CORPORATE ENVIRONMENTAL PERFORMANCE AND THE EFFECTIVENESS OF GOVERNMENT INTERVENTIONS
FY 2000 Science to Achieve Results (STAR) Program
NATIONAL CENTER FOR ENVIRONMENTAL RESEARCH
CLOSED: FOR REFERENCE PURPOSES ONLY
Opening Date: April 10, 2000
Closing Date: July 24, 2000
Motivations Behind Regulated Entities? Environmental Behavior
Effectiveness Of Government Interventions On Environmental Compliance And Performance
Desirable Research Characteristics
Relationship to Current EPA and DOJ activities
Instructions for Application Submission
Additional Requirements: Policy Relevance
Additional Requirements: Data Development
The Environmental Protection Agency (EPA) Office of Research and Development, National Center for Environmental Research (NCER), with the cooperation of the Department of Justice and the National Institute for Justice (NIJ), announces a new extramural grants competition supporting research in the areas of corporate environmental performance and the effectiveness of government interventions on performance and compliance with environmental regulations (Environmental Performance and Interventions, or EP&I).
Note: EPA has supported similar socio-economic research in prior years through the EPA/NSF joint program on Decision-making and Valuation for Environmental Policy. This year, subject to available funding, EPA also plans socio-economic solicitations addressing valuation of children's health and market mechanisms and incentives. Information on announcements and awards made in these competitions may be found on the Internet. NIJ has sponsored similar competitions with respect to compliance with other areas of the law. Information on similar NIJ competitions may be found on the Internet through: http://www.ojp.usdoj.gov/nij/funding.htm
Awards made through this competition will be dependent upon the responsiveness of proposals to the announcement, the quality of the proposed research, and the availability of funds. EPA anticipates making up to about $1 million available for Environmental Performance and Interventions research. The projected range is from $50,000 to $200,000 per award per year, with durations from 1 to 3 years. Proposed research can be retrospective or prospective, with prospective field experiments, survey research, and multi-investigator projects more likely to justify the higher funding level.
Proposals in response to this announcement must be received by July 24, 2000. It is anticipated that awards will be made by Fall/Winter 2000.
The following are definitions of some of the terms used in this solicitation, which are intended only to clarify the present use of these terms.
Environmental performance: the physical environmental results of actions taken by regulated entities, i.e., quantities and concentrations of air emissions, water discharges, waste generation and on- and off-site health and environmental risks posed by industrial or chemical management processes. Environmental performance may exceed or fall short of performance standards established by laws or regulations. Performance is affected by pollution prevention and abatement activities.
Environmental Behavior: actions taken by regulated entities to improve or worsen environmental performance or compliance with environmental statutes or regulations.
Compliance: achievement of environmental standards set by law or regulations.
Deterrence: the motivation of regulated entities to comply with environmental laws and regulations through consideration of the government-induced consequences of violating these laws or regulations.
Compliance assistance: information and technical assistance provided to the regulated community to help it meet the requirements of environmental laws.
Compliance incentives: policies that provide positive incentives to regulated entities to voluntarily discover, disclose and correct violations or clean up contaminated sites before they are identified by the government for enforcement investigation or response. Compliance incentives may also promote superior environmental performance.
EPA and DOJ/NIJ are interested in supporting research that (1) identifies the determinants, or motivators, of regulated entities? environmental behavior and performance, and (2) assesses the influence of various governmental interventions on this behavior/performance. Better understanding of these issues is needed to help federal, state, tribal and local governments effectively allocate resources to achieve the greatest degree of environmental and health protection and improvement. This understanding is hampered by a lack of empirical data on the motivations influencing corporate environmental behavior and the effectiveness of a range of government interventions. This is particularly important as a number of new initiatives, such as government-business partnerships, requirements for expanded environmental information, voluntary standards and compliance assistance programs have been initiated in recent years. These initiatives have been proposed as alternatives to traditional enforcement, yet their impacts on overall environmental performance remain uncertain. Therefore, research is critical that will create data sources and examine the effectiveness of both traditional and alternative environmental implementation approaches on regulated entity behavior.
The two principal topic areas, (1) identification and analysis of the motivators of regulated entities? environmental behavior and performance and (2) assessment of the influence of government interventions on environmental compliance and performance, are addressed in separate sections below, although there are significant overlaps between the two.
Interested researchers should note that EPA recently sponsored a separate solicitation entitled, Market Mechanisms and Incentives for Environmental Management (MM&I). That RFP addresses approaches that rely on market forces, financial mechanisms, or other instruments to encourage regulated entities to reduce emissions or improve environmental performance. To avoid redundancy, research proposed in response to the present RFA should focus more directly on the motivations behind corporate environmental behavior and the effects on this behavior of government interventions cited in this solicitation.
Various authors have noted the importance of a number of motivators of regulated entities? environmental behavior and performance, including costs, firm profitability, corporate or industry culture, geography, competitive environment, technological capability, and government interventions. However, motivations are not the same for all firms and facilities that generate or discharge pollutants into the Nation?s water, land and air. Fundamental behavioral, economic, management science, legal and other social science research is needed to better understand how different individuals, companies and facilities respond to various influences and combinations of influences, including governmental interventions.
For virtually all regulated entities, the cost of pollution prevention or abatement is a factor in determining how much pollution to control, as is the availability of expertise to manage pollution control systems. The specific roles of costs and capability may differ among firms in a predictable manner. Factors other than pollution control costs or technical capability may also affect a firm?s performance. Significantly, most regulated entities are concerned with the consequences of not meeting environmental standards for a variety of reasons, including legal and monetary penalties. In other cases, firms seem to embrace the notion of pollution prevention because pollution represents a waste of resources and preventing it saves money on production factors. Others may be more responsive to community pressure resulting from publication of information on plant emissions. Still others may have a corporate environmental stewardship ethic that encourages environmentally beneficial behavior beyond legal requirements. What makes some firms go beyond regulatory requirements, while others do only the minimum to meet the letter of the law, if that? How do different firms respond to the threat of sanctions? Research can determine if responses to some or all of these factors vary consistently with firm type, size or other characteristics, which can help direct resources to address specific problems.
In summary, EPA has a particular interest in two basic research questions:
1. What determines environmental behavior or performance and compliance with environmental laws and regulations?
2. What are the relationships between environmental compliance behavior and performance, and facility or business characteristics such as management structure, size, profitability, corporate policies, etc.?
Examples of research topics that address one or more of these questions include:
What motivates companies to monitor, dissuade and punish poor environmental performance by their own facilities or non-compliant behavior by their employees?
What motivates firms to attain environmental performance beyond that required by regulation?
What organizational characteristics (e.g., centralized or decentralized environmental compliance responsibility) foster improved environmental performance and compliance?
What (non-governmental) financial incentives exist to encourage compliance? Does pollution prevention really pay? How and in what circumstances do environmental compliance and performance contribute to the bottom line?
How does public involvement in corporate activities, or disclosure of environmental performance information affect environmental performance, i.e., are corporate decision making frameworks that involve the public, or release of information to the public, conducive of improved environmental performance or better compliance?
In economic terms, the effect of government intervention either can be to increase the cost of poor environmental performance through fines, penalties and sanctions, or to decrease the cost of improved environmental performance through such activities as technical compliance assistance and incentives. Government interventions that influence polluter behavior, encourage compliance, and/or deter violations of existing rules include: inspections and monitoring; civil and criminal enforcement; warnings; penalties and injunctive relief; technical and compliance assistance; public notification of violations, releases, or emissions levels; and the provision of various incentives, among others. Activities such as inspection and monitoring by public agencies affect the probability that a facility will experience extra compliance-related costs (such as penalties) and the course of intervention that the regulatory agency will pursue. The combination of some or all of these factors influences the degree to which compliance with rules or environmental performance will be achieved.
Different intervention strategies may be appropriate for different circumstances (i.e., intentional vs. unintentional non-compliance, or small businesses with low levels of expertise vs. large businesses with substantial capability). Research is needed to explore the influence and effectiveness of different interventions under a variety of conditions and business characteristics (e.g., compliance assistance for capability-challenged firms or increased sanctions for repeat violators). State, federal, local and tribal agencies need to better understand the circumstances under which different environmental performance enhancement strategies will best achieve environmental goals.
EPA and NIJ have a particular interest in several basic questions on the effects of government interventions on environmental behavior and performance:
What are the effects of compliance assurance measures (e.g., penalties, inspections, and enforcement) on: (i) compliance with regulatory requirements; and (ii) environmental performance beyond regulatory requirements? What compliance assurance approaches are appropriate for different corporate characteristics and situations?
What is the effect of the disclosure of environmental performance information on corporate environmental performance? If information disclosure results in behavioral change, what are the pathways that induce such change, e.g., internal communication, liability concerns, stock prices, community relationships, etc.
What are the effects of compliance assistance measures (e.g., technical assistance, education) on: (i) compliance; (ii) environmental performance beyond regulatory requirements? What compliance assistance approaches are appropriate for different corporate characteristics and situations?
What is the comparative effectiveness of various intervention strategies on compliance and environmental performance for different types of corporations and situations? What are appropriate measures of effectiveness for each of these strategies?
Examples of relevant research questions:
What characteristics determine how people and organizations respond to the threat of sanctions? Do penalties have any deterrent effect? Do larger penalties have a greater deterrent effect (specific or general) than smaller penalties?
How does disclosure of violations or emissions to the public improve environmental performance or compliance, either through market mechanisms (e.g., declining stock prices in response to pollution liability fears, or perceptions that eco-efficiency is related to profitability), or increased liabilities (e.g., torts; citizen suits; cleanups), adverse publicity, community pressure (community right-to-know)? How does public disclosure of violations or emissions interact with enforcement and compliance assistance? Does increased visibility of environmental noncompliance decrease detection costs or increase deterrence?
What enforcement strategies would maximize general deterrent effects (i.e., compliance among entities who are not immediate enforcement targets)? Is the general deterrent effect of an enforcement action greater within the same local area or industry?
What is the deterrent effect of criminal enforcement? Does the availability of criminal penalties affect compliance with the environmental laws? How does it differ in effect from civil enforcement?
What evidence exists to link compliance to environmental performance? Under what conditions is compliance a suitable proxy for environmental performance? What are other proxies or measures of environmental performance?
What is the optimal mix of enforcement and compliance assistance to maximize compliance or environmental performance? What is more effective, enforcement followed by compliance assistance, or compliance assistance followed by enforcement?
The competition encourages proposals from researchers from all legal, behavioral, social, organizational and economic sciences. It encourages collaborations with non-social science disciplines when needed to answer social science-based questions. It supports both research conducted within a single disciplinary tradition, as well as novel, collaborative, and interdisciplinary scientific efforts.
In internal priority setting for grant funding, preference will be given to proposals that:
1. demonstrate a detailed knowledge of current research in the field and use such research as a point of departure. Research that duplicates existing studies will not be funded;
2. will investigate conditions or develop methods that have broad applicability, i.e., are generalize to other industries, geographic areas or situations;
3. will develop data sets that can be used by other researchers to investigate other industries, geographic areas or situations, or to answer questions similar to those posed above, and
4. are based on empirical, statistically significant samples or censuses of affected facilities and/or actual governmental actions.
The EP&I research effort relates to several EPA and DOJ programs, including:
- the enforcement and compliance assistance programs of the Office of Enforcement and Compliance Assistance, for a related study sponsored by OECA;
- the Economy and Environment Program of the EPA Office of Policy, Economics and Innovation. For a list of previous related research sponsored by OPEI, see: http://www.ojp.usdoj.gov/nij/funding.htm
Personnel from these agencies, regions and programs will assist the EPA Office of Research and Development and NIJ in determining funding priorities for proposals.
Academic and not-for-profit institutions located in the U.S., and state or local governments are eligible under all existing authorizations. Profit-making firms are not eligible to receive grants from EPA under this program. Federal agencies, national laboratories funded by federal agencies (FFRDCs), and federal employees are not eligible to submit applications to this program and may not serve in a principal leadership role on a grant.
FFRDC employees may cooperate or collaborate with eligible applicants within the limits imposed by applicable legislation and regulations. They may participate in planning, conducting, and analyzing the research directed by the principal investigator, but may not direct projects on behalf of the applicant organization or principal investigator. The principal investigator's institution may provide funds through its grant to a FFRDC for research personnel, supplies, equipment, and other expenses directly related to the research. However, salaries for permanent FFRDC employees may not be provided through this mechanism.
Federal employees may not receive salaries or in other ways augment their agency's appropriations through grants made by this program. However, federal employees may interact with grantees so long as their involvement is not essential to achieving the basic goals of the grant. The principal investigator's institution may also subcontract to a federal agency to purchase unique supplies or services unavailable in the private sector. Examples are purchase of satellite data, census data tapes, chemical reference standards, analyses or instrumentation not available elsewhere, etc. A written justification for federal involvement by subcontract must be included in the application, along with an assurance from the federal agency involved which commits it to supply the specified service.
EPA encourages interaction between its scientists and grant principal investigators for the purpose of exchanging information in research areas of common interest that may add value to their respective research activities. However, this interaction must be incidental to achieving the goals of the research under a grant. If the involvement should become substantial, i.e., essential to achieving these goals, then the award would become a cooperative agreement. Interaction that is "incidental" is not reflected in a research proposal and involves no resource commitments.
Potential applicants who are uncertain of their eligibility should contact Dr. Robert E. Menzer in NCER, phone (202) 564-6849, email: email@example.com
A set of special instructions on how applicants should apply for an NCER grant is found on the NCERQA web site.Standard Instructions for Submitting a STAR Application and the necessary application forms may be found on this web site.
The need for a sorting code to be used in the application and for mailing is described in the Standard Instructions for Submitting a STAR Application. The sorting code for applications submitted in response to this solicitation is 2000-STAR-M1. The deadline for receipt of the application by NCERQA is no later than 4:00 p.m. ET, July 24, 2000.
EPA anticipates making available up to about $1 million for this research program. The projected range is from $50,000 to $200,000 per award per year, with durations from 1 to 3 years. Field experiments, survey research, and multi-investigator projects may justify the higher funding level. Awards made through this competition will depend on the availability of funds.
Further information, if needed, may be obtained from the EPA officials indicated below. Email inquiries are preferred.
Dr. Matthew Clark
EPA National Center for Environmental Research
Fax (202) 565-2447, Voice (202) 564-6842
Procedural or eligibility questions:
Dr. Robert E. Menzer
EPA National Center for Environmental Research
Fax (202) 565-2444, voice (202) 564-6849
To assist in the evaluation of how the research contributes to the needs of environmental decision makers, proposals in response to this solicitation must include a special section entitled, "Policy Relevance." This discussion is limited to two pages and must contain an explicit statement on the policy relevance of the proposed research. In particular, the applicant must identify how this research will contribute to making environmental policy more efficient or effective. The discussion should identify "target groups," or sets of policy makers and/or policy analysts, other than the federal government, who are likely to benefit from this research. Once identified, the applicant must elaborate the potential benefits of the research for the designated target groups and address ways that members of the research team intend to communicate the results to these groups. These pages are in addition to the 15 pages permitted for the project description.
Please note that all data sets, models, and databases developed under these grants will become part of the public domain and henceforth freely available to all researchers. Researchers who develop databases containing proprietary or restricted information should provide a strategy, not to exceed two pages, to make this data widely available while protecting privacy or property rights. These additional pages are in addition to the 15 pages permitted for the project description.
Last Updated: April 10, 2000