
Environmental Encyclopedia 3
Comparative risk
In late 1991, Senator Daniel Patrick Moynihan (D-
N.Y.) introduced a bill (S.2132) that would have required
EPA to seek the advice of experts in ranking relative risks and
to use that information in managing its available resources to
protect society from the greatest risks. Moynihan’s bill, and
its successor in the 103rd Congress, became important ele-
ments of the debate over whether risk-based “rational” prior-
ity setting should be required to ensure more efficient risk
reduction.
Even before the 1991 EPA report on the rising costs
of environmental protection, EPA Administrator William
K. Reilly had taken up comparative risk as a central theme
of his administration and had asked the agency’s Science
Advisory Board to review the report issued by the 75 agency
professionals. The board’s response, a 1990 report called
Reducing Risk: Setting Priorities And Strategies For Environ-
mental Protection, also recommended that EPA and other
government agencies “assess the range of environmental
problems of concern and then target protective efforts at
problems that seem to be the most serious.” Far and away
the greatest expenditures of EPA resources were directed at
the agency’s construction grants program for publicly owned
wastewater
treatment plants and the cleanup of abandoned
Superfund sites—for instance, a full 70% of the agency’s
fiscal year 1990 budget of $6 billion went to these pro-
grams—even though other problems were deemed more
serious from a scientific perspective. The science advisors
also suggested that EPA should give more attention to the
relatively neglected job of protecting ecosystems, which faced
high risks from
habitat
alteration, loss of
biodiversity
,
global
climate
change, and
ozone layer depletion
.
Reducing Risk, and the general topic of whether “Worst
Things First” should be the touchstone of environmental
priority setting, was debated at a November 1992 meeting in
Annapolis, Maryland, at which critics challenged its “quasi-
scientific” claims and offered competing priority setting ap-
proaches, including a strategy that would make preventing
pollution the fundamental criterion for
environmental pol-
icy
decisions founded on the public’s decision that pollution
is undesirable. In the critics’ view, comparative
risk analysis
presumes that some pollution and its risk is acceptable.
Skepticism notwithstanding, EPA chose to foster de-
velopment of the method. As part of its endorsement of
comparative
risk assessment
as an important priority set-
ting tool, EPA promoted a series of comparative risk projects
in several of its regions—Region 1, New England; Region
3, the Mid-Atlantic states; and Region 10, the Pacific North-
west—and in three pilot states: Washington, Colorado, and
Pennsylvania. Later, Vermont, California, Utah, Michigan,
and other states joined in. Sub-state entities also developed
projects, including Columbus, Ohio; Atlanta, Georgia; Eliz-
abeth River, Virginia; Houston, Texas; and Wisconsin tribes.
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Typically, comparative risk projects follow six basic
steps. First, they define and analyze the risks posed by envi-
ronmental problems facing the jurisdiction, usually working
from a list of problems. Second, they rank the problems
according to the relative severity of each, using technical
information and criteria to grade the negative impacts of
individual problems on health, ecosystems, or quality of life.
Third, they select priorities for special attention and set
goals for reducing risks posed by the problem. Fourth, they
propose, analyze, and compare strategies for achieving the
goals set in step three. Fifth, they implement strategies hav-
ing the greatest risk-reduction promise. And, sixth, they
monitor results produced by the strategies and adjust juris-
dictional policies or budgets based on those results. These
steps are carried out through committees composed of state
or local officials, industry representatives, environmentalists,
and citizens. The projects all seek to broadly incorporate
public values—not merely technical scientific information—
in assessing and ranking risks.
Among the more widely cited state comparative risk
projects is Washington Environment 2010, which, more
than any other state project, influenced legislation and state
policy. It was initiated in 1988 by Washington’s Department
of Ecology Director Christine Gregoire and included techni-
cal committees with members from 19 state agencies and a
steering committee composed of senior managers or heads
of those agencies. In addition, it had a public advisory com-
mittee composed of 34 prominent legislators, representa-
tives, and important interest groups. Resulting from this
project was a ranking of 23 threats to the environment within
five priority levels.
Ambient air
pollution, point-source dis-
charges of pollution to water, and polluted
runoff
ranked
as the top priorities, and non-ionizing radiation, materials
storage in tanks, and litter ranked as the lowest priorities.
Based on the project, and a statewide effort to solicit public
responses that produced some 300 risk-reduction options,
Washington’s legislature in 1991 adopted several new envi-
ronmental laws dealing with clean air,
transportation
de-
mand,
water conservation
,
recycling
, growth manage-
ment, and the state’s
energy policy
. The Department of
Ecology redirected $6.8 million of its budget from lower to
higher risk priorities. However, in 1993 Gregoire’s successor
reorganized the department, dismantling an Environment
2010 planning staff that had been established and, with
it, the state’s institutional memory of the comparative risk
project. Washington’s experience in this regard, and similar
experiences in other states, have made some proponents
of comparative risk assessment question how deeply and
lastingly its effects will be felt in environmental programs.
Despite such setbacks, the comparative risk concept
has continued to find a significant place in governmental
discussions of environmental policy. In 1993, the White