Environmental laws and regulations have not always been implemented in a manner that allows the consideration of pollution prevention (P2) alternatives as a means of achieving progress toward air quality goals. The historical impetus for P2 programs has been to curb solid or hazardous waste disposal problems. This is because the P2 "Measures of Merit" established under the Pollution Prevention Act were associated mostly with reductions in solid waste and/ar hazardous waste, and because it has traditionally been easier to track solid waste or hazardous waste costs to show paybacks for source reduction. In P2 analyses emissions into the air are addressed, but for most facilities the cost of disposal has been the main driver for implementing P2 programs. The impetus for the Clean Air Act (CAA) is towards eliminating immediate hazards to the public caused principally by criteria pollutants. It is always easier to prove that an end-of-the-pipe solution will attain the desired environmental reduction goal; it is far more difficult to prove that a P2 solution can meet the same goal. Because of these differing perspectives the CAA has unintentionally put in disincentives for facilities to follow good P2 practices. But even as the CAA has created unintentional disincentives it has also created unintentional incentives for P2 projects through programs such as the emissions trading and emissions-based fee structures. P2 analyses need to take into consideration these costs and opportunities associated with the CAA. This article first identifies the contrasting goals of P2 and the CAA programs. Then discussed are several CAA programs that offer facilities the opportunity to consider P2 alternatives to meet air quality compliance requirements including new source standards, emissions trading, and facility permitting.
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