Can voluntary pollution prevention programs make an impact?

Last year in Virginia, more than 450 facilities reported impressive environmental and economic performance: a combined savings of over $107 million. Energy use was reduced by 676,424 MMBtus, waste disposed was reduced by over 32,000 tons and total water usage went down by over 2.5 billion gallons.

What’s even more impressive is that those companies achieved the savings through a program run by the Virginia Environmental Excellence Program (VEEP), run by the state Department of Environmental Quality (DEQ). Companies must apply in order to participate. All facilities also must have a sustained record of regulatory compliance.

VEEP’s mission isn’t to set goals for a facility to meet, but to help a facility meet its self-defined goals. Participants aim for continuous improvement of its environmental performance. No predetermined goal must be reached to complete the program.

Luck Companies, one of the nation’s largest producers of crushed stone, sand and gravel, was one of the first members to join the VEEP program. Its quarry division has 19 facilities. 

“The most important advantage of the program is the close relationship that has developed between our facilities and the regional offices of DEQ," said Mark Williams, environmental manager for Luck Companies. "The ideas that we share with other members and the staff at the (DEQ) Central Office have saved us energy, fuel, water and money."

The 13-year-old program organizes the companies it works with into three tiers based on the robustness of its Environmental Management System (EMS): Environmental Enterprise (E2), Exemplary Environmental Enterprise (E3), and Extraordinary Environmental Enterprise (E4) for the most sophisticated systems.

To become a member, a facility must have an EMS equivalent to the level for which it is applying. The E2 level only needs a few basic components focused on environmental improvement. The E3 level needs to have a fully implemented EMS and E4 facilities must have a third-party certified EMS, must document environmental outreach efforts and must have adopted a commitment to sustainability. 

Once a facility’s application and compliance record meet VEEP requirements, the facility must report annually on at least one, two or three commitments for E2, E3 and E4, respectively. It is required to report on these commitments for three consecutive years. After three years it must reapply to the program. Usually this improvement is incremental. Facilities are encouraged to report on more than the minimum commitments, and many do.

Over the years, DEQ has developed an online reporting system that helps track actual and normalized data. The system was developed with stakeholder input so as best to be able to capture and represent data. It is regularly updated.

But over time, voluntary environmental programs that fail to help improve environmental performance often fall prey to entropy at participating companies. Facility priorities or personnel can change. In order to avoid complacency, VEEP facilities submit an annual report about participants' progress. DEQ staff review and approve the report.

The report includes numerical data on reporting commitments such as air emissions, water conservation and energy use, and narratives on awards won, EMS progress and possible compliance issues. Reports that lack continuity are flagged and the facilities are contacted. 

Those facilities at the E3 or E4 level get more attention: Aside from the annual reporting, any facility joining VEEP at the E3 or E4 level receives a non-regulatory visit from DEQ staff. During the visit, a facility walk-through aims to identify pollution prevention opportunities. The walk-through is also a time to share environmental success stories. DEQ staff like to keep in touch with members and if they are not showing progress, DEQ provides assistance to get facilities back on track.

How does DEQ work with companies to meet their goals? At the E2 level, DEQ likes to think it helps a facility get on the path to environmental improvement by setting up some infrastructure (like the beginnings of an EMS) and helping to incentivize and streamline the process of tracking environmental efforts. At the higher levels, the program offers alternative compliance opportunities for facilities that often need regulatory flexibility for innovative environmental efforts.

Voluntary environmental programs often walk a fine line: Some are criticized for giving too much for too little. VEEP gives participants public recognition, a single point of contact at DEQ, some permit fee discounts and the opportunity for regulatory flexibility.

Over the years, stakeholders have helped refine the program by recommending benefits and assisting in redefining the program levels. As a result, last year a separate track called “Sustainability Partners” (SP) was added. The SP Track moves away from the EMS requirement and focuses more on not just a facility but also an entity’s commitment to environmental sustainability and performance. SP encourages a company to adopt environmental sustainability as part of its culture through leadership, innovation and continual improvement.

There are many benefits to both the business community and the state from these voluntary programs. Businesses get the technical assistance they need to make their operations more efficient, thereby saving money and reducing the use of resources. The recognition program acknowledges that extra effort and is important for a company’s public image. From the state’s perspective, it helps assure a better baseline of environmental performance. Both sides benefit from the networking opportunities the program creates.

Image of raised hands provided by bluelake via Shutterstock.