The Sierra Club advocates the establishment of pollution taxes which would make it less expensive for a polluter to adopt alternative processes or invest in additional equipment to curtail releases to the environment than it would be for him to continue as before. Such taxes would supplement, and not replace, standards on maximum permissible emissions. These taxes should be imposed when the following conditions are found to prevail generally:
- for competitive or other reasons, cost-minimizing behavior tends to exist in the company or industry;
- the cost of abatement is expected to be significant, both in relation to revenue from sales and in absolute terms; and
- the quantity of the pollutant released to the environment can be determined with reasonable accuracy, either by direct monitoring of every source, statistical sampling of a small fraction of many similar sources produced by a few manufactures, or by indirect means. The cost of monitoring should be small in relation to the tax revenue expected in the absence of abatement.
As a first step, a tax equal to 15 cents per pound should be imposed on sulfur contained in fuels intended for combustion (with a rebate given to those who demonstrate that the sulfur was not released to the environment), and on sulfur emitted from smelters, refineries, and sulfuric acid plants. The tax on lead contained in gasoline ... should be promptly enacted.
The feasibility of taxes on the emission of nitrogen oxides, particulate matter, carbon monoxide, and hydrocarbons should be investigated ... for possible action on these air pollutants; studies should also be conducted on the practicality of similar taxes for various of the water pollutants.
Adopted by the Board of Directors, February 13-14, 1997
Guidance on the Relationship Between Environmental Management Systems (e.g., ISO 14000) and the U.S. Regulatory Process
Governments should adopt standards (enforceable by regulators and the public) to protect environmental quality and public health. Such standards are translated into practice through various tools, including regulatory requirements, incentives, and guidance. Governments bear responsibility for assembling the information, developing the processes and providing the public access needed to establish appropriate standards and to make the tools work effectively.
Government decisions concerning those entities to which the standards and requirements apply should be based on the government agency's own publicly verifiable fact-finding, not on the fact that an entity adheres to a code of conduct or uses a particular environmental management system. Accordingly, the Sierra Club opposes displacement of existing regulatory requirements by ISO 14000 and other similar systems.
Granting preferences to regulated entities, particularly suspending requirements based on adherence to such codes, is especially inappropriate where:
- such codes are not based on the environmental performance of the regulated entities;
- participation by the public has not been a significant factor in the development of the codes;
- conformance to the code and actual performance are notaudited regularly by independent third-party auditors with significant public participation and with the audit results made available to the public, or;
- the entities can declare themselves code-certified without verification by independent third-party registrars and without significant public involvement.
However, the Sierra Club encourages the adoption of such systems and codes by industries and firms when they are in addition to, and a potential means to exceed, governmental compliance requirements.
Approved by the Conservation Governance Committee, March 25, 1997