SETTING THE STAGE
The scene is the office of an environmental policy consultant who is also a professor at a top-ranking university. As we watch from the sidelines, the professor, hearing the phone ring, answers. We eavesdrop on the conversation.
Professor: Good Afternoon, Congressman Randolph.
Caller: Good Afternoon, Professor. As my assistant explained to you briefly, I have a small problem. I was hoping you could help me. Do you have a few minutes to talk?
Professor: Sure, of course.
Caller: As you probably know, there is increasing concern about the dangers to human health and the environment posed by chlorinated organics. In a speech I gave last week, I mentioned that it might be a good idea to ban or at least phase out all chlorinated organic compoundsāa view that is advocated by a range of environmental groups like Greenpeace and the International Joint Commission, a watchdog group for the Great Lakes. I wasnāt prepared for the flood of calls I got from industries in my district and constituents upset by my remarks.
Several chlorinated organics, including DDT, polychlorinated biphenyls (PCBs), and chlorofluorocarbons (CFCs), have been banned already or are being phased out. The use of chlorinated organic compounds is linked to increases in cancer rates and endocrine disruption, and they may pose serious risks to embryos and developing fetuses. But a host of arguments against phasing them out have appeared in scientific journals, the popular press, and political discourse. The comments Congressman Randolph heard might have included the following:
- There are nearly 15,000 chlorinated organic compounds used today in various industries including plastics manufacturing, solvents, pharmaceuticals, pesticides, and paper and pulp bleaching.
- A panel of Michigan scientists, convened to review the International Joint Commissionās decision calling for the phasing out of chlorinated organic compounds, found that there was āinsufficient scientific evidenceā to support the claim that chlorinated organic compounds produce environmental and health threats.
- Chlorine accounts for $91 billion of gross domestic product in the United States annually and, directly or indirectly, accounts for 1.3 million jobs.
- Banning an entire class of chemical compounds does not take into account the benefits that may be provided by their continued use.
The conversation continues:
Professor: Very interesting. It sounds like youāve gotten an earful! I agree; thereās certainly a wide range of opinions on this subject.
Caller: Well, thereās a lot more. Many of the people who called claimed that a ban on chlorinated organic compounds would be irresponsible and uninformed. My staff, though, keeps assuring me that thereās documentation to prove the dangers posed by these compounds.
I know that we need to balance various interests when reaching a decision on a contentious issue. And the well-being of my constituents, indeed of human health in general, must take precedence over everything else.
So, my problem is that I need credible support for the position I have takenāa position I believe in.
Professor: I see your point. Just how can I be of help?
Caller: I would like you to put together a report indicating that there really is scientific support for my position, namely, that the continued use of chlorinated organic compounds poses a risk to human health and the environment and that a ban or a phase-out makes sense.
Professor: Hmm. I am not sure I can help. And even if I could, Iām not sure thatās the right way to proceed. You have already come to a conclusion. If you simply need support for your position, then Iām not the person you need. Be aware, though, that such a report will probably not be any more credible than all the other reports, articles, and studies your staff has already looked at on the other side of the chlorinated organic compound debate.
In my view, merely commissioning one more advisory piece will just waste a lot of money. In addition, the results of such advocacy studies are often misappropriated or misunderstood, thereby making it even harder to get the real facts out.
Caller: So, Professor, what would you recommend that I do?
What should the congressman do? First, like any public official, heāll have to decide whether he is locked into a particular policy position before conducting a full-fledged environmental policy study. He needs to consider, for example, if he would support a ban or a phase-out if he learned that the risks to human health and the environment were minimal while the benefits to industry were enormous (in terms of jobs, availability of new drugs, etc.). Whether thatās the case or not, only the right kind of environmental policy study would leave room for that kind of counterintuitive result.
What should the professor do? We have often told callers such as the congressman that, if your mind is already made up, we canāt help you. No doubt the congressman could find some consultant happy to produce the report heās looking for. Our goal, on the other hand, is to craft studies that can be used as a basis for sound environmental policy making.
How can such studies be crafted in a charged political context like the one introduced by Congressman Randolph? That is the subject of this book. Among the principal points here is that conventional policy studies are often not up to the task. We begin by pointing out the shortcomings of the conventional approach to preparing environmental studies, particularly at the national level. We then offer a different approach, one that builds on what we think were the most useful environmental policy studies completed over the past few decades. These were studies identified by legislators like Randolph, along with government officials, industry representatives, environmental action groups, and others.
CONDUCTING POLICY STUDIES
Environmental policy studies may be undertaken in many different contexts. At the national level, a study might be requested by Congress when it is considering a new piece of legislation. Government agencies often conduct reviews of their rules and policies as a condition of their funding or in response to a request from the current administration. Regardless of whether the policy is to be carried out at the local, state, national, or international level, the issue may be highly charged, and the policy analyst may find it difficult to be heard among the competing interests at the table. The analyst must fulfill the terms of his or her agreement with the study sponsor (often one of the interests at the table) and yet remain independent and credible. The way in which the analyst factors these complications into study design often makes the difference between having an impact and accomplishing nothing at all.
Successful environmental policy studies help to shape the thinking of key policy workers and give them the confidence that they are doing the right thing, regardless of their initial thinking on the subject. Such studies share certain characteristics in that they
- define the problem in a helpful fashion,
- describe the full range of policy options,
- help to overcome agency resistance to change,
- provide opportunities for engaging interested stakeholders,
- enhance the legitimacy of whatever action follows, and
- facilitate setting resource allocation priorities.
In the case at hand, Congressman Randolph might think he needs only to enhance the legitimacy of particular actions. In fact, the other characteristics are equally important to him. Defining the problem correctly is critical. Is the problem of chlorinated organic compounds a problem of human health? Or is it one of jobs, economic growth, and broader societal benefit? Is it a combination of these factors? Or neither? Does it make sense to look at only one industry such as pulp and paper, or would it be best to look at all industries that use a particular chemical compound?
Second, the congressman thinks he has only two policy options: ban the use of chlorinated organic compounds, or do nothing. There may be other policy options he hasnāt considered. For example, it might make sense to do a risk benefit analysis for each compound before deciding whether to ban it.
Third, some agencies may already have positions on the issue. A good environmental policy study should be structured in a way that can soften agency resistance to change.
Fourth, there are a lot of stakeholders who will be affected by a decision concerning the use of the compounds. One goal of a good environmental policy study is to involve these groups in organizing the research effort.
As we have already discussed, there are many studies that have their basis in positions for or against the continued use of chlorinated organic compounds. Yet, as the calls to the congressmanās office indicate, these studies are viewed skeptically by people who donāt like the recommendations they contain. It is thus crucial that a study enhance the legitimacy of whatever policy recommendations finally emerge; otherwise, the policy study probably isnāt worth doing. On the other hand, if itās done right, a policy study can help set resource priorities. For example, should Congress spend money on a riskābenefit analysis for each chlorinated organic compound? Is it desirable to invest heavily in monitoring the impacts of these compounds in the decades ahead?
If the congressman is to have any hope of success, he must be extremely careful when assigning responsibility for the study or selecting experts to help. He needs to choose experts who enhance credibility and who bring a range of backgrounds to the issue. Experts also need to be familiar with parallel research efforts and be willing to seek peer review and advice.
Each consideration should play a role in deciding who should help with an environmental policy study. But there are other considerations as well. A second thing to keep in mind is how the study should be conducted. Options include:
- Engaging a major research organization
- Involving stakeholder groups
- Appointing a commission or task force
- Hiring experts directly
- Doing the study in-house (with a federal agency)
Then, of course, there is the question of how to interpret the study results. In other words, what institutional auspices will be used to analyze and interpret study results to ensure that the American people will learn the most from the study.
Caller: Okay, so what you are saying is that I need to address a series of organizational concerns. I suppose you cover these in your book?
Professor: Well, actually, yes. Look at the fifth chapter when you get the book. I go into some detail about the different tools and techniques of policy analysis. I compare the value of systems analysis, decision theory, and other new approaches to internal stakeholder participation in policy analysis. There may be someone on your staff particularly interested in this methodological discussion.
Caller: Good! At least youāre not expecting me to go back to school. Well, thatās a lot to think about. Iām not sure I can digest everything youāve said. However, I am interested in looking at the book.
Professor: Iāll have one in the mail to you this afternoon. Feel free to call if you or your staff have questions.
Caller: Thanks. Iāll be in touch. By the way, next time youāre in DC, drop by.
If we did give a course for members of Congress, we would use Chapter 6 of this book. It reviews the three basic sets of methods and their advantages and disadvantages:
- Analytical methods
- Rhetorical methods
- Process methods
They have all been used successfully in the past. When problems lend themselves to quantification, the analytical approach may be best. However, if the study is focusing more on possible changes in policy, a rhetorical approach, which focuses on persuasion or advocacy, may be more appropriate. Finally, process methods may be most appropriate when there are fewer stakeholders or where there is a need to build consensus among affected groups.
Our hope is that legislators like Congressman Randolph avail themselves of the real and meaningful contributions that a properly conducted policy study can make. But, as weāll see, that is not the only way a policy study can be sponsored and have an impact. As you read this book, continued reference will be made to the issues raised by Congressman Randolph about a possible ban on chlorinated organic compounds. While we do not offer a complete analysis of the policy options surrounding their particular issue, we try to show how and why a āgoodā environmental policy study on such an issue ought to be done.
