Critically Evaluating America’s
Pollution Control System
by Terry Davies
arly in 1994, researchers at RFF’s Center
Earguably
for Risk Management commenced what
is the most comprehensive evalu-
techniques for opening up the system as
citizen suits, regulatory negotiations (convening the key parties to negotiate a draft
rule), and the Toxics Release Inventory
(which makes public the amount of toxics
produced by individual facilities). Many
advances have been made in the science
and engineering of pollution control.
Nevertheless, our study shows that the
system is by nature fragmented. As a
result, resolving certain types of problems
is sometimes not simply difficult, but
fers of pollutants, and greatly reduces the
effectiveness of pollution control.
Beyond even these shortcomings, our
evaluation reveals more critical flaws. The
ation of the U.S. pollution control system
present system is focused for the most part
ever conducted. Our findings, which are
at the wrong targets, is very inefficient, and
reported in the newly published RFF book
is excessively intrusive.
Pollution Control in the United States:
The Wrong Priorities. Any gains in the effecEvaluating the System, point to a system
tiveness of policies and programs are holthat for all its accomplishments is deeply
low if the wrong problems are targeted. If
and fundamentally flawed. The need for a
one looks at what are the most serious
major overhaul, not simply more tinkering,
health or environmental risks, one will find
is imperative.
little or no relationship to our
This ambitious project, which
1970
current environmental regulatory
has involved the efforts of numer- Thousands
Short tons
short tons
1995
per year
per year
priorities. Comparing EPA and
ous RFF staffers, was initiated at
140,000
250,000
societal expenditures with health
the suggestion of the Andrew W.
and ecological risk rankings, we
Mellon Foundation and funded by 120,000
200,000
100,000
found a basic mismatch. Two topMellon and the Smith Richardson
150,000
ranking health risks that are at the
80,000
Foundation.
top of many experts’ lists—radon
The 336-page book that is the
60,000
100,000
and indoor air pollution—receive
result examines the major man40,000
50,000
minimal funding, while the highdates and functions of the
20,000
est expenditures on ecological
Environmental Protection Agency.
0
0
risks—oil spills and hazardous
Drawing extensively on an array of
SO2
Pb
NOx
VOC
PM-10
CO
-41%
-98%
6%
-25%
-79%
-28%
waste sites—go to problems that
government reports and similar
Emissions
do not even make it to most
data, it provides both a description
experts’ lists of the major risks.
of the system and an assessment of National Air Pollution Emissions Trends, 1970–1995.
Source: U.S. EPA. National Air Pollutant Emissions Trends, 1900–
In water pollution, nonpoint
its flaws.
Office of Air Quality Planning and Standards Research,
sources pose the major problem,
The book examines and evalu- 1995.
1996.
yet the current system still focuses
ates the system using these criteria:
on point sources. Indoor air pollution is
whether the system has reduced pollution impossible. For instance, a recent report
the major health threat for most people,
notes that the air deposition of mercury in
levels; whether it has targeted the most
but the system focuses on outdoor air
important problems; whether it has accom- the Everglades is twenty-five to fifty times
pollution. These are two of the most egregreater than mercury discharges by water
plished its goals efficiently; whether it has
polluters. Yet the current regulatory system gious examples, but by no means the only
been responsive to a variety of social valones. Risk cannot be the only guide in
cannot deal with this situation effectively,
ues; how it compares with the systems of
setting priorities; other factors, such as
because our water pollution laws ignore
other developed nations; and how well it
cost, administrative feasibility, and fairness
altogether the possibility that some pollucan deal with future problems. The study
considerations, must be put into play. The
tants end up in water bodies via the air.
focuses largely, although not entirely, on
basic goal of the system, however, is to
The most important shortcomings of
federal environmental efforts.
the system are due to Congress, not EPA or reduce risk.
Strengths and Weaknesses
Inefficiencies. The inefficiency of the curthe states. It is Congress that has proliferatThe present system has done much to
rent control system goes beyond focusing
ed environmental statutes, failed to think
improve environmental quality. Laws and
on the wrong targets. The system discourthrough how they ought to interrelate,
regulations have reduced air pollution
ages preventing pollution and focuses
failed to set priorities, and perpetuated the
from automobiles and large point sources.
myth of freedom from risk. The fragmenta- instead on end-of-pipe treatment.
Creative policies such as emissions trading
Prevention is often preferable, both envition that results increases the costs of
have been developed, along with such
compliance, encourages cross-media trans- ronmentally and economically. The system
WINTER 1998 / ISSUE 130 RESOURCES 17
18 RESOURCES WINTER 1998 / ISSUE 130
Portugal
Italy
Spain
France
United Kingdom
Japan
Ger many
Canada
United States
places and economic sectors. It
also is excessively prescriptive,
$/gallon
would be integrated throughout,
telling sources how to control
$5.00
■ Gas
rather than being divided into
pollution instead of setting a goal
$4.50
■ Tax
separate air-water-land categories.
and allowing flexibility in how to
$4.00
It would be efficient, taking costs
meet it. There is ample evidence
$3.50
into account. And it would be
that the prescriptive approach
$3.00
more participatory and less coeradds large sums to the cost of
$2.50
cive. Aside from its fragmentation,
control, money that comes from
$2.00
the current system’s other great
taxpayers’ pocketbooks and that is
$1.50
failure is its lack of adequate sciennot buying anything.
$1.00
tific, monitoring, and social science
The costs of controlling pollu$0.50
information. A performance-based
tion are borne largely by the private
$0.00
system will need information for
sector. Direct EPA expenditures are
measuring performance.
a small portion of the cost. More
Possibilities for changing the
efficient EPA regulations, however,
present system are good, but those
could reduce costs paid by all
changes will probably not take
parties as well as reducing the
Unleaded Gasoline Prices and Tax Component, Selected
place as fast as is necessary. Many
intrusiveness of the control system. Countries, 1994.
Intrusiveness. The intrusiveness of Source: RFF calculations based on OECD Environmental Data: of the national environmental
organizations have come to be the
the present system not only works Compendium 1995, p. 230.
arch-conservatives on the matter of
against some of its own goals, but
How the System Might Be Changed
reform, opposing nearly all significant
also generates bitter public resistance. It
While making recommendations for
changes. Such a position will damage their
tells people what to do rather than providchange falls beyond the scope of our evalueffectiveness in the long run. Industry
ing incentives for them to take necessary
ation project, one can infer the characteristends to focus more on the bottom line,
action. Its recordkeeping requirements and
tics of a reformed pollution control system
and thus will need outside incentives to
other bureaucratic aspects can be onerous
from our findings. It would have to be
motivate compliance. But industry is far
and often are duplicative or otherwise
results-oriented, perhaps with EPA’s regufrom unified regarding environmental
unnecessary.
latory and assistance efforts focused on
policy: even similar large companies disDeveloping alternatives to these shortcomings is a major challenge to
agree about such basic issues as
whether to encourage decentralany reform effort. One major set Billions of
$1996
of remedies that has been proization to the states. The picture
45
posed is increased use of “market
of the principal stakeholders in
■ Air
40
■ Water
mechanisms,” using pollution
the pollution control system,
■ Land
35
taxes, marketable permits, and
then, is nearly as complicated as
■ Chemicals
■ Multimedia
deposit-refund schemes as ways
the system itself.
30
to reduce and control costs. The
As one who was involved in
25
United States has pioneered
environmental matters before
20
there was an EPA and when few
some of these mechanisms, such
15
outside of scientific circles had
as the trading of emissions
10
heard of ecology, I remain optirights, and Resources for the
mistic concerning reform of the
Future can legitimately claim to
5
nation’s pollution control system.
be one of the intellectual parents
0
EPA
Non-EPA
State
Local
Private
But there is clearly still a long
of market mechanisms. However,
federal
way to go.
many other countries make
Total Costs by Medium and Funding Source.
greater use of taxes as a way of
Source: U.S. EPA, Environmental Investments: The Cost of a Clean
curbing fuel use than does the
Terry Davies is the director of RFF’s Center for
Environment, 1990; Table 8-12A, p. 8-51.
United States.
Note: Present implementation cost of regulations, annualized at 7%. Risk Management.