United States
Environmental Protection
Agency
Science Advisory
Board
(A-101)
SAB-EC-90-021
September 1990
&EPA
Reducing Risk:
Setting Priorities And
Strategies For
Environmental Protection
Do not weed. This document
should be retained in the EPA
Region 5 Library Collection.
7l> Printed on Recycled Paper
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Science Advisory Board, a public advisory group providing
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baJancedexpertassess
problems facing the Agency; hence the contents of this report
do not necessarily represent the views and policies of the "'
"
This particular project was conducted at the request of the
EPA Administrator and addresses a broader range of issues
• of a policy orientation than is usually the case.
Cover Photo by Steve Delaney
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REDUCING RISK:
SETTING PRIORITIES
AND STRATEGIES FOR
ENVIRONMENTAL
PROTECTION
The Report of The Science Advisory Board:
Relative Risk Reduction Strategies Committee
to
William K. Reilly
Administrator
United States Environmental Protection Agency
September 1990
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Science Advisory Board
U.S. Environmental Protection Agency
Washington, DC 20460
September 25, 1990
Mr. William K. Reilly
Administrator
U.S. Environmental Protection Agency
Washington, DC 20640
Dear Mr. Reilly:
Over a year and a half ago, you asked the Science Advisory Board to review EPA's
1987 report, Unfinished Business: A Comparative Assessment of Environmental Prob-
lems, and then assess and compare different environmental risks in light of the most
recent scientific data. You also asked us to examine strategies for reducing major risks
and to recommend improved methodologies for assessing and comparing risks and
risk reduction options in the future. This report and its three appendices have been
prepared in response to your request.
To undertake this project, the Science Advisory Board created a special Relative
Risk Reduction Strategies Committee composed of 39 distinguished scientists and
other experts from academia, state government, industry, and public interest groups.
The Committee carefully considered the reports written by each of its three Sub-
committees, and the findings and recommendations contained in Reducing Risk flow
from the work of the Subcommittees and reflect study, discussion, and synthesis by the
Committee as a whole. This report has been reviewed by the SAB Executive Com-
mittee and has been formally approved as an SAB document.
As you are aware, the Science Advisory Board normally reviews scientific reports for
the Agency and evaluates them on the basis of scientific and engineering data.
However, in this case our review of Unfinished Business and our analysis of risk
reduction options have led us to make findings and recommendations that are more
policy-oriented than is usually the case. We have done this at your request.
This report, together with its three append ices, suggests steps that the Environmental
Protection Agency should take to improve its own efforts — and to involve Congress
and the rest of the country in a collective effort — to reduce environmental risk. We
strongly believe that the Agency should take steps to ensure that this nation uses all the
tools at its disposal in an integrated, targeted approach to protecting human health,
welfare, and the ecosystem.
This report is only a step along a long road. We encourage you to lead the Agency in
taking the necessary further steps as soon as possible.
Sincerely,
Raymond Loehr
Chair, Science Advisory Jonathan Lash
Board, and Co-Chair, Relative Co-Chair, Relative Risk
Risk Reduction Strategies Reduction Strategies Committee
Committee
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Contents
Members of the Relative Risk Reduction
Strategies Committee iv
Chapter One: Executive Summary 1
The Concept of Risk 1
The Traditional Role of the Environmental
Protection Agency 3
Unfinished Business 4
The Relative Risk Reduction Strategies Committee.. 5
The Ten Recommendations 6
Chapter Two: Findings 7
1. The Importance of Unfinished Business 7
2. Problems in Ranking Risks 8
3. The Extraordinary Value of Natural Ecosystems.. 9
4. Time, Space, and Risk 10
5. The Links Between Risk and Choice 11
6. Public Perceptions of Risk 12
7. Relatively High-Risk Environmental Problems ... 13
8. Strategy Options for Reducing
Environmental Risk 15
Chapter Three: The Ten Recommendations 16
Recommendation 1 16
Recommendation 2 17
Recommendation 3 18
Recommendation 4 19
Recommendation 5 20
Recommendation 6 21
Recommendation 7 22
Recommendation 8 23
Recommendation 9 24
Recommendation 10 25
in
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U.S. Environmental Protection Agency
Science Advisory Board
401 M Street, S.W.
Washington, DC 20460
Relative Risk Reduction Strategies
Committee
Steering Committee
Co-Chairmen
Dr. Raymond Loehr
Professor of Civil Engineering
University of Texas
Austin, TX
Dr. Jonathan Lash
Secretary of Natural Resources
for the State of Vermont
Waterbury, VT
Members
Mr. Alvin Aim
Vice President
Science Applications International
Corporation
McLean, VA
Dr. Betsy Ancker-Johnson
Vice President of the
Environmental Activities Staff
General Motors Corporation
Warren, MI
Mr. Richard Conway
Senior Corporate Fellow
Union Carbide Corporation
South Charleston, WV
Dr. William Cooper
Chairman of the Zoology Department
Michigan State University
East Lansing, MI
Dr. Anthony Cortese
Dean of Environmental Programs
Tufts University
Medford, MA
Dr. Paul Deisler
Visiting Executive Professor
University of Houston
Houston, TX
Mr. Fred Hansen
Director of the Department of Environmental
Quality for the State of Oregon
Portland, OR
Dr. Morton Lippmann
Professor of Environmental Medicine
New York University
Tuxedo, NY
Dr. Roger McClellan
President
The Chemical Industry Institute
of Toxicology
Research Triangle Park, NC
*Dr. Norton Nelson
Director Emeritus of the Institute of
Environmental Medicine
New York University
New York, NY
Dr. Arthur Upton
Director of the Institute of
Environmental Medicine
New York University
New York, NY
Designated Federal Official
Dr. Donald Barnes
Staff Director, Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
Project Staff Coordinator
Mr. Frederick Allen
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington, D. C.
Editors
Mr. Tom Super
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington, D. C.
Mr. Steve Young
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington, D. C.
Support Staff
Ms. Joanna Foellmer
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
*Deceased
Ecology and Welfare
Subcommittee
Chairman
Dr. William Cooper
Chairman of the Zoology Department
Michigan State University
East Lansing, MI
Members
Dr. Yorum Cohen
Associate Professor of Chemical Engineering
University of California
at Los Angeles
Los Angeles, CA
Dr. Steve Eisenreich
Professor of Environmental Engineering
University of Minnesota
Minneapolis, MN
Dr. Mark Harwell
Director of Global Environmental Programs
Cornell University
Ithaca, NY
Dr. Dean Haynes
Professor of Entomology
Michigan State University
East Lansing, MI
Dr. Robert Huggett
Director of the Virginia Institute
of Marine Studies
College of William and Mary
Seaford, VA
Dr. Ronald Olsen
Professor of Microbiology and Associate
Vice President for Research
University of Michigan Medical School
Ann Arbor, MI
Dr. Dave Reichle
Associate Director of Biomedical
and Environmental Sciences
Oak Ridge National Laboratory
Oak Ridge, TN
Dr. June Lindstedt-Siva
Manager of Environmental Science
Atlantic Richfield Company
Los Angeles, CA
IV
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Designated Federal Official
Mr. Robert Flaak
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
Strategic Options Subcommittee
Chairman
Mr. Alvin Aim
Vice President
Science Applications
International Corporation
McLean, VA
Members
Dr. Betsy Ancker-Johnson
Vice President of Environmental
Activities Staff
General Motors Corp.
Warren, MI
Dr. Richard Andrews
Professor of Environmental Studies
University of North Carolina
Chapel Hill, NC
Mr. Richard Conway
Senior Corporate Fellow
Union Carbide Corporation
South Charleston, WV
Dr. Anthony Cortese
Dean of Environmental Programs
Tufts University
Medford, MA
Dr. Roger Kasperson
Professor of Geography
Clark University
Worchester, MA
Dr. Henry Kelly
Senior Associate
Office of Technology Assessment
U.S. Congress
Washington, D.C.
Dr. Paul R. Portney
Vice President
Resources for the Future
Washington, D.C.
Mr. William Ryan
Policy Director
National Environmental Law Center
Boston, MS
Ms. Nancy Seidman
Executive Director
Northeast States for Coordinated
Air Use Management
Boston, MA
Dr. Robert Stavins
Assistant Professor of Public Policy
John F. Kennedy School of Government
Harvard University
Cambridge, MA
Ms. Marcia Williams
Divisional Vice President
Environmental Policy and Planning
Browning-Ferris Industries
Washington, D.C.
Designated Federal Officials
Dr. C. Richard Cothern and
Mrs. Kathleen Conway
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
Support Staff
Ms. Darlene Sewell
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
Human Health Subcommittee
Chairman
Dr. Arthur Upton
Director of the Institute of
Environmental Medicine
New York University
New York, NY
Members
Dr. Julian B. Andelman
Professor of Water Chemistry
University of Pittsburgh
Pittsburgh, PA
Dr. Patricia Buffler
Director of Epidemiological Research Unit
University of Texas
Houston, TX
Dr. Paul Deisler
Visiting Executive Professor
University of Houston
Houston, Texas
Dr. Howard Hu
Assistant Professor of
Occupational Medicine
Brigham & Women's Hospital
Harvard University Medical Center
Boston, MA
Dr. Nancy Kim
Director of the Division of
Environmental Health Assessment
New York Department of Health
Albany, NY
Dr. Morton Lippmann
Professor of Environmental Medicine
New York University
Tuxedo, NY
Dr. Roger McClellan
President
The Chemical Industry Institute
of Toxicology
Research Triangle Park, NC
Dr. Arno Motulsky
Professor of Medicine and Genetics
University of Washington School of Medicine
Seattle, WA
Dr. Frederica Perera
Associate Professor of Public Health
Columbia University
New York, NY
Dr. Jonathan Samet
Professor of Medicine
University of New Mexico
Albuquerque, NM
Dr. Ellen Silbergeld
Senior Scientist
Environmental Defense Fund
Washington, D.C.
Dr. Bernard Weiss
Professor of Toxicology
University of Rochester Medical Center
Rochester, NY
Dr. Hanspeter Witschi
Associate Director of the Toxics Program
University of California
Davis, CA
Designated Federal Official
Mr. Samuel Rondberg
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C.
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Chapter One—Executive Summary
The Concept of Risk
Over the past 20 years this country has put in place
extensive and detailed government policies to control
a number of environmental problems. Smog in
heavily populated areas, the eutrophication of lakes,
elevated levels of lead in the blood of millions of
children, the threat of cancer from exposure to
pesticide residues in food, and abandoned drums of
hazardous wastes are a few of the problems that
have driven the enactment of more than a dozen
major Federal laws and the current public and
private expenditure of about $100 billion a year to
protect the environment.
Those efforts have led to very real national
benefits. The staggering human health and ecological
problems apparent throughout eastern Europe
suggest the price this country would be paying now
had it not invested heavily in pollution controls.
Yet despite the demonstrable success of past
national efforts to protect the environment, many
national environmental goals still have not been
attained. Factors like the growth in automobile use
and common agricultural practices have caused
national efforts to protect the environment to be less
effective than intended.
Furthermore, with hindsight it is clear that in
many cases those efforts have been inconsistent,
uncoordinated, and thus less effective than they
could have been. The fragmentary nature of U.S.
environmental policy has been evident in three ways:
• In Laws. As different environmental problems were
identified, usually because the adverse effects —
smog in major cities, lack of aquatic life in stream
segments, declining numbers of bald eagles — were
readily apparent, new laws were passed to address
each new problem. However, the tactics and goals of
the different laws were neither consistent nor
coordinated, even if the pollutants to be controlled
were the same. Many laws not passed primarily for
environmental purposes also had major effects on
the environment.
• In Programs. The Environmental Protection Agency
(EPA) was established as the primary Federal agency
responsible for implementing the nation's
environmental laws. EPA then evolved an
administrative structure wherein each program was
primarily responsible for implementing specific laws.
Consequently, the efforts of the different programs
rarely were coordinated, even if they were
attempting to control different aspects of the same
environmental problem. This problem is
compounded by the fact that EPA is not the only
agency whose activities affect the environment.
• In Tools. The primary tools used to protect the
environment have been controls designed to capture
pollutants before they escape from smokestacks,
tailpipes, or sewer outfalls, and technologies
designed to clean up or destroy pollutants after they
have been discharged into the environment. These
so-called "end-of-pipe" controls and remediation
technologies almost always have been applied
because of Federal, State, or local legal requirements.
For a number of reasons, this kind of fragmented
approach to protecting the environment will not be
as successful in the future as it has been in the past.
In this country the most obvious controls already
have been applied to the most obvious problems. Yet
complex and less obvious environmental problems
remain, and the aggregate cost of controlling those
problems one-by-one is rising.
Moreover, this country — and the rest of the
world — are facing emerging environmental
problems of unprecedented scope. Population
growth and industrial expansion worldwide are
straining global ecosystems. Never before in history
have human activities threatened to change
atmospheric chemistry to such an extent that global
climate patterns were altered.
Given the diversity, complexity, and scope of the
environmental problems of concern today, it is
critically important that U.S. environmental policy
evolves in several fundamental ways. Essentially,
national policy affecting the environment must
become more integrated and more focused on
opportunities for environmental improvement than it
has been in the past.
The environment is an interrelated whole, and
society's environmental protection efforts should be
integrated as well. Integration in this case means that
government agencies should assess the range of
environmental problems of concern and then target
protective efforts at the problems that seem to be the
most serious. It means that society should use all the
tools — regulatory and non-regulatory alike — that
are available to protect the environment. It means
that controlling the end of the pipe where pollutants
enter the environment, or remediating problems
caused by pollutants after they have entered the
environment, is not sufficient. Rather,
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waste-generating activities have to be modified to
minimize the waste or to prevent the waste from
being generated at all. Most of all, integration is
critically important because significant sources of
environmental degradation are embedded in typical
day-to-day personal and professional activities, the
cumulative effects of which can become serious
problems. Thus protecting the environment
effectively in the future will require a more broadly
conceived strategic approach, one that involves the
cooperative efforts or all segments of society.
One tool that can help foster the evolution of an
integrated and targeted national environmental
policy is the concept of environmental risk.Each
environmental problem poses some possibility of
harm to human health, the ecology, the economic
system, or the quality of human life. That is, each
problem poses some environmental risk. Risk
assessment is the process by which the form,
dimension, and characteristics of that risk are
estimated, and risk management is the process by
which the risk is reduced.
The concept of environmental risk, together with
its related terminology and analytical methodologies,
helps people discuss disparate environmental
problems with a common language. It allows many
environmental problems to be measured and
compared in common terms, and it allows different
risk reduction options to be evaluated from a
common basis. Thus the concept of environmental
risk can help the nation develop environmental
policies in a consistent and systematic way.
Scientists have made some progress in developing
quantitative measures for use in comparing different
risks to human health. Given sufficient data, such
comparisons are now possible within limits.
Although current ability to assess and quantify
ecological risks is not as well developed, an increased
capacity for comparing different kinds of risks more
systematically would help determine which problems
are most serious and deserving of the most urgent
attention. That capacity would be even more valuable
as the number and seriousness of environmental
problems competing for attention and resources
increase.
An improved ability to compare risks in common
terms would have another value as well: it would
help society choose more wisely among the range of
policy options available for reducing risks. There are
a number of ways to reduce the automobile
emissions that contribute to urban smog; there are a
number of ways to decrease human exposure to lead.
The evaluation of relative risks can help identify the
relative efficiency and effectiveness of different risk
reduction options.
There are heavy costs involved if society fails to set
environmental priorities based on risk. If finite
resources are expended on lower-priority problems at
the expense of higher-priority risks, then society will
face needlessly high risks. If priorities are established
based on the greatest opportunities to reduce risk,
total risk will be reduced in a more efficient way,
lessening threats to both public health and local and
global ecosystems.
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The Traditional Role
of the Environmental
Protection Agency
For the past 20 years, EPA has been basically a
"reactive" agency. As environmental problems were
identified, the public conveyed its concern to
Congress, and Congress passed laws to try to solve
the problems within some, often well-defined,
timeframe. EPA then implemented the laws using
the resources — budget and staff — allocated by
Congress.
Consequently, EPA has seen its mission largely as
managing the reduction of pollution and, in
particular, only that pollution that is defined in the
laws that it administers. EPA's internal programmatic
structure mirrors the environmental legislation that it
is required to implement. Moreover, the tools EPA
traditionally has used to reduce pollution have been
limited, in general, to the emissions controls it could
force polluters to apply through regulatory action.
This reactive mode, although understandable when
seen in its historical context, has limited the
efficiency and effectiveness of EPA's environmental
protection efforts. Because of EPA's tendency to react
to environmental problems defined in specific
environmental laws, the Agency has made little
effort to compare the relative seriousness of different
problems. Moreover, the Agency has made very little
effort to anticipate environmental problems or to take
preemptive actions that reduce the likelihood of an
environmental problem occurring.
Because most of EPA's program offices have been
responsible for implementing specific laws, they have
tended to view environmental problems separately;
each program office has been concerned primarily
with those problems that it has been mandated to
remediate, and questions of relative seriousness or
urgency generally have remained unasked.
Consequently, at EPA there has been little correlation
between the relative resources dedicated to different
environmental problems and the relative risks posed
by those problems.
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Unfinished Business
The Environmental Protection Agency squarely faced
the question of relative risk for the first time when it
established an Agency task force to assess and
compare the risks associated with a range of
environmental problems. In 1986 and 1987, about 75
senior career managers and staff compared the
relative risks posed by 31 environmental problems
within four broad categories of risk: 1) human cancer
risk, 2) human non-cancer health risk, 3) ecological
risk, and 4) welfare risk. The task force limited its
comparison to those risks that remain after
currently-required controls have been applied (i.e.,
residual risks). The results of this effort were
presented in Unfinished Business: A Comparative
Assessment of Environmental Problems.
Unfinished Business was a landmark study. For the
first time, the many environmental problems of
concern to EPA were compared to each other in a
non-programmatic context. Moreover, the report
explicitly pointed out the disparity between residual
risk and resource allocation at EPA. The problems
that the authors judged to pose the most serious
risks were not necessarily the problems that
Congress and EPA had targeted for the most
aggressive action.
However, the report did find a correlation between
EPA's programmatic priorities and the apparent
public perceptions of risk. That is, Congress and the
Agency were paying the most attention to
environmental problems that the general public
believed posed the greatest risks.
The authors of Unfinished Business recognized that
their risk rankings, while based on the judgments of
experienced professionals, were limited, since they
were based on incomplete data and novel risk
comparison techniques. But the value of the report,
then and now, rests not so much on the accuracy of
the rankings but on the fact that EPA had begun to
see the long-term public policy importance of
understanding relative risks. In short, Unfinished
Business was yet another sign that the nation as a
whole, and EPA in particular, could not continue
"business-as-usual" in the face of the environmental
risks of the 1990s and beyond.
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The Relative Risk
Reduction Strategies
Committee
Shortly after he took office early in 1989, EPA
Administrator William K. Reilly asked the Science
Advisory Board (SAB) to review EPA's 1987 report
on relative environmental risk, Unfinished Business,
evaluate its findings, and develop strategic options
for reducing risk. In response to that request, the
SAB formed a special committee, the Relative Risk
Reduction Strategies Committee (RRRSC), which in
turn was divided into three Subcommittees: the
Ecology and Welfare Subcommittee, the Human
Health Subcommittee, and the Strategic Options
Subcommittee.
The Relative Risk Reduction Strategies Committee
was co-chaired by Dr. Raymond C. Loehr, chairman
of the SAB and professor at the University of Texas,
and Mr. Jonathan Lash, Secretary of the State of
Vermont's Agency of Natural Resources. The Ecology
and Welfare Subcommittee was chaired by Dr.
William Cooper of Michigan State University; the
Human Health Subcommittee was chaired by Dr.
Arthur Upton of the Institute of Environmental
Medicine, New York University Medical Center; and
the Strategic Options Subcommittee was chaired by
Mr. Alvin Aim of Science Applications International
Corporation.
The 39 members of the RRRSC and its
Subcommittees were nationally-recognized scientists,
engineers, and managers with broad experience in
addressing environmental and health issues. Their
names and professional affiliations are listed at the
front of this overview report.
Through its combined efforts the RRRSC attempted
to achieve four objectives:
1. Critically review Unfinished Business, reflecting any
significant new information that bears on the
evaluation of risks associated with specific
environmental problems.
2. To the extent possible, merge the evaluations of 1)
cancer and non-cancer risks and 2) ecological and
welfare risks.
3. Provide optional strategies for reducing the major
environmental risks.
4. Develop a long-term strategy for improving the
methodology for assessing and ranking
environmental risks and for assessing the alternative
strategies that can reduce risks.
In particular, the Ecology and Welfare
Subcommittee and the Human Health Subcommittee
were charged with reviewing and updating the risk
findings from Unfinished Business. Those two
Subcommittees were to provide, to the extent
possible, a single aggregate ranking of the risks that
each Subcommittee assessed, and recommend a
long-term strategy for improving the methodology
for assessing such risks. The Strategic Options
Subcommittee was charged with 1) identifying
strategy options for reducing residual environmental
risks, and 2) developing and demonstrating analytical
methodologies for identifying and selecting risk
reduction options.
The RRRSC began planning its work in the spring
of 1989, and it held its first meeting in September
1989. In all, the Committee and its three
Subcommittees held twelve public meetings and
three working sessions.
The RRRSC has conducted a lengthy review of the
data and methodologies that support risk
assessment, comparison, and reduction today. This
review of environmental risk has led to several
conclusions about the need for and value of
comparative risk assessments and their implications
for the national environmental agenda.
This overview report highlights the most important
findings and recommendations from the three
Subcommittee reports, along with insights derived
from discussions among the Committee members
after they reviewed the Subcommittee reports. The
full reports of the three Subcommittees are included
as appendices to this report (see inside back cover)
and should be referred to for important additional
information and detailed support for the contents of
this overview report.
The RRRSC recognizes that this overview report
and its appendices contain policy-oriented findings
and recommendations that are outside the normal
scope of SAB purview. But in this case the EPA
Administrator explicitly asked the SAB to review,
from a technical and scientific perspective, the
optional strategies available for reducing risk. Thus
this report includes recommendations on approaches
to risk management and on the future direction of
national environmental policy. However, nothing in
this report or its appendices should be construed as
an SAB recommendation for a specific policy option
to be used to reduce a specific environmental risk.
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The Ten
Recommendations
1. EPA should target its environmental protection
efforts on the basis of opportunities for the greatest
risk reduction. Since this country already has taken
the most obvious actions to address the most obvious
environmental problems, EPA needs to set priorities
for future actions so the Agency takes advantage of
the best opportunities for reducing the most serious
remaining risks.
2. EPA should attach as much importance to
reducing ecological risk as it does to reducing
human health risk. Because productive natural
ecosystems are essential to human health and to
sustainable, long-term economic growth, and because
they are intrinsically valuable in their own right, EPA
should be as concerned about protecting ecosystems
as it is about protecting human health.
3. EPA should improve the data and analytical
methodologies that support the assessment,
comparison, and reduction of different
environmental risks. Although setting priorities for
national environmental protection efforts always will
involve subjective judgments and uncertainty, EPA
should work continually to improve the scientifc data
and analytical methodologies that underpin those
judgments and help reduce their uncertainty.
4. EPA should reflect risk-based priorities in its
strategic planning processes. The Agency's
long-range plans should be driven not so much by
past risk reduction efforts or by existing
programmatic structures, but by ongoing
assessments of remaining environmental risks, the
explicit comparison of those risks, and the analysis of
opportunities available for reducing risks.
5. EPA should reflect risk-based priorities in its
budget process. Although EPA's budget priorities are
determined to a large extent by the different
environmental laws that the Agency implements, it
should use whatever discretion it has to focus budget
resources at those environmental problems that pose
the most serious risks.
6. EPA — and the nation as a whole — should make
greater use of all the tools available to reduce risk.
Although the nation has had substantial success in
reducing environmental risks through the use of
government-mandated end-of-pipe controls, the
extent and complexity of future risks will necessitate
the use of a much broader array of tools, including
market incentives and information.
7. EPA should emphasize pollution prevention as
the preferred option for reducing risk. By
encouraging actions that prevent pollution from
being generated in the first place, EPA will help
reduce the costs, intermedia transfers of pollution,
and residual risks so often associated with
end-of-pipe controls.
8. EPA should increase its efforts to integrate
environmental considerations into broader aspects of
public policy in as fundamental a manner as are
economic concerns. Other Federal agencies often
affect the quality of the environment, e.g., through
the implementation of tax, energy, agricultural, and
international policy, and EPA should work to ensure
that environmental considerations are integrated,
where appropriate, into the policy deliberations of
such agencies.
9. EPA should work to improve public
understanding of environmental risks and train a
professional workforce to help reduce them. The
improved environmental literacy of the general
public, together with an expanded and better-trained
technical workforce, will be essential to the nation's
success at reducing environmental risks in the future.
10. EPA should develop improved analytical
methods to value natural resources and to account
for long-term environmental effects in its economit
analyses. Because traditional methods of economic
analysis tend to undervalue ecological resources and
fail to treat adequately questions of intergenerational
equity, EPA should develop and implement
innovative approaches to economic analysis that will
address these shortcomings.
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Chapter Two—Findings
1. The Importance of
Unfinished Business
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With the publication of Unfinished Business early in
1987, EPA took a bold and much-needed step: it
compared the relative residual risks posed by a range
of different environmental problems, and thus
suggested an important shift in national
environmental policy. With that report EPA took the
first step toward relative risk reduction; that is, a
policy that attempts to match Agency and societal
resources to risk.
To produce Unfinished Business EPA brought
together staff from all its program offices for the
explicit purpose of comparing the relative risks of
different environmental problems, regardless of
individual programmatic priorities or responsibilities.
To do that, the EPA staff had to assess
environmental risk in a context broader than
programmatic structure or legislated activities. In
short, they had to put aside considerations of
bureaucratic "turf" in order to rank the problems
they believed most needed society's attention. EPA
should be applauded for the courage and foresight to
undertake a project like Unfinished Business.
Unfinished Business presents useful, preliminary
information for comparing environmental problems,
although in some cases its rankings are a matter of
judgment and cannot be supported fully by existing
data. The Ecology and Welfare Subcommittee
questioned the welfare rankings, because it disagreed
with some of the economic assumptions underlying
those rankings and because of a general lack of
relevant economic data. The Human Health
Subcommittee questioned the accuracy of any
ranking of human health risks at this time, given the
limited human exposure and chronic toxicity data
currently available. Both Subcommittees observed
that the 31 problems assessed were not derived from
a systematic classification of all environmental
problems, and both suggested alternative and more
comprehensive approaches to classification that
would facilitate a more coherent ranking.
Most of the 31 environmental problems assessed in
Unfinished Business are so broad, and include so many
toxic and non-toxic agents, that its ranking of
problems cannot be evaluated with rigor or
confidence. Additionally, the authors of Unfinished
Business intentionally defined environmental
problems to correspond to legislation and
programmatic organization. As a result, they
attempted to compare heterogenous mixtures of
pollutants (like air pollutants and drinking water
pollutants) to pollutant sources (like oil spills and
mining waste) to receptors (like consumers and
workers). Yet without a consistent basis for
comparison, such comparisons are tenuous at best.
Moreover, because the authors chose to limit the
environmental problems they compared, Unfinished
Business does not address problems like the loss of
habitat and the decline in genetic diversity, even
though such problems pose very serious risks, and
EPA and other agencies may be able to take actions
to mitigate them. A meaningful ranking of relative
environmental risks must include all such risks,
whether or not laws have been passed or programs
set up to control them.
A final shortcoming for the authors of Unfinished
Business was the availability of data. Good data to
evaluate risks simply did not — and in many cases
still do not — exist. The EPA staff understandably
used their professional judgment to fill the data
gaps. The Subcommittee reports appended to this
overview report document in more detail the
members' judgments as to the relative strength and
weakness of the data used to support the risk
rankings in Unfinished Business.
The findings and recommendations described in this overview report have been derived mainly from the reports prepared
by the tturee Subcommittees of the Relative Risk Reduction Strategies Committee, those reports, which are included as
appendices to this report, contain detailed information that support and more fully explain the findings and
recomrfttniiitfons. Such information can be found by referring to the sections of the different appendices that are listed at
the be|$roBig of each finding and recommendation. In the listed cros&referencesj
• "W to the Report of the Ecology and Welfare Subcommittee;
• TH" refers to the Report of the Human Health Subcommittee; and,
* "S" refers to the Report of the Strategic Options Subcommittee.
-------
2. Problems in
Ranking Risks
As long as there are large gaps in key data sets,
B-3.% E*SL2 efforts to evaluate risk on a consistent, rigorous basis
H«3«0; H-&Q or to define optimum risk reduction strategies
necessarily will be incomplete, and the results will be
uncertain. For example, data on human exposure
and on the toxicity of many pollutants are seriously
deficient. In particular, the lack of pertinent exposure
data makes it extremely difficult to assess human
health risks.
Moreover, great uncertainty often is associated
with the data that do exist. Exposure and toxic
response models, the numbers used to quantify
risks, and variations in individual susceptibility to
risks are often highly uncertain. Without more and
better data, conclusions about relative risk will be
tenuous and will depend in large measure on
professional judgment.
In addition to the lack of data, methodological
inadequacies also impede the assessment and
comparison of risk. At this time EPA does not have
an effective, consistent way of identifying
environmental problems in a manner that neither
fragments nor aggregates sources of risk to an extent
that renders comparisons untenable. EPA's current
framework of statutory mandates and program
structure helps to maintain artificial distinctions
among environmental problems, and those
distinctions are conducive neither to sound
evaluation of relative risk nor to selection of the most
effective actions to reduce risk.
In particular, the methodologies currently used to
estimate the benefits of risk reduction activities are
inadequate and inappropriate. For example, a
methodology that presumes the future value of an
ecological resource necessarily must be less than its
present value will not be a useful analytical tool for
sustaining economic development over the long
term. The standard practice of discounting future
resource values is inappropriate, and it results in
policies that lead to the depletion of irreplaceable
natural resources.
Reliance on "willingness to pay" and similar
techniques commonly used in economic analyses has
distorted current understanding of the value of
natural resources. While some people may not care
about wetlands and assign no value to their
existence, such areas still provide valuable ecosystem
services to this and future generations. While few
people are likely to care about and be willing to pay
for plankton and fungi, such organisms play a critical
role in sustaining economically valuable ecosystems.
An additional difficulty entailed in any attempt to
compare and rank environmental risks is the
inevitable value judgments that must be made. For
example, are health risks posed to the aged more or
less serious than health risks posed to infants? Are
risks of cancer more or less serious than threats to
reproductive processes? Comparing the risks posed
to human populations with the risks posed to
ecosystems may be even more difficult. It seems clear
that subjective values always will — and should —
influence the ranking of relative environmental risks,
no matter how sophisticated the technical and
analytical tools become.
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3. The Extraordinary
Value of Natural
Ecosystems
Natural ecosystems like forests, wetlands, and
E-5.2 oceans are extraordinarily valuable. Those
ecosystems contain economically valuable natural
resources that feed, clothe, and house the human
race. They act as sinks that, to a certain extent,
absorb and neutralize the pollutants generated by
human activity. Although natural ecosystems — and
the linkages among them — are not completely
understood, there is no doubt that over time the
quality of human life declines as the quality of
natural ecosystems declines.
The value of natural ecosystems is not limited to
their immediate utility to humans. They have an
intrinsic, moral value that must be measured in its
own terms and protected for its own sake.
However, over the past 20 years and especially
over the past decade, EPA has paid too little
attention to natural ecosystems. The Agency has
considered the protection of public health to be its
primary mission, and it has been less concerned
about risks posed to ecosystems. The Agency's
relative lack of concern reflects society's views as
expressed in environmental legislation; ecological
degradation probably is seen as a less serious
problem because it is often subtle, long-term, and
cumulative. But for whatever reason, this imbalance
is a manifest, if inadvertent, part of current national
environmental policy.
EPA's response to human health risks as compared
to ecological risks is inappropriate, because, in the
real world, there is little distinction between the two.
Over the long term, ecological degradation either
directly or indirectly degrades human health and the
economy. For example, as the extent and quality of
saltwater estuaries decline, both human health and
local economies can suffer. As soils erode, forests,
farmlands, and waterways can become less
productive. And while the loss of species may not be
noticed immediately, over time the decline in genetic
diversity has implications for the future health of the
human race.
In short, human health and welfare ultimately rely
upon the life support systems and natural resources
provided by healthy ecosystems. Moreover, human
beings are part of an interconnected and
interdependent global ecosystem, and past
experience has shown that change in one part of the
system often affects other parts in unexpected ways.
National efforts to evaluate relative environmental
risks should recognize the vital links between human
life and natural ecosystems. Up to this point, they
have not.
-------
4. Time, Space,
and Risk
While the data needed to support firm rankings of
B"4Ji| -&¥•& risk were found to be limited, the RRRSC identified a
$"i>»2 number of important factors that must be considered
in any assessment or ranking of the risk associated
with a particular environmental problem. Those
factors include the number of people and other
organisms exposed to the risk, the likelihood of the
environmental problem actually occurring among
those exposed, and the severity of the effects,
including the economic losses and other damages
involved, if it does occur.
In addition, two other aspects of potential
environmental problems — i.e., their temporal and
spatial dimensions — also must be given
considerable weight in any analysis of relative
environmental risk. Consideration of time and space
can help guide judgments about relative risks in the
absence of complete data.
The temporal dimension of an environmental
problem is the length of time over which the
problem is caused, recognized, and mitigated. For
some environmental problems the temporal
dimension can be very long. For example, the
chronic human health effects of air or water pollution
may become apparent only after many years of
exposure. It may take decades of human activity to
begin to change the global climate, and more decades
may pass before the effects of human activity on the
global climate are clearly understood. Some
pollutants can persist in the environment — and thus
pose environmental risks — indefinitely. And it may
take decades or even centuries before depleted
species of wildlife recover from the loss of habitat, if
recovery is possible at all.
The spatial dimension of an environmental
problem is the extent of the geographical area that is
affected by it. Some environmental problems, like
elevated levels of radon, may be limited to the
basements of some homes, while problems like
stratospheric ozone depletion can affect the entire
globe. And some global problems, like the loss of
genetic diversity, can be caused by human activities
in relatively limited geographical areas.
The time and space dimensions of environmental
problems should weigh heavily in any comparison of
relative environmental risks. For example, if
long-lived pollutants like DDT and PCBs can become
concentrated in the food chain and pose a threat to
future as well as present human and ecological
health, those future risks should be taken into
account when relative risks are compared. Similarly,
if global climate change or stratospheric ozone
depletion has the potential to affect the health and/or
economic well-being of virtually everyone on earth,
now and in the future, the extent and duration of the
risk should suggest a relatively high-risk ranking.
Ecosystems are generally resilient to short-term
insults. For example, oil spills and water pollution
usually cause only temporary ecological changes;
nature has a substantial capacity for healing itself.
However, some changes are either permanent or
semipermanent. Destroying wetlands, altering
natural water flows (as in the Everglades), global
warming, and stratospheric ozone depletion can
cause irreversible and, in some cases, widespread
problems.
In fact, some long-term and widespread
environmental problems should be considered
relatively high-risk even if the data on which the risk
assessment is based are somewhat incomplete and
uncertain. Some risks are potentially so serious, and
the time for recovery so long, that risk reduction
actions should be viewed as a kind of insurance
premium and initiated in the face of incomplete and
uncertain data. The risks entailed in postponing
action can be greater than the risks entailed in taking
inefficient or unnecessary action. Moreover,
preemptive actions are especially justifiable if — like
the energy conservation efforts that would slow the
accumulation of greenhouse gases — they lead to
unrelated but immediate and substantial benefits,
such as improved ambient air quality and reduced
U.S. dependence on imported oil.
10
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5. The Links Between
Risk and Choice
It is sometimes tempting to think simplistically about
tne sources of environmental risk as being a
particular industry, a particular product, or a
particular pollutant. Conceptually, smokestacks can
be controlled, products modified, and pollutants
banned with relative ease.
But the sources of environmental risk are much
more diverse and complicated than that. In fact, the
sources of risk often are to be found in the
day-to-day choices made by individuals,
communities, and businesses. And many kinds of
environmental risk will not be reduced substantially,
especially over the long term, if past patterns of
individual, community, and business choices do not
change in light of the relative risks posed by those
choices.
In a sense, the very existence of the human race
inevitably poses some level of environmental risk.
People necessarily generate wastes, both as
individuals and through aggregate economic
activities. People necessarily destroy or infringe upon
some natural habitats when they construct their own.
Individuals either increase or lessen environmental
risk depending on which consumer products they
buy, how they design their homes, and whether they
walk or drive to work. Society affects environmental
risk at the local level through building codes and
zoning laws and at the national level through tax,
energy, and agricultural policies.
But all these activities involve choice, and the
environmental risks posed by many human activities
can be reduced sharply if different choices are made.
So one of the most important questions facing society
is how to influence and shape individual,
community, and business choices so that
environmental risks are reduced.
Choice is influenced by a number of factors,
including education and ethics. Some people may
choose to purchase certain consumer products
because of a genuine concern about the
environmental effects of their personal buying
patterns. Similarly, some businesses may redesign
production processes to eliminate pollution because
of a desire to be perceived as corporate "good
citizens."
Economic incentives are also important tools for
inducing particular kinds of choices. When the price
of energy rises, consumers are likely to buy more
fuel-efficient vehicles and weatherize their homes,
while plant managers have an added incentive to
purchase more energy-efficient equipment. Full
pricing of municipal services can give people an
incentive to recycle their household wastes and
conserve water.
Laws and regulations, of course, are very effective
at shaping individual and social choices. Local
zoning laws can change the pattern of economic
development in a community and limit where homes
can be built. Local, State, and Federal procurement
regulations can have a substantial effect on the
development of markets for recycled products.
Projected future growth in population and
economic activity could add enormously to the
environmental risks faced in this country and around
the world. But growth and reductions in
environmental risk are not necessarily incompatible,
if past patterns of individual, community, and
business choice can change. In national efforts to
assess, compare, and control relative risks, the
importance of those choices — and the policy options
available to influence those choices — should not be
overlooked.
11
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6. Public Perceptions
of Risk
Public opinion polls taken over the past several years
S-1,4 confirm that people are more worried about
environmental problems now than they were 20
years ago when the first wave of environmental
concern led to major changes in national policy. But
the areas of greatest concern to the public today are
not necessarily those problems identified in
Unfinished Business. In other words, the remaining
and emerging environmental risks considered most
serious by the general public today are different from
those considered most serious by the technical
professionals charged with reducing environmental
risk.
This dichotomy between public perceptions and
professional understanding of environmental risk
presents an enormous challenge to a pluralistic,
democratic country. A Federal agency like EPA must
be sensitive to public concerns about environmental
problems. In fact, since public concerns tend to drive
national legislation, Federal environmental laws are
more reflective of public perceptions of risk than of
scientific understanding of risk. Consequently, EPA's
budget and staff resources tend to be directed at
those environmental problems perceived to be most
serious by the general public.
Yet if national resources are to be used most
effectively to promote environmental quality, then
such resources must be aimed at those
environmental problems that pose the greatest risks.
The ability to match resources to risks will measure
the success of national policies to protect the
environment.
One obvious way to bridge this dichotomy would
be to improve the public's understanding of the
scientific and technical aspects of environmental risk
while improving scientists' understanding of the
basis of public concern. Public perceptions of
environmental risk tend to incorporate deeply-held
subjective values, like justice and equity, that,
although difficult to quantify, reflect important
elements of the quality of life that government is
bound to protect. Moreover, since the scientific
understanding of any environmental problem is
likely to evolve as the science improves, and since
environmental policy necessarily embodies subjective
values, scientific understanding should not be the
sole determinant of environmental policy.
Therefore, EPA must be prepared to listen
carefully to the public's perceptions of risk.
Moreover, EPA should balance those perceptions
with current scientific understanding as the Agency
develops long-term risk reduction strategies.
12
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7. Relatively High-Risk
Environmental Problems
i-4.0; B-6.0;
H»7.0
The RRRSC not only reviewed the risk rankings
contained in Unfinished Business, but it also identified
several environmental problems as relatively
high-risk, based on available scientific data and
technical understanding. This effort was challenging
for a number of reasons. Ecological, health, and
welfare risks can be manifested in a number of
different endpoints; it is difficult to compare risks
with widely different time scales and spatial
dimensions; because of data gaps and methodological
inadequacies, it is rarely feasible to quantify total
risk. In other words, the RRRSC faced many of the
same hurdles that faced the authors of Unfinished
Business when they developed their risk rankings.
Consequently, the RRRSC did not rank risks in the
same manner as Unfinished Business did. The Ecology
and Welfare Subcommittee grouped environmental
problems into high-, medium-, and low-risk areas;
the Human Health Subcommittee identified
environmental problem areas where existing data
indicated that risks could be relatively high.
Additional data might identify additional high-risk
problems. Both Subcommittees developed their
assessments in light of the latest scientific and
technical knowledge and using their best professional
judgment, and both caution that their assessments
are based on incomplete and often inadequate
knowledge about 1) the extent of human and
ecological exposures to pollutants and 2)
exposure-response relationships.
Risks To Hit-Natural Ecology And Human Weliare
The Ecology and Welfare SuboMnmittee identifies! areas
of relatively Mfh, medium, and low risk, despite gaps
in the relevant gjjafr* 'fae four environmental problems
that it cpnsiiejjei to be isiativdf high-risk am likely to
foe considered Mgh-rtsk even after data and analytical
methodologiei ate improved, because the geographic
scale of all font is vtejr'large (regional to global), and
becaute the MBSC Uttt could be required to mitigate all
four is very long, tnd some are iweveimfe
the Beologf Wltfare Subcommittee did not limit
tfteir assessment t» {ftp envjeonaaenta! problems listed
in Unfinished Hie order of problems listed
within each of the fwte different risk groups shown
below is not meant fo imply a ranking.
Relatively !%*•*»ft Problems
* Habitat Aitef wtw»s iftd Destruction
Humans are and destroying natural
habitats in pwiy woAhw,de> e.g., by the
draining and degradation of wetlands, soil
erosion, and Ae deforestation of tropical and
temperate »in forests,
* Species Extinction and Overall Loss of Biological
Diversity
Many human activities are causing; species
extinction iiwi depletion and the overall loss of
biological divinity, including the genetic diversity
of sufviviKg species.
« Stratospheric GsKone Depletion
Because of chloroflttorocarbons and other
ozorte-^ieptetiRg are thinning the earth's
stratospJieiie wops lay«r,. more ultraviolet
radiation is teaching the earth's surface, thus
stressing many lands of organisms.
* Global CMmate Change
Emissions of carbon dioxide, methane, and other
greenhouse gases are altering the chemistry of the
atmosphere, tht%*teni«g to change the global climate.
Relatively Medium-Risk Problems
* HerWeMps/Pestieides
• Toxics, Nutrients, Biochemical Oxygen Demand, and
Turbidity in Surface Waters
» Acid Deposition
* Airborne Toxics
Relatively Low-Risk Problems
• Oil
* Groundwater Pollution
• Radiortucldes •
» Acid Runoff to Surface Waters
* Thermal Pollution
-------
human 1
firmly by the
wete for. oiler health probleaw.
' that the development of .
ni«se complete data could
lead to a different approach to the assessment of human
an approach would involve
iK «nt«roffttental toxicants that
and Major risk reduction
; seujrees eonit a range of
J» which populations
~. i^.exp4ieft:^p«;li«|t.t^-''- --^ *-—*-
__,_,,, p^.r.,.,. —,-, -r— - —_„,_,- Others, such as
by a variety of
inhalation, inhalation of
tfgsl^ lpi;;teg«ttOB of dtist deposited
om ,§• others att .iisposrtant
tp compounds such as
• antf s«CH^f«lc •
• 'hjii^iidWis'iBt foBtE to At atmosphere over
s .aiseas'of'North America.
to CheinkaJs in Industry and
exposures can cancer and a
(
df
of -
• •
• fGlutton;
Ittfl^i%^fltop|«ritf »ay fee exposed to and
its MI''weil as to, Bnany airtwrte ,
coabwittan litclod|»g dioxide
and en*4»rtTi(iWtet'jiotacco smote. Indooi
exposures to toxic agents in consumer products
(e.g», $dM&&, ^stiddes, fonawldehydl:} also can
caw* caaeer a: raftge of nom»«^icet health
el^rts. Due !io' A® largt- popufafiBii ;dinterty
' exposed,to"-ft, wtpHi^ar *f ei uroch are
. wJatively high
porting Water
w ctelwerfed at the tap^ may
contain agents such a* lead, chiofofonoa, and
'
a»d tgrtailtip al worifcers are exposed to
> -party ios^i.fttta^noes ift tite worlcplaee, Such
• sach poliitam,ts intinkinfcwAte1 can cause cancer
and a' run§et of nonn^cerjhfiaith effects. This
piro'blWR'pesf s felsti^ely high human health risks,
. beetpse Jtigt- popaitlfcwjs are exposed dfcecfly to
Carious some of which ate hi#% to»c,
Other prtbleni aisas also involve potentially
significant expotiue ol large populations to toxic
dwnieaJs; *;g .„ pesttejde residues on tood and toxic
chemicals in consumer products. However, the data
"bases t» support concerns are not as robust as
they are for the feur areas Isted above,
14
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8. Strategy Options for
Reducing Environmental Risk
In addition to reviewing the findings of Unfinished
S-44 Business, the RRRSC also reviewed a broad spectrum
of policy options available for reducing major
environmental risks. The Strategic Options
Subcommittee examined a series of environmental
problems and identified a range of risk reduction
options for each of them. Thirteen problems were
included in the analysis, nine of which had been
ranked high in Unfinished Business.
The Subcommittee identified six generic risk
reduction tools that should be considered for any
problem area (see box on the following page), and
generated 60 specific examples of options that could
be applied to 13 environmental problems. The
Subcommittee also developed a series of criteria that
can be used to select from among the various risk
reduction options available. These criteria include the
magnitude of risk reduction to be achieved, the
likelihood of achieving that risk reduction, the costs
involved, the ease and speed of implementation and
enforcement, the degree of intermedia transfer of
risk, and overall cost-effectiveness.
and
Ijieseftftitt
"^.fwpt*
mi
.. •
_
could
«
of
s to'
global warming
potertive,
contaminated sediments.
of fw
f im
In ttitty :Hsk pedactfen can be jty
providing information to producers, consumers, and/or
State and local governments. For example, new home
bsjNMB with tht
Sj and tot
d wfamrixm to item •
'
* Atete
A key to ftdudfijg estwtownetittil risk m to ensure that
face flit Mj, - '
tar
pea
laws.
. Due to
Agencies and Notiom
rf
2)
aujti^ $)
-------
Chapter Three—Recommendations
1. EPA Should Target Its Environmental Protection
Efforts On The Basis Of Opportunities For The
Greatest Risk Reduction
Seen in its historical context, the ad hoc development
S-4-2 of U.S. national environmental policy is
understandable. Yet 20 years of experience in
developing and implementing environmental policy
has demonstrated that not all environmental
problems are equally serious, and not all remediation
efforts are equally urgent. The nation cannot do
everything at once. In national efforts to protect the
environment, the most obvious steps have been
taken to reduce the most obvious risks. Now
environmental priorities must be set.
In order to set priorities for reducing
environmental risks, EPA must weigh the relative
risks posed by different environmental problems,
determine if there are cost-effective opportunities for
reducing those risks, and then identify the most
cost-effective risk reduction options. This effort
should build on the analytical process begun in
Unfinished Business and in this report and its
appendices.
However, the SAB recognizes that risk analyses
always will be imperfect tools. No matter how much
the data and methodologies are improved, EPA's
decisions to direct specific actions at specific risks
will entail a large measure of subjective judgment.
Yet the SAB believes that relative risk data and risk
assessment techniques should inform that judgment
as much as possible. In short, EPA programs should
be shaped and guided by the principle of relative risk
reduction, and all available risk data and the most
advanced risk assessment and comparison
methodologies should be incorporated explicitly into
the Agency's decisionmaking process.
In order to implement a risk-based action agenda,
EPA must take several essential steps. It must
articulate to its own employees and to the general
public the fact that it intends to set priorities for
action based on opportunities for relative risk
reduction. Next the Agency must establish an explicit
process for incorporating those considerations into its
long-term planning and budget processes. Finally,
the Agency must act on those priorities.
In practice, of course, EPA's activities are defined
by the laws that it is required to administer. EPA
also has a responsibility to respond to public
concerns about an environmental problem, no matter
how limited the risk may seem to be. However,EPA
should not limit its risk comparison efforts to those
environmental problems it is required by law to
mitigate. The risks posed by other problems and
potential problems — like the loss of biological
diversity — must be compared and ranked as well.
Simply stated, EPA is responsible for protecting
the environment, not just for implementing
environmental law. Thus the Agency should assess
and compare the universe of environmental risks and
then take the initiative to address the most serious
risks, whether or not Agency action is required
specifically by law.
16
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2. EPA Should Attach As Much Importance To
Reducing Ecological Risk As It Does To Reducing
Human Health Risk
Largely because of the requirements of the laws it
E-4.0 administers, EPA has tended to pay far more
attention to protecting human health and welfare
than to protecting the ecology. Indeed, during the
1980s EPA's agenda was dominated by concerns
about the effects of toxic chemicals on human health.
Yet from the perspective of risk there are strong
linkages between human health and the health of
wetlands, forests, oceans, and estuaries. Most
human activities that pose significant ecological risks
— for example, the effects of agricultural activities on
wetlands — pose direct or indirect human health
risks as well. Likewise, actions taken to reduce
pollution and thus improve human health usually
improve various aspects of ecological quality.
These very close linkages between human health
and ecological health should be reflected in national
environmental policy. When EPA compares the risks
posed by different environmental problems in order
to set priorities for Agency action, the risks posed to
ecological systems must be an important part of the
equation.
This recommendation is not meant to imply the
relative value of human life vis a vis plant or animal
life. Rather, it is meant to reflect in national
environmental policy the very strong ties between all
forms of life on this planet. Ecological systems like
the atmosphere, oceans, and wetlands have a limited
capacity for absorbing the environmental degradation
caused by human activities. After that capacity is
exceeded, it is only a matter of time before those
ecosystems begin to deteriorate and human health
and welfare begin to suffer.
In short, beyond their importance for protecting
plant and animal life and preserving biodiversity,
healthy ecosystems are a prerequisite to healthy
humans and prosperous economies. Although
ecological damage may not become apparent for
years, society should not be blind to the fact that
damage is occurring and the losses will be felt, sooner
or later, by humans. Moreover, when species and
habitat are depleted, ecological health may recover
only with great difficulty, if recovery is possible at
all.
Thus EPA's risk-based priorities for action should
reflect an appropriate balance between ecological,
human health, and welfare concerns. Furthermore,
the Agency should communicate to the general
public a clear message that it considers ecological
risks to be just as serious as human health and
welfare risks, because of the inherent value of
ecological systems and their strong links to human
health.
17
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3. EPA Should Improve The Data And Analytical
Methodologies That Support The Assessment,
Comparison, And Reduction Of Different
Environmental Risks
•
The ability to assess environmental risks, compare
them, and select strategies to reduce them all depend
on the availability and sophistication of the relevant
data and analytical tools. The weakness in Unfinished
Business stems in large part from the weakness of the
data and analytical tools used, and those weaknesses
still exist. If EPA's efforts to assess, compare, and
reduce risks are to improve in the future, the data
and analytical tools must improve as well.
For example, in order to generate the
exposure-dose data needed to assess human health
risks more reliably, EPA should monitor chemicals in
the environment and in human tissues much more
systematically. Biomarkers and other
newly-developed measures of exposure should be
used. To this end, EPA should expand its research
and data collection efforts in this area, and cooperate
with other Federal agencies to facilitate development
of the requisite data bases.
EPA's health-related data collection efforts should
not be limited to those areas where risks to human
health already are recognized. EPA also needs to
develop an ability to predict the potential future risks
of emerging problems (e.g., low-level exposures to
electromagnetic fields). Therefore, EPA should
establish a formal risk-anticipation mechanism,
including an in-house expert committee, peer
oversight, and long-range research on emerging
problems.
Improved methodologies for comparing different
human health risks also are needed. A new approach
to ranking risks, one that uses a matrix of data on
sources, exposures, agents, and endpoints, is needed
to help identify specific agents and mixtures for
quantitative risk assessments. Risk rankings should
be based on risk assessments for specific toxic
agents, or definable mixtures of agents, and on the
total human exposure to such agents. When possible,
risks should be assigned to persons in target or more
sensitive populations, as well as to the population as
a whole.
For assessment of non-cancer human health risks,
the Agency should try to establish a risk assessment
framework consistent with that used for carcinogens.
Furthermore, although a large number of non-cancer
health endpoints exist, there is as yet no easy way to
combine assessments of cancer and non-cancer risks
into a single, overall health evaluation. The Agency
should explore procedures to achieve this end.
Improved data bases and methodologies for
assessing ecological and welfare risks also are
needed. For example, although ecological data are
plentiful, they have not been synthesized into
formats useful for assessing ecological risk.
Moreover, a substantial amount of ecological data are
collected and maintained by other Federal
government organizations. EPA should aggregate
ecological data that are collected government-wide,
and systematically synthesize those data into formats
useful for ecological risk assessment.
Finally, all three RRRSC Subcommittees took initial
steps in developing methodologies that would allow
a more rigorous, scientifically defensible comparison
and merging of environmental risks and alternative
strategies for reducing them. Those methodologies
are described in detail in the appendices to this
report. EPA should invest in both in-house and
extramural research to help improve those
methodologies. Unfinished Business took the first steps
to compare environmental risk; the appendices to
this RRRSC report describe more sophisticated
approaches. EPA should ensure that these ideas are
developed and tested in the years ahead, so that
relative risk reduction can be used as an effective,
continually evolving tool in the development of
national environmental policy.
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4. EPA Should Reflect Risk-Based Priorities In Its
Strategic Planning Processes
The Agency needs to build on and improve the kinds
of analyses carried out by the authors of Unfinished
Business and by the members of the RRRSC in the
preparation of this report and its appendices.
Ongoing assessments of different environmental
risks and the policy options for reducing them
should be carried out within EPA, but the Agency
should consider soliciting the input of external
groups and individuals with expertise and interest in
this effort. The results of such analyses — the
identification of relatively high-risk environmental
problems and the most promising strategies for
reducing them — then need to be incorporated
explicitly into the Agency's strategic planning
processes.
Recognizing that scientific understanding and
public concerns are constantly evolving, EPA should
update its risk-based priorities periodically. A major
review of remaining and emerging environmental
risks facing the nation — and the globe — should be
conducted every several years in order to reflect
advances in scientific knowledge and progress in
mitigating environmental problems over time.
Specific strategies for reducing specific environmental
risks should be reviewed and updated more often.
Risk reduction strategies always should be driven
by the environmental problems to be solved, not by
the structure of existing government programs. Thus
it is useful to analyze problems from different
perspectives — for example, as pollutants (e.g., toxic
air pollutants, groundwater pollutants), as sources
(e.g., automobiles, powerplants), in terms of their
effects (e.g., increased respiratory diseases, habitat
destruction), and in terms of the economic activity
causing or affecting them (e.g., energy use,
transportation systems, residential and commercial
development). Looking at environmental problems
from different perspectives will suggest different
types of strategic solutions, and EPA should develop
plans for specific risk reduction programs only after
undertaking this kind of comprehensive,
multi-faceted analysis.
The Agency should subject individual strategy
options to disciplined analysis to determine how
much risk reduction each will achieve. Information
on cost, timing, degree of certainty of results, and
ancillary benefits or risks should be included in such
analyses. The decision matrix developed by the
Strategic Options Subcommittee of the RRRSC
represents one approach for evaluating alternative
strategies against a set of defined criteria. After
promising risk reduction strategies have been
defined, they should be built into EPA's program
plans in a coordinated and explicit way.
Since State governments generally implement
national environmental protection policies at the local
level, State agencies need to incorporate relative risk
assessments into their strategic planning, too. EPA
should encourage and support State efforts to assess
relative risks and the various policy options available
to reduce them, especially since local action is the
most effective response to many environmental risks.
EPA support should include financial resources,
technical assistance, and information, and such
support should be focused on those problems and
geographical areas where particular risks are likely to
be reduced the most, and in the most cost-effective
ways.
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5. EPA Should Reflect Risk-Based Priorities In Its
Budget Process
Historically, EPA's budgets have reflected the
S-4*i resources necessary to establish and implement the
regulatory programs mandated by Congress, with
virtually no focus on relative risk and cost-effective
opportunities for reducing relative risks. Accordingly,
over time there has been little correlation between
the relative risk of a particular environmental
problem and the EPA budget resources dedicated to
reducing it.
Spending by EPA is not — and should not be —
the sole measure of society's response to a particular
environmental problem. In fact, other Federal
agencies, State and local governments, private
companies, and individual families will have to play
significant roles in reducing the risks posed by some
environmental problems. However, among those
environmental problems that clearly necessitate an
EPA response, the Agency should shift its budget
priorities toward those problems posing the greatest
risks.
Although this change in budget priorities is a
necessary component of future national
environmental policy, such a change need not occur
overnight. Small but consistent changes would
accomplish the same objectives, and such changes
should be made as the Agency's understanding of
relative risks improves. Moreover, changes in EPA's
budget priorities need not result in allocations exactly
proportional to risk and risk reduction goals, since
some risks can be reduced at relatively low cost.
The Agency should initiate a specific process for
incorporating relative risk considerations into its
budgetary deliberations. For example, at the
beginning of the budget cycle the Administrator or
Deputy Administrator of EPA could provide clear
guidance to the program offices regarding relatively
high-risk problems that appear to be relatively
underfunded. A second review to ensure that
relatively high-risk problems are given higher budget
priority could be completed just before the budget is
sent to the Office of Management and Budget. But
whatever kind of process is instituted, it is critically
important that a specific EPA administrative process
relates budgetary allocations explicitly to risk.
Finally, the Agency should take the lead in
ensuring that overall national efforts to reduce risks
are driven by cost-effective risk reduction strategies.
As activities by organizations outside EPA — at the
Federal, State, and local levels — become
increasingly important to the nation's risk reduction
efforts, EPA should guide, inform, and help
coordinate those efforts. As the Federal agency with
the most up-to-date, comprehensive understanding
of relative environmental risks and the options
available for reducing them, EPA needs to play an
active role in helping target national efforts to reduce
environmental risks.
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6. EPA—And The Nation As A Whole—Should
Make Greater Use Of All The Tools Available
To Reduce Risk
The main tool that this nation has used to reduce
S-4,4 environmental risk has been government-mandated
end-of-pipe controls and remediation or clean-up
technologies. Such "command-and-control" methods
for reducing risk have been very effective in
controlling some kinds of pollution, especially from
large, centralized sources. However, to control the
risks posed by widely dispersed sources like
naturally-occurring radon and some consumer
products, and to control the risks that remain after
the imposition of end-of-pipe technologies,
command-and-control approaches may not be as
effective. Consequently, other kinds of risk reduction
tools that appear to have great promise must be used
more extensively.
The RRRSC examined a variety of such tools,
including research and development, conventional
regulations, enforcement, and international
cooperative activities. Two general tools that appear
to hold particular promise are market incentives and
the provision of information.
The forces of the marketplace can be a powerful
tool for changing individual and institutional
behavior and thus reducing some kinds of
environmental risks. Whenever appropriate and
feasible, EPA should use and/or support them.
Marketable permits, deposit-refund systems, and
pollution charges are types of market incentives that
could — and should — play much larger roles in this
nation's efforts to reduce environmental risk.
EPA is only one of several Federal agencies with
authority in these areas, but EPA is the Federal
agency primarily responsible for protecting the
environment in the broadest sense. Consequently,
EPA should take the lead in fostering more
widespread use of market forces to reduce
environmental risk.
Information also can serve as a way to reduce risk
without the use of command-and-control regulations.
For example, the information requirements of the
Emergency Planning and Community Right-to-Know
Act of 1986 have encouraged companies to take
voluntary actions to reduce their inventories and
emissions of toxic substances. The exchange of
information also can facilitate the wider use of
cost-effective pollution prevention strategies.
Information provided through environmental audits
can help companies improve their risk-reduction
efforts. EPA should expand its efforts to provide
information and to facilitate information-sharing that
helps individuals, businesses, and communities
reduce environmental risk.
This recommendation is not meant to imply that
command-and-control regulations have outlived their
usefulness. For some environmental problems,
conventional regulatory approaches hold substantial
promise for further reductions in risk. Such
approaches include end-of-pipe performance
standards, design standards, use restrictions, and
product specifications. Together with strict
enforcement of existing environmental regulations,
these approaches give pollution sources a strong
incentive to look for cheaper, innovative ways to
achieve the same environmental goals. Thus the
RRRSC supports the continued use and strict
enforcement of existing regulations.
However, the long-term reduction of
environmental risks will require EPA, and the nation
as a whole, to use a far broader range of tools. EPA
should dedicate budget and personnel resources to
develop, test, and fairly evaluate all such tools. The
Agency also should make more of an effort to inform
and encourage other elements of society —
businesses, schools, State and local governments,
etc.— to use this broad range of tools.
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7. EPA Should Emphasize Pollution Prevention As
The Preferred Option For Reducing Risk
The costs of cleaning up and disposing of pollutants
after they have been generated can be enormous.
The costs of the Superfund program, the planned
cleanup of the Department of Energy's nuclear
weapons plants, and the cancellation and disposal of
chemicals already in use are painful examples of that
lesson.
Thus end-of-pipe controls and waste disposal
should be the last line of environmental defense, not
the front line. Preventing pollution at the source —
through the redesign of production processes, the
substitution of less toxic production materials, the
screening of new chemicals and technologies before
they are introduced into commerce, energy and
water conservation, the development of
less-polluting transportation systems and farming
practices, etc. — is usually a far cheaper, more
effective way to reduce environmental risk, especially
over the long term.
More widespread use of pollution prevention
techniques holds enormous environmental and
economic promise for a number of reasons. For one
thing, some environmental problems — like global
warming — simply cannot be remediated in any
practical way using only end-of-pipe controls.
Pollution prevention also minimizes environmental
problems that are caused through a variety of
exposures. For example, substituting a non-toxic for
a toxic agent reduces exposures to workers
producing and using the agent at the same time as it
reduces exposures through surface water,
groundwater, and the air.
Pollution prevention also is preferable to
end-of-pipe controls that often cause environmental
problems of their own. Air pollutants captured in
industrial smokestacks and deposited in landfills can
contribute to groundwater pollution; stripping toxic
chemicals out of groundwater, and combusting solid
and hazardous wastes, can contribute to air
pollution. Pollution prevention techniques are
especially promising because they do not move
pollutants from one environmental medium to
another, as is often the case with end-of-pipe
controls. Rather, the pollutants are not generated in
the first place.
The advantages of pollution prevention also are
becoming apparent as the nation tries to address
some of the environmental risks that remain after
end-of-pipe controls are applied. Ongoing growth in
the amount of wastes generated in this country is
quickly overcoming the ability of landfills and
incinerators to absorb it, especially since landfills are
no longer an option for hazardous waste disposal.
Society must find more ways to reduce the amount
of waste requiring disposal. Similarly, as the nation
attempts to reduce the environmental risks still
posed by urban smog more than a decade after
automobile emissions were reduced sharply by
end-of-pipe technology, it is clear that preventing
pollution — e.g., through mass transit, car pools,
and the combustion of alternative fuels — is a
promising long-term option.
In addition, pollution prevention techniques often
bring substantial economic benefits to the sources
that use them. Businesses can avoid the costs of
end-of-pipe controls, waste cleanup and disposal,
and liability by preventing pollution instead of
controlling it. Moreover, some pollution prevention
techniques, like using energy more efficiently and
recycling process materials, can pay for themselves
quite apart from environmental considerations. One
reason that Japan and Western Europe are
formidable economic competitors is that they use
energy and raw materials so efficiently. To compete
in the global marketplace, American businesses also
must use them more efficiently.
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8. EPA Should Increase Its Efforts To Integrate
Environmental Considerations Into Broader
Aspects Of Public Policy In As Fundamental A
Manner As Are Economic Concerns
For the past 20 years EPA has been the focal point of
S-4 ttIMW ^e Federal government's environmental protection
efforts. As such, EPA was largely responsible for
defining, implementing, and enforcing the national
command-and-control regulations that have been
remarkably successful in reducing certain kinds of
pollution, especially from large, centralized facilities.
But reducing environmental risk in the future also
will entail the control of small, widely dispersed
sources of pollution through the use of a wide range
of regulatory and non-regulatory techniques.
Consequently, EPA must have a broader perspective.
In solving environmental problems like habitat
destruction, indoor air pollution, non-point source
water pollution, and solid waste disposal, EPA will
be only one of a number of Federal and state
agencies with important roles to play. Thus EPA
should do more to foster the cooperation among
government entities that will be essential to the
national effort to reduce environmental risks in the
1990s and beyond.
EPA should play an important role in ensuring
that environmental considerations are a part of the
policy framework at other Federal agencies whose
activities affect environmental quality directly or
indirectly. Changing Federal policies in sectors not
traditionally linked with environmental protection
could provide cost-effective environmental benefits
that equal or exceed those that can be achieved
through more traditional means.
Environmental considerations should be an integral
part of national policies that affect energy use,
agriculture, taxation, transportation, housing, and
foreign relations. For example:
• Energy conservation measures, if given high
national priority, could improve the U.S. balance of
payments, lower future world oil prices, reduce
threats to national security, and help reduce
environmental risks locally, regionally, and globally.
• Federal agricultural policies and programs could be
revised to reduce or eliminate existing incentives for
environmentally unsound farming practices, and to
directly support efforts by farmers to control soil
erosion and chemical runoff and to make greater use
of low-input, sustainable farming practices.
• Tax policies could promote investments in new
plants and equipment that are less polluting and
more energy efficient.
• Housing and commercial development policies
could be used to control development in ecologically
fragile areas.
Because EPA is not the only Federal agency whose
actions affect the environment, it must work to
ensure that environmental considerations are
incorporated into policy discussions across the
Federal government. Environmental considerations
should be as fundamental in this context as economic
concerns are. In order to facilitate the
government-wide integration of environmental
policy, the EPA Administrator should encourage the
President to create a cross-government forum where
such integration would be explicitly considered and
carried out.
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9. EPA Should Work To Improve Public
Understanding Of Environmental Risks And Train
A Professional Workforce To Help Reduce Them
In a democracy the support of individual citizens is
* o important to the success of any national endeavor. In
the national effort to reduce environmental risk, such
understanding and support is essential, because both
the causes of and solutions to environmental
problems are often linked to individual and societal
choice. Consequently, EPA must expand its efforts to
educate the public in general and the professional
workforce in particular, both in terms of what causes
environmental risks and what reduces them.
For example, EPA should work to reduce the gap
between public perceptions of risk and the scientific
understanding of risk. In many cases, public
perception and scientific understanding are quite
different, if only because scientists have ready access
to information that the public does not. It is
important that EPA increase its efforts to share risk
information with the public, because in the long run
the public will have to approve EPA's risk-based
action agenda. Better public awareness of relative
environmental risks will help the nation allocate its
resources to maximize risk reduction.
At the same time the Agency must be attuned to
the concerns of people who are closest to the
real-world health, ecological, and welfare risks posed
by different environmental problems. An engaged
public often can be helpful in gathering information
that supports the technical analysis of risk.
Moreover, because they experience those risks
first-hand, the public should have a substantial voice
in establishing risk-reduction priorities.
Thus EPA should include broad public
participation in its efforts to rank environmental
risks. Such participation will help educate the public
about the technical aspects of environmental risks,
and it will help educate the government about the
subjective values that the public attaches to such
risks. The result should be broader national support
for risk-reduction policies that necesarily must be
predicated on imperfect and evolving scientific
understanding and subjective public opinion.
EPA also should take several specific steps to
develop and sustain the nation's scientific capability
and workforce. For example, the Agency should
provide technical and financial assistance to
universities to help them incorporate environmental
subject matter into their curricula and to train the
next generation of environmental scientists and
engineers.
In this regard, EPA also should support graduate
and post-graduate training programs in the relevant
scientific disciplines, and nurture the participation of
the scientific community in interdisciplinary research.
The nation is facing a shortage of environmental
scientists and engineers needed to cope with
environmental problems today and in the future.
Moreover, professionals today need continuing
education and training to help them understand the
complex control technologies and pollution
prevention strategies needed to reduce
environmental risks more effectively.
EPA also should expand its support for
environmental training programs targeted at Federal,
State, and local officials. Most environmental officials
have been trained in a subset of environmental
problems, such as air pollution, water pollution, or
waste disposal. But they have not been trained to
assess and respond to environmental problems in an
integrated and comprehensive way. Moreover, few
have been taught to anticipate and prevent pollution
from occurring or to utilize risk reduction tools
beyond command-and-control regulations. This
narrow focus is not very effective in the face of the
intermedia environmental problems that have
emerged over the past two decades and that are
projected for the future.
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10. EPA Should Develop Improved Methods To
Value Natural Resources And To Account For
Long-Term Environmental Effects In Its
Economic Analyses
1-5.2
Traditional forms of economic analysis, as applied to
the costs and benefits of economic development and
environmental protection, have systematically
undervalued natural resources. This practice
threatens the world's natural resources — like
estuaries and rainforests — without which the lives
of future generations will be impoverished. The
failure of current analytic techniques to estimate
properly either the full benefits of natural ecosystems
or the full costs of activities that degrade them too
often has allowed the justification of long-term
ecological degradation for the sake of present gain.
A private company invests its profits to maintain
and increase its capital value. When a company
invests to maintain facilities, expand production, buy
new equipment, and improve the quality of services
provided, it protects its long-term health.
In a similar manner, this planet requires certain
investments in order to maintain itself as a healthy
ecosystem and to ensure sustainable, long-term
economic growth. Future generations depend on
those investments, and if they are not made, then
civilization will put itself out of business.
It is necessary and appropriate to conduct
economic analyses of human activities that affect the
environment. But it is essential that such analyses
properly value the long-term, sustained productivity
of natural ecosystems. For that reason, EPA should
undertake a broad national effort to develop
analytical techniques that more adequately assess the
real long-term value of ecosystems, and that support
the identification of the most cost-effective ways to
reduce risks that threaten long-term, sustained
productivity.
There are a variety of problems with present
methods. Many of the problems stem from the fact
that public goods, such as clean air, are unpriced in
markets and thus are easily — and often —
undervalued in economic analyses. National
accounting schemes typically characterize revenues
generated by activities that deplete or degrade
environmental resources as "income" while failing to
consider the resulting depletion of society's
environmental capital assets.
When economists do try to value ecosystems, they
are hobbled by the limitations of the available tools.
For instance, the "willingness to pay" method can
significantly undervalue aspects of ecosystems with
which people are not familiar. Some of the
assumptions underlying discounting procedures do
not hold when environmental effects occur over long
time periods; thus they assign little value to some
very important long-term effects. Multipliers that are
applied differently to environmental values than they
are to more traditionally measured economic values
(e.g., employment) may further distort the results of
economic analyses.
As a first step EPA should commission a study
that surveys the ideas of ecologists, economists,
social scientists, and other experts from inside and
outside the Agency. The study should attempt to
develop a way of incorporating ecological
investments into a concept of sustainable growth.
Environmental economics is a controversial,
complex, and rapidly-evolving field. EPA should take
the lead in developing methods of analysis that will
give fair consideration to investments that will
protect the natural resource base for future
generations.
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This overview report has been derived mainly
from three detailed reports prepared by the
three Subcommittees of the Relative Risk
Reduction Strategies Committee. Those
reports are:
• Appendix A: Report of the Ecology and Welfare
Subcommittee(EPA-SAV-EC-9Q-021A).
Includes a critique of the ecological and
welfare rankings in Unfinished Business.
Suggests an alternative approach to defining
environmental problems, ranking them from
an ecological perspective. Identifies a need to
more accurately reflect ecological concerns in
economic/welfare considerations.
• Appendix B: Report of the Human Health
Subcommittee(EPA-SAV-EC-9Q-Q21B).
Includes a critique of the cancer and
non-cancer rankings in Unfinished Business.
Provides specific suggestions for
methodological improvements for analyzing
and evaluating relative risks of environmental
problems, including a possible approach for
merging cancer and non-cancer concerns.
• Appendix C: Report of the Strategic Options
Subcommittee(EPA-SAB-EC-90-021C).
Describes the wide range of "tools"
available for addressing environmental
problems. Includes 60 examples of such
strategic options applied to 13 different
environmental problems. Provides a set of
criteria for selecting from among the options
in any given case.
Copies of the three appendices to this
report can be obtained by writing:
The Science Advisory Board (A-101)
U. S. Environmental Protection Agency
401 M Street, S. W.
Washington, D. C. 20460
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U.S. Environmental Protection Agency
Region 5, Library (PL- 12J)
77 West Jackson Boulevard, 12th Flocf
Chicago, IL 60604-3590
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