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Thirty years' reliance on enforcement activity data to gauge
environmental progress has been misplaced, according to a
congressionally commissioned study by the National Academy
of Public Administration.
"It makes no sense to use the currently available enforcement
data to grade the states on their environmental progress or
to decide which environmental problems should get priority
attention," said former Illinois Governor Jim Edgar,
Chair of the Academy's panel of Fellows and other experts
who conducted the study. "The data weaknesses are too
great, whether you look at numbers from U.S. EPA or from the
individual states."
Critics have accused some states of backing off on environmental
enforcement in recent years, citing data that track state
enforcement activities. Last year, Congress asked the Academy
to evaluate the situation and make recommendations. In response,
the Academy has recently released Evaluating Environmental
Progress: How EPA and the States Can Improve the Quality of
Enforcement and Compliance Information.
Both EPA and the states need to invest in better monitoring
so they can collect information on actual environmental conditions
and compliance with environmental laws, the Academy's panel
found. Current enforcement data are not adequate to track
performance because they usually count activities -- such
as permits, inspections, and cases filed -- rather than measuring
results on the ground.
Also, what counts as "enforcement" varies enormously
from state to state, the study concluded, making it impossible
for EPA or the public to draw meaningful comparisons among
states.
"EPA and the states should be working to collect better
data on environmental results," said Susan Moore of Georgia-Pacific
Corp., a member of the Academy's panel. "Everyone has
the same interest in having an accurate picture of environmental
conditions."
"What's at stake is whether the public is getting real
environmental protection for its money, or not," said
panel member David Roe of Environmental Defense. "Without
timely, reliable data, agencies can't target the most important
problems, or know when problems are getting worse or better.
And the public can't hold government accountable."
The Academy's principal recommendations are:
- EPA and the state environmental
agencies should stop relying primarily on activities data
to evaluate the effectiveness of environmental protection
programs, including compliance assistance and enforcement
initiatives.
- EPA and the states should give
immediate and sustained priority to implementing multi-media
data systems for performance measurement and management
that are focused on actual outcomes, both in environmental
conditions and legal compliance.
- EPA and the states should make
information on environmental conditions central to their
short-term and long-term decisions on regulating and protecting
the environment.
- EPA's information systems that
monitor and collect state and national data should be modernized
and integrated across all media so they can gather more
accurate, timely, and comparable data on environmental conditions
and activities.
- EPA and the states should expand
public access to information about environmental conditions
in neighborhoods, communities and, more generally, across
the country.
- EPA and the states should direct
more attention to analyzing these data so they can identify
changes in environmental impacts and conditions, opportunities
for environmental gains, causes of environmental problems,
and methods for evaluating past agency actions.
In addition to Governor
Jim Edgar, who chaired the panel and is a Fellow of the Academy,
the panel for this study included Richard Wegman of Garvey,
Schubert, & Barer (also a Fellow), Shelley Metzenbaum
of the John F. Kennedy School of Government and the University
of Maryland, Susan Moore of Georgia Pacific, and David Roe
of Environmental Defense.
To obtain a copy of Evaluating Environmental Progress,
please contact Bill Shields at (202) 347-3190, est. 3014..
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