Evaluation of the Effectiveness of Pollution Prevention Planning in NJ

I. Introduction
This study evaluated the effectiveness of pollution prevention planning required under the New Jersey Pollution Prevention Act of 1991. The Act requires facilities in certain industries to prepare facility-wide pollution prevention plans and submit plan summaries and progress reports to the New Jersey Department of Environmental Protection (NJDEP). Facilities had not yet completed progress reports at the time of this study, so the analysis focused on the pollution prevention plans. In brief, the study examined whether reporting facilities have set higher goals for reducing their use and nonproduct output (NPO) of toxic chemicals as a result of the planning requirements set out in regulations under the act (section NJ 7: 1K-4.3 to 4.5). The study also looked at the completeness and quality of facilities' pollution prevention plans as indicators of effectiveness. A study to be completed in Summer 1996 will examine pollution prevention accomplishments in the first year of facilities' five year plans.

Specifically, the analyses fell into four broad categories:

• Elements of the plans. How effective were individual components of the planning process that are specified in the rule and guidance documents - such as process-level materials accounting, cost analyses, grouping and targeting - in terms of completing plans and setting goals?
• Previous planning and reduction activities. How did the facilities' plans fit into the context of reduction projects and planning activities they had undertaken before planning was required?
• Pollution prevention goals. Did planning result in greater reduction goals than would have been set without required planning?
• General outcomes of planning. Was planning more effective at facilities generating greater amounts of NPO? Did facilities find the process to be worthwhile, and if so, what benefits did they obtain? Did they find cost savings, and how much time and money did planning require? What other light can planning shed on pollution prevention in general?

Hampshire Research Associates, Inc., (HRA) visited 48 facilities from April to June, 1995, to examine the facilities' pollution prevention plans. New Jersey Department of Environmental Protection (NJDEP) staff visited 67 additional facilities from January to June, 1995. On site, both teams conducted two reviews of the facilities' pollution prevention plans - an Administrative Review to itemize contents of the plans and a Plan Quality Review to identify more particular features of the facility's plan.

HRA and NJDEP also interviewed facilities about previous environmental activities and facility attitudes toward planning, using an additional questionnaire developed separately by HRA and NJDEP. NJDEP made available some of its data on prior activities and facility attitudes toward planning for this study. Other data incorporated in this study include information from the facilities' plan summaries, which are submitted to NJDEP, and state and federal environmental reporting data such as New Jersey's DEQ-114 and the U.S. TRI Form R.

For its analyses, HRA developed a set of factors that could influence pollution prevention planning. Factors include specific elements of pollution prevention plans, aspects of planning and previous activities, and facilities' reactions to the planning process. The factors were used to examine four measures of the effectiveness of the planning process: plan completeness, plan quality, projected use reduction goals, and projected NPO reduction goals. To assess the effectiveness of pollution prevention planning requirements, HRA subjected the factors to a statistical correlation analysis of their association with the four measures of the results of the planning process. (Factors and measures appear in Box 1.)

HRA also examined reduction projections that facilities made prior to developing their plans. Hampshire reviewed the facilities' 1991 and 1992 DEQ-114 forms, where they were required to project reductions in NPO due to source reduction for the next five years, and compared those projections to the reduction goals resulting from pollution prevention planning.

Finally, HRA conducted an in-depth analysis of responses to its questionnaire on previous environmental activities and on facility perceptions of the planning process.

Where data collected by HRA and NJDEP overlap, HRA included as many facilities as possible in the analysis. Thus, questions on plan contents were analyzed using 115 facilities (HRA's 48 plus NJDEP's 67), while analyses of questions on previous activities used only HRA's 48 facilities, unless NJDEP provided data for that specific question. Since HRA could also examine reduction projections made on state reporting forms for all facilities, the analysis of reduction projections before and after planning covered all facilities that have submitted a plan summary to NJDEP, a total of 405.

Findings for facilities that HRA visited are consistent with those for facilities visited by NJDEP. The results of this evaluation were not affected by the choice of sample set, except that some of the tendencies in smaller samples were found to be statistically significant when analyzed with the larger sample.