The simplification measures for EMAS companies in Europe and in Germany

The simplification measures for EMAS companies in Europe and in Germany 1

Sommario 1 Introduction to the case study... 3 1.1 Motivation of case-study... 3 1.2 Background... 5 1.3 Methodology... 5 1.3.1 Description of survey sample... 6 2 The simplification measure... 15 2.1 Description of the measure... 15 2.2 Description of the characteristics of the sector within the region... 16 3 Analysis... 17 3.1 Analysis of the level of application of a measure... 17 3.2 Analysis of Adopters benefits... 19 3.3 Environmental benefit analysis... 22 3.4 Analysis of the achieved results at the macro level... 31 3.5 Satisfaction analysis... 33 2

1 Introduction to the case study Germany is undoubtedly the most important European countries for supporting to uptake the adoption of EMAS scheme among companies.. The EMAS registered companies in Germany are more than 1.300; the main sectors of these companies are Services (NACE code 90) (9%), Manufacture of chemicals and chemical product (around 8% - NACE code 20), Waste collection, treatment and disposal activities; materials recovery (around 7%-NACE code 38 ) Accommodation (around 4% NACE code 55). Many companies also operate in metals field, mechanic and automotive field and others. In these years, many initiatives were carried out at regional and national level to remove the typical drawbacks affecting EMAS adoption. For instance, there are 100 simplification measures for EMAS and ISO 14001 companies in Germany: 30 measures are implemented at national level by Federal Government and 70 measures are implemented at Lander level by the regional Authorities. One relevant example is the Federal Law selected for the case study is Ordinance of 24 June 2002, Enacting and Amending Ordinances, under Immission Control and Waste Law. The Ordinance aims to define a set of simplification measures and regulatory relief to simplify the administrative procedures concerning the environmental management (such as permit and monitoring activity) of companies. This Law reduced the commitment of firms in the administrative procedure and in the monitoring activities provided in other previous regulations. Because of Germany is the main European country for number of EMAS companies and number of simplification measures and incentives, this case study aim to investigate the level of knowledge and satisfaction concerning the simplification measures adopted in Germany. Furthermore, we compare the level and effect of EMAS adoption as well as the perception about the existing simplification measures between German companies and EMAS companies from other European countries (except Italy). 1.1 Motivation of the case-study As we above mentioned Germany is undoubtedly the most important European countries for supporting to uptake the adoption of EMAS scheme among companies. Since the first EMAS regulation, Germany has always recognized EMAS as an important instruments for companies to improve environmental performance. Data on EMAS registration highlight that Germany was always the first countries for number of registered organization and site, even if in the last years, Italy and Spain have achieved good results. 3

Figure 1 EMAS organization and sites This commitment is deduced also by considering the number of simplification measures adopted in Germany. Starting from 1996 the German Authorities implemented over 100 simplified measures to support the dissemination the EMAS and ISO 14001 certification and to award the companies The main type of measure is the reduction of reporting and monitoring requirements (17%) and public procurement (17%). The national Authority implemented also measures aiming to reduce inspections information requested for issuing an environmental permit. An important example of these initiatives is the Ordinance of 24 June 2002, Enacting and Amending Ordinances, under Immission Control and Waste Law. The Ordinance was adopted by the Federal Government and focused on environmental management of the productive companies. It promotes simplification measures to simplify permitting procedures and frequency of monitoring activities on emission and hazardous incidents. 4

1.2 Background The relevance of simplification measures for companies with environmental certification was already in the first studies and research focusing on the EMAS and ISO 14001 companies. For instance Morrow and Rondinelli (2002) 1 have investigated the main reasons of EMS adoption. By citing the results of a survey carried out by German Federal Environmental Agency, they confirm that EMAS or ISO 14001 companies perceive benefits and experience positive impacts from implementing environmental management systems and among these benefits there are the regulatory reliefs. A study carried out by the Multi-State Working Group on 50 private and public facilities that developed EMS as pilot projects in the United States, found that 89% of the publicly-traded corporations and 67% of the privately-owned businesses adopted EMS because they were mandated or encouraged to do so by their parent organizations (UNC-ELI, 2001). Companies in the sample reported strong motivations for adopting an EMS arising from expectations of improving regulatory compliance or achieving regulatory benefits. In one of the few large-scale surveys of companies adopting EMS and pollution prevention practices, Florida and Davidson (2001) 2 asked executives of 214 manufacturing companies in Pennsylvania what motivated them to do so. They found that the strongest motivator was the commitment to environmental improvement (91.9%), followed by the opportunity to attain corporate goals and objectives (88.7%), economic benefits and improved business performance (87.1%), State and federal regulatory climate and other regulatory benefits (85.5% and 83.9) and improved community relations (85.5%). 1.3 Methodology The methodology to assess the level of EMAS adoption, its benefit and drawbacks, mainly on the existing simplification measures, is based on a questionnaire survey among the EMAS registered companies operating in Germany and in Europe. The aim of the methodology is to obtain the perception of companies on EMAS scheme and on the role of simplification measures in the EMAS adoption. The following steps can be identified: i) identification of EMAS company list; ii) questionnaire design; iii) data collection; iv) data analysis. The first step was to identify the European EMAS companies in order to define the statistical population of the survey by analyzing the official EMAS register available on DG environment web site. Since our focus are industrial companies we excluded public authorities from the scope of the survey. The exclusion is justified by the fact that public authorities usually do not carry out 1 D. Morrow and D. Rondinelli (2002) Adopting Corporate Environmental Management Systems:Motivations and Results of ISO 14001 and EMAS Certification European Management Journal Vol. 20, No. 2, pp. 159 171, April 2002 2 Florida, R. and Davidson, D. (2001) Gaining from green management: Environmental management systems inside and outside the factory. California Management Review 43(3), 64 84 5

activities that are in the scope of the simplification measures. Moreover, they are mainly the promoter of simplification measures in the regulation, so the survey could generate confusion in the responder of public authorities. Moreover, we excluded also Italian organization since they are involved in a ad-hoc survey. Starting from the European database of EMAS companies, that contains data about 4518 registered organizations (July 2012)3, companies were selected and a statistical population of 3154 firms was identified. The survey was carried out by using the e-tool Survey Monkey, a software for on line interviews. The questionnaire is composed by 6 sections and 29 questions included personal data of respondents. The first section concerns the organization details and general information on clients, competitors and economic performance. The second section aims to evaluate the level of implementation of EMS requirements. The third section, composed by two questions, aim to assess the environmental performances of companies. The fourth section deals with investments in the last three years. The main sections of the questionnaire are the section 5 and 6 that concern the simplification measures by assessing the level of knowledge and the usefulness of the measures adopted, the incentives and hindrances for EMAS adoption. The questionnaire was also translated in Spanish and Portuguese by two project partners: IAT and Chamber of Commerce of Valencia that promoted the survey among all EMAS companies operating in these two countries by e-mail and phone call. All EMAS companies of the selected sample received the questionnaire by e-mail; the first e-mail was sent on 8th September 2012 and several reminders were sent until 15th November. 1.3.1 Description of the survey sample The number of respondents to the survey is 137 companies but only 97 questionnaires contain information that can be processed. Many companies have started to fill in the questionnaire, but they have included only few information that did not allow to make the questionnaires usable. The table 1 shows the geographical distribution of EMAS companies composing our statistical population and how many companies have filled in the questionnaire. In absolute value, the main response rate was achieved among Spanish companies (here, it was important the supporting role conducted by IAT), followed by Germany (15), Austria (12) and Denmark (11). Only one questionnaire came from Finland, Lithuania and Poland. 3 Data source: http://ec.europa.eu/environment/emas/register/ 6

Table 1 Number of EMAS companies contacted and number of respondents for European Member States Country EMAS companies contacted Respondents Austria 248 12 Bulgarian 2 1 Belgium 39 3 Czech Republic 24 5 Denmark 67 11 Finland 6 1 France 24 3 Germany 1260 15 Greece 43 3 Ireland 4 2 Lithuania 9 1 Malta 2 1 Norway 4 2 Poland 29 1 Portugal 60 7 Spain 1162 22 United Kingdom 46 7 TOTAL 3027 97 Response rates range from approximately 1% to 50%, with a weighted mean of almost 3,2% (see figure 2). With respect to previous industrial surveys undertaken in the environmental area, this result is low for an e-mail survey. For instance, in a review of 183 studies based on business surveys published in academic journals Paxson 4 reports an average response rate of 21%. The response rate is particularly low regarding Germany (around 1%), the country with the highest number of EMAS registrations; few companies participated in the survey respect to number of 4 Paxson MC. Response Rates for 183 Studies. Working Paper Washington State University (1992).Washington State University 7

registration in this country (1260 in the manufacturing field). Many other surveys on EMAS realized in Germany have achieved a low level of participation; for instance a survey to judge this new instrument of European environmental policy (Freimann and Schwedes) 5 has obtained a participation around 1% of German EMAS sites. Figure 2: Response rate for European countries The companies involved in the survey are classified in three categories according to their age: i) less than 50 years old, ii) age between 50 and 100 years, iii) more than 100 years old. The age of the interviewed firms is mainly less than 50 years old (71%); 20% of the sample has been founded after the Second World War and only 9 companies (9%) is more than 100 years old (see figure 3). The 5 J.Freimann and R. Schwedes EMAS experiences in German companies: a survey on empirical studies Eco- Management and Auditing Eco-Mgmt. Aud. 7, 99 105 (2000) 8

oldest companies involved in the survey are located in Germany (4) in Austria (3), Spain (2) an France (1), while the majority of young companies is located in Spain (17) and Denmark (8). Figure 3 Age of companies Regarding the organizations size, following the definition of Recommendation 2003/361/EC6, the survey sample was classified in 4 categories according to the number of full-time employees operating in the companies. It can be noted that the sample is mostly composed of medium organizations, employing from 50 to 250 employees (53%). The small firms are 24% of the sample and the large firms are 24%. In the category of small companies 9 can be classifies as micro because employ less than 10 people. 6 The Recommendation 2003/361/EC at article 2 of the Annex defines the category of micro, small and medium-sized enterprises (SMEs). Small enterprise is made up of enterprises which employ fewer than 250 persons and which have an annual turnover not exceeding EUR 50 million, and/or an annual balance sheet total not exceeding EUR 43 million. In the SMEs category the Recommendation defines the micro firms as an enterprise which employs fewer than 50 persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 10 million. 9

Figure 4 Dimension of respondents for number of employees In order to characterize a company in the market arena, several questions were set to investigate, for instance, the position along supply chain, number of competitors, market scope, etc. The first question investigates the position along the supply chain i.e. the phase of the product or service life-cycle in which they operate. The distance from the final consumer is certainly relevant to determine the motivation of adopting EMAS and, in some cases, the satisfaction towards enhancing measure implemented by policy makers. For the 40% of organizations the primary customer is final consumer/ end users, especially for Spanish, German and Danish companies, while 32% of the sample operate in a business-tobusiness market, selling their products to other manufacturing firms; 22% of the organizations provides own products to wholesalers or retailers. Just the 4% of interviewed companies sell own product/service to a facility within the same company (multisite or multinational corporations). By analyzing the German respondents, it emerged that for 7 companies the main client is final consumers and for other 6 is other facilities within the same company. 10

Figure 5 Primary customers Another characteristic of the sample organisations that can be emphasised, refers the features of the market in which a company competes such as geographical dimension and number of competitors. About geographical dimension, four categories were identified: local, national, European, international. The 42% of respondents affirms that their most important market is the national one, while the 30% mainly operates at international level. The local market is the main geographical reference for product from the 16% of firms. German companies operate especially at international level (7) and European level (5); Danish and Spanish respondents selected especially the local level. 11

Figure 6 Geographical scope of the market To measure the level of market competition, we asked how many competitors a company has with regards to own main commercial product. A respondent could choose selecting the following options: less than 5 competitors; from 5 to 10 and more than 10 competitors. Most of the respondents (47%) operates in a competitive market mainly in Spain, Germany and Austria. This confirms that EMAS is still viewed as an instrument can improve a firm s competitiveness. Figure 7 Level of competition To success in a competitive market, a company can strategically focus on different approach. It can apply a price competition or stress the quality of the product, it can invest on its reputation or construct strong relation with along its supply chain. In detail, we analyzed the competitive variable commonly used by the firm to promote its products on the market. 12

The results confirms that EMAS company mainly focus on product quality (very important for the 93% of the respondents); for the 68% of respondents organization s reputation is a very important competitive variable. Less than half of respondents considers price (mainly firms operating in UK, Czech Republic and Spain) and relation with suppliers as a key competitive variable. Reputation is very important for 10 German companies involved in the survey and for many enterprises operating in Denmark and Austria. The relationship with suppliers is very important only for 6 German companies, while the others considered this variable moderately or not important. Figure 8 Competitive variables The last question of the first section aim to evaluate the firm s economic performance during the last three years (How would you evaluate the economic performance of your organization during the last three years?). The questionnaire suggests 5 options based on the assessment of firm s revenues: i) revenues were so low that we had major losses; ii) revenues were not enough to cover costs; iii) revenues were enough to break even; iv) revenues were enough to have some profit; v) revenues were well above costs. The results confirms that for majority of EMAS firms the revenues were enough to have some profit (46%) only for the 1% the revenues were so low that we had major losses. For the German respondents 5 firms confirmed that the revenues were well above costs and for 6 enterprises were enough to have some profit. Figure 9Competitive variables Evaluation of economic performances of firms 13

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2 The simplification measure 2.1 Description of the measure As we above mentioned, this case studies does not focus on a specific simplification measures but aim to investigate the level of knowledge and satisfaction concerning the simplification measures adopted in Germany and in Europe. However, in this paragraph we intend to describe the main contents of one of the most important German simplification measure. The Ordinance of 24 June 2002, Enacting and Amending Ordinances, under Immission Control and Waste Law is one of main legislative measure to support EMAS adoption. As it can be deduced by reading the title, the Ordinance modifies existing environmental laws, such as the Authorization Procedure Ordinance published in Federal Law Gazette 1992 I p. 100, including several benefits for EMAS organizations, in the following fields: waste management and controls (section 1, 2,4 and 5); emissions of volatile organic compounds (section 3); waste recovery (section 6). In detail, the Ordinance provides for the exemption from the air emission control and hazardous incident officers for EMAS firms (section 1 article 3); furthermore, Annual reports pursuant by Act for Promoting Closed Substance Cycle Waste Management and Ensuring Environmentally Compatible Waste Disposal shall not be required if equivalent information emerges from the environmental audit report and operational emission control. Concerning air emission monitoring the competent authority should not require measurements until after expiration of a longer period than three years in the case of EMAS facilities; the competent authority should,moreover, allow the operator of an EMAS facility to perform measurements using its own personnel (If the personnel is qualified). This simplification is provided for other monitoring activities and for different types of plant (as firing plants, incineration plants for waste and others). At the article 7 the Ordinance provides simplification in the reporting activities with the competent authority. Still, the competent authority should extend by one year in each case the intervals for measurements on EMAS companies provided for the emissions of highly volatile halogenated organic compounds (article 8). The Ordinance valorizes also the environmental statement as a tool to inform and disseminate the environmental performance of EMAS firm among local stakeholder and Public Authorities. The section2 deals with another important field of simplification measures such as to support EMAS firms I permit renewal by using information included in the environmental statement or audit report. Specific simplification measures concerning the transfer and storage of motor gasoline and the end-of-life vehicle, are provided for in the section 3 and 4. 15

2.2 Description of the characteristics of the sector within the region This case study does not focus on a specific sector or region but analyzes the effectiveness of simplification EMAS for all EMAS registered organizations in Germany and Europe. In EU; the number of EMAS registrations accounts, in the first semester of 2012 4581 organizations (figure 10). Germany continues to be the country with the highest number of registrations and the corporate environmental management is on the rise. Nearly 10.000 companies and organizations have decided to either the European EMAS system or the international standard ISO 14001 or one of the many offered to introduce environmental management approaches in use. In Germany, there are currently 16 of these approaches. Many of these, infra EMAS and ISO approaches, addressed mostly in small and medium enterprises 7. In Germany the EMAS organizations are 1838 (September 2012), 40% of the European EMAS registrations. This result can be connected with different strategy for EMAS dissemination implemented in Germany at different territorial level; the main reason for the high number of EMAS registrations in this country can be the presence of simplification measures and incentives adopted at federal and regional level to incentive the EMAS adoption. The German federal states also have a number of environmental management approaches that may not reach the high level of EMAS but are tailored to the needs of certain industries and so help to identify potential for initial savings. They also provide an opportunity to introduce a comprehensive environmental management system step by step and then achieve EMAS. Figure 10 Evolution of EMAS registration 7 UGA, German EMAS Advisory Board, Creating Added Value with EMAS,2011. 16

3 Analysis 3.1 Analysis of the level of application of a measure The survey investigated the level of application of simplification measures in Germany and Europe. Two questions was set to analyze the level of application of measures: the first question investigate the level of knowledge of simplification measures among EMAS companies ( Are you aware of any regional or national regulation simplification for EMAS registered companies? ); the second question intends to quantify how many EMAS organizations have beneficed of simplification measures ( Has your organization ever benefited from simplification since registration? ). The following figures shows the level of awareness on existing simplification measures for EMAS organization in Europe and in Germany. Considering all respondents, 55% of them knows the simplification measures included in the applicable regional or national regulation. This percentage is significantly higher in Germany where the 87% of firms of the sample has a good knowledge of the existing simplifications measures. Good performance emerges also among Austrian organizations, while firms from Spain, Denmark and UK have a level of awareness in line with the average data (50%). On the contrary, a scarce awareness emerge in particular among firms from Czech Republic and Portugal. Figure 11 Level of awareness on existing simplification for EMAS registered companies among European (green) and German (blue) respondents As a consequence of a not full knowledge of the existing simplification, the percentage of firms that has benefited of simplifications is quite low (27%), while in Germany almost 2 EMAS firms of 3 have benefited of at least one simplifications. 17

Figure 12 Enterprises that benefited of simplification since registration among European respondents There are several types of simplification measures that policy makers can introduce in their legislation. Among the 14 types of measures identified in the questionnaire, respondents have selected 76 measures, 21 measures were selected by German firms. The main measures used by interviewed companies is Reduction of inspections (25% in Europe) and Self declaration in the procedure of extension of a permission (10%). The result emerged at European level are the same of at German level. In this country the main simplification measures used by EMAS firms are the Reduction of inspections (47%), Self declaration in the procedure of extension of a permission (20%) and Self declaration in the procedure of achieving a permission (20%). Few companies in Europe used measures such as Fast track permit (only one companies in Denmark) or Extension of permit period (only two companies one in Germany and one in Greece). Table 1 Simplification measures used by respondents EU GER EU GER (% on total of measures in UE) (%on total of measures in Germany) Type of measure Self declaration in the procedure of extension of a permission Self declaration in the procedure of achieving a permission 10 3 10% 20% 6 3 6% 20% Reduction of inspections 24 7 25% 47% Dispensation from Administrative Fines 3-3% 0% Extension of permit period 2 1 2% 7% Fast track permits 1-1% 0% 18

Modification in the aim of application Information required for permits Reduced reporting and monitoring requirements Reduction of technical reports to the competent body Reduction financial guarantee required for specific activities Advantages in the execution of contracts to supply and / or work with the Public Administration 2-2% 0% 3 1 3% 7% 9-9% 0% 4 1 4% 7% 3 1 3% 7% 5 2 5% 13% Tax Reduction 4 2 4% 13% TOTAL 76 21 3.2 Analysis of Adopters benefits One of the main purposes of the simplification measures for EMAS registered organization is to allow them to achieve resources savings both in terms of human and economic resources. We asked to EMAS organizations What are the advantages due to simplification since your EMAS registration?. The respondents had to select the level of agreement according to the following types of benefits: i) cost reduction; ii) time savings; iii) better relations with competent authorities; iv) stronger motivation to maintain certification; v) other. The following figure show the results emerging among the European respondents: the 52% confirmed (strongly agree) that simplification measures allow to reach relevant time saving employees time; reduction of cost is considered a benefits by 36% (strongly agree) and 54% (agree) of responders. Regarding the remaining options, the answers are equally distributed on the poles: better relations with competent authorities is considered a relevant benefit by 28% of respondents while the24% disagrees with this statement; the same percentage (18%) strongly agrees and disagrees with the statement that simplification measures determine a stronger motivation to maintain certification. By focusing on German respondents, it emerged that the level of agreement is significantly higher than firms from other countries about the improvement of relation with competent authorities. On the opposite, cost reduction is less considered as a benefit achieved by using simplification measures. 19

Figure 13 Advantages due to simplification - European and German respondents By benefiting from simplification measures a firm, as highlighted above, could achieve significant savings that could be used for environmental investment. The survey s results found that environmental investments are not changed for the 48% of European respondents (64%) for German firms) while they are increased or significantly increased for the 34% of European EMAS firms and for 21% of German firms. Finally, the investments decreased for the 18% of European respondents and for the 14% of German respondents. 20

Figure 14 Organization s investments in the last three years for European and German respondents Since simplification measures can generate significant savings that could be partially use to improve the effectiveness of environmental management system, we compare the answers to the question on environmental investments between firms have benefited to simplification measures (27%) and those did not (64%). The information emerging from the figure below is twofold: from the one hand, we cannot affirm that firms that have benefited to simplifications increase investments more than firms that have not benefited; on the other hand they reduced investment less than firms that have not benefited. Figure 15 Investments for companies that beneficed of simplification or not (European respondents) 21

3.3 Environmental benefit analysis Continuous improvement of environmental performance is one of the main aim of an environmental management system. The use of simplification measures does not have a direct effect on environmental performance but, by generating resource savings, this could be used to improve the effectiveness of the management system. In the literature several research have investigated the effect of EMAS adoption on environmental performance (Daddi et al. 2011; Iraldo et al. 2009) 8. For instance, a recent research compared the environmental performance of firms in Latvia before and after the EMAS registration (Tambovceva, 2010) 9 ; another research, by focusing on the environmental performances of German EMAS and ISO 14001 firms (Freimann and Schwedes, 2000) 10 found that the implementation of an environmental management system also leads to cost savings and corporate benefits. Furthermore, some research focused on specific industrial sector, for instance Fürst and Oberhofer (2011) 11 carried out a survey on the costs, methods and operating experience of environmental management in the respective companies. Only 43% of 259 participating companies described themselves as environmentally active. Especially larger companies carried out environmental management due to the awareness of its growing importance in the future, image improvement and the distinction from the competitors. In order to measure the environmental improvements generated by EMAS adoption, according to Arimura et. al (2008) we used the following question: With reference to the production unit, what is the environmental improvement attained in the following environmental aspects after implementing EMAS?.The environmental aspects provided in the questions are: energy efficiency; efficiency of the materials; water consumption; waste production; biodiversity; air emissions ; wastewater discharge. At European level (Figure 14), the most relevant improvement are obtained in waste production (40% of respondents declared to have obtained high improvement and 31% declared to have obtained good performance) and in energy efficiency (34% high and 42% good improvement). All respondents from Austria and Denmark declared high and good environmental improvement concerning energy efficiency while the Spanish and English firms achieved high and good results in water consumption. The main benefits concerning the air emission are achieved by English and Danish companies. 8 T. Daddi, M. Magistrelli, M. Frey and F. Iraldo (2011). Do environmental management systems improve environmental performance? Empirical evidence from Italian companies. Environment, Development, Sustainability, Volume 13, Number 5, Pages 845-862 Iraldo F, Testa F and Frey M (2009), Is an environmental management system able to influence environmental and competitive? The case of the eco-management and audit scheme (EMAS) in the European union, Journal of Cleaner Production 17 (2009): pp. 1444 1452 9 Tatjana Tambovceva, Assessment model of environmental management: a case study of construction enterprises in Latvia, Economics and Management, 2010. 15, 799-806 10 Jurgen Freimann and Roswitha Schwedes, EMAS experiences in German companies: a survey on empirical studies Eco-Management and Auditing, 2000, 7, 99 105 11 Elmar Fürst and Peter Oberhofer Environmental management: a brick in the wall of sustainable management - transport for hire or reward and own-account transport on trial,2011 Volume 13 Issue 3 22

Figure 16 Environmental improvement for European respondents By focusing on the German respondents, the results show that German firms are more capable to get high improvement on resource efficiency than firms from other countries. Figure 9 Environmental improvement for German respondents 23

Concerning the respondents that benefited to simplifications the distribution of answers are quite similar to respondents that did not benefit, except for improvement on energy efficiency performance. Figure 18Environmental improvement for respondents that have benefited and for enterprises that did not benefit of simplification at European level To verify the effectiveness of the environmental management system, we considered the four key elements composing the EMS according to Deming Cycle (Plan Do Check Act): Planning of environmental related activities; Training activities and involvement of employees in environmental matters; Implementation activities of management of environmental issues (including build up and emergency response); Measurements, surveillance and internal control. For each of these aspects composing the environmental management system, the questionnaire proposed three questions that the respondents could evaluate by using the following alternatives: 24

not implemented; poor implementation; implementation was started but not completed; good implementation; good implementation of the initiatives and positive evaluation of their effectiveness. Regarding the planning of environmental related activities the assessment is composed by 3 aspects (Figure 19): The environmental policy was effectively disseminated to all employees by 60% of European respondents and by 67% of German respondents; Based on the policy, setting measurable objectives and targets related to the environment was positively implemented by 63% of European respondents and by 67% of German respondents; Initiatives aiming to gather opinions and suggestions coming from the employees as regards the environment was successfully implemented by 25% of European respondents (40% declared also to have a good implementation ) and by 40% of German respondents. Figure 19 Planning activities for European and German respondents By comparing the answers between the respondents that benefited to simplifications and those that did not benefit, a significant difference only emerged on the actions to effectively disseminate the environmental policy. 25

Figure 20 Planning activities for respondents that have or not benefited of simplifications Regarding training activities and involvement of employees in environmental matters, the following aspects were taken into account (Figure 22): Incentives to implement the principles and procedures related to environmental protection are offered to employees: 66% of European respondents and 29% of German respondents affirmed to have effectively implemented this kind of initiatives; Project teams coming from different company departments are in charge of solving specific environmental issues: 71% of European respondents and 29% of German respondents affirmed to have effectively implemented this kind of initiatives There is a formalized system to detect any training needs in the environmental field: 65% of European respondents and 36% of German respondents affirmed to have effectively implemented this kind of system. 26

Figure 2110 Training activities and the involvement of employees (European and German respondents) No significant difference emerged by comparing the answers between the respondents that benefited to simplifications and those that did not benefit. Figure 11 Training activities and the involvement of employees for respondents that have or not benefited of simplifications Regarding the activities to manage environmental issues, the following initiatives were considered: 65% of European respondents and 43% of German respondents have successfully implemented specific operating instructions for the management of environmental issues; 70% of European respondents and 57% of German respondents have effectively implemented one or more procedures to detect and deal with potential emergency situations; 27

66% of European respondents and 43% of German respondents declared to fully re-examine and update emergency response procedures; Figure 23 Management of environmental issues for European and German respondents By comparing the answers between the respondents that benefited to simplifications and they that did not benefit, it seems that not beneficiaries have implemented more deeply actions to manage their environmental aspects. Figure 24 Management of environmental issues for respondents that have or not benefited of simplifications 28

Regarding the activities of measuring, monitoring and internal control, the following results emerged: Formal systems to measure the performance in order to detect the degree of achievement of the targets were successfully implemented by 70% of European respondents and by 80% of German respondents; 73% of European respondents and 53% of German respondents have effectively implemented actions to register and investigate non compliance and preventive actions. Moreover, 75% of European respondents and 80% of German respondents constantly and effectively scheduled internal audits to verify the correct implementation of instructions/procedures and the compliance with applicable legal requirements related to the environment. Figure 25 Activities for measurements, surveillance and internal control for European and German respondents By comparing the answers between the respondents that benefited to simplifications and they that did not benefit, it seems that not beneficiaries have implemented more deeply actions to monitor their environmental aspects. Figure 26 Activities for measurements, surveillance and internal control for respondents that have or not benefited of simplifications 29

To investigate how EMAS firms monitor their environmental performance, we asked how many performance indicators are used for assessing their environmental aspects. The following alternatives were provided in the questionnaire: only 1 indicator (poorly monitored); 2-3 indicators (sufficiently monitored); over 3 indicators (deeply monitored). Waste production, energy efficiency and wastewater discharge are the most monitored environmental aspect since approximately half of respondents declared to have implemented over three key performance indicators. Few European EMAS firms declared to monitor biodiversity (30% of them selected the answer not applicable ) and efficiency of materials (23% selected the answer not applicable ). For the German respondents, also air emission is deeply monitored by 62% of them while the attention on the environmental aspects biodiversity and efficiency of materials is higher than firms from other European countries. Figure 12 Environmental aspects monitored by European EMAS firms 30

Figure 28 Environmental aspects monitored by German EMAS companies 3.4 Analysis of the achieved results at the macro level This paragraph describes the role of simplification measures as incentive for the EMAS adoption and provide useful insights on how the simplification can be a tool to disseminate formal EMS. Several studies have explored the motivations of firms to adopt a certified EMS. These empirical analyses mainly focused on large multinational corporations in the United States and Europe. For instance, Strachan et al. (2003) reviewed the literature on environmental management system motivation and found that an EMS can provide numerous benefits to organizations such as third party assurance and recognition, market access, regulatory relief, improved investor confidence, and enhanced public image and community relations. Furthermore, Morrow (2002), conducted a survey on the motivations of EMAS or ISO 14001 adoption by interviewing 5 energy companies; he found that strong motivations for adopting an EMS arising from expectations of improving regulatory compliance or achieving regulatory benefits. The following figure shows, at European and German level, the distribution of answers to the question whether the regulatory simplification was one of the main motivation to adopt EMAS. It is important to underline that m any companies did not answer to this question (74% of European respondents and 60% of German respondents). Only the 3% of European respondents considers the simplifications the main motivation to implement an EMS comply with EMAS; while for the 13% of European and German respondents the simplification is one reason among others. Figure 29 Simplification as a motivation for EMAS adoption (EU and German respondents) 31

As a consequence a high number of not answers emerged also for the question on the comparison between regulatory simplification and other aspects as relevant motivation for EMAS adoption, In fact, only the 10% of European respondents and 33% of German respondents, considered the regulatory simplifications as, at least, an important motivation compared with other motivations to adopt EMAS. Figure 13 Importance of simplification compared to the other motivation of EMAS adoption (EU and German respondents) 32

3.5 Satisfaction analysis This section investigates the level of satisfaction of EMAS organization towards the existing simplification measures and which new regulatory simplification they wish to have in the legislation. The first element of analysis concerns the difficulties encountered by firms to try to take advantage from the simplification measures. The main difficulties emerging from the survey concern the clarity with which a measure is explained (77% of agreement), the level of communication of the measures (74% of respondents declared at least to agree) t and the delays in the knowledge of the measures (77% of respondents declared at least to agree). Similar results emerged by focusing just on German respondents. Figure 14 Difficulties encountered trying to take advantage of simplification (EU respondents) Figure 15 Difficulties encountered trying to take advantage of simplification (German respondents) 33

Regarding suggestions and proposals for new simplification measures, the 27% of European respondents would like to have further tax reductions and the 17% of them wish to have longer duration of environmental permits authorization. The 15% selected also renewal of the authorization by self-certification and reduction of technical reports. Among the German respondents the main suggestion concerns the reduction of technical reports (21%), further tax reductions, reduction of mandatory internal monitoring and longer duration of environmental permits (18%). Figure 25 Suggestions for new simplification measures for European and German respondents Regarding the communication tools and actions to disseminate the existence of simplification measures, there is a similarity of opinions between German respondents and those from other countries. The most preferred tools were periodic update by EMAS competent bodies, dissemination by environmental verifiers, seminaries and conferences. 34

Figure 166 Tools for disseminating knowledge on existing simplification measures (EU respondents) The last aspects investigated in the survey concern the role of stakeholders in influencing EMAS organizations to implement environmental actions and which are hindrances and difficulties encountered by firms to implement EMAS requirements. Regarding the first issue, at the European level the stakeholder categories considered as very important are public authorities (44%) and consumers (53%). The categories evaluated as not important are especially trade unions (48%), industries or trade associations (42%) and banks (40%). The German respondents, instead, gave much importance to environmental groups (36%), neighborhood groups (36%), public authorities (36%) and consumers (36%). 35

Figure 27 Stakeholders influencing the organization s choice concerning the environmental actions (EU respondents) Figure 28 Stakeholders influencing the organization s choice concerning the environmental actions (German respondents) Regarding the second aspect, the main problems encountered by organization to implement EMAS refers to comply with its requirements (42%) and the high cost of implementation (39%). Other aspects considered as moderately important are especially the personnel involving (52%) and the difficulties in attaining a steady improvement of the environmental performance (47%). The German respondents identified as main difficulties the difficulties deriving from the functioning of the EMAS scheme (45%) and high costs of implementation (45%). 36

Figure 17 Hindrances and difficulties encountered by firms implementing EMAS (European respondents) Figure 18 Hindrances and difficulties encountered by firms implementing EMAS (German respondents) 37