Pollution Prevention Performance Measures
for the Environmental Cooperation Pilot Program

Pollution prevention is a hallmark of the pilot program and is a strategy that underpins several of the explicit goals listed in the statute. The importance of pollution prevention is evident in both the cooperative agreements and the underlying requirement that each participant implement an environmental management system (EMS) based on international standards.

The EMS requirement ensures that each participant in the program is committed to the prevention of pollution. This commitment is in some ways separate from and in addition to the specifics of each cooperative agreement. We expect any company with an EMS to practice pollution prevention - whether the company is in our pilot program or not.

The cooperative agreements take this basic EMS commitment (to prevent pollution) to a higher level. Each participant in the pilot program must commit to measurable or noticeable improvements in environmental performance, including reductions in waste generation. In return they receive flexibility on specific administrative requirements. This flexibility not only provides an incentive for pollution prevention commitments, but it also facilitates some pollution prevention activities that would otherwise be difficult or impossible to undertake.

Analyzing Environmental Performance Data

This web page presents the results of an initial analysis of aggregated performance data from companies participating in the ECPP. These data demonstrate trends in environmental performance based on information collected by DNR. The performance elements analyzed here were selected because of their significance to public health and the environment, and because of their ubiquitous nature. We selected performance measures that are meaningful to the public and meaningful to large numbers of regulated businesses. Furthermore, each performance measure can be linked to specific commitments to superior environmental performance in one or more of the cooperative agreements.

Readers who are interested in reviewing any of the raw data used for this analysis are encouraged to contact mark.mcdermid@wisconsin.gov.

Selection of the Baseline Year

The first ECPP agreements were signed in 2001 with We Energies’ Pleasant Prairie Power Plant and Cook Composites and Polymers. By the end of that year, negotiations with Madison Gas and Electric, Northern Engraving Corporation, and Packaging Corporation of America were well under way. We Energies had by then applied for a second agreement covering more sites. We have selected the year 2000 as the baseline for most of this performance analysis because it is the year that predates nearly all of the significant ECPP milestones. The year 2000 also makes sense as a baseline because of EMS activity. 3M did not apply for the pilot program until 2002, but had achieved certification of the EMS for their Menomonie site in late 2000. Northern Engraving Corporation’s Sparta and West Salem sites were also certified in 2000. Other sites and other companies followed in later years.

We need to use a different baseline year for one of our performance measures, hazardous waste generation. Reporting requirements for hazardous waste generation are more comprehensive in odd-numbered years than in even-numbered years. Because of this distinction, it would not make sense to compare odd-year data to even-year data. We have chosen to examine only the more comprehensive and accurate odd-year data as our performance measure. In order to have enough data points to identify meaningful trends, we subsequently set the baseline year for this performance measure at 1997 even though that year significantly precedes the ECPP.