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Keeping Pace with Science and Engineering. 1993. Pp. 165-188. Washington, DC: National Academy Press. Acid Deposition James L. Regens C1S Attempts to link scientific, technical, and economic information to de- ions affecting the public sector have become a significant as well as contentious component of the policymaking process in the United States in recent decades. Even when high-quality information is available, barriers may impede its timely communication and use. Almost inevitably, when public policy choices are grounded heavily in scientific, technical, or eco- nomic data, much of the debate among contending sides involves conflict over whose information will become the more credible, and persuasive, in the political arena. The contention involved in accommodating scientific, technical, and economic information in the decision-making process also reflects the fact that our understanding of risks, benefits, and costs is not static but continuously evolves. Thus, it is always possible for new infor- mation to emerge that calls into question the previously accepted scientific, technical, or economic bases of regulatory choices. In a number of instances, environmental statutes incorporate explicit procedures for revising regulations to accommodate new data. The Clean Air Act Amendments of 1990 (P.L. 101-549), for example, provide a pro- cess for periodically revising the National Ambient Air Quality Standards; there are comparable mechanisms within the regulatory system that make it possible for administrative agencies to accommodate changes in existing knowledge after regulations are promulgated. Given concerns about the role that scientific, technical, or economic understanding plays in the rule- making process, it is useful to delineate the ways in which changing infor- mation similarly affects congressional deliberations about new legislation. 165

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166 JAMES L. REGENS The acid rain controversy provides an excellent case study of the potential for changing information to guide policy choices during congressional de- bates as well as the limitations of accommodation.) The acid deposition control program authorized by Title IV of the Clean Air Act Amendments of 1990 signaled the end to more than a decade of acrimonious debate. However, before these regulations were passed acid rain was one of the most prominent, complex, and divisive environmental research and policy issues of the 1980s (see Regens and Rycroft, 1988~. Both scientific knowledge and governmental policy were controversial. The controversy over science centered on how much information was needed to determine if acid rain was a threat and whether it could be prevented or mitigated. The policy controversy involved the appropriateness of alterna- tive responses to such a threat. A tremendous amount of research was conducted and the disagreement among interested parties was intense- especially the policy implications of research findings. What lessons can we learn from that experience that will improve the use and effectiveness of scientific and economic information in congres- sional policy debates? Can the lessons improve the effectiveness of large- scale interagency research programs as a mechanism for generating such information?2 The answers may be valuable in shaping timely and prudent responses to other major atmospheric pollution issues, such as global cli- mate change or stratospheric ozone depletion. OVERVIEW OF EXISTING INFORMATION Definition and Origin As a working definition, acid deposition, or acid rain as it is more commonly called, refers to the processes by which acidic substances, which are largely of man-made origin, are deposited from the atmosphere into ecosystems in precipitation or as fine dry particles. Acidity is measured on a logarithmic scale (pH) of 1 to 7, with 7 being neutral and acidity increas- ing as the numbers decrease toward 1.3 As shown in Figure 1, all forms of precipitation-rain, snow, sleet, hail, fog, or mist that have a pH value equal to or less than 5.6 typically are classified as acid rain.4 In fact, however, a review of deposition data in the existing literature suggests that the global average plI of precipitation in remote regions of the world is closer to 5.0, which appears to be a more appropriate cutoff point for "clean" rain. The "natural" value of precipitation pH probably varies from region to region depending on the climatology, local ecosystems, and other factors. Although the simplicity of the term acid rain conveys the image of an easily understood phenomenon, Figure 2 shows how the problem involves complex and varied chemical, meteorological, and physical interactions (see , ~ .

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ACID DEPOSITION Lemon Juice Mean pH of Adirondack Lakes - 1975 1 " Vinegar ~ ``Pure" Rain (5.6) \ \ \ 167 _ r . _ _ ~ L ~ ~ _ ~ _~ r~ ~ - ~. ~ = e ~ ~ F_d ~ ~ ~ ~ ~ ~ ~. ~ ~ ~ ~ ~A ~ ~ an ~ i Lo ~ _ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ l \ Mean pH of Adirondack Lakes - 1 930s Distilled Water l , i, , / Baking Soda L 1 r ~ ~ I I I 1 T 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Acidic FIGURE 1 The pH scale. Neutral Basic National Acid Precipitation Assessment Program tNAPAP], 1991a; National Research Council ENRC], 1983, 19861. Interestingly enough, the first sci- entific studies attempting to delineate the processes producing acid rain date back to the late 1800s (see Figure 3~. Robert Angus Smith's pioneer- ing studies of precipitation chemistry and its effects introduced the world to the term acid rain. Drawing on data measuring the chemistry of rain in England, Scotland, and Germany, Smith (1872) demonstrated that variation in regional factors such as wind trajectories, the amount and frequency of precipitation, decomposition of organic matter, proximity to seacoasts, and coal use influenced sulfate concentrations in rain. However, Smith's re- search was ignored for almost a century by both the scientific and policy . . communities. Research Efforts Serious interest in acid rain as a topic for scientific inquiry did not emerge until the early 1970s, and research throughout that decade empha- sized the contribution of sulfur compounds to acidification (see Cowling, 19821. Research that linked air mass trajectories to changes in precipitation chemistry (see Oden, 1968) provided the initial basis for concluding that acid deposition is caused by human activities and that it is a regional-scale environmental problem with long-term adverse consequences. The initial series of follow-on studies, primarily conducted by researchers in western Europe, concentrated on (1) delineating the effects of acid rain on aquatic

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ACID DEPOSITION Science and Engineering 1872 - Smith identifies acid rain Oden links aquatic damage to long-range transport of acid in precipitation Swedish case study asserts precipitation acidity causing adverse ecological and human health effects OECD atmospheric transport study reports long-range transport contributes to acid deposition Norwegian SNSF project reports damage to forests and fish NRC report concludes 50 percent reduction - of H+ ion deposition would ameliorate acidification of aquatic ecosystems U.S.-Canada MOI Work Group final report released NRC report concludes reduced SO2 emissions over a broad area for several years would produce roughly proportionate reduc- _ ion in average annual SO4 deposition EPA Draft Critical Assessment Review Papers released OSTP Peer Review Panel and OTA reports ~ conclude evidence supports least-cost SO2 emissions reductions 169 Policy and Regulation 1 870 19~5 1 960 1 965 I.., 1970 _l _ 1975 , . Air Pollution Control Act of 1955 provides first authority for federal government role to conduct R&D and provide training and technical assistance to states Clean Air Act of 1963 authorizes federal government to mediate state disputes over air pollution, if requested Air Quality Act of 1967 gives federal government authority to set criteria for health protection, create air quality control regions, and recommend control technologies Clean Air Act of 1970 gives EPA authority to set NAAQS, promulgate NSPS, and approve SlPs Clean Air Act Amendments of 1977 strengthen NSPS sections, provide special treatment for high-sulfur coal, include provisions for interstate or international transboundary pollution President Carter's environmental message to Congress :1980~ - U.S.-Canada MOI to negotiate an agreement on transboundary pollution Acid Precipitation Act of 1980 authorizes 1 0-year National Acid Precipitation Assess- ment Program to identify causes, effects, and severity of acid deposition as an environ- mental problem U.S. rejects Canadian proposal for joint 50 percent reduction in SO2 emissions FIGURE 3 Timeline of significant scientific, technical, and regulatory develop- ments in acid rain. (Figure continues on next page.)

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170 Science and Engineering - ICF's Coal and Electric Utilities Model and other simulation models indicate that magni- tude and uncertainty of control costs increase dramatically beyond ~10 million tons of SO2 - NRC report reviews existing scientific infor- mation on long-term trends - NAPAP National Surface Water Survey data indicate, except in high-elevation watersheds, lake acidification due primarily to anthropo- genic causes other than acid rain - NAPAP emissions inventory developed for Regional Acid Deposition Model indicates data available to implement interstate trading features of acid rain control strategies - NAPAP State of Science and Technology Report and 1990 Integrated Assessments released FIGURE 3 Continued JAMES L. REGENS Policy and Regulation - t985 199(3 ~- Clean Air Act Amendments of 1990 mandate a two-phase, market incentive-based regu latory program to reduce emissions of acid . _ deposition precursors ecosystems and forests, and (2) using atmospheric transport models to esti- mate source-receptor relationships. The Swedish case study prepared for the 1972 United Nations Confer- ence on the Human Environment in Stockholm asserted that acid rain was due primarily to sulfur dioxide (SO2) emissions from man-made sources- predominately coal-fired, steam electric power plants and industrial facili- ties and that it adversely affected ecosystems and human health (Swedish Ministry of Foreign Affairs and Swedish Ministry of Agriculture, 19721. The Norwegian Interdisciplinary Research Program, commonly referred to as the SNSF project, was conducted from 1972 to 1980 and focused on establishing effects on forests and fish. Like its Swedish counterpart, the SNSF project found conclusive evidence of chemical and biological changes, including fish kills and reproductive failure, in lakes and streams that had limited capacity to neutralize acidic inputs (Overrein et al., 19801. Another major research project under the auspices of the Organization for Economic Cooperation and Development (OECD) concluded that the acid deposition occurring over almost all of northwestern Europe was due to transboundary as well as local emissions of SO2. Unfortunately, because of serious prob ,.~

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ACID DEPOSITION 171 lems with the reliability of the available data bases on national emissions coupled with the quality of existing atmospheric transport models, the find- ings of the OECD study have an extremely large range of uncertainty (+50 percent) for individual receptor sites (OECD, 1977~. By the mid-1970s, papers noting declining pH levels and speculating about the possible impact of acidification due to sulfate (SO4=) deposition on aquatic resources stimulated similar concerns about the environmental consequences of acid deposition in the United States and Canada (see Beamish and Harvey, 1972; Cogbill and Likens, 1974; National Research Council of Canada, 1981~. Responding to such findings, in 1978 the United States and Canada established a Bilateral Research Consultation Group on the Long- Range Transport of Air Pollutants to coordinate the exchange of scientific information about acid rain. In 1980 the two governments took further steps to cooperate in the exchange of scientific, technical, and economic information about acid deposition when a set of three bilateral work groups composed of government experts in each of these areas was created to support negotiations under the U.S.-Canada Memorandum of Intent (MOI) concerning Transboundary Air Pollution (U.S. Department of State, 19811. The work groups were on impact assessment; atmospheric modeling; and emissions, costs, and engineering assessment, respectively. Disagreements within the work groups over dose-response functions (i.e., the relations between the amount of a substance received and the effects it produces) for damage attributable to acid deposition as well as over reduction targets were reflected in the final summary reports of the technical work groups (see U.S.-Canada Work Groups 1, 2, and 3B, 1982~. In fact, because of the policy implications of the findings presented in those documents, each country conducted its own external peer review. The U.S. review was conducted under the auspices of the White House's Office of Science and Technology Policy (OSTP), and both reviews ultimately con- cluded that the then available information supported selective reductions in SO2 emissions (see Nierenberg et al., 1984~. A separate evaluation of avail- able scientific, technical, and economic information conducted by the Of- fice of Technology Assessment (U.S. Congress, OTA, 1984) as well as an earlier report prepared by the National Research Council (NRC, 1981) reached the same conclusion. The public release of these three reports with presti- gious scientific imprimaturs was a major reason the Reagan administration felt compelled to initiate limited planning for a national strategy to reduce acid deposition and shifted away, at least symbolically, from exclusive reli- ance on its requirement for further research (Regens and Rycroft, 1988~. Starting in the early 1980s and continuing throughout that decade, re- search on acid deposition expanded dramatically in scope and funding level. Unlike the pioneering studies of the 1970s, which focused almost exclu- sively on sulfate deposition, what legitimately can be termed "second gen

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72 JAMES L. REGENS oration" research addressed the contributions of other precursor pollutants, especially nitrogen oxides (NOX) and volatile organic compounds (VOCs). There was also extensive research on control technologies and the effects of mitigation strategies. Four major efforts are worth noting: (1) the series of reports addressing ecological effects and atmospheric processes prepared by the National Research Council; (2) the studies on the effects of adding lime to aquatic ecosystems studies by Living Lakes, a nonprofit research group funded primarily by the electric utility industry to assess aquatic mitigation options; (3) the acid deposition research program conducted by the Electric Power Research Institute (EPRI); and (4) the National Acid Precipitation Assessment Program. Each contributed to developing and synthesizing in- formation about the nature and extent of the adverse effects associated with acid deposition as well as the potential scientific, technical, or economic efficacy of responses to the problem. National Acid Precipitation Assessment Program Because of its scale (total expenditures were approximately $530 mil- lion expressed in current dollars), it is useful to describe briefly the federal government's efforts to develop and synthesize information about acid deposition under the umbrella of the National Acid Precipitation Assessment Program. The Acid Precipitation Act of 1980 (P.L. 96-294, Title VII of the Energy Security Act of 1980) authorized a 10-year research effort, commonly re- ferred to as NAPAP, to assess possible damage to natural ecosystems, agri- culture, materials, and human health. The act established an Interagency Task Force on Acid Precipitation that consisted of representatives from 12 agencies, directors of 4 national laboratories, and four presidential appoin- tees to plan and coordinate NAPAP's implementation of a comprehensive research plan. The plan was to: Identify the sources of atmospheric emissions contributing to acid precipitation. Conduct a nationwide long-term monitoring network to detect and measure levels of acid precipitation. Delineate the processes by which atmospheric emissions are trans- formed into acid precipitation. . Develop and apply atmospheric transport models for predicting long range transport of substances causing acidic precipitation. . Define geographic areas at risk by monitoring deposition to identify sensitive areas. Build data bases of water and soil chemistry in receptor areas. Develop dose-response functions for effects. Prepare integrated assessments of (1) the environmental impacts caused

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ACID DEPOSITION 173 by acidic precipitation on crops, forests, fisheries, recreational and aesthetic resources, and structures; and (2) alternative technologies to prevent or ameliorate harmful effects. According to its original operating plan, NAPAP was to provide an initial damage assessment with preliminary estimates of acid rain impacts by 1985, focusing on the northeastern United States, and two additional integrated assessments in 1987 and 1989 to support policymaking. In addi- tion, NAPAP's legislative mandate called for providing annual reports to the President and Congress on the status and significance of the continuing research effort as well as recommending specific policy actions to deal with acid rain. The research agenda and the schedule for the assessments and other reporting requirements outlined above were extremely ambitious and required a high level of coordination across the participating agencies. Results After more than two decades of focused research, it seems appropriate to ask what scientific, technical, or economic insights have been gained. First, the overall chemistry of acid-forming compounds, sources of precur- sor pollutants, and the importance of man-made emissions of NOx and VOCs in addition to SO2 as acid rain precursors are reasonably well defined. While SO2 emissions come primarily from large point sources concentrated in a relatively small number of locales, emission of volatile organic com- pounds (VOC) and oxides of nitrogen (NOx) are more evenly distributed among point and mobile sources and are more uniformly dispersed spatially among regions. Second, regional models for simulating acid deposition transport processes especially comprehensive, process-oriented models or even relatively simple statistical models are capable of providing consis- tent, fairly accurate quantitative information about source-receptor relation- ships when projections are averaged over yearly time periods. Third, al- though data are insufficient to analyze regional trends in dry deposition, time series data for wet deposition reveal that the areas of maximum deposi- tion of acid rain in precipitation are located in the northeastern United States (see Table 1~. Fourth, research on effects, including NAPAP's Na- tional Surface Water Survey, EPRI's Integrated Lake Watershed Acidifica- tion Study (ILWAS), and the Living Lakes program, demonstrated that acid deposition produces chemical and biological changes in aquatic ecosystems that have limited capacity to neutralize acids. Adding lime to surface wa- ters or watersheds typically reverses adverse biological, chemical, and physical changes in those sensitive aquatic ecosystems. Similar evidence of direct effects on terrestrial ecosystems, materials, or human health remains incon- clusive or is lacking, but there is a widespread consensus that acid deposi

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74 JAMES L. REGENS TABLE 1 Trends in Wet Deposition of Cations and Anions in the Eastern and Western United States, 1985-1990 (in kilograms per hectare) Cations Anions Precipitation Year H+ NH4+ ca+2 SO4 NO3 (cm) Eastern U.S. (79 sites) 1985 0.40 2.36 1.55 21.33 13.08 107.2 1986 0.39 2.34 1.29 21.57 13.11 102.7 1987 0.38 2.44 1.29 20.34 12.79 100.9 1988 0.34 1.81 1.50 19.64 12.05 95.9 1989 0.38 3.09 1.44 21.45 14.07 110.0 1990 0.41 3.17 1.43 22.06 14.18 122.7 Western U.S. (44 sites) 1985 0.06 0.96 1.23 5.25 4.09 61.5 1986 0.05 1.07 1.18 5.51 4.47 72.0 1987 0.06 1.28 1.06 5.26 4.68 62.1 1988 0.05 0.70 1.16 4.72 3.83 56.1 1989 0.04 1.35 1.18 4.73 4.44 56.0 1990 0.05 1.57 1.18 5.16 4.90 67.0 SOURCE: National Acid Deposition Program/National Trends Network data. lion contributes to indirect effects on those resources as well as to reduced visibility. Fifth, economic assessment studies have evaluated options for achieving emissions reductions under various regulatory scenarios. OVERVIEW OF THE REGULATORY STRATEGY Figure 3 identifies the key events in the development of the regulatory strategy for managing the environmental consequences of acid deposition. The first air pollution control legislation adopted at the national level in the United States was passed in 1955 (Air Pollution Control Act of 1955, P.L. 84-159~. The federal government's role was limited to research, training, and technical aid to state governments. Eight years later, the Clean Air Act of 1963 (CAA, P.L. 88-206) was passed. While continuing the previous emphasis on federal support of scientific and technical advice to the states, the CAA also expanded the federal government's role as a facilitator of intermunicipal and interstate air quality efforts. Building on the 1963 CAA, the federal government's preeminence in air pollution control was enhanced by the Air Quality Act of 1967 (P.L. 90-148), which authorized the federal government to establish criteria for health protection, designate air quality control regions, and recommend specific control technologies for pollution ,. .

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ACID DEPOSITION 175 abatement, although the states retained standard-setting and enforcement responsibility. The Clean Air Act Amendments of 1970 (P.L. 91-604) gave the federal government additional authority to deal with ambient air quality problems by shifting responsibility for the standard-setting process from the states to the federal government. Three key features of the 1970 amendments are relevant to the evolution of the regulatory strategy for managing acid depo . . Sutton: The federal government was authorized to promulgate uniform na- tional ambient air quality standards (NAAQS) for certain pollutants. The federal government was authorized to promulgate uniform new source performance standards (NSPS) limiting emissions from new point sources of pollution. The states were required to formulate state implementation plans (SIPs), which were subject to EPA review, to attain NAAQS compliance. Those provisions potentially provided a framework for limiting emissions of acid deposition precursors from new sources under NSPS and existing sources under SIPs, but not for regulating acid deposition per se. In 1977 the CAA was reauthorized with a new series of amendments that had implications for acid deposition control (Clean Air Amendments of 1977, P.L. 95-95~. Reflecting emerging transboundary concerns, several sections were included in an attempt to address interstate and international effects using the existing SIP process. Section 126 permitted states or their subdivisions to seek relief from interstate pollution under section llO(a)~21(E), which theoretically limited emissions from one state that caused ambient concentrations in another to exceed NAAQS. Section 115 presumably pro- vided administrative procedures for addressing transboundary air quality concerns, including noncriteria pollutants. However, the statutory language of these sections is vague and, when considered as a set, they have proved to be an ineffective remedy. Two other provisions of the 1977 amendments also are worth noting: State governors were authorized to mandate the use of locally mined coals to prevent severe economic disruption or unemployment. The EPA was required to promulgate a revised NSPS for coal-fired power plants that specified a minimum percentage reduction in SO2 emis- sions based on the use of best available control technology (BACTJ for . . . continuous emission control. The 1977 amendments essentially required flue gas desulfurization (FGD) for all new coal-fired, steam electric power plants, regardless of the sulfur content of the coal used as fuel.

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178 JAMES L. REGENS LINKS BETWEEN INFORMATION .. AND POLICY CHOICE Because public policies represent responses to perceived problems, it is worth considering whether scientific, technical, or economic information developed through NAPAP or elsewhere helped shape the regulatory strat- egy that eventually emerged, as outlined above. Early scientific studies here and abroad, of course, brought concerns about the causes and effects of acid deposition to the forefront as an environmental policy issue. For ex- ample, almost two decades of research addressing transport and deposition processes pointed out the importance of and need to consider reductions in NOX and VOC emissions, as well as in SO2. Insights from engineering similarly identified the commercial availability and removal efficiency of alternative technologies for reducing precursor emissions by new and exist- ing sources. Economic analyses and theory informed the various interested parties about the potential costs of various emissions reduction scenarios, as well as prospective benefits if the adverse effects of acid deposition were ameliorated, including the greater economic efficiency of market incentive- based strategies. This suggests two related questions. First, what was the relative influ- ence of scientific, technical, and economic information in shaping the regu- latory program ultimately endorsed by the Congress? Second, did the as- sessment activities synthesizing the results from the federal government's large-scale, interagency research program conducted under the NAPAP um- brella directly influence the acid deposition provisions in the 1990 CAA amendments? A simple but not necessarily carefully reasoned response as- serts that the tremendous amount of information per se and NAPAP specifi- cally were influential in shaping public policy. In fact, however, there are widespread differences of opinion about the overall importance of new in- formation in general and of the NAPAP state-of-science-and-technology re- ports, or its integrated assessments specifically, for the legislation that ulti- mately was adopted (NAPAP, l 991 a, l 99 lb). On balance, a reasonably strong case can be made that new information (some of which was produced under the auspices of NAPAP) defining the scientific, engineering, economic, and institutional dimensions of the acid deposition problem was used in both the agenda-setting and formulation phases of the policymaking processes. Assertions that "science" (i.e., sys- tematic, empirical information) was irrelevant appear groundless. Slightly more than a decade ago, in 1980, few Americans identified acid deposition as an environmental policy problem. Only three years later, a Harris poll found that 63 percent of those questioned were aware of acid rain and approximately 66 percent favored stricter controls on SO2 emissions. In essence, in the early 1980s, scientific inquiry had transformed the acid in,.

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ACID DEPOSITION 179 deposition issue into a public policy question and played a key role in placing it on the environmental agenda. Results of Assessment Studies A number of initial assessment or synthesis studies conducted during the early to mid-1980s concentrated primarily on the state of existing scien- tific and technical knowledge but also offered some insights into the eco- nomics of alternative emissions reduction scenarios. The results were in- strumental in identifying regulatory options as well as the nature and extent of ecological effects. As a result, those reports were a major source of current information for decision makers involved in policy development. For instance, when serious deliberations about appropriate policy responses to the acid rain issue began in 1980, there were claims that sulfur emissions were causing an environmental "catastrophe" that was devastating aquatic and terrestrial ecosystems. Counterclaims were being made that acidity was primarily from natural sources, was not causing demonstrable impacts, and acidification levels were not likely to decrease substantially if emissions declined. Within the first five years of research by NAPAP as well as independent efforts, the policy debate surrounding congressional deliberations recog- nized the importance of NOX and VOCs, the localized nature of damage to sensitive surface waters, the highly uncertain role of acidification in forest diebacks, and the increasing marginal costs of control programs, especially for annual emissions reductions greater than 10 million tons. Although extensive research conducted by the private sector (such as EPRI's ILWAS project and the Living Lakes program) as well as under government auspices was instrumental in characterizing aquatic and terres- trial effects, the results of these studies appear to have had a limited impact on congressional deliberations and the evolving legislation. The continuing controversy surrounding aquatic acidification illustrates this point. While they did not say so explicitly, the 1983 and 1986 National Research Council reports, especially the water chemistry data presented in the 1986 report, fostered the impression that other human activities have much more sub- stantial effects on soil and water chemistry than those producing acid rain, except in a very few high-elevation watersheds that are otherwise undis- turbed by humans. The NAPAP National Surface Water Survey conducted during the mid-1980s also yielded late-summer, water chemistry data that reinforced the conclusion that addressing lake acidification ought not be the primary motivation for legislation (Landers et al., 1987, Linthurst et al., 1986~. While a paleoacidification study of lakes in the Adirondacks con- ducted with EPRI funding indicated that most of the lakes with pH values below 6.0 had acidified in the twentieth century, which underscores the

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180 JAMES L. REGENS importance of man-made sources (Charles et al., 1990), the results of this study, unlike earlier ILWAS results, were not readily available until recently and did not influence the congressional deliberations. As a result, although a tremendous number of studies on effects were conducted and many par- ticipants in the policy process knew about the findings, the accumulated evidence about the nature, rate, and magnitude of damage was not a driving force in the congressional deliberations shaping the final legislation. On the other hand, appraisals of the existing scientific knowledge about atmospheric processes and source-receptor relationships did play a key role. For example, the 1981 National Research Council report was extremely influential in defining emissions reduction goals. The report's recommen- dation of a 50 percent reduction in H+ ion deposition to protect sensitive aquatic ecosystems was used to justify proposals for a corresponding 50 percent reduction in SO2 emissions. The 1983 draft critical assessment review papers requested by the Clean Air Scientific Advisory Committee of EPA's Science Advisory Board (EPA, 1983a), the OSTP peer review panel's report (Nierenberg et al., 1984), and the 1984 OTA report contributed to heightening awareness of NOx and VOCs in addition to SO2 as precursor emissions and the transformation of pollutants to acidic compounds. As a result, when they were adopted, the 1990 CAA amendments focused on three pollutants rather than exclusively emphasizing reductions in SO2 emis- sions. The 1983 NRC report that concluded that reducing annual emissions across a broad spatial domain would produce corresponding, although not necessarily linearly proportionate, reductions in average annual deposition reinforced a focus on regulatory strategies that limited atmospheric loadings on a yearly basis rather than on a shorter time horizon. Contribution of Models Insights from environmental economics also played a major role, if not the dominant one, in shaping the precursor reduction policy ultimately adopted by Congress. A strong case can be made that the congressional debate was dominated by the results of simulation models that projected future emis- sions of precursors, especially by the electric utility sector, under scenarios with different energy, economic, and regulatory conditions. The Coal and Electric Utilities Model (CEUM) developed by ICE, Inc., provided a fairly detailed representation of the coal and electric utility market and was used extensively by the Environmental Protection Agency, the Department of Energy, the Congressional Budget Office, environmental groups, and indus- try in their analyses of proposed legislation (ICF, 1989, 1985~. Because the results of the model reflected the different assumptions of its users, the findings were easy to compare and the CEUM model gained credibility within policymaking circles. Also, since other models such as the Teknekron

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ACID DEPOSITION 181 Utility Simulation Model (USM) or NAPAP's Advanced Utility Simulation Model (AUSM) tend to produce roughly comparable results when used to estimate the control costs of emissions reductions, basic conclusions about cost curves were reinforced. Figure 4 shows that the models agree on the general shape of the cost curve as well as on a dramatic increase in marginal costs (in terms of their magnitude and relative uncertainty) for reductions beyond 10 million tons of SO2 annually (see Parker, 1985~. The 8- to 10-million ton range, with associated costs of $4 billion to $7 billion annually, also coincides with the level under the 1.2 lb/million British thermal unit cap established by NSPS at which eastern coal reserves have to be replaced by western low-sulfur coal and flue-gas desulfurization. Near-term costs are likely to be at the lower end of this range because prices for low-sulfur coal are depressed and not likely to increase dramatically given its oversupply. As a result, eco- nomic analysis coupled with interregional political realities suggested an upper bound target for reductions contemplated in the congressional delib- erations. Not surprisingly, reflecting the traditional command-and-control approach 6 En o to Go - 4 a) OCR for page 165
182 JAMES L. REGENS that characterized the U.S. air quality management system throughout the 1970s, the first proposals to emerge during the congressional deliberations over acid deposition controls mandated FGD use to reduce emissions with- out regard to cost efficiency. A number of analyses, however, suggested that a market incentive-based approach based on emissions trading and mar- ketable permits could achieve comparable reductions in a more economi- cally efficient manner, especially if a phased reduction timetable were used (see Raufer and Feldman, 1987~. The emissions inventory developed by NAPAP as part of its Regional Acid Deposition Model (RADM) project indicated that the data were available to implement Title IV of the 1990 CAA amendments, which incorporated the latter approach as the underlying basis for the acid deposition control strategy. In fact, without those data, it is questionable whether interstate, as opposed to intrastate, trading would have been allowed in the final version of the legislation. As a result, eco- nomic theory and analysis influenced both the level of reduction mandated and the compliance strategy selected by the Congress. The examples summarized above illustrate how scientific, technical, and economic information was useful in placing acid deposition on the policy agenda as well as in framing options during the process of formulat- ing the broad guidelines for a regulatory strategy. Information was used to define preliminary options, and the option ultimately chosen represented a modification of the original proposals. These were based on evolving infor- mation coupled with White House and congressional willingness to support a regulatory program. Assessment of NAPAP's Effectiveness During its 10-year life, NAPAP represented a novel interagency ap- proach to coordinating environmental research in the federal government. It most likely is due some credit for acid deposition policy to the extent that the work to produce useful information was funded under its interagency budget, especially in developing the emissions inventories that form the basis for allocating reductions. It is worth remembering that the original mandate for NAPAP was to produce policy-relevant assessments of the causes and effects of acid deposition as well as to recommend specific policy actions to deal with acid rain. The research being conducted under the NAPAP umbrella was justified as a contribution to a comprehensive pro- gram to synthesize understanding of the problem to aid policy choice. NAPAP produced high-quality scientific and engineering studies, particularly in at- mospheric sciences and ecosystems research, much of which was at the cutting edge of those sciences. The NAPAP integrated assessments, however, were not a significant factor in terms of shaping the policy agenda or designing a regulatory strat

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ACID DEPOSITION 183 egy. Because it was an executive branch program, NAPAP could only recommend the sitting administration's program rather than independently assess alternative policy choices. This situation frustrated some legislators who had hoped to use NAPAP as an independent source of advice during congressional deliberations. Instead, with few exceptions, the testimony and written documents produced by the NAPAP tended to emphasize scien- tific and technical information while leaving value judgments and policy implications to others. In essence, the NAPAP synthesis efforts failed to exert a direct impact on the very policymaking process that provided its formal rationale for existence. However, the widely held expectation that Congress would use NAPAP outputs "directly" is a naive perspective of how scientific, techni- cal, or economic knowledge and policy choice are related. It is incorrect to assume that there is a direct link between good science and good policy (see Regens, 1984~. All environmental legislation reflects personal preferences and societal values that shape interpretations of the facts that scientific, technical, and economic information provide. Thus, the political process, not science per se, dictates how much information is enough as well as the conditions under which information guides a given policy decision. When viewed in this light, it is possible to clarify why NAPAP's influence on congressional deliberations was both constrained and largely indirect. Several reviews of NAPAP concluded that the lack of well-defined in- formation needs coupled with a decentralized management approach tended to make agencies willing to seek funding under NAPAP but precluded the timely collection of valid, reliable data for risk-benefit analyses as a basis for designing a national acid deposition control strategy (EPA, 1983b; NAPAP, l991c; U.S. General Accounting Office [GAO], 19871. Why then was sci- entific, technical, and economic information in general influential in shap- ing the congressional debate while the NAPAP integrated assessments failed to play a central role in policymaking? It is important to answer this ques- tion given suggestions that NAPAP might serve as a model for future large- scale federal research efforts to improve understanding of and guide policy development on major environmental concerns, such as global climate change. Careful appraisal of the NAPAP experience suggests several possible explanations for this outcome. For one thing, policy leaders in the execu- tive branch did not establish at the start the priorities for the areas requiring additional scientific, technical, or economic information to guide policy choices. Moreover, NAPAP lacked true budgetary integration, and much of its research, especially in its early years, amounted to little more than simple relabelling of existing agency programs to fit under the NAPAP umbrella. The joint chairs and NAPAP director had limited control over the design and conduct of the scientific research activities, or the assessments, which were managed by the individual agencies. As a result, in its early years the -

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184 JAMES L. REGENS extent to which the research effort focused on producing information with clearly discernable policymaking value was limited. Another constraint on the NAPAP's effectiveness was the Reagan administration's use of executive branch personnel associated with NAPAP to support, through claims of scientific uncertainty, its opposition to imme- diate regulatory interventions. Advocates of intervention asserted that the use of such testimony did little to instill confidence in science as a means of resolving policy choice. This controversy fostered a perception that the NAPAP was little more than a delaying tactic by the Reagan administration to serve a political agenda and that it was under pressure to support political decisions. The acrimony surrounding the executive summary of the 1987 interim assessment did little to assuage such doubts. Unlike the supporting volumes of the 1987 interim assessment report, the executive summary pre- pared by Dr. J. L. Kulp, at the time NAPAP's scientific director, did not receive any external peer review. Numerous observers asserted that the executive summary offered a highly selective interpretation of the larger body of research findings, and its publication caused NAPAP's assessment efforts to lose considerable credibility. This episode illustrates how indi- vidual scientists in key positions can color the debate over the proper inter- pretation, especially the policy implications, of findings when they advo- cate specific policies. The NAPAP's lack of timeliness in producing periodic assessments of the policy relevance of principal scientific, technical, and economic find- ings was a significant shortcoming. In fact, throughout its existence, the NAPAP encountered major difficulties in meeting its own deadlines for assessment reports. The 1985 preliminary damage assessment was not re- leased because of a change in program leadership and management philoso- phy. This caused a two-year delay in making the first assessment publicly available, and the discredited 1987 assessment further diminished NAPAP's effectiveness in influencing congressional deliberations. By the time the post-Kulp leadership reestablished the more open decision processes that characterized NAPAP's first few years and enhanced the program's assess- ment capability, a three-month extension was necessary in order to com- plete the final 1990 integrated assessment and it was too late for the final assessment to influence legislative outputs. Ironically, the final assessment was released in early 1991, several months after acid rain control legislation was signed into law on November 15, 1990. On the other hand, the NAPAP's primary scientific and technical con- clusions supporting the integrated assessment were presented publicly in February 1990 at an international meeting held in Hilton Head, South Caro- lina, and the NAPAP had been issuing reports on individual projects throughout its existence. As a result, the major research findings on atmospheric pro- cesses, control technology, or effects of acid deposition that might have _ .

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ACID DEPOSITION 185 been useful in designing potential regulatory strategies had gone through an open process of peer review and were readily available to the public and decision makers. Finally, the speed with which public perception of acid rain as a serious environmental problem continued to increase throughout the 1980s also limited the usefulness of NAPAP's potential contributions to policy deci- sions. The heightened significance of the acid deposition issue generated pressure for political action and, when the Bush administration proposed acid deposition legislation in 1989, the question of deferring a policy deci- sion until NAPAP's final assessment was released became moot. LESSONS FOR ENVIRONMENTAL POLICYMAKING Sensitive environmental issues, by their very nature, create controversy. Once they find a niche in the policymaking process, the existence of scien- tific, technical, or economic uncertainty may forestall action but ultimately is not likely to preclude regulatory intervention. Careful assessments of existing knowledge that emphasize risk-benefit information, therefore, can map out the advantages and disadvantages of available policy options. This underscores the need to focus on "policy-relevant" research that reduces uncertainty about the probable outcomes of alternative choices. Unless research efforts are guided by the appropriate data requirements for inte- grated policy assessments, the likelihood of producing useful and timely assessments that inform decision makers during, rather than after, congres- sional debate is decreased substantially. Unfortunately, although the NAPAP experience suggests that mission agencies are willing to cooperate in pursuing collaborative research efforts, interagency support for policy assessment activities is more difficult to mo- bilize and sustain. In large part, this is because the respective agencies have different fundamental mandates that, while allowing cooperation in research, and create strongly divergent views on issues of policy. Despite such ob- stacles, if- the following guidelines are adopted, they are likely to increase the probability that focused research will produce timely, credible, and use- ful assessments to inform environmental decision making. . Senior decision makers should identify major policy-relevant ques- tions as a guide before research program planning is started. Follow-up reviews with those decision makers should be used to update key informa . . . . . . talon gaps and uncertainties In policy choices. The assessment function should "drive" the research function. Ad- equate funding and staffing should be provided to integrate assessment ac- tivities with research activities. In contrast to the usual pattern of discon- tinuing research once a policy option has been selected, Congress recognized

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186 JAMES L. REGENS the need to evaluate policy outcomes by reauthorizing NAPAP under the 1990 CAA in a unique effort to document the benefits of the acid rain control program. Recognize that the timeline for policy choice within the political system may differ from the optimal timeline for scientific, technical, or economic inquiry. To be of value to decision makers, information must be available if it is to play a role in policy formulation. Adapt to this by periodically releasing summaries of the state of knowledge and indicate degrees of uncertainty for policy-relevant questions. Credibility is critical for policy assessments. To establish and main- tain credibility as well as to confront directly the problem of partisan use or misuse of information and its implications, the operational plan and all analytical reports, including executive summaries, should receive external peer review. An outside group of experts should serve as an oversight board, and meetings should be held regularly with the public, academic community, environmental groups, industry, and congressional staff to present scientific findings and assessment results. Some important lessons in terms of the potential for incorporating new information into environmental policymaking can be learned from the acid deposition experience. They may be useful in developing policies to ad- dress other emergent environmental issues, such as global climate change. Those insights are likely to be especially useful if, as some advocate, an interagency approach similar to NAPAP is adopted. Such an approach is appealing, at least in part, because in the case of NAPAP it provided an opportunity for numerous individuals with differing perspectives in the mis- sion agencies as well as in the research community to gain a valuable under- standing of the dynamics of the environmental policymaking process. NOTES 1. To be consistent with popular usage, the term acid rain is used in this case study as a catchall for all forms of acidic deposition, unless otherwise indicated. 2. Background interviews for this case study were conducted with individuals representing a wide range of affiliations: the electric utility and coal industries, U.S. Department of Energy, U.S. Environmental Protection Agency, National Acid Precipitation Assessment Program (NAPAP), research scientists, congressional staff, and environmental organizations. I assured those inter- viewed that they would not be quoted: I feel confident that they were very candid in giving me their opinions. 3. Since acids release hydrogen ions (H+) in an aqueous solution, the level of acidity typically is measured by the logarithmic pH scale, with pH being equal to the negative logic of the H+ ion concentration. 4. By convention, the "natural" acidity value for precipitation is assumed to be pH 5.6; this is a somewhat arbitrary threshold calculated for distilled water in equilibrium with atmospheric carbon dioxide concentrations.

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