Hampshire Research Associates, Inc. * 9426 Forest Haven
Drive * Alexandria, VA 22309 * 703/683-6695
Evaluation of the Effectiveness of
Pollution Prevention Planning in NJ
A Program-Based Evaluation
- May 1996
Thomas E. Natan, Jr., Ph.D. - Catherine G. Miller, Ph.D. -
Bonnie A. Scarborough - Warren R. Muir, Ph.D.
New Jersey Contract Number: P39724
New Jersey Project Manager: Jeanne Herb
HRA Project Manager: Warren R. Muir, Ph.D.
This study evaluated the effectiveness of pollution prevention
planning required under the New Jersey Pollution Prevention
Act of 1991. Facilities in certain industries are required
to develop on-site pollution prevention plans and submit plan
summaries and yearly progress reports to New Jersey Department
of Environmental Protection (NJDEP). Since progress reports
data were not yet available, this study concentrated on facilities'
creation of their pollution prevention plans and reduction
Hampshire Research Associates, Inc., (HRA) visited 48 New
Jersey facilities, and NJDEP visited 67 to review plans and
administer questionnaires about the plans and the planning
process. HRA analyzed data for two sets of facilities, separately
and together, to determine whether reporting facilities set
higher goals for percentage reductions in their use and nonproduct
output (NPO) of toxic chemicals, as well as created better
plans, as a result of the planning requirements set out in
NJ 7: 1K-4.3 to 4.5 and NJDEP guidance (i.e., were the associations
between planning elements and increased reduction goals statistically
significant to the 95 percent confidence level). HRA also
analyzed data from all pollution prevention plan summaries
submitted to NJDEP (405 facilities) to compare facilities'
projections for NPO reduction before and after planning was
In general, planning appeared to be successful in leading
some facilities to identify new pollution prevention opportunities,
although not all aspects of planning were equally successful
and not all facilities benefited equally.
included inventories of processes that had not been previously
examined, greater understanding of processes, and a background/cost/benefit
framework to propose capital investment projects.
The heart of the New Jersey planning process - - attributing
NPO to individual sources within a process - - was key to
successful planning, especially in terms of setting higher
As a result of the planning
requirement, facilities examined processes that would not
ordinarily have been examined, investigated new reduction
options, and set reduction goals that far outstripped other
reduction projections made before planning was required.
On DEQ-114 forms submitted before the planning requirements
(1991 and 1992), average percent reduction goals ranged
from 4.1 to 7.8 percent. On their pollution prevention plan
summaries, facilities' projections averaged 20.0 percent
to 20.7 percent.
Facilities that had undertaken source reduction activities
prior to planning set greater percent reduction goals in
their plans than those facilities that reported undertaking
no previous source reduction activities, even though setting
no further pollution prevention goals in their plans was
Since most facilities did not perform a cost
analysis, as specified in the planning rule, the cost analysis
requirement could not achieve its purpose. In addition,
facilities that did undertake the full cost analysis did
not appear to benefit more than those that did not, in terms
of creating a better plan or greater reduction goals.
appeared to be less effective for facilities with smaller
amounts of NPO, since these facilities set lower percent
use reduction goals than facilities generating greater amounts
of NPO. Many are reluctant to "tamper" with operations
that are running well and are profitable, even though small
reductions in NPO generation can provide cost savings.
that could estimate their costs spent an average of $35,000
on planning activities, and the cost per facility drops
to $13,000 when calculating planning costs using an average
salary and time figures provided by facilities. At the same
time, facilities that predict cost savings from their actions
to reduce use and NPO expect to save an average of $116,000
per year, including facilities that had not estimated actual
savings. The average annual savings is $66,000 for all facilities
that were able to state that they would or would not save
money through planning.