ATTACHMENT C: SOURCES ON ENVIRONMENTAL REPORTING AND PERFORMANCE MEASURES
This attachment contains:  
•	Sources on Environmental Reporting
•	Sources on Performance Measures
Sources on Environmental Reporting

This attachment provides an overview of several major initiatives relative to corporate environmental reporting. It is designed primarily to assist participating facilities to access information that may be helpful in developing annual reporting procedures and formats.
•	United Nations Environment Program ‑ Technical Report on Corporate Environmental Reporting
•	Coalition for Environmentally Responsible Economies (CERES) – Annual Reporting Requirements
•	Coalition for Environmentally Responsible Economies (CERES) ‑ The Global Reporting Initiative
•	National Academy of Engineering ‑ Industrial Environmental Performance Metrics
•	The Public Environmental Reporting Initiative 
•	European Union  – Eco-Management and Audit Scheme Regulation
•	Investor Responsibility Research Center 
•	University of North Carolina‑ EMS/ISO 14001 Pilot Project Data Protocols 

United Nations Environment Program
•	Technical report: corporate environmental reporting

Published in 1994 the report is an overview of the state of the art in environmental reporting. It is rich with references to corporate environmental reports in a wide variety of industries. The heart of the document is a description of “the 50 reporting ingredients” based on what companies are reporting and on “what they may need to report to meet emerging stakeholder expectations” p.30). The document lists key indicators for each ingredient.

UNEP 50 REPORTING INGREDIENTS	
I. MANAGEMENT POLICIES & SYSTEMS	27. Life-Cycle Design	
1. Top Management Statement	28. Packaging	
2. Environmental Policy	29. Product Impacts	
3. Environmental Management System	30. Product Stewardship	
4. Management Responsibilities	III. FINANCE	
5. Environmental Auditing	31. Environmental Spending	
6. Goals and Targets	32. Environmental Liabilities	
7. Legal Compliance	33. Economic Instruments	
8. Research and Development	34. Environmental Cost Accounting	
9. Program and direction	35. Benefits and Opportunities	
10. Awards	36. Charitable contributions	
11. Verification	IV. STAKEHOLDER RELATIONS	
12. Reporting Policy	37. Employees	
13. Corporate Context	38. Legislators and Regulators	
II. INPUT/OUTPUT INVENTORY	39. Local Communities	
14. Material Use	40. Investors	
15. Energy Consumption	41. Suppliers	
16. Water Consumption	42. Customers and Consumers	
17. Health and Safety	43. Industry Associations	
18. EIAs and Risk Management	44. Environmental Groups	
19. Accidents and Emergency Response	45. Science and Education	
20. Land Contamination and Remediation	46. Media	
21. Habitats	V. SUSTAINABLE DEVELOPMENT	
22. Wastes	47. Global Environmental Issues	
23. Air Emissions	48. Global Development Issues	
24. Water Effluents	49. Technology Cooperation	
25. Noise and Odor	50. Global Operating Standards	
26. Transportation		

Another valuable section of the document (p. 57-60) identifies environmental topics and impacts that seven “environment-intensive” industry clusters are encouraged to report on: 1) Chemicals, 2) Oil and gas, 3) Metals and mining, 4) Pulp and paper, 5) Consumer goods, 6) Travel and tourism, and 7) Banking and finance. Also mentioned are energy utilities, textiles, leather tanning and retail.
The report rates CERs on a scale of stages 1 to 5.
1.	Green Glossies, newsletters, videos. Short statement in annual report.
2.	One-off environmental report, often linked to first formal policy statement.
3.	Annual reporting, linked to environmental management system, but more text than figures.
4.	Provision of full TRI-style performance data on annual basis. Input-output data for service companies. Corporate and site reports. Available on diskette or online. Environmental report referred to in annual report.
5.	Sustainable development reporting. Aim: no net loss of carrying capacity. Linking of environmental economic and social aspects of corporate performance supported by indicators of sustainability. Integration of full-cost accounting.
Of the 100 “pioneers” reports (published in 1992-1993) audited in the report, none received a stage 5, only five received 4, and eleven received 3-4.
The report also promotes the advantages of independent 3rd-party validation, and describes a set of minimum conditions for verification which are described in the Chapter 6 of this Program Guide on verification.
The document also highlights several central issues in environmental reporting:
Usefulness
•	Comparability – Performance data must be comparable; Industry associations should develop templates for presentation of environmental statistics; external benchmarking should be employed more
•	Scope – Companies should be clear whether they adopt an inventory approach (direct impacts within the fence) or life-cycle (upstream and downstream)
•	Credibility – Some companies have used external verifiers
•	Quantification – The more the greater the utility; Industry associations should define performance indicators
•	Transparency – Is paramount, including publication of both assumptions and methods
•	Extendability – Make it upgradable for future requirements
Feasibility
•	Sector Capabilities – Industry associations should help build capabilities of members
•	Reporting Burdens – An EMS makes reporting more feasible
•	Confidentiality – Industry association reports could make more sensitive data anonymous
•	Controversy – Reports are just one element of a wider stakeholder communication
•	Time-scales – Development and debate on environmental reporting will go on another 5-15 years
The report concludes noting that little is being done, but much needs to be done, on moving toward sustainability reporting.
The UNEP also defines procedures and conditions for verification of the accuracy and reliability of corporate environmental reports. 

United Nations Environment Program ‑ Minimum Conditions for Verification
The verifier and reporter [should] respect the following minimum conditions:
•	Availability of all raw data and other information – and of the analysis – used to compile the report.
•	An opportunity for the verifier to sample and track data collection and analysis methods from site level through business unit to company-wide results.
•	The verifier must be allowed to:
•	define scope of verification with reporter;
•	chose sample locations
•	interview any staff required
•	check any documentation as needed.
•	Freedom for verifier to give professional opinion in the statement which reflects:
•	the limits and scope of the verification conducted
•	the real findings (i.e. both the good and bad news).

Contact
United Nations Environment Programme, 39-43, Quai Andre-Citroen, 75739 Paris Cedex 15, France
SustainAbility Ltd., The Peoples Hall, 91-97 Freston Rd., London W11 4BD
Publication
UNEP and Sustainability Ltd., Technical Report #24 Company Environmental Reporting, A Measure of the Progress of Business & Industry Towards Sustainable Development, Technical Report #24, 1994.

Coalition For Environmentally Responsible Economies
•	
•	Annual Reporting Requirements
The Coalition for Environmentally Responsible Economies (CERES) is a not-for-profit organization begun in 1989 to obtain and provide better information about corporate environmental performance for investors. CERES is best known for the ten CERES Principles. Corporations, in adopting the CERES principles, make a commitment to sustainable operations (using the Brundtland Commission definition of sustainability), continuous improvement, going beyond the requirements of law, and updating their practices in light of advancing technologies and understandings. The ten principles are written as commitments to performance improvement and establish an environmental ethic and criteria by which investors and others can assess their environmental performance. 
The ten principles include:
1.	Protection of the Biosphere
2.	Sustainable Use of Natural Resources
3.	Reduction and Disposal of Wastes
4.	Energy Conservation
5.	Risk Reduction
6.	Safe Products and Services
7.	Environmental Restoration
8.	Informing the Public
9.	Management Commitment
10.	Audits and Reports 
The 46 companies (as of the 1997 Annual Report) that have adopted the CERES Principles include large corporations such as Coca Cola, General Motors, BankAmerica Corporation, and ITT Industries, and regional companies such as Nature’s Fresh Northwest.
The tenth Principle requires companies to perform an annual audit and complete a voluntary annual report to CERES. CERES provides a 34-page standard report form, and a short version for smaller or non-manufacturing companies. The report format was crafted through a collaborative effort of companies, institution investors, environmental organizations and other stakeholders. The Report form is revised and improved annually. Its purposes are:
•	To standardize the disclosure of environmental performance data
•	To facilitate the establishment of baselines and goals
•	To provide simultaneously provide an internal management tool and external communication tool
•	To provide a mechanism for mutually assessing trends and recommending improvements.
Companies may utilize this form, or produce a narrative report. The narrative report format must be consistent with the form and approved in advance by the CERES Report Committee. The Standard form includes the following sections:
1.	Company Profile
2.	Environmental Policies, Organizations and Management
3.	Workplace Health and Safety
4.	Community Participation and Accountability
5.	Product Stewardship
6.	Supplier Relationships
7.	Use of Natural Resources
8.	Emissions and Waste
9.	Compliance
10.	Priorities and Challenges
Copies of companies’ reports are available from CERES, and increasingly will be available on their web site.
Contact
Judy Kuszewski, Director of Corporate Programs, CERES, Tel: 617/247-0700, kuszewski@ceres.org., www.ceres.org
Publication
1997 CERES Report Standard Form – downloadable off their web site.

The Global Reporting Initiative (CERES)

In fall 1997 CERES initiated a Global Reporting Initiative (GRI) with the explicit objective to standardize corporate sustainability reporting through a global, voluntary and multi-stakeholder process. A number of corporations and organizations are actively involved in the Steering Committee and Working Groups. Completion is scheduled for December 1999. The intent is to develop three tools:
1.	A set of core metrics applicable to all business enterprises
2.	Sets of sector-specific metrics customized to specific types of enterprises
3.	A uniform format for reporting these metrics and related information.
In addition GRI intends to identify or help create a permanent home to monitor, advocate and continually upgrade the practice of standardized reporting worldwide.
The CERES commitment is that standardized reporting can mobilize the power of information and the marketplace to reward performance and “raise the bar on sustainability excellence”. Currently each corporation uses its own format and metrics in CERs which “yields far less value than they could or should.”
The report “Green Metrics,” cited below, provides an overview of environmental reporting, summarizes reporting guidelines worldwide, and makes a case for standardization. In addition to the reporting ingredients identified by UNEP above, the report identifies four additional reporting elements that are required by some reporting initiatives:
1.	New/modified product lines
2.	New/modified production facilities
3.	Environmental justice activities
4.	Normalization of metrics
The report states that “standardized environmental reporting should take its place alongside financial reporting as a tool for investors, communities and consumers.” The payoffs for this ‘universal currency’ of reporting would be: “expanded credibility of CERs through a standardized format, protocol and metrics with buy-in from multiple stakeholders; simplification of the reporting process for companies; enhanced value of reported information; and quick and reliable benchmarking.”
They view these reporting rules as possibly analogous to those of the Financial Accounting Standards Board, and perhaps to be incorporated into ISO or country-specific standards. 
Sustainability Reporting Guidelines In March 1999 CERES-GRI published a draft of the Sustainability Reporting Guidelines for public comment and pilot testing. The report includes a preamble, the Guidelines and a set of appendices. The preamble explains that the Guidelines, which are out for public review until the end of 1999, are intended to provide a flexible framework for voluntary reporting about environmental social and economic aspects of a company’s performance. It also provides a set of Reporting Principles that address qualitative characteristics of reports, underlying assumptions, and a hierarchy of performance reporting elements.
The Guidelines consist of nine parts:
1.	CEO Statement
2.	Key Indicators
3.	Profile and Financial Performance
4.	Policies, Organization and Management Systems
5.	Stakeholder Relationships
6.	Management Performance
7.	Operational Performance
8.	Product Performance
9.	Sustainability Overview
Many issues remain to be resolved in this initiative. Specific issues that are identified in the report include verification methodologies, adaptation to small and medium sized businesses, further development especially of the social and economic guidelines, and harmonization with other initiative worldwide.
Contact
Judy Kuszewski, Director of Corporate Programs, CERES, Tel: 617/247-0700, kuszewski@ceres.org., www.ceres.org
Publications
Allen White and Diana Zinkl of Tellus Institute for CERES, “Green Metrics: A Global Status Report on Standardized Corporate Environmental Reporting”, 5/98.
Global Reporting Initiative, “Sustainability Reporting Guidelines, Exposure Draft for Public Comment and Pilot Testing”, 3/99, available for download off the web site.

National Academy of Engineering Industrial Environmental Performance Metrics

The National Academy of Engineering launched a study of industrial environmental performance metrics. Though not explicitly addressing environmental reporting per say, it addresses a critical element of a report, the use of performance metrics. The “study is designed to examine the advances made in measuring industrial environmental performance and to seek methods by which improvement can continue.” 
The study will bring together selected representatives of US Industries, academia and NGOs to examine the state-of-practice and identify opportunities for improvement. Following the study an international conference will be organized to facilitate the transfer of the knowledge and technology of environmental performance measure, especially amongst APEC countries.
The study is focusing initially on four industries:
1.	Automotive
2.	Chemical
3.	Electronics
4.	Pulp and paper
The study intends to identify metrics that may facilitate comparison across industries, and so may have value in identifying performance measures. In addition they intend to try to link the environmental burdens, which are often reported in CERs, with actual impacts, e.g. health or ecosystem effects. 
Like CERES, the NAE sees a threat from the proliferation of reporting schema. “It is often difficult to develop sufficiently comparable information on environmental performance across a single company, let alone a whole sector, or nation.” (Frosch p.11)
The study has identified the following challenges in the pursuit of broader and more robust environmental metrics:
•	“improved standardization of metrics both within and across industry sectors,
•	disseminating best practices more widely;
•	applying metrics across the entire supply chain and product life cycle;
•	developing new analytic tools (e.g. impacts vs. loads);
•	addressing emerging environmental issues (e.g. ecosystem health, sustainability).”
Publication is scheduled for late March, 1999.
Contact
Mr. Gregory Characklis, National Academy of Engineering, 2101 Constitution Ave. NW, Washington, DC 20418, gcharack@nae.edu
Publications
NAE, “Opportunities and Challenges in the Application of Industrial Environmental Performance Metrics”
Robert Frosch, “Industrial Environmental Performance Metrics: Challenges and Opportunities”, a presentation at the International Conference on Industrial Environmental Performance Metrics, 11/98

The Public Environmental Reporting Initiative

In 1992 a number of companies convened to develop a specific framework for environmental reporting, in recognition of the growing demand for comprehensive and credible information, coupled with the lack of cross-industry reporting guidelines. The initiative is now international and has resulted in the Public Environmental Reporting Initiative (PERI) Guidelines.
The Guidelines are voluntary to help organizations better meet their stakeholders’ expectations “while recognizing the unique characteristics of an organization’s culture, management system, industry, and scope of business activities.” The Guidelines are intended to maximize flexibility while providing “the context for making facts and figures meaningful.”
The PERI Guidelines include ten report components, each of which contains specific guidance about what should be included:
1.	Organizational profile
2.	Environmental policy
3.	Environmental management
4.	Environmental releases
5.	Resource conservation
6.	Environmental risk management
7.	Environmental compliance
8.	Product stewardship
9.	Employee recognition
10.	Stakeholder involvement
Contacts
Two versions of the Guidelines can be obtained from the following web addresses:
www.ibm.com/ibm/Environment/annual97/ preface.html 
www.nortel.com/cool/Habitat/CommSol/ peri.html

European Union Eco-Management and Audit Scheme Regulation

In 1993 the European Union adopted the voluntary Eco-Management and Audit Scheme which aims to encourage companies “to undertake positive environmental management, including regular audits, and to report to the public on their environmental performance.” Member countries are directed to set up arrangements for registration of companies. Once registered a company is required to follow the requirements of the scheme.
Companies are required to implement an EMS and to perform periodic management system audits. The maximum audit cycle is three years. Upon each audit cycle, the company must issue an environmental statement, designed for the public, with respect to each site. The statement will set out information on:
•	The environmental performance of the site
•	Details of the success in meeting targets
•	New targets for the future
•	The time scale for the next statement.
The statement must be validated by an independent, accredited, environmental verifier. Verifiers are accredited by organizations established in each member country, and are assessed for independence, objectivity and competence.
Contacts
http://www.environment.detr.gov.uk/greening/emas/emashome.htm
http://www.quality.co.uk/quality/emas.htm
British Standards Institution (BSI), BSI Information Centre
389 Chiswick High Road, LONDON, W4 4AL , Tel: 0181 996 7022

Investor Responsibility Research Center (IRRC)

IRRC is an independent, not for profit, research firm founded in 1972 to provide impartial research on proxy voting, corporate governance and corporate social responsibility issues.  The organization's Environmental Information Service with information on over 1500 companies, enabling investors and other stakeholders to evaluate potential environmental liability and other business-related issues.  They provide 3-5 page profiles on all companies in the Standard and Poors 500 index including:
•	Toxic chemicals emissions efficiency index (TRI data normalized to their industry averages)
•	A reported spill index
•	A compliance penalty index (showing which statute the penalties occurred under)
•	Environmental management and policy (corporate responsibility, environmental staff, codes adhered to, and 10K capital expenditure disclosures)
•	Environmental auditing and reporting (audit frequency, by whom, and whether reported)
•	Sustainable development indicators (resource use, recycling, hazardous waste generation, and life cycle analysis)
•	Environmental achievements and projects (voluntary programs, emission reduction goals, etc.)
•	A variety of news and notes.
This report relies on data reported to EPA, notably TRI and accidental release reportings, and environmental management reports. IRRC calculates indices for toxics emissions, spills and compliance penalties, based on industry group and normalized to domestic revenues. This data for each company is presented alongside the industry average and is plotted over time. 
Annually IRRC provides a Corporate Environmental Profiles Directory, in printed form and on CD ROM, that presents aggregated statistics and key findings by industry, statute and year. They offer a software package that calls on their database (see bullets above) to perform benchmarking according to the revenue normalized indices.
These reports are intended to support activities of socially responsible investors, to evaluate companies for making investments and in proxy voting. Their newsletter, “Corporate Social Issues Reporter,” reports on shareholder resolution filings relative to social responsibility issues. For example, they track filings relative to environmental issues such as nuclear plant safety, global warming reporting, CERES principles adoption, discontinuation of PVC use in medical products, chlorine-free paper, and hazardous wastes, as well as issues related to labor, tobacco, alcohol, human rights, military contracting and animal testing.
Contact
http://www.irrc.org
Publications
Corporate Environmental Profiles Directories, and Executive Summaries, for 1994 – 1998, IRRC, Heidi Salkeld, Client Service Manager, 1350 Connecticut Ave. NW, Suite 700, Washington, DC 20036, e:mail://Heidi.Salkeld@irrc.org

EMS/ISO 14001 Pilot Project Data Protocols, University Of North Carolina

The data protocols are a set of environmental data reporting forms that were specifically developed for the state pilot programs that are sponsored by the EPA for the implementation of environmental management systems.  The EPA wishes to evaluate the impact of voluntary EMSs as a possible tool in public policy innovation and decision making. 
The EPA contracted with the University of North Carolina at Chapel Hill (UNC) and the Environmental Law Institute (ELI) to develop a system to collect and analyze standardized and comparable data from a wide variety of pilot project facilities. State and federal regulatory agencies as well as the public will use the database.  The Green Permit pilot facilities used them for reporting their environmental data for the pilot project.
The protocols consist of seven data categories:
1.	Environmental performance
2.	Regulatory compliance
3.	Environmental conditions
4.	Costs and cost savings
5.	Pollution prevention
6.	Interested party involvement
7.	Nature of the management system.
The protocols are organized in two groups. The first group contains two studies that are completed by the facilities during the first year of the pilot program. The first is a detailed description of the facility’s baseline performance. The second study examines how the facility designed its EMS and what features it contains.
The first group of these protocols provide a convenient and reasonably comprehensive set of data requirements which could be used for GEMS facilities to report their baseline information.  The second group contains templates for periodic reporting of performance, including a format for facilities to provide annual environmental reports to the GEMS program.  If facilities use these forms, data on their facility could be included in the national database.
Contacts
Deborah Amaral
University of North Carolina
Chapel Hill, NC 27599 
Phone 919/962-9827 deborah_amaral@unc.edu
www.eli.org/isopilots.htm
Publications
Data Collection Protocols for ISO 14001 Pilot Project Research, June 22, 1998; updated in 1999 (Baseline Performance Protocol and EMS Design Protocols) and 2000 (Update Protocols)
First Project Report, March 1999

Sources on Performance Measures

This attachment provides an overview of several major initiatives to define procedures, metrics or indicators for companies to evaluate or assess their environmental performance, or to compare it to the performance of others. It is designed primarily to assist participating facilities to access information that may be helpful in developing systems for performance measurement. Each initiative examined is evaluated according to the criteria described in the chapter text.
•	Global Environmental Management Initiative – Benchmarking
•	Global Environmental Management Initiative – Measuring Environmental Performance
•	EPA Project XL
•	ISO 14031 Environmental Performance Evaluation (EPE)
•	EDF Chemical Scorecard and EPA Sector Facility Indexing Project
•	World Resources Institute – Toward a Common Framework for Tracking Corporate Environmental Performance 
•	Semiconductor Industry Association – National Technology Roadmap for Environment, Safety and Health
•	World Business Council for Sustainable Development – Eco-efficiency Indicators
•	Measuring Permitted Releases

GEMI ‑ Benchmarking

Global Environmental Management Initiative (GEMI) is a group of 27 companies dedicated to fostering environmental excellence by business worldwide. GEMI promotes environmental business ethics; provides example, research and leadership; and promotes dialogue between companies. 
“Benchmarking: The Primer”, produced by GEMI, outlines a methodology for a business to create an environmental benchmarking structure for itself. Benchmarking is viewed as an internal goal setting element of a Plan-Do-Check-Act (TQEM) performance improvement process. 
The process creates detailed information on the environmental performance of 3-6 “best-in-class” comparable firms. These firms are termed “benchmarking partners”. The firms are selected as most comparable to the home company, and the environmental factors studied are targeted for relevance to the home company’s performance improvement goals.
The Methodology follows a 9-step process:
1.	Project Conception – get management commitment, establish scope, estimate resource requirements, set schedule, form the benchmarking team, develop project specifics
2.	Planning – develop project plan, share with management
3.	Preliminary Data Collection – develop best-in class (6-8) selection criteria, develop data collection forms, establish techniques and sources, collect preliminary data from secondary sources (focusing down on 8-12 most promising candidates, develop baseline of your home company’s current process
4.	Best-In-Class Selection – review and select benchmarking partners, review and refine question set
5.	Best-In-Class Data Collection – schedule and prepare data collection sessions, conduct site visits, prepare site visit report
6.	Assessment – analyze data, define elements of best-in-class model, define home company’s gaps, develop improvement recommendations
7.	Implementation Planning – develop operational plans and change strategies
8.	Implementation – manage and monitor the change process
9.	Recalibration – check and adjust benchmarking findings
Environmental performance parameters are not provided. However, one company is mentioned that used the ICC Business Charter for Sustainable Development as a set of standards.
Time commitment through the first 6 steps of the benchmarking project is estimated to be 122 hours for the team leader and 32 hours for each team member, and taking 9 months.
•	Analysis According to Principles
Pros:
•	GEMI provides detailed procedures that result in good information on selected companies
•	Meets individualized needs of companies and engages management to measure either existing performance or improvement activities
Cons:
•	Expensive and time consuming process
•	Benchmarking is relative to performance of selected other companies, 
•	Delivers only the information that was targeted by the home company 
•	Does not provide an objective, industry-wide standard for environmental performance
GEMI provides a basis of standardized procedures to perform benchmarking. However, without a set of standards, the choice of what information is collected and which ‘partners’ are selected fails to provide certainty or an objective and transparent yardstick. 
Contact
GEMI, 818 Connecticut Ave. N.W., 2nd Floor, Washington, D.C. 20006, Tel: (202) 296-7449
Publication
Benchmarking: The Primer, Benchmarking for Continuous Environmental Improvement, GEMI, 1994.

GEMI ‑ Measuring Environmental Performance

Measuring Environmental Performance: A Primer and Survey of Metrics in Use”, produced by Global Environmental Management Initiative (GEMI), provides a brief overview of environmental metrics used by several companies. The report also outlines certain general principles based on a survey of metric systems.
The different systems in use that they have identified include:
•	Lagging indicators measure outputs, e.g. pounds of pollutant emitted or discharged
•	Leading indicators are in-process measures of performance, e.g. number of facilities/units conducting self audits, or raw material use
•	Environment condition indicators (ECI) measure the direct effect of an activity on the environment
•	Benchmarking against other companies or average industry performance
•	Evaluating progress against codes of management practices developed by trade associations 
•	Measuring progress against principles, goals or corporate management system standards
•	Indices of environmental performance indicators (EPI) to evaluate progress from year to year
•	Measures of sustainability – “efficient use of resources that minimizes impact on the environment” – e.g. an eco-productivity index
•	Measures of business value of environmental performance – an environmental financial statement measuring income, savings and cost avoidance
GEMI identifies pros and cons of some of these tools:
•	Lagging Indicators
Pros
•	Easy to quantify and understand
•	Preferred by public and regulators
Cons
•	Timelag in feedback loop
•	Root causes not identified
•	Leading Indicators
Pros
•	Reflect current or future versus past performance
Cons
•	May not address stakeholder concerns
•	Difficult to quantify and evaluate
•	Hard to build support for use
•	ECI
Pros
•	Measures direct effect of activity on environment
Cons
•	Collecting data is time consuming and expensive
•	Data must often be collected over several years
•	Correlating organization’s operations and effect is difficult, many variables contribute to environment conditions
The report goes on to describe 12 considerations in planning a metrics program, four considerations in implementing a program, four considerations in evaluating a program, and guidance in improving a program. It includes four trends in environmental performance measurement:
1.	Globalization of metrics
2.	Emphasis on sustainability
3.	Increasing emphasis on EMS
4.	Integration of environmental performance with business performance
Four case studies are included.
Contact
GEMI, 818 Connecticut Ave. N.W., 2nd Floor, Washington, D.C. 20006, Tel: (202) 296-7449
Publication
Measuring Environmental Performance: A Primer and Survey of Metrics in Use, GEMI, 1997.

EPA Project XL

The 4/23/97 Federal Register (62FR19873) issued criteria for “Superior Environmental Performance” for Project XL, in order to “further refine the definition of superior environmental performance to assist future applicants, stakeholders and those evaluating the program.” 
It is important to recognize that Project XL is a site-specific initiative, encouraging customized approaches. Therefore the criteria are only defined conceptually and do not directly yield standardized procedures. It uses a two tiered (non-hierarchical) approach:
•	Tier I establishes a quantitative performance benchmark against which the improved performance of the facility under Project XL will be measured. The benchmark is a reasonable estimate of the performance that the facility would have shown absent Project XL. A measure is created of the current actual performance, with possible consideration of future changes required by regulations or permits, and future performance is compared to it.
The benchmarks are measured in terms of environmental loadings (emissions of specific pollutants or generation of waste streams) on the basis of per-unit of production or comparable normalization. Benchmarking can also measure pollution prevention in terms of units of input to production.
In cases of tradeoffs among loadings, projects must produce overall superior performance, with demonstrable net benefits to public health and environment, and without shifting the risk burden.
•	Tier II examines a number of factors that lead EPA to judge that the project will yield superior performance. These factors appear to be a loose set of subjective and objective measures. They include activity measures (such as P2 initiatives, adoption of ambitious improvement aspirations, and addressing community and stakeholder concerns), historical measures (such as demonstrated past leadership or initiatives), and benchmarking (such as benchmarking to best performance practices of comparable facilities).
On 6/23/98 a subsequent federal register (63FR34161) solicited additional XL project applicants and defined a number of -specific environmental performance themes for which they are seeking projects. One of those themes addresses environmental management systems, which specifically encourages the inclusion of stakeholders in the EMS development.
•	Analysis According to Principles
Pros
•	Individuality of environmental objectives and metrics are recognized.
Cons
•	The model is conceptual and does not directly yield standardized procedures or criteria.
•	It does not provide a certain or transparent yardstick for comparing facilities.
The Project XL system does not provide a mechanism to rate or rank facilities, but rather to demonstrate that a facility is improving its performance relative to pre-program levels. Its strength is that it accommodates the individuality of different approaches, but it does not provide standard procedures and criteria for comparison.
Contact
Christopher Knopes, Office of Reinvention, USEPA, Tel: (202) 260-5754
John Palmer, EPA Region 10, Tel: (206) 553-6521
Publications
Web site: http://www.epa.gov/ProjectXL
Federal Register: 5/23/95 60FR27282; 4/23/97 62FR19872; 9/11/96 61FR47929; and 6/23/98, 63FR34161

ISO 14031 Environmental Performance Evaluation (EPE)

ISO 14031 is a voluntary, non-auditable standard in the ISO 14000 series. The purpose of EPE is to be “an internal management process and toll designed to provide management with reliable and verifiable information on an ongoing basis to determine whether an organization’s environmental performance is meeting the criteria set by the management of the organization.” EPE works together with environmental system audits “to assess the status of its environmental performance and to identify areas for improvement as needed.” (quoted from the Introduction to ISO 14031)
The EPE standard, together with its Informative Supplement, places a strong emphasis on developing indicators:
•	Management Performance Indicators provide information about efforts and decisions by managers (e.g. policies, practices, procedures) to influence environmental performance
•	Operational Performance Indicators provide information about the environmental performance of operations (e.g. inputs and outputs)
•	Environmental Condition Indicators provide information about the local, regional or global environmental conditions (e.g. local air quality).
Fundamentally the purpose of indicators is to transform environmental data into information for assessment and action. The chain of logic is as follows:

ACTIVITIES
PRODUCTS
SERVICES

OBJECTIVES
AND TARGETS

ENVIRONMENTAL
ASPECTS

ENVIRONMENTAL
IMPACTS

ENVIRONMENTAL
CONDITION
INDICATORS

MANAGEMENT
PERFORMANCE
INDICATORS

ENVIRONMENTAL
PERFORMANCE
CRITERIA

ENVIRONMENTAL
PERFORMANCE
INDICATORS

OPERATIONAL
PERFORMANCE
INDICATORS

•	Analysis According to Principles
Pros
•	Integrated with and complimentary to ISO 14001
•	Provides extensive guidance and examples that if followed rigorously would provide adequate data for certainty and verification
•	Provides standardized data procedures that recognize the individual needs of organizations
Cons
•	Includes no objective yardstick
EPE provides a sound methodology for developing performance indicators but is designed to meet internal purposes and requires standards for measurement of an organization’s performance.
Contact
US Technical Advisory Group to ISO Technical Committee 207 for ISO 14000, Joe Cascio, TAG Chair, GETF, 7010 Little River Turnpike, Suite 300, Annandale, VA 22003-3241
Publication
ISO 14031, now in final draft form and not yet adopted.
ISO Technical Report 14032. This publication is a compilation of examples of EPE as undertaken by a number of different organizations around the world.

EDF Chemical Scorecard and EPA Sector Facility Indexing Project

The Environmental Defense Fund (EDF) is a not-for-profit environmental advocacy group with four main goals: (1) Stabilizing the Earth's climate, (2) Safeguarding the world's oceans, (3) Protecting human health, and (4) Defending and restoring biodiversity. They have over 300,000 members and a staff of 170, spread around the country. They have created a number of web-based environmental information tools.
EDF has created a web site that ranks industrial facilities according to chemical release numbers reported in Toxic Release Inventory (TRI). They rank facilities and by region according to the total weight of chemicals released. 
Also they provide detailed information about each facility sorting the TRI data according to specific chemicals, the release media (stack air, fugitive air, water, underground injection, land, and transfers.) and by health effect (recognized or suspected carcinogens, cardiovascular or blood toxicants, etc.). Data is presented from 1988 to 1995. 1996 data is being prepared.
Facility name and location is provided but generally no information is included about the manufacturing products or processes or production figures.
This is raw data and has not been normalized to production, indexed to a base, nor aggregated and weighted to risk factors.
•	Analysis According to Principles:
Pros:
•	An objective and transparent reporting of environmental releases according to TRI data.
•	Shows changes over time
•	Ranks facilities according to the weight in pounds of reported chemicals released within a selected geographic area.
•	Provides information about risk factors of chemicals.
Cons:
•	Provides no means of normalization to production nor comparison of facilities within the same industry.
•	The “yardstick” of amount of releases without information about production is difficult to use for comparative purposes.
•	It only includes TRI reported chemicals.
The EDF Scorecard is an extremely valuable source of raw data for use by stakeholders in assessing a facility’s environmental reporting. Without further analysis and normalization, however, the data by itself can be misleading and does not provide a method of measuring environmental performance.
The EPA Sector Facility Indexing Project (SFIP) provides a web site (http://es.epa.gov/oeca/sfi/) that provides similar and additional information on a facility specific basis for 650 facilities in five industrial sectors: automobile assembly, pulp manufacturing, petroleum refining, iron and steel production, and primary smelting and refining of nonferrous metals.
In addition to TRI data, the site provides data to EPA concerning RCRA, CWA and CAA enforcement on number of inspections, compliance with federal regulations, enforcement actions taken and spills. Facility production data is also provided. In contract to the EDF site, no capability of ranking facilities is provided. This data set enhances the EDF facility-specific data for those facilities covered.
Publications
Environmental Defense Fund, 57 Park Avenue South, New York, NY 10010
http://www.edf.org
http://www.scorecard.org/

World Resources Institute Measuring Up

The World Resources Institute (WRI) is an independent center for policy research and technical assistance of global environmental and development issues, located in Washington, D.C.
WRI published an early call for common measures of environmental performance in 1997. They noted that there is no agreement on what should be measured, nor how to measure corporate environmental performance. “Measuring Up” defines a new framework based on four standard categories:
•	Materials use
•	Energy consumption
•	Non-product output
•	Pollutant releases
The report calls for building a common framework for environmental accountability, similar to the “generally accepted accounting principles” (GAAP) used in financial reporting. These would provide for comparability, transparency and completeness as prerequisites for independent evaluation.
The report defines three types of environmental performance indicators, similar to the ISO 14031 standard:
•	Operational Indicators
•	Management Indicators
•	Environmental Condition Indicators
WRI calls for future progress on four broad fronts:
1.	Making environmental performance measurement standard business practice
2.	Recognizing firms that demonstrate improved performance and greater disclosure
3.	Expanding public access to environmental performance information
4.	Facilitating standard formats for environmental performance reporting.
WRI has participated on the Steering Committee for the CERES Sustainability Reporting Guidelines (see the write up in “Sources on Environmental Reporting” and their thinking has been incorporated into the more recent CERES publication.
Contact
Daryl Ditz, WRI, 1709 New York Ave., N.W., Washington, D.C. 20006
http://www.wri.org/wri
Publication
Measuring Up, Toward a Common Framework for Tracking Corporate Environmental Performance, World Resources Institute, July 1997

Semiconductor Industry Association
National Technology Roadmap for Environment, Safety and Health

The Semiconductor Industry Association (SIA) is a national consortium of semiconductor manufacturers. SEMATECH, Inc. is a research consortium that supported SIA in the development of the roadmap.
SIA and SEMATECH, Inc. have developed and published a National Technology Roadmap for Semiconductors. Begun in 1994, updated in 1997, the Roadmap is being updated for the year 2000. It examines 12 areas of technology development, and one of those areas is environmental, safety and health (ES&H). 
The core purpose of the Roadmap is to document an industry consensus that identifies the research needed to maintain the current high rate of advancement in integrated circuit development. The methodology and content is not designed to target environmental performance improvements. However, since environment is one of the focus areas, and given certain characteristics of the semiconductor industry, the Roadmap provides a very interesting and somewhat unique model that could be used by other industries for environmental challenges.
Like the challenge of environmental sustainability, semiconductor development is a rapidly evolving field that requires both innovation by individual companies and integration of purpose across companies. The SIA Roadmap process has several strengths that provide a valuable model for environmental improvement:
•	Individual challenges are identified and clearly defined through a consensus process involving wide representation of the industry in Technology Working Groups
•	The Roadmap is updated periodically 
•	Quantitative (where possible) target values and non-quantitative targets are identified to set goals for succeeding technology generations
•	Schedule requirements over a 15 year time frame for R&D and implementation are developed for each target improvement
•	The overall plan integrates an assessment of the state-of-the art and a projection of what needs to be done to get the industry to where it wants to be.
A weakness of the process for our purposes may be that since its focus in only peripherally on environment, it does not incorporate a strong environmental vision relating to the life cycle of the products. The environmental section is driven by ES&H considerations for production processes. However, the model is valuable within those limitations.
The ES&H component addresses four categories:
•	Chemical management, including selection of ‘better’ chemicals, improved dissemination of information, and elimination of emissions (especially PFC), and including a hierarchy – replace, reduce, reuse, reclaim, abate
•	Natural resource use reduction, especially water and energy, including higher efficiency use and recycling
•	Worker protection, including exposure to toxic chemicals and ergonomic design
•	Improved and integrated ES&H design tools, including a next generation refinement of risk assessment, improved toxicology modeling, life cycle analysis, material/energy flow modeling, cost accounting and EMSs.
Potentially these targets and schedules could be used as a yardstick to measure the performance and improvement initiatives of participating facilities.
Analysis According to Principles:
Pros
•	Provides a consensus-based objective yardstick for evaluating environmental improvement initiatives by individual companies
•	Some quantitative targets are defined
•	Everyone can excel in their individual programs and thereby advancing the entire industry on the Roadmap
Cons
•	Not being focused on environmental issues, the treatment of environment is somewhat light and lacks a life cycle vision
•	It is primarily activity-based.
Contact
http://notes.sematech.org/ntrs/
Rdmpmem.nsf
Publication
The National Technology Roadmap for Semiconductors, SIA and SEMATECH, 1997.

World Business Council For Sustainable Development Eco-Efficiency Metrics And Reporting

The World Business Council for Sustainable Development (WBCSD) is a coalition of 125 international companies united by a shared commitment to the environment and to the principles of economic growth and sustainable development. Its members are drawn from 30 countries and more than 20 major industrial sectors. 
WBCSD was formed in January 1995 through a merger between the Business Council for Sustainable Development (BCSD) in Geneva and the World Industry Council for the Environment (WICE), an initiative of the International Chamber of Commerce (ICC), in Paris. 
One of the WBCSD has been to help define metrics for eco-efficiency in their Eco-efficiency Metrics and Reporting Project. The project has three main deliverables:
•	A set of crosscutting eco-efficiency indicators
•	The testing of this metrics concept by WBCSD member companies
•	Tools and training materials for implementation.
They define eco-efficiency as the unit of value provided per unit of environmental burden. The working group is now in the final stage of defining the set of indicators and specifying guidelines for selection of sector-specific indicators for benchmarking.
WBCSD is also participating in other organizations’ programs such as the CERES Global Reporting Initiative. By the end of 1999 the coordinate pilot applications in member companies and develop application tools.
WBCSD has produced quite a number of publications relating to eco-efficiency.
Contact
http://www.wbcsd.ch/ecoeff1.htm
Publications
Eco-Efficient Leadership for Improved Economic and Environmental Performance (1996)
Eco-efficiency ‑ The Business Link to Sustainable Development (1997)
Environmental Performance and Shareholder Value (1997)
Cleaner Production and Eco-efficiency – Complementary Approaches to Sustainable Development (1998)

Measuring Permitted Releases

Several methods have been suggested to rate or benchmark facilities according to their actual releases, normalized to production, in relation to releases of others in the industry. The purpose of this measurement is to rank facilities according to an objective standard that applies to their industry. DEQ staff has suggested the following methods for consideration.
•	One option is to rank facilities relative to actual levels of releases of regulated pollutants by representatives of their industry sector. Data could be derived from TRI and permit reporting. The biggest challenge is the selection of comparable representatives of their industry sector, since many manufacturing operations are unique. 
Ideally, however, the benchmarking system should allow potentially all members of their industry sector to achieve top tier performance, if they all achieve qualifying levels of excellence. The first option inevitably creates winners and losers, since they are ranked against each other. It also creates a changing, and increasingly more stringent standard as industry practice improves – the ratchet down effect which is feared by industry. 
Some other optional methods could possibly better achieve this principle.
•	The standard yardstick could be defined according to the typical permit levels for sources within an industry sector, and within the smallest region (local, state or national) that includes other representatives of the sector. Tier III could be set at the top 10% of the typical permit level normalized to production.
•	The standard could be set to the allowable emissions of the allowable technology, e.g. RACT. Tier III could be the top 10% of permitted RACT releases normalized to production.
•	The standard could be set according to the lowest emitting technology for the industry. Tier III could be defined as performing within 10% of the best performing technology for the industry sector normalized to production.
•	Analysis According to Principles
Pros
•	This approach could provide certainty and an objective and transparent yardstick.
•	A system of standard procedures could be developed to assemble and display the data for evaluation by DEQ and stakeholders.
Cons
•	It does not incorporate the individuality of different environmental performance metrics that might be developed by different facilities.
•	Different types of facilities and different production technologies/processes are difficult to compare.
•	It only includes publicly reported pollutants and does not address other waste streams or consumption of resources that are not permitted parameters.