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.

Summary
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 goals.

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 required.

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.

• A majority of facilities found planning worthwhile and found benefits beyond reduction goals and fulfilling regulatory requirements. These benefits 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.
  
  
• Process-level materials accounting was a successful (and, in many cases, new) planning tool in examining processes for reduction opportunities. 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 reduction goals.
  
  
• Some facilities appear to have set higher reduction goals than they would have without required planning, leading to an increased statewide total for use and NPO reduction goals. 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.
  
  
• Pollution prevention opportunities continue to be plentiful at facilities with pollution prevention plans and activities prior to the New Jersey requirements. 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 an option.
  
  
• The required cost accounting was not associated with greater pollution prevention reduction goals. 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.
  
  
• "Small facilities" benefited less from the planning process than larger facilities. Planning 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.
  
  
• Average costs of planning are lower than average savings identified by such planning. Facilities 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.