Sustainability Concepts in Decision-Making
Tools and Approaches for the
US Environmental Protection Agency
Committee on Scientific Tools and Approaches for Sustainability
Board on Environmental Studies and Toxicology
Division on Earth and Life Studies
Science and Technology for Sustainability Program
Policy and Global Affairs Division
NATIONAL RESEARCH COUNCIL
OF THE NATIONAL ACADEMIES
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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance.
This project was supported by Contract EP-C-09-003 between the National Academy of Sciences and the U.S. Environmental Protection Agency. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the authors and do not necessarily reflect the view of the organizations or agencies that provided support for this project.
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THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences.
The National Academy of Engineering was establised in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing ith the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. C. D. Mote, Jr., is president of the National Academy of Engineering.
The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Victor J. Dzau is president of the Institute of Medicine.
The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. C. D. Mote, Jr., are chair and vice chair, respectively, of the National Research Council.
COMMITTEE ON SCIENTIFIC TOOLS AND APPROACHES FOR SUSTAINABILITY
MICHAEL C. KAVANAUGH (Chair), Geosyntec Consultants, Oakland, CA
SHERBURNE B. ABBOTT, Syracuse University, Syracuse, NY
DAVID T. ALLEN, The University of Texas, Austin, TX
PRAVEEN K. AMAR, independent consultant, Boston, MA
BRADFORD BROOKS, IBM Corporation, Boulder, CO
INGRID C. BURKE, University of Wyoming, Laramie, WY
JOHN C. CRITTENDEN, Georgia Institute of Technology, Atlanta, GA
JAMES FAVA, PE International, Inc., West Chester, PA
PAUL GILMAN, Covanta Energy Corporation, Fairfield, NJ
MICHAEL R. GREENBERG, Rutgers, the State University of New Jersey, New Brunswick, NJ
ANDREW M. HUTSON, Environmental Defense Fund, Raleigh, NC
CATHERINE KLING, Iowa State University, Ames, IA
H. SCOTT MATTHEWS, Carnegie Mellon University, Pittsburgh, PA
ERIK PETROVSKIS, Meijer, Inc, Grand Rapids, MI
HELEN H. SUH, Northeastern University, Boston, MA
ALISON TAYLOR, Siemens Corporation, Washington, DC
TERRY F. YOSIE, World Environment Center, Washington, DC
RAYMOND WASSEL, Senior Program Officer
KARA N. LANEY, Program Officer
MARK D. LANGE, Program Officer
NORMAN GROSSBLATT, Senior Editor
MIRSADA KARALIC-LONCAREVIC, Manager, Technical Information Center
RADIAH ROSE, Manager, Editorial Projects
ORIN LUKE, Senior Program Assistant
US ENVIRONMENTAL PROTECTION AGENCY
BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY1
ROGENE F. HENDERSON (Chair), Lovelace Respiratory Research Institute, Albuquerque, NM
PRAVEEN K. AMAR, independent consultant, Boston, MA
RICHARD A. BECKER, American Chemistry Council, Washington, DC
MICHAEL J. BRADLEY, M.J. Bradley & Associates, Concord, MA
JONATHAN Z. CANNON, University of Virginia, Charlottesville, VA
GAIL CHARNLEY, HealthRisk Strategies, Washington, DC
DAVID C. DORMAN, Department of Molecular Biomedical Sciences, Raleigh, NC
CHARLES T. DRISCOLL, JR., Syracuse University, Syracuse, New York
WILLIAM H. FARLAND, Colorado State University, Fort Collins, CO
LYNN R. GOLDMAN, George Washington University, Washington, DC
LINDA E. GREER, Natural Resources Defense Council, Washington, DC
WILLIAM E. HALPERIN, University of Medicine and Dentistry of New Jersey, Newark, NJ
STEVEN P. HAMBURG, Environmental Defense Fund, New York, NY
ROBERT A. HIATT, University of California, San Francisco, CA
PHILIP K. HOPKE, Clarkson University, Potsdam, NY
SAMUEL KACEW, University of Ottawa, Ontario, Canada
H. SCOTT MATTHEWS, Carnegie Mellon University, Pittsburgh, PA
THOMAS E. MCKONE, University of California, Berkeley, CA
TERRY L. MEDLEY, E.I. du Pont de Nemours & Company, Wilmington, DE
JANA MILFORD, University of Colorado at Boulder, Boulder, CO
MARK A. RATNER, Northwestern University, Evanston, IL
JOAN B. ROSE, Michigan State University, East Lansing, MI
GINA M. SOLOMON, California Environmental Protection Agency, Sacramento, CA
PETER S. THORNE, University of Iowa, Iowa City, IA
DOMINIC M. DI TORO, University of Delaware Newark, DE
JOYCE S. TSUJI, Exponent Environmental Group, Bellevue, WA
JAMES J. REISA, Director
DAVID J. POLICANSKY, Scholar
RAYMOND A. WASSEL, Senior Program Officer for Environmental Studies
ELLEN K. MANTUS, Senior Program Officer for Risk Analysis
SUSAN N.J. MARTEL, Senior Program Officer for Toxicology
EILEEN N. ABT, Senior Program Officer
MIRSADA KARALIC-LONCAREVIC, Manager, Technical Information Center
RADIAH ROSE, Manager, Editorial Projects
1This study was planned, overseen, and supported by the Board on Environmental Studies and Toxicology.
OTHER REPORTS OF THE BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY
Review of the Styrene Assessment in the National Toxicology Program 12th Report on Carcinogens (2014)
Review of the Formaldehyde Assessment in the National Toxicology Program 12th Report on Carcinogens (2014)
Review of EPA’s Integrated Risk Information System (IRIS) Process (2014)
Review of the Environmental Protection Agency’s State-of-the-Science Evaluation of Nonmonotonic Dose–Response Relationships as They Apply to Endocrine Disruptors (2014)
Assessing Risks to Endangered and Threatened Species from Pesticides (2013)
Science for Environmental Protection: The Road Ahead (2012)
Exposure Science in the 21st Century: A Vision and A Strategy (2012)
A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials (2012)
Macondo Well–Deepwater Horizon Blowout: Lessons for Improving Offshore Drilling Safety (2012)
Feasibility of Using Mycoherbicides for Controlling Illicit Drug Crops (2011)
Improving Health in the United States: The Role of Health Impact Assessment (2011)
A Risk-Characterization Framework for Decision-Making at the Food and Drug Administration (2011)
Review of the Environmental Protection Agency’s Draft IRIS Assessment of Formaldehyde (2011)
Toxicity-Pathway-Based Risk Assessment: Preparing for Paradigm Change (2010)
The Use of Title 42 Authority at the U.S. Environmental Protection Agency (2010)
Review of the Environmental Protection Agency’s Draft IRIS Assessment of Tetrachloroethylene (2010)
Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use (2009)
Contaminated Water Supplies at Camp Lejeune—Assessing Potential Health Effects (2009)
Review of the Federal Strategy for Nanotechnology-Related Environmental, Health, and Safety Research (2009)
Science and Decisions: Advancing Risk Assessment (2009)
Phthalates and Cumulative Risk Assessment: The Tasks Ahead (2008)
Estimating Mortality Risk Reduction and Economic Benefits from Controlling Ozone Air Pollution (2008)
Respiratory Diseases Research at NIOSH (2008)
Evaluating Research Efficiency in the U.S. Environmental Protection Agency (2008)
Hydrology, Ecology, and Fishes of the Klamath River Basin (2008)
Applications of Toxicogenomic Technologies to Predictive Toxicology and Risk Assessment (2007)
Models in Environmental Regulatory Decision Making (2007)
Toxicity Testing in the Twenty-first Century: A Vision and a Strategy (2007)
Sediment Dredging at Superfund Megasites: Assessing the Effectiveness (2007)
Environmental Impacts of Wind-Energy Projects (2007)
Scientific Review of the Proposed Risk Assessment Bulletin from the Office of Management and Budget (2007)
Assessing the Human Health Risks of Trichloroethylene: Key Scientific Issues (2006)
New Source Review for Stationary Sources of Air Pollution (2006)
Human Biomonitoring for Environmental Chemicals (2006)
Health Risks from Dioxin and Related Compounds: Evaluation of the EPA Reassessment (2006)
Fluoride in Drinking Water: A Scientific Review of EPA’s Standards (2006)
State and Federal Standards for Mobile-Source Emissions (2006)
Superfund and Mining Megasites—Lessons from the Coeur d’Alene River Basin (2005)
Health Implications of Perchlorate Ingestion (2005)
Air Quality Management in the United States (2004)
Endangered and Threatened Species of the Platte River (2004)
Atlantic Salmon in Maine (2004)
Endangered and Threatened Fishes in the Klamath River Basin (2004)
Cumulative Environmental Effects of Alaska North Slope Oil and Gas Development (2003)
Estimating the Public Health Benefits of Proposed Air Pollution Regulations (2002)
Biosolids Applied to Land: Advancing Standards and Practices (2002)
The Airliner Cabin Environment and Health of Passengers and Crew (2002)
Arsenic in Drinking Water: 2001 Update (2001)
Evaluating Vehicle Emissions Inspection and Maintenance Programs (2001)
Compensating for Wetland Losses Under the Clean Water Act (2001)
A Risk-Management Strategy for PCB-Contaminated Sediments (2001)
Acute Exposure Guideline Levels for Selected Airborne Chemicals (sixteenth volumes, 2000-2014)
Toxicological Effects of Methylmercury (2000)
Strengthening Science at the U.S. Environmental Protection Agency (2000)
Scientific Frontiers in Developmental Toxicology and Risk Assessment (2000)
Ecological Indicators for the Nation (2000)
Waste Incineration and Public Health (2000)
Hormonally Active Agents in the Environment (1999)
Research Priorities for Airborne Particulate Matter (four volumes, 1998-2004)
The National Research Council’s Committee on Toxicology: The First 50 Years (1997)
Carcinogens and Anticarcinogens in the Human Diet (1996)
Upstream: Salmon and Society in the Pacific Northwest (1996)
Science and the Endangered Species Act (1995)
Wetlands: Characteristics and Boundaries (1995)
Biologic Markers (five volumes, 1989-1995)
Science and Judgment in Risk Assessment (1994)
Pesticides in the Diets of Infants and Children (1993)
Dolphins and the Tuna Industry (1992)
Science and the National Parks (1992)
Human Exposure Assessment for Airborne Pollutants (1991)
Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991)
Decline of the Sea Turtles (1990)
Copies of these reports may be ordered from the National Academies Press
(800) 624-6242 or (202) 334-3313
Several years before requesting this report, the US Environmental Protection Agency (EPA) asked a committee established by the National Research Council to advise it on how to strengthen the analytic and scientific basis of sustainability as it applies to human health and environmental protection.
That committee’s report Sustainability and the U.S. EPA (referred to as the Green Book), published in 2011, was characterized by some as a document analogous to the “Red Book”, which was prepared in 1983 by another National Research Council committee and summarized the framework for risk assessment and risk management (RA/RM) used in the federal government at that time. The Red Book has profoundly influenced the integration of the RA/RM paradigm into EPA’s efforts to carry out its mission to protect human health and the environment. The paradigm continued to develop over the years and is now widely used in the agency, as summarized in the 2014 EPA report, Framework for Human Health Risk Assessment to Inform Decision Making.2 Thus, the Green Book was met with the expectation that it would have immediate effects on EPA’s risk-management decisions by applying a new framework that was based on sustainability principles and a more holistic assessment of environmental, economic, and social factors in decision-making.
The Green Book recommended a general sustainability framework that incorporated a Sustainability Assessment and Management (SAM) process. Among several recommendations, the Green Book committee challenged EPA to develop a “sustainability toolbox” that would contain a variety of analytic tools needed to implement the SAM process. Some issues remained unresolved in the Green Book, however, including recommendations on which tools or approaches were most applicable and how EPA would match the tools to the diversity of decisions facing the agency.
Those unresolved issues prompted EPA to reach out again to the National Research Council to form the present committee to provide advice on operationalizing specific recommendations in the Green Book. In particular, the Statement of Task (SOT) (see Appendix A) directed the Committee on Scientific Tools and Approaches for Sustainability to address seven key aspects of implementing tools and approaches that would be used in the SAM process, with the specific charge to focus on analytic and scientific tools, methods, and approaches and not recommend specific policy choices. The present report was prepared by the committee in response to that SOT.
EPA recently released Strategic Plan 2014-2018, which stresses the importance of sustainability assessments in pursuing the major goals of the organization. Clearly, there is a strong desire in EPA’s current management to incorporate more sustainability considerations or concepts into activities throughout the organization, including the decision processes in the agency’s statutory and enforcement contexts.
However, there are indications that a sustainability framework has yet to become broadly integrated into the agency’s activities. For example, the 2014 EPA report on risk assessment mentioned above considers “sustainability” as just one of several factors informing EPA’s risk-management decisions. Other considerations include laws and regulatory requirements; economic analyses; technologic, political, and public and social considerations, and risk-characterization analyses. This approach is quite different from the Green Book’s recommendation that EPA “include risk assessment as a tool, when appropriate, as a key input into its sustainability decision making.” Implementation of a sustainability framework after 30
2EPA/100/R-10/001 April, 2014.
years of reliance on the RA/RM framework in EPA’s decision-making context will probably require some time and considerable effort in the agency.
Interest in sustainability outside EPA continues to grow in intensity. Many US cities tout their “sustainability” plans, and several major cities have had such plans in operation for several years. Private-sector companies have embraced many of the principles of sustainability and established sustainability programs. Some publically traded corporations have a chief sustainability officer who reports to the CEO and has broad powers to influence strategic decisions, such as R&D priorities. Many of the EPA regions have also initiated sustainability programs tailored to their own conditions. Federal agencies are also actively promoting sustainability efforts in their internal operations, partly in response to Executive Order 13514, which required all federal agencies to develop sustainability performance plans. As would be expected, the number of tools, approaches, and methods being used or under development is staggering.
Given that intense interest in sustainability issues in all sectors of society, why haven’t the concepts already been integrated into decision-making in federal regulatory agencies, including EPA? That question is beyond the scope of this committee, but it highlights the fact that integration of environmental, economic, and social factors into federal decision-making can face many barriers, such as disagreements over the appropriate spatial and temporal regimes for sustainability analyses. EPA historically has focused primarily on the environmental pillar through the lens of the RA/RM paradigm. It is thus not surprising that most of the efforts related to integration of sustainability into decision-making have taken place within reasonably well-defined geographic boundaries (local or regional studies), economic boundaries (such as corporate supply chains), or time frames (for example, less than two generations). A further barrier to more rapid transition to a sustainability paradigm at the federal level is the difficulty in defining the term sustainability so that one can know in advance the definite characteristics of a sustainable society.
In the SOT, EPA requested advice on several issues related to application of tools and approaches to inform decision-making. In brief, these included
• Identification of the most appropriate tools for assessments used to inform EPA decisions.
• Data needs, strengths, and weaknesses of the tools.
• Applicability of the tools to decisions that cross geographic, population, and generational boundaries.
• Utility of the tools for screening purposes to assess the need for more in-depth assessments.
• Uncertainty in results of assessments that use the tools.
• Use of the tools for postdecision evaluation in the sustainability framework.
• Research and development needs to enhance the utility of the tools in incorporating sustainability concepts into decision-making.
The committee found the SOT to be challenging, to say the least, even though it does not call for advice concerning particular decisions that EPA needs to make. Given the plethora of available tools and methods, the large number of sustainability indicators, the wide variety of decisions facing EPA, and the long history of reliance on the risk-assessment framework to inform most EPA decisions, it is clearly beyond the scope of this committee to provide prescriptive advice to EPA on the use of specific tools for specific decisions. In providing broadly applicable actionable advice to EPA on sustainability tools and approaches, the committee recognizes that the incorporation of sustainability into EPA decision-making will be an evolutionary process.
As noted in EPA’s risk-framework document, sustainability is among several factors that inform risk-management decisions. The committee hopes, however, that consideration of sustainability factors will play an increasing and more influential role in reaching difficult risk-management decisions, including a much broader assessment of tradeoffs that go beyond the boundaries of a single pillar, within the social, environmental, and economic pillars. The urgency of this journey is unavoidable in the face of several megatrends that are highlighted in the report as well as the inevitable challenges in meeting US
and global economic and social needs while managing the risks to current and future generations associated with those actions. It is my hope that this report will provide an additional foundation for EPA’s journey in leading the efforts to achieve a more sustainable future.
Finally, I wish to acknowledge the dedicated efforts of my committee members, whose technical expertise and thoughtful deliberations on this complex topic have enriched this report. I enjoyed the opportunity to work with such a distinguished group. I also express my appreciation to the members of the National Research Council project staff for the very effective support they provided to the committee.
Michael C. Kavanaugh, Chair
Committee on Scientific Tools and
Approaches for Sustainability
The National Research Council assembled a committee of 17 members who had expertise in sustainability science, green design, exposure science, risk assessment, risk management, public health, environmental transport and fate, pollution prevention, energy technologies, life-cycle analysis, agriculture, ecology, economics, sociology, and environmental law. The committee members also had experience with scientific tools and approaches for sustainability that are used in industry and in other countries. (Appendix B contains biographic material on the committee members.)
This report has been reviewed in draft form by persons chosen for their diverse perspectives and technical expertise in accordance with procedures approved by the National Research Council Report Review Committee. The purposes of the independent review are to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards of objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We thank the following for their review of this report: Paul T. Anastas, Yale University; Kenneth J. Arrow, Stanford University; Dallas Burtraw, Resources for the Future; Alison C. Cullen, University of Washington; Laura Draucker, World Resources Institute; Daniel C. Esty, Yale Law School; Courtney G. Flint, Utah State University; Al Iannuzzi, Johnson & Johnson; Jerald L. Schnoor, University of Iowa; and Daniel Sklarew, George Mason University.
Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of the report was overseen by the review coordinator, Armistead G. Russell, Georgia Institute of Technology and the review monitor, Robert A. Frosch, Woods Hole Oceanographic Institution. Appointed by the National Research Council, they were responsible for making certain that an independent examination of the report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of the report rests entirely with the committee and the institution.
Over the course of its study, the committee held two public information-gathering sessions. On November 21, 2013, the committee heard from Lucy Greetham (Ecovative Design, LLC) and Elizabeth Craig, Brooke Furio, Al McGartland, Jeffery Morris, Nena Shaw, E. Ramona Trovato, and James Woolford (US EPA). On December 12, 2013, the committee heard from Kevin Dooley and Sarah Lewis (The Sustainability Consortium), Al Iannuzzi (Johnson & Johnson), Stewart Leeth (Smithfield Foods), Robert Perciasepe (US EPA), Andrew Place (Center for Sustainable Shale Development), Carter Strickland (New York City Department of Environmental Protection), and Ron Voglewede (Whirlpool Corporation).
The committee is grateful for the assistance of the National Research Council staff in preparing this report. Staff members who contributed to the effort are Raymond Wassel, project director; James Reisa, director of the Board on Environmental Studies and Toxicology; Mark Lange, program officer; Kara Laney, program officer; Constance Karras, research associate; Keri Stoever, research associate; Norman Grossblatt, senior editor; Mirsada Karalic-Loncarevic, manager of the Technical Information Center; Radiah Rose, manager of editorial projects; Ricardo Payne, program coordinator; Orin Luke, senior program assistant; and Ivory Clarke, senior program assistant.
BOXES, FIGURES, AND TABLES