The Environmental Cooperation Pilot Program: 2006 Progress Report October 31, 2006 TABLE OF CONTENTS Executive Summary Environmental Cooperation Pilot Program – Environmental Performance Program Participant Accomplishments Renewal of Agreements USEPA Collaboration Program Challenges Conclusions
Also available as a pdf For more information on the Environmental Cooperation Pilot Program, please see our ECPP web pages.

---

I. Executive Summary:

The Environmental Cooperation Pilot Program (ECPP) along with the companion Green Tier program was selected as one of 18 finalists out of over 1000 applicants for the Innovations in American Government Award. As promised in last year’s report, this year’s report describes our work on performance measurement and renewal. Performance measurement work received considerable assistance at no charge from the Governor’s internship program. The Environmental Cooperation Pilot Program continues to affirm the environmental and economic gain from performance-based relationships that can change as needs change.

Performance metrics have been a specific focus. The state is indebted to five interns and two groups of graduate students collaborating with program staff to work on various elements of the performance metrics. Extensive work was also done initially by second year law students and then further developed by graduate students from the School for Public Policy. We have found measurement to be quite different from traditional regulatory measures. The kind of outcomes that are reflected within this report and the relationships and transparency information under development are new in our reporting realm.

The program participants have continued to serve as environmental performance leaders with new commitments and directions in renewals.  Two of the six participating companies have renewed agreements.  Through these new agreements we are now starting to explore ways to make sustainability a functional term in the business community and to do so within the legal framework provided by the cooperative agreements.  Cook Composites and Polymers has presented the next level of leadership as the company has challenged DNR to take collaboration to a new level in their new agreement with product stewardship, green product design and managing wastes from one company so that those wastes become raw materials for another company (“by-product synergy”).

The Environmental Cooperation Pilot Program is about results and once again the Program Participant’s section tells the rest of the story.  Whether saving 1900 train cars of coal at Pleasant Prairie, 3000 administrative hours at Northern Engraving or over $600,000 at 3M, each provides examples of what is being done to improve performance.   The full story is contained in the metrics supplied by the companies.  Beyond the performance commitments, these are leaders helping other companies considering environmental management systems or looking at options for regulatory flexibility.  On a more global scale, these companies have worked with groups of companies, such as the printing industry, pursuing participation in the Green Tier program.  Their reports on their commitments provide significant additional detail behind the overall metrics that have been added to this year’s report to form a more comprehensive look at environmental outcomes.

---

II. Environmental Cooperation Pilot Program – Environmental Performance

This section 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 data 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.

In order to provide a simple, straightforward picture of whether performance is improving or getting worse, we present all of the data in a way that shows the percentage increase or decrease in performance from baseline levels. For each measure, we also compare the performance of ECPP participants (aggregated) to the performance of all other Wisconsin stationary pollution sources (aggregated). We begin with just five performance measures, but we hope to add additional measures (perhaps including energy and water use) to this analysis in the future.

Note: Data from 2005 were not available in time to be included in this report. The information in this report is available online at http://dnr.wi.gov/org/caer/cea/ecpp/p2/index.htm. The online version should be updated to include 2005 data by the end of December 2006.

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 environmental management system (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.

Nitrogen Oxide Emissions

Nitrogen oxides, or NO_x, is the generic term for a group of highly reactive gases, all of which contain nitrogen and oxygen in varying amounts. To learn more about NO_x and the human health and environmental effects of NO_x, visit DNR’s website at Oxides of Nitrogen.

As the chart below shows, ECPP participants have reduced their NO_x emissions to less than half of baseline (year 2000) levels in the course of just four years. Over the same time period, NO_x emissions from all other stationary sources in Wisconsin have also declined, but the decline has not been as dramatic and may be leveling off.

Sulfur Dioxide Emissions

Sulfur dioxide, or SO₂, belongs to the family of sulfur oxide gases (SO_x). DNR provides more information on SO_x and its human health and environmental effects on the following web page: Sulfur Dioxide.

ECPP participants have reduced SO₂ emissions by approximately 15% from baseline (year 2000) levels. This accomplishment has happened at a time when SO₂ emissions at all other stationary sources in Wisconsin have increased by roughly 5%.

Volatile Organic Compound Emissions

Volatile organic compounds (VOCs) are emitted as gases from a wide array of products including paints and lacquers, cleaning supplies, pesticides, building materials, glues and adhesives. More information about VOCs and their effects can be found at: Volatile Organic Compounds

ECPP participants have reduced their VOC emissions by more than 35% since the baseline year of 2000. Over the same time period, VOC emissions from all other stationary sources in Wisconsin have also declined, but not by nearly as great a percentage.

Hazardous Air Pollutant Emissions

This performance measure encompasses emissions of more than 400 different chemicals that are listed by Wisconsin and/or the federal government as hazardous air pollutants (HAPs). The human health and environmental effects of HAPs vary from chemical to chemical. Concise information on all of the listed HAPs is not available at this time, but a wealth of information covering more than a hundred HAPs is available from the U.S. Environmental Protection Agency website at Health Effects Notebook for Hazardous Air Pollutants [exit DNR].

Just as we saw with the previous performance measures, the trend in HAP emissions among ECPP participants is very encouraging. Total HAP emissions have declined nearly 30% from baseline (year 200) levels. At the rest of Wisconsin’s stationary sources, HAP emissions have varied erratically from year to year but were virtually the same in 2004 as they were in 2000.

Hazardous Waste Generation

“Hazardous waste” is a term that has a very specific meaning in Wisconsin and federal laws. The term includes an incredibly wide variety of materials each of which potentially poses some risk to human health or the environment. A DNR publication, available in electronic format at What is Hazardous Waste? [PDF], provides a detailed explanation of what is and is not considered a hazardous waste and what kinds of risks these materials pose. Under certain circumstances, regulated facilities must report to DNR the amount of hazardous waste (HW) they generate (or create) in a given year, which provides us with this performance measure.

As explained above, this performance measure only considers HW generation data reported in odd-numbered years because by law those reports are more comprehensive and accurate than reports in even-numbered years. The baseline year for this performance measure is set at 1997 in order to provide enough data points to discern meaningful trends.

Between 1997 and 2003, HW generation dropped more than 70% among participating ECPP companies. Most of the decrease occurred from 1997 to 1999, in other words prior to the implementation of EMS at the participating companies and prior to the signing of any cooperative agreements. HW generation continued to decline from 1999 to 2001, but then increased in 2003. In summary, it is difficult to discern any obvious trends in HW generation among ECPP companies. The one thing that does appear to be clear is that HW generation has increased for the rest of Wisconsin over this same time period, and in that respect the ECPP participants once again appear to be outperforming their Wisconsin peers on this performance measure.

III. Program Participant Accomplishments

The Environmental Cooperation Pilot Program has brought both sustained environmental performance and environmental innovation together. Wisconsin continues to reap the benefits realized from the first years of formal participation and new commitments as participants pursue continual environmental improvement.

Cook Composites and Polymers Co. (CCP) – Saukville

CCP continued to improve their environmental results, community involvement and development of new, more environmentally sensitive products.

• CCP implemented a new program to recycle and return rinse xylene with an off-site service. CCP managed approximately 510,000 pounds of xylene through recycling and return in 2005.

• The CCP Community Advisory Committee (CAC) met quarterly at CCP from January 2001 through the end of 2003.  In 2004, the CAC agreed to revise its schedule and meet on a semi-annual basis (e.g. April and October), unless specific issues require more frequent meetings. In 2005, the CAC met in January, May and October. Meetings are open to the public, and public comment is accommodated at a set time on each agenda.
• CCP has been formally recognized and participated in major events both nationally and internationally: 
  • CCP was invited to participate in a panel for the 2005 US EPA / Environmental Council of the States (ECOS) Innovation Symposium.  The scope of the panel was to share business drivers for environmental improvement and sustainable development.
  • CCP presented its Saukville experience at the 2005 TOTAL Sustainable Development Seminar in Paris, France. CCP was recognized for its efforts by TOTAL in their internally published “ACTIONS” Newsletter.
• CCP successfully completed its integrated registration audit in September 2005 and received ISO 14001 Certification for the Saukville facility.  Several Det Norske Veritas (DNV) auditors observed this audit since it was the first audit integrating health, safety and environment that DNV had conducted in the Unites States. CCP was also rated at one of the highest levels according to the International Safety Rating System (ISRS) that is used to rate health and safety systems.
• Below is a brief summary of emissions for CCP.  The chart shows Particulate Matter (PM), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx) and Carbon Dioxide (CO).  Reports and graphs on other specific areas of environmental performance are included in the full annual report for CCP on the Environmental Cooperation Pilot Program web site.

Madison Gas and Electric -- MGE - Madison

Through the end of 2005 MGE had accomplished all of the following:

• Re-registered their EMS to the new ISO 14001:2004 standard on November 12, 2005.
• Purchased 44,491 gallons of biodiesel since 2002 to reduce vehicle emissions of carbon monoxide, particulate matter, sulfur dioxide, and volatile organic compounds.
• In just one year (2005) diverted nearly 21,000 tons of fly ash away from landfill to beneficial reuse.
• Met with members of their Community Environmental Advisory Group at least twice annually throughout the term of the environmental cooperative agreement.

In the first half of 2006 MGE also launched two major initiatives:

• Energy 2015, a plan that will provide a balanced, cost-effective and environmentally responsible energy supply for the next 10 years. It calls for replacing Blount's coal-fired energy with new cleaner coal electricity by 2011.
• Power Tomorrow, a comprehensive energy conservation initiative that reaches every residential customer.

We Energies

Progress continues on the 2002 Multi-Emission Cooperative Agreement (MECA). In February 2006, DNR and We Energies renewed the 2001 Pleasant Prairie Power Plant (P4) Agreement for another five years. Through these two agreements We Energies has achieved the following:

• Virtually eliminated landfilling since 2002 at Pleasant Prairie site thanks to approximately 100% beneficial reuse of ash.
• Recovered for beneficial use approximately 70,000 tons of coal ash that had been formally located in the Pleasant Prairie Power Plant landfill.
• Avoided use of more than 1,900 railroad cars of coal (approximately 19 unit trains - 100 cars per unit train) by recovering ash from multiple landfill locations and reburning it at Pleasant Prairie as a supplementary fuel.
• Reduced potential CO₂ emissions by over 275,000 tons through reburning or reusing coal ash.
• Made progress towards completing the $325M Air Quality Control System at Pleasant Prairie. This includes the installation of a second Selective Catalytic Reduction unit and two wet Flue Gas Desulfurization (FGD) systems.  The first FGD system will be operational at the end of 2006.
• Met (and exceeded) a commitment to reduce NO_x emission levels to 0.25 lb/mmBtu within five years of signing MECA. (Actual emission rate was 0.229 lb/mmBtu.)
• Met a second commitment to reduce SO₂ emission levels to 0.70 lb/mmBtu within five years of signing MECA. (Actual emission rate was 0.665 lb/mmBtu.)
• Continued to sponsor research on co-control mercury removal technologies, the environmental fate of mercury emissions, and the use of non-carbon based sorbents for mercury removal. ^[1]
• Recognized by the Department of Energy’s National Renewable Energy Laboratory for its Energy for Tomorrow Green Power Program which ranked in the top ten nationwide.
• We Energies participating power plants continued to work with interested stakeholders, including hosting information sessions and tours for several schools, universities, and community members, as well as recently-hired employees of the Environmental Protection Agency.

[1]  Most recently, We Energies announced a first-of-a-kind carbon dioxide capture research project at the Pleasant Prairie Power Plant.

Northern Engraving – NEC - Sparta, Holmen, West Salem and Galesville Facilities 

Northern Engraving Corporation has been a program participant since June 2002. Northern Engraving and DNR have met annually to discuss annual reports, company and agency performance and opportunities for improvement. At the most recent meeting, discussions started for a 5-year extension of the agreement and exploration of amendments that could add value to a renewed agreement. Both parties have acknowledged that the cooperative and professional relationship has helped to realize positive environmental gains. Northern Engraving Corporation’s extremely robust environmental management system continues to drive the improvements that are reported below.

NEC and DNR continue to learn from each other. The agreement has provided a forum to develop an understanding of business and market complexities. The working relationship has also provided effective strategies to address an ever changing business environment and the challenges to provide environmental improvement. The parties continue to partner in ways to assure continual growth and stability for both the community and the company while working toward zero environmental impacts as a result.

NEC continues to conduct monthly audits of their EMS. In 2005 only two minor nonconformities were discovered by external auditors for all facilities during their annual audit and both were resolved within 30 days.

Continual Realized Improvements/Benefits

• Combined savings of natural gas usage due to shutdown of Sparta and West Salem incinerator equals approximately 12,400 thousand cubic feet (MCF); in 2005
• Over 3000 hours of reporting requirements avoided annually
• Estimated 93 days saved in permit turn around time in 2005
• Continual water reduction and Energy reduction efforts

Interested Persons

NEC used in-person and electronic means to satisfy their interested persons commitments for 2005. In May 2005 NEC provided information on their efforts electronically to interested persons group members with offers to meet in person and discuss. In 2005, NEC had several members of the interested persons group drop from the group due to lack of time and or interest. NEC met on Nov 7, 2005 with remaining stakeholders and DNR. NEC has also stepped up their effort to create a more diverse group of participants in 2006.

Corporate Summary (1996 through 2005)
(1996 is the baseline for NEC’s Environmental Cooperative Agreement)

• VOCs - decreased 63 % (221 tons)

• HAPS - decreased 91% (119 tons)
• Hazardous Waste – decreased 68% (42,881 gallons)
• Water Usage – decreased 73% (93 million Gallons)
• Solid Waste – decreased 58% (1,050 tons)

2005 Report Sparta Facility

• Although VOCs increased in 2005 due to significant increase in sales, the overall sales to VOC emission ratio improved by 6%.
• Hazardous waste generation to sales ratio improved by 15%. Reformulation of sprays from a solvent base to water base significantly reduced hazardous waste generation while increasing the quantity of wastewater treated as non-hazardous.
• Water usage was reduced by 18,000,000 gallons in 2005. Reduction in water pressures, reconfiguration and replacement of nozzles and reuse of used water contributed.
• Electricity consumption increased by 16%. Increased sales, addition of injection moldings and unexpected third shift operation contributed to the increase.

Holmen Facility

• Though sales to VOC showed a slight decline, it was the second best efficiency rating since 1996. It was due in part to replacement of spent solvent with virgin screen cleaning. Solvent was recycled.
• Distillation and reuse of waste solvent and improved ink management resulted in 30% reduction in waste ink.
• Recycled 3 tons of plastic waste through new program. Solid waste was reduced by 18.3 tons overall.
• Reduced natural gas usage by 6%, however electric use increased 3%. Energy consumption remains a target at all facilities.
• 63 jobs were converted to a new UV primer that is free of VOCs.

West Salem Facility

• Increase of hazardous waste was due to increase in coatings and launch of new project. To be addressed in 2006 objectives.
• Increased plastic recycling and reduced solid waste generation by 43% over 2004.
• New production caused increase in water usage in 2004, however, by converting a traditional flow through non-contact cooling system to a chilled water closed-loop system, created a 21% lower than average water usage in last four months of implementing this project in 2005.
• Instituted an energy management program with assistance from Focus on Energy.
• Painted selected areas of roof white to reflect sun and reduce heat buildup. To be evaluated.

Galesville Facility

• 54 ton reduction in solid waste generation through the Plastic Recycling project.
• On February 1, 2006 Northern Engraving Company announced that the Galesville facility will close in April 2006 as part of a reorganization effort.

Packaging Corporation of America (PCA) - Tomahawk

PCA establishes annual key environmental objectives based on an assessment tool featured in their site-specific EMS. Key objectives identified for calendar year 2006 include:

• Recordkeeping enhancements regarding petroleum spill prevention inspections and air permit compliance requirements. (Outcome – operating area inspection forms developed and incorporated into Statistical Process Control (SPCC) plan as of May of 2006)
• Strategic efforts associated with two federal Clean Air Act rules (maximum achievable controls on solid fuel boilers and best available retrofit technology for industrial boilers constructed between 1962-77) (Outcome – compliance with boiler MACT)
• Two expansion projects
  • Design to increase biogas collection (Outcome – engineering review completed, WDNR Water Bureau notified, construction began September 2006)
  • Landfill Cell 2A construction (Outcome – construction began in May ’06, two lifts of clay installed in July 2006, membrane installed August 2006, construction to be completed by the end of October 2006)
• Study results from mercury pollution prevention project (Outcome – P2 plan data indicates principal source of Mercury is from hardwood used for pulp. Total discharge is less than 100grams/year, due to water conservation Hg concentrated, working with WDNR on review of plan since June 2006).

• valuate water reduction accomplishments (Outcome – year-to-date water consumption goal is being met – with the mill utilizing slightly below the target of 3,500 gallons of water per ton of production).
• Pursue alternative beneficial uses of wastewater treatment residuals (Outcome – samples of wastewater treatment plant residuals sent to Racine poultry operation. Trial indicated favorable results, transportation costs inhibit process.)

3M Company -- Menomonie

For all of 2005, 3M Company -Menomonie operated under an Amended Agreement (signed December 22, 2004). Changes to the original Agreement included operational flexibility of new and existing processes requiring air construction permits and a facility wide cap on VOCs and HAPS. The changes also included a new facility-wide Title V air permit that supersedes air permits established prior to December 2004. DNR and 3M met several times in 2005, with the Governor James Doyle and Secretary Scott Hassett attending one of the events to recognize the new Agreement. Additionally, on August 25, 2005, 3M participated in a third-party recertification audit of their Environmental Management System to the conformance of the new ISO 14001:2004 standards. The company has met all conditions and statutory requirements of the Agreement in 2006.

Interested Persons Group

3M met with the interested persons group twice in 2005-06 and continues to maintain a diverse list of community representatives.

Cooperative Agreement Initiatives

In 2005, 3M-Menomonie initiated 6 operational projects that were covered under the Amended Agreement (Title V Part III for pre-approved projects). These include:

• 3M estimated time saved in startup totaled 9 months for the projects
• An estimated 144 hours of 3M administrative time was saved

3P (Pollution Prevention Pays)

In 2005 3M celebrated 30 years of their 3P program. 8 projects were approved in 2005 at the Menomonie facility.

• 15.66 tons of recycled cardboard and consolidated paper. Saved $17,107. Also reduced three vendors to one that handled consolidated paper.
• Saved $12,800 and prevented .212 metric tons of GHG by reducing heat up cycle on one of their ovens. Saved 4.0 MMBTU.
• Reuse of packaging saved roughly $7,404 and 8.4 tons of waste from being land filled.
• Reuse of pallet boxes saved $2,827 and prevented 3.3 tons of waste material.
• Installation of thermal oxidizer on 2 ovens reduced VOC and Formaldehyde emissions by 27 tons. Saved $5,022 through reduced maintenance.
• Replaced resin drums with bulk containers. Reduced labor, transportation, and employee exposure. Savings of $156,000. Reduced solid waste by 8.5 tons and GHG by 18.0 metric tons.
• Developed returnable and reusable cardboard packaging to replace wooden crates. Saved $233,600. Reduced waste 233 tons.
• Total energy savings of projects equaled 313 mmBtu.
• Total GHG emissions reduced equaled 18.2 tons of CO₂.

Data for these projects reflect 2004 information gathered to justify approval by corporate office.

TRI

• Reduced the ratio of TRI releases to good output (finished, semi-finished product, recycle/reuse materials) produced by 54% from 1999 to 2004. (Will reestablish goals with extended agreement in 2007).

VOCs

• Reduced the ratio of VOCs released to good output produced by 26% of 2000 levels (reflects ratio and established target of 25%)

Solid and Chemical Waste

• Obtained an actual 18% reduction vs. a targeted 25% reduction in the ratio of waste produced per pound of good output) from 2000. Goal established to reduce waste by 5% in 2005 in order to meet target. An increase of 20% production in 2005 over 2004 resulted in new film lines and ceramic fibers line, and modifications, which added to waste generation that could not be offset in 2005.

Total Recycling Efforts in 2005 (in pounds and savings)

Material	Pounds Recycled	Savings
Plastics	6,145,191	$385,306
Metals	245,325	$277,723
Aluminum cans	2,314	$775
Silicone Liner	264,182	$14,560
Cardboard	338,969	$723

Other materials recycled or reused by 3M Menomonie in 2005 for which the facility did not receive monetary benefit included:

Material	Pounds Recycled/Reused
Office paper	22,539
Security waste paper	5,650
Recyclable packaging	2,296,400
Recycled drums	2,816 drums reconditioned

IV. Renewal of Agreements

Last year’s Progress Report identified several challenges facing the program. First among these was the need to develop a process for renewing agreements at the end of their initial 5-year terms. The issue involved a certain amount of urgency because the first two agreements were due to expire in 2006 unless they were renewed.

In the past year the DNR has worked with our pilot companies and the Legislative Fiscal Bureau (representing the Joint Committee on Finance) to develop and test a renewal process that satisfies statutory requirements and meets the needs of all stakeholders. First up was the agreement with We Energies covering the Pleasant Prairie Power Plant, which served as a test case. Despite encountering a few minor glitches and imperfections in the process, this agreement was amended and renewed for an additional 5-year term on February 3, 2006. After making a few adjustments to the process, the second test case ran more smoothly. The Cook Composites and Polymers agreement was amended and renewed for an additional 5-year term on September 29, 2006.

The renewal process is now fully developed and tested. In 2007 five agreements are set to expire unless renewed. We do not yet know if renewal will be desired or appropriate in all five cases, but we are confident that any renewals we pursue can be effectively and efficiently managed.

V. USEPA Collaboration

The US Environmental Protection Agency (USEPA) and the Department of Natural Resources successfully renewed the Cooperative Agreements for both We Energies and Cook Composites and Polymers.  USEPA and DNR have also started to investigate potential changes for the agreement with Northern Engraving Corporation.  In the course of renewing the agreement for Cook Composites and Polymers, the company challenged DNR and USEPA to work with the company in new ways including the design and development of products, by-product synergy and product stewardship.  The Department and EPA will be having further discussions over the course of the year to determine how best to meet that challenge.

In 2005, Wisconsin was in a leadership role for a national initiative to develop incentives for both state and federal leadership programs.  This was a joint effort that culminated in the recommendations being published in the Federal Register.  While most of the recommendations relate to Performance Track participants, there were several recommendations that will result in the creation of infrastructure to explore and secure additional incentives for state performance programs.  Similarly, initial work is underway to explore ways for state performance programs such as the Environmental Cooperation Pilot Program to receive the same incentives that are available through the federal Performance Track Program.

VI. Program Challenges

Sunset Provisions and Statutory Limitations – With the renewals that are now underway, the term of the Cooperative Agreements has a firm end date since the Cooperative Agreement Law allows for only one 5 year renewal.  After that time the flexibility and the performance would need to be maintained through another mechanism such as going through the administrative processes of the Green Tier program unless the Cooperative Agreement participants are somehow “grandfathered” into the Green Tier program.  The Cooperative Agreement Program, anticipated as a “pilot,” has actually proved to be a very valuable resource for research and development of incentives and performance elements, implemented through the Green Tier program.

Performance Metrics – Over the course of the next year the metrics for Green Tier and the Environmental Cooperation Pilot Program will be examined for alignment.  Green Tier is in the process of working with the external advisors to come up with a strategy for assessing performance and managing tracking issues.  Once completed, we would expect some adjustments in order to have the two programs working with equivalent information.  While basic environmental metrics are ready for presentation, the work on relationships, transparency and sustained business value are in the final stages of development and will be underway for implementation in the upcoming year.

Program Resources – The Environmental Cooperation Pilot Program has been further stretched with the implementation of Green Tier. Both the Bureau of Cooperative Environmental Assistance and the program bureaus have made adjustments but continued restriction on federal funds, limits associated with state funding sources and budget reductions restrict the scope and nature of the work under both the Environmental Cooperation Pilot Program and Green Tier.  Securing “pro bono” work, unpaid/very motivated university interns, research projects through university classes, self-responsibility models, reduced communications, emphasis on “one to many” agreements and reduced participation in policy development have all been employed as interim strategies to deal with resource constraints.

VII. Conclusions

ECPP companies continue to show leadership in demonstrating new ways to achieve superior environmental performance and sustaining the delivery of environmental results over time. The program has exerted both international and national leadership. ECPP provided a working base for implementation of Green Tier, resulting in a formal working agreement with USEPA. This is complimented by national initiatives to build value into leadership programs. ECPP companies have stepped into the role of mentor, teacher, counselor, leader and advocate as the needs arose while continuing in their roles as innovators and superior environmental performance managers.  The results of their performance management are summarized within this report and can be examined in detail at the ECPP web site. The results that they have achieved are the most important part of the program.

Careful attention will be paid over the course of this next year to make sure that these companies continue to be recognized as leaders and that the capacity of the ECPP to do research and development work for Green Tier companies is maintained by renewing the ECPP agreements. In last year’s report, we recognized that ECPP companies are “in the best position to test new approaches, explore untested methods and develop innovative ideas that might otherwise be difficult to try”. ECPP companies will continue to demonstrate their environmental leadership as they have done for the last several years.

---

For more information on the Environmental Cooperation Pilot Program, please see our ECPP web pages.