
1­
13­
05
1
Survey
of
State
Support
for
Performance­
Based
Environmental
Programs
and
Recommendations
for
Improved
Effectiveness
Final
Report
Executive
Summary
At
the
request
of
Administrator
Leavitt,
the
Environmental
Council
of
the
States
(
ECOS)
has
prepared
this
report
to
describe
the
level
of
support
among
states
for
Performance
Track
and
state
performancebased
environmental
leadership
programs
and
to
recommend
actions
states
believe
EPA
should
take
to
improve
the
effectiveness
and
enhance
the
value
of
these
programs.
These
recommendations
are
based
on
interviews
with
commissioners
and
senior
management
from
40
state
environmental
protection
agencies.
ECOS
also
met
with
representatives
of
the
Performance
Track
Participants
Association
to
seek
their
input.

The
fundamental
goal
of
Performance
Track
and
other
state
innovations
programs
is
to
achieve
better
environmental
results.
As
such,
these
programs
tend
to
focus
on
environmental
outcomes
(
reduced
emissions
or
higher
compliance
rates)
rather
than
operationally­
based
output
measures
(
number
of
inspections
or
permits).
These
programs
often
provide
regulatory
flexibility,
creating
opportunities
for
high
performers
to
go
beyond
the
compliance
measures
that
are
typically
established
by
regulations.
They
also
provide
opportunities
for
state
and
federal
government,
as
well
as
the
regulated
community,
to
target
financial
and
human
resources
more
strategically
to
produce
better
overall
environmental
results.

The
ECOS
states
applaud
Administrator
Leavitt,
Steve
Johnson,
and
the
key
leaders
at
the
Environmental
Protection
Agency
for
their
leadership
and
vision
to
advance
these
goals
through
Performance
Track
and
other
state
programs.
These
programs
represent
a
fundamental
change
from
the
past
approach
to
environmental
protection,
focusing
on
incentives
and
risk­
based
decision­
making.
They
will
require
commitment
and
careful
direction
to
succeed.
With
the
priority
and
support
currently
coming
from
the
administrator
and
his
staff,
these
programs
have
the
potential
to
move
the
country
significantly
forward
in
meeting
and
exceeding
its
environmental
goals.

We
found
substantial
interest
among
states
in
performance­
based
environmental
leadership
programs:

 
More
than
20
states
have
active
state­
level
performance­
based
programs,
and
an
additional
five
states
are
currently
developing
programs;
 
Eighteen
states
rank
performance­
based
leadership
programs
among
their
10
top
priorities
(
eleven
of
these
rank
them
among
their
top
five
priorities);
 
Nearly
half
of
the
states
interviewed
for
this
effort
(
19
states)
report
actively
promoting
Performance
Track;
and
 
Nine
states
have
signed
Memoranda
of
Agreement
(
MOAs)
with
EPA
to
enhance
coordination
and
alignment
of
their
state­
level
efforts
with
EPA's
Performance
Track
program.

ECOS
believes
that
performance­
based
programs,
such
as
EPA's
Performance
Track
and
similar
state
programs,
have
the
potential
to
play
an
increasingly
important
role
in
our
nation's
environmental
management
system.
Performance­
based
programs
can:

 
Encourage
and
reward
strong
and
sustained
environmental
performance
improvement
among
the
regulated
community
that
goes
beyond
compliance
and
addresses
unregulated
environmental
issues;
 
Foster
greater
collaboration
between
environmental
regulatory
agencies
and
high­
performing
companies
and
government
facilities
to
achieve
state
and
regional
environmental
goals
and
address
environmental
problems;
1­
13­
05
2
 
Support
the
development
of
cost­
effective
approaches
for
achieving
environmental
goals
that
focus
on
performance
results;
and
 
Free
some
agency
compliance
assurance
resources
to
address
higher
environmental
priorities.

Because
of
our
strong
support
for
performance­
based
programs,
ECOS
welcomes
the
opportunity
to
offer
recommendations
to
EPA
for
actions
that
can
strengthen
both
Performance
Track
and
state
programs
and
make
them
core
elements
of
the
environmental
protection
system
in
the
U.
S.
Our
recommendations
fall
into
four
main
areas.
These
areas,
along
with
recommended
priority
actions
for
attention
in
2005,
include:

1.
Support
State
Programs
and
State
Efforts
to
Work
with
Performance
Track
 
EPA
and
states,
through
Performance
Partnership
Agreements
(
PPAs)
or
other
state
planning
agreements,
should
provide
credit
to
states
for
environmental
and
compliance
outcomes
achieved
through
performance­
based
programs.
Such
credit
should
be
negotiated
between
the
state
and
their
EPA
Regional
counterparts
and
include
tradeoffs
with
traditional
output
measures.
To
facilitate
this
process
we
recommend
that
EPA
and
ECOS
jointly
develop
guidance
documents
for
Headquarters
and
Regional
program
staff
that
encourage
and
accept
the
use
of
alternative
outcome
measures
of
performance­
based
programs.

 
Direct
management
to
create
specific
line
items
in
each
office
budget
to
include
support
for
performance­
based
programs
as
a
component
of
the
FY
06
budget
development
process
 
both
financial
and
in­
kind
(
e.
g.,
funding
positions
for
experts
within
EPA
regional
offices
to
assist
states).
States
can
use
this
support
for
program
management,
outreach,
recruitment
and
incentive
implementation
related
to
Performance
Track
and
state
performance­
based
environmental
leadership
programs.

2.
Assure
Program
Support
from
All
EPA
Program
Offices
 
Establish
an
EPA­
ECOS
working
group
(
perhaps
through
the
ECOS
Planning
Committee)
to
facilitate
building
Performance
Track
into
next
year's
strategic
plan
for
each
EPA
regional
program
office.
The
plan
development
process
should
focus
 
on
building
support
from
program
office
staff
and
empowering
them
with
appropriate
performance
measures.
This
will
help
move
Performance
Track
goals
and
responsibilities
into
core
programs
and
ensure
that
staff
from
all
program
offices
at
EPA
Headquarters
and
Regions
are
familiar
with,
responsible
for,
and
actively
support
federal
and
state
performance­
based
programs.

3.
Provide
Better
Incentives
to
Participants
Faster
 
Convene
an
EPA­
ECOS
working
group
to
establish
a
revitalized
system
for
identifying,
developing,
and
implementing
incentives
for
Performance
Track
and
state
programs.
This
effort
should
also
include
the
National
Pollution
Prevention
Roundtable
(
NPPR),
Multi­
State
Working
Group
(
MSWG)
and
participants
in
Performance
Track
and
state
performancebased
programs
 
all
partners
in
advancing
the
effectiveness
of
these
programs.
By
September
2005,
the
working
group
should
produce
a
detailed
blueprint
of
a
streamlined
process
for
incentives
development
with
lower
transaction
costs,
which
involves
active
participation
of
representatives
from
across
EPA's
program
offices
and
ECOS.

 
Establish
a
joint
EPA­
ECOS
working
group
to
conduct
an
evaluation
of
potential
regulatory
and
statutory
options
for
supporting
performance­
based
programs
and
incentives
by
September
2005.
1­
13­
05
3
4.
Conduct
More
Strategic
Marketing
and
Education
of
the
Programs
 
Establish
a
working
group,
comprised
of
EPA,
ECOS,
NPPR,
MSWG
and
participants
in
performance­
based
programs,
to
develop
a
long­
term
strategic
plan
by
December
2005
for
"
branding"
the
Performance
Track
and
state
programs.
The
plan
should
identify
strategic
outreach
and
participant
recruiting
actions
to
pursue,
including
joint
marketing
of
Performance
Track
and
state
programs
at
high
visibility
events,
targeting
"
sectors
of
opportunity"
at
the
state­
level,
and
designing
outreach
and
marketing
materials
that
can
be
customized
by
states
to
meet
their
needs.

The
attached
report
contains
additional
specific
actions
that
ECOS
recommends
for
making
performancebased
environmental
programs
more
effective.
ECOS
is
firmly
committed
to
working
with
EPA
to
implement
these
recommendations;
members
of
our
Cross­
Media,
Compliance
and
Planning
Committees
stand
ready
to
participate
in
these
activities
and
help
advance
the
success
of
these
important
programs.
As
proposed
in
this
report,
a
joint
EPA­
ECOS
working
group,
with
additional
participation
from
NPPR,
MSWG
and
members
of
performance­
based
programs,
could
serve
as
an
effective
mechanism
for
making
rapid
progress
on
many
of
the
specific
recommendations
in
2005.
1­
13­
05
4
I.
Introduction
At
the
request
of
U.
S.
Environmental
Protection
Agency
(
EPA)
Administrator
Leavitt,
the
Environmental
Council
of
the
States
(
ECOS)
has
prepared
this
report
to
recommend
actions
states
believe
EPA
should
take
to
improve
the
effectiveness
of
performance­
based
environmental
leadership
programs.
This
request
emerged
from
a
breakfast
discussion
on
performance­
based
programs
between
Administrator
Leavitt
and
ECOS
representatives
on
October
4,
2004
in
Oklahoma
City,
Oklahoma.
1
These
recommendations
are
based
on
interviews
with
commissioners
and
senior
management
from
40
state
environmental
protection
agencies.

What
are
performance­
based
environmental
leadership
programs?

Performance­
based
environmental
leadership
programs,
such
as
EPA's
National
Environmental
Performance
Track
(
http://
www.
epa.
gov/
performancetrack/),
are
voluntary
partnership
programs
that
recognize
and
reward
private
and
public
facilities
that
demonstrate
strong
environmental
performance
beyond
current
requirements.
The
fundamental
goal
of
Performance
Track
and
other
state
innovations
programs
is
to
achieve
better
environmental
results.
As
such,
these
programs
tend
to
focus
on
environmental
outcomes
(
reduced
emissions
or
higher
compliance
rates)
rather
than
operationally­
based
output
measures
(
number
of
inspections
or
permits).
These
programs
often
provide
regulatory
flexibility,
creating
opportunities
for
high
performers
to
go
beyond
the
compliance
measures
that
are
typically
established
by
regulations.
They
also
provide
opportunities
for
state
and
federal
government,
as
well
as
the
regulated
community,
to
target
financial
and
human
resources
more
strategically
to
produce
better
overall
environmental
results.

Interest
in
performance­
based
environmental
leadership
programs
has
risen
over
the
past
decade:
more
than
20
states
have
active
state­
level
performance­
based
programs,
and
an
additional
five
states
are
currently
developing
programs.
Based
on
our
interviews
with
state
commissioners
and
senior
managers,
18
states
rank
performance­
based
leadership
programs
among
their
10
top
priorities
(
eleven
of
these
rank
them
among
their
top
five
priorities),
and
nearly
half
of
the
states
interviewed
for
this
effort
(
19
states)
report
actively
promoting
Performance
Track.
In
addition,
nine
states
have
signed
Memoranda
of
Agreement
(
MOAs)
with
EPA
to
enhance
coordination
and
alignment
of
their
efforts
with
EPA's
Performance
Track
program.
These
MOAs
focus
on
joint
outreach,
application
process
alignment,
reciprocity,
and
coordinated
incentive
development.

Why
is
this
report
needed?

Despite
the
interest
and
initial
success
of
performance­
based
environmental
leadership
programs,
EPA
and
states
face
substantial
challenges
in
ensuring
that
these
programs
continue
to
grow
and
ultimately
meet
their
full
potential
by
becoming
core
elements
of
our
nation's
environmental
management
system.
There
is
a
need
to
reduce
transaction
costs2,
both
for
agencies
in
developing
and
implementing
these
programs,
and
for
facilities
that
choose
to
participate
in
them.
EPA
and
states
also
need
to
provide
better
incentives
faster
to
attract
and
retain
program
participants.
In
addition,
greater
flexibility
is
needed
to
allow
states
to
utilize
performance­
based
programs
to
achieve
state­
specific
environmental
goals
and
address
environmental
problems.

1
Representatives
from
the
following
states
participated
in
the
October
4,
2004
discussion
with
EPA
Administrator
Leavitt:
California,
Colorado,
Delaware,
Iowa,
Maine,
Massachusetts,
Minnesota,
North
Carolina,
Pennsylvania,
South
Carolina,
Tennessee,
Texas,
Utah,
and
Virginia.
2
In
this
report
the
term
transaction
cost
is
used
to
refer
to
the
protracted
time
it
takes
to
achieve
a
proposed
result
and
the
organizational
resistance
to
change
at
multiple
levels
which
requires
continued
and
persistent
advocacy
for
an
uncertain
outcome.
1­
13­
05
5
This
report
is
intended
to
identify
specific
actions
to
effectively
address
these
and
other
challenges
in
promoting
and
improving
beyond­
compliance
performance
through
performance­
based
environmental
leadership
programs.
In
order
to
be
successful,
the
states
must
join
EPA
in
taking
these
important
steps.
Our
hope
is
that
this
report
serves
as
a
blueprint
for
future
collaboration
between
EPA
and
states
that
builds
on
the
strong
level
of
interest
in
performance­
based
programs
at
EPA
and
among
states.
Given
the
high
level
of
interest
in
these
programs
that
we
found
through
interviewing
state
commissioners
and
senior
managers,
we
are
confident
that
the
states
will
be
effective
partners
for
EPA
in
this
important
work.

The
ECOS
states
applaud
Administrator
Leavitt,
Steve
Johnson,
and
the
key
leaders
at
the
Environmental
Protection
Agency
for
their
leadership
and
vision
to
advance
Performance
Track
and
state
performancebased
programs.
These
programs
will
require
commitment
and
careful
direction
to
succeed.
With
the
priority
and
support
currently
coming
from
the
administrator
and
his
staff,
these
programs
have
the
potential
to
move
the
country
significantly
forward
in
meeting
and
exceeding
its
environmental
goals.
We
would
like
to
affirm
ECOS'
strong
support
for
EPA's
Performance
Track
program
and
for
state­
level
performance­
based
environmental
leadership
programs,
as
well
as
our
interest
in
working
with
EPA
to
follow­
up
on
the
recommended
actions
presented
in
this
report.

The
EPA­
ECOS
working
relationship
has
continually
strengthened
in
recent
years.
The
National
Center
for
Environmental
Innovation
(
NCEI)
has
worked
closely
with
the
Cross­
Media
Committee
to
develop
a
joint
workplan
and
the
chairs
of
the
committee
have
been
invited
to
sit
as
participating
members
of
the
Innovation
Action
Council
(
IAC).
In
addition,
EPA
has
invited
the
ECOS
Planning
and
Alignment
Committee
to
work
with
it
in
developing
agency
strategic
plans
with
state
input
and
establishing
joint
performance
measures.
This
is
resulting
in
better
communication,
better
goals,
and
a
common
direction
for
environmental
protection.
These
committees
are
committed
to
continuing
this
relationship
and
welcome
the
opportunity
to
participate
in
building
strong
and
effective
innovations
programs,
such
as
Performance
Track
and
state
performance­
based
programs,
which
focus
on
achieving
greater
environmental
results.

What
is
our
vision
for
performance­
based
programs?

ECOS
believes
that
effective
performance­
based
programs
can
become
an
essential
component
of
the
environmental
protection
system
in
the
U.
S.
Our
vision
for
the
future
of
these
programs
consists
of
the
following
four
elements
that
we
view
as
fundamental
to
their
success:

 
These
programs
are
no
longer
"
innovative,"
but
are
counted
among
the
core
agency
programs
with
measurable
outcomes;
 
Transaction
costs
of
developing,
implementing
and
participating
in
performance­
based
programs
are
low;
 
States
and
EPA
jointly
implement
sufficient
incentives
to
inspire
facilities
to
participate
and
to
achieve
meaningful
beyond­
compliance
performance;
and
 
States
are
allowed
and
encouraged
to
utilize
performance­
based
programs
to
work
with
regulated
entities
to
develop
creative
and
effective
solutions
that
address
state
environmental
priorities.

What
was
the
process
for
preparing
this
report?

The
ECOS
Cross­
Media
Committee
co­
chairs
convened
a
subgroup
of
interested
state
agency
representatives
to
prepare
this
report
in
response
to
a
request
from
Administrator
Leavitt
for
a
list
of
recommended
actions
to
improve
the
effectiveness
of
performance­
based
environmental
leadership
programs.
We
were
able
to
hold
informal
interviews
with
environmental
commissioners
and
senior
managers
from
40
states.
Based
on
the
information
from
these
interviews,
which
is
summarized
in
Attachment
A,
we
developed
the
recommendations
outlined
in
this
report.
In
addition,
we
met
with
representatives
of
the
Performance
Track
Participants
Association
(
PTPA)
to
obtain
additional
insights
1­
13­
05
6
from
the
perspective
of
program
participants.
These
recommendations
have
been
shared
with
state
commissioners
of
all
50
states
and
received
broad­
based
support.
The
Executive
Officers
of
ECOS
support
this
report
and
the
chairs
of
the
Cross­
Media,
Planning
and
Compliance
Committees
stand
ready
to
work
closely
with
EPA
to
implement
these
recommendations.
1­
13­
05
7
II.
Recommendations
to
EPA
ECOS
believes
that
performance­
based
programs,
such
as
EPA's
Performance
Track
Program
and
similar
state
programs,
have
the
potential
to
play
an
increasingly
important
role
in
our
nation's
environmental
protection
system.
Performance­
based
programs
can:

 
Encourage
and
reward
strong
and
sustained
environmental
performance
improvement
among
the
regulated
community
that
goes
beyond
compliance
and
addresses
unregulated
environmental
issues;
 
Foster
greater
collaboration
between
environmental
regulatory
agencies
and
high­
performing
companies
and
government
facilities
to
achieve
state
and
regional
environmental
goals
and
address
environmental
priorities;
 
Support
the
development
of
cost­
effective
approaches
to
achieving
environmental
goals
that
focus
on
performance
results;
and
 
Free
some
agency
compliance
assurance
resources
to
address
higher
environmental
priorities.

To
accomplish
these
goals,
ECOS
recommends
that
EPA
pursue
specific
actions
in
four
main
areas,
as
outlined
below.
The
ECOS
Cross­
Media,
Compliance
and
Planning
Committees
stand
ready
to
work
with
EPA
to
implement
these
recommendations
and
to
help
realize
the
full
potential
of
performancebased
environmental
programs.

1.
Support
State
Programs
and
State
Efforts
to
Work
with
Performance
Track
High
transaction
costs
between
EPA
and
states
combined
with
limited
support
from
EPA
program
offices
hinder
state
efforts
to
develop
and
implement
performance­
based
environmental
leadership
programs,
including
efforts
to
work
with
the
Performance
Track
program.
Efforts
are
needed
to
align
the
EPA­
state
relationship
to
recognize
and
support
performance­
based
programs
and
to
reduce
transaction
costs
associated
with
program
implementation.
ECOS
recommends
that
EPA
pursue
the
following
specific
actions:

a.
Allow
states
to
receive
credit
for
outcomes
from
performance­
based
and
innovative
work
and
clarify
acceptable
approaches
with
documented
guidance
to
EPA
staff.
The
current
focus
on
"
beancounting
provides
strong
disincentives
for
states
and
EPA
to
engage
in
performance­
based
and
other
innovative
work
that
can
produce
better
environmental
results.
Common
themes
from
the
interviews
with
ECOS
and
PTPA
representatives
indicate
that
it
is
essential
for
EPA
to
more
firmly
demonstrate
that
it
values
these
efforts.
For
example,
EPA
could
allow
pollution
prevention
(
P2),
environmental
management
system
(
EMS),
compliance
assistance
and
other
leadership
program
audits
to
count
towards
inspection
quotas,
or
begin
to
evaluate
performance­
based
programs
based
on
outcomes
and
not
outputs.
We
recommend
that
EPA
develop
guidance
documents
for
Headquarters
and
Regional
program
staff
in
2005,
with
consultation
from
ECOS,
that
encourage
and
accept
these
and
other
state
measures
of
innovative
work
in
lieu
of
traditional
"
bean­
counting"
measures.

b.
Work
with
volunteer
states
to
develop
agreements
regarding
goals,
priorities
and
measurement
of
performance­
based
programs
through
revised
Performance
Partnership
Agreements
(
PPAs)
or
other
state
planning
agreements
by
September
2005.
States
and
EPA
should
use
existing
tools
or
develop
new
ones
for
coordinating
EPA
and
state
environmental
protection
activities.
They
should
serve
to
identify
key
common
priorities
and
to
set
goals
for
specific
activities.
It
is
critical
to
make
Performance
Track
and
state
performance­
based
programs
explicit
priorities
in
these
agreements,
and
to
allow
states
to
receive
credit
for
performance­
based
programs
and
related
innovations
activities.
This
can
be
accomplished
through
including
these
activities
in
special
collaboration
categories
or
by
incorporating
them
as
tools
within
other
core
programs.
As
state
programs
are
developed
and
1­
13­
05
8
enhanced,
EPA
needs
to
support
them
by
allowing
a
reduction
in
other
work
or
a
disinvestment
in
some
of
the
traditional
tools
and
approaches.

We
recommend
that
EPA
solicit
volunteer
states
(
across
at
least
two
EPA
regions)
to
develop
revised
state
planning
agreements
with
regional
offices
by
September
2005.
The
goal
of
this
effort
would
be
to
develop
standard
language
for
use
by
other
regions
in
support
of
Performance
Track
and
other
innovative
programs.
Specifically,
this
language
should
allow
states
to
receive
credit
for
performance­
based
and
innovative
work.
This
effort
should
be
accompanied
by
aggressive
outreach
to
staff
responsible
for
these
agreements
in
state
agencies
and
EPA
regional
offices.

c.
Establish
a
joint
EPA­
ECOS
working
group
to
reassess
effectiveness
of
existing
EPA­
state
coordination
mechanisms
by
September
2005.
ECOS
commends
EPA
for
developing
a
variety
of
mechanisms
to
encourage
coordination
with
states
in
developing
and
implementing
performancebased
programs
 
for
example,
EPA
has
signed
formal
MOAs
with
nine
states,
sponsors
monthly
conference
calls
with
state
agency
staff
working
on
performance­
based
programs,
convenes
an
annual
state
and
regional
conference
to
promote
performance­
based
programs,
and
has
initiated
the
State
Innovation
Grants
Program.
ECOS
recommends
that
EPA
and
states
evaluate
whether
these
and
other
mechanisms
are
providing
sufficient
opportunities
for
EPA­
state
communication
and
coordination,
and
consider
whether
there
are
additional
ways
to
increase
alignment
of
our
efforts
and
reduce
transaction
costs.
This
reassessment
could
be
conducted
in
conjunction
with
other
joint
EPAECOS
working
group
efforts
proposed
in
this
report.

d.
Identify
opportunities
for
improving
alignment
and
coordination
of
Performance
Track
with
state
and
sector
priorities
in
2005.
EPA
has
recognized
the
varying
priorities
across
regions
by
giving
two­
forone
credit
to
companies
for
Performance
Track
challenge
commitments
that
address
key
regional
environmental
issues.
We
recommend
that
EPA
extend
this
approach
to
commitments
that
address
either
state
environmental
priorities
or
key
challenges
for
specific
sectors.
Specific
opportunities
for
improving
alignment
and
coordination
of
performance­
based
programs
with
state
and
sector
priorities
should
be
developed
in
conjunction
with
other
joint
EPA­
ECOS
working
group
efforts
proposed
in
this
report.
Allowing
greater
flexibility
for
states
to
develop
a
performance­
based
approach
to
address
these
priorities
or
challenges
could
provide
an
effective
alternative
to
pursuing
a
traditional
regulatory
approach
of
command
and
control
and
permitting.
This
approach
could
be
highly
effective
at
engaging
new
sectors,
such
as
the
agriculture
sector,
in
performance­
based
programs.

In
addition,
states
need
greater
flexibility
to
tailor
performance­
based
efforts
to
match
the
profile
of
industries
that
they
regulate.
We
recommend
that
the
joint
EPA­
ECOS
working
group
examine
opportunities
for
supporting
efforts
to
tailor
performance­
based
programs
to
target
specific
sectorbased
opportunities
and
state
environmental
priorities.
For
example,
states
should
have
a
clear
path
to
develop
performance­
based
approaches
to
address
existing
or
emerging
sector­
specific
problems.
In
such
a
setting,
a
state
and
EPA
could
work
together
with
specific
sectors
to
identify
performance
commitments
and
develop
incentive
packages.
This
process
could
lead
to
performance­
based
agreements
that
are
highly
relevant,
addressing
state
environmental
priorities
in
a
manner
that
builds
business
value
for
participating
companies
within
a
sector.
For
example,
Wisconsin's
Green
Tier
Program
contains
provisions
for
sector­
focused
"
charters,"
similar
to
those
used
in
the
Netherlands
and
Bavaria,
Germany.
This
sector­
focused
environmental
covenant
approach
to
encouraging
and
responding
to
high
performance
provides
an
intriguing
model
for
targeting
performance­
based
programs
on
regional
or
state
environmental
priority
areas.

Other
examples
of
this
approach
include
an
innovative,
performance­
based
partnership
with
the
auto
salvage
industry
and
the
dental
industry
to
promote
mercury
reduction
and
achieve
other
goals;
an
agreement
with
confined
animal
feeding
operations
(
CAFOs)
or
the
agricultural
community
to
achieve
state
goals;
and
an
innovative
stormwater
excellence
program
to
achieve
greater
compliance
rates
within
the
construction
industry.
In
each
of
these
examples,
regulatory
agencies
work
with
1­
13­
05
9
specific
sectors
or
groups
of
companies
to
secure
commitments
for
targeted
performance
improvements
that
address
a
state
or
regional
environmental
priority,
and
to
develop
incentives
that
encourage
these
commitments.
The
joint
EPA­
ECOS
working
group
should
examine
ways
to
support,
enhance,
and
streamline
this
process
for
targeting
performance­
based
programs
to
address
regional
and
state
priorities
and
sector­
based
environmental
improvement
opportunities.

e.
Establish
a
joint
EPA­
state
working
group
to
develop
sub­
categories
of
the
Performance
Track
Program
that
are
tailored
to
be
less­
burdensome
for
certain
segments
of
the
business
community.
Performance
Track,
in
its
current
design,
has
transaction
costs
associated
with
entry,
reporting,
and
renewal
that
are
too
high
to
be
attractive
to
certain
segments
of
the
business
community,
such
as
many
small
businesses,
local
governments,
and
the
agriculture
sector.
States
believe
that
opportunities
exist
to
tailor
performance­
based
programs
to
be
relevant
and
attractive
to
companies
within
these
business
segments.
ECOS
recommends
that
EPA
establish
a
working
group
through
which
EPA
and
interested
states
can
collaborate
to
develop
a
component
of
the
Performance
Track
program
that
is
more
relevant
to
small
businesses,
local
governments,
the
agriculture
sector,
and
other
sectors
where
the
current
program
model
is
less
viable.

f.
Direct
management
to
include
support
 
both
financial
and
in­
kind
 
for
performance­
based
programs
as
a
component
of
the
FY
06
budget
development
process
to
enhance
program
management,
outreach,
recruitment,
and
incentives
implementation.
Increases
in
EPA
financial
and
in­
kind
support
for
implementation
of
performance­
based
environmental
leadership
programs
to
EPA
regions
and
states
would
send
a
strong
signal
that
EPA
is
committed
to
transforming
Performance
Track
into
a
core
agency
program.
Budget
pressures
in
many
states
and
EPA
regions
are
preventing
states
from
securing
sustained
resources
to
invest
in
the
development
of
performance­
based
programs.
Financial
resources
could
be
used
to
offset
state
costs
for
initial
program
implementation,
to
enable
more
state
staff
to
participate
in
performance­
based
program
implementation
activities,
or
to
support
new
incentives
such
as
off­
setting
revenue
shortfalls
from
the
provision
of
reduced
permitting
fees
to
Performance
Track
participants.
EPA
should
provide
staff
expertise
at
the
regional
level
to
assist
states
in
developing
and
implementing
performance­
based
leadership
programs.

EPA
should
also
provide
the
flexibility
for
states
to
use
current
funding
to
support
innovation,
education
and
outreach
activities.
If
EPA
allows
for
alternative
measures
and
outcomes,
as
discussed
above,
states
can
use
existing
resources
to
develop,
implement
and
promote
incentives
and
performance­
based
programs.

2.
Assure
Support
from
All
EPA
Program
Offices
EPA's
and
states'
efforts
in
developing
and
implementing
performance­
based
programs
have
been
hindered
by
a
lack
of
coordinated
support
from
EPA's
core
program
offices.
Core
program
staff
often
rely
on
the
historical
regulatory
command­
and­
control
approach
to
environmental
regulations
upon
which
their
programs
were
built.
There
is
also
no
structure
in
place
at
EPA
that
rewards
program
staff
for
innovative
approaches
to
environmental
problems.
Consequently,
while
there
is
often
support
for
innovation
at
some
management
levels,
staff
support
is
frequently
lacking.
Efforts
are
needed
to
overcome
several
structural
barriers
that
inhibit
innovation
and
performance­
based
program
implementation,
such
as:

 
Lack
of
familiarity
with
performance­
based
programs
and
innovations,
and
poor
understanding
of
how
these
can
relate
to
core
program
functions,
goals,
and
performance
measures;
 
Risk
aversion
due
to
lack
of
perceived
reward
for
making
changes;
 
Cultural
resistance
to
change
(
reliance
on
existing
regulatory
approaches);
and
 
Large
numbers
of
approvals
required
to
make
changes
or
implement
innovative
approaches
(
transaction
costs).
1­
13­
05
10
EPA
should
take
action
to
build
understanding
and
commitment
from
Headquarters
and
Regional
staff
in
these
offices
so
they
can
support
the
important
role
of
performance­
based
programs
in
achieving
better
environmental
results.
We
recommend
that
EPA
take
the
following
specific
actions
to
increase
internal
support
for
performance­
based
programs:

a.
Work
with
national
and
regional
EPA
program
managers
and
ECOS
to
integrate
Performance
Track
activities
into
next
year's
strategic
plans
and
performance
measures
for
each
program
office.
ECOS
believes
this
is
necessary
to
ensure
that
other
core
program
staffs
at
EPA
HQ
and
Regional
Offices
are
familiar
with,
responsible
for,
and
actively
support
federal
and
state
performance­
based
programs.
States
frequently
encounter
EPA
staff
in
core
program
offices
at
HQ
and
regions
who
are
unfamiliar
with
or
do
not
support
Performance
Track.
This
represents
a
major
impediment
to
our
ability
to
assist
with
the
implementation
of
Performance
Track
incentives
and
other
aspects
of
the
program.
Increased
awareness
of
this
program
and
the
strong
support
that
it
has
from
senior
EPA
management
is
essential
to
its
continued
growth.
We
recommend
that
EPA
work
to
garner
the
support
of
its
national
program
managers
and
to
clearly
communicate
this
support
to
staff
at
all
levels.
We
also
recommend
that
EPA
leadership
work
actively
with
these
national
program
managers
to
address
the
structural
barriers
mentioned
above.
One
way
to
encourage
this
greater
awareness
would
be
to
"
push
Performance
Track
down
through
the
ranks"
by
involving
program
staff
at
EPA
Headquarters
and
Regional
offices
more
actively
in
Performance
Track
program
implementation,
including
incentives
delivery
and
related
pilot
projects.
Performance
Track
and
state
performance­
based
programs
have
the
potential
to
help
each
program
office
meet
its
goals
more
effectively
and
each
office
should
be
involved
in
developing
a
program
that
works
for
them.

We
also
see
the
critical
need
to
implement
effectively
the
IAC
"
issue
resolution
process"
to
quickly
identify
and
address
situations
where
development
and
implementation
of
performance­
based
programs
becomes
mired
in
administrative
process;
this
is
particularly
relevant
to
developing
and
implementing
incentives.
In
the
current
state,
incentive
development
can
be
delayed
indefinitely
by
a
single
EPA
office
representative.
One
approach
could
be
to
have
a
mechanism
for
prompt
elevation
of
incentive
ideas
to
senior
agency
management
to
expedite
review
and
approval.
Another
approach
could
be
to
have
designated
"
innovations
advocates"
within
OECA,
OGC
and
program
offices,
or
within
NCEI,
who
have
authority
to
challenge
decisions
unfavorable
to
innovations
and
to
help
expedite
incentive
development.

b.
Improve
coordination
and
alignment
of
Performance
Track
with
other
EPA
voluntary
programs.
We
believe
that
there
are
opportunities
to
leverage
the
full
suite
of
EPA
voluntary
programs
to
better
identify
and
add
value
to
performance­
base
program
implementation.
In
many
cases,
voluntary
programs
such
as
EPA's
Green
Suppliers
Network,
Sector
Strategies
Program,
Resource
Conservation
Challenge,
and
Pollution
Prevention
Assistance
programs
work
directly
with
companies
and
federal
facilities
that
are
participating
in
or
are
good
candidates
for
Performance
Track.
ECOS
recommends
that
EPA
establish
a
framework
for
improving
coordination
between
these
and
other
EPA
voluntary
programs
and
for
identifying
and
pursuing
potential
synergies.

3.
Provide
Better
Incentives
to
Participants
Faster
It
is
critical
to
deliver
better
incentives
faster
to
attract
and
retain
program
participants.
Incentives
must
deliver
significant
business
value
to
potential
program
participants
 
in
the
form
of
enhanced
external
reputation,
operational
cost
reductions,
or
improved
capital
productivity.
It
is
important
to
note
that
the
longer­
term
success
and
attractiveness
of
performance­
based
programs
is
tied
to
the
ability
to
deliver
incentives
that
can
optimize
companies'
capital
investment
strategies.
Most
current
incentives
focus
on
operational
efficiency
and
flexibility,
such
as
reducing
inspections
or
reporting
obligations.
Providing
incentives
that
alter
the
timing
or
focus
of
capital
investment
could
make
performance­
based
programs
1­
13­
05
11
significantly
more
attractive.
For
example,
sector­
focused
incentives
could
enable
qualifying
participants
to
delay
investment
in
certain
pollution
control
equipment
in
exchange
for
making
other
investments
that,
in
aggregate,
bring
greater
environmental
improvement
faster.
Similarly,
incentives
could
increase
participants'
flexibility
in
controlling
pollution
through
more
cost­
effective
means.
Efforts
in
these
areas
will
broaden
the
attractiveness
of
participation
beyond
a
small
segment
of
industry
leaders.

ECOS
recommends
that
EPA
pursue
the
following
specific
actions
to
support
the
provision
of
better
incentives
faster:

a.
Develop
and
implement
a
revitalized
system
in
2005
for
identifying,
developing,
and
implementing
incentives
for
Performance
Track
and
state
programs.
While
important
progress
has
been
made
in
expanding
federal
and
state
program
incentives,
ECOS
believes
the
incentives
development
system
needs
substantial
improvement.
It
is
critical
to
develop
incentives
that
have
greater
value
to
participants,
and
to
align
federal
and
state
incentives
to
achieve
maximum
impacts.

Incentive
development
should
be
more
demand­
driven,
drawing
more
actively
on
perspectives
and
ideas
from
current
and
potential
program
participants.
For
example,
EPA
and
states
could
more
actively
engage
the
members
of
their
performance­
based
programs,
trade
associations,
and
other
participating
organizations.
A
demand­
driven
approach
could
also
help
prioritize
incentive
ideas
based
on
their
attractiveness
to
program
participants,
and
build
consensus
around
which
incentives
to
pursue.

The
incentive
development
system
should
also
include
a
process
to
more
systematically
identify
and
evaluate
incentives
that
would
be
attractive
to
specific
economic
or
industrial
sectors.
For
example,
several
states
cited
the
need
to
develop
incentives
that
are
relevant
and
attractive
to
specific
sectors
such
as
agriculture,
CAFOs,
and
pulp
and
paper.
EPA
could
support
a
collaborative
process
to
work
with
specific
sector
and
state
representatives
to
develop
sector­
focused
incentive
packages.
We
see
two
major
advantages
to
developing
sector­
focused
incentive
packages:
(
1)
they
enhance
recruitment
efforts
within
a
sector,
and
(
2)
they
help
EPA
and
the
states
use
performance­
based
programs
to
target
specific
environmental
impacts
that
may
be
associated
with
sector
operations.
Opportunities
also
exist
for
more
active
coordination
and
cooperation
between
Performance
Track
and
other
EPA
programs
that
have
sector­
focused
orientations,
such
as
the
Sector
Strategies
Program,
the
Green
Suppliers
Network,
and
the
Resource
Conservation
Challenge.

Finally,
efforts
are
needed
to
better
align
and
coordinate
incentive
identification,
development,
and
implementation
between
EPA
and
states.
In
many
cases,
states
are
the
direct
service
providers,
interacting
with
companies
and
federal
facilities
to
conduct
inspections,
issue
permits,
and
provide
technical
assistance.
Improved
alignment
and
coordination
among
EPA
and
interested
states
can
help
ensure
that
incentives
are
implemented
in
the
desired
way,
and
that
respective
federal
and
state
roles
complement
each
other
in
delivering
incentives.
Improved
alignment
and
coordination
can
also
help
to
identify
and
remove
potential
state
regulatory
or
other
barriers
that
could
inhibit
the
effectiveness
of
a
particular
incentive.
MOAs
provide
a
useful
framework
for
the
necessary
effort
to
align
and
coordinate
EPA
and
state
incentives
activities.

b.
Evaluate
several
specific
ideas
for
incentives
in
2005
that
may
be
of
significant
value
to
current
and
potential
program
participants.
ECOS
has
identified
several
specific
incentive
ideas
that
could
provide
significant
value
to
some
current
and
potential
future
performance­
based
program
participants.
In
addition,
during
our
discussions
with
PTPA
representatives
they
identified
three
priority
areas
for
incentives
implementation:
priority
permitting/
streamlined
permitting,
reduced
inspection
frequency,
and
support
for
innovation
alternatives.
In
light
of
input
from
ECOS
and
PTPA
representatives,
we
recommend
that
EPA
evaluate
the
following
ideas
in
2005
as
part
of
the
revitalized
incentive
development
process:
1­
13­
05
12
 
Expand
permitting
incentives
that
reduce
time,
uncertainty,
and
administrative
burden,
such
as
expedited
permitting,
expanded
use
of
permitting
techniques
that
afford
operational
flexibility,
streamlined
monitoring,
recordkeeping
and
reporting
provisions;
 
Expand
incentives
that
reduce
inspections
of
participating
facilities
through
the
use
of
riskbased
targeting
of
inspections;
 
Enable
the
development
of
source
and
sector­
specific
innovation
alternatives
to
conventional
environmental
requirements;
 
Provide
direct
financial
incentives
such
as
access
to
government
environmental
research
grant
money
and
reduced
or
waived
permitting
fees;
 
Establish
financial
and
competitiveness
incentives
through
preferences
for
program
participants
in
federal
and
state
contracting
and
procurement;
and
 
Promote
the
Performance
Track
program
and
members
in
the
financial
services
sector,
exploring
options
to
better
position
participants
with
regard
to
company
valuation
and
investment,
lending,
and
insurance.

ECOS
is
also
aware
that
several
lists
of
potential
incentives
have
been
developed
in
recent
years
by
various
parties.
These
lists
should
be
considered
in
the
revitalized
incentive
development
process
recommended
above.
As
mentioned
elsewhere
in
this
report,
the
incentive
development
process
will
need
to
accommodate
efforts
to
identify
and
develop
incentives
that
are
specifically
targeted
at
particular
sectors
or
groups,
including
small
businesses,
local
governments,
and
the
agriculture
sector.

c.
Work
with
ECOS
in
2005
to
evaluate
potential
regulatory
and
statutory
options
for
improving
and
streamlining
the
incentive
implementation
process.
The
ability
to
drive
significant
environmental
improvement
through
performance­
based
programs
could
be
significantly
enhanced
through
a
federal
statutory
change
or
cross
media
regulation
that:
(
1)
recognizes
performance­
based
programs
as
an
important
tool
in
the
nation's
environmental
management
system,
and
(
2)
addresses
directly
the
challenge
of
establishing
procedural
and
technology­
based
standards
"
equivalency"
between
conventional
regulatory
approaches
and
alternative
improvement
approaches
developed
through
performance­
based
programs.
Without
doing
away
with
the
intent
or
general
state
of
progress
that
the
national
air,
water,
and
waste
statutes
have
produced,
such
a
statute
or
regulation
could
delegate
to
states
the
authority
to
approximate
"
equivalency,"
on
at
least
an
experimental
basis.

We
recommend
that
EPA
work
with
interested
states
in
2005
to
evaluate
the
potential
scope
for
and
desirability
of
pursuing
regulatory
or
statutory
options
for
supporting
performance­
based
programs.
A
regulatory
option
would
likely
require
careful
analysis
of
existing
enabling
acts
to
develop
a
cross
media
performance­
based
regulatory
program
for
Performance
Track
and
state
leadership
program
participants.
Several
states,
including
Texas
and
Virginia,
have
enacted
or
are
pursuing
legislative
options
to
explicitly
recognize
the
importance
of
providing
performance­
based
incentives.
These
new
state
laws
generally
allow
for
variances
to
existing
state
regulations
to
support
innovation
and
performance­
based
incentive
provision.
Federal
regulation
or
legislation
could
be
highly
useful
to
complement
and
support
these
state
efforts.
These
state
legislative
approaches
could
also
provide
models
for
federal
legislation.

4.
Conduct
More
Aggressive
Marketing
and
Education
of
the
Programs
More
aggressive
marketing,
outreach
and
education
are
needed
to
increase
awareness
of
Performance
Track
and
state
performance­
based
programs
and
to
recruit
new
participants.
The
medium
and
long­
term
viability
of
performance­
based
environmental
programs
hinges
on
their
ability
to
attract
and
retain
new
participants.
Failure
to
increase
program
participation
will
erode
states'
willingness
to
invest
in
and
support
these
programs.
We
believe
that
EPA
can
play
an
important
leadership
role
in
the
promotion
and
outreach
around
Performance
Track
and
state
performance­
based
programs.
ECOS
recommends
that
1­
13­
05
13
EPA
pursue
the
following
specific
actions
to
recruit
more
program
participants
faster
and
to
increase
the
national
visibility
of
Performance
Track:

a.
Establish
a
joint
EPA­
ECOS
working
group
to
develop
a
long­
term
strategy
for
"
branding"
the
Performance
Track
program
and
state
programs.
This
"
branding"
strategy
development
should
be
conducted
in
conjunction
with
other
joint
EPA­
ECOS
working
group
efforts
for
2005
proposed
in
this
report.
Developing
an
identifiable
"
brand"
for
the
Performance
Track
program
is
critical
to
supporting
the
recognition
benefit
to
members,
as
well
as
to
attracting
new
participants.
The
development
of
a
long­
term
"
branding"
strategy
would
focus
limited
outreach
and
marketing
resources
to
maximize
awareness
of
the
program
among
key
constituencies.
For
example,
"
Energy
Star"
stickers
on
appliances
are
well­
recognized.
Targeted
branding
strategies
can
reach
potential
corporate
and
federal
facility
program
participants,
trade
associations,
professional
organizations,
financial
markets,
the
public,
and
other
groups
that
can
contribute
to
the
program's
success.

b.
Meet
with
interested
states
in
2005
to
develop
an
action
plan
for
conducting
aggressive
outreach
and
participant
recruitment.
There
is
much
that
EPA
and
states
can
do
to
improve
the
effectiveness
and
impact
of
Performance
Track
outreach
and
recruitment
efforts.
EPA
should
work
more
aggressively
with
interested
states
to
coordinate
outreach
and
to
promote
Performance
Track
and
affiliated
state
programs.
ECOS
recommends
several
specific
actions:

 
Senior
EPA
leadership
should
reach
out
to
state
Governors
to
promote
Performance
Track
and
state
programs,
and
to
enlist
Governors'
support
in
marketing
these
programs
at
high
visibility
events;
 
States
should
identify
"
sectors
of
opportunity"
within
their
state,
where
it
would
be
desirable
to
increase
participation
in
Performance
Track
so
that
joint
state­
EPA
outreach
can
target
those
priority
sectors;
 
EPA
and
interested
states
should
meet
in
2005
to
develop
coordinated
action
plans
for
outreach
and
program
recruitment;
and
 
EPA
and
state
agency
leadership
should
step
up
efforts
to
jointly
participate
in
and
conduct
conferences
and
events
to
raise
the
profile
of
Performance
Track
and
state
performance­
based
programs.

EPA
can
play
an
important
role
in
developing
marketing
and
outreach
materials
that
can
promote
both
Performance
Track
and
state
performance­
based
leadership
programs.
We
recommend
that
EPA
consider
the
following
ideas
for
marketing
and
outreach
materials:

 
Develop
a
brochure
on
Performance
Track
and
affiliated
state
performance­
based
programs
that
states
can
customize
and
include
in
their
outreach
efforts;
 
Further
document
and
more
widely
disseminate
information
on
participants'
cost
savings
and
other
program
results;
and
 
Document
the
business
case
for
company
involvement
in
performance­
based
leadership
programs,
highlighting
financial
benefits
associated
with
risk
reduction
and
competitive
advantage.
1­
13­
05
14
Attachment
A
Summary
of
Interviews:
State
Environmental
Commissioners
and
Senior
Managers
1­
13­
05
15
Exhibit
A­
1
STATE­
SPECIFIC
INFORMATION
State
Response
MOA
Promote
Performance
Track
Performance­
based
Environmental
Leadership
Program1
Priority
level
2
Alabama
Yes
No
Yes
No
Middle
Alaska
Yes
No
No
No
Not
a
priority
Arizona
Yes
No
Unclear
Active
High
Arkansas
No
No
­­
No
­­
California
No
No
­­
No
­­
Colorado
Yes
Yes
Yes
Active
Middle
Connecticut
Yes
No
No
No
Not
a
priority
Delaware
Yes
No
Yes
Active
Low
Florida
Yes
No
No
No
Rank
not
specified
Georgia
Yes
Yes
Yes
Active
High
Hawaii
Yes
No
No
No
Not
a
priority
Idaho
Yes
No
Yes
Active
Middle
Illinois
Yes
No
No
Active3
Low
Indiana
No
No
­­
Active
­­
Iowa
No
No
­­
No
­­
Kansas
No
No
­­
No
­­
Kentucky
Yes
No
No
Under
development
High
Louisiana
Yes
No
No
Active
Mixed
Maine
Yes
Yes
Yes
Active
Middle
Maryland
Yes
No
Unclear
No
Mixed
Massachusetts
Yes
Yes
Yes
Currently
inactive
Middle
Michigan
Yes
No
No
Active
High
Minnesota
Yes
No
Yes
No
Mixed
Mississippi
Yes
No
Yes
Under
development
Middle
Missouri
Yes
No
Yes
Active
Low
Montana
Yes
No
No
No
Low
Nebraska
Yes
No
No
No
Low
Nevada
Yes
No
No
Under
development
High
New
Hampshire
Yes
No
Yes
No
Low
New
Jersey
No
No
­­
No
­­
New
Mexico
Yes
No
No
Active
High
New
York
No
No
­­
Under
development
­­
North
Carolina
Yes
No4
No
Active
High
North
Dakota
No
No
­­
No
­­
Ohio
No
No
­­
No
­­
Oklahoma
Yes
No
Unclear
Active
Mixed
Oregon
Yes
No
No
Recently
deactivated
Mixed
Pennsylvania
Yes
No
Yes
No
Rank
not
specified
Rhode
Island
Yes
No
No
No
Low
South
Carolina
Yes
No
Yes
Active
Mixed
South
Dakota
Yes
No
No
No
Low
1­
13­
05
16
Exhibit
A­
1
STATE­
SPECIFIC
INFORMATION
State
Response
MOA
Promote
Performance
Track
Performance­
based
Environmental
Leadership
Program1
Priority
level
2
Tennessee
Yes
Yes
Yes
Active
High
Texas
Yes
Yes
Yes
Active
Mixed
Utah
Yes
Yes
Yes
Active
High
Vermont
Yes
No
No
Active
Not
a
priority
Virginia
Yes
Yes
Yes
Active
High
Washington
Yes
Yes
Yes
No
Rank
not
specified
West
Virginia
Yes
No
Yes
Under
development
Middle
Wisconsin
Yes
No
No
Active
High
Wyoming
No
No
­­
No
­­
TOTAL
40
9
19
1
Information
on
state
environmental
leadership
programs
is
provided
to
the
best
of
our
knowledge.
Sources
include
interviews,
state
websites,
and
previous
research
conducted
by
Industrial
Economics
and
Ross
&
Associates.
2
Interview
respondents
interpreted
the
question
regarding
the
priority
level
of
leadership
programs
in
several
different
ways.
Some
respondents
refer
to
the
priority
level
of
Performance
Track
only,
while
others
speak
to
both
state
and
federal
leadership
programs.
States
where
the
priority
level
varied
between
senior
management
and
program­
level
staff
are
marked
as
"
Mixed."
For
instance,
in
Minnesota,
leadership
programs
are
a
high
priority
to
the
administration
and
a
low
priority
within
core
program
offices.
States
that
ranked
leadership
programs
among
their
top
ten
and
top
five
priorities
are
marked
as
"
Middle"
and
"
High,"
respectively.
3
Active,
but
no
longer
accepting
applications.
4
North
Carolina
has
recently
introduced
a
new
"
Rising
Steward"
level
into
its
Environmental
Stewardship
Initiative,
which
is
similar
to
Performance
Track.
North
Carolina
indicated
that
it
plans
to
work
on
developing
an
MOA
over
the
next
six
months.
1­
13­
05
17
Exhibit
A­
2
SUMMARY
OF
STATE
PERFORMANCE­
BASED
PROGRAM
STATUS
AND
PRIORITY
State
Performance­
based
Environmental
Leadership
Program
Active
21
Under
development
5
Currently
inactive
1
Recently
de­
activated
1
No
22
Priority
Level
of
Leadership
Programs
High
11
Middle
7
Low
8
Mixed
7
Not
a
priority
4
Rank
not
specified
3
SUMMARY
OF
INTERVIEW
RESULTS:

I.
Support
State
Programs
and
State
Efforts
to
Work
with
Performance
Track:
(
Number
of
states
that
commented
on
improving
EPA­
state
coordination
=
30)

(
23)
Incorporate
performance­
based
programs
in
PPA
and
allow
credit
for
bean­
counting
[
includes:
(
6)
Reduce
focus
on
bean­
counting]
(
21)
Funding
and
resources
(
5)
Connect
PT
to
state
and
core
program
priorities
(
6)
Align
Performance
Track
and
state
programs
II.
Assure
Program
Support
from
All
EPA
Program
Offices
­
Internal
EPA
Coordination:
(
Number
of
states
that
commented
on
internal
EPA
coordination
=
13)

(
6)
More
involvement,
specifically
from
program
staff
(
3)
Encourage
culture
change
within
EPA,
OECA
and
OGC
(
2)
Senior
management
communicate
support
(
2)
Improve
coordination
of
all
EPA
voluntary
programs
and
initiatives
1­
13­
05
18
III.
Provide
Better
Incentives
to
Participants:
(
Number
of
states
that
commented
on
incentives
=
26)
(
8)
Regulatory
incentives
(
7)
Suggestions
on
considerations
when
developing
incentives
(
state
regulations,
facility­
specific,
small
businesses,
other
environmental
issues,
involvement
of
program
staff)
(
4)
Streamlined/
Less
reporting
(
4)
Priority/
Expedited
permitting
(
3)
Flexibility
to
states
in
implementing
incentives
(
3)
Economic
incentives­
green
investment
ratings
(
2)
Expanded
permit
terms
(
years)
(
1)
State
purchasing
program
(
1)
Implement
low
priority
for
inspection
(
1)
High
profile
activities
(
1)
Discount
to
state
parks
for
employees
of
member
facilities
IV:
Program
Outreach
and
Marketing:
(
Number
of
states
that
commented
on
outreach
and
marketing
=
20)

(
5)
Expand
program
to
accommodate
small
and
medium
sized
businesses
or
facilities
with
small
environmental
footprint
(
5)
Expand
program
to
accommodate
more
sectors
(
including
tribal
groups)
and
engage
facilities
one­
on­
one
(
5)
Demonstrate
costs
savings
and
program
results,
share
success
stories
(
4)
Reach
out
to
state
governors,
participate
in
state
events,
and
utilize
partnerships
(
4)
Improve
reputation
through
more
stringent
compliance
or
performance
criteria
(
1)
Provide
assistance
through
guidance
documents
(
sector­
specific
EMS
guidance)
(
1)
Reach
out
to
national
business
leaders
and
encourage
them
to
share
the
benefits
of
being
an
environmental
steward
from
a
business
perspective.
