| This dissertation examines permit requirements and environmental performance at two pulp mills located in Washington. It finds that in practice permit conditions are more flexible and broader than those described in academic literature. First, permit requirements to install technology are negotiated and conditional. Second, permits regulate technology change initiated by the facility through clearance requirements designed to ensure that the possible environmental impact of the desired technology change will be considered prior to installation. Finally, permits in Washington have included management system requirements since the early 1970s.; In the majority of cases, machinery installed as a result of permit requirements resulted in improved environmental performance, but in other instances there was no significant effect, and in one instance performance worsened. Technology changes initiated by the facility had no significant independent effect on environmental performance.; In addition to, and independent of the effect of changing machinery, one facility showed a declining trend in pollutant levels, while the other did not. This declining trend was attributed to management intervention at the facility. While both facilities were required by law to implement specific environmental management systems, and both facilities had developed general environmental management systems, only one showed a significant declining trend. Thus it appears that, in at least one case, legal requirements to develop environmental management systems, and the presence of management systems, are not sufficient to result in continuous improvement, or a downward trend in environmental performance. |
