Regional Highlights Pacific Northwest
Pollution Prevention Roundtable
October 28-29, 1998 in Seattle, Washington — Minutes

Table of Contents

Goals and Audiences

Welcome and Introductions

Pollution Prevention and Salmon

Linking Assistance Programs to Salmon Recovery Efforts and Other Environmental Impacts
The Challenge: What Is Expected of Assistance Providers
Rising to the Challenge: How Assistance Programs Can Contribute to Solutions
Upcoming EPA Headquarters Priorities
Making Voluntary P2 Approaches Effective for ESA Compliance
Motivating Business: Tips and Tools
Tapping Resources and Measuring Results

Introductions: Besides More Funding, What Is No. 1 on Your Wish List of Things That Would Help You Serve Your Clients Better?
Understanding Assistance Services in the Northwest
Measuring Results: Current and Emerging Approaches
Information Resources
Favorite Failures: Learning from Our Mistakes
List of Attendees

List of Handouts

Meeting Notes  


Summary of Goals

Pollution Prevention and Salmon

  1. Build understanding of connections between technical assistance and salmon restoration.
  2. Develop ideas on technical assistance approaches that deliver environmental and economic results, using salmon as an indicator

Tapping Resources and Measuring Results

  1. Document information resources available to assistance providers, and build productive working relationships among different provider groups.
  2. Develop promising and reliable approaches for measuring program results.


  1. Pollution prevention technical assistance providers and policy staff
  2. Compliance assistance providers
  3. Industrial Technical Assistance Providers (ITAP)


  Madeline Sten
    Pacific Northwest Pollution Prevention Resource Center (PPRC)
  Ron Kreizenbeck
    EPA Region 10, Office of Enforcement

The Bottom Line
The regional roundtable’s central purpose is to protect public health and the environment, by fostering information exchange that helps industry become more efficient and reduce waste. Salmon restoration is an opportunity for assistance programs to demonstrate their value to the region.

Madeline Sten: The agenda was designed for the needs of pollution prevention practitioners, compliance assistance providers, and the Industrial Technical Assistance Providers (ITAP), which is a voluntary association of P2, energy and manufacturing assistance programs.

Assistance programs have an opportunity to play an important role in restoring endangered salmon and steelhead runs. Enforcement alone will not bring about species recovery. Restoration also will require voluntary actions. Assistance programs with experience in bringing about voluntary behavior change and documenting the results can help lead the region in addressing an environmental challenge with both broad public appeal and large-scale ramifications for the region’s economy. Working together, the various assistance programs can improve their effectiveness.

Ron Kreizenbeck: Focusing technical assistance efforts on salmon is an opportunity for assistance programs, which are underappreciated and receive little notice compared to other programs. EPA Region 10 is adopting a compliance assistance strategy that will include information sharing and new ways to measure results.

Attendees introduced themselves and described the most interesting projects they are working on. Examples included measuring results of technical and compliance assistance, sector-based assistance projects, assistance to small communities, P2 incentives and awards programs, and salmon recovery planning.

Salmon Information Resources

Pollution Prevention Northwest – Restoring Salmon: P2’s Role

Salmon Information Center

The Oregon Plan for Salmon and Watersheds

Northwest Power Planning Council




  Angus Duncan
    Columbia/Pacific Institute and Bonneville Environmental Foundation

The purpose of the presentation was to provide an overview of salmon’s status, what’s necessary for their recovery, and the role assistance providers can play.

The Bottom Line
To restore endangered salmon runs, the region must "lighten the footprint" that development has left on natural ecosystems. The science underpinning salmon recovery and the steps necessary for restoring salmon must be translated into language that is relevant to the everyday concerns of the region’s industries and farms.

Salmon are an ecological "pivot point." They are an element of many Northwest ecosystems as a result of their unique life history. Salmon fry hatch in mountain, forest or desert creeks; migrate to sea via coastal rivers, Puget Sound or the Columbia River; and return a number of years later to spawn in the creeks where they were hatched and die. In returning to rivers, salmon contribute nutrients that sustain watershed ecosystems.

Salmon, the Northwest’s marquee species, are an indicator of people’s impacts on the environment. Salmon are a useful context for defining our relationship to the environment. The quality of our environmental management will be indicated by the health of salmon runs.

Through development, people have intervened in all stages of salmon’s life history. Consequently, the causes of their decline are many in number and cumulative in impact. Wild salmon may emerge in streams polluted by runoff or high temperatures. They face competition from hatchery-reared salmon. They may have to traverse warm, slack pools backed up behind dams.

The impacts of development have resulted in fewer salmon and steelhead returning to the region’s rivers and numerous threatened and endangered species listings affecting Oregon, Washington and Idaho runs, in both urban and rural areas. (For information on the status of West Coast salmon and steelhead populations, visit the National Marine Fisheries Service’s Northwest region at, and click on the fact sheets button.)

The question is how the runs can be restored short of asking for draconian measures that have little chance of being adopted. The key is providing high-quality, connected habitat from the mountains to the ocean. Society must "lighten our footprint" on ecosystems that support fish.

The region is in a transition from a "development model" in which resources are fully exploited to an "ecological model" in which resources are managed sustainably. In order to lighten society’s "footprint" on resources, good science translated into understandable language must support changes that businesses are asked to make. The gap between science and people’s choices must be closed.

Assistance providers must make the case for change using understandable science that has meaning for people’s lives and livelihoods. If that case is made, people will respond and incorporate ecological protection into their values.



  Fred Colvin
    Doelman Dairy Farm, Rochester, Wash.
  Kathy Fletcher
    People for Puget Sound
  Chris Wiley

Other Scheduled Panelists:
  Ken Grimm
    Capital Industries
  Sydney Randell
    U.S. Postal Service

Handout Available: U.S. Postal Service environmental management, presentation overheads

Different interest groups have differing expectations of assistance providers. The panel’s purpose was to give business and non-government organization representatives a chance to discuss their perspectives with assistance providers.

The Bottom Line
    • Agriculture needs consistency and predictability in non-point source pollution regulations.
    • P2 should be central to water quality protection strategy by coupling it to strong enforcement.
    • Assistance providers can bring about behavior change by training business employees, and by proposing small-scale, easily implemented changes.

Fred Colvin: Enforcement of non-point source water quality regulations is relatively new to agriculture, a very diverse sector which is not well-informed about the compliance requirements it faces.

Farmers have received mixed messages from regulators about the compliance issues they must deal with. For example, Washington dairies were assured by the state that compliance requirements dealt only with surface water. But regulators then said that standing water and groundwater also were affected. Regulators have been ineffective in communicating non-point source compliance requirements in simple and clear language.

Agriculture needs consistency and predictability. Consistency is needed both within agencies and among agencies. Predictability is needed for farmers to know what is expected of them in the areas of pollution prevention and compliance.

A valuable resource for delivering P2 and conservation information is local resource conservation districts, which are non-regulatory agencies that provide farmers and other landowners with technical assistance in soil, water and resource conservation. (Nearly every county in the nation has a local conservation district. For more information about conservation districts, including their mission, services and a directory of Northwest districts, visit the National Association of Conservation Districts at

Kathy Fletcher: Non-government organizations are troubled by agencies posing pollution prevention and technical assistance as alternatives to enforcement. Another troubling concept is coupling voluntary compliance with regulatory certainty for business. Agencies should give more attention to the linkages between enforcement and technical assistance. In Iowa, for example, a study identified lack of enforcement as a deterrent to P2 implementation.

In relation to salmon recovery, People for Puget Sound advocates strong enforcement of existing laws, such as the federal Clean Water Act and state Growth Management Act. Enforcement has been weak. A failing of the point source program is addressing trace toxins, which harm salmon reproduction, immune systems and growth. (See People for Puget Sound’s literature review on salmon and toxics at

The National Pollutant Discharge Elimination System (NPDES) has not increased the stringency of permit requirements as water pollution control technology has improved. For example, a Washington refinery is surpassing permit requirements as a result of improved technology, yet requirements in the refinery’s discharge permit have not been tightened accordingly. That is a failing that does not encourage P2 adoption. (For details on People for Puget Sound’s activities in regard to this refinery permit, visit P2 should not be a separate, voluntary program, but an essential component of a regulatory program.

Chris Wiley (formerly with Capital Industries and speaking on behalf of Capital Industries’ Ken Grimm): There are three ways that technical assistance providers can be of greatest service to business. They include:

Another important consideration is translating environmental science into understandable language. That will be important for businesses facing Endangered Species Act compliance issues, such as facilities in the industrialized Duwamish corridor in south Seattle.

U.S. Postal Service: (Sydney Randell was unable to deliver his presentation in person. The following is a summary of information contained in overhead transparencies prepared for the presentation.) The U.S. Postal Service employs 750,000 people in 40,000 facilities, and uses more than 250,000 vehicles. The Postal Service is the nation’s largest recycler, buys products with recycled content, and owns the nation’s largest fleet of alternative fuel vehicles. For example, 7,000 vehicles are powered by compressed natural gas. Environmental management policies are developed and carried out by a headquarters staff, 10 area environmental coordinators, and 85 district coordinators. The challenge is to integrate environmental practices into business functions, including collection, processing, transportation, delivery, and marketing.

In response to a question about coupling technical assistance with performance standards, Fletcher said that general standards are not enforceable. Further, if agencies lack resources for enforcement, that raises the question of whether they have sufficient resources for technical assistance.

Based on his experience with watershed management in the Grand Ronde basin, Duncan said the combination that seems to work best is setting clear, measurable performance standards, but deferring to local knowledge in determining ways to meet the standards. Neither enforcement nor local initiative by themselves will lead to lasting behavior change.

Duncan said there is evidence that a shift toward an "ecological model" is under way, although the transition is confusing. The certainty that people and businesses are seeking will come by adopting aspects of the ecological model. Wiley said one way to translate the ecological model into technical assistance is to show that the needs of salmon and people for clean water and healthy habitat coincide.

Colvin said there should be a place for both the "development" and "ecological" models. The marketplace may be a tool for helping the ecological model along. For example, a "green milk" program in the Chesapeake Bay area gives people the option of paying a premium for milk produced through environmentally sound practices. (For information about this program, visit



Oregon Department of Environmental Quality (DEQ)
  Pete Dalke
  Gil Hargreaves
Washington Department of Ecology (Ecology)
  Bruce Barbour
  Dave Misko
  Hugh O’Neill

Handout Available: Pollution Prevention & Compliance Success Through Technical Assistance, Washington Department of Ecology

The purpose of the presentation was to provide information on carrying out pollution prevention outreach efforts in a watershed context, by focusing behavioral change on achieving measurable improvement in a body of water’s quality and habitat.

The Bottom Line
    • Businesses and residents won’t listen to government, but will listen to people like them when asked to change their behavior in order to incorporate the needs of salmon.
    • Real success in improving water quality will be achieved by different organizations working together.
    • State agencies can’t do technical assistance entirely on their own, but need to engage local organizations and agencies.
    • Agencies doing technical assistance can measure results and adapt their programs as they go along. Be willing to try out ideas.
    • To deal with wider sustainability issues, assistance programs could broaden their efforts to cover water and air quality, energy, occupational safety, and water efficiency.

Bruce Barbour: Ecology has facilitated four teams that are comprehensively addressing water quality issues in the Lake Whatcom watershed in northwestern Washington. The teams include monitoring, restoration, business and residential. The latter two are working on changing behaviors and community culture to accommodate salmon’s needs. Change happens more effectively when peers, rather than government, are the change agents.

The residential team sent pollution prevention booklets and pledge cards to area households, and so far 400-500 have been returned. The 20-page booklets provide information on stormwater runoff, lawn care, watering, household toxics, and reducing unnecessary driving.

The business team sent technical assistance teams made up of local agency and non-profit organization representatives to every business in the watershed. Each business received a P2 checklist and workbook. Once a business completes the checklist, it receives a plaque from local children. Five percent of the visited businesses refused the assistance visits. Those that refused are to be visited by compliance inspectors.

To connect assistance to environmental results, the project is sampling water quality, sediments, and the tissues of aquatic creatures in streams in the vicinity of Whatcom Creek. High levels of pesticides, heavy metals, fecal coliform and even unrefined oil have been detected.

Dave Misko: The program is using GIS technology to better understand Lake Whatcom’s 20-square-mile watershed, and to use the information to determine the best ways of effecting change. The sign of success will be if Ecology can walk away and the process can carry on under locally generated momentum.

Pete Dalke: The Environmental Partnership for Oregon Communities is a state initiative to assist small, resource-limited communities in complying with environmental requirements through voluntary measures, technical assistance, identification of funding resources, and negotiation of compliance schedules. The program is geared for communities with less than 2,500 population. An essential step is building trust with rural communities that don’t trust distant government agencies.

An example of a project area is the Calapooya Creek watershed in southern Oregon. There are two communities in the watershed with which the partnership is working, Oakland and Sutherlin. The main compliance issue with Oakland is discharge of chlorinated wastewater into waters that are coho salmon habitat. The concern is excessive chlorination. The partnership provided technical assistance, and the city was asked to report how it will implement changes. For technical assistance to be effective, the program must include the efforts of local agencies, such as resource conservation districts and watershed councils.

Gil Hargreaves: DEQ’s western region has documented the environmental results of several assistance projects. An example was the A-3 channel project, in which stormwater and waste management assistance was provided to small businesses in a Eugene-area watershed. One result was that 89 percent of "beyond compliance" suggestions were implemented. (For more information about the A-3 project, see an article published in Pollution Prevention Northwest, at and the minutes of the Regional Roundtable held in June 1998,

The Oregon projects show that measuring environmental results of technical assistance is possible. Programs should set up measuring systems, learn from the results, and adapt to improve, without getting bogged down in statistical minutiae. For programs to continue in existence, they must show they make a difference.

Hugh O’Neill: Three guiding principles of technical assistance are audience, content, and location. Ecology’s assistance programs started with reducing hazardous waste generated by point sources. The programs have expanded to cover stormwater runoff and integrated pest management. Audiences still being missed are non-point water pollution sources in agriculture, forestry and aquaculture, retail sectors, and households. The conventional focus on hazardous waste reduction could be broadened to cover energy and water efficiency, worker and fire safety.

An example of an innovative approach is the Toxics Reduction Engineer Exchange (TREE) program, an intensive technical assistance program for metal finishing plants. In the first such project, carried out at a Seattle electroplater, 300 hours of engineering assistance yielded a 50 percent reduction in water consumption and elimination of 42 million pounds of hazardous waste the first year. (For more information about TREE, see an article published in Pollution Prevention Northwest, at An important lesson that has come out of TREE is that finishers need to be shown that P2 approaches will work with their particular chemistries and equipment. Case studies are not sufficient.

So far, Washington is making progress toward its goal of reducing hazardous waste generation by 50 percent. From 1992 to 1996, hazardous waste generated fell from 289 million to 188 million pounds (numbers corrected for economic conditions).

To set technical assistance into a biological perspective, environmental impact on ecosystems is the product of population, consumption and technology. Technical assistance that increases technological efficiency reduces the scale of the impact. The key question is, when will we become native to this place? In the long run, the "ecological model" is the only workable approach.

Suggested readings on these issues include: Culture and Habitat by Gary Nabhan, In the Absence of the Sacred by Jerry Mander, Abstract Wild by Jack Turner, and The Case Against the Global Economy, edited by Jerry Mander and Edward Goldsmith.

Tom Eaton said the P2 community needs to avoid framing technical assistance as an either-or alternative to enforcement. The real task is to identify the pollution problems that need to be addressed and determine the most effective tools for solving them.

Another issue brought up in discussion is discharge of hazardous waste into sewers. Hargreaves said that such disposal is increasing dramatically, creating an additional stress on fish populations, and EPA should address the matter.

Prothro concluded the discussion by observing that salmon have cultural value, and can help bring focus to assistance programs.



  Carolyn Gangmark
    EPA Region 10
  Lynn Vendinello
    EPA Office of Enforcement and Compliance Assurance (OECA)

Handout Available: EPA Compliance Assistance Centers brochure

The Bottom Line
OECA is looking for more effective ways to measure the results of information, assistance, and incentives tools.

Carolyn Gangmark: Guidelines for the Pollution Prevention Incentives for States (PPIS) grant program were issued in mid-October. Another grant program is the Sustainability Challenge, which supports community sustainability initiatives. States are not barred from applying, but are not encouraged to apply either. Award amounts will range up to $200,000. A request for proposals for a community-based environmental protection grant program will be issued in December 1998 or January 1999.

Lynn Vendinello: There is a mix of tools for assuring compliance, including assistance, incentives, monitoring and enforcement. OECA is learning that assistance alone is not sufficient, and that incentives, such as financial or shared liability provisions, may be necessary to effect behavior change.

EPA’s role is to wholesale information to the states, focusing on federal rules and acting as a clearinghouse. In some cases, EPA works in partnership with trade associations trusted by particular industry sectors.

The compliance assistance tool box includes on-line information, plain English guides to regulations, self-assessment tools, training and incentives, all designed to encourage self-policing and voluntary disclosure.

OECA has been working since 1993 on developing measurement tools that will document results achieved by the agency. OECA is collecting output measures from the regions, and looking for better ways to measure compliance, without necessarily establishing a causal link with any one compliance assistance tool. (For information on OECA’s performance measures project, visit

Measurement can cover both activities, such as number of facilities reached and number using compliance assistance services; and outcomes, such as changes in awareness, behavioral change, compliance rate statistics, and environmental results.

Awareness change metrics include number of companies seeking assistance, and the percentage that improve understanding of regulatory requirements. Behavior change metrics include number of best management practices adopted, number of process changes adopted, and number of audits conducted. Environmental performance metrics include number of facilities that reduce emissions, amounts reduced, and changes in worker health. The quality of existing compliance databases is a problem for measuring results. Many small businesses are missing from the databases, and those that are in the databases are not necessarily representative.



  Dave Galvin
    King County Local Hazardous Waste Management Program (LHWMP)
  Leslie Romer
    Washington Department of Ecology
  Mary Abrams
    Portland Bureau of Environmental Services
  David McDonald
    Seattle Public Utilities, Resource Conservation Office
  Ray Carveth
    King County LHWMP

Handout Available: Toward ‘A Small but Powerful’ Set of Regional Salmon Habitat Indicators for the Pacific Northwest executive summary, prepared for Pacific Northwest Salmon Habitat Indicators Work Group by the Green Mountain Institute for Environmental Democracy On line at

The purpose of the panel was to describe principles and examples of effective voluntary programs that will bring about measurable behavior change.

The Bottom Line
    • Endangered species listings provide a context for assistance programs, giving them focus and a hook for working with business.
    • Regional salmon habitat indicators will help agencies plan salmon recovery programs and track progress.
    • Don’t complain about measurement requirements. Measurement helps show that voluntary programs will achieve results in protecting resources, the programs’ central purpose.
    • Make sure there is a balance between measuring and doing—focus on doable actions. Carefully select metrics that provide useful information but don’t require a lot of resources for data gathering.
    • Learn how to market your services. Know what your audiences care about and speak their language. Avoid jargon and keep communication simple.

Dave Galvin: The general causes of salmon and steelhead declines are commonly described as the "4 H’s." The relative importance of each "H" varies from watershed to watershed. (A summary of the 4H’s is available at

Briefly, the 4 H’s cause the following impacts:

The National Marine Fisheries Service (NMFS) has three requirements for salmon recovery plans: substance, assurances and adaptability. Substance means the plans must be based on science and include specific recovery actions. Assurances mean there must be commitments in writing, with funding, to carry out those actions. Adaptability means the plans must include a monitoring component and be adjustable in light of new information.

Recovery plans must provide reasonable assurance that results will be achieved. Earlier this year, a federal magistrate ruled that NMFS improperly relied too heavily on voluntary measures in Oregon’s coastal salmon recovery plan. Measurement is necessary to convince NMFS that results will be achieved. Complicating the issue is that NMFS is unable to say specifically what measures will work in urban areas.

Endangered species listings are an opportunity for assistance programs to focus their work. The listings provide a context and a hook for working with business. Assistance programs can point to salmon recovery as a tangible and motivating end result of their work, because people throughout the region want salmon recovered.

Leslie Romer: A work group to develop regional salmon habitat indicators was put together in 1997 by EPA Region 10, Environment Canada, the four Northwest states and the province of British Columbia. The purpose of the project was to develop common indicators that could be used across the region to collect data, measure the effectiveness of agency programs, determine the condition of the Northwest environment, and to set environmental management priorities.

The group developed a list of 15 indicators covering fish abundance, water quality, water quantity, land use, and physical habitat. The value of the work is in planning projects and tracking progress. The set will not be implemented regionally in the near future, but in selected areas. Applied to the Snohomish River watershed, for example, the indicators showed varied conditions for one indicator, water temperature.

The indicators set will be a starting point for further discussions about issues such as the indicators’ technical characteristics, data gathering resources needed to support them, and implementation.

Mary Abrams: Salmon recovery is an opportunity to work closely with regulators and business, but there will be a great deal of oversight from courts and third parties. The court decision against the Oregon plan underscored the necessity of ensuring that recovery efforts, such as voluntary programs, will achieve results.

Incentives are a practical tool for effecting behavior change, but there are always going to be laggards that don’t change willingly. Technical assistance programs must remember that their mission is to protect the resource, not just help business become more efficient. In the context of salmon recovery, the goal is to ensure that businesses comply with environmental requirements and assure NMFS that assistance programs will lead to recovery. An important point to remember is that under the Endangered Species Act, permit issuers are liable for the actions permitted.

Non-point source pollution is the most important salmon habitat issue. From a fish habitat perspective, high water temperature and sedimentation caused by runoff and land use practices are considered pollutants, along with chemical discharges. In the Columbia Slough, the city worked with businesses to revegetate properties in order to prevent sedimentation and keep water temperatures cool.

Monitoring and measurement are essential. Complaints about measurement requirements are misguided. The goal of assistance is to protect public resources.

David McDonald: Pipers Creek is a small, urbanized watershed in northwestern Seattle. A watershed action plan was adopted in 1990 to stop non-point source pollution from entering the creek and to improve habitat conditions for salmon. The plan emphasized watershed awareness and pollution prevention education for business and households.

Lessons that were learned include:

A successful approach in Pipers Creek was combining enforcement with education. Programs should consider combining enforcement and technical assistance on field visits. Use education and recognition to effect behavior change, but the bottom line is that change must occur. Speak persuasively and carry a big stick.

In selecting indicators, programs should measure factors that can be influenced and track limiting factors that drive changes in the ecosystem. Examples of such factors are temperature and dissolved oxygen. Another useful indicator is tracking "benthic invertebrates" – worms, shellfish, insects and other creatures whose numbers and distribution signal a stream’s condition.

Ray Carveth: Limits on resources mean that enforcement efforts must be carefully targeted and leveraged. There is no way that enforcement agencies can keep track of every business that may create an environmental impact. There are 23 million businesses in the U.S., and 30 percent of them use hazardous materials. Ninety percent of businesses have 50 or fewer employees, and 75 percent of businesses have 7 or fewer employees. It’s impossible to collect large fines from small businesses, so other approaches to effecting behavior change are necessary.

In King County, there are 40,000 businesses that face hazardous waste compliance requirements, but the county can only conduct 3,000 inspections per year. Eighty percent of business startups will be dead in five years, so there is a continuing necessity to visit new businesses. To be effective in getting businesses to change behavior, assistance providers should study small business marketing textbooks. A suggested reading is Guerrilla Selling: Unconventional Weapons and Tactics for Increasing Your Sales, by Jay Conrad Levinson, Orvel Ray Wilson and Bill Gallagher.

Impacts of assistance programs are effectively communicated through stories that speak the language of the intended audience. For example, a company the King County Local Hazardous Waste Management Program worked with spent $260,000 per year to dispose of acids used in truck washing. While the company was in compliance with hazardous waste regulations, the county showed the company how to save on the disposal costs and remain in compliance by switching to detergent washing. Another example shows the value of leveraging limited enforcement resources by gaining the cooperation of property owners in dealing with tenants that are out of compliance. At a contaminated gas station in Seattle, for example, compliance was achieved quickly when the county notified the property owner, and the owner subsequently demanded that the tenant take care of the problem or lose the property lease.

Marketing is paramount if programs are to be effective. Remember the audience and communicate in language your audience understands. Politicians like stories about children, the elderly and saving money. Businesses relate to language about improving profits, building market share, and cutting avoidable costs. Too often, agencies communicate with government jargon and with detailed studies and statistics that are difficult to read. Politicians making appropriations decisions will pay little attention to statistics. Stories will win budgets more effectively than statistics will.

A question was raised on how programs can make a difference in stream water quality without statistically valid monitoring. Abrams responded that it’s not necessary to measure everything. The goal is streams that support life. Measure only what matters.

Galvin suggested finding a cross-cutting indicator, such as invertebrates. The beauty of such indicators is that volunteers can be trained to do the sampling and tallying. Biological data collected by volunteers will mean more for salmon recovery purposes than a million dollars worth of chemical sampling. Be creative.

Carveth said to remember the marketing potential with decision-makers funding the monitoring. Relying on schoolchildren to collect the data is a marketing gold mine. Assistance programs shouldn’t be shy about building support. Politicians will go along if environmentalists, trade associations and bureaucrats agree on a problem-solving approach.

McDonald recommended that assistance programs address issues in terms that relate to the concerns of your audience. For example, homeowners care about the health of their lawns and businesses care about their machines. Don’t compartmentalize assistance by air, water, or hazardous waste, because people don’t think in those terms.

Another question dealt with the relationship between NMFS and EPA. Abrams said that Region 10 Administrator Chuck Clarke and NMFS Regional Director Will Stelle are trying to develop pragmatic approaches to implementing ESA requirements. The ideal would be ensuring that both Endangered Species Act and Clean Water Act requirements could be met through the same recovery measures.

A question was raised about the risks of tying assistance programs to salmon recovery. What if the salmon don’t recover? Romer said political decisions are never based entirely on numbers. Abrams cautioned not to make fish returns the sole criterion for success. Habitat damage is not the only reason why salmon are declining. Remember the other three H’s that assistance programs have no control over.

Since there are many causes of salmon decline, there is a danger that blame finding and paralysis will stand in the way of action. Galvin said strong political leadership will be necessary to ensure that all four H’s are addressed together.



  John Bernardo
    Idaho Division of Environmental Quality (DEQ)

  David Kunz
    Oregon DEQ
  Kevin Masterson
    Oregon DEQ
  David Wigglesworth
    Alaska Department of Environmental Conservation (DEC)

Handout Available: Portland Metro Area Eco-Logical Business Program, presentation overheads
Idaho DEQ presentation overheads

The purpose of the session was to exchange ideas on motivating businesses to adopt P2.

The Bottom Line
    • Oregon DEQ uses a variety of tools, including incentives, enforcement and assistance.
    • The Eco-Logical Business program is working closely with business associations, and uses a "multi-media" approach covering all environmental bases to build credibility with business.
    • Alaska is exploring the use of incentives to encourage businesses to adopt P2. Pilot projects will tell which, if any, are attractive to businesses.
    • Presentation and language are critical. It’s all about marketing.

David Kunz: Pollution prevention is motivated by both compliance and financial concerns. Oregon is trying a number of approaches to facilitate P2 adoption. One is permitting that covers all media, including air, water and waste. For example, the Environmental Management Systems Incentives Program (EMSIP) will provide multi-media permits for companies implementing environmental management systems. (To learn more about this program, visit

Examples of technical and compliance assistance approaches include the Environmental Assistance Project (EAP) in Portland, P2 teams, roundtables, statute training, and amnesties. In the enforcement area, supplemental environmental projects (SEPs) are an option for promoting P2. SEPs can provide for implementing P2 planning or projects in lieu of penalties. Since 1994, 17 SEPs have been negotiated in Oregon, eight with P2 planning requirements. A pilot program to include P2 language in Notices of Non-Compliance began in August.

Kevin Masterson: The goal of the Eco-Logical Business program is to recognize businesses that adopt environmentally responsible practices. The program covers air, water and waste. DEQ works with other agencies to develop and operate the program. Businesses that qualify will be recognized for a three-year term, then will have to re-apply for recognition.

A pilot program with the auto repair industry is underway, and importantly, the agencies are working with the American Automobile Association, the Oregon State Public Interest Research Group (OSPIRG), and two auto service trade associations. A guidebook entitled Keep Shops in Tune is available. Application packets for Eco-Logical Business recognition include best management practices. Thanks to marketing by the trade associations, 50 packets have been requested so far.

Program results will be measured by counting number of businesses that qualify on their second or third attempts; number and types of best management practices that are implemented; and the number of technical assistance recommendations that are implemented.

Lessons learned include:

Barriers and problem areas include:

David Wigglesworth: The key questions Alaska is trying to answer are how to get businesses to think about environmental issues, and how to keep businesses that already are working on them to stay involved.

Through the Environmental Leadership Program, Alaska DEC is exploring incentive approaches, such as recognition, compliance assistance, tax credits, reduced fees, less frequent reporting, and expedited permitting for businesses that go beyond compliance in preventing pollution. Possible drivers for business participation are greater efficiency in dealing with environmental management issues, reduced costs, modified agency oversight, and public recognition. The attractiveness of incentives probably varies among different businesses. Pilot projects will tell.

Green Star is a recognition program for businesses that meet 12 of 18 standards covering energy, solid waste, and hazardous materials. In a study of participating businesses, the University of Alaska found that the motivators for taking part included cost reductions, improved public relations, customer relations, information exchange, internal morale, and community involvement. (To learn more about Green Star, visit

John Bernardo: Assistance providers must choose their language carefully. In working with agriculture, Idaho DEQ has found that the term "pollution prevention" is not attractive to farmers because "pollution" is a negative word. A better alternative might be for pollution prevention coordinators to call themselves "business improvement coordinators" or "efficiency gurus."

Marketing is critical. The P2 community must improve the marketing of its product by thinking of its audience’s needs. Doors will open if services are marketed skillfully. They’ll slam shut if they aren’t. A good example of a marketing blunder was GM’s introduction of the Nova automobile into a Spanish-speaking market. In Spanish, "no va" means "it doesn’t go."



Participants were asked to introduce themselves and answer the following question: "Besides more funding, what is No. 1 on your wish list of things that would help you serve your clients better?" Answers included the following:



  PPRC – 206-352-2050
    Madeline Sten,
    Cathy Buller,
  Ross & Associates – 206-447-1805
    Lane Nothman,

Participants engaged in a "mind-mapping" exercise to gather information on assistance services available in the Northwest, and to identify potential areas of collaboration. The exercise was posed as a scenario: a local assistance provider receives a call from a client in the metal fabrication industry concerned about a possible inspection related to Maximum Achievable Control Technology (MACT) standards for reducing hazardous air pollutants. What do you do to serve the client’s needs?

Information gathered in this session is being used to compile a directory of assistance services. The directory will be available as an electronic resource at a later date.



  PPRC – 206-352-2050
    Madeline Sten,
    Cathy Buller,
  Ross & Associates – 206-447-1805
    Lane Nothman,

  Mike Vogel
    Peaks to Prairies P2 Information Center
  Tom Neltner
    Indiana Department of Environmental Management
  Dennis Pearson
    Seattle City Light

Handout Available:Seattle City Light’s Case Study Evaluations: Measurement of Energy and Non-Energy Benefits, presentation overheads
Mike Vogel, presentation overheads

The purpose of this session was to exchange information on setting up practical, useful measurement systems that will document program results.

The Bottom Line
    • Measurement gives programs credibility, helps them engage audiences with a concrete story, and focuses efforts on specific goals.
    • Measurement is not as hard as it may seem. Keep measurement simple, know why you are evaluating programs, know what you need to measure, know whom you’re measuring for, and strive for impact.
    • Industrial customers are interested in cost reduction, productivity, and quality. To sell energy efficiency, tailor the sales pitch to the audience’s concerns.

Tom Neltner: Measurement is a continuing controversy in the P2 community. The Environmental Commissioners of the States (ECOS) considered a resolution to drop P2 core performance measures. In Neltner’s view, this is a step backward for P2 measurement. EPA should develop measures as guidance for the states. (For more information on ECOS, visit

P2 work is not easy to quantify, because the results can be intangible. However, politicians who make funding decisions pay more attention to anecdotes than to statistics anyway. For that reason, anecdotes are a useful measure of success.

While there is nervousness about distilling the results of assistance work into numbers, there are three benefits that measuring results provides to P2 programs:

An important aspect of the measurement issue is that there is no universally accepted definition of what pollution prevention is. For example, some states consider recycling to be P2. One question that arises is whether P2 should be thought of as a tool or as a final goal. Another wrinkle is a perception that voluntary programs are P2, but enforcement programs are not, even though P2 can be used as a compliance strategy. Additionally, some states don’t recognize that P2 is about business using resources more efficiently. Further, there are fears that if EPA adopts a definition of measurement, it will be cast in stone, whether it meets local needs or not. An important point to keep in mind is that your program has an ultimate public policy goal beyond its own existence.

In Indiana, P2 is built around tangible goals. For example, the state is seeking to reduce styrene emissions from fiberglass fabrication employed in the state’s recreational vehicle manufacturing industry. A combination of tools is being used, including enforcement, technical assistance, compliance assistance, and permitting. Only when all the tools are used together can pollution redution progress be made.

Overall, the Indiana program has two sets of measures, one for the Department of Environmental Management commissioner, the other for the Performance Partnership Agreement (PPA) with EPA. The PPA measures include the following:

When measuring, however, don’t overdo it. Indiana’s state-funded P2 institute documented the tons of pollutants reduced through P2 programs, and resulting savings to taxpayers and business. Having those numbers in hand almost backfired, because the state Legislature said it made the program look like corporate welfare. The lesson is to anticipate what lawmakers think about.

Above all, figure out measurement approaches that work. Without those numbers, P2 won’t be able to make its case as a business efficiency program. Don’t let the perfect be the enemy of the good, however, by worrying that your numbers may not be 100 percent accurate. TRI reports are close enough. Shades of grey are OK.

Mike Vogel: There is no one-size-fits-all measurement system, but often measurement is made more complicated than necessary. A quotation from Albert Einstein offers a helpful perspective: "Not everything that can be counted, counts. Not everything that counts can be counted." Legislators are interested in the bottom line, in terms of outcomes. Measurement gives concrete evidence to stakeholders about program impacts, both short-term and long-term. Evaluation also shows how the program functions, such as whether participants are those it is intended to serve, and how resources are being used.

Measurement is a process, not a one-time event. It should be performed continually, not just at the end of service delivery.

There are several approaches to measuring results, including "results mapping" by Kibel, Jacobs’ "ladder," Bennett’s hierarchy, and the Government Performance and Results Act, which applies to federal programs. (For a General Accounting Office guide to implementing GPRA, visit GPRA, however, doesn’t offer guidance as to how the requirements are to be met. There are several models setting forth the structure and functioning of measurement systems.

Bennett’s hierarchy was developed by Dr. Claude F. Bennett, an evaluation specialist with the Cooperative State Research, Education, and Extension Service, to evaluate extension services. Bennett’s hierarchy describes a spectrum for program evaluation, starting with resource inputs and concluding with results. The goal of any program is to get as high in the hierarchy as possible.

Tips to follow in designing measurement systems include:

Methods of gathering information include surveys, case studies, direct observation, journals and diaries, and benefit/cost analyses.

Dennis Pearson: Seattle City Light’s energy management services division has operated an industrial energy efficiency program since 1988. The program has served 81 customers, which have reduced electricity consumption by 57 million kilowatt-hours.

Industrial plants are interested in reducing costs, improving productivity and product quality, and environmental management. Energy efficiency is best sold by marketing the impacts that address an individual company’s concerns.

Using engineering estimates and metering, Seattle City Light evaluates efficiency projects to calculate energy consumption savings and reduction in the peak power demand a customer may impose on the utility. Where data are available, non-energy benefits of energy efficiency can be measured. Those benefits may include operations and maintenance cost reductions, production capacity increases, labor reallocation, reduced environmental impacts, and improved worker safety.

Tips to improve assessment of energy and non-energy benefits of efficiency projects include:

One question that arose in discussion is the role of estimates in preparing measurement reports. Vogel said estimates are acceptable because in some cases, it may be difficult to obtain precise numbers. In measuring dry cleaning solvent "mileage," for example, Neltner said his agency samples shops and asks perchloroethylene suppliers about sales reductions. Pearson pointed out that the necessary size of a survey sample depends on the amount of variability in the audience being surveyed.



  Lynn Vendinello
    EPA Office of Enforcement and Compliance Assurance (OECA)
  Chris Wiley

The purpose of the session was to share information about P2 and compliance assistance resources.

The Bottom Line
Numerous electronic resources are available for P2 and compliance assistance providers.

Lynn Vendinello: Nine virtual compliance assistance centers are on line to serve the needs of auto repair, metal finishing, printed wiring board manufacturing, printing, transportation, agriculture, paint and coatings, chemical processing, and local government sectors. The centers offer a variety of resources, including guides to federal regulations, technical databases, chat rooms, and vendor directories. (For more information on compliance assistance centers and links to them, visit

A measurement tool the centers use is on-line surveys, which help determine both who is using the centers and what behavior changes they have adopted. For example, metal finishers were asked to list five changes they implemented as a result of visiting the compliance assistance center. A total of 128 responded, and 87 reported they had adopted changes. Those who filled out a survey received a free screen saver. Those willing to participate in a focus group received a free mouse pad, and so far 300 have been given away.

The centers have been directed to become self-supporting. Trade associations may be approached to help support them. If industry doesn’t contribute, the centers will be closed, as each costs $300,000 per year to operate.

Chris Wiley: The Pollution Prevention Resource Exchange (P2Rx) is a network of nine regional P2 information centers that was established to give P2 assistance providers seamless access to high-quality, synthesized, and peer-reviewed information, and to avoid duplication. A key component of this project is standardizing information to improve its utility. The nine centers are currently collaborating on materials for the hospitality and metal fabrication sectors. Centers are taking the lead on certain sectors. For example, the center covering EPA Region 9 took the lead on hospitality, while the center covering EPA Region 1 took the lead on metal finishing. (For a directory of the P2Rx centers, visit

PPRC houses the regional center serving EPA Region 10. Resources available include:

Other helpful search tools and resources that assistance providers can tap include:



Discussion Leader:
  Dave Waddell
    King County LHWMP

The purpose of the session was to share favorite stories about technical assistance flops, and the lessons that were learned.

The Bottom Line

Stories and Lessons

The Herbicide Can on the Ground
Waddell agreed to visit a concrete sign manufacturer located in a potential aquifer protection area. The manufacturer had learned there was a possibility the facility would have to move, and asked for a field visit to show how well the facility is managed. The first mistake was agreeing to a visit in which those expectations had been expressed without clarifying that the agency cannot provide "absolution."

In meeting the foreman, Waddell asked about a herbicide container on a dirt floor that he had noticed. Annoyed, the foreman said the herbicide was used to prevent plant spores from contaminating concrete. That exchange got the visit off to a bad start and the foreman was upset for hours. During the visit, Waddell noticed a number of potential pollution problems, such as a 1,000-gallon tank of 25 percent hydrochloric acid that had deteriorating secondary containment. Company officials were furious when problems were detailed in a followup letter. Their expectation had been that Waddell would confirm their perception that the facility was responsibly managed.

Lessons Learned:

Airing Dirty Laundry in the Schoolhouse
The Alaska DEC was working with a school to develop curricula. One aspect of the project was showing children how to do site assessments. A report detailing site problems was written and sent to the teachers, principal and the school district administrator. Showing it to the administrator was a big mistake, because it damaged the department’s relationship with the teachers and principal. A better course would have been to show the report to the teachers and principal only, and work with them to resolve the problems.

Lesson Learned:

Leaky Berms Around the Plating Tank
A permit manager asked for berming around a metal finishing tank at a plating shop. The facility manager hand-mixed concrete and installed the berming himself but wasn’t aware the berms had to be sealed to be effective. As a result, liquid from the plating tank seeped beneath the berms.

Lesson Learned:

Money Didn’t Talk
Joe Junker of the Oregon Manufacturing Extension Partnership recalled a facility with a compressed air system that was poorly controlled, causing a great deal of energy waste. He proposed a more efficient system that would be paid for with a Bonneville Power Administration grant. The client wasn’t interested, despite the energy cost savings benefits. The time necessary to install the project and the resulting production disruption made the project unattractive to the client, regardless of the cost savings.

Lesson Learned:

Waddell said clients will have little interest in changing behavior or installing a project if they perceive the change will be a hassle. If possible, persuade them to try the change in small steps. Be sure to communicate the liability reduction benefits. Businesses understand liability, and environmental liability is one of the benefits to bring up in marketing. Another factor to consider in marketing a project is fear of the unknown.

Carolyn Gangmark said that relationship building is essential. A good marketing tool might be a simple means of showing the cost each day of delaying a P2 change.

Another issue that arose in discussion was what agencies should do if they notice a potential violation of regulations administered by other agencies, such as fire departments or occupational safety authorities. Waddell said that if a possible violation of such regulations is noticed, companies should be informed that there is a potential problem and be given referrals. Another approach is to inform property managers or lenders that their tenants or borrowers are incurring a potential liability. Usually, that approach is effective in getting a potential problem resolved and is faster than agency enforcement. Alaska DEC includes referrals in to-do checklists that visited companies are asked to return.

Another issue was what an assistance provider should do if an immediate hazard is observed. David Wigglesworth said assistance providers should act if they see an immediate danger, such as a fire hazard, but should be careful not to overstep their authority.

Waddell said the immediate hazard issue illustrates the need for assistance providers to be very clear on what they will and will not cover in their field visits.



NameOrganization TelephoneE-mail
Mary AbramsPortland Bureau of Environmental Services
Shirli AxelrodSeattle Solid Waste
Cynthia BaloghKing County LHWMP
Bruce Barbour WA Dept. of Ecology
Gary BarnesPortland Bureau of Environmental Services
John BernardoIdaho DEQ
Jon BiemerBPA
Vaughn BlethenEPA Region 10
JJ BrownEPA Region 10
Cathy BullerPPRC
Rosemary BusternaPSAPCA 206-343-8800
Ray CarvethKing County LHWMP
Alice ChapmanKing County LHWMP
Bart CollinsworthOregon DEQ
Fred ColvinDoelman Dairy 360-273-7379
Robin CongerPNL
Mary Jane CoombsWhitman College
Nancy CouchOregon DEQ
Charlie CunniffECOSS
Pete DalkeOregon DEQ
James DeMayWA Dept. of Ecology
Alice DeVaultNEBC
Catherine Dickerson PPRC206-352-2050
Jim DiPesoPPRC
Angus DuncanColumbia Pacific Institute
Dave DzurecNorthwest PETE
Tom EatonWA Dept. of Ecology
John EricksonWA Dept. of Ecology
Rondi FeltonPortland BES 503-823-7740
Marianne Fitzgerald Oregon DEQ503-229-5946
Kathy FletcherPeople for Puget Sound
Dave GalvinKing County LHWMP
Carolyn GangmarkEPA Region 10
Ken GrimmCapital Industries 206-762-8585
Carrie HansonWhitman College
Gil HargreavesOregon DEQ
Tom HonadelOregon DEQ
Dawn HottenrothPortland BES
Jeff HuntEPA Region 10 206-553-0256
Dennis JohnsonWA Dept. of Ecology
Joe JunkerOR MEP
Judy KennedyWA Dept. of Ecology
Ron KreizenbeckEPA Region 10
David KunzOR DEQ
Dennis LazzarEPA Region 10
Eric MarchegianiAK Rural Energy
Kevin MastersonOregon DEQ
David McDonaldSeattle Public Utilities
Dennis McLerranPSAPCA
Holly MerglerConcurrent Technologies
Dave MiskoWA Dept. of Ecology
Nancy MoorePNL
Tom NeltnerIN Dept. of Env. Mgmt.
Lane NothmanRoss & Associates
Margaret NoverPortland BES
Hugh O'NeillWA Dept. of Ecology
John PalmerEPA Region 10
Rob PenneyWSU Energy Extension
George PerryKing County LHWMP
Dave PisarskiIdaho DEQ
Martha ProthroRoss & Associates 206-447-1805
Keith RitalaUW Washington Technology Center
Leslie RomerWA Dept. of Ecology
Laura SchleyerWA Dept. of Ecology
Paul StaschWA Dept. of Ecology
Madeline StenPPRC
George SutherlandWA MEP
Kathleen VeitEPA Region 10
Lynn VendinelloEPA OECA
Gwen VernonCascadia Consulting 206-343-9759
Mike VogelPeaks to Prairies P2 Information Center
Dave WaddellKing County LHWMP
Craig WeckesserOAPCA
David Wigglesworth Alaska DEC907-269-7582
Chris WileyPPRC
Elliot ZimmermanWA Dept. of Ecology



Updates and Background Materials

Alaska Department of Environmental Conservation
Program Update
David Wigglesworth, 907-269-7582,

EPA Office of Enforcement and Compliance Assurance
Compliance Assistance Tools booklet
Lynn Vendinello, 202-564-7066,

EPA Office of Pollution Prevention and Toxics
Program Update
Julie Shannon, 202-260-2736,

Idaho Division of Environmental Quality
Program Update
John Bernardo, 208-373-0114,

Industrial Technical Assistance Providers
Various energy assistance program brochures
Rob Penney, 360-956-2053,

King County Local Hazardous Waste Management Program
Program Update
Cynthia Balogh, 206-689-3075,

Oregon Department of Environmental Quality
Program Update
David Kunz, 503-229-6237,

Pacific Northwest Pollution Prevention Resource Center
Program Update
Madeline Sten, 206-352-2050,

Portland Bureau of Environmental Services, P2 Program
Program Update
Clean River Works brochure
P2 Week Resolution
State of Environment Report description
Margaret Nover, 503-823-7623,

Washington Department of Ecology
Program Update
"Pollution Prevention & Compliance Success Through Technical Assistance"
Judy Kennedy, 360-407-6744,

Presentation Materials (In agenda order)

The Challenge: What Is Expected of Assistance Providers

U.S. Postal Service
Presentation overheads
Sydney Randell, 206-625-7004,

Making Voluntary P2 Approaches Effective for ESA Compliance
Pacific Northwest Salmon Habitat Indicators Work Group
"Toward ‘A Small but Powerful’ Set of Regional Salmon Habitat Indicators for the Pacific Northwest"
Presentation overheads
Leslie Romer, 360-407-6998,
Seattle Public Utilities
Natural Lawn Care
David McDonald, 206-684-7650,
Motivating Business: Tips and Tools
Idaho Division of Environmental Quality
Presentation overheads
John Bernardo, 208-373-0114,
Oregon Department of Environmental Quality
Eco-Logical Business Program overheads
Kevin Masterson, 503-229-5615,
Measuring Results: Current and Emerging Approaches
Peaks to Prairies P2 Information Center
Presentation overheads
Mike Vogel, 406-994-3451,
Seattle City Light
Presentation overheads
Dennis Pearson, 206-684-3254,

Compiled by the Pacific Northwest Pollution Prevention Resource Center, 513 First Ave. West, Seattle, WA 98119
phone: 206-352-2050, fax: 206-352-2049, e-mail:, WWW address:

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