,f
EPA
United States
Environmental Protection
Agency
Science Advisory
Board
Washington. D.C.
EPA-SAB-EC-99-
1999
Integrated Environmental
Decision-making in the
Twenty-first Century:
Summary Recommendations
Peer Review Draft
U.S. Environmental Protection Agency
Science Advisory Board
Integrated Risk Project Steering Committee
1999
G:\USER\SAB\DON\IRPajRAFT5\GLSYMA Y3.DOC; 5/3/99
EPA
SAB-
EC-
99-
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Information Resources Center
US Ef% (3404)
401 M Street, SW
Washington, OC 20460
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The Science Advisory Board (SAB) of the U.S. Environmental Protection Agency is a body of
independent experts who provide advice to the EPA Administrator on scientific and engineering
issues. The SAB was established in its present form by the Congress in 1978. The SAB's
approximately 100 members and more than 300 consultants include scientists, engineers, and other
specialists drawn from a broad range of disciplines-physics, chemistry, biology, mathematics,
engineering, ecology, economics, medicine, and other fields. Members are appointed by the
Administrator to two-year terms. The SAB meets in public session, and its committees and review
panels are designed to include a diverse and technically balanced range of views, as required by the
Federal Advisory Committee Act (FACA).
The Board's principal mission is to review the quality and relevance of the scientific
information being used to support Agency decisions, review research programs and strategies, and
provide broad strategic advice on scientific and technological matters. In addition, the Board
occasionally conducts special studies at the request of the Administrator to examine comprehensive
issues, such as anticipating future environmental problems and developing new approaches to
analyze and compare risks to human health and the environment.
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546
Integrated Environmental Decision-making
in the Twenty-first Century: Summary Recommendations
Peer Review Draft
V
U.S. Environmental Protection Agency
Science Advisory Board
Integrated Risk Project Steering Committee
M Stree,,SW
DC 20460
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Letter to the Administrator
,1998
Ms. Carol Browner
Administrator
U.S. Environmental Protection Agency
Washington, DC 20460
Dear Ms. Browner:
Science Advisory Board
U.S. Environmental Protection Agency
Washington, D.C.
TO BE DRAFTED
IV
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NOTICE
This report has been written as part of the activities of the Science Advisory Board, a public advisory
group providing extramural scientific information and advice to the Administrator and other officials of the
Environmental Protection Agency. The Board is structured to provide balanced, expert assessment of scientific
matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and,
hence, the contents of this report do not necessarily represent the views and policies of the Environmental
Protection Agency, nor of other agencies in the Executive Branch of the Federal government.
This particular project was conducted at the request of the EPA Administrator and addresses a broader
range of issues and concerns than most SAB reports. Consequently, many of the recommendations in this report
have more of a policy orientation than is usually the case.
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ABSTRACT
At the request of the EPA Deputy Administrator, the Science Advisory Board developed a framework for
Integrated Environmental Decision-making (TED), The IED builds on the successes of environmental protection
over the past three decades and expands the process by integrating a fuller range of scientific information, the
practice of comparative risk, a wider spectrum of management options, explicit economic considerations, the impact
of decisions on actual outcomes, and the pervasive impact of public values. This overview report describes the
three integrated Phases of the IED: Problem Formulation, Options Analysis, and Decision-making. The report
elaborates on the IED in a set of 10 specific recommendations.
The overview report was drawn primarily from an extensive report on integrated environmental decision-
making (EPA-SAB-EC-98-XXX) which describes the framework and the contributions of the five Subcommittees
mat developed elements that ied to the framework in greater detail.
Keywords:
VI
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
EXECUTIVE COMMITTEE
^ INTEGRATED RISK PROJECT STEERING COMMITTEE
CHAIR
Dr. Genevieve M. Matanoski, School of Hygiene and Public Health, The Johns Hopkins University, Baltimore,
MD
MEMBERS AND CONSULTANTS
Dr. Joan M. Daisey, Lawrence Berkeley National Laboratory, Berkeley, CA
Dr. Paul Deisler, Austin, TX
Dr. Mark A. Harwell, University of Miami, Miami, FL
Dr. Wayne Kachel, MELE Associates, Brook AFB, TX
Dr. Alan Maki, Exxon Company, USA, Houston, TX
Dr. Paul R. Portney, Resources for the Future, Washington, DC
Dr. Milton Russell, Joint Institute for Energy & Environment, and the University of Tennessee, Knoxville, TN
Dr. Ellen K. Silbergeld, University of Maryland, Baltimore, MD
Dr. Robert Stavins, Harvard University, Cambridge, MA
Dr. Paul H. Templet, Louisiana State University, Baton Rouge, LA
Dr. Valerie Thomas, Princeton University, Princeton, NJ
Dr. Bernard Weiss, University of Rochester Medical Center, Rochester, NY
Dr. Marcia Williams, Putman, Huges, & Banlett, Inc., Los Angeles, CA
Dr. Terry F. Yosie, Ruder and Finn, Inc., Washington, DC
Dr. Terry F. Young, Environmental Defense Fund, Oakland, CA
SCIENCE ADVISORY BOARD STAFF
Mr. Thomas O. Miller, Designated Federal Officer, US EPA/Science Advisory Board, Washington, DC
Ms. Stephanie Sanzone, Designated Federal Officer, US EPA/Science Advisory Board, Washington, DC
Ms. Wanda Fields, Management Assistant, US EPA/Science Advisory Board, Washington, DC
Mr. Thomas Super, US EPA/Science Advisory Board, Washington, DC
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CONTENTS
Integrated Environmental Decision-making (IED)
A. Environmental Integration: The Next Phase
B. Origins ofThisReport
C. Results
1. Reformulating the Charge
2. The IED Framework
3. Recommendations
Recommendation 1: The Value of Integrated Decision-making
Recommendation 2: The Role of Science
Recommendation 3: Methodologies for Comparing Risks
Recommendation 4: Integrated Tools for Managing Integrated Risks
Recommendation 5: Full Costs and Benefits
Recommendation 6: Characterizing Public Values
Recommendation 7: The Need for New Metrics
Recommendation 8: An Environmental Report Card
Recommendation 9: Evolving Government Partnerships
Recommendation 10: Unaddressed Environmental Risks
VUl
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INTEGRATED ENVIRONMENTALDECISION-MAKING
A. Environmental Integration: The Next Phase
. Concern for the environment has become an
important part of the American value system. We
care about the environment as it relates to human
health, the viability of ecosystems, and our children's
future. We care about the quality of life, today and in
the future, and in the interconnected environmental
conditions that play such an important role in
determining life's quality.
Starting in 1970, our national environmental
values led to the enactment of a series of major
federal environmental laws designed to protect
human health and environmental quality. Most of
those laws mandated targeted actions to control
specific pollutants in the air, water, or land. Those
actions were intended to protect specific aspects of
human and/or ecological health e.g., human lung
functions, estuarine water quality - from the effects
of specific pollutants like carbon monoxide in the air
or phosphorus in water bodies. Thus, for most of its
history the Environmental Protection Agency (EPA)
has tended to respond to its legal obligations by
emphasizing the control of single pollutants affecting
specific aspects of environmental quality.
Although this collection of federal laws and
regulatory requirements is neither systematic nor
comprehensive, it has been largely successful in
controlling many of the targeted pollutants and in
providing a strong national underpinning for an
effective environmental protection program. This
program, a mixture of federal, state, and local
controls, has led to substantial environmental
benefits.
Yet this piecemeal approach to
environmental protection, in part because of its past
success, may obscure our vision of the ultimate
environmental goal, i.e., protecting the overall health
of people and the long-term viability of whole
ecosystems. Further, by paying primary attention to
the trees - the specific risks caused by individual
pollutants we might have lost sight of the forest
the human health and ecological outcomes that are
critically important to our quality of life. For the
reasons stated below, we suggest that making ever
smaller reductions in selected single risks may not
necessarily be the best policy either for protecting
overall environmental quality or for making the best
use of society's resources.
In other words, in terms of sources,
receptors, and effects, environmental risks are to a
large extent integrated. They can be assessed,
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measured, and controlled individually, but they affect
the real world in the aggregate.
For example, reducing emissions of carbon
monoxide from automobiles is not an end in itself; it
is one important step in improving and protecting
human health. Reducing concentrations of copper in
the San Francisco Bay is not an end in itself; it is one
important step in improving and protecting the Bay's
ecological productivity. Similarly, measuring envir-
onmental success in terms of downward trends in
national emissions of individual pollutants, or in
terms of concentrations of individual pollutants in the
air or water, may lead us to a false sense of
confidence that our environmental goals are being
achieved. Even if specific symptoms of
environmental deterioration improve, overall health
whether of humans or ecosystems - still can decline.
Neither humans nor ecosystems experience
environmental risk one stressor at a time. They are
not exposed to risk through one environmental
medium at a time. Sources of pollution do not
typically impose environmental risks one chemical or
one process at a time. Consequently, risk reduction
efforts should be designed to control more than one
pollutant at a time, protect more than one kind of
human or ecological receptor at a time, and thus
realize broader benefits at lower costs.
In the largest sense, environmental stressors
are the adverse side effects of a dynamic economic
system of production and consumption that poses
multiple risks operating simultaneously, but with
varying effects, on a variety of receptors that include
subsets of the human population and different kinds
of ecosystems. Those multiple risks vary from place
to place and from time to time, as do their sources.
To respond effectively to such diverse,
aggregate risks that can involve a variety of special
populations, we need to assess them as they occur
simultaneously, operating across many different
routes of exposure, and affecting many different
human and ecological endpoints. We need to design
risk reduction strategies that are more consciously
attuned to the environmental outcomes the public
desires and expects. We need to think less about
reducing single risks and to think more about
efficiently reducing collective risks using all the
mitigation and management tools, both regulatory
and non-regulatory, at hand. In short, we need to
develop and apply an integrated, outcomes-based
environmental decision-making process that allows
us to reduce aggregate risks efficiently and
effectively, even when those risks are caused by
multiple sources and affect multiple receptors, both
human and ecological, through multiple pathways.
To achieve the full benefits of a new, more
integrated approach, environmental problems should
be defined as they manifest themselves in specific
contexts; e.g., in terms of the risks posed by whole
industries, or the risks faced by particular
communities, particular ecosystems, or particular
subsets of the population. Answers must be found to
questions that were not asked when the current
.
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pollutant-by-pollutant system was established.
These new kinds of questions include, What
are the most serious risks facing children, or the
elderly, across the nation? What are the factors that
pose an aggregate set of risks to everyone living in
urban areas? What are the interrelated risks to
human and ecological health associated with a
particular industrial sector? Of all the risks affecting
a particular geographic area or subset of the
population, which are most serious, and which are we
most capable economically, technologically, and
politically - of limiting? How can we achieve the
right balance between protecting the health and the
welfare of the present generation and those which
come after and assure ecological security for the long
term? What combinations of risk management tools -
- regulatory and non-regulatory, technological and
non-technological - can be used in concert to
achieve the overarching human health and ecological
goals in particular communities or ecosystems? How
can we measure our progress in solving integrated
environmental problems and reaching our long-term
goals: protection of ecological integrity, human
health, and quality of life?
The evolution in environmental decision-
making called for in this report is not meant to detract
from past environmental accomplishments nor
supplant existing regulatory processes and
requirements. Rather, an integrated framework is
meant to be tested, further developed and used in
conjunction with existing environmental management
approaches including federal and state regulations.
The immediate value of a new approach lies in its
potential to strengthen current risk reduction
programs, not replace them. A new system can
emphasize the results of actions taken to protect
humans and ecological systems thereby helping the
public to see more clearly the benefits of national
investments in environmental protection.
Finally, an integrated decision-making
system can help EPA fulfill its mission. While
continuing to implement its current legal
responsibilities, EPA has an opportunity to use its
substantial flexibility to identify environmental risks,
and then act to reduce them, in ways that promise
greater environmental benefits and more efficient
resource use. By using a more integrated approach
to addressing either individual risks, or when
'addressing multiple risks at a variety of scales, as
advised in this report, EPA can help move the nation
towards its environmental goals.
B. Origins of This Report
The assessment of relative environmental
risks to humans and ecosystems from different
environmental stressors is beneficial within a system
of targeted, single-pollutant environmental laws and
regulations. Comparisons can provide environmental
decisionmakers with a better sense of which
problems are most serious,a perspective that can be
used to help focus programmatic activities across
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TYPES OF INTEGRATION IN THE IED FRAMEWORK
The Integrated Environmental Decision-making framework requires that information and
viewpoints be integrated at multiplepoints in the decision-making process in order to select
management options that most effectively, efficiently, and demonstrably reduce total risk. Six critical
types of integration are involved:
Integrated Risk Assessment:
developing scientific data and analytical methods for determining risks from multiple
exposures, and multiple outcomes in order to more accurately represent real world
sauations.
Risk Comparisons:
considering a wide range of environmental risks simultaneously so that the seriousness of
risks can be characterized relative to one another.
Integrated Analysis of Management Options:
investigation of options to reduce subsets of ranked risks, rather than considering single
risks in isolation, to achieve greater aggregate risk reduction.
Integrated Analysis of Economic Consequences:
identifying the full range of benefits and costs, both monetized and non-monetized,
associated with reduction of multiple risks.
Integration of Performance Information:
using performance evaluation measures to devise course-corrections.
Integrating Multiple Disciplines and Points of View:
understanding and utilizing information from all concerned parties in the IED process.
Hie details of the IED process are discussed in the SAB report Integrated Environmental
Decision-making in the Twenty-first Century (EPA-SAB-EC-98-xxx).
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many different laws. A series of activities by a
variety of groups has helped to move us from an
intuitive appreciation for relative risk approaches to
the design of a conceptual framework for using
integrated analyses to design effective and efficient
environmental policies.
At the national level, EPA was instrumental
in two distinct efforts to rank environmental risks
nationwide. In one, a select group of professional
managers and experts from within the Agency,
supplemented by a group of outside ecological
experts, produced Unfinished Business: A
Comparative Assessment of Environmental Problems
(EPA, 1987). That report compared 31 different
problems in four different classes; i.e., cancer risk,
non-cancer human health risk, ecological risk, and
welfare effects.
In the second effort, the EPA Science
Advisory Board (SAB) reviewed the findings of
"Unfinished Business," identified major human
health and ecological risks, examined strategies for
reducing major risks, and recommended improved
methodologies for assessing and comparing risks and
risk reduction options. The SAB's report, Reducing
Risk: Setting Priorities and Strategies for
Environmental Protection (EPA/SAB 1990),
identified relatively high, medium, and low
ecosystem risks, and listed four types of pollutant
exposures associated with likely significant impacts
on human health.
Both reports discussed the considerable
scientific uncertainty, methodological inadequacy,
and insufficient data that have limited attempts to
compare environmental risks. Both reports suggested
that setting priorities for risk management at EPA
and across the country as a whole should reflect the
relative importance of particular risks, so that better
use could be made of the funds available to protect
the environment
After "Reducing Risk" was published, many
states, counties, cities, and regional groups
conducted their own comparative risk studies. Some
went beyond the scientific issues to incorporate
community values.
The SAB moved forward in a 1995 report to
EPA, Beyond the Horizon: Using Foresight to
Protect the Environmental Future, in which the
Board identified issues which might become
problems in the future. One issue identified by many
of that project's committees, integration, became the
seed of the integrated risk project (IRP). Beyond the
Horizon suggested that in the future "Emphasis [will
be] placed on multiple endpoints and exposures
requiring new management criteria." This emphasis
was reinforced when the Food Quality Protection Act
of 1996 required EPA to examine the risks to
children from pesticides using a multiple exposure
paradigm for risk rather than a single agent approach.
The concept of integration of exposures and risks has
also been recommended to the EPA by several
committees since that time. As the next logical step
in this progression, the current report developed by
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the IRP attempts to help the EPA consider this
concept of integration, not only within the context of
the science of risk assessment and management, but
throughout the steps of policy practice used in
decision-making.
The Integrated Risk Project was initiated by
a request to the SAB from EPA and the U.S.
Congress to revisit the comparative risk issue by
updating the assessment of environmental risks and
risk reduction strategies contained in "Reducing
Risk." In addition, EPA requested that the SAB:
explore additional techniques and criteria for
identifying environmental risks; identify risk
reduction opportunities and strategies; identify
uncertainties and data quality issues associated with
risk rankings; provide an assessment of the costs and
benefits of various risk reduction options; and
propose a new framework for assessing ecosystem
value.
To fulfill this request, the SAB Executive
Committee established the Integrated Risk Project,
consisting of a Steering Committee and five separate
subcommittees, each with a specific charge:
a) The IRP Steering Committee (IRPSC) was
charged with overall direction for the project,
including the definition of its scope and timing and
the integration of scientific elements.
b) The Ecological Risks Subcommittee was
charged with developing a methodology to assess and
rank risks to ecosystems at various geographical
scales, from local to regional and national, and with
establishing the relative risks to the environment at
the national scale.
c) The Human Exposure and Health
Subcommittee was charged with developing a
methodology for assessing and ranking risks to
human health, considering ways in which an
integrated risk ranking could include both cancer and
non-cancer risks, and testing the methodology for a
limited set of environment-related health issues.
d) The Risk Reduction Options Subcommittee
was charged with developing a methodology for
identifying an optimal set of risk reduction options
for controlling human health and/or ecological risks.
e) The Economic Analysis Subcommittee was
charged with assessing current methods for
estimating the costs and benefits associated with
environmental risk management.
f) The Valuation Subcommittee was asked to look
beyond traditional economic analysis approaches
and consider new ways for assessing the value of
ecosystems, including ecology-related quality-of-life
values.
In the course of this project, the IRP
Steering Committee and its five subcommittees held
over 25 publicly-accessible meetings and conference
calls, including meetings in Washington, DC,
Berkeley, San Francisco, Atlanta, New Orleans, and
Baltimore. The committees consisted of SAB
members and consultants who explored the
discipline-specific issues. The complete SAB report
from which this summary is drawn, Integrated
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Environmental Decision-making in the Twenty-first
Century, can be obtained by contacting the SAB at:
Mail: EPA/SAB, (1400), USEPA, Washington, DC
20460
Telephone: 202-260-4126
Fax: 202-260-9232
World Wide Web: http://www.epa.gov/sab
C. Results
1. Reformulating the Charge
In conducting this project, the IRP Steering
Committee decided that, even though it would focus
on developing a science-based approach to integrated
decision-making, it would look beyond the scientific
aspects of risk comparisons and explore the entire
environmental decision-making and management
process from their perspectives as scientists. To
develop a more integrated, science-based
environmental protection approach, the IRP
Subcommittees considered the various technical
analyses that underlie the process including risk
assessment, risk comparison and ranking, benefit/cost
analyses, selection of risk reduction options,
implementation of selected actions, and evaluation of
results.
The IRPSC decided to expand the scope of
this project, in part, because scientific understanding
of the causes and effects of environmental risk,
including the interrelated effects on humans and
ecosystems from multiple stressors, has improved
substantially in the past decade. Those advances can
help improve environmental decision-making.
In the area of human health, for example,
scientific capabilities have evolved from crude
measurements of human mortality related to episodes
of severe air pollution (e.g., Pennsylvania's Donora
Valley) to the analysis of more subtle developmental
and behavioral changes in children from exposures to
lead early in life.
Today scientists are beginning to understand
more clearly the complicated human health problems
that can result from the interactions of multiple
stressors. For example, there is accumulating
evidence that, although noise alone can damage
hearing, the effect of that physical stress is enhanced
in the presence of chemicals such as carbon
monoxide. Thus, the presence of both stressors will
change the risk of hearing loss from exposure to
noise alone.
In the area of ecology, science has gone
beyond an ability to consider only the effects of
single chemicals on single species (e.g., effects of
specific pesticides on bald eagle populations) to
assessments of ecological change at the landscape
scale (including evaluation of the relationships
among ecosystem types).
Scientific tools needed for integration are
becoming available and it is now possible to begin to
consider and respond to multiple stressors through
science-based processes. These processes can be
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used to identify important risks; find common points
such as stressors or sources which can be targeted to
prevent risks; and evaluate the effectiveness of
actions in improving total environmental health.
Seen from a scientific perspective,
integration can improve the environmental decision-
making process in several ways. Interrelated and
cumulative environmental risks, as they are found in
specific integrated contexts such as particular
ecosystems, local communities, segments of the
population, or industrial sectors, can be assessed and
compared. Formal benefit/cost methodologies can be
improved so they weigh the full costs and benefits of
different risk management options, and so they begin
to weigh difficult-to-monetize values, such as
ecological sustainability and intergenerational equity,
deeply held by individuals and society. Risk
management strategies can be tailored to specific
community or geographic circumstances so they
simultaneously reduce multiple risks to both human
health and ecosystems. They can be designed not
only to control well-understood risks and prevent
potential risks, but also to manage emerging risks
whose implications are just beginning to be studied.
Finally, the outcomes of complex environmental
decisions designed to simultaneously protect both
human health and ecosystems can be measured in
new, more comprehensive ways, and these outcomes
then can be compared with defined environmental
goals to evaluate past actions and to guide future
ones.
In fact, the focus of decision-making on
goals that are defined in terms of improved human
health and ecosystem outcomes, rather than simply
documenting steps taken, is consistent with
accountability mandates that EPA must meet as a
result of the Government Performance and Results
Act (GPRA). GPRA now requires government
agencies to plan their activities and to evaluate the
success of their programs in relation to the outcomes
of the actions.
The idea of integrating environmental
actions with outcome measures as the point of
evaluation did not originate with this SAB report.
"Reducing Risk" began to raise the issue almost eight
years ago, and EPA has begun to incorporate
elements of integration into its reinvention and
demonstration programs.
But the concept is worth reinforcing and
developing more fully. Society has yet to take full
advantage of a more extensive integrated evaluation
of complex, multi-stressor environmental problems.
Integration is an idea still in its infancy, with much of
its potential for reducing aggregate risk still
unrealized.
To help speed the evolution of integrated,
environmental decision-making, the IRPSC
reformulated the charge given by EPA and Congress.
In this report the IRPSC lends its support to the goal
of integration and provides a conceptual framework
and some analytic tools needed to move toward that
goal. Integrated environmental decision-making is
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the natural next evolutionary step from the calls for
setting priorities for risk management with an eye
toward the relative importance of particular risks in
Unfinished Business and Reducing Risk, and the need
for emphasis on multiple endpoints and multiple
exposures noted in Beyond the Horizon. In a sense,
the IRP's conceptual framework for integrated
decision-making begins to lay out a scientifically-
based approach for considering multi-faceted
environmental problems in a manner that leads to the
most efficient and effective overall reduction in
environmental risk. The framework also examines
the factors in decision-making that are not the
province of science.
2. The BED Framework
The IED framework is an integrative scheme
for making decisions where many different variables,
often interacting across physical, regulatory, and
organizational boundaries, can be considered
simultaneously rather than in isolation by may types
of participants. It allows for: a) the consideration of
related clusters of risks; b) the development of
multiple risk reduction scenarios; c) the definition of
markers for evaluating progress toward specific
environmental goals; and d) consideration of public
preferences and values throughout the process.
Integrated environmental decision-making
should foster a transition to a systematic way of
thinking about and managing multiple environmental
risks. It should build on the current system,
incorporate advanced scientific capabilities, and
. focus on environmental outcomes. Transition to a
more integrated approach will require changes in -
the types and amount of information collected, the
kinds of analyses used to support decision-making,
the roles of different levels and agencies of
government, the ways in which progress is measured,
and the specific environmental goals to be achieved.
These changes will result in making risk reduction
decisions at a place most appropriate to where the
problem is being addressed (i.e., Federal, state or
local). This could lead to actions that differ from
place to place.
The transition to a more flexible integrated
system requires clear, consistent decision-making
procedures that the public understands and in which
it is willing to participate. These procedures should
make clear to the public the reasoning behind
environmental decisions and include a stronger
system of public accountability to ensure that the new
integrated approach delivers what it promises, is
insulated from manipulation, establishes clear
responsibility for results, and provides the expected
level of environmental protection.
Accordingly, the IRPSC spent much of its
time and energy developing a framework that
provides a transparent and systematic way of thinking
about integrated environmental problems. As part of
the framework, the IRP developed a methodology for
comparing human health risks, developed and applied
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a methodology for comparing ecological risks, and
developed a methodology for evaluating menus of
integrated risk management options. In addition, ERP
subcommittees assessed the applicability and
limitations of economic analysis for valuing
ecological systems, and provided insights on issues
critical to a more complete valuation of additional
environmental goals such as sustainability and equity.
In developing a conceptual framework for
integrated thinking, the IRPSC concluded that risk
rankings should not be the sole driver of
environmental decision-making. Nor should
decision-making be conceived of as a step-wise
process leading in one direction from risk ranking to
risk reduction options assessment to comprehensive
benefit/cost analysis to the final decision. The
approach suggested attempts to circumvent the
limitations of unidirectional assessment by proposing
a dynamic system that allows risk, hard-to-monetize
values, and benefit/cost information to be considered
iteratively.
The ffiP's proposed framework is shown
schematically in Figure 1. It is described in detail in
the SAB document, Environmental Decision-making
in the Twenty-first Century (EPA-SAB-EC-99- ).
Integrated decision-making can be initiated
for a number of reasons; for example as a result of
public concern, a series of events, or requirements
contained in an environmental law. Once initiated,
consideration of integrated environmental problems
should occur in an iterative manner mat proceeds in
phases. For convenience of discussion, these phases
are shown as separate and distinct in Figure 1 with
each phase having its own special emphasis. These
phases include Problem Formulation, Options
Analysis and Decision-making, and Implementation
and Performance Evaluation. In practice, however,
there is not always a clear boundary between these
phases of activity.
The activities in each phase should be
conducted through the close cooperation of scientists
(hazard, exposure, economics, engineering, etc.),
decisionmakers, and stakeholders from regulated
entities and the public. Activities can include the
evaluation and comparison of human and ecosystem
risks; the identification and analysis of risk reduction
tools; prediction, monitoring, or evaluation of die
performance of environmental management actions;
and communication among those involved.
Comprehensive and complete communication among
the participants is one of the most important
requirements of integrated decision-making, because
it insures that all activities are coordinated and
complementary, not fragmented and isolated.
Integrated decision-making should begin by
defining the scope of an interrelated set of problems
that will be considered concurrently, i.e., Problem
Formulation. Specific activities can include goal
setting, data gathering, risk identification and
comparison, identification and preliminary screening
of a broad range of feasible risk management tools,
and extensive communication among the participants
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in decision-making. Goals for decision-making must
be established to reflect public values, both those
elicited during decision-making events and those
embedded within environmental laws.
In the next phase, Analysis and Decision-
making, the integrated problems should be analyzed
in detail to determine how risk might change under a
variety of combined environmental management
actions. The intention of this detailed and iterative
evaluation activity is to determine how alternative
courses of action contribute to achievement of the
goals set for decision-making. This should also
include evaluation of the costs associated with
implementing alternative actions and the benefits of
the action as described quantitatively and
qualitatively. Evaluations in this phase provide
decisionmakers with the information needed to
decide on the appropriate response to the defined
problem. This phase of activity culminates in a
decision on needed actions.
In the concluding phase, Implementation
and Performance Evaluation, activities directed at
achieving the human health and environmental goals
identified during Problem Formulation should be
planned and implemented by responsible parties.
The results of those actions must be monitored over
time and the knowledge gained fed back into the
system to allow accountable parties to decide on the
need for continued or modified actions. A critical
part of this phase should be the reporting and
comparison of actual performance of the system
against the previously established benchmarks of
human and ecological system health.
An integrated decision-making framework
should be inclusive and flexible in order to be
applicable to problems of different scope and at
different places or so it can be used by different
levels of government or by combinations of
government and non-government groups.
Integrated decision-making should involve
risk assessors and risk managers working together to
more clearly inform decision-making. Further, it
should strive to elicit public input in an organized
and effective way so that hard-to-quantify public
values, as well as public knowledge and insight about
the matter, are included in the decision-making
process. It should also be based on the
understanding and a clear statement of the points
where scientific fact, uncertainty, value judgment,
and opinion play a role in order to provide needed
transparency. This transparency should foster
improved accountability for achieving the identified
human health and ecosystem protection goals.
The conceptual framework proposed by the
IRPSC is not a finished product. Rather, it is a work
in progress that will be improved through practical
application. This way of thinking about
environmental problems will advance the state-of-
the-art and provide a useful basis for further efforts
to refine and apply integrated thinking to
environmental problems at local, regional, and
national levels. Such thinking will be critical to
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achieving the nation's desired economic and
environmental sustainability.
3. Recommendations
National environmental risk management
systems have evolved over the past quarter century in
response to several factors, including a better
understanding of environmental problems,
improvements in analytic techniques, and the testing
and use of a number of innovative, non-regulatory
risk management tools. The SAB is convinced that
this system has to continue to evolve to meet the
changing needs of the twenty-first century, and that
the principle of integration should guide that
evolution. Integrated decision-making has enormous
potential for the future if it is widely applied. It can
be used fruitfully in the near term because it builds
on the environmental protection system already in
place, and most elements of the integrated system are
already well understood. Other parts are being
tested. What remains is to tie the pieces together
more rigorously, and then use the integrated decision
process more consciously and more extensively to
mitigate environmental problems.
This report provides an overarching
rationale for an integrated environmental decision-
making system from a scientific perspective. The
recommendations made by the IRP Steering
Committee are summarized in Table 1 of this report.
Each recommendation is then explained more fully in
the sections that follow. An expanded view of the
thinking that led to the concepts explained in this
document is contained in the accompanying full
report, Environmental Decision-making in the
Twenty-first Century (EPA-SAB-EC-99- ).
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Integrated Environmental Decision-Making Framework
-tafonoadog
-Eipert Judgment
Values: Paklfc 4
other Stakeholders
-Information
-Eipm Judgment
-Lc{»l and Institutional
MiHeo
PROBLEM FORMULATION
(What are the most important environmental risks?
W aai are o»r environmental goals?)
gist Cam ftrijon Coal Sitting
frtUmatrj Optiaits Ataljiis
Dtliltrelion
IMPLEMENTATION and
PERFORMANCE EVALUATION
. (How are we doing?)
lupltmtttalifs U txiuritf enlKepottotf
Jn/ornalion Eialuatun
ANALYSIS AND DECISION-MAKING
(What are die best risk redaction opportunities?
How can we achieve our soils and objectives?)
Hut Atstssmint Scritting/SiUctimt
Optiaas Aneljsit D iliberttion
ftrforaaact Uitturet
REPOR
CARD
(Is the Nat re
oftbeProb
Changing
REPORT
CARD
(Are we neelin
out objective!?
-------
Table 1.
Recommendations of the EPA Science Advisory Board on Integrated Environmental Decision-making
1: EPA should accelerate the transition to integrated, outcomes-based environmental protection,
and apply an integrated environmental decision-making framework in selected cases while
maintaining the safeguards afforded by the current system.
2: Because science plays a critical role in protecting the environment, EPA should commit the
resources necessary to expand the scientific foundation for integrated decision-making and
outcomes-based environmental management
3: EPA should apply and encourage the broader use of risk comparison methodologies, such as
those described hi this document, that clearly identify how scientific information and judgment
are incorporated into risk comparisons.
4: EPA should use a broader range of risk reduction options hi combination to manage
environmental risks.
5: When evaluating risk reduction options, EPA should weigh the fun range of advantages and
disadvantages, both those measured hi dollars as costs and benefits and those for which there
may not be a comprehensive dollar measure, such as sustainability and equity.
6: EPA should make fuller use of the scientific methods available to characterize public values and
incorporate those values into goal-setting and decision-making.
7: EPA should identify, collect, and disseminate scientifically>based environmental metrics
organized in new ways to support a more integrated approach to managing environmental risk.
8: EPA should develop a system of "report cards" to organize and disseminate information on the
status of ecological and human health and the quality of life in order to assess the effectiveness of
its environmental decisions and to guide future environmental management
9: EPA should expand and develop new collaborative working relationships with other, federal and
non-federal agencies and others who also will be involved in integrated environmental decision-
making.
10: EPA should aggressively explore options for reducing risks from significant stressors that
currently are addressed inadequately by the nation's environmental institutions.
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RECOMMENDATION 1
NEW APPROACH TO DECISION-MAKING
EPA should accelerate the transition to
integrated, outcomes-based environmental
protection and apply an integrated environmental
decision making framework in selected cases
while maintaining the safeguards afforded by the
current system.
The first step in an integrated environmental
decision-making framework is to set goals which
reflect scientific knowledge, expert judgment, and
public values. The time has come to base the goals
on an outcomes-driven approach to protecting and
improving the health of humans and ecological
systems. The gains made by using the current system
of controlling individual chemical pollutants must not
be undermined. But the next generation of
environmental decisions should go beyond the end-
of-pipe control focus and should aim to achieve the
explicit outcome-directed goals that society directs.
Over the past quarter century this country's
environmental protection system has evolved and
improved as we learned more about managing
environmental risk. Refinements in the system
such as expansion of the kinds of tools used to
reduce risks - have helped increase environmental
benefits while making more efficient use of the
nation's risk reduction resources.
However, much of our environmental
protection activity remains focused on single
pollutants, from single sources, emitted into a single
medium. This approach to environmental protection
has led to many "environmental standards" that are
useful tools for regulators, decisionmakers, and
enforcers. However, the outcome of this activity on
environmental conditions is much more difficult to
assess.
In the next generation of environmental
decision-making, the focus will be on results; that is,
on demonstrable outcomes (improvements) in the
environment resulting from integrated action, rather
than on a simple single pollutant strategy that infers,
but does not demonstrate, a connection between end-
of-pipe or process-based compliance and
improvements in the environment. The need to
consider outcomes comes from a number of forces:
a) Expanded public expectations for environmental
protection that includes both public health and
ecological issues.
b) Demands for greater accountability on the part of
governmental and other institutions whose decisions
affect environmental quality.
c) Recognition that the approach to environmental
decision-making during the past generation has
accomplished much of what it was designed to do in
the United States and further efforts in this direction
will have diminishing benefits at higher costs. It is
likely that the greatest remaining threats to the
environment and public health involve multiple
stressors, sources, endpoints, and routes of exposure.
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Therefore, the greatest opportunities for risk
reduction need to be sought by an integrated
examination of risks.
d) Advances in the state of scientific knowledge that
enable environmental decisions to increasingly be
based on projected outcomes.
In order to make the most effective,
outcomes-based environmental decisions to improve
human and environmental health, a more expansive
approach will be needed that will:
a) Bring a wide range of scientific information to
bear on a problem.
b) Identify the priorities among and interrelationships
between the major environmental and human health
problems.
c) Expand appropriately the decision-making process
to include deliberative stages that will involve non-
technical experts to reflect public values and
knowledge in the setting of environmental goals and
informing decisionmakers.
d) Broaden the horizon of risk reduction options to
seek opportunities to reduce aggregate risk.
e) Make more transparent the bases of environmental
decisions; i.e., the role of both technical and non-
technical factors.
f) Establish a "report card" system for evaluating the
results of actions on the health of the environment
and/or the human population.
In the course of conducting this project, the
SAB has developed a science-based conceptual
framework for integrated environmental decision-
making that incorporates these requirements. Further
development and implementation of an integrated
approach by the Agency would help facilitate the
transition to a new phase of environmental protection
in the next century.
The integrated framework developed by the
SAB, which is described in this report, and the
companion exposition reinforces ideas advocated in
several recent studies, such as Understanding Risk-
Informing Decisions in a Democratic Society
(National Research Council, 1996) and Framework
for Environmental Health Risk Management
(Presidential/Congressional Commission on Risk
Assessment and Risk Management, 1997). The fact
that the current SAB revaluation, which began as a
revisitation of comparative risk issues, concurs with
the findings and recommendations of these other
groups demonstrates the importance and timeliness of
the concept of integration and its potential for
reducing aggregate environmental risk.
Moreover, it should be noted that the
concept of integration underlies much of EPA's
recent agenda for reinventing environmental
regulation. In fact, over the past few years, EPA has
taken several positive steps to address environmental
issues in a more integrated way. A number of EPA
projects embody some of the elements of integrated
decision-making, though none contain all elements.
For example, in the early 1990s the Agency
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introduced the Green Lights Program, the
Comparative Risk Projects, and the 33/50 Project as
experiments in voluntary, cost-effective energy
conservation, community involvement in agenda
setting, and large-scale, cross-media emissions
reductions respectively. More recent Agency
projects containing such elements include the
Common Sense Initiative, Project XL, the National
Environmental Performance Partnerships, and
implementation of the Food Quality Protection Act
(FQPA) have moved beyond single pollutant, single
receptor concerns in order to reduce environmental
risks in a more integrated and comprehensive way. .
But most of the integration now underway at
EPA remains confined to experimental or
demonstration programs and many do not emphasize
the incorporation of science as an essential
consideration for integration. The Agency's agenda
seems stiil to reflect a narrow interpretation of what
respective environmental laws require it to do, rather
than a proactive interpretation of what the laws allow
it to do.
EPA should build on its promising
experiments in integrated risk management and work
to incorporate this innovative way of thinking
throughout the Agency and its programs. The
Agency should use all the flexibility allowed under
existing law to more completely characterize
environmental risks and the options it considers to
manage diem. EPA should be prepared to use
innovative, multi-faceted mitigation strategies and be
prepared to defend such use on the grounds of
improved environmental benefits achieved more
efficiently.
EPA should incorporate integrated thinking
more thoroughly across its programs, and it should
select a few test cases where the framework can be
applied explicitly. The best way to test the potential
of IED, identify its weaknesses, improve its
methodologies, and gain its benefits is by applying it
to real-world problems.
As EPA's integrated risk management
processes evolve, the Agency should give ample
incentives to the agents and programs of change,
because aggressive action is one of the keys to
success. At the same time, this new approach to
managing risk need not cause sudden disruptions in
the old system. Rather, it should build on and
strengthen the old system by both defining problems
and designing more comprehensive solutions.
Integrated decision-making can be applied
to environmental problems of different magnitude
and in different locations. It can be used effectively
by different levels of government. Indeed, by
looking at environmental risk as a complex,
interrelated set of effects operating in defined
contexts (e.g., in urban areas, in watersheds, across
the whole nation), integrated risk management will
often demand the involvement of different levels of
government. Though applicable to single stressor
risks, its greatest value will be in situations where
several different stressors operate simultaneously.
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RECOMMENDATION 2
THE ROLE OF SCIENCE
Because science plays a unique and
critical role in protecting the environment, EPA
should commit the resources necessary to expand
the scientific foundation for integrated decision-
making and outcomes-based environmental
management.
Science has a unique and critical role to play
in protection of the environment It is through
scientific investigation that most environmental
problems are first discovered. Such investigations
can be theoretical, laboratory-oriented, and/or field-
oriented. For example, the ozone depletion story
originated in theoretical and lab investigations and
was only later confirmed by field measurements.
Similarly, it took the integration of the results of
studies by various scientific disciplines to develop a
cohesive hypothesis about environmental endocrine
disrupters, a story that is still evolving in research
institutions around the world.
Science also is instrumental in developing,
testing, and evaluating risk reduction options. This
activity includes both "hardware options" from the
traditional hard science and engineering community
(e.g., control technologies and process changes) and
"socialware options" from the social sciences
community (e.g., market incentives and educational
materials). For example, over the past decade
emissions of dioxins from some stationary sources
have been reduced by as much as 90% through a
combination of new end-of-pipe controls on outputs
and innovative alternatives in inputs and process
conditions. Also, the predictions of some in the
economic community as to the effectiveness of
emissions trading for SOx and NOx have been borne
out in large measure in the real world, while
educational efforts have led to reductions of risk
from radon gas in homes.
Of course, addressing environmental risks
involves much more than science and scientists,
where science includes the traditional scientific
disciplines, engineering, and social sciences. Legal,
ethical, and political considerations all play an
indispensable role. It is through harnessing all of
these considerations, including the scientific ones,
that society can take the most appropriate, effective,
and efficient steps in risk reduction.
At the same time, the unique nature of the
scientific contribution in spotlighting the
fundamental truths underlying environmental
problems cannot be ignored or replaced by a popular
vote.
In confronting today's environmental
problems, we are asking more realistic - but
increasingly complex - questions. To generate the
needed answers to these questions requires
increasingly sophisticated science. Because our
scientific capability is increasing at a rapid rate we
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can realistically expect to get the answers we need.
For example, a range of new techniques
exists for gathering large amounts of data; cf., the
satellite-based and other remote sensing technologies
that provide a larger-scale, synoptic view of the
environment. Today new algorithms and model
constructs enable us to simulate the complexity of
ecological and human systems to a degree of realism
unknown before. This theoretical analytic capability
is complemented by high-speed computing
capabilities and enormous data storage and handling
capacities that allow the acquisition, storage, and
analyses of data at a level of sophistication
commensurate with the complexities of
environmental problems. The sophisticated display
devices of geographic information systems have
actually simplified what would have been a daunting
chore of comprehending and extracting meaning
from this mass of information. Innovative tools and
techniques begin to allow us to ask and answer
questions that were undreamed of only a few
decades ago; e.g., "What is the cumulative risk in a
given situation to an individual whose genomic
susceptibility to pollutants is known?" Improved
electronic communications have permitted a new
level of integration within and between scientific
disciplines to the point that knowledge is assimilated
at an increased rate and the very boundaries between
disciplines are disappearing.
However, if the promise of these advances
is to be realized in an era of increasingly complex
problems and in which there are increasing calls to
demonstrate the results of environmental protection
actions, EPA and the nation will have to make the
requisite investments. These investments will be in
the form of scientific capital both hardware and
intellectual capital that will provide the information
for an accurate characterization of the state of
ecological and human health, the risks posed to them,
and the results of applying innovative corrective
measures to them.
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RECOMMENDATION 3
METHODOLOGIES FOR COMPARING RISK
EPA should apply and encourage the
broader use of risk comparison methodologies,
such as those described in this document, that
dearly identify how scientific information and
judgment are incorporated into risk comparisons.
Science plays a particularly important role in
comparing the relative seriousness of environmental
risks, especially early in decision-making. In fact,
scientific information on risk, such as quantified risk
assessments and scientifically-demonstrated linkages
between stressors and effects, provides the essential
underpinning which make objective risk comparisons
possible.
Past efforts to compare and rank different
environmental risks, like those undertaken in
Unfinished Business and Reducing Risk, were an
important step in the evolution of the nation's
environmental protection system. They were among
the first attempts to impose some order on an ad hoc
protective system that assumed all environmental
problems were equally serious and equally amenable
to amelioration. They provided scientific information
and a science-based rationale for beginning to set
priorities among the many environmental issues
competing for public attention and funding.
Often, the desired scientific information is
incomplete or absent, and the scientists have to use
their best professional judgment to bridge important
gaps in the data; e.g., best estimates, default
assumptions, and the like. In other cases, scientific
information and analyses, by themselves, are not
sufficient for rating and comparing risks; e.g., human
health risk versus ecosystem risk, cancer risk in
adults versus neurologic risk to children, or risks to
wetlands versus upland habitats. In these instances,
it is public values that come into play in making these
comparisons.
Thus it is important that any methodologies
used to compare and rank environmental risks
whether human health risks, ecosystem risks, or both
not only incorporate the most up-to-date scientific
information, but that they also identify explicitly
where professional judgment and values have
influenced the results. By clearly pointing to the role
and impact of professional judgments and public
values in such comparisons and rankings, the
decisionmaker and the public will better appreciate
the basis for the decisions that have to be made.
As part of this project the SAB developed
two risk comparison methodologies that require
analysts to be clear about which elements come from
science, which are based on professional judgment,
and which ones reflect public values.
First, the SAB's Human Exposure and
Health Subcommittee (HEHS) developed a
methodology for soliciting a defined group's input to
20
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ranking the relative risks to human health from
exposures to different environmental stressors and to
capture information on the group's judgment and
values.
The Subcommittee's goal was to develop a
methodology mat was relatively easy to use so that
information could be gathered quickly and
inexpensively from any group of respondents,
technical experts, stakeholders, or the general public.
The methodology utilizes scientific information and
methods to derive ratings, analyze variabilities in the
ratings, and identifies factors and confidence levels
influencing the ratings. The results are amenable to
analysis of correlations within and between
respondents.
The methodology is capable of
simultaneously comparing both current and possible
future health risks, in iight of existing and emerging
scientific knowledge, and is applicable on any
geographic scale. It is capable of incorporating
quickly any new information on stressors, exposure
standards, or public concerns.
A complete description of the Web-based
human health risk rating methodology developed by
the HEHS can be found in the SAB's Integrated
Environmental Decision-making in the Twenty-first
Century (EPA-SAB-EC-99- ).
The Ecological Risks Subcommittee (ERS)
took a different approach in developing an ecological
risk ranking methodology. The ERS first
summarized in an ecological risk profile the nature of
each stressor and its potential ecological effects.
Each risk profile identified the co-occurrence of the
stressor and related ecological effects at some
specific scale. Ecological effects were assessed in
terms of changes in ecological endpoints, defined to
be those specific ecological attributes that can be
used to characterize the health of ecological systems,
ranging from population- and species-level attributes
(e.g., presence of endangered species or the
productivity of economically important species) to
landscape-level attributes (e.g., the diversity of the
mosaic of habitats across the landscape).
The ERS risk ranking methodology then
applied a series of multiplicative factors that translate
generic stress-effect relationships into an estimate of
the relative magnitude of the risk at particular scales
and for particular ecological systems. Examples of
multiplicative factors used include the spatial scale of
the stressor, the duration of ecological effects, the
potential for irreversibility, and the potential for
effects on critical components of ecological systems.
These multiplicative factors were developed through
the expert judgment of the ERS scientists and are
clearly identified as such. The methodology was'
designed to make transparent the underlying
assumptions, the risk factors, and the specific values
for each risk factor used in developing the ecological
risk rankings.
A complete description of the risk rating
methodology developed by the Ecological Risks
Subcommittee can be seen in the SAB's Integrated
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Environmental Decision-making in the Twenty-first
Century (EPA-SAB-EC-99-__).
The two risk ranking methodologies
developed by the SAB are complementary and can be
used in tandem. The Web methodology of the HEHS
providing a survey of a broad set of experts, and the
consensus methodology of the ERS providing an
analysis based on intensive considerations of the
nature of environmental systems. These methods can
be used, either singly or together, in different
geographic areas, at different levels of government,
or by non-governmental users. Both clearly reveal
the processes, which include technical data,
professional judgment, and respondents' values, by
which they arrive at their conclusions. It is possible
to subject the results of both to sensitivity analyses to
determine how they would change in response to
changing variables.
In summary, the SAB developed two
prototype methodologies that clearly reveal the
science, expert judgment, and values that together
lead to a rating and comparison of environmental
risks. These approaches should be points of
departure for the Agency as it seeks to develop and
use science-based methodologies to compare relative
environmental risks at various levels.
EPA could help other groups of
decisionmakers apply these methodologies in specific
communities and ecosystems. National risk
comparisons always have had limited applicability to
local or regional circumstances. Risks that may rank
low on a national list, as was the case with the
ranking of contaminated Superfund sites in the
SAB's "Reducing Risk," may rank very high in a
particular community. As efforts to protect the
environment evolve in the years ahead, it is likely
that many risk comparisons will continue to be
conducted at the state, regional, and local levels.
EPA should assist others to develop and use these
improved risk comparison methodologies to meet
their unique needs.
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RECOMMENDATION 4
INTEGRATING TOOLS FOR MANAGING
INTEGRATED RISKS.
EPA should use a broader range of risk
reduction options in combination to manage
environmental risks.
Historically, the range of risk reduction
options considered by risk managers has often been
limited by narrowly defined, statute-driven goals.
This fragmented approach can result in missing
benefits that could accrue from simultaneously
controlling several pollutants. Further, little or no
attention may be given to the negative consequences
of ignoring some options entirely. Narrowly targeted
approaches can miss opportunities for reducing
aggregate risk more efficiently.
Integrated strategies, on the other hand,
attempt to assess multiple-stressor problems and then
determine combinations of control or management
options that provide the most overall risk reduction
for the least cost. They are focused on the ultimate
ecological and human health outcomes that society
desires. They lend themselves to the simultaneous
use of several policy tools ( e.g., government
regulations, economic incentives, or voluntary
initiatives), depending on the risks in question. In
fact, integrated decision-making can foster the use of
non-traditional policy tools like economic incentives
and education as decisionmakers try to find the best
'mix of strategies to reduce aggregate environmental
risks. Because of the flexibility inherent in such
decision-making, risk reduction strategies can be
tailored to fit local and regional circumstances, a
result that is often missing in the traditional
regulatory system.
In 1990 the SAB recommended in Reducing
Risk that the nation make greater use of all the tools,
including market forces, information, and product
specifications, available to reduce risk. Now, almost
a decade later, many of those tools are being used to
a greater extent than ever before. From the emissions
trading caps and tradeable discharge permits in the
1990 Clean Air Act to the widespread use of
environmental audits to the vastly expanded
environmental information available to the American
public, we now have available a much broader and
more flexible array of options for controlling risk.
Now the challenge for EPA is not only to
expand the use of those various tools but also to use
them in creative, coordinated ways to reduce multiple
risks to multiple receptors in communities and
ecosystems across the country.
A risk reduction options evaluation
methodology was developed during the Integrated
Risk Project. This method can be applied fruitfully
to single stressors, such as a heavy metal. However,
it will be especially useful for identifying multi-
dimensional strategies intended to control complex
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environmental problems involving many sources,
stressors, and receptors. (A complete description of
the risk reduction options methodology is contained
in the SAB's Integrated Environmental Decision-
making in the Twenty-first Century (EPA-SAB-EC-
99- ).
Seven categories of tools that can be used,
either singly or in combination, in tailored control
strategies are noted in the description of this
methodology. They are: a) communication and
education; b) enforcement; c) conventional and
innovative engineering; d) international and
intergovernmental cooperation; e) environmental
management systems; f) market incentives; and g)
regulations.
Determining the best tool, or mix of tools, to
be used in specific contexts will be a complex task,
but it will be worth the result: more effective risk
management strategies tailored to specific situations
(e.g., urban areas, children's health, watersheds, etc.)
at different levels of government (local, regional, and
national). The best possible risk management
strategy will emerge only after the full array of
options available for managing a set of interrelated
risks is defined through broad participation of those
inside and outside EPA and analyzed for their
applicability.
The best strategy, by definition, is not
necessarily the one that reduces the worst risk to a de
minimis level, but the one that reduces the most risk
with the resources available, with due regard to any
legislatively mandated risk reduction requirements.
In this respect this methodology goes beyond the
suggestions in the SAB's 1990 Reducing Risk report.
While ranking risks is important for gauging the
relative magnitude of individual risks, it is more
important to focus on the reduction of total risks
resulting from risk management decisions than it is to
focus on the reduction of any particular risk, per se.
In short, we should target the most first, not the worst
first.
The proposed approach to risk management
options selection is consistent: it can be applied in
the same way to simple or complex environmental
problems. It is flexible in the sense that any number
of a wide range of tools can be applied to a particular
problem. It can - and should be transparent so that
people standing outside the process are able to
understand how decisions are reached.
In summary, when assessing its options for
the control of complex risks in integrated contexts,
EPA should not limit its analyses to the sources or
stressors defined by existing laws, regulations, or
traditional approaches. The Agency should identify
and analyze different combinations of control options
regulatory and non-regulatory, technological and
non-technological that, when implemented in a
coordinated way, can best improve the overall quality
of life for the American people.
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RECOMMENDATION 5
FULL COSTS AND BENEFITS
When evaluating risk reduction options,
EPA should weigh the full range of advantages
and disadvantages, both those measured in
dollars as costs and benefits and those for which
there may not be a comprehensive dollar measure,
such as sustainability and equity.
Environmental actions are intended to
efficiently and effectively achieve community and
national goals; e.g., clean air and water, safe food,
sustainable resources and equitable access to them,
biodiversity, etc. The value of an environmental
management action is related to how that action
contributes to these goals.
The valuation framework that undergirds
environmental decisions is the simple formulation of
whether the gains that accrue from protective actions
are worth what is given up to attain them. There is a
subsidiary question: would other possible actions be
preferable? This question highlights the importance
of taking all effects, including long-term effects, into
account. It also raises the sometimes hidden issue of
how people value different aspects of the
environment. Ultimately, it is this value that
determines both the relative worth of protecting the
environment and the relative investments society is
willing to make to achieve environmental and health
goals.
Some of society's environmental values can
be measured directly in monetizable terms, and others
can be inferred and translated into monetizable terms'
with some confidence. Tools are available to
measure such value in terms of efficiency in
allocating resources. Chapter 4 in the SAB's
Integrated Environmental Decision-making in the
Twenty-first Century discusses a number of these
methods (EPA-SAB-EC-99- ).
Other things that people value, such as
sustainability and equity, may not have
comprehensive quantitative expressions, yet they are
of no less importance for that reason. Because
integrated thinking about human health and
environmental risks is likely to suggest a broader
range of environmental values to be considered for
simultaneous protection, a broader array of control
options will need to be assessed; thereby, requiring
more information about more options. Both sides of
the benefit/cost equation will be more complex. In
assessing all of the costs and benefits of possible
management options, analysts will have to untangle
an interlocking array of variables.
Complicated qualitative issues are certain to
emerge as decision-making becomes more integrated.
Not all costs and benefits can be quantified, much
less translated into dollar terms. Difficult-to-quantify
goals like fairness, sustainability, and biodiversity
have to be interwoven into the decision-making
25
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process as explicitly as monetized costs and benefits
are, with care that value measures for the goals not be
double-counted; i.e., that they are not already part of
the monetized calculation. Qualitative assessments,
and the methodologies that support them, can be as
important as quantitative measures, depending on the
risk management options being assessed.
Qualitative methods should not be dominated by
quantitative, and vice versa, but the two should be
considered together with all the implications of
alternative courses of action made as explicit and as
transparent as possible.
In order to incorporate qualitative and
quantitative values information properly, new
methods of decision-making may be needed. One
such method, formal deliberation among
stakeholders, can be useful in raising and defining
qualitative issues and in assuring that quantitative
issues are fully and properly included. Deliberative
processes bring together diverse groups of people to
examine findings, interpretations, and/or economic
and non-economic values and their measures in order
to elucidate different management options from a
variety of perspectives. Although the results of
deliberation are not necessarily quantifiable, in many
cases they may be indispensable in assuring that all
relevant elements are included in the analysis,
providing insight and evidence about the value of
each element, and assessing the full range of benefits
and costs likely to accrue from a control action.
For deliberation to contribute meaningfully
to decision-making, care must be taken to ensure that
it is conducted in a manner that does not bias the out-
come. The document Integrated Environmental-
Decision-making in the Twenty-first Century,
discusses this issue further. The document discusses
four types of deliberation, each of which is related to
the sufficiency of knowledge underlying the
environmental issue and the level of controversy that
attends it.
In "Reducing Risk" the SAB asserted that
ecological benefits often are underestimated in
traditional benefit/cost analyses. That report
recommended that EPA undertake a broad national
effort to develop analytical techniques that assess
more adequately the real long-term value of
ecosystems. Such an improvement in assessing
ecological benefits will be even more important in an
integrated system, where management options often
will incorporate measures to protect human health
and ecosystems simultaneously, and where tradeoffs
between human and ecosystem health and quality of.
life concerns may be necessary.
While a framework for comparing costs and
benefits is a necessary and appropriate part of the
decision-making process, formal benefit/cost
analyses alone are not a sufficient basis for choosing
among different possible actions. Neither a low net
benefit estimate nor a high risk ranking should be the
sole factor that dictates an expenditure of resources.
Risk rankings and benefit/cost analyses are useful
tools that inform the decision-making process and
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increase the probability that effective, efficient risk-
reducing strategies acceptable to society will be
designed and implemented. Neither analysis is
sufficient, by itself, to determine the need for and
best action to take.
As a part of this project, the SAB has
described the applicability and limitations of the
benefit/cost framework, and suggested areas where
new approaches to characterizing values are
essential. The SAB also has attempted to define
better the full range of relevant questions that must
be considered in ecological valuation. See Chapter 5
in the SAB' s Integrated Environmental Decision-
making in the Twenty-first Century (EPA-SAB-EC-
99- ).
In short, the SAB has found that the
benefit/cost framework is a valuable tool for helping
determine the most efficient responses to
environmental problems. It will continue to inform
decisionmakers when environmental problems are
defined in a more integrated way. In fact, the
economic analysis can provide an integrating
function, because it can lead decisionmakers to
integrate different kinds of information about
people's preferences.
To support the new decision-making
procedures, EPA should expand its economic
analysis framework to include more and different
kinds of information. For example, when assessing
options for the control of complex, multi-stressor,
multi-receptor problems, EPA should look at the
costs of a wider more complex range of management
options that are capable of controlling a number of
different stressors simultaneously. On the benefits
side, EPA also should begin to quantify the range of
benefits likely to result from different kinds of
control strategies when combined. This analysis
should include both easily quantified and difficult-to-
quantify values held by the people affected by risk
management strategies.
In fact, because qualitative value
descriptions can be as important to decision-making
as quantitative costs and benefits, separate analyses
of valued attributes like sustainability, biodiversity,
and equity should be conducted in parallel with, and
as a complement to, standard benefit/cost analyses.
These separate analyses will help provide a complete
and balanced picture of the full consequences of
alternative courses of action. All these analyses
should be provided to decisionmakers and
reproduced as pan of the public record.
At the same time, EPA should develop
improved ways to measure and communicate the
value of attributes like sustainability, biodiversity,
and equity- This should be a key area of EPA
research in the future.
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RECOMMENDATION6
CHARACTERIZING PUBLIC VALUES
EPA should make fuller use of the
scientific methods available to characterize public
values and incorporate those values into goal-
setting and decision-making.
Community and national values have been
and will continue to be the primary driver of
community-level and national desires to protect the
environment. These values have led to laws that
provide the authority to address environmental
problems. Values also work alongside science, and
within the structure authorized by environmental
laws, to influence specific decisions about which
risks to control.
However, values usually are not weighed
transparently in the decision-making process. Rather,
they are usually implicit in the judgments made by
decisionmakers. Thus, they influence decisions in
ways that are not clear to, or reviewable by, the
public. They operate in a kind of "black box"
hidden from the view of everyone but the immediate
decisionmakers.
Because public values undoubtedly help
shape environmental decisions, it is important to
understand and document their role in and influence
on decision-making. It is also important to elicit
public values systematically, differentiate values
from technical information as a pan of decision-
making, and include their effects on decisions as part
of the public record. In this way, value judgments
wiH be neither disregarded nor disguised. Just like
quantitative information, they will be clear, open,
reviewable elements of the decision-making process.
Public values are incorporated at several
points in integrated decision-making. The attitudes
and values of people affected by environ-mental risks
reflect concerns that must be considered when
environmental problems are defined for
consideration. Public values also must be considered
in setting goals for risk reduction. Communities must
understand the risks affecting them and the environ-
mental management actions intended to reduce those
risks, because widespread public support for
protective action is essential to success.
Procedures for incorporating public values
into environmental decisions require more than
simply gathering people. Public opinion regarding
environmental goals must be sought in a systematic
and unbiased fashion. These procedures are likely
time-consuming and complicated, but they are
essential for providing adequate public input.
Over the past several years EPA, as well as
many other agencies at all levels of government, have
made a greater effort to include stakeholder input in
their decisions. This proliferation of stakeholder-
based decision-making derives from the assumption
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that stakeholders reflect the interests and values of all
parties interested in environmental decisions,
including the sources of risk and the communities
that are exposed to them. Incorporating individual
and community values into environmental decisions
undoubtedly will strengthen those decisions, and
strengthen public support for them.
However, it is important to take care that
stakeholder values solicited systematically as part of
the response to particular environmental problems
really represent broad community values and
preferences and not simply the narrow interests of
vocal individuals or groups. In many cases, it will
not be adequate to convene meetings and invite
representatives of particular interested groups, and
then incorporate their preferences at face value. In
complex cases sophisticated techniques are necessary
to bring together an effective and representative .
group.
Community values should be solicited
systematically by social scientists and other
appropriately-trained individuals. The deliberative
processes that are used in arriving at decisions should
involve professionals trained in fields like consensus-
building and dispute resolution. A number of
organizations today are conducting research into
effective ways to elicit broadly representative public
values, and others are helping communities apply
these kinds of techniques in response to specific
local or regional environmental problems. EPA
should make more extensive use of existing expertise
in the areas of behavioral science and decision logic,
so a more complete representation of community
values is incorporated into the Agency's decisions.
Multiple types of deliberation can be used in
integrated decision-making. They can help elicit
public values and respond to public desires to be
involved in decisions that affect their lives. At the
same time, it is important to recognize that formal
deliberation may not be necessary in every case.
EPA should make clear to the public exactly in what
ways and to what extent community values affect its
decisions and whether formal deliberation has been
used in its decision-making For a more complete
discussion of the deliberative process, see the SAB's
Integrated Environmental Decision-making in the
Twenty-first Century (EPA-SAB-EC-99-^, Chapter
5).
EPA's experience with the methodical
solicitation of public values also will be useful at
other levels of government. Because EPA will
continue to be recognized as the environmental
leader at the federal level, the Agency should be
prepared to assist other agencies in communities and
states in soliciting public values. Therefore, EPA
should expand its efforts to make current techniques,
findings, and professional expertise available
wherever environmental decisions are made.
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RECOMMENDATION 7
THE NEED FOR NEW METRICS
EPA should identify, collect, and
disseminate scientifically-based environmental
metrics organized in new ways to support a more
integrated approach to managing environmental
risks.
. The transition to and effectiveness of
integrated, outcomes-based environmental protection
will depend to a large extent on the availability and
utilization of appropriate information in the area of
exposure, human health, ecological health, and
quality of life.
Current data collection efforts fall short.
For example, exposure variables are now collected
only at limited locations for short periods of time.
Human health data on non-fatal outcomes, such as
asthma, are not being collected except in a
rudimentary manner or at fragmented sites.
Ecosystem information being collected today is either
insufficient, inadequately organized and
disseminated, or focused on inappropriate endpoints
and/or scales.
Therefore, in order to support a more
integrated, goals-driven environmental protection
system, EPA needs to develop a systematic data
collection mechanism that more appropriately
describes exposure, human health, and ecosystem
health.
For example, in the area of ecological
health, EPA, in conjunction with other government
agencies and the private sector, should collect,
aggregate, and disseminate information that could be
used to characterize the current status of different
types of ecosystems such as wetlands, lakes, forests,
and grasslands (See Recommendation 8). This
information should include the extent to which each
ecosystem is exposed to and affected by the
cumulative impacts of non-chemical stressors such as
habitat conversion, habitat fragmentation, and
invasions of exotic species.
EPA also should help develop indicators of
ecological condition and sustainability to be used by
decisionmakers at the local, regional, and national
levels. These indicators would suggest the relative
health and productivity of different ecosystems
subject to different kinds and levels of stressors.
The Agency should keep in mind that this
information is needed to answer environmental
management questions. In this regard, the Agency
should review its current monitoring programs to
determine whether additional or alternative
parameters should be added, or additional analyses
conducted, to characterize ecological conditions and
sustainability better and to estimate more accurately
the costs and benefits of different options to protect
ecosystem health.
The human health data needed to evaluate
environmental effects include outcomes such as
reproductive performance, asthma, neurological
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deficits, behavioral changes, respiratory function,
hearing, vision, and any other health measures that
can be used to evaluate relatively short-term effects.
Data on confounding variables are needed. Meeting
this need is complicated by the fact that all medical
data systems are subject to issues of ethics and
privacy. Yet, to conduct surveillance on the links
between human health and environmental pollutants,
these data are necessary.
In addition, data on population exposures
must be measured and related to individuals by
residence either directly or through modeling. The
Agency needs to move beyond current exposure data
systems that usually are limited to a few monitoring
sites and, in some cases, to episodes of non-
compliance with environmental requirements which
does not allow determination of cumulative
exposures.
In order to better link human health effects
to environmental exposures, information systems
should contain not only exposure data for various
locations but also - to the degree consistent with
privacy rights data on the individuals who lived in
those locations at the time of disease susceptibility.
An example of data collection that provides such
relevant data is infant mortality records which, unlike
adult mortality records, are tied to the birth record
(here the baby's residence is noted on both the birth
and death record). Thus it is possible to identify
residential exposures for the first year of a child's
life.
As a first step, EPA could provide an
extraordinarily valuable service simply by beginning
to assess information needs and resources in an
integrated way. It will not be enough to pull together
in one office, or in one report, different sets of data
collected by different government agencies, federal
or state. There should be the possibility of
combining those data so as to paint a picture of
environmental conditions affecting specific places or
specific subsets of the population (See Rec. 8). In
some cases, the necessary data already exist; they just
need to be integrated better. In other cases, the right
kinds of data are not being collected at all. Integrated
thinking within EPA will help identify data gaps and
then fill them.
In short, EPA needs to support efforts to
coordinate the extensive, and largely fragmented,
data collection exercises already underway, and
determine what other data might be useful for future
evaluation of environmental effects. Then it needs to
strengthen its methods for disseminating that
information to environmental decisionmakers and the
public nationwide; e.g., the "report card" process
described in Recommendation 8. To guide its
efforts, EPA should ask: what information is needed
to make integrated decisions and then evaluate the
results of those decisions? Who needs that
information? Is it being collected today? Who is
best suited to collect it? How can EPA help
communicate such information to the public and
decisionmakers so they can use it effectively?
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RECOMMENDATION 8
ENVmONMENTAL REPORT CARDS
EPA should develop a system of "report
cards" to organize and disseminate information
on the status of ecological and human health and
the quality of life in order to assess the
effectiveness of its environmental decisions and to
guide future environmental management
One of the most valuable uses of
environmental data is to measure the results of the
actions society takes to reduce environmental risk.
However, even if such data did exist, through a
vigorous implementation of Recommendation 7, the
country lacks procedures for translating this
information into easily comprehensible assessment of
the overall conditions or evaluations of the impacts
of environmental decisions. The lack of widely
accepted and commonly used methods for evaluating
a) the state of our environment or b) the success of
national environmental protection efforts where
success is measured in terms of the overall health of
humans and ecosystems - is a serious shortcoming of
the existing.system. It has limited the public's ability
to link actions taken, and money spent, with tangible
improvements in their quality of life. This
shortcoming will be felt even more as environmental
issues become more complex and as the cost of risk
mitigation is scrutinized more intensely.
Regarding the status of the environment,
EPA should work with federal and state entities to
develop indicators of ecological and human health
conditions in our country. Such an overall
"environmental report card (ERC)" reflecting
cumulative impacts of decisions should be readily
comprehensible to the public and policy makers alike,
serving to galvanize them on action toward specific,
measurable goals.
The concept of a report card is also useful -
for evaluating the impact and effectiveness of
individual decisions made under integrated
evaluation systems; i.e., an environmental decision
report card (EDRC).
Information useful for measuring results -
for either an ERC or an EDRC - will be even more
important as a more integrated system evolves and
becomes outcome-driven. Integrated decision-
making will foster greater flexibility for both
government agencies and private companies as they
search for innovative ways of reducing the risks
posed by multiple sources to multiple receptors.
Because the overarching goal will be to reduce total
aggregate risk, isolated information on the emissions
of a particular pollutant or on a particular aspect of
water quality will fail to tell the whole story since
one or more parameters of environmental health can
improve while overall health declines.
New, more integrated information also is
needed so that the responsible program managers and
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institutions can be held accountable for the results of
outcomes-based decisions. Accountability for
program results, in terms relevant to improved human
health and ecosystems, is an essential part of any
effective management system.
Many current single-stressor risk
management strategies also measure progress against
pre-established goals - the management of criteria
air pollutants, for example. What differentiates the
measurement of progress in an integrated system is
the fact that many different, but interrelated, goals
may be set, including combinations of human health
and ecosystem goals. Determining which parameters
to measure, and then compiling those measurements
into a coherent evaluation, will be a formidable
challenge, and current programmatic evaluation
mechanisms do not appear adequate to meet it.
Fortunately, the technologies needed to
suppon this type of informational activity are
becoming available. Modem society now has the
technological capacity to generate, aggregate, and
widely disseminate vast quantities of information.
The time has come to use mat technological capacity
to satisfy more complex environmental information
needs.
Therefore, building upon
Recommendation 7, EPA should begin to collect,
aggregate, and disseminate data that will make up the
national ERC and individual EDRCs. This new kind
of reporting system, which evaluates the results of
integrated decision-making - an outcomes-driven,
not a process-driven, system will emphasize
outcomes and accountability. It will bring more
focus and discipline to EPA by expressing the
relationship between investments (measured in time,
money, or information) and results. It will help EPA
retarget its efforts to be more outcomes-based and
less procedure-based. It will help other federal, state,
and local agencies assess the results of their control
efforts. Finally, a well-designed, outcomes-based
information system will strengthen public support for
environmental programs, because people will see
how the expenditure of public and private funds
leads to measurable, tangible improvements in the
quality of their lives.
Such report cards will only be as useful as
the information contained within them. Therefore, to
assess progress toward environmental goals, the
report card should include information that
characterizes both the short-term and long-term
results of environmental protection activities.
Information on short-term results will help determine
1) whether outcomes-based risk reduction decisions
are being implemented as conceived, and 2) whether
these actions are producing the desired reductions in
stressor levels.
The information on longer-term results will
help determine whether risk management decisions
and the consequent reductions in stressor levels, in
fact, have led to the desired improvements in human
and ecosystem health and the overall quality of life,
outcomes that may be discernible only after years, or
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even decades, have passed. Such long-term results be accessible for use at the local and regional levels.
will be most valuable for determining whether 1)
goals have been met, 2) further actions are needed to .
control well-recognized stressors, or 3) new actions
are needed to control new stressors.
Information on short-term results is
important because it can give impetus to course
corrections that help achieve long-term goals.
Moreover, measures of short-term results enhance
accountability, in contrast to long-term results, which
will only rarely be useful in assessing accountability
constructively because of the time-spans involved. In
many instances the measurement of an early marker
of health or environmental improvement will be the
most effective way of judging risk reduction results
in the short term.
To strengthen their credibility and
usefulness, report cards should contain information,
whether related to short-term or long-term
environmental conditions, that is derived in a clear
and methodical fashion from objective
measurements. Whenever expert judgment is
required to aggregate information, the method of
aggregation should be laid out explicitly so that the
public can better understand it. Clear documentation
also will help assure continuity over time, so report
cards can be compared from one decade to the next.
Finally, the report cards should provide an
aggregated source of information measuring progress
toward both specific and broad societal goals, and the
data sets on which the report cards are based should
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RECOMMENDATION 9
EVOLVING PARTNERSHIPS
EPA should expand and develop new
collaborative working relationships with other
federal and non-federal governmental agencies
and others who also will be involved in integrated
environmental decision-making.
The sources of environmental risks arc not
always located where the effects are manifested. The
risks considered most serious, and most amenable to
reduction, vary from place to place. Similarly,
environmental protection goals vary from region to
region and from place to place within a region. For
some problems, the most effective risk reduction
strategies will depend on local or regional
circumstances. For all these reasons, one of the most
valuable aspects of integrated environmental
decision-making is its capacity to be applied in the
geographic area, at the level of government, or by
non-governmental or private sector entities most
appropriate to the problem at hand, where the relative
seriousness of different kinds of risks are most
apparent, and where the inevitable tradeoffs between
the costs and benefits of environmental protection
can be made. Simply stated, integrated evaluation of
and response to environmental problems allow those
responsible to match the scale and location of
environmental actions to the scale and location of the
problems being addressed.
In some cases, decisions may be most
effective when local or state governments, non-
governmental groups or the private sector plays the
primary role. In others, coordinated action across
several levels of government or among a number of
state and/or local governments or groups may be
required. In still others, the current emphasis on
centralized decision-making within the federal
government may be the preferred approach. In any
event, integrated thinking about environmental
problems will tend to drive decision-making to the
agency, to the level of government, or to other
entities or multiple agencies where decisions are most
appropriately made.
Thus, the expanded use of integrated
decision-making will shift the roles played by
different agencies, groups, or levels of government.
It also will change cooperative relationships across
agencies and levels of government. Local entities
may play a larger role, for example, in determining
the range of actions that could be taken to reduce the
environmental risks facing a particular community or
ecosystem. In such cases, decision-making
responsibility at the state and local levels may be
expanded.
These changes in the roles of responsible
institutions do not mean that an overarching federal
presence is no longer necessary, or that EPA's role
will be diminished. Rather, the Agency's role will
evolve to one in which depth of control gives way to
broader involvement in partnership with others.
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There will continue to be a national interest in local
issues and decisions and their net effect on the
national level. EPA will continue to be responsible
for implementing and enforcing federal
environmental laws and regulations. Even in a fully
mature, fully integrated system, some environmental
risks undoubtedly will be controlled most effectively
through direct action at the federal level. Also, the
Agency will continue to conduct research and
development, and carry out stressor-specific risk
assessments, that will be valuable across the country.
But EPA's role sometimes will be different
within an integrated system from what it has been
historically. At times, the Agency will participate in
integrated risk decisions where the federal
government is only one of several cooperative
decisionmakers. In these cases, EPA will be
responsible for ensuring that risk management
systems put in place in specific communities or
ecosystems provide a basic level of protection.
Perhaps most importantly, EPA will play an essential
leadership role through encouragement and
assistance to decisionmakers at the local, state, and
regional levels by providing them with information
that helps them fulfill their responsibilities more
effectively.
EPA also should continue to provide
leadership among the other federal agencies whose
environmentally related activities are expanding.
"Reducing Risk" discussed the growing importance
of other federal agencies in managing environmental
risk, and recommended that EPA work to ensure mat
environmental considerations be included within the
policy frameworks at other federal agencies whose
activities affect environmental quality. That
recommendation is as relevant today as it was in
1990. Many risk reduction options involving
multiple stressors and/or multiple receptors will
likely involve actions related to EPA's mission but
they will also require involvement of other agencies
in areas such as energy development or use,
transportation systems, land use, forest management
and timber harvesting, housing, farm management
practices, and education - to name just a few. In
each of these areas, federal agencies other than EPA
have primary responsibility at the national level. In
short, in order to reduce today's most serious
environmental risks, more extensive coordination and
cooperation among different levels of government
will be needed, and the different agencies of the
federal government will have to better coordinate
their decision-making as well.
In summary, recognizing that human health
and ecological problems can have very serious long-
term consequences, including economic, the Agency
should take steps to ensure that the appropriate
agencies, private sector, and non-governmental
groups are involved in addressing these problems.
EPA can exert national leadership by bringing
together the appropriate local, state, and federal
stakeholders to begin exploring integrated solutions
to these serious problems.
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RECOMMENDATION 10
UN ADDRESSED RISKS
EPA should aggressively explore options
for reducing risks from significant stressors that
currently are addressed inadequately by the
nation's environmental institutions.
While the SAB was developing its
conceptual framework for integrated environmental
decision-making, it came to a troubling conclusion.
From the scientific perspective of the SAB, it appears
that a number of important human health and
ecological risks are not being addressed adequately
by the nation's environmental institutions.
Moreover, those inadequacies are likely to continue
without a broadly integrated decision-making system.
Throughout this project, the SAB had the
advantage, as non-EPA scientists, of exploring a
broader range of environmental risks than those
regulated by EPA. Many of these risks are being
inadequately addressed because risk management
responsibility either is not clearly assigned to any one
government entity, or responsibility is scattered over
many agencies and/or levels of government. This
fragmented approach results in uncoordinated and
incomplete efforts to identify cause and effect
linkages and to manage those risks.
Concern exists for inadequately addressed
ecological risks. The SAB's Ecological Risks
Subcommittee (ERS) assessed a wide range of
stressors affecting ecosystems nationally. Through
this exercise, several high-ranking risks were
identified (see Table 2). These risks are largely
associated with physical and biological, rather than
chemical, stressors, which - as in the case of many
human health stressors - do not fall clearly within
the purview of any single federal agency.
Responsibility for these stressors often is fragmented
across a variety of federal, state, and local agencies.
Sometimes the physical stressors have an
international dimension, suggesting that risk
reduction actions at the multi-nation level will be
necessary.
For example, three types of physical
stressors habitat conversion (such as building a
housing tract in a grassland), hydrologic alteration
(such as damming or diverting water or .draining
Table 2: High-Ranking Ecological Risks'
(National Scale)
Hydrologic Alterations
Harvesting Living Marine Resources
Habitat Conversion
Climate Change
Introduction of Exotic Species
' Assuming compliance with existing regulations
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wetlands), and habitat fragmentation (the partial
disruption of ecosystems by dividing them into
smaller pieces by roads, fences, or land use changes)
- pose especially serious risks to the nation's
ecological health. At the other end of the spatial
scale, the introduction of exotic (e.g., non-native)
species is disrupting many ecological systems around
the globe as organisms are transported from their '
native areas. Similarly, the increase in global
temperatures and related climate changes predicted
over the next century would have serious effects on
several types of ecosystems, particularly those
located in low-lying, coastal areas.
. The fragmented approach to responding to
environmental risks limits the ability to
systematically address many of these serious risks
affecting ecosystems and human well-being today.
Control of hydrologic alteration, for example, is
distributed among several layers of government
Although the physical stressors responsible for
habitat conversion usually operate - and are
regulated - at the local level, it is difficult for local
governments, by themselves, to find the expertise,
funding, or public support necessary to change
patterns of development whose ecologically ,'
destructive effects can only be seen at larger scales.
An environmental decision-making system focused
primarily on controlling individual stressors in the
environment, or operating primarily within a single
agency or a single level of government, will not be as
effective in reducing the risks posed by such wide-
spread, multi-faceted, and integrated stressors.
Concern also exists for human health issues
that remain unaddressed. One group includes
observed health effects that appear to be increasing in
incidence at a rate that suggests causation by some
environmental agent, such as personal lifestyle
choices or from an environmental stressor. Several
examples of increasing rates of disease which have
caused concern in the health professions are asthma,
brain cancer, and non-Hodgkins lymphoma.
Another category of health issues for which
a coordinated response is needed is in the area of the
effect of environmental pollutants on susceptible
and/or compromised human populations. While
children have appropriately been identified as one
such population and a cross-agency response has
been launched, the full extent of the program has not
yet developed. Further, the needs of the fastest
growing segment of our population, the elderly, have
not been examined in relation to environmental
impacts and risks in this susceptible group.
.To control many of these inadequately
addressed risks will require the kind of integrated
decision-making system envisioned in this document.
An effective response will depend on a decision-
making system that is capable of evaluating complex
sets of stressors affecting multiple endpoints over
broad regions of the country. It will depend on an
improved scientificability to assess the current
overall health of humans and ecosystems and then
measure future changes in health status.
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Most of all, it will depend on a new kind of
integrated leadership. Although no single agency,
level of government, or other entity now has primary
authority to control many serious ecological and
human health risks, EPA is uniquely situated at the
federal levei to coordinate a combined effort When
serious risks are not being addressed effectively by
existing environmental institutions or decision-
making systems, the Agency has a responsibility to
inform the public about those risks and bring together
the appropriate federal, state, and local agencies, and
other institutions to explore ways of controlling them.
Further, it will be necessary to identify and develop
new kinds of risk reduction tools needed for
controlling national-scale problems like habitat
fragmentation, water diversion, and indoor air
pollution, and to assist in fully evaluating the costs
and benefits of different control options, including
difficult-to-monetize environmental benefits.
There are some hopeful examples in the area
of human health in which interinstitutional
cooperation has led to substantial advances in
managing environmental stressors that have resulted
in healthier conditions for human populations. In
these cases, collaboration among federal agencies,
various levels of government, and industry have
contributed to these advances. Such examples
include innovations in waste disposal, reductions in
emissions of environmental contaminants, and
introduction of safe industrial practices.
EPA should take the principles of integrated
environmental decision-making described in this
report and quickly take steps to address the root of
many of these outstanding risks to human and
ecological health. The Agency should be able to take
these steps without new legislative authority and
thereby help the country to develop risk management
actions that reduce the most risk in the most efficient
and effective way.
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