Comments on the Recommendations from Members of NACEPT The following comments provide an impressive range and depth of analysis and input concerning the complex subject of international trade policy and its relationship to environmental policy. NACEPT members chose to comment both on the nature of the topic and on specific issues they believed to be missing or incorrectly emphasized. The Trade and Environment Committee welcomes the comments and provides them in tandem with its recommendations as an indication of their relevance and importance to the subject matter. In addition, Chairman Sam Schulhof believes that the most effective way to address the comments, considering their breadth and depth, is for the Committee to include them in their scope of study in future work. The following represent summaries and excerpts from the comments received from NACEPT members: " ... The Need for Addressing the Trade/Environment Intersection "....... there is a need for special cooperation in environmental management and trade worldwide in order to protect basic resources. We further believe that a need exists to mediate conflicts which arise between trade and environmental objectives." "... the world can achieve both expanded free trade and environmental protection, 'provided that deliberate crafting of environmental safeguards is an integral part of trade policy'." " The History of U.S. Trade Policy vs. U.S. Environmental Policy ... it is inappropriate to state that U.S. Environmental Policy is less developed. Environmental policy in the United States is probably more developed than any other country in the world at this time, and is considered a model for other countries. It is clearly being used as a model, for example, for Mexico." " ... Local vs. Global Environmental Issues in talking about environmental threats that were once viewed as localized, citing air pollution as a representative example is inappropriate. Air pollution by its nature has been perceived as a broad geographic area problem for many years. The movement of contaminated air masses on a global basis is a natural phenomenon that has been understood in concept for a great many years and modeled in some form 20 plus years ago." Transparency and Public Participation "The recommendation of the three working groups to improve public participation and transparency in trade decision making is an important step towards the enhanced cooperation of all parties. The importance of non-governmental organizations in these discussions cannot be overstated." The U.S. EPA Training Institution "The Recommendation for 'continued and enhanced support' of the U.S. Environmental Training Institute (U.S.ETI) ignores the contribution of professional associations in favor of a private enterprise. There are professional and trade organizations uniquely equipped to facilitate the participation of the U.S. environmental goods and services industry in international markets. . . . Active support of these organizations will enhance the efforts of the U.S. in promoting the greening of world trade, and ensure a strong U.S. presence.” Harmonizing Standards "We firmly believe in the importance of harmonizing standards to reduce trade barriers and lower production and distribution costs.... The International Union of Air Pollution Prevention and Environmental Protection Associations (IUAPPA) Declaration on Pollution Prevention ... addresses the issue of harmonization of environmental standards... (and was) used in Rio by some countries to support their national positions on this issue...." OECD Environmental Advisory Committee "We support the establishment of an Environmental Advisory Committee for the OECD, similar to the existing Business and Industry Advisory Committee and the Trade Union Advisory Committee. Further, (we) would welcome the opportunity to serve as a member organization on such an OECD committee, and recommend that other NGOs be likewise used as a vehicle for reaching those in the environmental profession." Western Hemisphere Institutional Issues “Rather than create a new program for the developed and developing countries of the Western Hemisphere, we recommend supporting the expansion and improvement of existing programs of professional and trade associations... (it) makes the best use of limited assets by leveraging the resource of the private sector." Environmental Technologies focus on environmentally sound or clean technologies, not just environmental products and technologies, as a trade opportunity." "...I believe that we should be presenting the United States in the most positive way possible from the perspective of international trade as it relates to environmental technology. It is not unreasonable to expect that the country with the most developed environmental policy, laws, rules, and regulations would also be the country that has the most developed technology. Now that technology can have application in other countries." Competitiveness "In reviewing the specific recommendations, I am unclear about whether the working group is making a recommendation concerning the potential impact of environmental considerations on U.S. export capability. The environmental concerns come through clearly. I do not believe that is also true of the export concerns." "This [OECD Working Group, II. Competitiveness, No. 4] is the first comment in which we mention the impact of present U.S. environmental regulations on flexibility and efficiency, and particularly the ability of the U.S. to develop new, marketable, and innovative solutions to environmental problems within the U.S. for export as opposed to developing them overseas for import. I believe this is a very important issue that is significantly interleaved with and influenced by the overall trade issues that have been discussed. This issue should get some further attention in the earlier parts of the report, and somewhat greater highlighting in the recommendations." "This recommendation [OECD Working Group, II. Competitiveness, No. 5] should be more comprehensive in nature. We need to have the support of the appropriate U.S. agencies including the Department of State and the Department of Commerce to help improve our competitive position overseas. At a minimum, we should learn and adopt what we can from our most successful competitors in newly opening markets (reference the success of German industry in Eastern Europe [and not just because of proximity] and the Japanese worldwide).” Implementing the Recommendations "Sustainable development, transparency, participation, a significant role for EPA, are motherhood principles, and the overview report says nothing on their implementation. To recommend that efforts be undertaken 'to reconcile the GATT and multilateral environmental agreements, when they are in conflict' is not very useful. Finding that criteria should be developed to evaluate the environmental impacts of future trade agreements, or the effects of environmental protection on competitiveness, does not add much either. The administrator will be happy to learn the Committee is in favor of flexibility and incentives to encourage efficiency and innovation, but will he be better prepared to do his job?" |