Executive Summary1. PCSD's co-sponsor of the event is the not-for-profit organization, the Global Environment Technology Foundation.
2. Sustainable America, p. 3
3. Sustainable America, p. 4
4. Sustainable America, pp. 6-7.
5. Sustainable America, p. v-vi.
1.Intergovernmental Panel on Climate Change (IPCC), Climate Change 1995, The Science of Climate Change, Summary for Policymakers (Cambridge: Cambridge University Press, 1996), p. 10.
2. Climate Change 1995, The Science of Climate Change, Summary for Policymakers, p. 11.
3. IPCC, The Regional Impacts of Climate Change: An Assessment of Vulnerability (Cambridge: Cambridge University Press, 1998).
4. Climate Change 1995, The Science of Climate Change, Summary for Policymakers, p. 13.
5. United Nations Framework Convention on Climate Change, Article 2, adopted in New York on 9 May 1992.
6. United Nations Framework Convention on Climate Change, Article 4.2.
7. The six greenhouse gases include carbon dioxide, methane, nitrous oxide, and three man-made gases (sulfur hexafluoride, perfluorocarbons, and hydrofluorocarbons).
8. Kyoto Protocol to the United Nations Framework Convention on Climate Change, Article 3.1 and Annex B.
9. The Clean Development Mechanism is defined in Article 12 of the Kyoto Protocol. For a discussion of the Clean Development Mechanism, see chapter 5 of this report.
10. Data on carbon dioxide emissions can be found in: Carbon Dioxide Information Analysis Center (CDIAC), Environmental Sciences Division, Oak Ridge National Laboratory, 1995 Estimates of CO2 Emissions from Fossil Fuel Burning and Cement Manufacturing Based on the United Nations Energy Statistics and the U.S. Bureau of Mines Cement Manufacturing Data, ORNL/CDIAC-25, NDP-030 (an accessible numerical database) (Oak Ridge, Tn., 1997). Per capita emissions data presented in: World Resources Institute, United Nations Environment Programme, United Nations Development Programme, World Bank, World Resources 1998-99 (Oxford: Oxford University Press, 1998), p. 176, fig. GC.6.
11. International Energy Agency, World Energy Outlook 1995 (Paris: Organization for Economic Cooperation and Development/International Energy Agency, 1995), pp. 48-49.
12. Climate Change 1995, The Science of Climate Change, Summary for Policymakers, page 8.
13. Announcement by President William J. Clinton on April 21, 1993 cited in President William J. Clinton and Vice President Albert Gore, Jr., The Climate Change Action Plan (Washington, D.C.: Government Printing Office, 1993), p. i.
14. For an overview of Federal government initiatives to secure voluntary greenhouse gas emissions reductions see The Climate Change Action Plan.
15. U.S. Department of Energy, Energy Information Agency, Annual Energy Outlook, 1998 (Washington, D.C.: Government Printing Office, DOE/EIA-0383(98), 1997), page 27 and fig. 17.
16. Interlaboratory Working Group on Energy-Efficient and Low-Carbon Technologies, Scenarios of U.S. Carbon Reductions: Potential Impacts of Energy Technologies by 2010 and Beyond (Washington, D.C.: Department of Energy, 1997) page 3.10, table 3.4.
17. See for example, Robert R. Nordhaus and Stephen C. Fotis, Analysis of Early Action Crediting Proposals (Washington D.C.: Pew Center on Global Climate Change, 1998).
18. A number of studies on impediments to the introduction and deployment of technology have been published previously. See for example, National Science and Technology Council, Technology for a Sustainable Future: A Framework For Action (Washington, D.C.: Government Printing Office, 1993); National Science and Technology Council, Bridge to a Sustainable Future: National Environmental Technology Strategy (Washington, D.C.: Government Printing Office, 1995); National Science and Technology Council, National Environmental Technology Strategy: Status and Action (Washington, D.C.: Government Printing Office, 1995); and A.K.N. Reddy, "Barriers to improvements in energy efficiency," Energy Policy (1991): 953-961. The impediments identified by the Council in this report are those that are the most significant in their opinion.
19. Paul Ehrlich and Anne Ehrlich popularized a theoretical framework for considering the impact of human activity on the environment as: I = P x A x T. Impact (I) is a function of Population (P) times affluence (A; a measure of the scale of resource use and convenience) times Technology (T; a measure of the resource, energy, or environmental intensity of the methods that are used to produce and consume goods and services). For a discussion of the basis for the I = PAT formulation, see Paul Ehrlich and Anne Ehrlich, Population Explosion (New York: Simon and Schuster, 1990), pp. 58-59.
20. The potential of each greenhouse gas to warm the atmosphere is different. For example, methane is 21 times more powerful a greenhouse gas than is carbon dioxide. Reporting emissions in millions of metric tons of carbon equivalent (MMTCE) provides a way to compare the ability of each greenhouse gas to trap heat in the atmosphere relative to CO2. Consequently, one million metric tons of methane emissions are equivalent to 21 MMTCE. For more information, see U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996 (Washington, D.C.: EPA, 1998), p. 1-6 - 1-7 and table 1-1.
21. U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996 (Washington, D.C.: EPA, 1998), p. ES-2.
22. Contributions of CO2, CH4 and N20 calculated from data in Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996.
23. Annual Energy Outlook, 1998, p. 75, fig 109.
24. Annual Energy Outlook, 1998, pp. 102-103, table A2 and p. 122, table A17.
25. Annual Energy Outlook, 1998, p. 111, table A7.
26. Annual Energy Outlook, 1998, pp. 106-109, tables A4 and A5.
27. Greenhouse gas emissions from food and wood processing are counted in the industry sector. Emissions from vehicles used for farming, ranching and timbering are counted in the transportation sector.
28. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996, p. 5-2, tables 5-1 and 5-2.
29. R. Lal, J.M. Kimble, R.F. Follett, and C.V. Cole, The Potential of U.S. Cropland to Sequester Carbon and Mitigate the Greenhouse Effect (Chelsea, Mi.: Sleeping Bear Press, 1998), p. 9.
30. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996, pp. 6-3 - 6-4 and table 6-3.
31. Data reported as 75 - 208 million metric tons of carbon in The Potential of U.S. Cropland to Sequester Carbon and Mitigate the Greenhouse Effect, p. 81, table 40.
32. Eco-efficient means a practice that is both economically efficient and environmentally effective.
33. President's Council on Sustainable Development, Sustainable America: A New Consensus for Prosperity, Opportunity, and a Healthy Environment for the Future (Washington, D.C.: Government Printing Office, 1996), pp. 45-47.
34. Annual Energy Outlook, 1998, pp. 106-109, tables A4 and A5.
35. W.P. Anderson, P.S. Kanaroglou, and E.J. Miller, "Urban Form, Energy and the Environment: A Review of Issues, Evidence and Policy," Urban Studies 33 (1996).
36. For more detailed information on the sensitivity and adaptation of systems to climate change, see IPCC, "Scientific-Technical Analyses of Impacts, Adaptations and Mitigation of Climate Change, Summary for Policymakers" in Climate Change 1995, A Report of the Intergovernmental Panel on Climate Change (Cambridge: Cambridge University Press, 1996), pp. 28 - 36 and IPCC, The Regional Impacts of Climate Change: An Assessment of Vulnerability (Cambridge: Cambridge University Press, 1998), pp. 7-8.
37. These examples were presented to the Council by PCSD member Scott Bernstein at the June 1998 public meeting. Fact-checking was the responsibility of the presenter. The 211 Atlanta project was described in a personal communication to Mr. Bernstein by Mark O'Connell, President, United Way of Metropolitan Altanta. Additional information on the DOE - Goldman Sachs partnership can be found on the DOE web site (www.eren.doe.gov) under the subject "International Performance Measurement and Verification Protocol." The concept of location efficiency is discussed in Sustainable America: A New Consensus for Prosperity, Opportunity, and a Healthy Environment for the Future, pp. 92-93. Further detail on the cost of sprawl can be found in: Urban Land Institute, Cost of Infrastructure (Washington, D.C.: Urban Land Institute, 1989) and National Research Council, The Cost of Sprawl Revisited (Washington, D.C.: National Academy Press, 1997). The Great Lakes Energy Network is a project of the High-Performance School Partnership between the Center for Neighborhood Technology and the Chicago and Pittsburgh public school districts.
1. For more information on the 1939 New York World's Fair, start by visiting the following website: http://amsterdam.park.org:8888/Pavilions/WorldExpositions. Trylon and Perisphere, the gleaming spire and globe that became symbols of the New York World's Fair of 1939-40 and appeared on countless World's Fair souvenirs, served as constant reminders of the fair's message of optimism, hope for the future, and valorization of the "typical American." Perisphere, "the largest globe ever made by man," symbolized the world we live in (with all its typicality), and Trylon, a slender three-sided tower 700 feet tall, symbolized our aspirations for the future.
2. 1997 PCSD Charter Language: Advise the President on the next steps in building the new environmental management system of the 21st century by reviewing current environmental management reforms (including Project XL and other innovations), further developing a vision of innovative environmental management that fosters sustainable development (environment, economy and equity), and recommending policy improvements and additional opportunities to advance sustainable development. The Council shall report its initial recommendations on environmental management reform to the President no later than Spring 1998 and its broader recommendations on the role of environmental management in sustainable development by December 1998. Sec. 4, Scope of Activities, Revised Charter, President's Council on Sustainable Development, April 25 1997. See also Executive Order No. 12852, July 19 1993; Further Amendment to Executive Order No. 12852, As Amended June 30 1997.
3. The PCSD charter refers to the new environmental management "system"; to avoid confusion, the task force has chosen the word "framework" to refer to a broader set of institutional and individual influences that effect the environment including but not limited to the system of government regulations, the economic and financial system, technology, and features of organized society.
4. The task force was charged with advising "the President on the next steps in building the new environmental management [framework] of the 21st Century." The EMTF developed a workplan to fulfill this mission and other activities of the council outlined in the PCSD charter. The first step of a three part approach was designed as a visioning exercise before the task force began the second and third steps of reviewing current environmental management reforms and recommending how to build a new environmental management framework to foster sustainable development. The Task Force founded its review of current reforms and subsequent recommendations on the vision exercise and the recommendations contained in Sustainable America, the PCSD's 1996 published report.
5. Workplan Step 1 - Vision Exercise: The EMTF held two meetings to develop a framework, comprised in part of crucial attributes, that served as a reference point for reviewing current environmental management reforms and making further policy recommendations. The task force surveyed a number of economic, technological, environmental and societal trends providing the context for discussing a new environmental management framework. It heard opinions from diverse experts on what direction these major drivers are headed thus allowing the group to form some plausible assumptions about the condition of world in the near future. The exercise then proceeded towards describing (generally) a desired state of the world based on the principles and goals of sustainable development. The goal was to also understand which trends/conditions will need to be modified to achieve more sustainable development and identify the implications for environmental management.
6. The benchmarking format used by the task force to review current environmental management reforms was based in part on work by US EPA's Office of Policy, Planning and Evaluation, Industrial Strategies Division: Sustainable Industrial Development - A Benchmark Evaluation of Public Policies and Reporting. The task force encourages the use of sustainable development criteria such as this to review corporate practices and environmental management proposals, programs and reforms.
7. Task Force Workplan Step 2 - Review Process: From the PCSD charter and as described in the task force workplan, it was agreed to pursue the general goal of identifying and assessing a range of current environmental management reforms in light of the developing vision of a sustainable environmental management framework. Due to limitations on time and resources, the initial task force write-ups on current reforms (based on publicly available documentation) were not intended to be technically comprehensive or conclusive. The summaries were also used to conduct a benchmarking evaluation to assist the task force in identifying reforms and their relationship to the attributes and/or objectives of a new environmental management framework. These attributes, referred to as framework attributes in the materials (see, July 23 Task Force Reference and Meeting Materials) , also acted as the basis for benchmarking criteria in the task force review of current environmental management reforms. The review (and the benchmarking) was not intended to measure the general success or failure of the programs involved - the task force was interested to know what reforms were likely to help foster sustainable development.
8. PCSD, Sustainable America - A New Consensus for Prosperity, Opportunity, and a Healthy Environment, Chapter Two, p.25 , February 1996.
9. The framework attributes for fostering sustainable development also served as the basic criteria for the task force's review of current environmental management reforms (see footnote 7 and 8 supra).
10. As the task force understands the concept of a "green-track," it complements, rather than replaces, the existing regulatory system. See generally Shelley Metzenbaum, Making Measurement Matter: The Challenge and Promise of Building a Performance-Focused Environmental Protection System, (Brookings Institutions's Center for Public Management, October 1998), p. 71-73 (pointing out the important difference between "opting out of the command-and-control model and being allowed to "opt into the alternative track"); and C.f., Ira Feldman, ISO 14000 Can Underpin a New "Dual-Track"Regulatory System: Greentracking as an Alternative to Command and Control," Environmental Business Journal (January 1997), pp.11-15 (denoting, inter alia, the idea of utilizing demonstrated environmental performance, including a properly implemented environmental management systems and core performance measures, as the basis for a more flexible system).
11. The Aspen Institute, The Stewardship Path to Sustainability of Natural Resources, (forthcoming) 1999.
12. PCSD, Sustainable America - A New Consensus for Prosperity, Opportunity, and a Healthy Environment, p. V, February 1996.
13. Paul Hawken, "Natural Capitalism," Mother Jones, March/April 1997, p. 40.
14. Ibid, p.50
15. PCSD, Sustainable America, op cit, p. 60.
16. PCSD, op cit, p. 64.
17. PCSD, Sustainable America, A New Consensus for Prosperity, Opportunity and a Healthy Environment for the Future, PCSD, February 1996, p. 38-39.
18. PCSD, Eco-Efficiency, p. 11-13.
19. In Sustainable America the PCSD identified the "use of market incentives as a part of an overall environmental management system to achieve environmental and natural resource management objectives, whenever feasible." PCSD, op cit, p. 50.
20. Aggregating the available literature on the financial performance of equity instruments that "screen" or select companies according to environmental management performance, there is some basis for asserting that it is possible to analyze publicly traded companies for environmental performance without diminishing a risk-adjusted return (i.e., comparable shareholder return, for instance, with the Standard and Poors 500 Index). Whether or not environmentally screened investment products (e.g., socially responsible investment products or mutual funds, etc.) "outperform" the S&P 500 Index or other investment tools is debatable and not necessary to decide for the purposes of measuring and valuing environmental performance. The implication for the overall environmental management framework is that it is possible to measure and assign economic value to the environmental management performance of companies, including energy efficiency and greenhouse gas emissions reductions. See generally Gottsman and Kessler, The Journal of Investing, Vol. 7, Number 4, Fall 1998; and, Ganzi and DeVries, Corporate Environmental Performance As A Factor in Industry Decisions: Status Report, US EPA, Office of Cooperative Environmental Management, March 1998; and The Aspen Institute, Uncovering Value: Integrating Environmental Performance with Financial Performance, (1999).
21. Sustainable Development in the United States - An Experimental Set of Indicators, U.S. Interagency Working Group on Sustainable Development Indicators (1998 report pending).
22. Source: "Accounting for Sustainable Development: A Business Perspective", Management Accounting Issues Paper 14, Society of Management Accountants of Canada.
23. "Metrics are systems of measurement by the application of statistics and analysis to a particular field of study" (Webster's University Dictionary). In this case, environmental performance metrics which may include measures of energy use and efficiency, air emissions and toxics releases, water use and discharge quality, waste treatment, etc. The terms "metrics" and "indicators" are sometimes used interchangeably or generally.
24. "Indicators are one of many tools for simplifying, quantifying, and communicating vast amounts of information in ways that are more easily understood. They are also useful for alerting us to what areas that need more attention, as well as areas that see improvement." U.S. Interagency Working Group on Sustainable Development Indicators, Council on Environmental Quality, (1998 report pending).
25. Pollution Prevention [citation pending]
26. Design for the Environment [citation pending]
27. Extended Product Responsibility [citation pending].
28. As stated at footnote 10 supra, "green-track" is considered by the task force to be supplemental to the current system, but that alternative strategies for administrative efficiency and processs-specific requirements that lead directly to demonstrable high environmental performance should be pursued. Any "green-track" or performance-based system must address multiple aims as set forth in Section B.
29. See The Aspen Institute, The Alternative Path: A Cleaner, Cheaper Way to Protect and Enhance the Environment (Washington, D.C. 1996)(outlining particular policy issues that must be addressed in offering operational flexibility in exchange for superior environmental performance and stakeholder involvement). See also Appendix C - Next Generation Reports: The convergence of ideas on how to modernize the current system of environmental protection is summarized here by permission of the author in a recent manuscript by Karl Hausker, the former Project Director of the Enterprise for the Environment at the Center for Strategic and International Studies.
1. Joint Center for Sustainable Communities, 1998.
2. President's Council on Sustainable Development, Sustainable America, Washington, D.C., 1996, p. 52.
3. Phyllis Myers, State Resources Strategies, firstname.lastname@example.org, December 1, 1998.
4. Benjamin Goldman, Sustainable America: New Public Policy for the 21st Century, Jobs and Environment Campaign, 1995.
5. Robert Lund and William Hauser, The Remanufacturing Industry in the United States, Boston University, 1997.
6. Neal Peirce, "Recycling the Urban Junkyard," Washington Post Writers Group, April 5, 1998. Also John E. Young and Aaron Sachs, The Next Efficiency Revolution: Creating a Sustainable Materials Economy, Worldwatch Paper No. 121, Worldwatch Institute, Washington, D.C., September, 1994.
7. President's Council on Sustainable Development, Eco-Industrial Park Workshop Proceedings, October 17-18, 1996 in Cape Charles, Virginia, published by PCSD, Washington, D.C., February 1997.
8. Robert Costanza et al, "The Value of the World's Ecosystem Services and Natural Capital," Nature, May 15, 1997.
9. Albert F. Appleton, "The Challenge of Providing Future Infrastructure in an Environment of Limited Resources, New Technologies, and Changing Social Paradigms," paper presented to the National Research Council Board on Infrastructure and the Constructed Environment, March 24, 1995.
10. The Sierra Club, The National Sprawl Fact Sheet, http/www.sierraclub.
11. Scott Bernstein, "Imaging Equity," Environment and Planning, American Planning Association, December 1993. Analysis of regional growth indicators based on data supplied by metropolitan planning organizations and regional councils of government. Absolute land use increases from 1980 to 1990 supplied by the American Farmland Trust, reported in Neighborhood Works special issue on regionalism and community, Center for Neighborhood Technology, V. 20, no. 6, November 1997.
12. David Bollier, How Smart Growth Can Stop Sprawl, Essential Books, Washington, D.C., 1998, p. 11.
13. Thomas E. Bier, "Public Policy Against Itself: Investments that Help Bring Cleveland (and Eventually Suburbs) Down," in Cleveland Development: A Dissenting View, ed. by Alvin Schorr, Cleveland: David Press, 1991.
14. Phyllis Myers, op. cit.
15. Timothy Egan, "The New Politics of Urban Sprawl," New York Times, November 15, 1998, p. 44.
16. Geographic analysis of NIPC Chicago land use inventory by Peter Haas, Center for Neighborhood Technology. Presented in report of the Chicago Transportation and Air Quality Commission. 1997. NIPC land use inventory available at www.nipc.org.
17. National Academy of Public Administration, Building Stronger Communities and Regions: Can the Federal Government Help?, Washington, D.C., March 1998, p. 5.
18. U.S. Department of Housing and Urban Development, The State of the Cities, Washington, D.C., 1998.
19. John McKnight and John Kretzmann, Building Communities from the Inside Out, Northwestern University, Evanston, Illinois, 1995.
20. John McKnight and John Kretzmann, op. cit.
21. Michael Sherraden, Assets and the Poor: A New American Welfare Policy, M.E. Sharpe: Armonk, New York, 1991.
22. Michael Porter, op. cit. Also, Robert Weissbourd et. al, "The Business of Neighborhood Markets."
23. U.S. Department of Agriculture, Understanding Rural America, Washington, D.C., 1995.
24. Neil Seldman, Institute for Local Self Reliance.
25. Neal Peirce, "Recycling the Urban Junkyard," Washington Post Writers Group, April 5, 1998. Also John E. Young and Aaron Sachs, The Next Efficiency Revolution: Creating a Sustainable Materials Economy, Worldwatch Paper No. 121, Worldwatch Institute, Washington, D.C., September, 1994.
26. John Young and Aaron Sachs, op. cit.
27. Institute of Scrap Recycling Industries, Inc., fact sheet, 1998.
28. Jesse Ausubel, "Industrial Ecology: Reflections on a Colloquium," Proceedings of the National Academy of Science, Washington, D.C.
29. PCSD, Eco-Industrial Park Workshop Proceedings, op. cit
30. Robert Lund and William Hauser, op. cit.
31. Neil Seldman, op. cit.
32. The President's Council on Sustainable Development, Sustainable America, Washington, D.C., February 1996, p. 58.
33. Office of Technology Assessment, Technological Reshaping of Urban America. See also Eliot Sclar in Henry Cisneros, Uneven Destinies; Nicholas Negroponte, in "Information for the 21st Century," special issue of Scientific American.
34. Ronald Thomas, "Using Television as an Interactive, Democratic Planning Tool," Planners' Casebook, Spring 1997, American Institute of Certified Planners.
35. Alice Shabecoff et. al., Green Jobs, Green Communities, prepared for the Joyce Foundation, Community Information Exchange, Washington, D.C., 1998.
36. Peter Barnes, "Who Owns the Sky?," 1997 Entrepreneurial Economy Review, Corporation for Enterprise Development, Washington, D.C. 1997.
37. Michael Cohen. op.cit. p. 119.
38. Metropolitan and Rural Strategies Task Force of the PCSD, "People, Places, and Markets: Comprehensive Strategies for Building Sustainable Communities," draft workshop proceedings, July 1998.
39. U.S. Small Business Administration, The Facts about Small Business, Wash., DC, May 1996.
40. National Academy of Public Administration, op. cit., p. 47.
41. Ibid., p. 47.
42. American Planning Association, Research Department, Land-Based Classification Standards, www.planning.org/lbcs, November 21, 1998.
43. Peter Barnes, op. cit.
1. For more information, see the website: http://www.un.org/desa/ffd
2. As stated in remarks by U.S. Secretary of Commerce William M. Daley at the President's Export Council Virtual Trade Mission, November 10, 1998.
3. See Business Week, November 10, 1997 "When Green Begets Green" pp 98-106.
4. Excerpt from the MAI web site (http://www.oecd.org/daf/cmis/mai/maindex.htm#top): "Negotiations on the MAI are no longer taking place. However, the officials agreed on the importance of multidisciplinary work on investment at OECD. There are a number of important issues on which further analytical work and inter-governmental co-operation are needed. The officials agreed that this work should be carried out in a transparent manner and should involve all OECD members as well as interested non-member countries, including those that participated as observers in the negotiations."
5. The co-convening organizations were: the Alliance to Save Energy, the Business Council for Sustainable Energy, Edison Electric Institute, International Climate Change Partnership and the United States Council for International Business.
6. Presentation by Mark Hall, Director of Government Affairs, Trigen Energy Corporation at the Forum on the Clean Development Mechanism and Sustainable Development, July 27, 1998.
1. See, e.g., Final Consensus Report of the National Commission on Superfund (1994) or Ozone Transport Assessment Group Executive Report (1997).
2. Sustainable America, supra note x, at 26.
3. Sustainable America, supra note x, at 27.
4. Typically, and not surprisingly, expert panel reports were able to make more specific and controversial recommendations, while consensus reports are less specific and controversial.
5. National Academy of Public Administration, Setting Priorities, Getting Results: A New Direction for EPA (hereinafter NAPA I).
6. These were: John Adams (Natural Resources Defense Council), Jay Hair (National Wildlife Federation), Fred Krupp (Environmental Defense Fund), and Michele Perrault (Sierra Club).
7. National Academy of Public Administration, Resolving the Paradox: EPA and the States Focus on Results, 1997 (hereinafter NAPA II).
8. Center for Strategic & International Studies, The Environmental Protection System in Transition: Toward a More Desirable Future, 1998 (
9. These several participants, and their reasons for not signing, are described in David Clarke, What Went Right, Envtl. F., Mar./Apr. 1998. See also Linda Greer, Why We Didn't Sign, Envtl. F., Mar./Apr. 1998 at 37-38.
10. This Dialogue uses "technology-based regulation" interchangeably with "command-and-control regulation" (as do most authors), and distinguishes it from "performance-based regulation" and other policy tools in the pages that follow.
11. See, e.g., Risk Commission Report, supra note x, at 31; Daniel C. Esty and Marian R. Chertow, Thinking Ecologically: An Introduction, in Thinking Ecologically, supra note x, at 6.
12. E4E Report, supra note x, at 5.
13. The Alternative Path, supra note x, at 10.
14. See, e.g., Risk Commission Report, supra note x, at 4,14; NAPA II, supra note x, at 39-46.
15. Sustainable America, supra note x, at 12-23.
16. The Alternative Path, supra note x, at 5.
17. E4E Report, supra note x, at 4.
18. See, e.g., The Alternative Path, supra note x, at 5-7, 16; Risk Commission Report, supra note x, at 23-28, 45-48; Jane Coppock and John Gordon, Ecosystem Management and Economic Development, in Thinking Ecologically, supra note x, at 40; Jason Rylander and John Turner, Land Use: The Forgotten Agenda, in Thinking Ecologically, supra note x, at 69; E. Donald Elliott, Towards Ecological Law and Policy, in Thinking Ecologically, supra note x, at 176; Emil Frankel, Coexisting with the Car, in Thinking Ecologically, supra note x, at 193.
19. Sustainable America, supra note x, at 57-68; E4E Report, supra note x, at 19-24, NAPA II, supra note x, at 53-56, 68.
20. The degree to which current regulations are performance-based vs. technology-based is subject to endless debate. For one of most lucid discussions of this issue concluding that, in practice, technology-based standards do predominate, see NAPA I, supra note x, at 91-92.
21. Sustainable America, supra note x, at 28.
22. Compare policy recommendations in Sustainable America, supra at note x, at 31, 34 with the those at 35, the latter of which involve superior environmental performance.
23. The Alternative Path, supra note x, at 10,13; E4E Report, supra note x, at 29-30.
24. See, e.g., Sustainable America, supra note x, at 26-27; E4E Report, supra note x, at 27; Marian R. Chertow and Charles W. Powers, Industrial Ecology: Overcoming Policy Fragmentation, in Thinking Ecologically, supra note x, at 19-36.
25. Sustainable America, supra note x, at 60; NAPA II, supra note x, at 68; E4E Report, supra note x, at 21-23; NEPI, Integrating Environmental Policy: A Blueprint for 21st Century Environmentalism at 64-68.
26. See, e.g., NAPA I, supra note x, at 103-104; Sustainable America, supra note x, at 27; The Alternative Path, supra note x, at 5; Risk Commission Report, supra note x, at 29-31; NAPA II, supra note x, at 37; Robert Stavins and Bradley Whitehead, Market-Based Environmental Policies, in Thinking Ecologically, supra note x, at 105-117; E. Donald Elliott, Towards Ecological Law and Policy, in Thinking Ecologically, supra note x, at 179-186; E4E Report, supra note x, at 23-24 and 34-40; NEPI, Reinventing the Vehicle, supra note x, at 45-48.
27. See, e.g.,E4E Report, supra note x, at 41-44; NEPI, Building Partnerships for Accountable Devolution (1997).
28. Sustainable America, supra note x, at 53.
29. See, e.g., Sustainable America, supra note x, at 33, 37, 49, 54, and 125-129.
30. See, e.g., Risk Commission Report, supra note x, at 52; Marian R. Chertow and Charles W. Powers, Industrial Ecology: Overcoming Policy Fragmentation, in Thinking Ecologically, supra note x, at 33, fn. 3; E4E Report, supra note x, at 45-47.
31. E4E Report, supra note x, at 47.
32. NAPA I, supra note x, at 132; NAPA II, supra note x, at 74; E4E Report, supra note x, at 48-49.
33. Sustainable America, supra note x, at 38-44.
34. E4E Report, supra note x, at 51-60.
35. Robert A. Frosch, The Industrial Ecology of the 21st Century, in Scientific American, September 1995, at 178, 181.
36. David R. Berg and Grant Ferrier, the U.S. Environmental Industry, 1998, at 73.