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Good information is fundamental to effective management and
public confidence in government agencies. For the last three
decades, however, EPA and most state environmental agencies
have relied on data about enforcement activities that do not
actually show how well the environment is doing, or how well
the regulated community is obeying environmental laws. To
the extent that these data measure enforcement or other governmental
performance, they are much more likely to be misleading than
useful.
The data on which EPA and the state agencies currently rely
-- and that Congress asked the Academy Panel to evaluate --
relate almost exclusively to activities: the numbers of permits
issued, inspections conducted, enforcement actions initiated,
and penalty dollars collected. For many years, these data
have served as the basis for management decisions and oversight
of agency performance. When EPA delegated responsibility for
implementing national environmental programs to the states
and provided them with funding to do so, it created data systems
to track these activities; and it has used activities data
to hold states accountable for proper use of federal funds
and implementation of federal laws, including timely and appropriate
enforcement.
Using these same data, EPA's Inspector General and an environmental
advocacy group have recently concluded that state enforcement
activities declined between 1993 and 1997, raising concerns
that states have de-emphasized enforcement to the detriment
of the environment. The Environmental Council of the States
(ECOS) challenged these conclusions, however, arguing that
state data in the EPA systems were often incomplete and inaccurate,
did not reflect the full range of state compliance activities,
and revealed little about whether environmental conditions
are improving.
The recent ECOS study on state enforcement and compliance
activities provides a more complete picture of state enforcement
and compliance assistance activities. At the same time, state
information reported to ECOS also demonstrates the serious
limitations of current data on enforcement activities. For
example, the data show that one industrial state with a population
of nearly 11.5 million regulates nearly 19,000 facilities,
while a state with a smaller industrial base and a population
of only 4.5 million regulates nearly five times as many facilities
-- about 87,000 (See Appendix 15). This unlikely result apparently
stems from the fact that only two media programs from the
larger state reported data to ECOS, while 12 media programs
from the smaller state reported data. Unfortunately, such
disparities are commonplace in any collection of activities
data; and they make accurate comparisons among states, as
well as assessments of program effectiveness, virtually impossible.
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