G e r a l d R. P r o u t

Industry And The Environment: A Communication Gap

An issue that galvanized millions in the late 1960s and contributed to zvidespread anti- business sentiment in the United States was protection of the environment. Viewed as "'a reluctant partner" in the cleanup of American resources and prevention of pollution, bzdustry has continued to be perceived as complying only minimally with the wave of anti- pollution regulations affecting heavy manufacturing.

This author argues that this lingering negative perception has been fostered by industry' s failure to communicate about its efforts to reduce pollution and mounting programs to insure safe use of air, water and land. Even dramatic reversals of pollution-ridden natural resources have gone without publicity, he says--even though sophisticated communication chmmels are available to industry.

Gerald Prout is the director of public affairs for FMC Corp.' s Industrial Chemical Group, Philadelphia.

T hroughout the decade of environmentalism, symbolically commencing with Earth Day in April 1970, industry was viewed as a reluctant partner

in the nationwide commitment to curtailing pollution. However, the Bureau of the Census conservatively estimates that, in the period from 1973 to 1980, industry spent more than $100 billion for pollution control equipment and operation costs. This does not take into account an estimated $6 billion the Census Bureau calculates was spent on research and development related to pollution abatementJ Yet, in spite of this substantial investment in maintaining and improving environmental quality, industry continues to be viewed as doing only the minimum required by law.

As the current Administration has pursued sometimes controversial approaches to environmental regulation, business is seen as tacitly approv- ing actions relaxing existing standards, delaying deadlines for compliance,

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and weakening or eliminating those organizations charged with enforcing a complex array of environmental statutes. It remains to be seen whether new leadership in the nation's major environmental agencies may help change this impression.

In fact, the general image of business insensitivity to environmental concerns is largely inconsistent with its record. It reasonably can be argued that industry did not anticipate the emergence of environmentalism as a major domestic policy issue. Yet, it is also true that over the last 10 years, industry has taken an increasingly active role in pollution control, both by investing in pollution abatement technology and by becoming more directly involved in the policy-making process. Industry generally has increased its say over the future direction of environmental management, and in most cases, has done so responsibly.

Nonetheless, industry 's continuing failure to publicly communicate this involvement in maintaining and improving environmental quality has left public opinion malleable to the rhetoric of others. Environmental activists are consistently able to stir the public conscience and define the policy agenda in this important area. Though industry may not be a reluctant partner, it is largely silent about its role.

From the pronouncement in the late '60s that Lake Erie was dead to Love Canal - - the cause c~l~bre of the '80s--for over a decade, environmental activists have effectively communicated in a now familiar pattern. Sources of pol lut ion--usual ly industrial--are identified and public attention drawn to their effects; the effects become the subject of intense sloganeering and hyperbole; a local (but often national) constituency is aroused to take action; the episode becomes pretext for new or more stringent legislation; and the legislation is translated into an often intricate set of regulations with which industry must comply.

Leadership of public opinion on environmental matters has thus tended to gravitate to environmental activists; spokesmen such as Russell Peterson or Barry Commoner , or politicians such as Cecil Andrus or Gaylord Nelson, have been able to arouse public concern over the " imminent" dangers of neglecting our natural endowment . While industry spokesmen have con- sistently acknowledged that an appropriate regard for the environment is part of a broader concept of corporate social responsibility, the communi- cations initiative has belonged to others. Environmentalism continues to be a public relations problem for industry, a clear example of how corporate performance is not being effectively communicated and thus seems to fall below public expectations. Environmentalists have successfully drawn attention to the exceptions in industrial environmental management , rather than its consistently improving performance.

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Much like its antecedents, the civil rights and anti-war movements of the "60s, environmentalism emerged as a viable political movement by making rhetorical attacks on established institutional behavior--in this case, demonstrable evidence of industry pollution. Media coverage of the Santa Barbara Channel oil spill in 1969, for example, was effectively exploited by environmentalists to galvanize public opinion and help create a political basis for creation of the Environmental Protection Agency a year later. Indeed, industry has faced sizable odds attempting to fire the public's interest in its cleanup efforts. The media, by definition, gravitate to instances of gross pollution rather than examples of the incremental control of this or that pollutant. Moreover, the convergence of historical circumstances weighed against industry communication efforts.

The prevailing view of a Great Society at the turn of the last decade did not include polluting industries. Environmentalism became an integral component of a broader philosophical attack on the legitimacy of corporate power and the very economic system in which the invisible hand had purportedly failed. As William Schambra wrote recently, these critics of the system "promised prosperity, while harboring suppressed hostilities toward the traditional sources of progress. ''2 But environmentalism was and is a movement with broad appeal across the entire spectrum of political thought. It is a phenomenon which attracts those who hold to an ever-expanding definition of American abundance and those who shrink from such a vision and openly worry about the exhaustibility of our resource base.

Other factors too, perhaps subliminal, encouraged the environmental awakening. As Rice Odell of the Conservation Foundation observes:

The Environmental Revolution undoubtedly was inevitable. Popula- tion was growing inexorably; pollution was increasing dangerously; land was being desecrated relentlessly. At some point, these excesses were bound to reach the limits of political endurance. 3

While this may overstate the case, in its formative stages, environmentalism effectively employed the rhetorical techniques which have typically char- acterized similar social movements. Hyperbole was necessary to catalyze public opinion around successive causes, from phosphates in Lake Erie to fluorocarbons in the ozone.

Yet today, after a decade of intense rhetoric and righteous indignation, many environmentalists have begun to reevaluate whether similar tactics are appropriate for the '80s. Purported quick fixes offered to remedy many environmental crises have often spawned serious secondary environmental consequences. In some cases these unintended results might have been avoided had less emotionalism and political rhetoric attended the initial decision-making process. For example, increasing stack heights, though they may have an immediately favorable impact on meeting localized air

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pollution requirements, may also tend to increase the amount of so-called transboundary pollution and the acidity of rainfall in the northeastern United States and in Canada. As a similar example of unintended conse- quences, few foresaw that removal of pollutants from wastewater at sewage treatment facilities would result in a growing sludge disposal problem, exacerbated by a number of environmental statutes which govern sludge disposal and limit the options available to communities.

Rhetoric vs. Performance Many environmental issues raised over the last decade have matured,

and now require much more than rhetorical flourish or simplistic techno- logical approaches. Yet, even in the first generation of environmentalism, there were those who understood the scope and nature of environmental cleanup. As Peter Drucker warned in a Harper's article almost 10 years ago:

The sewage treatment plants that are urgently needed all over the world will be designed, built and kept running not by purity of heart ballads or Earth Days, but by crew-cut engineers working in very large organizations, whether businesses, research labs or government agen- cies. 4

Indeed, over the last decade, more than $30 billion in federal monies was committed to the construction and upgrading of sewage treatment plants nationwide, one of the largest public works projects in U.S. history. Yet the resultant improvements in water quality are so gradual they typically escape national attention. In some cases the quiet success stories of this program are remarkable, given that it has only been in effect in a significant way for 10 years. The resuscitation of Lake Erie, for example, is now largely attrib- uted to the federal municipal sewage construction grants program.

From the beginning, the control of pollution in its various forms has entailed this type of technological solution. The details of addressing the environmental agenda have been left to those truly able to grasp the com- plexity of the task. In fact, an entire industry has evolved over the last decade to address the needs of industry and government in meeting the requirements of various environmental statutes. While the pollution control equipment industry's health is peculiarly tied to politics, it remains an industry with substantial growth opportunities as it confronts the task of safely disposing of vast quantities of solid waste.

In its approach to environmental management in the "real world," indus- try is increasingly finding that many forms of pollution represent the uneco- nomic use of valuable resources. The application of pollution reduction and recovery techniques in some cases can turn what would otherwise be expenses into profits. Many industrial wastes are thus now being reprocessed for use

Industry" vs . E n l ~ I r o n m e n t

as energy or recycled as raw materials for use again in the industrial process itself. As early as 1975, 3M Company began a program it called "Pollution Preventiow Pays," stressing four essential concepts: product reformulation, process modification, equipment redesign and the recovery of waste mate- rials for reuse. In three years, total savings to 3M's domestic facilities were $17.4 million. 3M eliminated the equivalent of 75,000 tons of air pollutants, 500 million gallons of polluted wastewater and 2900 tons of sludge per year. s Other companies have also found similar economic incentive to con- trol pollution.

In meeting society's environmental expectations in a responsible man- ner, balancing economic growth with an appropriate concern for natural resources, industry has the potential to shed its image as a reluctant partner in environmental management. Industry is uniquely positioned to reconcile the often-conflicting values of economic growth and environmental quality. Moreover, there seems to be broad public support for the effective recon- ciliation of these values. As Everett Carl Ladd recently suggested in Public Opinion, the public does not necessarily believe that attainment of environ- mental goals is in conflict or constitutes a trade-off with economic prosper- ity. Rather, environmentalism has become a "post-materialist" value. Ladd's survey data indicate that beyond any shadow of a doubt, "Americans want the environment protected and they want to achieve other national objec- tives, like an adequate energy supply and economic growth. ''6

A growing public receptivity seems to exist for industry to communicate the significance of its investment in environmental control equipment and to more actively communicate that market incentives do exist and are being used to transform waste into industrial resources. Yet, industry commu- nications efforts in this area are sadly deficient. Though an already sub- stantial and growing record of performance exists, it is seldom publicized. A recent poll conducted by Opinion Research Corp., which sought to identify which institution the public trusted most to recommend changes in the Clean Air Act, found business rated dead last. 7 Absent any commu- nication to the contrary, the public seems to have accepted the stereotype of industry as the callous polluter--and industry seems resigned to this image.

Most businesses seems reluctant to draw attention to their efforts to improve the nation's environment. While other capital expenditures or facility expansions are usually announced with some fanfare, expenditures for a new pretreatment system, scrubber or baghouse are seldom announced unless through the most routine of statements. More importantly, the cumulative accomplishments of individual manufacturing facilities in reducing pollutants are seldom placed in perspective for employees, shareholders or the community. Nor typically have indtistry's major trade associations

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effectively assembled the record for their industry group and put it before the public.

Industry's Reluctance to Communicate Business's failure to draw attention to its record of accomplishment can

be explained by several conditions: 9 The very installation of pollution control equipment or modifications

in an industrial process to reduce pollution implies that a problem may have previously existed and thus gone unaddressed;

9 The installation of equipment is often piecemeal and the results some- times uncertain and undramatic;

9 The installation of the equipment is often the final step in a process of negotiation with government authorities in which the very scope and/ or design of the project has itself been at issue;

9 Planned or actual reductions in various pollutants cannot be easily correlated to actual environmental improvements.

As Robert Crandall of the Brookings Institution noted recently, "It seems ludicrous to me that we regulate air and water pollution extensively without being able to tell whether the regulation is working. "'8 Nonetheless, after years of concerted effort, it is difficult to measure actual results.

In addition, while the process and expense of compliance proceeds at a technical level for industry and government technocrats, leading environ- mental activists seek to move the environmental agenda relentlessly for- ward at a political level. Thus, while American industry proceeded to meet the requirements of much of the environmental regulation of the "70s, a new environmental issue-- the disposal of hazardous wastes--has perco- lated, becoming the environmental priority of the '80s. It is difficult for industry to proclaim substantial accomplishment in one area when its defi- ciencies in another area are the subject of emotional community and national debate. Nonetheless, it must. If industry fails to effectively communicate what it has done and is doing for environmental quality, it may begin to relinquish its hard-won role in shaping future environmental policy at a time when the environmental movement is itself seeking to reshape its own identity.

As the environmental movement enters its own transitional phase, its leadership is coming to grips with the difficult problems of sustaining public enthusiasm for an agenda which continues to grow in scope and cost. Sustaining the popular appeal of this movement, particularly in the wake of the 1980 election, has led its leadership to focus on a new grassroots effort aimed at raising more money for political use by forming statewide

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political action committees. 9 The difficulty of this effort--promoting "post- materialist" values during a period of difficult economic transition--is obvious.

And yet, the environmental ethic has shown resiliency even during the previous economic downturns of the last decade. As Ladd's interpretation of recent survey data seems to suggest, Americans by and large want to successfully reconcile materialist and post-materialist values. Again, it is business which may be most uniquely positioned to reconcile these in a practical, cost-effective manner. Many companies have begun to take a much broader role in the actual process of environmental governance, demonstrating they are as much interested in "reregulation" as deregula- tion.

The extent of industry's dollars and cents commitment to the environ- ment was indicated previously. This record of performance--of actually having to find what works best in practical, real-world applications to curtail pollution--provides industry with growing credibility to assert itself more broadly in the area of environmental policy-making.

As examples of such involvement, two broad concepts, largely conceived and supported by industry, are now having some initial impact on the environmental policy process. While these ideas, largely being put forward by industry representatives, are complex and have many specific applica- tions, a brief summary of each provides insight into how business has assumeci a new role in environmental policy making.

The Application of Good Science to Environmental Policy As Victor Hugo observed, "Science says the first word on everything and

the last word on nothing." By definition, uncertainty surrounds virtually every political decision in the environmental area, decisions which must be made on often conflicting and indefinite scientific information.

In the current debate over acid rain, for example, general agreement exists in the scientific community that much of the Northeastern United States and Southeastern Canada are receiving much more acid rain than would be expected to come from a "pure" atmosphere. But experts cannot agree as to whether the acidity of the precipitation is increasing, or the extent to which local versus longer-range sources of pollution are respon- sible for such precipitation. Decisions must, by definition, always be made with some significant degree of uncertainty; the issue, however, is how to reduce the uncertainty level and the emotion surrounding the debate, by application of the best science available. The recent popularity of cost- benefit analysis has only served to heighten the problems generally asso- ciated with scientific uncertainty and increase the costs of bad science.

Science has also become increasingly political. In her recent study of the Love Canal situation, Adeline Gordon Levine suggests that the announce-

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ments of various "scientific" findings by government and private sector experts were timed to coincide with political factors, and the procedures used in the studies themselves adjusted to meet various political exigen- cies. 1~ The Carter EPA's own 1980 study of chromosomal damage to Love Canal residents, looked to by many as the final word in an already emotional debate, was so obviously flawed that any remaining shred of credibility to which local residents might have gravitated in their hour of desperation was lost.

Long before the Love Canal incident and increasingly since, conscious effort has been made by industry to upgrade the quality of science which serves as a basis for political decision-making, and to create greater consen- sus within the scientific community on key issues in order to expedite the decision-making process. Since consensus on basic scientific questions, particularly those elevated to a level of public policy concern is difficult and time consuming to achieve, a consortium of six companies (Dow, duPont, Exxon, Mobil, Monsanto, and Rohm and Haas), are currently funding a s tudy on the practicality of "state-of-science conferences"--a mechanism designed to air conflicting views on basic scientific questions in hope of achieving a consensus which will have broader public (and therefore polit- ical) acceptability.

This notion is looked upon as capable of overcoming some of the delays and confusion which have resulted from more formalized peer review processes. Generally, industry is supportive of peer review as a means of insuring that policy decisions are based on the best science available (the current EPA has formalized such a process largely as the result of industry urging). But the current notion of a conference or science court attempts to create safeguards which will prevent ideological crusaders from coopting public opinion with bad science, while good science takes its normally long and arduous course.

Applying Marketplace Incentives to Environmental Regulation From the initial phases of the environmental movement, if not before,

policy analysts have suggested assigning property rights, complemented by specific provisions for liability, to the air, water and land. Several notable spokesmen have urged the charging of pollution taxes as a means of con- trolling excessive degradation of our common resources. Such effluent or emission charges may indeed represent a more efficient means of control- ling pollution and would certainly have reduced the costs of administering environmental regulation and thus the overall cleanup costs to society. However, initial skepticism over the extent to which industry might prefer to pay the fines rather than curtail pollution led to the alternative command- control regulatory structure under which we presently operate.

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Environmental regulatory strategies today are oriented around a standard setting-monitoring-enforcement regulatory process coupled with uniform effluent and emission requirements. Under the current regulatory scheme, some opportunity does exist for the economics of regulation to at least be considered. Under the Clean Air Act, for instance, a company may locate in areas that are considered "non-attainment" if the company installs the best available technology and pollution from new sources is offset by reduced pollution from other sources in the area. Similarly, under the Clean Water Act, variances for industry can be permitte d if a lower level of control represents "the maximum use of technology, within the economic capability of the owner or operator."

Yet such examples of economic considerations being factored into the existing regulatory scheme are rare. By and large the system remains largely inflexible to economic considerations. Moreover, the costs of complying with regulation continues to grow. The Council on Environmental Quality estimates that between 1979 and 1988, $735 billion will be spent for all pollution control capital and operating costs. In recognition of the growing expense of this and other forms of regulation (which constitute a major component of the "Great Inflation" of the last decade), the Reagan Admin- istration sought to give higher priority to analysis of the costs of any pro- posed regulation, and to weigh the benefits against the effects of regulation on productivity, a healthy economy and adequate energy supplies. Indus- try, for the most part, supports such cost-benefit analysis as now required under Executive Order 12291; indeed, industry has promoted its develop- ment and sought to make it politically acceptable.

Yet, as survey data suggests, there exists a threshold of public tolerance for deregulation, even in the name of economic growth. Moreover, regu- latory reform does not necessarily change the command-control nature of existing regulation. As note'd previously, the public, while sensitive to the exorbitant costs of regulation, is not insensitive to the goals set forth. Discarding regulation on the basis that it is too expensive is but the first step in a process of reregulation: designing a regulatory structure which acknowledges the need for providing greater flexibility and economic incen- tive for compliance with practical, achievable environmental goals, which the public still seems to support. As Robert Crandall suggests:

Study after study documents the inefficiency of the current regulatory approach and its lack of enforceability. By simplifying the traditional air and water pollution programs through use of market incentives, while improving monitoring and enforcement techniques, the agency could contribute substantially to both regulatory reform and regula- tory relief. '1

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Here again, however, industry is taking a lead role in sponsoring basic academic and related research which is the prerequisite for legitimizing any new approach to regulation. Studies such as those sponsored by duPont on the so-called "bubble concept" (which allows for cost-effective combi- nations of reductions of a given pollutant under an imaginary bubble rather than from each individual source) suggest that application of this idea at a single duPont plant could achieve an 85 percent discharge reduction at 60 percent of the cost of achieving the same discharge reduction utilizing uniform technology standards. When 50 duPont plants were all placed under a multiplant bubble, total savings were estimated at $91.1 million. 12

Similar examples of substantial pollutant reductions and cost savings by Armco Steel and Narragansett Electric Co. convinced the Carter Adminis- tration to formally propose the bubble concept as a means of allowing more flexible, rapid and efficient attainment of air quality standards. On May 12, 1982, the Reagan EPA, after further examination of practical applications of this and similar concepts at a state level, proposed a number of general principles to further encourage adoption of various forms of emissions trading. Under the new policy guidelines, firms can now profit by selling

9 their excess emission reductions to other firms, use such credits themselves to achieve the most cost-effective overall pollution reduction, or sell them to other firms which may, in fact, have higher marginal emission control costs.

Both the application of good science, as well as the introduction of new economic incentives to the l~roce~of environmental policy-making, sug- gest that industry is, by and large, seeking to play a constructive role beyond merely complying with existing targets. The results of such efforts are as yet unclear, but industry participation in the process should only help to strengthen its credibility and the soundness of environmental regulation. But industry's role in developing and promoting such innovative new approaches to environmental management stand to go largely unnoticed by the public unless industry can undertake to communicate its own role more effectively.

Today the environmental movement appears more uncertain of its own future than at any time since it came to prominence. There continues to be uncertainty about the extent of public support for current Administration policies, viewed by many environmeatal activists as retrenchment against the progress of the last decade. According to Robert Chlopak, political director of Friends of the Earth, "There's a feeling that we are being tested. The movement has to show that if it is threatened by public officials, we will do everything possible to turn that around. ''13 Indeed, the current Reagan Administration environmental policies have been a hotly contested political issue and will inevitably be a part of the 1984 Presidential campaign.

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As the most active and financially committed partner in the actual cleanup of the environment, industry is not served by rhetoric which polarizes the environmental debate. To continue to make constructive progress in meet- ing its own environmental objectives, industry needs to encourage a more rational public discussion of complex environmental issues.

At this stage in the evolution of the environmental movement, industry is uniquely positioned to a take more prominent public role; to stand on its record, albeit imperfect, but clearly equal to that of government and indi- viduals. Industry can best explain the obstacles to env.ironmental cleanup, not as an excuse for inaction, but to contribute to better environmental management in the future.

The vehicles available to business for communicating on political and public issues have been well honed by its own public relations experts. The components of the message are straightforward: (1) industry has .committed billions to environmental cleanup; (2) industry is demonstrating that flexible new approaches to regulation can provide new incentives for more expe- ditious cleanup; (3) industry can help in formulating regulation based on good scientific fact rather than specious scientific supposition; and (4) indus- try is a willing partner in environmental cleanup if the goals are attainable and the regulatory framework clear and consistent over time.

Aldo Leopold said in his Round River Journal that "the outstanding sci- entific discovery of the 20th century is not television or radio, but rather the complexity of the land organism. ''~4 A decade of dealing with environ- mental problems firsthand has certainly revealed that we have only barely begun to unders tand the relationship of industrial society to the environ- ment, both for good and bad. It may not be easy for industry to communicate its growing technical understanding of real world solutions to environmen- tal problems in the electronic media or the press. But if continued progress is to be made in this area in the next decade and the public is to have confidence in the future direction of environmentalism, then industrial spokesmen must find a way to make our accomplishments known and to clarify the choices before us.

R e f e r e n c e s IBureau of the Census, Pollution Abatement Costs and Expenditures. (MA-200-(80)-2), pp. 1-

15. 2William A. Schambra, "The Roots of the American Public Philosophy," The Public Interest,

Spring 1982, p. 44. 3Rice Odell, Environmental Awakening (Cambridge: Ballinger Publishing, 1980) p. 2. 4Peter F. Drucker, "Saving the Crusade," Harper's, January 1972, reprinted in Business and

Environment (Washington D.C.: Conservation Foundation, 1977), p. 290. 5Moni Campbell and Bill Glenn, "Profit from Pollution Prevention," Probe Post, June 1983,

p. 22.

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6Everett Carl Ladd, "Cleaning the Air: Public Opinion and Public Policy on the Environ- ment," Public Opinion, February/March 1982, p. 19.

r'Opinion Roundup," Public Opinion, February/March 1982, p. 37. 8Robert W. Crandall, "The Environment," Regulation, January/February 1982, p. 29. 9Bill Peterson, "Environmental Lobbyists Map New Effort," The Washington Post, April 20,

1982, p. A6. t~ Gordon Levine, Love Canal (Lexington: Heath Co, 1982). 11Crandall, pp. 30-1. 12Gordon L. Brady and Richard E. Morrison, Emissions Trading: An Overview of the EPA Policy

Statement, (Washington: National Science Foundation, 1982), p. 7. ~3peterson, p. A6. UAldo Leopold, Round River (London: Oxford University Press, 1953) p. 146.

E d i t o r i a l R e v i e w C o m m i t t e e

Robert L. Bishop, University of Georgia John E. Bowes, University of Washington Glen Broom, San Diego State University Allen H. Center, San Diego State University Hugh M. Culbertson, Ohio University Scott M. Cutlip, University of Georgia William P. Ehling, Syracuse University William R. Faith, University of Southern California James E. Grunig, University of Maryland Carl F. Hawver, Parker Nash & Associates Michael B. Hesse, University of Alabama Frank B. Kalupa, University of Georgia Philip Lesly, The Philip Lesly Company Walter K. Lindenmann, Hill & Knowlton, Inc. Adolph Mayer, University of Denver Douglas Ann Newsom, Texas Christian University Carol Oukrop, Kansas State University F. John Pessolono, Council in Public Relations & Public Affairs Marion K. Pinsdorf, INA Corporation Betsy Ann Plank, Illinois Bell John C. Pollock, Research & Forecast, Inc. Kenneth H. Rabin, E. R. Squibb & Sons, Inc. John G. N. Rushbrook, Phillips Petroleum Company Raymond Simon, Utica College of Syracuse University Kenneth Owler Smith, University of Southern California Leonard J. Snyder, San Francisco State University Carlton E. Spitzer, Spitzer Associates William B. Toran, Ohio State University Judy Van Slyke Turk, Syracuse University James K. VanLeuven, Washington State University Francis E. Walsh, University of Texas at Austin Dennis L. Wilcox, San Jose State University Frank W. Wylie, California State University at Los Angeles

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