Planning Process

Overview

The Green Business Certification Program planning process is summarized in the schematic shown below. Note that planning a GBCP is not a linear process; it may be necessary to return to previous steps and re-visit decisions made. To learn more each flow chart NAME is linked to the element's detailed information; or you can download the information in a pdf file for printing and hands-on use.

 

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Geographic Focus

The Bay Area Green Business Program began at the county level, grew into a regional program and now is expanding statewide. Program administration continues to be at the county level. The Green Business Programs in Hawaii and Arizona were developed at the state level with initial implementation occurring in one or two cities. In general, states with small populations such as Idaho, Oregon and Montana have state level programs, while states with large populations such as California and Colorado have city, county and regional programs. Small states are in a better position to develop state-level programs than large states with complex bureaucracies.

For a state level GBCP, it is important to consider the pros and cons of piloting the program in a large city or county, a small city or county, or at the state level. If it starts out in the capitol or a large city, this may discourage other cities from adopting the program, as they may be concerned that the program will be dominated by the big city. While starting the program at the state level may result in a good long-term buy-in, it may also be challenging to set up, as the program will require the participation of many local regulatory agencies.

Identify Key Players (back)

The following is a list of possible key players/program partners, reasons to include or not include them in the Core Team and the role they may play.

Governmental Agency Representation - Possible regulatory and other governmental agencies that may participate on the planning team include:

To help assess exactly which agencies to involve in the program development and the role they may play, it is useful to identify:

In some geographic areas, agencies with the same environmental compliance enforcement authority meet regularly to work on common issues. These working groups, although not sharing a single media focus, can help with the development of the GBCP. To identify inter-agency activities, it is useful to locate all Inter-Agency Memoranda of Understanding, Joint Powers Acts, and business advisory boards that may link environmental efforts.

Business Representation - The planning team may wish to include representatives from one or more of the industries that they are considering targeting. Inviting industry representation early in the process may bias the group towards targeting a particular sector. On the other hand, it can help get industry "buy in" early in the process. If the core team is not ready to select targeted industries, then the program may choose to include business representatives later in the process. Alternatively, business representatives can be invited to join advisory and/or technical committees, rather than the Core Team.

Business Assistance Program Representation - The planning team should identify organizations that provide business assistance as well as environmental information and services to determine whether to invite their participation. Possible organizations include:

  • Small Business Development Centers (SBDCs),
  • Chambers of Commerce,
  • economic development organizations,
  • vendors of environmental products and services, and
  • industry or trade associations.
For these organizations, it is be helpful to identify:
  • size and types of businesses served,
  • services provided including materials and training offered,
  • any coordination with other organizations,
  • any fees charged for services,
  • staff contact information,
  • award, recognition, or incentive programs.

As in the case of business representation, it may be preferable to include them later in the planning process or on an advisory committee.

Environmental and Public Interest Organization Representation - Environmental and public interest organizations may offer information and technical assistance helpful to the GBC program. To determine whether to include them on the Core Team, it is useful to consider how well they would work with other committee members (are they cooperative or contentious) and whether they have the time and interest to commit to the process. They may prefer to be involved in reviewing GBCP materials rather than attending meetings.

Elected Representatives - Support of the GBCP by elected leaders can help keep the program on track. It may encourage all the stakeholders to get and stay involved in the planning process. There are several ways for them to be involved. One is for them to join the Core Team or if they cannot attend regularly, to send a representative.

An alternative is, at a minimum, to educate them about the program or to keep them appraised of the program planning progress and invite them to meetings where they can make a direct contribution. Another approach is to present the program concept to elected bodies and request resolutions of program support, funding and/or adoption of a "Green Government Pledge". The resolution should acknowledge the creation of partnerships between the environmental agencies, business, and the public to cooperatively protect the environment by supporting businesses recognized as being environmentally friendly.

Assemble Core Team (back)

Assembling the Core Team is a difficult, time-consuming, but necessary task. Partners can provide program oversight, assist in the strategic planning process, help grow the program through outreach efforts, and improve inter-agency relations. In addition, partners add to the program’s credibility and effectiveness. For example, regulatory agencies are needed to certify environmental compliance. Without their participation, the program is limited to recruiting businesses that don’t require certification. Additionally, partners can provide in-kind commitments. For example, utilities often have staff trained to conduct energy audits.

It may be necessary to add partners incrementally, as some organizations will be interested in participating immediately while others will take a "wait and see" approach. To recruit partners it is necessary to identify how participation will help them meet their program goals without being unduly burdensome. Start with recruiting the "low hanging fruit" and solicit those partners’ help in your recruiting effort.

Who to include on the Core Team will depend upon:

Choosing an industry focus that will help Core Team members do their jobs more effectively can motivate them to participate. The GBCP can target specific business sectors, allow any interested business to apply, allow small businesses only or business of any size to apply, and/or allow schools, government agencies and non-profit organizations to apply. To decide which approach to use, the Core Team may want use the following criteria:

 

Receptivity - Small consumer-oriented businesses have in general been more receptive to participation in GBCPs than business-oriented businesses (B2B). It is appropriate to consult with local industry trade groups to assess their receptivity. Also, an industry with environmental image problems may be receptive.

Environmental Impact - Many GBCPs focus on the industries generating the greatest adverse environmental impacts within their jurisdiction. This includes determining whether there are a significant number of those businesses within the jurisdiction and whether that sector is a priority for the partner agencies. In addition, identifying environmental mandates not being met or which could be improved upon can help identify priorities for the GBC program.

Ease of Implementation - To make this assessment, the team should assess whether a GBCP checklist currently exists for that sector, whether the appropriate regulatory agencies will be willing to participate in the program and whether compliance issues are stable.

Example - The Bay Area GBP began by focusing on the Vehicle Service and Repair (VSR) sector. US EPA Region IX had developed pollution prevention training material for this sector. The California Department of Toxic Substance Control was building an outreach campaign based on that material, and there were a significant number of these businesses throughout the program area. VSR business owners tended to be small businesses with little time to evaluate p2 information (their primary sources of information were trade associations and suppliers). These businesses used many hazardous materials and generated hazardous waste. They were high visibility with considerable public contact. Finally, some programs ask Core Team Members to sign a commitment once they’ve agreed to participate, to increase program awareness and to formalize their participation.

An example of the Bay Area Green Business Program’s "Green Government Pledge" follows.

"We believe a healthy environment depends upon a healthy economy. We are actively working to show our environmental responsibility to our community through leading by example and committing to the following objectives:
  • To work with businesses and coordinate with local, state, and federal regulators to achieve the objectives of the Green Business Program.
  • To agree to a common set of Green Business Program environmental standards for the business community.
  • To provide businesses with technical assistance and guidance to achieve these environmental standards.
  • To support the conservation of energy, water and other natural resources.
  • To work with business to educate and inform the public regarding the Green Business Program."
Team Meetings - The Team will need to meet regularly with possible conference calls in between to insure that program planning stays on track. Using a professional facilitator may help. The Team's initial tasks will be to:
  • develop a mission statement,
  • define the program’s goals and objective,
  • identify the strategies for program implementation, and
  • generate an action plan specifying each participant’s responsibilities.

These tasks may be amended as work progresses. In addition, the Team should identify possible barriers to program implementation, such as overlapping jurisdictions or high inspection costs, as well as opportunities for collaboration and combining of resources. This will include assessing the regulatory process that the GBCP will address and sharing experiences. In addition, the Team should determine whether GBC-type programs have been tried and failed in the community, and if so why. In addition, they should find out whether any other agencies are currently planning a GBC-type program, and whether the Core Team can collaborate with those agencies.

Who should attend team meetings from each agency may change over time. For example, initially government agencies may choose to send upper level management. However, once the program concept is deemed worthwhile, the agency may choose to send inspectors. With their "on the ground" experience, inspectors can provide reality checks -- determining how long inspections will take, whether businesses will respond positively and under what condition, and how committed their agencies are to making the program work.

Subcommittees - The Team should decide which subcommittees to establish and who should sit on them. Possible subcommittees include:

  • Program Standards--to establish program scope and standards and oversee other subcommittees;
  • Technical--to develop checklists and supporting documents and well as program indicators. This subcommittee may include: representatives from the industries that the GBCP is certifying, trade associations, environmental regulatory agencies (which will work to ensure or create consistency between their requirements), and agencies/programs addressing resource conservation, waste reduction and pollution prevention. This committee should determine what information tracking system each agency has and how to best leverage existing resources to share information in order to monitor program effectiveness;
  • Certification/Verification--to develop recognition formats, recognition and program materials and arrange site visits to confirm information provided on the checklist, to educate participating businesses and to identify and develop assistance resources to help businesses implement pollution prevention, waste reduction and resource conservation. Participants may include:
    • Environmental advisory board or standards committee members
    • Regulatory agencies
    • Local government environmental staff
    • Department of Environment--state or local
    • Utilities
    • Government and Nonprofit Conservation Programs
    • Water Districts
    • Waste Management Programs
    • Proactive Waste Management Firms
    • P2 Programs
    • Storm water Protection Programs
    • HazMat Programs
    • Colleges and universities with environmental programs
    • Resource Conservation District
  • Public Relations/Outreach--to publicize the program and to "market" the certified businesses. Initially this subcommittee will be concerned with lining up program support. Once the program is up and running, the subcommittee will focus on increasing business participation and public awareness.
  • Advisory--to review educational material for the targeted industry, such as the information brochure and compliance checklist before distribution. Members of this subcommittee may include representatives from the targeted industry, area Chambers of Commerce and the media. This group of "friendly critics" can provide ideas and suggestions for the program before it is unveiled before the general public. The Advisory Committee can help develop program criteria, define customer requirements, and suggest the best forms of public recognition. Members of this subcommittee can use their networks to build the program awareness.
Resource Needs

The biggest start-up cost is staff time. Setting up a GBCP requires lots of time—time identifying key players and assembling the Core Team, time setting up meetings and conference calls, time holding those meetings and conference calls, and time doing the follow-up.

The main budget items in the start-up year include staff, telephone, mailing, copying, printing and travel. It may include contractual services for a facilitator and for presentations by representatives from successful GBCPs as well as funds to search for and hire a program coordinator. As the program moves towards implementation, other costs may include additional inspection time, marketing and publicity materials and activities, and training for inter-agency or multi-media inspections.

The Bay Area GBPs started small and grew. Many began with as few as 0.25 FTE funded by the lead agency. Additional staff assistance was "donated" by other agencies participating on the Core Team. Most of the programs took about one year before they were ready to certify the first business.

Funding Sources

Funding sources range from US EPA’s Pollution Prevention Incentives for State (PPIS) recently renamed Pollution Prevention Grant (PPG) grant funds with in-kind matches from partner agencies to direct contributions by partner agencies. As the programs have grown, so too have the funding sources and amounts. Grants are typically a good source of start-up (rather than long-term) funding. They usually come with stipulations about what they can be used for, and competition for these funds can be fierce.

In addition to being awarded a US EPA grant to develop its first checklist (auto repair shops), the Alameda County’s Green Business Program used the "foot-in-the-door" funding technique. It began in 1996 with four local partners – Alameda County Environmental Health Department, East Bay Municipal Utility District, Alameda County Economic Development Alliance for Business, and the Alameda County Waste Management Authority. Each local partner initially contributed $2,000 or staff hours. As the program demonstrated its effectiveness, contributions and the number of partners have grown. The program now has over 35 partners, about 20 of whom are funders contributing a total of over $50,000 per year.

Another way to leverage funding is to have an agency contribute to an effort that supports their mission. For example, because of their focus on wineries, the Sonoma County GBP has received financial contributions from the Economic Development and Tourism Boards within the county. Similarly in Hawaii the State Department of Business, Economics and Tourism supports the program’s focus on hotels.

Additional start-up funding sources have included grants from foundations, state and local agencies; ratepayer taxes; and enforcement fines and violation fees. The Contra Costa GBP, as an example, uses hazardous waste generator fees in addition to support from partners including the local Publicly Owned Treatment Work (POTW --an acronym for wastewater treatment plant), sewer, fire, storm water and solid waste agencies

In addition, GBCPs have solicited and received in-kind donations of staff time and services from government agencies and trade associations. For example, the California Department of Toxic Substance Control (DTSC) has helped the Bay Area GBP by printing program materials. In Arizona, the Rocky Mountain Fleet Association is providing staff time and marketing assistance because the program is focusing on fleet maintenance facilities. In Hawaii, hotels hoping to be certified have provided meeting space.

Once the GBC program has gained recognition and credibility, sponsorships could be a funding source. "Neutral" sponsors such as radio, TV, and newspaper organizations are usually the most appropriate. Certain corporate sponsorships can create real or perceived conflicts of interest.

Another option is to charge fees for GBC program participation. Businesses may accept this once the value of the program has been demonstrated. However, the Bay Area GBPs have determined that this would discourage participation and has therefore not chosen this option.

For additional ideas, use the Core Team to identify resources that can be leveraged from all participating program partners.

Possible sources of support include:


Administrative Structure

In most GBC programs, one agency takes the lead in the planning process -- a staff member from that agency organizes meetings and conference calls and sends out agendas, announcements, and information. These tasks can be rotated among team members. The Team's lead agency will not necessarily become the program's lead agency once the program moves into the implementation phase. Therefore, during the planning process it is necessary to determine what entity will administer the program. Options include:

The following are the pros and cons of each option.

Non-Profit Organization - While a non-profit organization has the advantage of being "independent" and of being dedicated exclusively to the GBCP, it is difficult to establish and maintain. Among other things, a lawyer must be hired to obtain non-profit legal status, tax returns must be filed, and minutes kept. However, the advantage of a non-profit is that program applicants may be more open to employees of a non-profit organization than of a regulatory agency. There is a tendency to trust government less than non-profits. An alternative is to house the program in an existing non-profit.

Regulatory Agency - While housing the GBCP in a regulatory agency may encourage business compliance, it may also discourage participation by businesses reluctant to share necessary certification information. According to BAGBP administrators, housing the GBCP in a regulatory agency works if the regulatory agency embraces the program. However, expanding the program beyond the businesses the agency regulates may be problematic since the agency may feel that this goes beyond their scope. To respond to this concern, the program may require funding dedicated to this additional mission. Another concern is addressing compliance with other agencies' regulations.

Local Government Agency - Using a local government agency to head up the GBCP administration may address the concerns raised above. However, in this case it may be difficult to get assistance from regulatory agencies, if they are not committed to the program. If the regulatory agencies are not partners in the program, then the program will be limited to certifying businesses that are not regulated. Pressure from elected officials may encourage the participation of regulatory agencies.

Multi-Agency Entity - Establishing a multi-agency organization to oversee the GBCP is similar to setting up a non-profit organization - it is logistically challenging and may depend upon the goodwill of the participating individuals. A change in agency administration could end the partnership. However this structure offers the advantage of many committed partners and therefore good coverage of many different business types. It can:

  • Build cooperative relations among regulatory agencies,
  • Ensure consistency between various jurisdictions’ compliance standards
  • Provide concise and consistent multimedia compliance information to the regulated business community,
  • Leverage scarce agency resources for enhanced compliance and public awareness building.
  • Program Coordinator

Program Coordinator - Besides selecting a lead agency, the program will need to designate or hire a Green Business Certification Program Coordinator. This individual will serve as the point of contact for interested businesses. While he/she will not be able to answer all questions, that individual will know to whom to direct the questions and requests for assistance.

In the case of the Bay Area GBPs, a Program Coordinator based in each county administers the program. She or he is attached to a county government agency, which varies by county. For example, in Contra Costa County, the Program is housed within the CUPA and in Alameda County within the Alameda County Environmental Health Department. However, Alameda County’s GBP finances are handled by a nonprofit. The Association of Bay Area Governments (ABAG) oversees regional coordination of the GBPs.


Expand Core Team

At this point, it may be necessary and/or desirable to expand the Core Team. For ideas of additional Core Team members, return to the section entitled Assembling the Core Team.

Develop Program

The steps involved in program development include:


Program Standards - Green Business Certification Program standards are laid out in industry checklists. An industry checklist is a list of regulatory compliance requirements in an industry sector as well as possible pollution prevention and resource conservation measures a business in that sector can take. Regulations may include business license and other business operating requirements, hazardous waste management, wastewater discharge, storm water protection, hazardous materials storage, air emissions, etc. Resource conservation and pollution prevention measures include water conservation, energy conservation, solid waste reduction and recycling and hazardous waste reduction.Sectors for which Bay Area Green Business Program checklists are available include (to request GBP checklists contact EFC9):
Sectors for which the Bay Area GBPs are considering developing checklists:
Another program design issue is whether or not the GBCP will have tiers. In programs with no tiers, participating businesses are required to comply with all relevant regulations. In some cases they are assigned points for the pollution prevention and resource conservation measures they assume and are required to achieve a minimum point value for certification as well as a commitment to continue complying with all pertinent regulations. An alternative is a performance-based assessment—requiring businesses to undertake a certain number of pollution prevention and resource conservation measures from different categories within the industry checklist.In tiered programs, businesses receive distinct forms of recognition for achieving each tier. They must complete core standards and meet a specified number of additional standards to advance.

In some tier programs the first tier is "achievement of compliance", the second tier is "achievement of pollution prevention and resource conservation measures" and the third tier is "achievement of additional environmental measures as well as measures that promote demonstrates environmental and community leadership".The following is a more detailed description of an alternative tiered program.
Tier 1: entry level or commitment level. This level consists in signing up to participate in the program. A tier 1 business must move to tier 2 within 2 years or be dropped from the program. In exchange for tier 1 status, the business is entitled to attend free training sessions, mentoring services, and is eligible for various audits (energy, p2 and waste minimization). Businesses at this level are not entitled to display the GBCP logo.

Tier 2: compliance plus or achievement level. Businesses certified as tier 2 must comply with all relevant regulations and have undertaken pollution prevention and resource conservation measures. The tier 2 business is a certified green business and may display the GBCP logo.

Tier 3: Environmental Excellence. Tier 3 businesses are model businesses. Besides meeting tier 2 requirements, these businesses may also comply with additional elements such as good neighbor practices/community involvement, commitment to worker health and safety and mentor tier 1 & 2 businesses in their industry. A tier 3 requirement could include adoption of an EMS such as ISO 14001.
A variation of the program described above follows:
Tier 1-- commitment to participate in the program (as described above), Tier 2-- compliance with environmental regulations, Tier 3-- compliance plus (compliance with environmental regulations and achievement of pollution prevention and resource conservation measures) and, Tier 4-- environmental excellence.

Establishing a tiered program is more complex than a non-tiered program. It requires more staff time to set up and administer than a non-tiered program. Achievement of each tier requires a recognition event and the expenditure of resources.

In addition, getting businesses to meet the certification standards of a non-tier GBCP is not significantly more difficult than getting them to achieve the compliance level tier, since complying with environmental regulations is over half the battle, according to Bay Area Green Business Coordinators. For these reasons, the Bay Area Green Business Program does not support tiered programs.In addition, the number of tiers may vary by industry since non-regulated businesses cannot achieve the compliance tier. On the other hand, a tiered program may be a way to ease businesses into the program gradually. As they learn more, they may commit to more measures and receive more benefits. It is also a way to recognize green leaders, business that may already be doing quite a bit when the program begins.

A variation on the tiering is to set up the program with no tiers, but to require improvements during recertification. This is a form of continuous improvement.

Example of programs with no tiers - Since 1996, the Alameda County Green Business Program has offered certified businesses technical assistance and incentives to go beyond basic regulatory requirements. Newly certified green businesses are recognized at an awards event in each county annually. In addition, certified green businesses receive as much publicity as the program coordinators can arrange. Once a business is certified, it can display the GBP logo at its place of business and use it on stationary and other business materials. Contra Costa and Santa Clara County also have non-tiered Green Business Programs.

Examples of tiered programs - The Green Zia program evaluates participants based on: leadership, planning for continuous environmental improvement; customer, supplier and others' involvement; information management; employee involvement; process management; and results. The Levels include Commitment, Achievement and Excellence. Organizations that meet the program criteria are recognized at an annual ceremony.

EnviroStars - from Kings County, Washington, has a two to five-star rating scale. The more proactive and comprehensive a business’s practices, the more stars they receive and the more benefits. Two stars are awarded to businesses that have had a site review and have goals to reduce hazardous waste. Three stars are awarded to businesses that have changed their practices, processes or products to reduce hazards. Four stars are awarded to businesses that have waste prevention built into their operations. Five stars are awarded to businesses that demonstrate leadership in preventing and recycling waste.

Program Materials and Forms - The program should develop material and forms and assemble them in packets for distribution to potential business participants. These packets should contain information on the program, including instructions for becoming a recognized business, application forms, the appropriate checklist, record keeping forms and contact names and numbers for technical assistance. More details are listed below in the following subject areas.
  • Logo
  • Program Explanation
  • Green Business Pledge or Commitment Statement
  • Application
  • Resource Guide
  • Measurement
Logo - The program should design a logo. It will be used to identify participation in the program and should therefore be easy for potential customers to identify and understand. The planning committee may want to hire a graphic designer for this task. Besides providing certified businesses with plaques they can display at their business, the logo can be made available for use on stationary and other business material (such as business cards, brochures and even phone book).

Program Explanation - A brochure describing the program, its benefits and the certification process is an important marketing tool. It is important to include information on the benefits associated with becoming a certified green business. Besides a written description of the program, the brochure can include a flow diagram describing the certification process. The diagram and description should identify how to sign up, the information the business needs to provide, the assistance it can receive, how information is verified, the recognition process, what happens in case of non-compliance, any appeals processes as well as contacts for other questions. Programs should consider using existing programs’ marketing materials.

Certified Green Business Pledge or Commitment Statement - Participating businesses sign the pledge to demonstrate their commitment to environmental improvement and cooperation with the GBCP. This is the starting point. The pledge can include a commitment to monitoring compliance by senior management.

Example Pledge from the Bay Area Green Business Program:

"We believe a successful business is dependent upon a healthy environment. We are actively working to show our environmental responsibility to our community by committing to the following objectives:
  • To comply with all applicable environmental regulations and strive to exceed compliance;
  • To conserve energy, water and other natural resources;
  • To develop and implement practices that prevent pollution and waste;
  • To be an environmentally responsible business within our community."

Application - The application should include the appropriate industry checklist with space for the applicant to indicate which items have been undertaken. The business should indicate that it complies with all regulatory requirements and laws, which could include:

  • Hazardous waste management program
  • Hazardous materials storage program
  • Industrial discharge program
  • Air emissions program
  • Storm water protection program
  • Other environmental regulation
  • Other business requirements (such as a business license)

The application should include requests for written proof or sign-offs by agencies, which have conducted on-site assistance or audits. This will minimize the measures that need to be validated during a site visit.

In addition, the application should include a list of possible pollution prevention and resource conservation measures a business in that sector can take with space for the business to indicate which items it has undertaken. The application is a "self-audit" that the business must fill out. It should include whom to contact in case the business needs assistance.


Resource Guide - A resource guide should include suggestions and resources on how interested businesses can achieve environmental improvements. Examples of such resources could include services, contacts, rebates, vendor lists, etc. available to businesses in the GBCP community.

  • As much as possible it should provide more than basic information such as step-by-step procedures, industry specific measures, practical tips and information about where to acquire local products or services, etc.

  • It should identify sources for telephone and on-site consultation. Some of these services may be provided by utility companies (energy audits), waste management agencies (solid waste assessments) and water agencies (water audits), small business development centers (business license).

  • Other possible resources for assistance to have in the guide include student interns from local colleges and universities and community volunteers, as well as business referral and mentor programs.

Measurement - It is important to monitor the program’s effectiveness. Towards this end, the Team should decide what they most want to be able to measure--environmental benefits, customer satisfaction, success of the program in spurring behavior change, improvement in the regulatory system, or all of the above. The next step is to select indicators of program success and develop appropriate record keeping forms. This will be the job of the Compliance Committee. Demonstrating the program’s effectiveness will be key to securing future funding and support for the program. However, it is important to keep in mind that the indicators be realistic. Most small business owners don’t have the time to do more than operate and GBCP Coordinators also don’t have much additional time either. Possible indicators include items that are already monitored such as: hazardous waste disposal listed on bills, solid waste disposal listed on bills, water and energy use (again from bills) and number of violations. It is possible to add more record-keeping requirements as part of recertification.

Pacific Northwest P2 Resource Center's (PPRC) Environmental Management Primer is an on line resource for measurement indicators. This primer provides information and expertise on measuring the environmental results of P2 activities. Resources include case studies, fact sheets, checklists, and guides for measuring environmental performance as well as links to other sites.

Certification / Recertification / Revocation - Certification, recertification and revocation of certification are performed by the Verification / Certification Team.

Certification - To be certified, a business must meet the Green Business standards laid out in the industry checklist. Participating businesses are required to comply with all relevant regulations. As described in the Program Standards section, in some program applicants are assigned points for the pollution prevention and resource conservation measures they assume. In those cases, a minimum point value is required for certification as well as a commitment to continue complying with all pertinent regulations and implementing resource conservation and pollution prevention measures. In other cases, the programs require applicants to undertake a specific number of pollution prevention and resource conservation measures.

Certification requirements will vary depending upon whether the program is tiered or not. To be effective, the GBCP must verify completeness and accuracy of the compliance checklist, determine whether the applicants have any hazardous waste issues or violations on record, and assess whether the applicant has implemented the indicated resource conservation and pollution prevention measures, through review of the forms and on-site visits. This is an opportunity to educate the applicants

Three types of verification for regulatory compliance are possible:

  • One site visit by the inspector from the lead agency to verify that all regulatory requirements have been met,
  • One visit by a joint team of inspectors to verify that all regulatory requirements have been met; or

  • Separate site visits by individual inspectors to verify that all regulatory requirements have been met.

The Verification Team will have to determine how it will assess implementation of resource conservation, pollution prevention and waste reduction measures. In addition, the team should develop a notification system to inform the lead agency of the assessment results.

To prepare businesses for verification visits, the program may train student interns or community volunteers to make preliminary site verification visits or use businesses which have already achieved GBCP status (like mentor businesses) for this purpose.

Prior to program implementation, the Verification Team should run practice verification drills at facilities of steering committee members.

Recertification - The program should determine how often a business needs to be recertified and what it needs to do to meet recertification requirements. In most GBC programs, businesses must be recertified every three years and recertification requires inspections and sign offs by regulatory agencies. The program team should consider if it wants to require applicants to improve their behavior each recertification period and if so what is required and what the reward will be. To promote continuous improvement, the program can require businesses to mentor each other or arrange for certified businesses to meet each other regularly and share greening tips.

Revocation - The conditions under which certification is revoked need to be specified. In most GBCPs, certification can be revoked if an agency inspector finds a willful or significant violation during a routine inspection before the recertification time period. Minor violations are acceptable, if the business reports and corrects the problem within a reasonable time period.

Incentives - In order to encourage business participation in the GBCP, the team should identify participation drivers. This will vary by industry and business size. In particular, consumer-oriented businesses are enticed by different incentives than business-oriented businesses. GBCPs have identified customer retention, industry leadership, cost savings, employee morale and elimination of environmental/regulatory surprises as some of the key program participation motivators.

The most common perks given are a recognition certificate, a sticker and media coverage as well as publicity in GBCP promotional materials, at events and through advertising. Signing, issuing and awarding the GBCP certificates (at a ceremony) is an opportunity for public education and free publicity for the business. It is important to select a signer, issuer and award event that will maximize these. Possible signers include local politicians, industry "stars" or agency administrators. Possible issuers include an industry trade association or the GBCP. The recognition event may be held at the industry trade association’s annual meeting or at an Earth Day or Pollution Prevention Week event.

Another set of incentives is environmental compliance assistance including concise and consistent compliance information, a reduction in redundant regulatory inspections and an integrated compliance checklist that streamlines the environmental compliance inspection process. While it may not be possible to offer all of these benefits initially, regulatory agencies should consider reviewing the way they are delivering environmental compliance assistance to the regulated business sectors and address any contradictory regulatory requirements so that businesses receive a consistent message.

The GBCP can offer applying businesses technical assistance in learning how to meet the program standards, which may save them money and help increase consumer loyalty. Fee reductions, while desired by businesses, may be difficult to get adopted.Possible program incentives include:
Implementation Plan

The final step in the planning process is to plan the program implementation. This includes hiring the program coordinator, assembling the program material, identifying the first program applicants, determining how they will be evaluated, and planning the kick-off event at which the first certified businesses are recognized.To solicit the first applicants, the GBCP coordinator may request assistance from the Core Team members. For most GBCPs, businesses helping develop the program are interested in being the first certified. The program should start by targeting "low hanging fruit"—businesses that are ripe for this opportunity. These early adopters are industry leaders and their experience will help recruit others. In addition, they will help vet the program