Establishing a Bureau of Environmental Statistics: More Data Collection and Analysis Would Greatly Enhance Our Ability to Set Policy and Measure Its Effectiveness

Article excerpt

In 2003, Rep. Doug Ose (R-Calif.) proposed the Department of Environmental Protection Act, which would elevate the Environmental Protection Agency (EPA) to a cabinet department and create within it a Bureau of Environmental Statistics (BES). Although cabinet status for the EPA may have symbolic or organizational advantages, the creation of a BES could prove to be the most meaningful portion of the bill, as well as an important development for future environmental policymaking.

Noting the weakness of available data describing the environment, in comparison to data available to other agencies in their own respective purviews, the bill would authorize the proposed BES to collect, compile, analyze, and publish "a comprehensive set of environmental quality and related public health, economic, and statistical data for determining environmental quality ... including assessing ambient conditions and trends."

Why do we need another bureaucratic agency collecting statistics? The overarching reason is that we simply do not have an adequate understanding of the state of our environment. In many cases, the network of monitors measuring environmental quality is insufficient in geographic scope. For example, in many cases our knowledge of national air quality is based on a few monitors per state; our knowledge of water quality is even weaker.

Of course, this easy answer begs the further question of why we need a better understanding of the state of our environment. There are at least three returns that will result from collecting environmental data, each of which could pay greater dividends with reorganization and investment.

The first return from a BES would be to improve our monitoring and enforcement of environmental standards. Environmental standards in the United States generally fall into one of three types: standards for production technology or other behavior, emissions, and ambient concentrations. Technology standards prescribe that a specific technology or technique be used in the production process (for example, a specific type of equipment at a factory or plowing practice for farmers). Emissions standards specify a maximum rate of pollution emissions from a source, per unit of time or output. When pollution emissions are concentrated at a discrete number of sources (power plants and large factories), both types of standards are fairly straightforward to enforce through inspections or monitoring. Ambient standards pose greater challenges. Ambient standards require that pollution, after dispersing from its source through the air and water, not surpass some specific level. For example, eight-hour average concentrations of ozone cannot exceed 0.08 parts per million on more than three occasions per year at any location. If concentrations do exceed this standard, they trigger technology-based standards and other rules for the region. In the case of air quality, counties and regions that fail to meet the ambient standards risk the loss of federal highway dollars, bans on industrial expansion, and mandatory installation of expensive pollution-abatement equipment.

The integrity of such a system depends on the network of monitors measuring ambient quality. Currently, many expensive environmental regulations, with serious consequences for businesses and local economies, are based on a limited monitoring network. One may well wonder if some areas that are above the ambient thresholds have escaped detection. At the same time, there is some evidence that other areas continue to be designated as noncompliant even when they seem to meet the ambient standards. Recent research by Michael Greenstone of the University of Chicago has shown that many counties remain in official noncompliance for sulfur dioxide standards, even though readings from the available monitors have shown compliance for many years. The catch-22 is that a county must prove compliance throughout its jurisdiction even if the monitoring network is inadequate to shed light on all areas. …