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Command and Control Regulation in Action

Command and Control Regulation in Action. Regulating Industrial Water Pollution in the US. Clean Water Act of 1972. Sets national goals as zero-discharge of pollution by 1985 2 Main Policy Tools Construction grants program $$

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Command and Control Regulation in Action

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  1. Command and Control Regulation in Action Regulating Industrial Water Pollution in the US

  2. Clean Water Act of 1972 • Sets national goals as zero-discharge of pollution by 1985 • 2 Main Policy Tools • Construction grants program $$ • Technology based regulations for discharge of water pollution from point sources

  3. National Pollutant Discharge Elimination System • EPA- establishes Federal Effluent Guidelines • States– write,monitoring, and enforce NPEDS permits • Main Targets • Biochemical oxygen demand (BOD) • total suspended solids (TSS) • 15 pollutants of concerns, (metals i.e. arsenic and mercury)

  4. POTW publicly owned treatment works

  5. POTW

  6. POTW • Tech Regulation • Primary treatment (skimming, screening, settling) 65% • Secondary treatment - 80-90% • Criteria on uses for sludge • ensuring effective operation and maintenance

  7. Direct Discharges from Industrial Plants

  8. Direct Discharges from Industrial Plants • EPA guidelines for 30 designated industries • best practicable technology by 1977 • Best Available Tech by 1983 • New Source Performance Standards

  9. Complexity • Dairy Standards • Different standards for subcategories • Acceptable pollutant discharge rates vary • BOD 30 day standard for large facilities Butter .55kg per 1000 kg of BOD input; Cottage cheese 2.6, Ice bream 1.84, Condensed Milk 1.38, Dry Milk .65 • Separate limits for one day maximum discharge, 30 day average, for small and large facilities.

  10. Indirect discharges from industrial plant • Industrial plants to POTW • Pretreatment guidelines

  11. Rulemaking Process • Information Requirements • Writing of direct discharge standards • How to operationalize best, practicable, economically achievable • Need information on production techniques, location, waste products, and waste treatment tech • heterogeneity --360 industrial subcategories among first 30 industries requiring effluent guidelines • separate BPT, BAT, NSPS< and pretreatment regulations

  12. Rulemaking Process • Role of consulting firms • Proposed standards, industry comment • 250 lawsuits

  13. Regulatory Output • BPT - 1 year • BAT standards – 1/3rd done by 1995 • Zero Discharge – still waiting

  14. Abatement Costs • Big variation in incremental costs • Estimate of costs > than actual

  15. Compliance • Assumption- 97% reduction in discharge of priority pollutants • Compliance – mixed • 6% of major direct dischargers -significant noncompliance • % of US served by POTWs increases from 42% to 74% • POTW pretreatment- 54% of significant indutstrial users were in significant noncompliance (1992)

  16. But is the water cleaner? • Some big successes- Potomac, Delaware • Lack of data,

  17. Perverse Incentives • Expansion of POTW Construction Grants Program • shift from direct discharge towards indirect discharge

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