Abstract: Over the past decade, the U.S. Environmental Protection Agency (EPA) and states have developed environmental leadership programs (ELPs), a type of voluntary environmental program designed to recognize facilities with strong environmental performance records and encourage facilities to perform better. Proponents argue that ELPs overcome some of the limitations of traditional environmental regulation by encouraging managers to address the full gambit of environmental problems posed by their facilities, reducing the costs of environmental regulation, easing adversarialism, and fostering positive culture change. Although ELPs have been in place for at least five years at the federal level and in seventeen states, these programs have been subject to little empirical evaluation. In this paper, we chart a course for assessing whether ELPs achieve their goals. Drawing on archival research and interviews with government officials who manage these programs, we provide the first comprehensive analysis of the characteristics of these programs, describing program goals, activities, communication strategies, and data collection practices. We find that EPA and many states have established ELPs to improve the environment and to achieve various social goals such as improving relationships between business and government. When it comes to collecting data that could be used to assess these programs' successes, however, government efforts fall short. Even when agencies collect reliable data, these data usually cannot be aggregated sensibly and are insufficient to draw inferences about the true impact of these programs. They also cannot help answer the question of whether ELPs are actually prompting pollution reductions or improving regulatory relationships. These general data weaknesses are significant, even surprising, given the aspirations for ELPs to facilitate policy learning and advocates' claims that these programs are delivering important environmental benefits.Government Clubs: Theory and Evidence from Voluntary Environmental Programs
Abstract: The U.S. Environmental Protection Agency (EPA) has established numerous voluntary environmental programs over the last fifteen years, seeking to encourage businesses to make environmental progress beyond what current law requires them to achieve. EPA aims to induce beyond-compliance behavior by offering various forms of recognition and rewards, including relief from otherwise applicable environmental regulations. Despite EPA's emphasis on voluntary programs, relatively few businesses have availed themselves of these programs -- and paradoxically, the programs that offer the most significant regulatory benefits tend to have the fewest members. We explain this paradox by focusing on (a) how programs' membership screening corresponds with membership rewards, and (b) how membership levels correspond, in turn, with membership screening. Our analysis of three major case studies, as well as of data we collected on all of EPA's "green clubs," shows that EPA combines greater rewards with more demanding membership screening, which in turn corresponds with lower participation. EPA's behavior can be understood as a response to the political risks the agency faces when it recognizes and rewards businesses it otherwise is charged with regulating. Given the political constraints on EPA's ability to offer significant inducements to business, we predict participation in all but the most inconsequential voluntary environmental programs will remain quite low, thereby inherently limiting the ultimate value of voluntary programs as a strategy for advancing environmental protection.