Green Tier frequently asked questions
The Green Tier law, s. 299.83, Wis. Stats., empowers leading organizations to unleash the potential of their environmental management system (EMS) to guide their business strategy towards protecting Wisconsin’s environment while growing the economy. To better understand the possibilities of continual improvement and going beyond compliance, we have provided answers to these frequently asked questions. Please select a topic area to learn more.
Green Tier's history
Green Tier was the first program of its kind in the country and serves as a model for others. It is based on recommendations from an advisory committee representing a wide array of business sectors, industry councils, municipalities and environmental organizations. It also builds on the successes of the Environmental Cooperation Pilot Program, which the DNR launched in 1998 to offer participating companies the opportunity to pursue environmental initiatives that would not have been possible under traditional regulations.
Components of "superior environmental performance" encouraged through Green Tier are based largely on the principles of the Coalition for Environmentally Responsible Economies (CERES), a nonprofit organization that leads a national coalition of investors, environmental organizations and other public interest groups working with companies to address sustainability challenges and promote continual progress toward pollution reduction, energy conservation and other environmental goals.
Governor Jim Doyle signed the original Green Tier legislation on April 16, 2004. It was set-up as a five-year pilot program with a sunset date of July 2009. In order to preserve the program and build upon successes, re-authorization legislation was proposed to accomplish the following three goals.
- Repeal sunset dates to make Green Tier a permanent program.
- Update elements of the statute to make administering the law more efficient and clear.
- Improve and expand the law's ability to improve both environmental and business results.
Due in part to great bi-partisan support, Gov. Jim Doyle signed re-authorization legislation on July 8, 2009.
In June 2012, Governor Scott Walker signed Executive Order 69 directing the DNR to undertake actions to increase Green Tier program participation.
- What is the vision?
Green Tier is a voluntary program that recognizes and rewards environmental performance "that voluntarily exceeds legal requirements related to health, safety and the environment resulting in continuous improvement in this state's environment, economy, and quality of life." (s. 299.83(1m)(b), Wis. Stats.)
Many provisions of Green Tier were tested in an Environmental Cooperation Pilot Program. Among the pilot program participant accomplishments were:
- As part of its pilot program agreement, We Energies committed to reduce its annual coal use by at least 10,000 tons and generate more than 10,000 megawatts of electricity per year by burning coal ash recovered from company-owned landfills. This is enough electricity to meet the average annual needs of more than 1,000 Wisconsin homes. We Energies activities normally would have required multiple case-by-case approvals for each landfill site and ash reuse plan. The cooperative agreement allowed the DNR to grant We Energies a blanket approval to save both parties time and labor. Wisconsin's environment benefited more quickly, and at a lower cost.
- Northern Engraving Corporation manufactures nameplates and similar items at five facilities in Wisconsin and Iowa. A cooperative agreement allowed NEC to close a costly but relatively ineffective waste incinerator at their Sparta, Wisconsin facility and focus their resources on cleanups and other meaningful methods of environmental improvement. The agreement also allowed NEC to operate new equipment prior to obtaining a permit in certain cases provided that ambient air quality standards were protected and NEC first received written approval from the DNR. NEC realized tremendous emissions reductions over the 10 years they were in the pilot program and this agreement gave them the flexibility they needed to do so. NEC is currently transitioning to Tier 2 of Green Tier.
- What is the problem?
Current law does not allow state environmental officials to differentiate between exceptional environmental performers and those performing at or near the regulatory minimum. The use of staff resources to oversee these exceptional environmental performers does not yield environmental results proportional to the investment. Failure to tap the capacity and capability of good companies to produce substantive environmental results is inefficient for the DNR and inhibits environmental improvement.
- How will the department support a company's efforts to achieve superior environmental performance?
Environmental policy programs in the past have centered on a "command and control" approach to regulation. Regulatory programs have no mechanism for recognizing regulated entities that go beyond compliance with minimum environmental requirements. Entities achieving a high level of environmental performance receive no more benefits or recognition than those that merely comply with minimum standards. In some instances, in the short term, it may be costly for entities to go beyond compliance when they are in competition with others that are expending only those resources necessary to meet minimum regulations. Green Tier is designed to help entities offset these costs. While the department doesn't directly provide funding to achieve superior environmental performance, it can indirectly increase the competitive position of companies that are exceptional environmental performers.
- How does the program work?
While entry into the program is voluntary, participation in Tier 1 is governed by a letter from the DNR to the company which lays out both responsibilities and benefits. Participation in Tier 2 is governed by a legal contract. Companies, communities and governments seeking a different level of involvement may negotiate contracts and charters that are flexible, innovative, efficient and enforceable. Self-auditing, third-party auditing, public involvement and reporting make the processes transparent and the results verifiable. For more information, read the Green Tier: An Overview of Performance-Based Environmental Management (CO-504) fact sheet.
- Is an Environmental Management System required for Green Tier?
Wisconsin's Green Tier program places great value on Environmental Management Systems. Tier 1 participants must have an ISO-14001 certified or a functionally equivalent Environmental Management System in place by the end of their first year of participation. Tier 2 participants must have a well-developed EMS (ISO certified or functionally equivalent) at the time of application with a documented history of results. (See Environmental Management Systems web page for more information.)
- How stringent are the requirements for adequate demonstration of superior environmental performance?
The Green Tier program requires "performance that results in a measurable or discernible improvement in the quality of the air, water, land, or natural resources, or in the protection of the environment, beyond that which is achieved under environmental requirements…" The precise criteria for meeting this requirement will vary according to the creative strategy submitted by the entity for recognition in Green Tier.
- Are the requirements for participation in Green Tier the same for each applicant? If not, how does the department manage the diverse approaches participants have to move beyond compliance?
While the requirements for eligibility are the same for all applicants, the specific activities to achieve superior environmental performance are established by the participant. This allows participants to move beyond compliance by committing to an environmental strategy that is sensitive to their unique strengths and opportunities.
Each participant is paired with one regulator at the DNR who gets to know the participant's particular strengths and opportunities. This departmental contact will often specialize in an area that is of particular interest or concern to the participant. They can then offer their guidance to help enhance the participant's performance in their area of expertise and other areas that impact the participant.
- Could the DNR limit participation in the Green Tier program? Is this something to be cautious of when applying? Are there some inevitable limitations participants may face?
The DNR staff in charge of Green Tier will only limit the extent of participation by an applicant if it is necessary to protect the integrity of the program. This may be necessary due to the substandard quality of an application or lack of department staff and/or resources available to process applications. The department may also delay admission to the program and wait for an applicant to demonstrate environmental performance that is judged to be superior. While DNR has delayed the admission of applicants, it has not limited participation because of resource constraints.
- What are the costs of applying to the program? How can the proposed incentives offset the costs of participation? Are there other benefits that may offset the costs besides the proposed incentives?
There are no fees for applying to or participating in Green Tier, however, there will be indirect costs that are associated with the development and implementation of an Environmental Management System. These costs would be borne by any company choosing to implement an EMS. Environmental management systems are an integral requirement component of participation in Green Tier, and there is a cost in designing, implementing and auditing an EMS. Other costs include time and resources spent on the initial application and ongoing audits. Successful participants will often offset these costs with the increased efficiency that comes from both the direct incentives proposed by the program and the increased organization and effective investment that can occur as the result of participation.
- How informed is the public about Green Tier? How much of an impact will participation have on public perceptions?
Green Tier is still gaining significant public recognition. Those who visit the department's website have access to information about the program and each applicant submits a list of stakeholders who might be interested in knowing more about Green Tier. These stakeholders are contacted directly by the DNR. As more entities participate in Green Tier, more of these notices will be sent to newspapers around the state, so the potential for positive public perception increases as more participants enter the program. These news releases along with the program logo will stimulate public interest and discussion and create business value for Green Tier participants.
- What are the advantages of the Green Tier logo? It seems as if this could really enhance brand image.
The logo is meant to stimulate interest in the program and create an easily recognizable symbol that ties the participant's name to the goals and values of an innovative and credible environmental excellence program. As Green Tier achieves greater recognition among members of the public, this logo will prompt recognition of superior environmental performance and enhance the quality of participants' images.
- How might participants benefit from sharing information with those who have an interest in their actions, performance and involvement in Green Tier? What kinds of negative consequences might this have for participants?
Participants in Green Tier are required to inform stakeholders about their progress toward superior environmental performance. This information sharing recognizes participants for their Green Tier actions while building trust with stakeholders and can earn them recognition and distinction among their competitors. Providing public notice of participants' involvement and performance in Green Tier might entice competitors to follow similar paths. This may increase the number of entities that demonstrate superior environmental performance, but some participants may not want to share this information with their competitors. Moreover, Green Tier's requirement for public involvement may expose negative aspects about participants to community stakeholders, regulators and environmental groups. While some may view the transparency of Green Tier as a potential threat to businesses, there are ways for participants to fulfill the requirement and involve the public without surrendering their competitive edge.
Although Green Tier participants must share relevant information with stakeholders, they are not required to share all information that may be relevant to competitors. The department does require an annual report from participants including a summary of their accomplishments, information on generic indicators, audit findings and reports on the success of the environmental management system. Participants are not required to submit a copy of the actual EMS. Aside from the contents of the annual report, they may submit any other information with a request that the information is held confidential because of trade secrets.
- How will participants be recognized on the department website? Is this recognition obvious to visitors? Who will be looking at this?
Green Tier participants will be listed on the DNR website's Green Tier page along with links to public notices, press releases and photos. The webpage provides these entities with a showcase for their superior environmental performance and innovative thinking. Potential viewers of this information include regular visitors to the DNR website, those seeking more information about Green Tier, and those looking for information about the participants.
- What's in it for businesses?
While most companies have achieved consistent compliance with regulatory requirements, the current business environment provides the opportunity for companies to engage in behaviors that would constitute a superior environmental performance. Green Tier would save time, reduce costs, encourage innovation, contain liability and adapt to market demands. For more information, read The Business Case for Green Tier (CO-506) fact sheet.
- What's in it for the environment?
Each company in the program commits to specific and measurable environmental improvements and reports regularly on their progress. Actions may result in reduced pollution, energy conservation and the implementation of sustainability strategies. For more information, read The Environmental Case for Green Tier: Moving from Compliance to Performance (CO-505) fact sheet.
- What's in it for the community?
The community will benefit from a cleaner environment, more communication between public and private entities and increased community involvement.
- What's in it for taxpayers?
Green Tier reduces bureaucracy and allows regulators to focus on the most pressing environmental concerns, like businesses with sub-standard environmental records.
- What is the department's relationship with the public? How does their input affect Green Tier?
One of Green Tier's most important goals is transparency. Community stakeholders' access to all pertinent information regarding Green Tier participation is crucial to the success of the program. This transparency is necessary both to encourage trust between the DNR and participants and to allay public suspicions about the interests behind Green Tier negotiations.
Public support is vital to the successful Green Tier applicant. Each application is subject to public scrutiny before it is accepted. Public comment periods are held to allow the community to respond to these applications. The department also communicates with the public on its website and through annual notices to newspapers regarding entities' participation in the program.
- How does participation in the program affect relationships with the Department?
Once a formal environmental management system is implemented, Tier 1 participants will experience the lowest allowable level of inspection frequency from the DNR. Participation in the Green Tier Program will also subject entities to deferred civil enforcement. The single point of contact will also help increase communication and trust between the entity and the department. This individual will help remove obstacles to smooth, timely processing of participants' paperwork and provide them with valuable information about how to work effectively with regulators. In addition to these benefits, Tier 2 participants are eligible for regulatory incentives. These benefits are negotiated by the participant and the department, which ensures that the incentives granted are proportional to the environmental benefits provided by the participant.
- What is Tier 1?
Participating at the Tier 1 level is all about commitment and credibility. It is designed for those who want to improve their performance by using an Environmental Management System (EMS). By operating under an EMS, participants are not only able to drive their environmental efforts but also document their commitment to and success with managing their environmental footprint. Perhaps the most important aspect of Tier 1 participation, is the credibility gained through the required external audits which ensure that the EMS is functioning properly and allow you to communicate successes with confidence. The DNR is committed to supporting Tier 1 participants with various incentives that are not available to other companies.
- What are the benefits of participating in Tier 1 of Green Tier?
As a Tier 1 participant you will receive:
- A DNR-hosted webpage, where your achievements are shared. This includes a brief summary of your organization, a place where others can read about your commitments as well as your environmental goals and achievements.
- Matching with a DNR Single Point of Contact (SPOC) who will help you work more efficiently with the department and provide expertise to help you improve your environmental footprint;
- Use of the Green Tier logo to demonstrate your environmental commitments in your marketing efforts;
- Liability protection in the form of deferred civil enforcement when self-reporting and self-correcting any violations that may occur; and
- The lowest allowable inspection frequency provided by law.
The benefits do not stop there, when you manage your impact with an EMS you can identify areas in your business that are important, have significant environmental impacts or cost money. This allows you to:
- Improve profits by creating efficiencies in the identified areas to bring value and reduce costs to the business;
- Minimize risks by knowing your environmental impacts and the regulations that apply for each of them;
- Achieve long-term goals through incremental progress, a characteristic of management systems that can help you to move the needle on long-term goals and projects;
- Position your business for the future. Setting and achieving future-facing environmental goals through your EMS signals that you have a plan to be successful in the future through continued innovation; and
- Investing in these identified innovations can benefit your business and the environment. Allowing you to be more nimble than your competition as you continue to incrementally evolve.
- What are the participation criteria for Tier 1?
To be considered for Tier 1 participation, applicants must have a:
- Clear Compliance Record: Tier 1 applicants must have a strong environmental compliance record without any convictions or criminal violations from the Wisconsin Department of Justice. The clear environmental record applies not only to the facility but also to any managing operator of the applicant or any person with a 25% or more ownership interest in the applicant; for the following timeframes:
- Within five years prior to the application date have no judgments of conviction made for criminal violations where the facility and its actions caused substantial harm to or presented a significant threat to public health or the environment.
- Within three years prior to the date of application, there were no civil judgments against it for actions that resulted in harm to public health or the environment.
- Within two years prior to the date of application, the facility was not issued a citation from the DNR or had a suit filed against them by the Department of Justice to enforce an environmental requirement.
- Functioning EMS: Commitment to have a formal and functioning environmental management system implemented by the end of the first full year in the program.
- Perform Audits: Green Tier participants need to audit their EMS every year. Tier 1 participants must, at a minimum, have their EMS audited by a DNR approved outside environmental auditor every three years. Who are approved auditors? See the Green Tier Approved Auditors webpage for more information.
- Perform Corrective Actions: Prompt follow-up action to any findings of non-compliance or non-conformance discovered during the annual audits.
- Submit Reporting: Annual reports must be submitted to the DNR that includes a description of continual improvement and superior environmental performance, progress on environmental goals, supporting environmental metrics, an effective plan for the future and evidence of an effective environmental management system.
See the Green Tier Annual Report Instructions webpage for more information.
- Clear Compliance Record: Tier 1 applicants must have a strong environmental compliance record without any convictions or criminal violations from the Wisconsin Department of Justice. The clear environmental record applies not only to the facility but also to any managing operator of the applicant or any person with a 25% or more ownership interest in the applicant; for the following timeframes:
- What is Tier 2?
Tier 2 is designed for companies with an effective Environmental Management System and a history of superior environmental performance. Tier 2 participants represent the truly exceptional companies that are not only committed to going above and beyond but are also committed to bringing about change in their industry, region or within their supply chain.
Tier 2 participants negotiate customized environmental contracts with the DNR. Interested stakeholders, including the public, are invited to help negotiate the contacts. These flexible agreements generally identify areas of current environmental regulations that the company wishes to modify and contains new requirements that require the company to commit to superior environmental performance. Tier 2 contracts may be the most innovative and valuable part of Green Tier, as they support both government efficiency and business competitiveness.
- What are the participation criteria for Tier 2?
- A strong environmental compliance record, with no recent civil or criminal judgments or DNR citations. Participation in Tier 2 requires a stronger environmental compliance record than Tier 1. (See the application instructions for more information.)
- A formal EMS that has been in place and has documented results.
- Annual compliance audits are performed by the participant or an external auditor.
- Annual audits of the EMS for Tier 2 are performed every year by an external, certified auditor.
- Prompt follow-up action to any findings of non-compliance or non-conformance discovered during the annual audits.
- Annual report to the DNR that includes performance reviews and audit results. (See the Green Tier Annual Reports for more information.)
- Continual improvement of environmental performance.
- What are the benefits to participants of Tier 2 over Tier 1? Is the public aware of the differences?
Tier 2 participants negotiate contracts with DNR staff stating their specific strategy for achieving superior environmental performance, their commitment to implement that strategy and the incentives they expect to receive from the department. These incentives may be more valuable than those offered only in Tier 1 because they can directly reduce costs associated with regulation and improve participants' positions relative to their competitors. These contracts also foster greater efficiency in the department by reducing the time and resources spent on regulation.
Participants in Tier 2 are also recognized for satisfying more rigorous eligibility requirements than those in Tier 1 with a stronger environmental compliance record and an EMS already in place at the time of application. The DNR promotes awareness of the distinctions between Tiers 1 and 2 through public hearings, news releases and information recorded on the department website regarding program participants.
- What is a participation contract?
A participation contract is a legal agreement entered into by the DNR and a Tier 2 participant that specifies:
- The participant's legal commitment to superior environmental performance; and
- Incentives to be provided to the participant (may include regulatory flexibility, public recognition, branding, etc.).
- How will the DNR ensure that the incentives to participants are proportional to their benefits to the environment? How is this proportionality determined?
The applicant, DNR staff and interested stakeholders will negotiate the incentives. DNR Green Tier administrators will also weigh the value of the proposed benefits to the environment against the magnitude of the incentives requested. There will also be a 30-day comment period for the public to provide feedback on the proposed contract. A Tier 2 contract that describes substantial environmental benefits will be approved unless the department determines that:
- the environmental benefits proposed are not sufficient to justify granting the incentives.
- the incentives granted would result in adverse environmental change way before the environmental benefits would be realized.
- the speculative nature of the environmental benefits provides insufficient justification for issuing immediate and tangible incentives.
- the declaration of proportionality is not in the best interest of the program. This reaction will occur if public reactions to the proposal indicate that determining proportionality would erode public confidence in the program.
- Why is the participant responsible for explaining how its proposed measures for improvement are proportional to the incentives it expects to receive?
Green Tier is not a program that tells entities what to do. Part of participating in Tier 2 of the program is developing contracts that indicate a commitment to improving environmental performance while diminishing the need for regulation. While the DNR determines eligibility and negotiates the terms of these contracts, the commitments necessary to receive the incentives are actually specified by the participant. In this way, the program encourages creative thinking about ways to increase business value while achieving better environmental results.
Tier 2 participants submit a letter of intent to the DNR stating how they propose to achieve superior environmental performance and the incentives they expect in return. If the department determines that the applicant is eligible for Tier 2, then, following an initial public comment period, they will begin negotiating the terms of the contract with the participant. This could take up to a year or longer depending on the department's assessment of how proportional the participant's proposed environmental benefits are to its requested incentives.
- What is a Green Tier charter?
A charter is a contract that provides opportunities and a framework for any combination of public and private entities, businesses, supply chains, industry sectors and other groups to work collaboratively to further shared environmental goals. The charter contract is the legal structure to implement commitments negotiated between the department and charter signatories. A charter may even allow flexibilities which would not be an option under traditional approaches. Membership in a charter also provides a method for interacting with the DNR to aid in achieving superior environmental performance outcomes or to participate in Green Tier 1 or Tier 2.
- Who would benefit from charter participation?
Charters are a great platform for those that are committed to achieving or making progress on a shared environmental goal. Members often are neighbors linked to a location, businesses in a sector or entities that share an environmental concern. Membership can also provide an excellent opportunity for those that have environmental expertise to mentor or demonstrate leadership by collaborating with those that want to improve their own environmental footprint.
- What are the benefits?
Green Tier charters help provide benefits to members and Wisconsin’s natural resources through collaboration, sharing of knowledge and leveraging resources. Potential outcomes can include:
- Providing feedback on ways to streamline regulations on a mutual environmental concern;
- Facilitating training of members to help maintain and build from compliance;
- Improving the overall group’s environmental footprint; and
- Supporting the continual improvement of environmental impacts by focusing on common goals and collaboratively working towards them.
Members of charters that also participate in Tier 1 or Tier 2 receive the incentives of being a Green Tier participant as well as any additional incentives that are negotiated in the charter.
- What do charter members commit to?
Charter members commit to meeting the requirements of their charter by:
- Developing achievement goals that lead to superior environmental performance
- Establishing member responsibilities and methods to accomplish shared goals
- Carrying out activities to reach their goals
- Submitting an annual report to the DNR on the group's progress towards achieving the goals established in the charter agreement.
- What are the costs to participate?
There are no fees for creating or participating in a Green Tier charter; however, there may be indirect costs that are associated with the development and implementation of the charter's goals. Other costs which could be incurred include time and resources spent on drafting the charter with the DNR, annual reporting and meeting ongoing charter requirements, including auditing if required by the charter. Successful charter members will often offset these costs with savings found from completing environmental projects, receiving positive public and stakeholder feedback and promoting their environmental improvement efforts with current and potential customers.
The actual business value offered by a Green Tier charter, measured in simple economic terms, will vary according to each organization and their innovation.
- What is the due date for our annual report?
Each Green Tier participant has an individualized due date for their annual report, there is not one single due date for all participants. These dates are tailored to each company’s reporting year and reporting schedule — the DNR wants these to be at a convenient time for the participant. You can find your due date in your Green Tier commitment outline or by asking your single point of contact (SPOC) or project coordinator. Your commitment outline can be found on your company’s Green Tier webpage by clicking on “Acceptance Letter”. The due date can be found in section IV-Annual Reporting of that document. You can also find the names of both your SPOC and project coordinator in this section.
- These new instructions are requiring elements that weren’t previously required. Will existing Green Tier participants be grandfathered to using the previous instructions?
No, we are asking all participants to use the new annual report instructions. These new instructions were created to help participants provide the best information to show continual improvement in their environmental efforts. You can contact your single point of contact (SPOC) with any questions or concerns while working on your report.
- If our company produces a corporate sustainability report (CSR), can we submit this as our annual report?
We would prefer that you provide a separate annual report for Green Tier. However, your CSR may be accepted if all of the Green Tier requirements are easily found, including the Environmental Metrics spreadsheet from Appendix 1 and your EMS audit results from Appendix 2. Please discuss with your SPOC or Project Coordinator.
- Executive Summary
- Do we need to list all of our significant environmental aspects and impacts or just the ones we have goals for?
We would like to see all of your significant environmental aspects and impacts. You can note the ones you have goals for and will discuss in the upcoming sections. For those significant aspects, you do not have goals for, a narrative on why you are not or the risks of not addressing these items would be valuable.
- Our environmental policy is available on our website, can I include a link to the document?
Yes, you can provide a link to your environmental policy. You could also include a copy or an image of your policy.
- What information are you looking for under “Sustainability Vision”?
- We are looking for answers to the following questions:
- What will it look like for your company to be sustainable?
- What do you need to get there?
- How much progress have you made?
- What are the big problems you have to solve?
- Environmental Performance
- Why are you requesting information since we joined Green Tier, isn’t this an annual report?
In this section we are looking for a summary of your past environmental performance, since you joined Green Tier, to give readers a summary of your efforts leading up to this year. This is also helpful to those participants that had large capital expenditures on past improvement projects like adding solar arrays or updating to more efficient equipment that may have slowed what they could accomplish in this reporting year.
- What is meant by “performance improvements that have reduced the level of regulations”?
We are looking for areas where environmental improvements have allowed you to reduce your permit levels or even to a point where you are no longer regulated. An example would be a company that used a hazardous waste material in production causing them to follow regulations as a small quantity generator (SQG), through their work in their supply chain they were able to find an alternative, non-hazardous material that provided the same quality product. They are no longer generating hazardous waste; therefore certain regulations no longer apply.
- Progress on Goals and Objectives
- Do we have to tie each goal to a Superior Environmental Performance outcome?
Superior environmental performance is broad enough that most environmental goals can help accomplish at least one of the nine outcomes, but as long as you make the connection to at least one outcome, your report can be accepted.
- We have long-term goals with five-year or longer target dates for completion. On one of our goals we have yet to implement the changes to move the needle toward improvement, should we drop this goal from our report?
No, you should keep the goal on the report and show what steps or actions you have taken so far to achieve this goal. Activities for the current fiscal reporting year can be strategic (long-term planning), tactical (short-term actions) or operational (actions put into use). This may include reviewing current equipment use, gathering data, building a business case for capital to purchase a new piece of equipment, or explaining the business plan to meet this target on time.
- We’ve experienced a management change since the beginning of the year and our company focus and environmental goals have been changed. How should we report on our goals?
Explain the changes that occurred and note the new objectives or goals that you are tasked with. Then explain the progress you have made on these new goals since they were in place.
- Metrics Narrative (more under Environmental Metrics)
- I’ve already explained the metrics tied to my environmental objectives under “Progress on Goals & Objectives” do I have to repeat that information here?
No, this section is to explain the metrics we are asking participants to supply in Appendix 1. These metrics may be broader than what you are tracking for your goals.
- Why should I provide data on items I do not have objectives against?
The information supplied in Appendix 1 will help the DNR tell the story of Green Tier by providing data to show the collective improvements on environmental impacts by participants in Green Tier. If you track these metrics, you may also find unintended improvements in different aspects of your business due to the implementation of your goals or other projects.
- Additional Accomplishments
- Our company was recognized as an industry “Best Place to Work” last year, does this qualify as the type of additional accomplishment you are looking for?
This is an opportunity to share your achievements with the public. The DNR is mostly interested in your other environmental accomplishments or achievements, but any accomplishment or certification that sets you apart from your industry peers is acceptable. The "Best Place to Work" recognition speaks to the culture of your company and how your employees feel about the goals and future of the company.
- Stakeholder Relationships
- I thought the law only required Tier 2 companies to have interactions with interested parties. Do I have to report anything if I am in Tier 1?
Both Tier 1 and Tier 2 companies should interact with interested parties and other stakeholders. Both ISO 14001 and Green Tier Functionally Equivalent EMS’s require training of employees (stakeholders). Also, under 299.83 (3)(d)(3), Tier 1 facilities are to explain how discussions with community members near their facility influenced their choice of objectives in their EMS.
- We did a supply chain survey and ranking as one of our environmental objectives. Do we have to describe it again here?
Giving a short summary of your survey work in this section would be appropriate. You could reference that more information is available under the "Progress on Goals & Objectives" section.
- Future Goals
- We’ve already set and achieved goals for all of our environmental impacts. How do we continue to set new goals?
If you truly have tackled all your environmental impacts, then setting goals to maintain current levels is possible. Be sure that you have looked at all areas; could you review your suppliers and find more environmentally-friendly inputs?
- Our EMS is very mature, and we feel like we have completed every upgrade at our facility. Where can we go next?
Green Tier law includes the idea of facility or activity that is performed. Are there activities or processes that extend beyond your facility? Can you use a life-cycle approach to determine goals and objectives that go beyond your fence line?
- We want to work on environmental objectives, but our facility doesn’t have much for environmental impacts. How can we continue to demonstrate a commitment to the environment?
Superior Environmental Performance references voluntarily restoring or preserving natural resources. You could look at some opportunities that exist near you. Are there local natural areas that could use your support? Are there any impacts that could be improved further to set you apart from others in the industry?
- Our company has a strong commitment to addressing risks associated with climate change. Is this something we can use to set our future goals?
Yes, these can be included in your goals. We encourage participants to look at ways they can address environmental issues; locally, regionally and beyond.
- Environmental Metrics
- Do I have to fill out the metrics that do not match our current goals, that we do not track or that we decline to answer?
Yes, we would like you to fill them out. Most of the metrics requested are easily accessible for participants to track.
- I use normalized data for all of my reporting, can I supply this information on the metrics sheet?
We are asking for raw data on the metrics sheets. This will allow Green Tier to better aggregate the data from all our participants. Since participants use different normalizing units it would be more difficult to combine the data. Please feel free to use normalized data to explain your metrics sheet in the narrative above.
- My raw data numbers do not reflect the actual story of continual improvement and efficiencies my company has achieved. The total kWh has increased year on year, but when normalized it shows we use less per unit of production.
As previously noted, Green Tier is using the raw data to show the collective results of all our participants. Please use the “Metrics Narrative” to explain these numbers. You can say it was an overall increase due to a production increase, but we found efficiencies in the usage per unit. You can explain with the actual numbers or percentages. We will use these explanations to help tell the full Green Tier story for each metric item.
- I do not want to provide purchasing information, the amounts we spend are proprietary.
We are looking for the percent (%) of your purchases that come from the three categories, not the actual dollar amounts.
- Local Purchases: used to analyze if supply chain proximity is aiding in reduced transportation emissions
- In-State Purchases: used to show economic contributions to WI
- Green Tier Purchase: used to show interactions and support of other Green Tier participants
- EMS Audit Information
- Our company has an ISO 14001:2015 EMS and certificate. Can we just attach our certificate instead of doing an audit report?
GT law 3(d)(4) & 5(c)(2) states participants must provide a report on the EMS audit. Your ISO 14001 certificate does not give us the summary of your audit.
- Our auditor will not give us the final report or letter of conformance for our functionally equivalent EMS audit, they want us to complete the corrective actions first. Why are they doing this?
Green Tier auditors are instructed to hold the letter of conformance of the EMS until they deem all nonconformities are sufficiently addressed and/or corrected. A non-functioning EMS is considered a violation of Green Tier law and must be resolved in 90 days or an agreed timeframe.
Tier 1 facilities with a non-functioning functionally equivalent EMS are not permitted to wait for their next external audit to prove their EMS is now functioning. It will need to be corrected in a timely manner and approved by your EMS auditor.
- My EMS auditor is not approved by the DNR, but they have been our auditor for several years, can they be grandfathered in, or do I have to switch auditors?
You should request that your auditor contacts Green Tier to complete the necessary steps to become approved. Information on becoming a Green Tier auditor can be found on the auditor page of the Green Tier website.
- We have a corporate contract with an ISO registrar and do not always get the same auditor, how can we be sure to have a DNR-approved auditor?
This will be discussed on a case-by-case basis, please contact your Project Coordinator for more information.
- Compliance Reporting
- My company had a violation found by an inspector, but we corrected it right away. Do we have to report this?
Yes, we are asking all participants to be transparent about their environmental performance over the reporting period. You should note there was a violation and give the time period it was corrected in
- Is it appropriate to request Deferred Civil Enforcement in the annual report?
No, to be eligible for deferred civil enforcement, you must report any violations to Green Tier immediately. You should use this section to summarize the outcomes of any deferred civil enforcement that has occurred over the past year.
- My company is in Tier 1, do I need to explain the results of our Compliance Audit?
No, Tier 2 participants are required to provide information about their compliance audit. We do encourage Tier 1 participants to explain the audit but documenting when it occurred is sufficient.
The complexity of environmental challenges facing Wisconsin demands that we move beyond the current compliance model.
Said one Green Tier advocate