Comparative risk

Initiated by the United States Environmental Protection Agency's (EPA) federal Comparative Risk Project in 1986, comparative risk projects by the end of the twentieth century, there were 46 projects underway. Furthermore, today the priority setting method had gained national attention as many members of Congress, federal professionals, and policy experts agree that environmental protection and public health agencies should, when setting priorities, consider the relative degree of risk their actions will reduce. However, while proponents tout comparative risk as a rational approach to making decisions about priorities, critics among national and grassroots environmental organizations believe that comparative risk ranking can be a "hard" technocratic approach that ignores non-risk factors in decision making, is "undemocratic," and is contrary to pollution prevention or the will of the people.

In the past, risk has not been factored into environmental priority setting and, as remarked by William Ruckelshaus, who twice served as EPA administrator, it "was hardly mentioned in the early years of EPA, and it does not have an important place in the Clean Air or Clean Water Acts passed in that period." But, building on Ruckelshaus's groundwork in comparative risk, EPA Administrator Lee Thomas helped thrust the concept onto the national agenda in 1986 when he asked 75 agency professionals to examine 31 environmental problems in the areas of cancer , non-cancer, and ecological risks as well as welfare effects (visibility impairment, damage to statuary from acid rain , etc.). In their 1987 report to Thomas, Unfinished Business: A Comparative Assessment of Environmental Problems, the professionals reported that, "Overall, EPA's priorities appear more closely aligned with public opinion than with our estimated risks." For instance, the EPA professionals regarded indoor air pollution and global warming as relatively high risks and contaminated hazardous waste sites as relatively low risk problems, while opinion polls showed that the public had an opposite ranking. In releasing the report, Thomas noted that EPA has finite resources and therefore must choose its priorities carefully "so that we apply those resources as effectively as possible" in reducing risks. The EPA report became the first significant study suggesting that national environmental priorities were inconsistent with the experts' sense of the most serious environmental problems, and instead the nation's priorities were guided by public perceptions of risk.

Concerns about the growing number of environmental regulations and problems demanding attention, coupled with the decline in resources to spend on these problems, kept up the pressure for EPA, states, and local governments to find a rational approach for deciding where to target finite resources. The publication of a report in 1991, Environmental Investments: The Cost of a Clean Environment, reinforced these concerns. That report was a first estimation of the costs that industries and municipalities must incur through compliance with federal pollution control programs. In 1991, costs were $115 billion a year—2.1% of the Gross National Product (GNP)—but were projected to rise to $185 billion or 2.8% of the GNP by the year 2000.

In late 1991, Senator Daniel Patrick Moynihan (DN.Y.) introduced a bill (S.2132) that would have required EPA to seek the advice of experts in ranking relative risks and to use that information in managing its available resources to protect society from the greatest risks. Moynihan's bill, and its successor in the 103rd Congress, became important elements of the debate over whether risk-based "rational" priority setting should be required to ensure more efficient risk reduction.

Even before the 1991 EPA report on the rising costs of environmental protection, EPA Administrator William K. Reilly had taken up comparative risk as a central theme of his administration and had asked the agency's Science Advisory Board to review the report issued by the 75 agency professionals. The board's response, a 1990 report called Reducing Risk: Setting Priorities And Strategies For Environmental Protection, also recommended that EPA and other government agencies "assess the range of environmental problems of concern and then target protective efforts at problems that seem to be the most serious." Far and away the greatest expenditures of EPA resources were directed at the agency's construction grants program for publicly owned wastewater treatment plants and the cleanup of abandoned Superfund sites—for instance, a full 70% of the agency's fiscal year 1990 budget of $6 billion went to these pro grams—even though other problems were deemed more serious from a scientific perspective. The science advisors also suggested that EPA should give more attention to the relatively neglected job of protecting ecosystems, which faced high risks from habitat alteration, loss of biodiversity , global climate change, and ozone layer depletion .

Reducing Risk, and the general topic of whether "Worst Things First" should be the touchstone of environmental priority setting, was debated at a November 1992 meeting in Annapolis, Maryland, at which critics challenged its "quasi-scientific" claims and offered competing priority setting approaches, including a strategy that would make preventing pollution the fundamental criterion for environmental policy decisions founded on the public's decision that pollution is undesirable. In the critics' view, comparative risk analysis presumes that some pollution and its risk is acceptable.

Skepticism notwithstanding, EPA chose to foster development of the method. As part of its endorsement of comparative risk assessment as an important priority setting tool, EPA promoted a series of comparative risk projects in several of its regions—Region 1, New England; Region 3, the Mid-Atlantic states; and Region 10, the Pacific Northwest—and in three pilot states: Washington, Colorado, and Pennsylvania. Later, Vermont, California, Utah, Michigan, and other states joined in. Sub-state entities also developed projects, including Columbus, Ohio; Atlanta, Georgia; Elizabeth River, Virginia; Houston, Texas; and Wisconsin tribes.

Typically, comparative risk projects follow six basic steps. First, they define and analyze the risks posed by environmental problems facing the jurisdiction, usually working from a list of problems. Second, they rank the problems according to the relative severity of each, using technical information and criteria to grade the negative impacts of individual problems on health, ecosystems, or quality of life. Third, they select priorities for special attention and set goals for reducing risks posed by the problem. Fourth, they propose, analyze, and compare strategies for achieving the goals set in step three. Fifth, they implement strategies having the greatest risk-reduction promise. And, sixth, they monitor results produced by the strategies and adjust jurisdictional policies or budgets based on those results. These steps are carried out through committees composed of state or local officials, industry representatives, environmentalists, and citizens. The projects all seek to broadly incorporate public values—not merely technical scientific information—in assessing and ranking risks.

Among the more widely cited state comparative risk projects is Washington Environment 2010, which, more than any other state project, influenced legislation and state policy. It was initiated in 1988 by Washington's Department of Ecology Director Christine Gregoire and included technical committees with members from 19 state agencies and a steering committee composed of senior managers or heads of those agencies. In addition, it had a public advisory committee composed of 34 prominent legislators, representatives, and important interest groups. Resulting from this project was a ranking of 23 threats to the environment within five priority levels. Ambient air pollution, point-source discharges of pollution to water, and polluted runoff ranked as the top priorities, and non-ionizing radiation, materials storage in tanks, and litter ranked as the lowest priorities. Based on the project, and a statewide effort to solicit public responses that produced some 300 risk-reduction options, Washington's legislature in 1991 adopted several new environmental laws dealing with clean air, transportation demand, water conservation , recycling , growth management, and the state's energy policy . The Department of Ecology redirected $6.8 million of its budget from lower to higher risk priorities. However, in 1993 Gregoire's successor reorganized the department, dismantling an Environment 2010 planning staff that had been established and, with it, the state's institutional memory of the comparative risk project. Washington's experience in this regard, and similar experiences in other states, have made some proponents of comparative risk assessment question how deeply and lastingly its effects will be felt in environmental programs.

Despite such setbacks, the comparative risk concept has continued to find a significant place in governmental discussions of environmental policy. In 1993, the White House of Science and Technology Policy and the Office of Management and Budget invited comparative risk analysis experts to meet with federal government officials to explore how the approach could be used by federal agencies to establish broad priorities more systematically. That effort resulted in a 1996 report, Comparing Environmental Risks: Tools for Setting Government Priorities, that proposed a basic framework for using the method in federal agencies. Furthermore, during the 104th Congress, comparative risk analysis was one of numerous risk-related reforms that were included in the Republican Contract With America and its agenda of reducing regulatory burdens through a downsizing of government, the most far-reaching attempt to impose a "rational" risk-based priority setting system on federal agencies.

While the future of comparative risk analysis as a basis for establishing environmental priorities remains uncertain, federal, state, and local interest remains strong. Today, most practitioners and proponents of the approach recognize that comparative risk alone will not suffice to establish priorities. Public values, hard to quantify benefits, and other non-scientific elements that must be weighed in decisions about priorities have a clearly recognized role. That conclusion has been reinforced in all the state and local projects. Some recent studies suggest that the future progress of comparative risk analysis requires more research on how to better inform diverse parts of the affected public throughout the process of setting environmental priorities. Even though federal legislation that would mandate comparative risk analysis as a basis for selecting priorities may never pass, the risk-based approach enunciated in 1987 has emerged today as a central piece of environmental policy and is explicitly discussed in EPA's draft Environmental Goals for America With Milestones for 2005, the latest federal effort to clarify and organize environmental priorities.

[David Clarke ]

RESOURCES

BOOKS

Davies, J. C., ed. Comparing Environmental Risks: Tools for Setting Government Priorities. Washington, D.C.: Resources for the Future, 1996.

Finkel, A. M., and D. Golding, eds. Worst Things First? The Debate over Risk-Based National Environmental Priorities. Washington, D.C.: Resources for the Future, 1994.

U. S. Environmental Protection Agency. Science Advisory Board. Reducing Risk: Setting Priorities and Strategies for Environmental Protection. Washington, D.C.: GOP, 1990.

U. S. Environmental Protection Agency. Office of Policy, Planning, and Evaluation. Unfinished Business: A Comparative Assessment of Environmental Problems. Washington, D.C.: GPO, 1987.