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Volume 27, Issue 12 — December 1997


The Tiered Approach to Corrective Action Objectives and the Site Remediation Program in Illinois

by James P. O'Brien

Editors' Summary: In mid-1997, the Illinois Pollution Control Board promulgated two rules that will affect the way contaminated sites are cleaned up in the state: the Tiered Approach to Corrective Action Objectives (TACO) rule and the Illinois Site Remediation Program (voluntary cleanup program) rule. This Article describes the TACO and voluntary cleanup program rules and the changes they make. The Article first gives some background on how cleanups were formerly conducted in Illinois. Next, the Article discusses the TACO rule and its corresponding "tiers" of cleanup objectives, including its approach to remediating contaminated groundwater. The Article then discusses the voluntary cleanup program rule, and concludes with an assessment of the new rules' impact.


Reinventing Environmental Permitting: Drafting the Permit

by James M. Thunder

This Dialogue proposes to give permittees a new option in environmental permitting. The option will compress the permitting cycle while simultaneously generating better public support and better environmental protection. To some people, the option will seem radical. It should seem less so after reviewing the breadth and depth of the current initiatives in reinventing environmental permitting.

The ISO 14001 Environmental Management Systems Standard: A Modest Perspective

by Christopher L. Bell

Since the final publication in late 1996 of the International Organization for Standardization's (ISO's) environmental management systems (EMSs) standard, ISO 14001, the cacophony of claims and counterclaims about the standard has grown louder. The commentary is wide-ranging, with some of the more noteworthy claims being that ISO 14001:

. is a "green passport" signifying environmental excellence;

. is a plot by industry to undercut more deserving international environmental initiatives;

. is a plot by consultants to make money off of industry;

. is a plot by governments and nongovernmental organizations (NGOs) to push a "green agenda";

. is a basis for eliminating environmental regulations;

. is irrelevant to compliance assurance;

. is useless as a tool for improving environmental performance;

. does not represent the "leading edge" of thinking in the EMS area;

. represents a completely "new paradigm" for thinking about environmental issues;

. is too complicated and expensive for implementation by small and medium-sized enterprises;

. will be used as a nontariff trade barrier; and

. will facilitate trade.

But the range of opinion on ISO 14001 provides public and private organizations with little useful advice on fundamental questions such as why, whether, where, when, and how to implement ISO 14001, and what decisions about ISO 14001 might mean for purposes of environmental protection, public policy, and trade.