"The government is very keen on amassing statistics. They collect them, add them, raise them to the nth power, take the cube root and prepare wonderful diagrams. But you must never forget that every one of these figures comes in the first instance from the village watchman, who just puts down what he damn well pleases." —Sir Josiah Stamp (1880-1941)
No doubt true, Mr. Stamp, but this nation's problems with the collection, analysis, and dissemination of environmental data go far beyond those created by the whims of village watchmen. Buffeted by budget cuts, policy redirections, and congressional and administrative indifference, our understanding of environmental conditions and trends is at, or near, an all-time low. Strong measures are needed to address this situation. One such action should be the creation of a Bureau of Environmental Statistics.
There are attractive models for the new office I propose. For more than a half century now, the Bureau of Labor Statistics in the Department of Labor has collected and published data about current rates of unemployment, labor force participation, layoffs, and related matters. The Bureau of Economic Analysis in the Department of Commerce has performed a similar function for data on foreign trade (since 1921), GNP growth (since 1942), and other economic measures. And the Bureau of the Census, also a part of Commerce, has been responsible for our decennial population count since 1902. All three bureaus were created in part to ensure the independent and nonpartisan treatment of data and measures that might be politically sensitive.
By most accounts, these bureaus have been very successful undertakings. While there have been occasional cries that population, unemployment, inflation, or GNP growth statistics have been "cooked" to suit political purposes, such charges are rare exceptions. Furthermore, when proposals surface for changing the way population, national income, or unemployment or inflation rates are measured, they are scrutinized and discussed openly.
While no one would argue that our current measures of population or economic activity are exact, it is impossible to imagine modern government operating in their absence. Indeed, these measures drive important federal grant and entitlement programs; they also help trigger, and then measure the success of, major tax and spending programs, monetary policies, and even foreign policy decisions related to economics, defense, immigration, and other issues.
An environmental analogue
It is time, for many reasons, to establish a Bureau of Environmental Statistics that will give the United States much-needed measurement capability in this field. Simply put, we have not a single data series for the environment that goes back as far as even the most recently established of the economic and demographic series listed above, nor one that is subject to the same quality control, careful measurement protocols, or subsequent thorough analysis.
Consider, for example, the beacon light of U.S. environmental monitoring programs—our national program to collect and analyze air pollution data. To begin with, even for the so-called criteria air pollutants (ubiquitous pollutants for which the Environmental Protection Agency [EPA] sets national standards), the nationwide monitoring program is inadequate in several ways.
For instance, such data as do exist on airborne concentrations of lead—a serious threat to health—come from a "network" of only fifty-three monitoring stations intended to represent the whole country. Similarly, despite cries that ambient ozone levels be reduced, in part to alleviate agricultural crop losses, virtually no monitoring is carried out for ozone in rural areas. Instead, we "interpolate" (guess at) rural ozone levels by taking weighted averages of urban readings often obtained hundreds of miles away. And as for the national program that monitors all the toxic air pollutants causing widespread concern? It doesn't exist.
The situation is even bleaker for water quality monitoring and for measurements of pesticides and other substances in soil, on foodstuffs, and in fish, bird, and other animal populations. The same is true for data on the levels of toxic substances in human body tissues, for which a small monitoring program was just eliminated, and for measurements related to wetlands and a host of other sensitive ecosystems.
In short, we are woefully ignorant of the current state of our environment, of how that state compares with the past, and of the role that current policies may have played in accounting for the differences between past and present. To make matters worse, the data that do exist are not at all accessible to interested parties.
Present problems
One reason for this poor state of affairs is the diffusion of effort among many federal agencies. At present, important environmental data are collected by the Environmental Protection Agency, the Geological Survey (in the Department of the Interior), the Forest Service (Department Of Agriculture), the National Oceanic and Atmospheric Administration (Department of Commerce), the Departments of Defense, Energy, and Health and Human Services, and even the National Aeronautics and Space Administration, which has been responsible for recent measurements of stratospheric ozone depletion.
Even if this far-flung network of data collectors were well-funded and operating smoothly, it would still be necessary to gather the relevant measures and disseminate the most important among them in a single, accessible source. An excellent model is the annual Economic Report of the President, prepared by the Council of Economic Advisers (CEA). To prepare the report, economic data from many federal agencies are compiled, and findings are presented in about one hundred tables, many of which show annual statistics going back to 1929. Despite quibbles about the appropriateness of certain series or about changes in measurement techniques from one year to the next, the CEA report makes it possible to assess a number of important economic measures. In so doing, it provides a benchmark against which to measure the consequences of past policies and to anticipate the effects of new ones.
Before its gradual evisceration over the past seven years, the president's Council on Environmental Quality (CEQ) would have been the logical candidate for the compilation and dissemination of environmental data. In fact, CEQ is directed to perform this function by the National Environmental Policy Act of 1969. While CEQ used to take this responsibility more seriously, even in its halcyon days it never mustered the resources to present truly comprehensive and consistent environmental data on an annual basis. Recently the Conservation Foundation has stepped bravely into the breach and attempted to provide regular data on environmental trends. But this responsibility is clearly a federal, not a private, matter.
Unfortunately, current problems with environmental measurement go far beyond the lack of a coordinating body. First, it is probable that too little is spent in the aggregate on environmental measurement and analyses. It is difficult to be more definitive because no recent effort has been made to tally such spending. A 1978 CEQ report put total spending for air and water quality monitoring at more than $300 million per year, which I believe is implausibly high. Even if correct, however, it is not large in comparison with the $70 billion to $90 billion the United States spends each year to comply with federal, state, and local environmental regulations. If we are willing to spend this much money to protect our environment, we ought to care about whether the programs we establish make it better.
Even when adequate monies are appropriate for data collection and analysis, they often get short shrift during the fiscal year. There are two reasons for this. First, money for environmental monitoring is seldom earmarked as such; rather, it is typically part of a more general allotment for specific regulatory programs like air quality, groundwater, or hazardous waste. When Congress then gives these programs unexpected new regulatory or other responsibilities, the money needed to carry them out is invariably withdrawn from data collection and analysis.
Such a withdrawal would be unlikely if data collection and analysis had any political sex appeal. But they do not. No senator could reap credit for battling to increase the number of rural ozone monitors in the United States. Similarly, no congressman could benefit much from jump-starting the moribund water quality monitoring program at EPA, even though such a program is badly needed to help determine whether the hundreds of billions of dollars spent on sewage treatment plants and industrial water pollution controls are having the desired effects.
Addressing the problems
While no panacea, a Bureau of Environmental Statistics—with a separate line in the federal budget—would be much more immune to budgetary triage than are present programs. Such a bureau might even attract congressional champions who are currently unwilling to fight for separate appropriations for environmental data analysis in a handful of programs scattered around a dozen different agencies.
The creation of a strong Bureau of Environmental Statistics might also lessen the temptation to "fudge" environmental data. Although it may seem hard to believe, billion-dollar regulatory decisions can now hang on readings at a few pollution monitors. Consider, for instance, the difference it makes to a metropolitan area to be considered an "attainment" area—a region where national air quality standards are being met—rather than a "nonattainment" area under the 1970 amendments to the Clean Air Act. The deadline for meeting the standards of the act was December 31, 1987, and, technically speaking, metropolitan areas that are not in conformance with these standards are now subject to hundreds of millions of dollars each year in nonattainment sanctions. Local officials in these nonattainment areas face having to notify local air pollution sources that they must install costly additional control equipment. Far more important, these areas face the threat of an EPA-ordered ban on all new construction, a ban viewed as a sort of environmental "death penalty."
Such data as do exist on airborne concentrations of lead—a serious threat to health—come from only fifty-three monitoring stations intended to represent the entire country. Chart shows trends in maximum quarterly average lead concentrations at these fifty-three sites over a ten-year period.
If nonattainment sanctions were triggered by readings at only one or two monitors and for only a few hours per year, the temptation to shut monitors down at strategic times for maintenance or to relocate them to more "convenient" sites could be considerable. Yet these air quality data are currently collected under minimal EPA supervision by the same local governments upon which nonattainment sanctions would fall. While there is no evidence to suggest that our national air quality data have been compromised because of this, only now—with the 1987 deadline past—have these sanctions become a serious possibility. A credible, independent federal presence is badly needed to guard against this possibility. A Bureau of Environmental Statistics could be such a force.
Controversy about environmental data collection and analysis is hardly confined to the local level. Witness the recent contretemps over the 1986 annual report of the federal government's National Acid Precipitation Assessment Program (NAPA). When the report was released in the fall of 1987, critics charged that the underlying scientific data and analysis were, at best, not adequately reflected in the executive summary or, worse yet, were irrelevant to the problem at hand. An independent Bureau of Environmental Statistics would be much better insulated from political pressure than is the interagency NAPAP task force for the job of collecting and presenting information on environmental trends.
There is another reason—more symbolic than substantive, but nevertheless important—that favors the creation of this bureau. Environmental issues matter to the public. While they generally rank below concerns about economic security, this is not always the case. In fact, in a recent public opinion survey by Cambridge Reports, Inc., 58 percent of those polled agreed with the statement, "We must sacrifice economic growth in order to preserve and protect the environment." Only 19 percent supported the opposite view. Support for the primacy of environmental protection in this hypothetical trade-off has grown steadily since 1976, when only 38 percent of those polled by the same organization agreed with the assertion quoted above. Thus, the public is intensely interested in what is happening to the environment; it deserves better answers than are now available.
Setting up shop
Several decisions must first be made if a Bureau of Environmental Statistics is to be established. The initial decision concerns its home in the federal government. In view of the success enjoyed by the Bureau of Labor Statistics and the Bureau of Economic Analysis, the best place for the proposed bureau would he within an existing agency—probably the EPA, because the EPA currently conducts, or should conduct, much of the monitoring and data analysis for which the bureau would be responsible.
However, the EPA is not the only possibility. The Interior Department would also be suitable, in view of the Geological Survey's water quality monitoring work and other department programs on wetlands, endangered species, and related issues.
Regardless of its executive branch "parent," the proposed bureau would have to be granted more independence than is generally given programs in cabinet departments. Greater independence could be achieved by ensuring that the person named as bureau director is a senior civil servant widely respected for integrity and experience in environmental measurement and management. Political appointments to this position should be avoided. In addition, the bureau chief's term of service should be at six to eight years—in other words, long enough for program strength and continuity to be developed.
Another issue to be resolved before establishing a Bureau of Environmental Statistics is the scope of its activities. For instance, should it take over all of the relevant, ongoing monitoring programs carried out by federal agencies? Of should it instead concentrate on coordinating these activities, taking on the primary responsibility for ensuring that the quality of the data collected is high and seeing to it that the data are disseminated in a timely and usable form?
The latter strategy makes more sense, particularly in the early years of the organization. While the bureau might eventually be vested with some data collection responsibilities—perhaps for gathering data not now collected by any other group—it would have its hands full in its start-up years with these functions:
- identifying a comprehensive and standardized set of environmental quality measures on which to report, including traditional indices of air and water quality as well as measures of wetland acreage, stratospheric ozone concentrations, and groundwater pollution;
- determining where, when, and how these measurements are to be taken;
- establishing quality assurance procedures for each data series and ensuring timely reporting by the collecting agencies to the bureau; and
- reporting this information to the public frequently, by way of annual reports and other appropriate means of communication.
A final matter to be resolved is whether the bureau should concern itself only with monitoring environmental quality or whether it should also become involved in what is known as compliance monitoring. In contrast to monitoring ambient air levels of pollution, the latter responsibility would involve the measurement or estimation of pollution emissions by cars, power plants, factories, wood stoves, sewage treatment plants, feedlots, and the multiplicity of other sources of pollution. Here again, the more narrow objective seems appropriate, for two reasons. First, taking responsibility for the development and coordination of a comprehensive ambient monitoring system is ambitious enough without the mission's being expanded even further. Second, compliance monitoring cannot be separated from the enforcement of our environmental laws, and the proposed bureau is not intended to be a cop.
Is the timing right?
There is some reason to believe that a proposal to create a Bureau of Environmental Statistics would not fall on deaf ears. First, Congressman James H. Scheuer (D-N.Y.) has on several occasions introduced an "Environmental Monitoring Improvement Act" to create a temporary national commission that would investigate this country's efforts to collect and publish environmental information and report on ways that these efforts might be improved. His initiatives deserve more serious consideration than they have received. They might be given more notice if his idea for a temporary commission were replaced with the proposal of an independent and permanent Bureau of Environmental Statistics.
There are other indications that the time may be right for the creation of such a bureau. First, a new president will be elected in less than a year, and both parties will have something to gain from espousing the establishment of this entity. For their part, Republicans have consistently and justifiably decried the lack of data on which to base major environmental or natural resource policy decisions. They rightfully claim that debate on a number of pending issues, such as acid rain, groundwater pollution, and stratospheric ozone depletion, suffers from a lack of adequate data. But Republicans have been singularly unwilling to remedy this situation by spending money to fill the information void. If they wish to be seen as credible participants in environmental debates rather than as obstructionists whose excuse is a lack of data, they have to be willing to back up their concerns with new programs to help solve the problem.
Democrats, too, have much to gain from the creation of this bureau. They are often portrayed as being too quick to legislate in the absence of hard evidence of an environmental problem. No data collection system—however complete—will ever be able to "prove" definitively that action is required. But such a system would make it easier to separate serious from less serious problems and would provide details to help tailor programs that effectively address the problems.
Make no mistake about it: any proposal entailing new federal spending will—and should—have hard sledding in future congressional debates. Nevertheless, there is growing support for spending federal money to set up a body such as this bureau. The public cares greatly about the quality of the environment and the condition of the natural resource base. A great deal of money is spent each year because of these concerns. Yet there is no comprehensive and reliable system for collecting, analyzing, and disseminating information about how these expenditures are linked to environmental quality.
This state of affairs makes little sense, and it is hard to see how one could think otherwise. The creation of a Bureau of Environmental Statistics, preferably within the EPA, would not remedy this situation overnight. But it would be a sensible and politically feasible step in the right direction.
Paul R. Portney is a senior fellow and director of the Center for Risk Management at RFF.
A version of this article appeared in print in the January 1988 issue of Resources magazine.
