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An empirical examination of innovations in integrated environmental management: the case of the Great Lakes Basin.

The American commitment to environmental protection has grown markedly in recent decades, whether measured by public opinion surveys or the amount of money devoted to protection activities. Environmental issues have steadily climbed as an area of widespread public concern, reflected in their growing prominence on the agendas of federal, state, and local governments. In turn, this interest is also reflected in fiscal terms, as a nation which devoted less than 1 percent of gross domestic product (GDP) to environment-related matters in 1970 is expected to allocate more than 2.5 percent of GDP to such concerns by 2000.

This dramatic expansion of concern and investment has not, however, been translated into significant improvements in environmental quality. Some successes have been achieved, but these have been eclipsed by a series of problems that were not effectively addressed at the time the Environmental Protection Agency (EPA) was created and much decisive legislation was enacted at the federal and state levels in the late 1960s and 1970s. Perhaps foremost among these environmental problems is pervasive toxics contamination.

Numerous explanations can be advanced for the failure of past efforts to achieve greater environmental improvement, but one of the most convincing is the problem of regulatory fragmentation and its perverse environmental effects. This fragmentation divides regulatory policy into distinct spheres by medium (air, water, and land), often establishing separate approaches and management systems. Increasing evidence from the physical sciences indicates that this fragmentation has had the perverse effect of merely shifting pollutants - including pervasive toxics - from medium to medium rather than addressing them in any comprehensive manner. Consequently, many of the nation's most serious environmental problems may not stem from illegal dumping of wastes or failure to enforce individual permit standards. Instead, the irony is that much of the problem may be attributable to medium-based pollution control strategies created and implemented by federal and state governments. A similar dynamic is evident in Canada, where both federal and provincial environmental policies tend to be modeled closely after their American predecessors (Hoberg, 1991).

The extent of this problem is well illustrated by the massive ecosystem encompassed in the Great Lakes Basin, which will be the major focal point of this article. Massive efforts to reduce major point source emissions, supported by the Clean Water Act, have led to some genuine improvements in Basin water quality, albeit at a very high cost. But the entire Basin remains highly vulnerable to the effects of cross-media pollution. It is on the receiving end of numerous air toxics; has extensive commercial, agricultural, and recreational activity that contribute "nonpoint" pollution to Basin water; and has a long "residence time" for water before it circulates out of the Basin (Alder, Landman, and Cameron, 1993; Elder et al., 1989). Air deposition accounts for more than 80 percent of many of the most threatening organic compounds found in the Great Lakes (Colborn et al., 1990). Further surface water contamination derives from groundwater discharge, landfill leaching, pesticide runoff from farmland, and dredging of lake-bottom sediments contaminated by prior dumping, all of which further compound the problems facing the Basin. Such problems are not unique to this region, as other North American ecosystems, such as the Chesapeake Bay, are similarly endangered by cross-media pollution (Horton and Eichbaum, 1991). Nonetheless, the diverse and expansive geographic scope of the Great Lakes Basin effectively illustrates the larger phenomenon of cross-media pollution within a medium-based regulatory system that often becomes a vehicle (witting or otherwise) for cross-media "transfer, transport, or transformation" (Irwin, 1989).

The existence of this cross-media problem is not a new discovery. Richard Nixon's executive order that gave birth to the EPA acknowledged this phenomenon and called for an agency and related programs that could effectively integrate environmental management (Marcus, 1980). Many of the individuals who headed that agency have publicly endorsed such an integrated approach, calling attention to agency failures. In fact, the last four holders of that office - William Ruckelshaus, Lee Thomas, William Reilly, and Carol Browner - have spoken out on the issue with considerable frequency and intensity.

Nonetheless, the federal regulatory system has shown little sign of shifting toward this broader focus. Indeed, these EPA administrators, and most scholars who have examined this aspect of environmental policy, have tended to downplay the prospects for integration given the significant political and technical impediments to such change (Guruswamy, 1989; Krier and Brownstein, 1992). Prevailing theories of bureaucratic behavior suggest minimal likelihood that medium-specific officials in environmental agencies would either be inclined or allowed to take such integrative steps. If not absorbed with securing their base and expanding resources, such officials are frequently portrayed as mannequins of elected principals who are likely to be hostile to any bureaucratic initiative or pursuit of broader, integrative approaches to regulation (Niskanen, 1971; Moe, 1984; Wood and Waterman, 1991; Weingast, 1984; Banks and Weingast, 1992). In turn, industry and environmental advocacy groups are widely thought to have invested too heavily in existing programs to risk any reinvention of the environmental regulatory system that might force them to accept the uncertainties inherent in alternative approaches. Finally, the very notion of more integrated environmental management poses difficult questions of administrative and technical feasibility, independent of political considerations (Bartlett, 1990; Lindblom, 1973; Fontaine, 1993).

While most scholarly analysis has concentrated on the federal level, similar patterns have been evident at the state level as well. Through at least the mid-1980s, states were found eager to meet the terms of federal regulatory programs and assure the smooth flow of related transfer dollars. Indeed, many states used the legislative and administrative models developed in Washington to guide the construction of their own environmental regulatory systems. And perhaps even more so than their federal counterparts, most state environmental officials gave little indication that they understood the dynamics of cross-media pollution in this earlier period, much less were willing to explore regulatory alternatives that might foster greater integration (Rabe, 1986).

Although the foibles of this fragmented regulatory regime provide relatively easy pickings for scholarly analysts and journalistic commentators, it is important to note that these patterns need not be inevitable. A growing body of evidence from Western Europe indicates considerable acceptance and development of integrated forms of environmental management (Haigh and Irwin, 1990). Moreover, and more central to the theme of this article, a growing body of evidence from within the Great Lakes Basin indicates at least some shift toward greater integration in the late 1980s and early 1990s. Both quantitative and qualitative data indicate that cross-media pollution is increasingly recognized as a central environmental problem facing the Basin. A series of new policy initiatives designed to address this problem have been undertaken. This new-found recognition and willingness to act is reflected in state and Canadian provincial environmental agencies and legislatures, as well as among regional bodies, environmental advocacy groups, and industries.

Many of these initiatives remain far too new to evaluate fully their administrative feasibility, political resilience, or ability to generate improved environmental outcomes. Nor do these developments guarantee any capacity for these changes to diffuse to other regions or ecosystems of the United States or Canada. But they do suggest that environmental policy shows potential for creative modification and that the ideas of integrated environmental management and cross-media integration need no longer be dismissed as merely academic exercises. It further suggests that prevailing views of environmental policy - and regulatory policy more generally - may be so locked into cynical views of agency, legislative, and interest group performance that they may present an overly constricted view of the possibilities for regulatory reform. Moreover, as Elinor Ostrom has noted, "Given the presumption of failure that categorizes so much of the policy literature, it is important to present examples of success" (Ostrom, 1990; 143). This is especially true in environmental policy, where a growing scholarly literature reveals countless failures and offers repeated lamentations but yields little insight as to how policy might best be modified to increase administrative efficiency and foster greater outcomes effectiveness. Hence, subsequent portions of this article follow Ostrom's general call. I examine the conditions that appear to have facilitated new regulatory experimentation within the Great Lakes Basin, present an overview of elite receptivity to regulatory alternatives as explored through survey analysis, and offer a review of case studies that examine some of the specific innovations now being implemented. In the concluding section, I review these developments and consider both the enduring impediments to integration and the prospects for replication of the Great Lakes experience elsewhere in the United States.

Factors Fostering Integration

The relatively rapid set of changes within the Great Lakes Basin stem from a strong convergence of factors widely thought essential to policy formation. These factors include: riveting evidence of new problems not being addressed through prevailing regulatory approaches; generation of new, coherent ideas for policy innovation; growing willingness of key political institutions to incorporate these ideas into their responses to pressing problems; and a considerable amount of entrepreneurial activity clamoring for integration, much of it advanced by newly trained environmental policy professionals far less wedded to prevailing approaches than their predecessors (Kingdon, 1984; Young, 1989). When combined, these factors give greater coherence and political acceptability to integrative strategies than ever before and help account for the sorts of changes evident in a number of states around the Basin.

A common theme linking these various regulatory innovations is the virtual absence of any federal authority - such as regulatory, legislative, or judicial institutions - imposing them from on high. Instead, much of the shift toward integration within the Basin has occurred despite continuing pressures from both Washington and Ottawa to maintain medium-based approaches. Where federal policy did contribute to state-level innovation, it was through grants, flexible oversight, and technical support rather than edicts. Furthermore, in a surprising number of these state efforts, elected state officials in both executive and legislative branches either played no role or proved responsive to requests from environmental agency officials, suggesting a far less hierarchical principal-agent relationship than widely postulated. This follows the general pattern evident in the growing literature on international environmental policy that rejects traditional, hegemonic explanations for policy coordination in favor of more complex models that emphasize multiparty bargaining and the centrality of new policy ideas in bringing about reform (Young, 1989; Young and Osherenko, 1992; Haas, 1990; Ostrom, 1990; Rabe, 1994). These international models are difficult to transfer fully to domestic - or binational - situations such as the Great Lakes Basin but corroborate the general finding that policy coordination does not hinge on marching orders from central governments or elected principals.

In the absence of central government commands or prodding from elected state officials, actual steps toward integration in the Basin were due to other forces. First, an increasingly sophisticated and well-publicized body of research has solidified public understanding that environmental contamination of the Basin poses significant public health threats, particularly due to the unexpectedly widespread distribution of toxic substances in all of the Great Lakes. Whereas earlier research focused on habitat effects and portrayed the lakes as a vital natural resource, more recent analysis has focused on the likely health ramifications of public contact with the lakes (Colborn et al., 1990). This has contributed to a sense of crisis in deliberations over policy for the Basin and has legitimized a search for new policies more likely to reduce threats to public health. Unlike other areas of environmental policy, there has been no singular episode (a Santa Barbara oil spill, a Love Canal revelation, or an Exxon Valdez wreckage) to galvanize attention and begin to turn the wheels of policy making. The cumulative effect of these numerous discoveries has steadily given the issue greater saliency.

Second, physical scientists, policy analysts, and policy makers worked hand-in-hand to bring unprecedented precision to the concept of integrated environmental management. This resulted in development of a series of technical tools, such as mass balance analyses, to measure pollutant inputs and outputs in a given region, and to administrative reforms such as integrated permitting and agency reorganization. As discussed in subsequent sections, these helped move the debate over integration from its fairly cosmic, opaque traditions into something specific that could actually be attempted at the state or regional level (Young and Osherenko, 1992; 236).

Third, this outcry over the well-being of the lakes and refinement of alternative policy ideas coincided with a significant expansion in the capacity of state governments in the region in environmental policy. Many states dramatically increased program funding during this period, providing added resources for experimentation independent of federal restrictions. In turn, institutions representing various Basin-wide concerns, including the Council of Great Lakes Governors and Great Lakes Commission, among others, intensified their environmental commitments and endorsed more integrative regulatory efforts, both within individual states as well as on a multistate or regional basis. These groups give the region well-defined boundaries and helped foster the notion of the Great Lakes Basin as a unique environmental resource and problem worthy of a response superior to traditional, fragmented regulatory approaches (Ostrom, 1990; 91-92). They also encouraged and reinforced state efforts to ensure greater integration.

Fourth, this combination of new concern over the lakes, emergence of workable policy ideas, and new political receptivity to innovation were galvanized through the efforts of supportive policy entrepreneurs. Just as Oran Young and Gail Osherenko have viewed entrepreneurship as crucial to cases of unexpected coordination in various areas of international environmental policy, each of the cases involving a state shift toward integration in the Great Lakes Basin was guided by one or a series of key entrepreneurs (Young and Osherenko, 1992; 232-235). These entrepreneurs are environmental policy professionals, employed by agencies, legislatures, industry, and advocacy groups, who have demonstrated considerable creativity and willingness to challenge prevailing approaches to environmental management. They constitute the beginnings of a broader, "epistemic" community or network, which through continued expansion and maturation, could bring the promise of integrated environmental management closer to realization in the Basin in the years and decades ahead (Haas, 1990). Such entrepreneurs must, to a large extent, continue to adhere to traditional, fragmented approaches to environmental management that have been mandated by federal and state legislatures. Nonetheless, interviews with many such individuals reveal an unexpected eagerness (an eagerness - and awareness - not discernible in similar interviews conducted in the mid-1980s) to not only contemplate alternative, more integrative approaches, but actually to take the political risks inherent in developing and attempting to implement them in the absence of support from federal or elected state principals (Schneider et al., 1995).

Support for Alternative Approaches to Controlling Cross-Media Pollution Problems

When presented in broad fashion, the idea of promoting cross-media integration wins fairly broad support from a diverse array of influential environmental policy officials throughout the Great Lakes Basin. Several questions in our survey were designed to assess respondents' attitudes toward pursuing regulatory integration.(1) The results showed consistent support for developing more integrated environmental programs. For example, a substantial majority (80.1 percent) of all respondents felt that cross-media analysis is likely to help facilitate a more cost-effective allocation of resources than existing, medium-specific approaches. This was true regardless of respondents' state or province of residence or their group affiliation (agency, legislature, industry, advocacy group). Similarly, nearly three-quarters (74.5 percent) of all respondents thought that achieving greater integration in environmental management should be given "high" or "very high" priority. This high rating was observed for all categories of respondents. In sum, respondents seem to favor taking a more comprehensive approach to managing environmental problems, at least at a broad conceptual level.

The survey also explored respondents' feelings about particular means of achieving greater integration of medium-specific programs. Numerous strategies were examined, ranging from the relatively simple, such as increasing the use of multi-disciplinary task forces, to the more complex, such as integrating all medium-specific statutes into one, comprehensive bill. As William Gormley has noted, an array of generic regulatory reform measures, ranging from symbolic ones to those that are highly coercive, are available and have been tested in various policy areas (Gormley, 1989). Many of these varying approaches are evident in recent efforts to integrate environmental management, and several of the more prominent reforms are examined below.

Respondents' views of these various ways of achieving greater integration in environmental programs are shown in Table 1. In particular, respondents were asked: "To what extent do you support or oppose the development of these strategies in your state/province?" A striking finding from this table is the broad support for each of the 16 strategies identified: there appears to be a general willingness among respondents to support a wide range of approaches to achieving greater cross-media integration. There was overwhelming support for a number of strategies, especially recycling/waste reduction and increased staff training on cross-media issues. Even the strategies that received the lowest ratings - staff rotation, departmental reorganization, and the enactment of comprehensive legislation - drew appreciable support, with at least half of all respondents somewhat or strongly supporting them. There was relatively little variation in respondents' attitudes according to their place of residence.

There were, however, somewhat mixed results depending on whether the respondent represented executive agencies, industry, environmental advocacy groups, or legislatures. Environmental advocacy groups tended to show the greatest support for all strategies, except for staff rotation, for which they offered less support than any other group. Representatives of industry tended to show the least amount of support for most of the strategies. They were less supportive than other groups of increasing funding for program development, enacting comprehensive legislation, staff rotation, prohibiting the manufacture or use of certain products, requiring changes in manufacturing techniques, and increasing funding for research or program development. However, despite [TABULAR DATA FOR TABLE 1 OMITTED] their comparatively lower levels of support for these measures, at least a majority of respondents from industry still favored all but one of them (increased funding for program development).

The survey also explored respondents' attitudes about the potential of 11 common management functions in helping to overcome cross-media fragmentation. Most respondents felt that most of these functions had a moderate or large degree of potential for producing more integrated policy. Functions rated most highly included permits, enforcement, environmental impact assessment, monitoring, planning, research, information systems, and inspection. By contrast, respondents were more skeptical of the potential of budgeting, rulemaking, and auditing for producing more integrated environmental management.

Opportunities for Cross-Media Integration

The relatively broad support for most proposed strategies and functions coincides with growing state, provincial, and regional willingness to experiment with many of them. Whereas many of these regulatory options were largely unknown and untested as recently as a decade ago, a growing number of regulatory initiatives around the Basin have used them in recent years. The following discussion considers in greater detail several of the most prominent strategies and functions that have been adopted or considered by subfederal governments.

Integrated Permitting

The preponderance of survey respondents supported developing more integrated permitting procedures, regardless of their state or province of residence and group affiliation (Table 1). The proliferation of permits and the fragmented way in which they are reviewed in many states and provinces has long served as a lightning rod for criticism of prevailing approaches to environmental protection. Although most state permitting reforms of the 1980s focused on procedural efficiency rather than substantive integration, cross-media issues have served as the major, if not exclusive, driving force behind permit reform in a growing number of cases in more recent years. Among these, Minnesota has been perhaps the most innovative, with its most recent experiment in permit integration being the Lake Superior Partnership Plan. Under this plan, the Minnesota Pollution Control Agency (MPCA) has targeted major firms along Lake Superior (many in or near Duluth) that receive numerous, single-medium permits and release major amounts of toxic substances. The MPCA has assembled a team of inspectors from various medium specializations who visit facilities and examine compliance with each permit and search for any cross-media transfers that may have been caused by fragmented permit implementation. But more than just integration of traditional permits, the inspection teams are also given the responsibility of promoting pollution prevention in all interactions with these facilities and providing technical assistance on any pollution prevention matters that might emerge. Such assistance may include direct involvement by state authorities in a follow-up visit. Officials from both the MPCA and Minnesota Office of Waste Management (MOWM) envision this as a model for coupling permit integration with pollution prevention initiatives throughout the state. "We're trying to break down these barriers in permitting, and this is part of an ongoing experiment with how best to do this," explained one state agency official.

State officials have also developed a "flexible permit" for major industrial firms that offers greater flexibility in attaining approval of manufacturing process changes covered by the permit. In exchange, permit recipients must achieve dramatic emissions reductions and secure substantial improvements in facility monitoring. The first permit under this program was issued in 1993, resulting in dramatic decline in volatile organic compound emissions from a major tape manufacturing plant, and it has been widely supported by all involved stakeholders (Rabe, forthcoming).

Several other Great Lakes states and provinces have also attempted to develop more integrated permitting procedures. Among the most far reaching of these efforts is New York's "integrated facility management" plan. This proposal builds upon a multiyear project in which all medium-specific permit requirements for Rochester's Kodak Park were managed by a multi-disciplinary team of regulators. New York's Department of Environmental Conservation (DEC) has developed an integrated facility management pilot program for toxic substances for select industries within the state. The program uses multi-disciplinary teams to integrate all aspects of the regulatory process (permitting, compliance, remedial action). One facility per region has been selected by such a team. These facilities then are required to develop a Toxic Release Inventory (TRI) Plan, after which they are subjected to multimedia permitting inspections, compliance, and remedial actions, as necessary. The program will be financed in part by a fee attached to the first year TRI reporting data. The response to this proposal has generally been enthusiastic, although its critics have charged that it is too complex and is too labor intensive to be used on a widespread scale.

Environmental Impact Assessment

Environmental impact assessment remains a bit of an enigma in terms of its capacity to deliver cross-media integration of environmental management. Long thought to hold integrative potential given its required cross-agency examination of anticipated environmental impacts, it has been in many respects overshadowed at the federal level in both Canada and the United States by medium-based pollution control programs. Nonetheless, survey findings indicate general agreement that it retains considerable integrative potential.

There was substantial support for environmental impact assessment among the survey respondents. It was viewed as having the greatest potential for producing more integrated environmental policy of eleven major management functions, ranking well ahead of other functions such as inspection and rulemaking. One respondent commented, for example, that environmental impact assessment "forces us to look at all of the impacts for a given project or proposal. Even if we view a problem as predominantly a water pollution issue or an air pollution issue or a mining issue, we still have to evaluate the impact on other media. In preparing these analyses, we all have to talk to each other. It forces us to consider cross-media issues." There was, however, some variation in respondents' support for environmental impact assessment depending on the state or province in which they live. Survey respondents from Ontario were especially positive about the potential of environmental impact assessment, whereas respondents from Michigan were the most skeptical.

Within the Great Lakes Basin, the New York State Environmental Quality Review Act (SEQRA) is widely acknowledged as the strongest ongoing program of this nature at the state or provincial level. This law requires agencies or, where appropriate, permit applicants to prepare environmental impact statements "on any action they propose or approve which may have a significant impact on the environment." Agencies that carry out or approve an action subject to an environmental impact statement are to make, to the maximum extent practicable, "decisions which minimize or avoid adverse environmental effects, consistent with social, economic and other considerations of public policy." The New York program has become an increasingly effective tool of integrated management in recent years. SEQRA's potential for such integration has been fostered by the New York Department of Environmental Conservation's (DEC) willingness to employ it aggressively to force consideration of the multiple environmental - and media - concerns involved in a single project proposal. Moreover, the enactment and implementation of SEQRA also bolstered other legislation that was intended, at least in part, to foster integrated environmental decision making.

Agency Organization

Subnational governments have employed a wide variety of administrative measures for fostering greater inter-program coordination in recent years. Although no two states or provinces in the Basin have devised identical coordination measures, most have been guided by an interest in developing a more integrated environmental management system. The strategies have ranged from far-reaching institutional reorganization to modifications in fairly routine meeting procedures.

One of the most widely used techniques for achieving greater integration in earlier periods was the gathering of disparate state environmental programs under the umbrella of a single agency. In practice, however, these organizations have generally tended to ossify single-medium divisions reflected in national legislation. By contrast, some Basin states, such as Ohio (and other states such as Iowa and Massachusetts) have attempted more far-reaching reorganizational reform in more recent years. In these cases, medium-specific environmental divisions, such as air, water, and land-based programs, have been replaced with functional divisions or bureaus, such as enforcement, planning, and auditing, which are intended to foster greater integration. In Canada, Quebec has recently completed a similar reorganization.

In general, survey respondents supported further departmental reorganization, although of all strategies identified in Table 1, this strategy drew the greatest opposition, with 29.9 percent of all respondents somewhat or strongly opposing the measure. Indeed, there is some evidence, as in the Ohio case, that suggests that major departmental reorganization can produce turf battles that further cement traditional rivalries among medium-based constituencies. There are, of course, a range of administrative techniques short of full-blown departmental reorganization that may assist in developing more integrated environmental programs. Many of these have been attempted within the Basin in recent years. A technique commonly used in most states in the Basin, for example, involves cross-disciplinary task forces or working groups. Over three-quarters (78.8 percent) of survey respondents supported increasing the use of such task forces designed to tackle cross-media pollution problems (Table 1). The greatest levels of support were from representatives of environmental advocacy groups; agency officials and industry were somewhat less supportive.

Wisconsin's Department of Natural Resources (DNR) has developed an innovative variation of interdisciplinary task forces called "technology" (or "tech") teams. These multimedia teams of agency officials and client representatives (from industry or agriculture) are organized to develop policy recommendations for particular environmental problems that have a bearing on more than one agency or medium-specific bureau. Examples of cross-disciplinary problem areas for which tech teams have been established in Wisconsin include medical waste, pulp and paper, asphalt paving, electric power generation, and salvage yards. One of the most comprehensive of these efforts was the agriculture tech team, which was designed to better integrate agricultural activity with environmental goals. More generally, according to a state official, tech teams give such cross-cutting "issues a home, a place to go where there's residence-developed expertise in a single location rather than split among three, four, or five different bureaus where you would then have to pull all of those people together to make sure that we were giving a consistent answer to a question."

Another organizational mechanism that bears some potential for producing more integrated environmental policy is the allocation of extensive multi-program authority to a series of geographic district offices. A leading example of this decentralized, regional approach to environmental management is the broad policy-making authority granted to Wisconsin's six field district offices. Each Wisconsin field director is responsible for "the total mission" of the department in his or her district and for managing the department's field operations (Wisconsin Legislative Reference Bureau, 1990; 524). The district directors' main responsibilities include program control and management of department operations; issuance of water regulation permits; environmental impact assessments; land acquisition; and land appraisals. District directors tend to be generalists who oversee and manage the multi-media activities of the district's staff; they report directly to the Office of the DNR Secretary in Madison.

In Michigan, New York, and Wisconsin, an important "integrating" mechanism has been the use of the deputy director, an administrative position just below the departmental secretary and above the medium-specific environmental division directors. These officials are not at such a high level that they are constantly in the public eye nor are they positioned within the narrowing confines of a single program or medium focus. Instead, they tend to have oversight responsibilities for programs in all media and assume a good deal of the day-to-day, top-level administrative burden within their respective agencies. According to one agency official in Michigan:

The Deputy Directors play an important integrating role; they have to maintain a multi-media perspective most of the time. If there's a disagreement between the different media-based programs, as there always is, there is a referee in a position of authority to solve that disagreement. Other states rely on the different divisional directors to work out their differences - they don't have this person to arbitrate their disagreements.

This position has provided an important base for integration entrepreneurs in multiple states within the Basin.

Finally, some environmental agencies have rotated senior staff among the different medium-specific divisions as a way of promoting greater regulatory integration. If successful, these rotational assignments familiarize senior staff with the leading issues facing each medium, helping to educate and train them to think in a multi-media fashion. This strategy has been attempted with particular frequency in Wisconsin, another part of that state's multifaceted effort to promote greater integration. One senior state agency official explained this effort:

Our air director used to run a major element of our water program. Our solid waste and hazardous waste director, one person, used to run industrial waste water permitting. Our water supply director has run both the solid and hazardous waste program and the municipal waste water program. Before that she worked in laboratory liaison and administrative staffing for work planning and budgeting. So, we have tried to rotate assignments. And we do, on an acting basis, reassign people when we can within the program - across media. Now, what we have not done is arbitrarily changed hats.

Mass Balance

The shift toward integrated environmental management may also be accelerated by the refinement of a variety of methodological tools which make it increasingly possible to consider cross-media and cross-jurisdictional pollution transfers. Many of these tools fall under the general heading of mass balance approaches. Under such approaches, the quantity of contaminants that enter an ecosystem or subsystem, less the quantities stored, transformed, or degraded within the system, must be equal to the quantity leaving the system. If the quantities do not balance, either there are sources which have not been identified and quantified, or the measurement of the quantities entering or leaving is not accurate (Muldoon and Valiante, 1989). The U.S. EPA has refined such methods through its Integrated Environmental Management Project to demonstrate numerous problems stemming from cross-media transfer in various regions of the United States (Schmandt, 1985; Cohen and Weiskopf, 1990). In Pennsylvania, for example, major concentrations of airborne volatile organic compounds proved traceable to volatilization from a wastewater treatment plant (EPA, Office of Policy, Planning and Evaluation, 1986). In the Great Lakes, mass balance analyses have been used to document numerous instances of toxic substance contamination of surface water through air deposition (Colborn et at, 1990). In the Green Bay "remedial action plan," for example, a mass balance modeling framework is being used to offer greater understanding of the sources, transfer, transport, and fate of toxic substances and ultimately lead to more integrative regulatory authority (Harris, 1992; DePinto, 1994).

Survey respondents generally thought that mass balance analysis would be useful in facilitating an integrated approach to managing the Great Lakes Basin. However, one-fifth of all respondents expressed no opinion at all, which may reflect a general lack of understanding of just what mass balance analyses entail. There was relatively little variation in respondents' attitudes according to their group affiliation. Critics allege that a chief difficulty with mass balance is the insufficiency of available data. It seems likely, however, that increasingly sophisticated and reliable data from community right-to-know programs and related state-based sources will strengthen the capacity of agency officials to conduct mass balance analyses and make effective use of them. Such programs require a wide array of industrial firms to report releases of numerous toxic substances into all media each year.

Pollution Prevention

Many of the attempts to better integrate single-medium pollution programs discussed above may serve as forerunners of even more fundamental environmental regulatory reforms. Gathered under the broad umbrella of "pollution prevention," there is growing commitment within the Great Lakes Basin to developing programs that lead to substantial reductions in the amounts of pollutants released into any medium. In fact, the growing evidence of cross-media pollution transfer - and the revelation that many purported control strategies may be inadvertent transfer strategies - has dramatically increased interest in preventive approaches.

Any steps toward prevention are striking in that American policy analysts estimated in the mid to late 1980s that less than 1 percent of all funding allocated to environmental regulation in the United States was devoted to approaches that can be characterized as "preventive," including such overlapping categories as "source reduction," "waste reduction," and "toxic use reduction" (U.S. Office of Technology Assessment, 1986; Hirschhorn and Oldenburg, 1991). Canada and its provinces have an even more modest record in prevention than the United States, although they have begun to take some initial steps during the 1990s.

Nonetheless, pollution prevention alternatives are receiving growing consideration - and resource support - at all levels of environmental governance within the Great Lakes Basin. Forty-nine states, including all 8 in the Basin, have devised some type of pollution prevention program in recent years, as have Ontario and Quebec (U.S. General Accounting Office, 1994). Both American and Canadian federal governments have made some overtures toward prevention in recent years, with Washington developing a series of grant and incentive programs to states that cover nearly one half of Basin states' overall pollution prevention expenditures. The great majority of state and provincial initiatives remain focused on basic information dissemination and agency technical support for firms seeking to reduce pollution output. Among this genre of programs, the Minnesota Technical Assistance program (MnTAP) is one of the best known in the Great Lakes Basin, and North America more generally, having played an active role in providing technical assistance in pollution prevention to industries located within the state since the mid-1980s.

Such programs, however, are increasingly being supplemented with more aggressive initiatives that formally incorporate them into the state regulatory process. States such as Minnesota clearly fit this pattern, with a host of new pollution prevention initiatives designed to build upon earlier ones. In fact, MnTAP got a significant boost from the 1990 Minnesota Toxic Pollution Prevention Act, which emphasizes the prevalence of cross-media transfers from pollution control efforts as a central reason for pursuing cross-media integration and pollution prevention with unprecedented vigor. This legislation calls upon all facilities required to report chemical releases under federal and state community-right-to-know legislation to submit "toxic pollution prevention plans" for review by state environmental officials. Approximately 350 Minnesota firms must comply with these requirements, which call for preparation of comprehensive plans that outline their current use and release of toxic pollutants. They must also establish formal goals for eliminating or reducing their use and release of these substances. These plans must be updated on an annual basis by reports that describe and certify progress made toward meeting each pollution prevention performance goal specified in the plan. State officials have developed supplemental state requirements that require eligible firms to release additional data and set more exact timetables for reducing toxic releases. "These plans present a whole new wrinkle for us in our pollution prevention efforts," explained one state official. "Whereas the right-to-know program has led to the generation of lots of data, it hasn't always been clear as to how to best use it. But since it provides information on release of toxics into all media, we're finding it an invaluable source for considering cross-media transfers and targeting pollution prevention plans."

The Minnesota program also has developed a novel mechanism for funding pollution prevention efforts through fees on facilities that release toxic substances. The initial increase in funding has enabled MnTAP to more than double its staff, making possible considerable state technical support for industries as they devise and implement their toxic pollution prevention plans. The state is also attempting to link these activities with its efforts to integrate permitting, inspection, and other parts of the regulatory process.

Minnesota is not alone among Great Lakes states or provinces in moving rapidly into pollution prevention. New York's Department of Environmental Conservation (DEC), for example, has established a Waste Minimization Section in the Division of Hazardous Substances Regulation and given this new section a formal role in the hazardous waste permitting process. This section has developed new regulations that require submission of hazardous waste "reduction plans" and "impact statements" as part of the process of applying for hazardous waste management permits. This impact statement process is designed to force each permit applicant to review options for minimizing or reducing wastes that are generated instead of merely releasing them to one or more medium. In addition, the DEC has begun to introduce waste minimization impact statements into other medium-based permit programs so as to further formalize consideration of possible waste reduction measures and minimize any possible cross-media transfers.

New steps toward pollution prevention at the regional level are also likely in the years ahead and have been actively encouraged by the International Joint Commission (IJC). Commission authority is narrowly defined, although it has promoted integrated approaches to regional water quality and developed the remedial action plan (RAP) process. The 52 RAPs being developed at "toxic hot spots" around the Basin, under IJC oversight, involve planning activities expressly designed to explore integrative, preventive options for each of these endangered areas (Hartig and Zarull, 1992).

Regional initiatives, attempting to coordinate preventive, integrative activity both within and across state and provincial boundaries, are also being encouraged by multi-state institutions such as the Council of Great Lakes Governors and the Great Lakes Commission, among others. These face considerable fiscal, political, and constitutional limitations, and some have encountered difficulty in fully incorporating Canadian provinces into regional policy deliberations. Nonetheless, they are contributing to a growing regional recognition of the problems of cross-media pollution in the Great Lakes Basin (Rabe and Zimmerman, 1995).

Conclusions

A growing array of initiatives have been undertaken to foster greater integration of environmental management in the Great Lakes Basin. These initiatives suggest that, despite the enduring impediments to integration, many mechanisms can in fact be conceptualized, gain acceptance from diverse stakeholders, and be implemented through various state or provincial agencies. States such as Michigan, Minnesota, New York, and Wisconsin have been especially active in recognizing the shortcomings of single-medium pollution control programs and devising more integrative methods of environmental management. Given the profound complexity of cross-media pollution problems and the range of impediments to integration, these developments are quite remarkable. They suggest far greater promise for integration than does much of the existing literature, particularly at the subfederal level. They further indicate a series of political and technical developments that may be making integration more desirable and feasible than ever before. In particular, the convergence of health-related focusing events, technical advancements that help refine the set of available regulatory tools, an increasingly receptive political climate within the region, and effective entrepreneurship by agency officials, appear to foster these steps.

The developments in the Great Lakes Basin do not, of course, assure that an era of integrated environmental management is about to be ushered in across North America. Even within the Basin, there remain numerous uncertainties about the extent to which integration will be undertaken and what environmental and economic impact it will have. Many of the innovations discussed in prior pages remain relatively new and untested, and the continuation of some may become vulnerable when the region faces economic downturns. Moreover, the long-term challenge of integration calls for coordinated strategies across individual state and provincial boundaries. Despite the growing importance of regional institutions and approaches in the Basin, a good deal of the integration we have found operates on an intrastate basis, with no formal linkage to other states or provinces. Finally, not all states or provinces within the Basin have proven as willing or as capable of pursuing integrative strategies as those states featured in this article. For example, Ontario, which borders four of the five Great Lakes, has made only halting steps toward integration of any sort, in many respects maintaining the medium-based regulatory approach dominant in most Basin states a decade or more ago. Thus, any true cross-Basin integration remains problematic at best.

There are also uncertainties concerning the extent to which the Basin experience is being - or can be - replicated in other North American regions. Many factors would lead one to anticipate that the Great Lakes Basin would take a lead role in this area. States within the Basin have historically ranked among the most active nationally on environmental issues and the Basin has a unique history of institutions devoted to its protection. By contrast, it remains uncertain whether other regions, such as the Chesapeake Bay or the Puget Sound, or other areas lacking such clear regional definition, will be able to follow a similar pattern or instead adhere to traditional, medium-based strategies.

Nonetheless, these findings from the Great Lakes Basin are significant. They represent not only a more hopeful view of the possibilities for environmental policy but also contribute to a basic change in the debate of the future of environmental management. Rather than argue whether integrated environmental management could ever be moved from concept to practice, a dominant theme in the 1970s and 1980s, there is now, at least in one region, a sizable body of innovations that can be examined and expanded if desired. There is also a growing community of policy professionals, representing state and regional agencies, environmental advocacy groups, and industry, who appear eager to further experiment with and develop integrated environmental programs. This shifts the debate from its highly theoretical origins to one that can increasingly be grounded in real practice and experience.

Notes

The author is grateful for the research assistance of Janet Zimmerman and for financial support from the Joyce Foundation. He also appreciates the helpful comments from participants in a Public Affairs Workshop of the La Follette Institute of Public Affairs at the University of Wisconsin-Madison, where an earlier version of this article was presented, and from anonymous reviewers.

1. The methods used in this study consisted of an in-depth written survey followed by a series of semi-structured interviews. A pilot test survey was mailed to 40 people, then refined and mailed to 1,045 individuals from each case study states and province (Michigan, New York, Ontario, and Wisconsin). Survey respondents represented a diverse body of individuals involved in Great Lakes policy making, including representatives of environmental advocacy groups, executive agencies, industry, regional planning bodies, and state and provincial legislatures. Six-hundred and thirty surveys were returned, yielding a total response rate of 60.3 percent. There was little return rate or sample size variation among professional groups or subnational units. The survey covered an extensive range of issues related to cross-media integration and regulatory fragmentation in the Great Lakes Basin.

Following the survey, 50 individuals were interviewed from environmental agencies, industry, and advocacy groups in the four case study states and province, as well as neighboring states. Individuals from several other institutions were also interviewed, including representatives of the U.S. EPA in Washington, D.C.; various research institutes involved in Great Lakes matters; the EPA's Great Lakes regional office in Illinois; and the Canadian federal environmental agency, Environment Canada, in Ottawa. The interviews served two main purposes. First, they yielded descriptive information on the various efforts of the case study states and province to develop integrated environmental programs. Second, they provided interviewees with an opportunity to elaborate on their responses to the survey, which made it possible to probe more deeply into the reasons behind some of their opinions. Most of the interviews were tape recorded and then transcribed. All interviews were confidential.

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