evaluate its program.  These measures will
assess the amount of pollution prevented and the impact of
environmental programs on the state's natural resources.  New York
officials have not yet established milestones for performing this
evaluation. 


--------------------
\3 1993-1994 Annual Report Multimedia Pollution Prevention in New
York State, New York State Department of Environmental Conservation
(Jan.  1995). 


      NEW JERSEY IS TESTING
      FACILITYWIDE PERMITS
---------------------------------------------------------- Letter :3.5

New Jersey is testing the use of a single, integrated permit for
industrial facilities, an approach that departs from the existing
practice of issuing permits to industrial facilities on a
medium-specific basis.  Under the existing practice, a facility may
have dozens of medium-specific permits that regulate environmental
releases through "end-of-the-pipe" treatment.  Depending on the
medium-specific program, permits may state what pollutants may be
discharged, prescribe technology-based discharge limits, or contain
other requirements. 

In 1991, the New Jersey legislature passed a Pollution Prevention Act
that directed the state's Department of Environmental Protection to
test the use of facilitywide permits at industrial facilities.  The
test is intended to identify ways to streamline and integrate
medium-specific requirements, incorporate pollution prevention into
the permitting process, and improve the overall administrative
efficiency of permitting by consolidating all of a facility's
environmental permits for air, water, and solid and hazardous waste
into a single, facilitywide permit.  This permit incorporates a
pollution prevention plan that examines all of a facility's
production processes and identifies those that use or generate
hazardous substances regulated under New Jersey's Pollution
Prevention Act.\4 Thus, the permit encourages the facility to
consider those substances for elimination or reduction. 

In the past, industry has criticized permits to approve a facility's
production processes and equipment, particularly air permits, because
they hampered the facility's efforts to respond quickly to changing
market conditions.  Facilities that wish to make even minor changes
to a process often had to go through lengthy preapproval procedures. 
As an incentive to participate in its permitting pilot, New Jersey
allows facilities with facilitywide permits to change processes
without preapproval, as long as the changes will not increase
releases of hazardous substances or increase the generation of waste. 
Companies that take advantage of this operating flexibility are
required to expand the number of pollutants that come under their
plans to prevent pollution. 

New Jersey's facilitywide permit requires facilities to at least meet
existing emission standards.  State officials believe that requiring
facilities to achieve the lower emission levels identified in their
source reduction plans would deter them from identifying
opportunities to reduce emissions.  State officials expect that
facilities will voluntarily undertake additional source reduction
projects and reduce their emissions to obtain such benefits as
reduced costs for raw materials and waste disposal. 

New Jersey officials selected 18 facilities from those that
volunteered to participate in the test of facilitywide permits. 
According to state officials, issuing the first permit took 3 years
because major changes were made in the state's permitting process and
some participants did not calculate the information on waste
generation needed to identify opportunities to prevent pollution. 
New Jersey issued the first facilitywide permit in December 1994 to a
pharmaceutical manufacturer that makes tablets, ointments, creams,
and inhalation products for asthmatics.  As of December 1995, two
additional permits had been issued. 


--------------------
\4 New Jersey firms must develop plans to reduce their use and
generation of the chemicals listed in EPA's Toxic Release Inventory,
a major database through which companies annually report to EPA and
the states on their facilities' estimated releases of hundreds of
chemicals.  Firms must perform "materials accounting" to track their
inputs, byproducts, and outputs throughout their production
processes. 


      NEW JERSEY BELIEVES IT IS
      TOO EARLY TO EVALUATE THE
      PROGRAM'S SUCCESS
---------------------------------------------------------- Letter :3.6

Because New Jersey has issued only a few facilitywide permits, state
officials believe that it is too early to evaluate the program's
success or predict whether this permitting approach should be used
more extensively.  Nonetheless, New Jersey officials have already
found that some facilities lack key technical data about the amount
of waste generated, such as accurate data on baseline emissions for a
whole facility.  New Jersey's legislature has directed the state's
Department of Environmental Protection to report by March 1, 1996, on
the results of the test and include recommendations as to whether the
state should expand the use of facilitywide permits. 


      INDUSTRY'S VIEWS
---------------------------------------------------------- Letter :3.7

To obtain industry's views on integrated approaches, we interviewed
officials representing six firms that had participated in the
integrated initiatives in the three states.  These officials
generally believed that their state's integrated approach was
beneficial to the environment while increasing regulatory
efficiencies and reducing costs to industry. 

Company representatives at two small facilities in Massachusetts
reported that the facilitywide inspections, coupled with the state's
technical assistance, contributed to source reduction at their
facilities.  For example, according to an official from a
Massachusetts electroplating company, the awareness of preventing
pollution that was gained from the state's facilitywide inspections
and technical assistance has convinced the company of the value of
reducing pollution at its source.  The company anticipates that
replacing a hazardous chemical with a nonhazardous one will allow it
to pay lower annual compliance fees as a small- rather than
large-quantity generator of hazardous waste. 

According to a representative of a New York manufacturer, its
facility manager has been able to expedite changes in the company's
production processes.  For example, in less than a month the facility
received approval to substitute ethanol for methanol, a change that
eliminated the need for at least 30 air permits.  According to this
representative, the approval process ordinarily would have taken 8 or
more months. 

Representatives of a New Jersey pharmaceutical manufacturer, the
first company in that state to obtain a facilitywide permit, stated
that this facility has eliminated one hazardous substance and
substantially reduced the use of two others.  The company eliminated
1-1-1 trichloroethane, an ozone-depleting substance, in its
label-making process by changing to an aqueous-based process that
uses no hazardous substances.  The facility also developed a
recycling program to recover Freon, an ozone-depleting substance,
from its production of inhalers. 

Representatives of this firm also thought that the facilitywide
permit had simplified their company's compliance activities.  For
example, a new 5-year permit combines 70 air and water permits, as
well as approvals of hazardous waste storage, into a single permit
that eliminates the need for the company to frequently renew multiple
permits.  The company's facilitywide permit consolidates a 3-drawer
horizontal file cabinet filled with permits into one 4-inch binder
(see fig.  1).  The company also enjoys greater operating flexibility
under New Jersey's air regulations, which allow holders of
facilitywide permits to change production processes without a lengthy
preapproval process if the change does not increase hazardous
emissions to air or discharges to water. 

   Figure 1:  Paperwork Reduction
   Resulting From Facilitywide
   Permit

   (See figure in printed
   edition.)

   A representative of a New
   Jersey pharmaceutical
   manufacturer holds the binder
   containing the single
   facilitywide permit that
   replaces voluminous
   medium-specific permits.

   (See figure in printed
   edition.)

   Source:  Schering-Plough
   Corporation.

   (See figure in printed
   edition.)

According to representatives of the pharmaceutical manufacturer, the
company spent $1.5 million in capital and labor resources to develop
the permit but anticipates annual cost savings of $300,000 from
reduced costs for waste disposal and raw materials.  The company also
anticipates substantial reductions in administrative costs because it
will no longer have to frequently replace numerous individual
permits. 

Officials at other facilities, however, were less positive about
their state's integrated approach.  For example, while supportive of
New York's integrated approach, an official of a company in that
state thought that the competitive marketplace, rather than the
government, prompted industrial involvement in preventing pollution. 
Similarly, an official from a Massachusetts company stated that an
interest in economic efficiency drove the company's interest in
reducing waste. 


   EPA'S FUNDING AND REPORTING
   SYSTEMS PRESENT PROBLEMS FOR
   STATES WITH MULTIMEDIA
   INITIATIVES
------------------------------------------------------------ Letter :4

According to officials from Massachusetts, New York, and New Jersey,
while EPA has provided funding for their multimedia pollution
prevention activities, reaching agreements with EPA to fund such
activities has required extensive negotiations.  Obtaining funds for
Massachusetts also required EPA's approval as well as congressional
authorization to reprogram funds from other activities.  New Jersey
and EPA officials have discussed ways to incorporate that state's
multimedia activities into EPA's medium-specific grant system, but
they have not fully resolved the issue.  Officials in all three
states concurred that even though EPA's grant system has some
flexibility, having to petition the agency to obtain funds may
discourage some states from considering multimedia initiatives. 


      MEDIUM-SPECIFIC PROGRAM
      GRANTS DO NOT READILY FIT
      MULTIMEDIA ACTIVITIES
---------------------------------------------------------- Letter :4.1

EPA has provided grants to each of the three states to support their
multimedia pollution prevention activities.  Massachusetts received a
$288,000 grant in fiscal year 1990 for its facilitywide inspection
pilot; New York received a $222,276 grant in fiscal year 1993 to
conduct outreach and technical assistance projects; and New Jersey
received a $207,000 grant in fiscal year 1993 to assist the state
with its permitting pilot.  However, all three states subsequently
found that continued funding for multimedia activities was not easily
obtained under the current federal medium-specific grant programs. 

For each medium-specific grant program, the states use EPA's guidance
to prepare annual plans detailing the activities they intend to
perform in the coming fiscal year.  Once EPA approves a state's plan,
it allocates funding on the basis of the planned activities.  In
fiscal years 1993 and 1994, Massachusetts and New Jersey requested
that EPA provide additional credit for work performed under these
medium-specific programs for their facilitywide inspection and permit
programs.  The two states asked that EPA, in calculating their
allocation, give them extra credit for multimedia activities because
these activities encompass all media programs, require additional
staff training and guidance, and contain an additional component to
prevent pollution. 

After extensive negotiations, Massachusetts and EPA signed agreements
attached to medium-specific grants for fiscal years 1993 and 1994. 
These agreements allowed the state to conduct facilitywide
inspections and to support its multimedia activities by using the
funds allocated for compliance and enforcement activities under its
existing medium-specific grants.\5

Because of the potential benefits from multimedia activities and the
difficulty of funding them through medium-specific grants, EPA
awarded Massachusetts a $1 million grant in fiscal year 1995 to
demonstrate multimedia activities.  This grant was made with funds
that would have otherwise been awarded through medium-specific
grants, and no new funds were granted.  According to EPA and state
officials, although the grant was intended to alleviate their
concerns about using medium-specific funding for multimedia
activities, it does not permanently resolve the problem of funding
for multimedia activities because it can be renewed for only 2 years. 

EPA and New Jersey officials have extensively discussed ways to fund
that state's facilitywide permit activities through medium-specific
grants.  As of September 1995, New Jersey and EPA have not fully
resolved this issue. 

New York asked EPA for a special allocation from its medium-specific
grants to support the state's pollution prevention unit because if
the unit's duties were part of a medium-specific program they would
be eligible for EPA's support.  New York also noted that its
multimedia program represents a new way of doing business because its
focus is on preventing pollution at the state's largest dischargers. 
After extensive negotiations, EPA agreed to allow New York to fund
the multimedia activities of the pollution prevention unit with
funding for medium-specific activities.  New York's pollution
prevention unit incurred costs of $838,000 in fiscal year 1994 and
operated under a comparable agreement in fiscal year 1995. 

Officials in all three states noted that having to extensively
negotiate with EPA to obtain funds for an integrated approach may
discourage other states from adopting multimedia initiatives. 


--------------------
\5 These funds amounted to $1.5 million in fiscal year 1993 and $1.4
million in fiscal year 1994. 


      REPORTING RESULTS FROM
      MULTIMEDIA INSPECTIONS TO
      EPA'S MEDIUM-SPECIFIC
      REPORTING SYSTEMS IS
      DIFFICULT
---------------------------------------------------------- Letter :4.2

In addition to the problems with obtaining funds for multimedia
activities, Massachusetts has encountered problems in reporting its
multimedia activities to EPA, as required under various federal
environmental statutes.  For example, while Massachusetts conducts
facilitywide inspections and prepares comprehensive reports detailing
the results from multimedia inspections, EPA requires the state to
report the results to multiple medium-specific reporting systems,
each of which has different formats, definitions, and reporting
cycles.  According to a Massachusetts official, preparing these
duplicative reports is both wasteful and demoralizing to staff. 


      RECENT EPA INITIATIVES
      ADDRESS STATE MULTIMEDIA
      ACTIVITIES
---------------------------------------------------------- Letter :4.3

A grant program EPA recently proposed may provide states with easier
access to multimedia funding and promote the reporting of their
integrated facilities management activities.  As part of EPA's fiscal
year 1996 budget request, the President proposed that the Congress
give EPA's Administrator the authority to allow states to consolidate
numerous medium-specific grants into a new "Performance Partnership"
grant program.  These grants would allow states to allocate funds to
reflect local priorities while continuing to pursue national policy
objectives and fulfilling all federal statutory requirements.  The
grant program would include new performance measures to simplify
reporting requirements while ensuring continued environmental
protection.  EPA plans to work with state officials to develop
performance measures that assess the programs' environmental impact,
instead of using measures that focus only on the number of
medium-specific program activities performed.  According to officials
in Massachusetts, New York, and New Jersey, each state plans to
participate in this grants program. 

EPA is also studying the effectiveness of initiatives to prevent
pollution in eight northeastern states, including the multimedia
efforts in Massachusetts, New York, and New Jersey.  The study, which
EPA planned to complete by December 1995, will compile data on the
experiences of industrial facilities with government activities on
how to prevent pollution.  In addition, EPA plans to conduct a
national study of pollution prevention effectiveness in 1996. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

Although the three states have not yet fully assessed the
effectiveness of integrating environmental management, this approach
shows potential for reducing pollution and increasing regulatory
efficiency.  Officials representing Massachusetts and New York, the
states having the most experience with integrated approaches,
generally report improvements in promoting pollution prevention and
achieving regulatory efficiencies.  Industry representatives also
reported positive results from using this approach.  Nonetheless,
drawbacks exist.  For example, performing integrated inspections and
promoting pollution prevention requires inspectors to have additional
expertise. 

Each of the three states has found it difficult to fund its
multimedia activities through EPA's grants for medium-specific
programs.  While EPA has worked with these states to resolve the
funding problems, the extensive negotiations that were required could
discourage other states from adopting multimedia initiatives.  In
addition, Massachusetts had problems reporting multimedia activities
under medium-specific reporting systems.  A new grant program
recently proposed by EPA has the potential to facilitate the
multimedia funding and reporting process for the three states.  If
successful, this grant program may resolve funding and reporting
issues for those other states that are interested in using an
integrated environmental management approach in their regulatory
activities. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

We provided copies of a draft of this report for review and comment
to EPA, the Massachusetts Department of Environmental Protection, the
New York Department of Environmental Conservation, and the New Jersey
Department of Environmental Protection.  On December 8, 1995, we met
with EPA officials, including the Director of the Pollution
Prevention Policy Staff, who generally agreed with the report's
findings.  The officials stated that the funding and reporting
problems noted in the report are, at least in part, the result of (1)
medium-specific statutes and appropriations and (2) the
medium-specific accountability processes associated with them. 

On December 5, 1995, we met with Massachusetts and New York state
officials, including the Director of the Office of Program
Integration of the Massachusetts Department of Environmental
Protection and the Chief of the Bureau of Pollution Prevention of the
New York State Department of Environmental Conservation.  On December
8, 1995, we met with New Jersey officials, including the Director of
the Office of Pollution Prevention of the New Jersey Department of
Environmental Protection.  These state officials agreed with the
report's facts and findings and suggested some technical corrections,
which we have incorporated into the report as appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

We performed our work at the Massachusetts Department of
Environmental Protection, the New York Department of Environmental
Conservation, and the New Jersey Department of Environmental
Protection.  According to EPA, these states are among the leaders in
adopting integrated approaches to regulatory activities.  We
contacted six companies that had significant experience with their
state's integrated efforts--three in Massachusetts, two in New York,
and one in New Jersey.  We also performed work at EPA's headquarters
in Washington, D.C., and at the agency's regional offices in Boston
and New York City, the EPA offices that cover the states we visited. 
We performed our work in accordance with generally accepted
government auditing standards from May 1995 through December 1995. 


---------------------------------------------------------- Letter :7.1

As arranged with your office, unless you publicly announce this
report's contents earlier, we plan no further distribution until 10
days after the date of this letter.  At that time, we will send
copies of the report to other appropriate congressional committees
and the Administrator of EPA.  We will also make copies available to
others upon request. 

Please call me at (202) 512-6112 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
I. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Lawrence J.  Dyckman, Associate Director
Ed Kratzer
James S.  Jorritsma
Bruce Skud
Janet G.  Boswell


*** End of document. ***