Meaningful Program Incentives

1. Meaningful Program Incentives Incentives To Encourage Performance Track Membership Harold Tilden Senior Environmental Policy Advisor October 27, 2008

2. Some Musings About Incentives Incentives aren’t likely to fully offset the cost of participating in Performance Track Improvements are often costly and, by definition, beyond regulatory requirements Incentives provide two key benefits to members A benefit unavailable to competitors (distinguished in marketplace) A tangible demonstration to management and stakeholders

3. What is “Meaningful”? Beauty is in the eye of the beholder But clearly, some relationship between the incentive and the ability to either (or both): Distinguish in the marketplace Demonstrate a difference Usually including some sort of cost savings

4. What’s Meaningful to PNNL? PNNL is a large Government (GOCO) research laboratory operated for DOE by Battelle Memorial Institute. Two current incentives are in use: Low priority for routine inspections Extended waste accumulation time Both provide a modest cost savings Extended accumulation also enables footprint reduction Current air/water incentives don’t fit with research Relationships, recognition, reputation are PNNL’s most valued benefits – not the regulatory incentives

5. Increasing Value of Existing Incentives Increased state/local collaboration to guide existing incentives through delegated programs to field implementation States don’t always adopt EPA incentives – why? Delegated programs wary of increased EPA oversight “Portability” of member benefits Can use member benefits at Battelle-owned facilities in Richland (50% of campus), but not at adjacent leased facilities or DOE-owned facilities occupied by PNNL (different EPA ID#s, some not contiguous) Unified facility ownership isn’t the goal – superior performance is

6. Structure of New Incentives Design to attract the types of facilities desired Many administrative requirements exist in the regulations that could be made into incentives without posing environmental risk Primary objection of many to incentives is increased risk Performance Track members are also a good potential testing ground for regulatory streamlining type changes EMS still assesses and addresses environmental aspects and impacts Already seeking innovation

7. Innovations of Interest to PNNL Expedited and simplified permitting and permit modifications Streamlined reporting Alternative approach for laboratory waste management Project XL for labs (40 CFR 262 Subpart J) Proposed rule – academic laboratories

8. MBA (Management), University of Oregon BS (Chemistry) cum laude, Seattle Pacific University Currently Senior Environmental Policy Advisor, Pacific Northwest National Laboratory Environmental regulatory policy and analysis PNNL unit and Hanford Site RCRA permitting Innovative modular RD&D permit for APEL facility EMS and Performance Track Technical Resource Formerly Environmental Protection Coordinator, Sacramento Municipal Utility District RCRA, TSCA, and CERCLA compliance and permitting manager Formerly held several positions with Riedel Environmental Services Performed contracted cleanups for EPA under Superfund and for private clients EWC/ACHMM co-Hazardous Materials Manager of the Year, 2006 CHMM since 2000 About Harold Tilden