NRC report: EPA should incorporate sustainability tools and approaches in its decision making more broadly

Washington, D.C. — A broad array of tools is available to help the U.S. Environmental Protection Agency incorporate sustainability concepts into its decision making, and the agency should do so across its spectrum of activities, says a new report from the National Research Council.

For every major decision, EPA should include a strategy to assess implications for the three dimensions of sustainability — environmental, social, and economic — in an integrated manner. EPA should also collaborate with private-sector companies and non-government organizations (NGOs), leveraging their insights and experiences with sustainability and sharing best practices with companies that have not made much progress in incorporating sustainability concepts into their business models.

“We hope sustainability approaches will play an increasingly influential role in EPA’s risk-management decisions going forward,” said Michael Kavanaugh of Geosyntec Consultants in Oakland, Calif., and chair of the committee that wrote the report. “The complexity of the challenges facing the agency and the nation – such as climate change and greater consumption of natural resources – make the use of these approaches vital for protecting current and future generations, encouraging innovation in problem solving, and building solutions relevant to the scale of the problems we face.”  

The new report builds on a 2011 report by the National Research Council, Sustainability and the EPA, referred to as the Green Book. The Green Book recommended that EPA adopt a sustainability framework that would incorporate a more holistic assessment of environmental, economic, and social factors in its decision making. It recommended that EPA develop a “sustainability toolbox” of analytic tools that would help the agency implement this approach. EPA then asked the National Research Council for advice on tools and analytic approaches, and the new report responds to that request.

A broad array of sustainability tools and approaches could be applied by EPA to assess potential environmental, social, and economic outcomes in the agency’s decision-making context. EPA took a good first step by collecting a set for its recent report Sustainability Analytics: Assessment Tools and Approaches, which summarizes 22 types of tools for conducting sustainability assessments, ranging from economic benefit-cost analysis to risk analysis to environmental-justice analysis. Some of the tools are well-developed and widely used, while others are still in development.

The new Research Council report says EPA should consider using a consistent set of criteria to rate those and other sustainability tools, a step that will help the agency determine which approaches are developed enough for use and what tools are appropriate for a particular situation. The report offers a set of rating criteria, examples of which include the adequacy of data to support a tool’s application and the degree of consensus among stakeholders and the scientific community as to how the method should be used. EPA should consistently use similar criteria to periodically evaluate and update its views and experiences with sustainability tools. The agency should also use a publicly available Internet-based mechanism — for example, an online wiki — to track updates about existing and emerging tools.

A potentially important tool that was not included in EPA’s Sustainability Analytics report is analysis of the social cost of carbon — an estimate of the monetized damage associated with future potential effects of an incremental increase in greenhouse gas emissions. This approach allows government agencies to evaluate and incorporate the benefits of reducing greenhouse gas emissions. Given the prominence of climate-change mitigation issues for EPA, the agency should include it in its Sustainability Analytics list in the future. The committee also recommended that EPA develop a process to determine when uncertainty analysis is an essential component of the use of a tool.

The report provides several case studies to illustrate how EPA can incorporate sustainability tools into decisions. One case study illustrates how to build consideration of the sustainability pillars – social, environmental, and economic dimensions — into the criteria used to select a remedy for a site remediation project. Life-cycle analysis was used to take into account greenhouse gas emissions, water pollution, and other environmental effects, while analyses of the costs of possible remedies and their potential effects on the community shed light on the economic and social impacts.

Without losing focus on its existing regulatory mandates, the report says, EPA should broaden its considerations from its traditional emphasis on reducing emissions or waste releases from individual point sources in specific economic sectors to an approach that considers life-cycle effects of business processes along the entire “value chain” of a product’s development, including raw material extraction, manufacture, consumer use, and reuse.

Although private-sector experiences are not applicable to all of EPA’s mission-related activities, the agency should collaborate with industry and other organizations and leverage their experience and insights, the report adds. The last decade has seen a dramatic expansion in collaborative relationships created by NGOs and global companies in order to address sustainability challenges. By working with these companies and organizations, EPA and other government agencies can gain new insights that will help them define performance requirements, using a combination of regulatory and non-regulatory approaches to improve performance on key sustainability indicators. In addition, as EPA develops its greenhouse gas management policies, it should strive to learn from private-sector experiences how well-designed economic incentives can approach sustainability objectives. EPA should also share leading companies’ insights and best practices with businesses that have not made as much progress in incorporating sustainability concepts.

The study was sponsored by the U.S. Environmental Protection Agency. The National Academy of Sciences, National Academy of Engineering, Institute of Medicine, and National Research Council make up the National Academies.

The full report is available at www.nap.edu/catalog.php?record_id=18949.