Appendix C
The Sustainability Assessment and Management Approach
Sustainability and the U.S. EPA (NRC 2011), known also as the Green Book, was prepared in response to a request from EPA for an NRC study committee to help the agency strengthen the analytic and scientific basis for sustainability.1 Specifically, the following questions were posed to the NRC Committee on Incorporating Sustainability in the U.S. Environmental Protection Agency:
• What should be the operational framework for sustainability for EPA?
• How can the EPA decision-making process rooted in the risk assessment/risk management (RA/RM) paradigm be integrated into this new Sustainability Framework?
• What scientific and analytical tools are needed to support the framework?
• What expertise is needed to support the framework? (NRC, 2011, p. 133)
EPA had already begun sustainability initiatives and featured sustainability in its 2011-2015 strategic plan prior to its request to the NRC, but it sought “an operational framework to integrate sustainability as one of the key drivers within its regulatory responsibilities” (NRC, 2011, p. 1). A framework would provide a means by which to institutionalize sustainability in agency decision-making and effectively use the concept as a process and as a goal.
The Green Book committee relied upon the definition of sustainability provided in Executive Order 13514: “to create and maintain conditions under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations.” It presented the Sustainability Framework and the Sustainability Assessment and Management approach to guide and support EPA in its use and incorporation of sustainability (Figure 1-1 in Chapter 1). In developing the framework, the Green Book committee sought to ensure that it would need to lead to measurable goals and objectives that can be publicly reported, be flexible for use with new developments in science, technology, and the economy, work within the current RA/RM paradigm, and facilitate decision making supportive of EPA’s mission to protect human health and the environment (NRC, 2011).
The framework is organized into a two-level process. The Sustainability Framework is described in the Green Book as Level 1 (Figure 1-1). At this level, the framework begins with a paradigm, principles, and responsibilities. The Green Book committee recommended that EPA select the three-pillar approach (social, environmental, and economic) as its sustainability paradigm and that it highlight in particular the inclusion of human health as a component of the social pillar. The Green Book committee also suggested that EPA develop, adopt, and publish EPA Sustainability Principles to “guide the agency’s implementation of regulatory mandates and discretionary programs in ways to optimize benefits” related to sustainability (NRC, 2011, p. 41). Such principles could include transparency, accountability, and effectiveness, and the Green Book placed emphasis on principles related to justice, intergenerational and intragenerational equity, and a holistic systems approach to solving environmental problems. Finally, the Green Book noted that EPA would benefit from integrating sustainability into its implementation of regulatory authorities and objectives.
____________________
1NRC (National Research Council). 2011. Sustainability and the U.S. EPA. Washington, DC: National Academies Press.
The next step in Level 1 of the framework is the development of an EPA Sustainability Vision to guide employees in the use of sustainability as a process and as a goal. With this vision set, EPA can then establish objectives, goals, indicators, and metrics to achieve sustainable outcomes and to reinforce to employees the agency’s commitment to integrating sustainability into its operations. In terms of organization and culture, the Green Book committee emphasized the need to incorporate sustainability into the culture of EPA, which has already begun in some parts of the agency. Another key recommendation of the Green Book is that “EPA should incorporate upfront consideration of sustainability options and analyses that cover the three sustainability pillars, as well as trade-off considerations into its decision making” (NRC, 2011, p. 49). The penultimate step of Level 1 is the Sustainability Assessment and Management approach, which addresses day-to-day activities and comprises Level 2 of the framework. The framework concludes with periodic evaluation and public reporting of accomplishments toward objectives and goals.
Level 2, or the Sustainability Assessment and Management (SAM) approach, is designed to help sustainability inform decision-making (Figure 1-2). It is a multi-step process geared towards major decisions that could affect more than one pillar of the sustainability paradigm. However, it could be scaled down to address more minor or routine decisions. Therefore, the first step in SAM is to evaluate the level of depth of analysis needed for the decision at hand.
To do this, screening tools must be used. One example included in the Green Book is a quick scan process to assess whether a project affects more than one pillar of sustainability and what the magnitude of potential impacts will be. EPA could also make use of check lists and impact matrices to evaluate a program initiative against economic, environmental, and social criteria to determine if there will be moderate impacts to and potential conflicts between the pillars. If so, EPA could decide that further analysis is needed. Regardless of what screening tools EPA selects, it needs to formalize a screening procedure to be used at the start of its decision-making process.
If further analysis is needed, then EPA has to define the scope of the problem and identify alternative decisions that could be made with respect to the problem. Once alternative options have been identified, EPA can begin to assess the extent and timing of stakeholder engagement. It can also develop indicators and metrics to help them evaluate outcomes and success.
When the problem has been scoped, stakeholders and collaborators identified, and metrics for success developed, then EPA needs to select and implement assessment tools to quantify the impacts of decisions on sustainability criteria. The Green Book highlighted many sustainability assessment tools that have been developed but emphasized that the list is not exhaustive and that EPA will need to keep abreast of the latest developments in sustainability assessment tools and possibly develop new tools itself as assessment capabilities progress.
The Green Book presented six principles in the application 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 impacts 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 communicated to decision makers.
• Data availability will, in part, determine the necessary tool.
• Uncertainty and sensitivity analysis will be required (NRC, 2011, pp. 59-60).
However, the Green Book committee did not make prescriptive recommendations about what tools to use in particular situations. Rather, the framework was designed to provide EPA with a way to assess how sustainability can be incorporated into a decision and how to select tools to use to achieve sustaina-
ble outcomes in the myriad types of decisions that EPA makes. However, the Green Book did not illustrate how to apply sustainability tools and methods in the SAM approach. The report noted that EPA will have to continue to adapt and improve tools to inform sustainability analysis.
Following the application of appropriate sustainability tools, the SAM approach includes trade-off and synergy analysis, which seeks to maximize all three pillars of sustainability in a decision while minimizing the adverse effects that occur when sustainability goals amongst the three pillars are in conflict with one another. The Green Book stressed that EPA will need to develop a systematic way to assess trade-offs “because improperly managed trade-offs can compromise environmental protection, public health, or other key aspects of sustainability” (NRC, 2011 p. 66).
The SAM approach also emphasized the need to clearly communicate results of the screening procedure, sustainability assessment tools, and trade-off and synergy analysis to decision-makers. This communication is essential to helping a decision-maker process the results before deciding which course of action to take. It also may help illuminate whether any further analysis needs to be undertaken before a decision is made.
The end of the SAM approach includes an evaluation of outcomes. This may start with a comparison between the observed outcome and the one projected in the original options identification. Differences that exist may point out weaknesses in the assessment tools or the data used to inform the process. It is also important to assess whether the outcome was within the predicted range of uncertainty. The results of such evaluations should be published to keep stakeholders engaged and to provide lessons learned about incorporating sustainability.
An important Green Book recommendation for a SAM approach is that EPA needs to develop a “sustainability toolbox” to use with this approach. In addition to analyzing the consequences of different decisions in the context of the sustainability paradigm, the tools should be used in a way that can address situations ranging from simple to complex and that “have the capability for showing distributional impacts of alternative options with particular reference to vulnerable or disadvantaged groups or ecosystems” (NRC, 2001, p. 72).
While EPA has made efforts to incorporate sustainability as a priority in its work, the Green Book noted that there was no formalized approach to conducting the analyses called for in the SAM approach. Therefore, the report recommended EPA create and adopt a formalized process for using the SAM approach when making decisions. The full set of findings and recommendations from the Green Book on the SAM approach are presented below.
FINDINGS AND RECOMMENDATIONS ON THE SUSTAINABILITY ASSESSMENT AND MANAGEMENT APPROACH2
4.1. Key Finding: The Sustainability Assessment and Management approach “requires application of a suite of tools capable of analyzing the full set of current and future social, environmental, and economic consequences of alternative 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 modification or expansion to be appropriate and some new tools will need to be developed (pp.60-65).
4.1. Key Recommendation: EPA should develop a “sustainability toolbox” that includes a suite of tools for use in the Sustainability Assessment and Management approach. Collectively, the suite of tools should have the ability to analyze present and future consequences of alternative 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 disadvantaged groups and ecosystems.
4.2. Finding: An important step in the Sustainability Assessment and Management 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
____________________
2The findings and recommendations are excerpted from pages 72–74 of NRC (2011).
potential future conditions as a function of the decision option chosen, although there will always be some degree of uncertainty attached to the forecast (pp.64-65).
4.2. Recommendation: EPA should identify potential future environmental problems, consider a range of options to address problems, and develop alternative 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 involved in state-of-the-environment and environmental assessments, it currently 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 (pp.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 environmental issues often does not adequately account for the full range of ecosystem benefits, take intergenerational considerations into account sufficiently, 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 environmental 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 sustainability 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.
