49 



I would just like to make a couple of additional comments with 

 respect to the commercialization of environmental control technol- 

 ogies, because without commercialization, the technologies just end 

 up sitting on the shelf. Technologies are invented and commercial- 

 ized by entrepreneurs and enterprises with the intent of making 

 profits. The risk-takers are involved in all of the necessary func- 

 tions and expect to get a timely and reasonable return on their in- 

 vestments. 



But one of the major factors is whether an individual or venture 

 capital firm or private company decides to invest is the amount of 

 uncertainty, market response, market size, cost of development, 

 etc. High uncertainty is high risk and higher risk demands higher 

 returns or no deal. 



Well, since it doesn't seem to be obvious to all, most environmen- 

 tal control technologies are created in response to regulations. 

 They are regulatory driven, rather than market driven and, hence, 

 introduce a new variable into the picture. The uncertainty takes 

 many different forms, but most often it involves delays, will law- 

 suits cause the regulations to be delayed or sent back to the agency 

 for rework, will the Congress, through subsequent amendments, 

 changes the compliance deadline, etc. 



When there is a cost advantsige associated with the new control 

 technology, a company may well take on a project, as long as the 

 benefits which can come to that company outweigh all of the risk, 

 including the additional risk of the potential delays. 



One of the most encouraging developments over the last couple 

 of years has been the emergency of pollution prevention or waste 

 reduction. Former EPA Administrator William Reilly undertook 

 very important initiatives in this regard, and a growing number of 

 companies are accepting the twin premises that a heedthy economy 

 can be good for the environment and a healthy environment can be 

 good for the economy. 



Leading companies, such as 3M, DuPont, Dow Chemical, Polaroid 

 and AT&T, have adopted very innovative pollution prevention pro- 

 grams and are demonstrating that these efforts can improve their 

 bottom lines. 



Technology often plays a very major role in avoiding pollution 

 generation, but not as an after-the-fact end-of-pipe treatment. New 

 production process may be used, existing process may be returned 

 and closely monitored, feedstock substitutions may stop creation of 

 by-products. How will these promising new approaches, which may 

 significantly reduce pollution with a cost savings, be factored into a 

 major push for environmental control technology? Given EPA's 

 traditional reliance on end-of-pipe treatment technologies, this 

 answer is not obvious to me. 



Finally, I would just like to reiterate that regulatory uncertainty 

 hovers like a black cloud of commercialization of environmental 

 control technologies, and that is why I feel the bill introduced in 

 1992 by Senator Mikulski really does little to solve the problems. 

 There are some interesting features in that bill, such as the low- 

 interest loan fund which could supplement the supply of private 

 capital, but I feel that such a loan fund really would work much 

 more effectively within a department of the environment, where 

 there is a much greater likelihood that regulatory policy can be 



