command and control regulation in action
Post on 05-Feb-2016
43 Views
Preview:
DESCRIPTION
TRANSCRIPT
Command and Command and Control Control Regulation in Regulation in ActionAction
Regulating Industrial Regulating Industrial Water Pollution in the Water Pollution in the
USUS
Clean Water Act of 1972Clean Water Act of 1972
Sets national goals as zero-Sets national goals as zero-discharge of pollution by 1985discharge of pollution by 1985
2 Main Policy Tools2 Main Policy Tools Construction grants programConstruction grants program $$ $$ Technology based regulations for Technology based regulations for
discharge of water pollution from discharge of water pollution from point sourcespoint sources
National Pollutant National Pollutant Discharge Elimination Discharge Elimination SystemSystem
EPA- establishes Federal Effluent EPA- establishes Federal Effluent GuidelinesGuidelines
States– States– write,monitoring, and enforce write,monitoring, and enforce NPEDS permitsNPEDS permits
Main TargetsMain Targets Biochemical oxygen demand (BOD)Biochemical oxygen demand (BOD) total suspended solids (TSS)total suspended solids (TSS) 15 pollutants of concerns, (metals i.e. 15 pollutants of concerns, (metals i.e.
arsenic and mercury) arsenic and mercury)
POTW publicly owned POTW publicly owned treatment workstreatment works
POTWPOTW
POTWPOTW
Tech RegulationTech Regulation Primary treatment (skimming, Primary treatment (skimming,
screening, settling)screening, settling) 65% 65% Secondary treatment - 80-90% Secondary treatment - 80-90% Criteria on uses for sludgeCriteria on uses for sludge ensuring effective operation and ensuring effective operation and
maintenancemaintenance
Direct Discharges from Direct Discharges from Industrial PlantsIndustrial Plants
Direct Discharges from Direct Discharges from Industrial PlantsIndustrial Plants
EPA EPA guidelines for 30 designated guidelines for 30 designated industriesindustries
best practicable technology by best practicable technology by 19771977
Best Available Tech by 1983Best Available Tech by 1983 New Source Performance New Source Performance
Standards Standards
ComplexityComplexity
Dairy StandardsDairy Standards Different standards for subcategoriesDifferent standards for subcategories Acceptable pollutant discharge rates varyAcceptable pollutant discharge rates vary BOD 30 day standard for large facilities BOD 30 day standard for large facilities
Butter .55kg per 1000 kg of BOD input; Butter .55kg per 1000 kg of BOD input; Cottage cheese 2.6, Ice bream 1.84, Cottage cheese 2.6, Ice bream 1.84, Condensed Milk 1.38, Dry Milk .65Condensed Milk 1.38, Dry Milk .65
Separate limits for one day maximum Separate limits for one day maximum discharge, 30 day average, for small and discharge, 30 day average, for small and large facilities. large facilities.
Indirect discharges from industrial Indirect discharges from industrial
plantplant
Industrial plants to POTWIndustrial plants to POTW Pretreatment guidelinesPretreatment guidelines
Rulemaking ProcessRulemaking Process Information Requirements Information Requirements
Writing of direct discharge standardsWriting of direct discharge standards How to operationalize best, practicable, How to operationalize best, practicable,
economically achievableeconomically achievable Need information on production techniques, Need information on production techniques,
location, waste products, and waste treatment location, waste products, and waste treatment techtech
heterogeneity --360 industrial subcategories heterogeneity --360 industrial subcategories among first 30 industries requiring effluent among first 30 industries requiring effluent guidelinesguidelines
separate BPT, BAT, NSPS< and pretreatment separate BPT, BAT, NSPS< and pretreatment regulationsregulations
Rulemaking ProcessRulemaking Process
Role of consulting firmsRole of consulting firms Proposed standards, industry Proposed standards, industry
commentcomment 250 lawsuits 250 lawsuits
Regulatory OutputRegulatory Output
BPT - 1 yearBPT - 1 year BAT standards – 1/3BAT standards – 1/3rdrd done by done by
19951995 Zero Discharge – still waitingZero Discharge – still waiting
Abatement CostsAbatement Costs
Big variation in incremental costsBig variation in incremental costs Estimate of costs > than actualEstimate of costs > than actual
ComplianceCompliance
Assumption- Assumption- 97% reduction in discharge 97% reduction in discharge of priority pollutantsof priority pollutants
Compliance – mixedCompliance – mixed 6% of major direct dischargers -significant 6% of major direct dischargers -significant
noncompliancenoncompliance % of US served by POTWs increases from % of US served by POTWs increases from
42% to 74%42% to 74% POTW pretreatment- POTW pretreatment- 54% of significant 54% of significant
indutstrial users were in significant indutstrial users were in significant noncompliancenoncompliance (1992) (1992)
But is the water cleaner?But is the water cleaner?
Some big successes- Potomac, Some big successes- Potomac, DelawareDelaware
Lack of data, Lack of data,
Perverse IncentivesPerverse Incentives
Expansion of POTW Construction Expansion of POTW Construction Grants Program Grants Program
shift from direct discharge towards shift from direct discharge towards indirect dischargeindirect discharge
top related