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OCR for page 165
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
OCR for page 166
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
, ~
.
OCR for page 167
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
OCR for page 168
168
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OCR for page 169
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.)
OCR for page 170
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
OCR for page 172
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
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a)
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
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
-
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
_
.
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
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.
ACID DEPOSITION
187
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