256 



fectiveness are much more important than removal efficiency or technological so- 

 phistication. 



Third, technologies developed for end-of-pipe treatment generally have little to do 

 with technologies developed for cleanup of contaminated sites, which in turn have 

 little to do with technologies developed to prevent pollution. We must be realistic in 

 our expectations and clear in our intent. 



Pollution Prevention and Control Technology 



One of the most encouraging developments of the past few years has been the 

 emergence of pollution prevention or waste reduction. Former EPA Administrator 

 William Reilly undertook an important initiative in stressing pollution prevention 

 and encouraging many voluntary efforts in companies across the country. A grow- 

 ing number of companies are accepting the twin premises that a healthy economy 

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

 economy. 



A number of leading companies have transformed the concept into a new business 

 approach. Companies such as 3M, DuPont, Dow Chemical, Polaroid, and AT&T have 

 adopted innovative pollution prevention programs and are demonstrating that these 

 efforts can even improve their bottom line. In another report of the Carnegie Com- 

 mission on Science, Technology, and Government, it was stated, "Waste reduction 

 and energy efficiency are complementary and make good economic sense. Preven- 

 tion of pollution can often pay for itself through reduced demand for inputs, reduc- 

 tion in waste disposal and liability costs, and other means. Indeed, achieving reduc- 

 tions in production of waste or the amount of energy required by waste-producing 

 industrial processes can contribute significantly to the competitiveness of U.S. in- 

 dustries." 2 



In providing pollution prevention services to manufacturers across Northern 

 Ohio, we at CAMP view the approach as extending the Continuous Improvement 

 Process — one of the best ideas to come from Japan — to help our companies become 

 more competitive. One thing we have learned from our companies is that pollution 

 prevention has little to do with environmental control technology — as we have 

 known it to date. In fact, the best mesisure of success in pollution prevention is that 

 pollution is never produced in the first place. 



Technology often plays a major role in avoiding pollution generation, but not as 

 an after-the-fact, end-of-pipe treatment. New production processes may be used; ex- 

 isting processes may be retuned and closely monitored; feedstock substitutions may 

 stop creation of bjrproducts. How will these promising new approaches which may 

 significantly reduce pollution with a cost savings be factored into a major push for 

 environment control technology? Given EPA's traditional reliance on end-of-pipe 

 treatment technologies, the answer is not obvious to me. 



To illustrate my concern, I should mention the impatience of some in the regula- 

 tory community with the pace of pollution prevention. Notwithstanding the fact 

 that most manufacturers have suffered from the recession and slow growth of the 

 p£ist two years, some environmental officials seem to be frustrated that companies 

 aren't moving faster to implement pollution prevention. At several national meet- 

 ings, I have heard the sentiment "Since voluntary pollution prevention efforts 

 aren't working fast enough, then let's write some regulations requiring companies 

 to reduce their wastes" expressed several times. Regulations mandating pollution 

 prevention will quickly kill most of the excellent voluntary programs that are ac- 

 complishing so much. This is not an ideological statement. Pollution prevention has 

 to be driven by good economics and detailed knowledge of manufacturing processes, 

 not by overly restrictive r^ulations written by laypersons. 



Commercialization of Environmental Control Technologies 



Finally, I would like to comment on the special challenges confronted in commer- 

 cializing environmental control technology. 



Usually technologies are invented and commercialized by entrepreneurs and en- 

 terprises with the intent of making profits. The risk takers who invest in the re- 

 search, development, manufacturing, marketing, and sales of the new products 

 expect a reasonable and timely return on their investments. One of the major fac- 

 tors in whether an individual, venture capital fund, or company decides to invest is 

 the amount of uncertainty — market response, market size, actual cost of develop- 

 ment, time required to complete development, poorer performance of the technology 

 than anticipated, etc. High uncertainty is high risk. And higher risk demands 

 higher returns or no deal. 



Since it may not be obvious to some, it should be stated that most environmental 

 control technologies are created in response to regulations. Since they are regula- 

 tion-driven rather than market-driven, a new uncertainty variable enters the pic- 



