4


Sustainability Assessment and Management: Process, Tools, and Indicators

ELEMENTS OF SUSTAINABILITY ASSESSMENT AND MANAGEMENT

Embedded in the general Sustainability Framework recommended by the Committee on Incorporating Sustainability in the U.S. EPA is an approach to incorporating sustainability to inform decision making. It is called “Sustainability Assessment and Management” and is illustrated as Level 2 in Figure 4-1. This chapter describes the steps involved in this approach, beginning with a screening evaluation to determine whether to conduct the Sustainability Assessment and Management process and to determine the appropriate level of effort or depth of such an assessment. This step is followed by problem definition and scoping, which includes identification of options, preliminary scoping of the analysis, stakeholder involvement, and opportunities for collaboration. The next section describes a set of analytic tools that can be used in the Sustainability Assessment and Management process. The set of potential tools include risk assessment, life-cycle assessment, benefit-cost analysis, ecosystem-services valuation, integrated assessment models, sustainable impact assessment, environmental justice, and present and future scenario tools. This list is not meant to be comprehensive, nor will all of the tools be useful in all cases. The tools, however, are the types of tools that should be in EPA’s sustainability toolbox and are likely to be useful in some instances. Following the discussion of tools, the next topic is how to integrate the Sustainability Assessment and Management process into management and policy decisions. Integration into decision making involves summarizing the major results of the assessment in terms of a trade-off and synergy analysis that highlights impacts on important social, environmental, and economic objectives (Box 4-1). This step is followed by presentation of results to the decision makers.



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4 Sustainability Assessment and Management: Process, Tools, and Indicators ELEMENTS OF SUSTAINABILITY ASSESSMENT AND MANAGEMENT Embedded in the general Sustainability Framework recommended by the Committee on Incorporating Sustainability in the U.S. EPA is an approach to incorporating sustainability to inform decision making. It is called “Sustainability Assessment and Management” and is illustrated as Level 2 in Figure 4-1. This chapter describes the steps involved in this approach, beginning with a screening evaluation to determine whether to conduct the Sustainability Assessment and Management process and to determine the appropriate level of effort or depth of such an assessment. This step is followed by problem definition and scoping, which includes identification of options, preliminary scoping of the analysis, stakeholder involvement, and opportunities for collaboration. The next section describes a set of analytic tools that can be used in the Sustainability Assessment and Management process. The set of potential tools include risk assessment, life- cycle assessment, benefit-cost analysis, ecosystem-services valuation, integrated assessment models, sustainable impact assessment, environmental justice, and present and future scenario tools. This list is not meant to be comprehensive, nor will all of the tools be useful in all cases. The tools, however, are the types of tools that should be in EPA’s sustainability toolbox and are likely to be useful in some instances. Following the discussion of tools, the next topic is how to inte - grate the Sustainability Assessment and Management process into management and policy decisions. Integration into decision making involves summarizing the major results of the assessment in terms of a trade-off and synergy analysis that highlights impacts on important social, environmental, and economic objectives (Box 4-1). This step is followed by presentation of results to the decision makers. 53

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54 SUSTAINABILILTY AND THE U.S. EPA FIGURE 4-1 A framework for EPA sustainability decisions (level 2). New gure 4-1 Bitmapped BOX 4‑1 Biofuels Adopting a sustainability framework could help address the social, economic and environmental impacts of biofuel expansion and guide policy decisions oward t more sustainable energy supplies. Concerns over energy security, environmental impacts, cost, and availability led to the passage of the Energy Independence and Security Act of 2007 establishing an ambitious goal of producing 36 billion gallons of biofuels annually by 2022. Biofuels are a renewable energy source that can be produced domestically with potentially reduced environmental impacts compared with fossil-fuels. However, the push for biofuels preceded careful sustainability analysis, and the rapid expansion of biofuels production raised its own set of social, economic, and environmental concerns. The law also requires EPA to report to Congress every three years on the im- pact of biofuel production on the air, water, and soil quality; ecosystem health and biodiversity, and invasive and noxious plants. The reports are required to include a quantitative assessment of significant environmental changes associated with biofuels production. To date, EPA has not been able to complete a quantitative risk assessment of biofuel production because of a number of factors, including the significant data limitations, substantial uncertainties associated with the produc- tion and conversion of biomass feedstocks to biofuels, and a lack of consistency in biofuel production by region. Impact on food prices: In 2010, 38% of the U.S. corn harvest went to ethanol production. In 2010, total U.S. ethanol production was 13.23 billion gallons (RFA 2011) while U.S. corn production was 12.45 billion bushels (USDA 2011). To produce 13.23 billion gallons, assuming 2.8 gallons of ethanol per bushel of corn, requires 4.725 billion bushels, or 37.95% of total corn production. Some

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55 SUSTAINABILITY ASSESSMENT AND MANAGEMENT Finally, once decisions are taken and implemented there should be follow-up evaluation of outcomes on important dimensions of sustainability. The Sustainability Assessment and Management process should incorporate certain key features: 1. Comprehensive and systems-based: Analysis of alternative options should include an integrated evaluation of the social, environmental, and economic consequences. 2. Intergenerational: The long-term consequences of alternatives should be evaluated in addition to the more immediate consequences. 3. Stakeholder involvement and collaboration: Stakeholders should be involved throughout the process. The committee recognizes that the formal Sustainability Assessment and Management process can be quite involved and may require EPA to devote analysts blame recent high prices for corn and other crops, at least in part, on biofuel demand (Runge and Senauer 2007; Mitchell 2008). It is difficult, however, to separate out the impact of others factors on food prices, such as the impact of production costs, including high energy prices, weather-related poor harvests, and commodity speculation. Commercial viability: Biofuel production has been assisted by generous tax credits to refiners, currently $0.45 per gallon for corn ethanol and $1.01 per gallon for cellulosic ethanol, to make it commercially viable (PEW 2009). Environmental impact: A potential benefit of biofuels is lower life-cycle green- house gas emissions (Farrell et al. 2006; Hill et al. 2006; Wang et al. 2007). Yet, if biofuel expansion causes conversion of forests, wetlands, or native grasslands to croplands, the carbon debt from land-use change can take decades to centuries to repay (Fargione et al. 2008). Increased biofuel production can put pressure on l ocal water supplies and may lead to declines in regional water quality (NRC 2008a). Also, concerns about impacts of changes in land use include the potential negative impacts associated with the expansion of biofuel production on marginal lands and withdrawal of the land from the Conservation Reserve Program (NRC 2010). Biofuel production can also cause an increase in air pollution (Hill et al. 2009). A 2008 NRC workshop summary on this topic noted that future efforts in this area could include “creating a framework for assessing bioenergy production and biorefineries in the context of sustainability” (NRC 2008b, p.33). Both the United States (EPA 2010) and the European Union (CEU 2010) have requirements to conduct life-cycle assessments of biofuels, but this requirement has to date f ocused primarily on greenhouse-gas emissions and land-use change rather than the full suite of social, environmental, and economic impacts.

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56 SUSTAINABILILTY AND THE U.S. EPA significant staff time and resources to the task. A formal sustainability analysis could also take an extended time period to complete. Therefore, it is important that EPA carefully match the level and depth of the analysis with the scale and magnitude of consequences of the decision at hand. The Sustainability Assess - ment and Management process should be undertaken for major decisions that could have large impacts on multiple pillars of sustainability. Such an in-depth analysis should not be undertaken for routine or minor decisions, but a system - atic approach for addressing sustainability for such decisions could be desirable. The challenge is to match the intensity, detail, and scope of the assessment and management process to the decision needs. This point is discussed further in the screening evaluation section below. Screening Evaluation EPA has the discretion to decide what kinds of activities or actions to ad - dress in the Sustainability Assessment and Management process. Application of sustainability assessment tools, such as the risk assessment, life-cycle assessment, benefit-cost analysis, ecosystem services valuation, integrated assessment models, sustainability impact assessment, and environmental justice tools described in this chapter, can be applied to programs, policies, and projects; however, not all of them will necessarily require the application of these tools. The agency may wish to focus on major new rules, on complex and important emerging issues, or on making changes to relatively routine decision-making processes. The committee explicitly recommends that EPA develop a sustainability screening approach. There are examples of screening tools used by other governments and the private sector, but EPA will probably need to develop its own set of screening tools. The screening approach would first determine whether to undertake the Sustainability Assessment and Management approach for any particular program, policy, or project. If it is determined that this process should be undertaken, the screening tool could also provide some guidance on the appropriate analyti- cal tools to apply and on the appropriate degree of depth and detail of analysis needed. The screening tool should help EPA managers determine whether the full Sustainability Assessment and Management approach is needed. At the one ex - treme, narrow routine decisions may affect small geographic areas, such as the tens of thousands of permitting decisions on water effluent and air emissions that the agency makes or facilitates annually. For these types of decisions, routine processes have been established. It would be impractical and unworkable to make each of these types of decisions using the formalized Sustainability Assessment and Management approach. Instead, practices and guidelines could be changed so that over time the outcomes are more in line with agency sustainability goals. At the other extreme, the decision-making case may be fairly unique and have wide impact, such as whether to embark on a particular fuel strategy. Such policy

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57 SUSTAINABILITY ASSESSMENT AND MANAGEMENT decisions will have high impact for all three pillars—social, environmental, and economic—and involve a variety of statutes. Such decisions would probably benefit from the Sustainability Assessment and Management process, either led by EPA or other agencies where EPA has input. EPA may not be the lead federal agency but may be a collaborator, perhaps having an important role in articulating the health and environmental impacts. EPA may have a limited ability to affect the overall decision-making process but may be able to contribute adequately to consideration and analysis of the social/health and environmental dimensions, and potentially voice ways to approach consideration of trade-offs. Finally, other cases may involve repeated but wide-impact decisions (NRC 1996), such as a major expansion of a large refinery, the siting of a power plant, the re-registration of a major use pesticide, actions to address environmental justice issues in a heav - ily affected community, or a major new rule under the Clean Air Act. These types of high-stakes decisions have potentially large impacts on each of the pillars. They can pose a challenge for the analysis and process. Although any particular new problem may be similar to a previously addressed one, the new problem will likely be sufficiently different to require tailoring of the analysis or process to the specifics of the new problem. In addition, high-stakes decisions typically involve a varied group of interested parties with unequal impacts in terms of those that bear the burden versus those that benefit. Not all applications of the sustainability assessment tools need to be done at the same level of depth and detail. The distinctions made in administration of the environmental review process under the National Environmental Policy Act (NEPA) provide an example of adjusting the depth of the analysis to the scale of the problem. In addition to providing for categorical exclusions, the NEPA process provides for environmental assessments resulting in a finding of no sig - nificant impact (FONSI) or an environmental impact statement (EIS), requiring a much more elaborate analysis and review process (Council on Environmental Quality [CEQ]). (NEPA Regulations, 40 CFR Pt. 1501 [1978]). Varying assess - ments in the scope and depth of analysis according to the action being consid- ered has long been practiced in the field of risk assessment. A matching of the assessment process to meet the needs of the decision is often recommended as a way to improve the decision-making process (NRC 1996, 2007; IOM 2009). EPA’s task is to incorporate sustainability factors and tools—at an appropriately selected level of detail—into existing or new decision-making frameworks so that a multidisciplinary, systematic, and long-term look at the three pillars of sustainability is assured. Screening is particularly important to avoid undue delays in taking action in the face of environmental problems. A quick scan process can be applied to determine the need for sustainability assessment tools. The quick scan process can determine whether the project is sufficiently large to establish a presumption of possible impacts on one or more pillars of sustainability, to determine the range and magnitude of potential impacts, and to identify which pillars will have large

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58 SUSTAINABILILTY AND THE U.S. EPA potential impacts. When impacts are likely to be small and the Sustainability Assessment and Management process is not needed, then a library of best-practice techniques and technologies should be consulted and compared with the proposal. Check lists or impact matrices are often used for screening purposes. The program or project initiative can be broken down into a number of components that can be assessed against social, environmental, and economic criteria of sus - tainability. For example, in the Swiss assessment process, screening is based on a number of preset social, environmental, and economic criteria (OECD 2010). A rough judgment is made about the causal relationships between the project and the various dimensions of the criteria, and then relevance scores ranging from 0 to 3 are assigned without regard to whether they are positive or negative. A judgment is made on whether there are moderate impacts and potential conflicts between at least two of the pillars (OECD 2010). If both of those conditions are met, then further analysis is needed. How to integrate results from the sustain - ability screening is discussed further below. Problem Definition and Planning and Scoping EPA is engaged in a wide variety of activities as part of its statutory mandates and its initiatives to protect human health and the environment. Specific problems outside EPA’s usual activities can also arise, for example, through congressional action, requests for assistance from state or local governments, acts of nature, or terrorism. At the early planning and scoping stage, project managers and analysts diagnose the issue or problem to be addressed. Upfront review of the nature of the problem, credibility of the science, and the decision and legal context helps in considering the nature of the assessment and decision process (Goldstein 1993; NRC 1996, 2007) and whether to embark on a formal or semiformal Sustainabil - ity Assessment and Management approach. An important early step in the process is to identify alternative decisions that could be made (options identification) and to scope the important social (including health), environmental, and economic pillars that could be potentially affected by the decision. Once attention has been applied to problem definition and identification of alternative options, managers and analysts can begin to develop provisional ap - proaches for the assessment process and the analysis. The Sustainability Assess- ment and Management approach should begin to develop provisional plans about the level and depth of analysis; the level, extent, and timing of stakeholder engagement; indicators by which they will judge the decision outcomes and pro - cess; and collaborative opportunities to explore the range of potential solutions and approaches. To be successful, the overall sustainability process will probably involve a high degree of collaboration, including federal partners, state and local governments, as well as the private sector, nongovernmental organizations, and other stakeholders (NRC 1996, IOM 2009). The levels of information gathering,

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59 SUSTAINABILITY ASSESSMENT AND MANAGEMENT analysis, and stakeholder involvement for actions that are made subject to the Sustainability Assessment and Management approach will vary depending on the significance of the action and the needs of the decision process (NRC 1996), as discussed in the screening section above. Another component of the problem definition and scoping process is to select indicators and associated metrics by which to judge success. These metrics can focus on accountability at varying levels of detail and can be directed toward dif - ferent organizational levels, for example, (1) individual management units within the agency (metrics to show progress toward sustainability goals for program or regional offices), (2) Office of Research and Development (ORD) (a focus on metrics to assess whether the research funded portfolio for ORD is leading to more sustainable solutions to environmental problems), (3) EPA in general, and (4) multiagency collaborations or the United States as a whole (metrics of sustain- ability regarding overall “performance” of the United States or even the world). Application of Sustainability Tools To incorporate sustainability effectively within EPA and to achieve external adoption in various sectors, EPA will have to make use of a variety of assessment tools. EPA will need to develop a set of tools or models that can be used to quan- tify impacts on important, social, environmental, and economic indicators that might be affected by the program, policy, or project under evaluation. Such tools can provide a uniform and transparent basis on which to evaluate alternatives. The broadening of the analysis from environment and human health to sustainability means that instead of or in addition to risk assessment, additional economic and social factors will need to be considered. This process also means that EPA will need to adopt, develop, or modify a set of tools to conduct such analyses that go beyond traditional risk assessment. A large number of tools can be applied to address component parts of an analysis. Typically a comprehensive analysis will require the application of a suite of tools. Several principles are important in applying this suite of tools: • No single tool is likely to be comprehensive; a comprehensive analysis will probably require application of a suite of tools to analyze impacts on social, environmental, and economic pillars of sustainability. • The suite of tools should include dynamic analysis that analyzes the consequences of alternative options through time (intergenerational component). • Tools should be capable of delivering quantitative assessments of im- pacts to the greatest extent feasible. • It is desirable to have relatively transparent methods that can be easily explained and where the results of the analysis can be effectively com - municated to decision makers.

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60 SUSTAINABILILTY AND THE U.S. EPA • Data availability will, in part, determine the necessary tool. • Uncertainty and sensitivity analysis will be required. Overview of Selected Sustainability Tools A large number of existing tools can be usefully applied in the Sustainability Assessment and Management process. A small subset of the most appropriate tools, including risk assessment, life-cycle assessment, benefit-cost analysis, ecosystem services valuation, integrated assessment models, sustainability impact assessment, environmental justice tools, and present and future scenario tools are described below. This list is not intended to be a comprehensive list of potential tools but rather a brief review of some important assessment tools. Risk Assessment Risk assessment is a tool widely used for characterizing the adverse hu - man health and ecologic effects of exposures. Classically, risk assessments for human health endpoints involves four major steps: a hazard identification, dose- response assessment, exposures assessment and risk characterization (NRC 1983, 1994, 2009; EPA 2005). In the hazard identification step a determination is made about the type of effects potentially caused by the environmental exposure. In the dose response step, the level of exposure such as dose or air concentra - tion is related to the level of adverse effect, such as the incidence of a health effect from an environmental exposure. The exposure assessment characterizes elements of the exposure, for example its intensity, frequency, and timing. The risk characterization combines the dose response and exposure assessments to produce descriptions of the risk for the variety of adverse effects determined in the hazard identification step. In this last step, the uncertainty in the description is also characterized along with variability of the effects in those exposed. For example, a risk assessment may include predictions of the increased incidence of cancer from an environmental chemical exposure in the general population or highly exposed groups or of the margin between the environmental exposure and that causing a noncancer effect seen in the laboratory or in human studies. Ecologic risk assessments evaluate the likelihood that ecologic effects result from environmental exposures to chemicals and other stressors (EPA 1998a). EPA has numerous documents that provide guidance, explain practice, and give opera - tional approaches for specific programs to conduct human health and ecologic risk assessments (EPA 1991, 1996, 1998a, 2000, 2005). A wide variety of analytic approaches and tools are used in conducting a risk assessment. Risk assessments are important inputs into the process of establishing environmental regulations, cleanup levels, and permitting industrial facilities. An important consideration in any sustainability action is whether environmental or human health will be better or worse off if an action is taken, both near term and

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61 SUSTAINABILITY ASSESSMENT AND MANAGEMENT in future generations. It is also important to understand not just the direction but also the magnitude. However, it is not always possible to approach these ques- tions quantitatively. Complexity or lack of knowledge may limit the reliability and usefulness of quantitative risk descriptions, but systematic approaches can produce useful qualitative descriptions that can inform decisions. Early on, the NRC (1983) recognized that risk assessments could not always be quantitative, and most recently, the NRC (2009) emphasized the need for tools for fuller characterizations of cumulative risks, including qualitative ones, that adequately account for the full range of chemical and other stressors, particularly for envi- ronmental justice contexts. Such risk descriptions could be useful inputs for sustainability decision making. In addition, risk assessment tools for facilitating green chemistry evaluations are needed as green chemistry will continue to be an important component of mitigating human health and environmental risks (NRC 2005a, b). Chapter 5 contains a more detailed discussion of risk assessment. Life-Cycle Assessment Life-cycle assessment is a “cradle-to-grave” analysis (or “cradle-to-cradle” ([McDonough and Braungart 2002]) of environmental impacts from produc - tion, use, and eventual disposal of a product. Life-cycle assessments are used to analyze the major environmental impacts of various products, to determine how changes in processes could lower the environmental impact, and to compare the environmental impacts of different products (Blackburn 2007). Life-cycle as - sessments are already used by EPA and have been used to compare the environ - mental impacts of transportation fuels and specifically to judge whether biofuels meet requirements for carbon-emissions reductions relative to fossil fuels (EPA 2009). Life-cycle assessments take a systems perspective to include the whole production process, from production of raw materials to eventual disposal and is therefore consistent with, and often an essential component of, sustainability analysis. Life-cycle assessments require a large amount of data on necessary inputs, outputs, and various types of environmental emissions of processes. The availability of standardized economy-wide input-output coefficients for ready use simplifies this challenge. Other challenges with applying life-cycle analysis in a sustainability context involve decisions on where to set system boundaries and what to assume about future technologies. Benefit-Cost Analysis Benefit-cost analysis is a widely used tool from economics to evaluate the net benefits of alternative decisions. Benefit-cost analysis seeks to assess the change in welfare for each individual affected by a policy choice, measured in a com- mon monetary metric, under a set of alternatives. Most benefit-cost analyses then aggregate the measure of individual net benefits to find a social net benefit and

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62 SUSTAINABILILTY AND THE U.S. EPA then rank the alternatives. There have been concerns that benefit-cost analysis as commonly applied to environmental issues places too much emphasis on the economic costs and too little on benefits and their distribution (OECD 2006). Recent developments in benefit-cost analysis as applied to environmental issues can be used in an attempt to ensure that the full range of benefits and costs can be taken into account better. These developments include, for example, integrating life-cycle analysis into benefit-cost analysis, having improved methods of esti- mating the value of ecosystem services, and paying close attention to distribution of benefit and costs across different groups in society to address environmental justice concerns (Pearce et al. 2006). Of particular concern for sustainability analysis is the weighting (discount - ing) of benefits and costs that accrue to future generations compared with those that accrue to the current generation (intergenerational equity). Although dis - counting will account for the costs to present generations of providing protec - tions, opponents of benefit-cost analysis perceive discounting as inconsistent with an environmental law’s forward-looking premise because the standard technique of constant exponential discounting can have a potentially large adverse effect on the perceived benefits—such as protecting against long-latency diseases like cancer—that aim to prevent future harm (Harrington et al. 2009). For further discussions on alternative discounting methods, see Pearce (2006); with specific reference to the use of discounting in climate policy, see Nordhaus (2007) and Stern and Taylor (2007). Such issues will need to be addressed in sustainability analyses that use benefit-cost analyses. Ecosystem Services Valuation Ecosystem services are goods and services that contribute to human well- being and are generated by ecosystem processes. For example, ecosystems can filter contaminants to provide clean water for human use and modulate water flow, reducing the probabilities of flooding and providing higher flows during drier periods. Ecosystem-service valuation is an attempt to measure the relative benefits of ecosystem services in a common metric (usually a monetary metric). Ecosystem-services valuation requires integration of ecological and other natural sciences (EPA SAB 2009). It is used to better understand the provision of services as a consequence of the state of the ecosystem (“ecologic production functions”) along with economics and other social sciences to gain an understanding of how nature contributes to human well-being (“valuation”). Ecosystem-service valuation measured in money terms can be used in benefit-cost analysis to capture a more complete picture of the net benefits of alternative actions. Economic valuation methods for ecosystem-service valua - tion are well described in both NRC (2005a,b) and EPA SAB (2009). EPA SAB (2009) also reviewed a number of other noneconomic approaches to valuation. For sustainability analysis, what is of most interest is how the value of ecosystem

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63 SUSTAINABILITY ASSESSMENT AND MANAGEMENT services will probably change through time. Notions of sustainability can be as - sessed through an evaluation of the value of natural capital and other forms of capital assets (including manufactured capital, human capital, and social capital). The value of natural capital is the contribution of an attribute of an ecosystem to present value of the flow of services through time. de Groot et al. (2002) also provided a conceptual framework and typology for the classification, description, and valuation of ecosystem goods, functions, and services. Integrated Assessment Models Integrated assessments cross disciplinary lines to merge theory and data from multiple disciplines to address complex environmental issues. Modeling is the standard tool used for conducting an integrated assessment. Integrated assessment models, such as the Global Change Assessment Model (GCAM), arose in the study of climate change, bringing together global circulation models and economic models to assess the probable benefits and costs of alternative energy- and climate-policy choices (Hannam et al. 2009). Although typically not called integrated assessment models, models used for ecosystem-services valua - tion are also examples that integrate models from multiple disciplines to assess the benefits and costs of alternative policy choices. The strength of integrated assessments is that they combine knowledge from multiple disciplines needed to understand how human actions might affect the system in important ways (e.g., greenhouse gas emissions and the climate system). Integrated assessments often take an expansive and long-term view, which is suitable for sustainability analysis. Integrated assessment models are often complex, tending to make them nontransparent to nonexperts. Furthermore, outcomes can be sensitive to model- ing assumptions for that might have inadequate factual bases for clearly deter- mining the right assumption to use. Still, integrated assessment models will often be needed to understand the relationships among the social, environmental, and economic pillars of sustainability in the context of a particular decision. Sustainability Impact Assessment Sustainability impact assessment is used to analyze the probable effects of a particular project or proposal on the social, environmental, and economic pillars of sustainability. This assessment is also used to develop integrated policies that “take full account of the three sustainable development dimensions” and include the “cross-cutting, intangible and long-term considerations” of those policies (OECD 2010). Sustainability impact assessment is used in many European coun - tries and in Canada but has not been used to any great extent in the United States (Zerbe and Dedeurwaerdere 2003). Sustainability impact assessment is modeled on, but different from, environmental impact assessment, which was pioneered in the United States through the National Environmental Policy Act of 1969 and

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68 SUSTAINABILILTY AND THE U.S. EPA Decisions Taken and Implemented A series of briefing documents at a depth appropriate to the decision would probably be prepared to inform the decision making. The range of options and the associated social (including health), environmental, and economic impacts for each option would be presented along with any trade-off analyses that may have been undertaken. As is the case with alternatives analysis under NEPA, options in a sustainability assessment allow the decision maker to understand different ways of taking a particular action and thus provide the decision maker with more choices to reduce adverse impacts. In addition, options in a sustainability assess - ment allow the decision maker to find better ways of improving social well-being, economic development, and environmental protection at the same time. Options also make clearer the causes of any trade-offs among the three pillars and help the decision maker to reduce the adverse effects of any trade-offs. Questions could arise that would require some additional analysis as well as follow-up with vari - ous stakeholders and collaborators. Evaluation of Outcomes An important component in communicating the potential benefits of adopt- ing sustainability and justifying further efforts directed toward sustainability is demonstrating the effectiveness of prior actions and providing the information to be used in the feedback loop to modify goals. Such work goes by such names as project evaluation, post facto evaluation, or accountability analysis (NRC 2005b). Evaluation is useful in identifying best practices, reducing uncertainties, and identifying additional linkages. Evaluation, like tools and indicators, is founded on having the appropriate data. There is a significant literature on program evalu - ation, including methods for measuring program performance, including but not limited to Cronbach 1980, Chelimsky 1997, Vedung 1997, Stufflebeam 2001, and Posner 2004. At the first level, evaluation should compare the observed response of the indicator (or associated metric) to the project goals. Discrepancies should be evaluated to identify weaknesses in the assessment process, including the tools and data used. This evaluation can be assisted by identifying additional data to better characterize system linkages and responses in indicators other than those that are used to assess goals. An important question to address is whether the response was within the range of uncertainty estimated during the alternative options analysis. Planning for evaluation includes identifying additional data and tools that are critical in understanding the system at a level that the predictability of future similar projects or policies is improved. Given the transgenerational nature of many sustainability indicators and goals, the evaluation may need to be based on indicators that are longer term than those directly used in assessing how well a project or policy meets the stated goals.

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69 SUSTAINABILITY ASSESSMENT AND MANAGEMENT Identifying the most appropriate indicators can be driven by models; for example, sensitivity analysis can be used to quantify how system indicators will respond to perturbations (e.g., policies and projects). The dual role of sustain - ability indicators is to both measure and communicate the range of factors that are involved in the decision-making process. Indicators, generally, are measures of the system of interest and can be either directly observed or derived quantities. Sustainability Indicators Substantial work has been done on the subject of sustainability indicators internationally (see Hak et al. [2007] for a review of the state of the art in sustain- ability indicators), much of which EPA has been involved in. The corporate sector has also developed indicators and metrics for sustainable performance (Székely and Knirsch 2005). EPA’s new 5 year strategic plan calls for the development of additional indicators that will improve understanding of the integrated and complex relationships involved in maintaining human health and environmental well-being (EPA 2010). The plan envisions that the development of additional indicators will be useful in tracking changes in environmental justice, children’s health, and regional ecosystems, such as the Great Lakes. The plan also foresees development and use of indicators to advance the sustainable communities pro- gram. In preparation for EPA’s next report on the environment, a task force has begun work to identify indicators of sustainability and associated metrics. In general, the work on sustainability indicators has tended to rely on work already done to gather social, environmental, and economic data. Most sustain - ability indicators are transformations of these data, and the experts involved in the sustainability-indicator efforts have been guided by a need, not only for relevance, but also for practicality. The committee recognizes the need for EPA to identify indicators and indicator sets that can help it to take the opportunities that a sustainability approach presents both locally and globally (Box 4-3). In serving both a measurement and a communication role, indicators can be used to promote beneficial change and also identify potential threats to sustainabil - ity. Sustainability indicators differ from those developed to measure a specific outcome of a program, such as an air quality parameter, as they must be able to capture information across multiple factors. Sustainability indicators would synthesize and report on various complex areas, including social, environmen - tal, and economic aspects. For example, a well-known indicator for assessing health and well-being in developing countries is infant mortality, as this indicator can be used singularly to infer information about maternal health, behaviors, and economic conditions in a particular country. A sustainability indicator would also be actionable in that the agency can take practical steps to address fac- tors contributing to an indicator to attain sustainability goals. Although some sustainability challenges addressed in one region may overlap to some degree in another, there will also be distinct challenges in that region and, to that end

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70 SUSTAINABILILTY AND THE U.S. EPA BOX 4‑3 Indicator Attributes • Actionable—practical steps taken to address factors contributing to an indica- tor to attain sustainability goals • Transferable and scalable—adaptable at regional, state, or local levels • Intergenerational—The fair distribution of costs and benefits among different generations • Definable—simple to understand and easily communicated • Relevant—be relevant to actual or anticipated policies • Important—reflect an important aspect of the social, environmental, or eco- nomic pillars • Measureable—measure something of obvious value to the public and decision makers • Durable—long-term relevance sustainability indicators would be transferable and scalable and be adaptable at a regional, state, or local level. Because some sustainability goals may require long-term solutions, sustain - ability indicators would be applicable in the short-term but also intergenerational and usable in a long-term time frame. Inherent in sustainability is concern about intergenerational impacts, thus differentiating sustainability indicators from many commonly used environmental indicators that reflect the current state of the envi- ronment. One approach that can be used to address intergenerational dimensions is the use of “stock-and-flow indicators.” Stock-and-flow indicators address the availability of a resource and the rate of depletion or growth, and are thus more intergenerational; policy indicators are more applicable to assessing change over short periods of time (intragenerational) that can be attributed to policies. Use of stock-and-flow indicators will require multiagency cooperation. An issue with the stock-and-flow indicators is their complexity, and as such, their development is more difficult (NRC 1999). Assessing impacts across generations can compli - cate the quantification of an indicator and introduce additional uncertainty. Thus, one component of quantifying an indicator will also be assessing the related uncertainty. Further discussion of indicators can be found in Appendix E. Reporting EPA would benefit from systematically conducting and publishing results of sustainability evaluations of major decisions, projects, activities, and programs by using indicators that provide accurate, comprehensive, and reliable information. Stakeholders could be further engaged by publicizing the results of these evalua - tions, including not only successes but also lessons learned and areas where data are insufficient to draw a conclusion. Decision makers need to assure that proper

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71 SUSTAINABILITY ASSESSMENT AND MANAGEMENT stakeholder engagement has occurred and is part of final decisions. Following implementation, the effectiveness of the decision/action as well as verification of the impacts will need to be pursued. Some states (e.g., Michigan) require analysis and periodic reporting on emerging environmental and sustainability issues.1 Such reporting can serve as a kind of early warning system and enable public and private decision makers to address issues at an earlier stage than might be possible otherwise. EPA would benefit from this kind of analysis and reporting as part of future reports on the environment. EPA could also benefit from the practice of systematically docu- menting and providing public information about the sustainability co-benefits of its actions and decisions, including not only environmental benefits but also economic and social benefits. The object of this practice would be to educate the public about the links between environmental protection and human well-being, and to help the public understand the role that EPA has played and will continue to play in fostering sustainability. When quantitative description of such benefits is not possible or feasible, qualitative description of these benefits would be appropriate. The agency may wish to consider, at the regional and headquarters levels, regularly producing a sustainability report utilizing widely recognized indicators (such as the “Global Reporting Initiative”2). Consistent with Executive Order 13514,3 EPA would benefit from implementing an internal agency program to identify key sustainability indicators, implementing a tracking and reporting system to demonstrate progress toward the goals of more sustainable operational practices and benchmark performances against other federal or government agen - cies and private sector organizations. The agency is already required to report on the seven metrics of sustainability and energy performance described in the Exec- utive Order and recently produced a FY2010 OMB Scorecard on Sustainability/ Energy to document its performance (EPA 2011). Stakeholder Engagement and Collaboration Stakeholder engagement is generally cited as one of the essential elements of a sustainability approach (Feldman 2002). The Sustainability Framework out - lined in this report contemplates that EPA will involve stakeholders at appropriate times throughout the process. The Sustainability Assessment and Management 1 The Michigan Environmental Indicators Act (P.A. 1999, No. 195); Codified at Mich. Comp. Laws Ann. 324.2521. 2 The GRI is a “network-based organization that pioneered the world’s most widely used sustainability reporting framework. The Reporting Framework sets out the principles and Performance Indicators that organizations can use to measure and report their economic, environmental, and social performance” (GRI 2011). 3 Executive Order 13514, titled Federal Leadership in Environmental, Energy, and Economic Performance, sets sustainability goals for Federal agencies, including the need for improvements in environmental, energy and economic performance.

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72 SUSTAINABILILTY AND THE U.S. EPA approach has as a component the identification of stakeholders interested in a particular program or action during the scoping process after a decision has been made to perform some level of sustainability assessment. EPA has extensive experience with public participation activities, many of which are legal mandates, in its regulatory work. The sustainability assessments suggested here are not regulatory requirements, and their implementation presents a new opportunity to advance the state of practice of involving people in governmental decision making. FINDINGS AND RECOMMENDATIONS 4.1. Key Finding: The Sustainability Assessment and Management approach requires application of a suite of tools capable of analyzing the full set of cur- rent and future social, environmental, and economic consequences of alterna- tive options. Many tools already exist, and much activity is under way in the United States and globally to develop such tools. Some tools will need modi- fication or expansion to be appropriate and some new tools will need to be developed (p.60-65). 4.1. Key Recommendation: EPA should develop a “sustainability tool- box” that includes a suite of tools for use in the Sustainability Assess- ment and Management approach. Collectively, the suite of tools should have the ability to analyze present and future consequences of alterna- tive decision options on the full range of social, environmental, and economic indicators. Application of these tools, ranging from simple to complex, should have the capability for showing distributional impacts of alternative options with particular reference to vulnerable or dis- advantaged groups and ecosystems. 4.2. Finding: An important step in the Sustainability Assessment and Man- agement approach is an evaluation of present and future conditions to show that present decisions and actions are not compromising future human and ecologic health and well-being. Therefore, a requirement is to be able to forecast potential future conditions as a function of the decision option chosen, although there will always be some degree of uncertainty attached to the forecast (p.64-65). 4.2. Recommendation: EPA should identify potential future environmental problems, consider a range of options to address problems, and develop al - ternative projections of environmental conditions and problems. 4.3. Finding: The culture change being proposed here will require EPA to conduct an expanding number of assessments. Although EPA has been

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73 SUSTAINABILITY ASSESSMENT AND MANAGEMENT involved in state-of-the-environment and environmental assessments, it cur- rently does not have a formalized approach to conducting or participating in the analyses required in the Sustainability Assessment and Management approach. Thus, such assessments could readily miss sustainability concerns not typically considered in past environmental assessments, including social and economic issues and environmental justice (p.58-59). 4.3. Recommendation: The agency should develop a tiered formalized process, with guidelines, for undertaking the Sustainability Assessment and Management approach to maximize benefits across the three pillars and to ensure further intergenerational social, environmental, and economic benefits that address environmental justice. 4.4. Finding: Screening is often used in other OECD countries prior to undertaking full sustainability assessments; criteria examined include the magnitude of the activity and potential short-term and long-term conflicts between at least two dimensions of sustainability (p.56). 4.4. Recommendation: EPA should formalize a screening procedure for implementing the Sustainability Framework recommended by the committee. 4.5. Finding: Economic benefit-cost analysis as commonly applied to en- vironmental issues often does not adequately account for the full range of ecosystem benefits, take intergenerational considerations into account suf - ficiently, or take into account the distribution of benefits and costs among population groups (p.61). 4.5. Recommendation: EPA should continue to adapt its current method of cost benefit analysis for sustainability by, among other things, improving its estimates of the value of ecosystem services, extending its boundaries by incorporating life-cycle analysis, and better addressing intergenerational and environmental justice considerations. 4.6. Finding: Risk analysis as commonly applied to environmental issues often does not adequately account for the full range of human health and ecosystem risks, including cumulative risks, intergenerational considerations, and the distribution of risks among population groups. In addition, better methods are needed to support consideration of health and environmental effects for the green chemistry goal of safer products and more sustainable chemical usage (p.60). 4.6. Recommendation: EPA should develop a range of risk assessment methods to better address cumulative risk and intergenerational and envi-

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74 SUSTAINABILILTY AND THE U.S. EPA ronmental justice considerations and to support comparisons of chemicals as part of an alternatives analysis for green chemistry applications. 4.7. Finding: EPA and other organizations have developed and continue to develop environmental indicators; however, appropriately addressing sustain- ability in the decision-making process will require additional attention to economic and social issues, including environmental justice (p.69). 4.7. Recommendation: EPA should expand its environmental indicators to address economic and social issues in collaboration with other federal agencies to address economic and social issues, and consider adopting them and developing appropriate metrics to inform sustainability considerations for state and local actors. Where relevant, these indicators should allow for international comparisons and the rapid adoption and adaptation of best practices from other countries responding to the challenges of sustainability. REFERENCES Blackburn, W.R. 2007. The Sustainability Handbook: The Complete Management Guide to Achieving Social, Economic, and Environmental Responsibility. Sterling, VA: Earthscan. CEU (Council of the European Union). 2010. Communication from the Commission on the practical implementation of the EU biofuels and bioliquids sustainability scheme and on counting rules for biofuels. O. J. EU. C160:8-16 [online]. Available: http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:C:2010:160:0008:0016:EN:PDF [accessed Apr. 19, 2011]. Chelimsky, E. 1997. The coming transformations in evaluation. Pp. 1-26 in Evaluation for the 21st Century: A Handbook, E. Chelimsky, and W.R. Shadish, eds. Thousand Oaks, CA: Sage. Cronbach, L.J. 1980. Toward Reform of Program Evaluation: Aims, Methods and Institutional Arrangements. San Francisco, CA: Jossey-Bass. de Groot, R.S., M.A. Wilson, and R.M.J. Boumans. 2002. A typology for the classification, descrip - tion and valuation of ecosystem functions, goods and services. Ecol. Econ. 41(3): 393-408. EPA (U.S. Environmental Protection Agency). 1991. Guidelines for Developmental Toxicity Risk Assessment. EPA/600/FR-91/001. Risk Assessment Forum, U.S. Environmental Protec- tion Agency, Washington, DC. December 1991 [online]. Available: http://www.epa.gov/raf/ publications/pdfs/DEVTOX.PDF [accessed May 2, 2011]. EPA. 1996. Guidelines for Reproductive Toxicity Risk Assessment. EPA/630/R-96/009. Risk Assess - ment Forum, U.S. Environmental Protection Agency, Washington, DC. October 1996 [online]. Available: http://www.epa.gov/raf/publications/pdfs/REPRO51.PDF [accessed May 2, 2011]. EPA. 1998a. Guidelines for Ecological Risk Assessment. EPA/630/R-95/002F. Risk Assessment Forum, U.S. Environmental Protection Agency, Washington, DC. April 1998. [online]. Avail - able: http://www.epa.gov/raf/publications/pdfs/ECOTXTBX.PDF [accessed July 13, 2011]. EPA. 1998b. Final Guidance for Incorporating Environmental Justice Concerns in EPA’s NEPA Compliance Analyses. U.S. Environmental Protection Agency. April 1998 [online]. Available: http://www.epa.gov/compliance/ej/resources/policy/ej_guidance_nepa_epa0498.pdf [accessed May 2, 2011]. EPA. 2000. Supplementary Guidance for Conducting Health Risk Assessment of Chemi- cal Mixtures. EPA/630/R-00/002. Risk Assessment Forum, U.S. Environmental Protection Agency, Washington, DC [online]. Available: http://cfpub.epa.gov/ncea/cfm/recordisplay. cfm?deid=20533#Download [accessed May 2, 2011].

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