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Building Evaluative Models in Environmental Policy:
State Innovations in Environmental Management
Exploratory Essay
Matthew Alan Cahn
Department of Political Science
California State University, Northridge
18111 Nordhoff Street
Northridge, CA 91330-8254
(818) 677-4797
internet: [email protected]
Building Evaluative Models in Environmental Policy:
State Innovations in Environmental Management
ABSTRACT
California has long been looked to for innovations in environmental policy. As a consequence
of its growing urban density and degraded environment, California has emerged as a leader in creative
environmental policymaking. This paper blends normative and empirical approaches to public policy
analysis in an effort to evaluate California's environmental policy approach. The study builds a model
for evaluating the efficaciousness of environmental policy models, and applies that model to southern
California's South Coast Air Quality Management Plan (SCAQMP).
The model evaluates policy success based on eight components: breadth of policy,
intergovernmental autonomy (federalism), regulatory flexibility, economic environment, corporate and
citizen behavior change, compliance strategies, mechanisms for effective implementation, and outcome.
In this sense, the model addresses policy coverage, implementation, and outcomes. Implicit in this is
an analysis of policy evolution, which ultimately influences all of these factors.
Building Evaluative Models in Environmental Policy:
State Innovations in Environmental Management
I. Introduction
California has long been looked to for innovations in public policymaking. California's
environmental policy is no different. Perhaps as a consequence of its growing urban density and
increasingly degraded environment, California has emerged as a leader in creative environmental
policymaking. This is especially true in air quality policy. Southern California's South Coast Air
Quality Management Plan (SCAQMP or AQMP) leaves the federal air quality model and institutes
a stringent twenty year plan to reduce smog. The commitment of California to lower emissions
through a four point plan of conservation, alternative fuels, mass transit, and a shift in residential
and economic social patterns, makes the plan the strongest clean air program in the world.
Incorporating a cross-methodological approach, this study builds a qualitative model of
environmental policy efficaciousness, drawing on several studies, and tests that model according to
California's experience. Through such an approach it is possible to evaluate policy success in a
comprehensive manner, pinpointing elements that may bring utility to related policy areas. In
developing systematic criteria for evaluating case studies this model provides a lens through which
to deconstruct policy and assess policy elements independently and collectively. This, in turn,
allows observers to draw specific conclusions on real world policy alternatives. At this juncture in
the policy literature it is appropriate to assess experimental policies so as to determine which tools
provide the most utility.
Policy analysis as a discipline has sought to build tools for identifying successful policy
construction. This study contributes to this literature in two areas: first, it sharpens evaluative
criteria for measuring policy success; and second, it evaluates one of California's most innovative
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policies -- the SCAQMP -- in an effort to determine whether the program provides an efficacious
policy model. In this sense, this study develops a normative tool for assessing real-world policy
experiments, and applies that tool through a case study of Southern California air quality
management.
II. Policy Analysis: The State of the Literature
Over the past several decades policy analysis has emerged as a major subfield within the
discipline. Yet, there remains several disparate approaches, with little unifying consensus. The
literature revolves around the "art and craft" of policy analysis (e.g., Wildavsky 1979), evaluation
research methodologies (e.g., Caro 1977), outcomes analysis (e.g., Mazmanian and Morell 1992),
and implementation research (e.g., Pressman and Wildavsky 1984, Mazmanian and Sabatier 1989).
Formal methodology in policy evaluation goes back to Rice's (1897) work in education
research. Chapin (1917) later sought systematic application of experimental methodologies in
sociological research. Evaluation research expanded through the 1920s and 1930s with several
studies looking at emerging social programs (e.g., Mayo 1933; Dickson 1939). Lippit (1940) went
on to explore the effects of autocratic and democratic leadership styles on children.
Following the second world war Lewin (1948) and others further developed experimental
research models in social psychology (Caro 1977a). As the 1950s unfolded systematic social
scientific methodologies were the norm in program evaluation. Riecken's (1952) study of work
camp programs and Hyman, Wright, and Hopkins (1962) study of the effects of summer camp
experiences on college students are indicative of the behavioral trend. The evolution of poverty
related social programs in the 1960s led to several studies of antipoverty programs (e.g., 1967).
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Large scale formal program analysis emerged in the 1970s (e.g., Rivlin 1971).
"What's Wrong with Policy Analysis"
Policy evaluation is predicated on identifying clear goals, and measuring the extent to which
such goals have been attained (Peters 1993). Goal identification, however, is typically difficult.
Several authors remind us that stated policy goals are often different than actual policy goals (e.g.,
Edelman 1971, 1977; Navarro 1984; Stone 1988; Cahn 1995). The current crime policy discourse
(e.g., "Three Strikes") provides but one example.
Thus, how one defines policy goals, issues of equity, and policy efficiency, will necessarily
determine evaluation outcomes. Peters suggests that "evaluative programs will have their own
perspectives on what is right and what is wrong in policy and will bring those values with them
when they perform an analysis" (1993:160).
One example of such different evaluation perspectives was presented by Nelson (1979) in an
article suitably titled "What's Wrong with Policy Analysis." The Kennedy School of Public Policy
and Berkeley's School of Public Policy each evaluated the Comprehensive Employment and
Training Act (CETA) in the late 1970s. The JFK evaluation stressed economic efficiency, and
implemented a narrow benefit-cost calculation. They concluded that CETA was a wasteful and
inefficient program. The Berkeley evaluation stressed the level of participation in the program, and
thus found CETA to be quite successful (Peters 1993).
Policy Analysis and Policy Evaluation
A distinction is made between policy analysis and policy evaluation. Dye (1992) defines
policy analysis as a threefold venture, including "a primary concern with exploration rather than
prescription.... a rigorous search for the causes and consequences of public policies.... (and) an effort
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to develop and test general propositions about the causes and consequences of public policy and to
accumulate reliable research findings of general relevance" (1992:7). Policy evaluation is
concerned with assessing the impact or consequences of public policy (e.g., Wholey et al. 1970). In
this sense policy evaluation is a subset of policy analysis -- analysis being concerned with an overall
explanation of policy, from origination through implementation and evaluation; evaluation is
concerned only with assessing effectiveness of policy or program.
Still, policy analysis is an incredibly slippery animal. Wildavsky, perhaps, said it best.
Calling policy analysis undefinable, he wondered "how can you teach (or write a book about) a
subject if you can't say what it is?" (1979:2). Or, in the immutable words of George Bush, we may
not be able to define it, but we know it when we see it. Yet, there is a necessity to learn what we
can about policy impacts. Wildavsky suggests that "policy analysis is an art. Its subjects are public
problems that must be solved at least tentatively to be understood...." (1979:15).
Clear assumptions can be made about policy analysis and policy evaluation, though these
may vary from person to person. Analysis, classically, is the attempt to anticipate the effect of
potential policies and programs -- what impact will these policies have? Evaluation, in contrast,
measures the degree to which policies or programs have met their specified goals -- what impact did
these policies have?
Approaches to Policy Analysis
Methodological applications for policy analysis vary depending on how indicators are
defined. Benefit-cost analysis creates a calculus for weighing the value of benefits against
the cost of benefits. Ethical modeling allows assessment based on normative issues such as
life preservation (e.g., public health criteria), equity, and efficiency (Stone 1988). Outcomes
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analysis may focus on measuring the degree to which stated goals are met. Impact analysis
assesses the broader impact of a policy or program on target groups, non-target groups, on
budgets, and even on symbolic discourse. Process analysis assesses the value of the policy
formation process itself. What interests influenced the process? Who were the winners and
losers? What assumptions, values, and agendas were helped by those influencing, and
ultimately making policy? Institutional evaluation explores the relationships between the
institutional policy actors within the policy subsystem and the output they produce (Bartlett
1994).
Bartlett (1994), in discussing environmental policy evaluation, suggests that while there are
many different kinds of approaches to policy analysis it is not useful to combine them into a "grand,
all-purpose evaluation model." Rather, he suggests that each approach may be appropriate for
specific types of questions. Still, it may be even more appropriate to develop larger, multivariate
models, particularly when evaluating a large and complex program such as air policy controls. A
model of appropriate indicators would allow us to understand policy more organically -- more
accurately. That is, policy impacts are present on several levels simultaneously, and overall
assessment can only be made when each level is understood in relation to each other. The section
below defines an eight point model consisting of evaluation criteria in several areas.
III. The Model
This model blends normative and empirical approaches to public policy analysis in an effort
to evaluate California's environmental policy approach. The study builds a model for evaluating the
efficaciousness of environmental policy models, and applies that model to Southern California's Air
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Quality Management Plan (AQMP). The model evaluates policy success based on eight
components: breadth of policy, intergovernmental autonomy (federalism), regulatory flexibility,
economic environment, corporate and citizen behavior change, compliance strategies, mechanisms
for effective implementation, and outcome. In this sense, the model addresses policy coverage,
implementation, and outcomes. Implicit in this is an analysis of policy evolution, which ultimately
influences all of these factors.
I Breadth of Policy
To what extent do these policies address the breadth of related environmental problems, and
unrelated environmental controls?
Environmental policy has traditionally approached different types of environmental
degradation as independent problems requiring independent solutions. This ignores the
interdependence of environmental problems, and the often competing goals of specific
environmental controls. The following experience illustrates the problem.
The EPA office of air quality issued a directive to a large chemical plant in New Jersey
requiring the facility to install a "wet air scrubber" on its smokestack. The scrubber washes
contaminants out of the stack exhaust and dissolves them in waste water. The EPA office of water
quality, on the other hand, issued a directive that the facility install waste water treatment equipment
that removes contaminants from water and releases them in the air. Complying with both of these
competing controls cost the company $3 million dollars, and eliminated any positive reduction of air
emissions or contaminants in waste water. (Healy 1994)
The "breadth" component assesses the impact the policy may have -- both anticipated and
unanticipated -- on other environmental areas.
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II Intergovernmental Autonomy (Federalism)
To what extent do these policies comply with federal regulations; To what extent does
California maintain respect for local autonomy and attempt to maximize local and regional
initiative?
The relationship between federal, state, and local agencies has always been a critical concern
within the policy process. There has always been tension between federal power and states' rights.
And, while the environmental infrastructure evolving in the 1960s and 1970s clearly illustrates the
need for federal mandates for environmental improvement, the slow compliance of most states
suggests that federal mandates alone create an adversarial relationship with regulated jurisdictions.
Local and state autonomy will maximize the initiative of regulated jurisdictions, and create a sense
of ownership of regional policy controls. This ownership will create a greater sense of regional
responsibility, maximizing compliance with federal guidelines.
In studying California's air quality programs Mazmanian (1995) argues that the private
sector has internalized environmental values, and concerned with the intrusiveness and inefficiency
of public sector policies, has initiated alternative approaches to reducing smog. Such actions, he
points out, should be encouraged by decentralizing air regulations. In this sense, a multi-level
approach may be useful.
Federal intervention should be minimal, perhaps only in providing baselines -- minimum
standards and deadlines. The baseline should provide a transparent foundation upon which local
policy initiatives are built. State level intervention should focus on facilitating regional
management and shared technology (e.g., Mazmanian 1995). Local control, therefore, should
remain paramount. Such an approach provides maximum flexibility in meeting standards.
As such, the "federalism" component assesses the degree to which local and regional
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policies comply with state mandates, and the degree to which state policies comply with federal
mandates. Additionally, this component assesses the extent to which local autonomy is maintained
in order to maximize local and regional initiative.
III Policy Flexibility
This component evaluates the degree to which the policy is flexible. Policy flexibility is
important both to maximize local initiative and to allow room to navigate unanticipated
events in the future.
As the Federalism component above suggests, policy flexibility is critical. The key is to
allow policy flexibility while maintaining policy goals. The best analogy might be taken from
coastal navigation and seamanship. Coastal navigation is based on deduced reckoning, or "dead
reckoning", to chart an evolving course from the point of origin to the destination (Maloney 1978).
If the policy goal is seen as the destination, dead reckoning may provide useful insights.
Dead reckoning begins with a known point, and requires constant reassessment of current
location based on several indicators. The influence of currents, wind direction and velocity, and
wave action all push the vessel off the original chartline. Course adjustments are necessary to
account for these intervening influences in order to arrive at the predetermined destination. The
altered course brings the vessel from the currently calculated position toward the final destination.
Policy navigation requires the same process. All policies are subject to intervening
influences, such as shifting political priorities, unanticipated funding constraints, and intruding
management crises. The success of any policy, then, may be in frequent reassessment and
repositioning to accommodate intervening influences and maintain a course, albeit an updated
course, toward the predetermined policy goal.
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IV Economic Environment
This component evaluates the degree to the economic environment is anticipated during the
life of the policy.
The economic environment is central in the selection of policy options. Since policy
resources are limited, a reduction in available funding would clearly undermine the policy in
implementation. Thus, the evolving economic environment must be assessed to identify the level of
resources that may reasonably be expected to be available during the life of the policy.
V Corporate and Citizen Behavior Change
Environmental improvement relies on technical improvements, and perhaps more
importantly, corporate and citizen behavior changes. This component evaluates the degree
to which these policies encourage behavior changes, both on the commercial and residential
level.
The literature on environmental degradation focuses on the consequences of specific human
behaviors that are manifest in economic production and social interactions (see, for example,
Rosenbaum 1991 or Smith 1992). Environmental policies have traditionally focused on
technological changes (e.g., the 1990 Clean Air Act). What is often overlooked is the necessity to
change human behavior patterns so as to create environmentally friendly economic and social
patterns (Ophuls 1977; Heilbroner 1980; Milbrath 1989; Orr 1992; Cahn 1995).
Bartlett (1994) points out that while Superfund (CERCLA) has been widely criticized as a
failure due to the large amounts of money spent on litigation and the relatively few cleaned sites, the
liability clause in the act has forced behavior changes that may significantly reduce future
contamination. The impact of such behavior changes is significant.
This component assesses the degree to which the policy encourages environmentally friendly
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behavior changes, both on the individual level, and on the collective level.
VI Compliance Strategies
To what degree do these policies employ rational strategic mechanisms to maximize
compliance?
Non-compliance has emerged as a major issue within the environmental policy subsystem.
Traditional command and control policy structures have largely failed. Cohen and Kamieniecki
(1991) argue that rational strategies can be utilized to maximize compliance. Rather than rely on
command and control structures, they suggest an integrated plan utilizing several compliance
devices, including market incentives, insurance requirements, self-regulation, taxes and fees,
permitting, adjudication, and inspections.
This component assesses the degree to which the policy incorporates innovative compliance
strategies in order to avoid the regulatory stalemate that has characterized environmental regulation
through the 1970s and 1980s.
VII Mechanisms for Effective Implementation
To what extent does the policy framework employ mechanisms to maximize implementation
potential?
Implementation is perhaps the greatest point of vulnerability within the policy process
(Pressman and Wildavsky 1984; Mazmanian & Sabatier 1989). Regardless of the good intentions
of policy designers, if policy goals are vague, or if implementing agencies do not share the goals of
the policy, policy implementation will deteriorate and policy success will be minimized.
Mazmanian and Sabatier provide six criteria for successful policy implementation. A summary of
these criteria follow (1989:41-42):
1)
The policy (enabling legislation or other legal directive) provides clear and consistent policy
objectives, and provides substantive criteria for resolving goal conflicts.
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2)
The policy provides implementing agencies adequate jurisdiction and leverage to attain
desired goals.
3)
The policy assigns implementation responsibilities to sympathetic agencies with adequate
financial resources.
4)
The management of implementing agencies possess adequate organizational and political
skills and are committed to policy goals.
5)
The policy maximizes support by organized constituency groups and key legislators and
executive agency personnel throughout the implementation process.
6)
The priority of policy goals is not undermined by the emergence of conflicting policies.
This component utilizes the Mazmanian and Sabatier
conditions as criteria to assess implementation success.
VIII Outcomes
To what extent have/ will these policies result in the anticipated outcomes?
Outcomes analysis, of course, remains a critical component in evaluating policy success.
This component assesses the degree to which the policy has attained, or may be expected to attain,
the stated goals.
IV. The South Coast Air Quality Management Plan: An Overview
Like many other jurisdictions, California was slow to comply with the 1970 Clean Air Act
amendments. California's State Implementation Plan (SIP), accepted by the EPA under the Reagan
administration, argues that Southern California simply could not meet federal standards. But,
ironically, it was this weak SIP that initiated California's evolution as the leader in innovative clean
air policy. The acceptance of California's SIP allowed environmentalists to challenge the EPA's
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weak implementation of the Clean Air Act in court.
The 1989 AQMP
In 1987, after discussions with EPA broke down, the Ninth Circuit Court of Appeals in San
Francisco ordered the EPA to reject California's 1984 SIP. Facing potential sanctions, including the
loss of federal highway and sewer funds, and with prodding from Rep. Henry Waxman (D- Los
Angeles), the California Air Resources Board (CARB), the Air Quality Management District
(AQMD), and the Southern California Association of Governments (SCAG), created the initial Air
Quality Management Plan (AQMP) for southern California in 1989 (Kraft 1993).
California has the nation's worst record for air quality. This, in part, explains why California
state air quality officials voted to leave the federal air quality model and institute a stringent twenty
year plan to reduce smog. The plan mandates specific controls to be in place by 2010. The first part
of the plan (Tier I) includes 123 immediate controls to be implemented between now and the year
2000. These controls focus on immediate changes based on current technologies, such as
reformulating commercial and household paints and solvents to reduce hydrocarbon emissions,
regulating charcoal broilers in restaurants, requiring emission control equipment for bakeries and
dry cleaners, and more effective inspection of motor vehicles. In addition, the AQMP requires large
employers -- those employing 100 people or more -- to provide employees with incentives for
carpooling and public transit use. (Kamieniecki and Ferrall 1991; SCAQMD 1994)
The second section of the plan (Tier II) depends on the development of new technologies,
and requires implementation over a fifteen year period. This portion of the plan mandates that 40%
of private vehicles and 70% of commercial trucks and buses be required to run on non-petroleum
fuels, such as methanol, by 1999. Two percent of all cars sold in 1998, and ten percent in 2003,
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must meet zero emission standards. With available technology, only electric vehicles are able to
meet that standard. The plan also includes the construction of housing hubs closer to job centers,
and improved mass transit and car pooling.
The final portion of the plan (Tier III) requires the further evolution of new technologies, and
therefore focuses on research and development and includes the establishment of an Office of
Technology Assessment. The specific controls in this section of the plan include the conversion of
motor vehicles to "extremely low-emitting" engines, which may preclude the use of the internal
combustion engine (Kraft 1993; SCAQMD 1994).
Changes for 1991
By 1991 the AQMD adopted a revised AQMP. The 1991 plan maintains the basic structure
of the 1989 plan, but establishes several new control measures that include the application of more
advanced technologies, such as the Phase 2 reformulated fuels program, for reducing stationary and
mobile emissions. Additionally, the 1991 plan included eight specific measures for controlling
transportation related emissions by reducing government related vehicle miles and vehicle trips (see,
for example, the district's "Trip Reduction Ordinance Handbook").
Changes for 1994
The 1994 AQMP was designed to fulfill the requirements of federal Clean Air Act
Amendments (1990) and the California Clean Air Act (1988). Structurally, the 1994 plan is similar
to the earlier versions. Tier I measures are now divided into "short term" and "medium term"
measures (to be implemented between 1994 and 2005). Tier II and III measures are now
consolidated as "long term" measures. Control changes are a little more substantial. In addition to
the controls mentioned above, the plan imposes more stringent emissions and fuel quality standards,
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accommodating the California Air Resources Board -- the statewide agency -- Low Emission
Vehicle (LEV) and Clean Fuels regulations. Stationary sources require greater application of
"technologically feasible" control equipment. The plan also requires the adoption of new
technologies that "may reasonably be expected to be utilized by the year 2010" (SCAQMD 1994).
Ships, trains, aircraft, farming and construction equipment continue to be regulated primarily
by the federal EPA and state Air Resources Board (CARB). A court ordered Federal
Implementation Plan (FIP) was released by the EPA in February 1994, requiring greater federal air
quality standards. The standards were adopted by the new AQMP. And, although the FIP was
ultimately withdrawn as a concession to the new Republican Congress, the AQMP continues to
require additional measures for non-road sources, including recreational boats and vehicles to meet
these standards (SCAQMD 1994).
Alternative Implementation Approaches
Several new implementation strategies have been included in the 1994 plan, including
increased use of market incentives, greater use of permitting, greater education programs, equipment
standards, and greater communication between the local agency (the AQMD), and state (CARB)
and federal (EPA) agencies. The "SIP fix," discussed below, is an important element in this. Each
of these strategies supplement the existing command and control regulatory structure of the earlier
plans.
Several market incentives have been written into the plan. The plan expands the RECLAIM
program, a "bubble" policy requiring aggregate control of a facility's emissions rather than command
and control of specific emissions within the facility. RECLAIM (Regional Clean Air Incentives
Market) also creates a pollution permit market where participants can sell unused pollution rights.
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Further, the plan establishes a wider program of tax credits for companies that reduce vehicle
emissions. And, perhaps most creative, the plan develops a model of emission based registration
fees and sales taxes to encourage financial incentives for emissions reduction.
The wider use of pollution permits will allow the use of Memorandum of Understanding
(MOUs) to regulate pollution when there are only a few sources involved. The AQMD argues that
this will allow faster emissions reductions by "specifically tailoring control measure requirements to
the sources' operation" (SCAQMD 1994:ES-8).
Educational outreach programs are utilized to help bring newly regulated small source
categories (e.g, dry cleaners and bakeries) into compliance. Since the district is attempting to create
a better working relationship with the business community in the south coast basin, information on
alternative products, cleaner processes, and equipment modifications is being distributed so as to
encourage greater emissions reductions. In addition, the plan encourages public education
campaigns in order to encourage environmentally friendly behavior changes, including maximizing
mass transportation use and minimizing residential emissions such as BBQs and fireplaces.
(SCAQMD 1994)
The plan also proposes emissions standards for equipment sold within the basin.
Manufacturers of small combustion sources such as water heaters, boilers, process heaters, and
internal combustion engines would be required to meet specified emissions standards for any
equipment intended for sale within the basin.
The earlier AQMPs (1989 and 1991) required a "SIP fix" -- any rule adopted by the district
that is rejected by the state Air Resources Board or the EPA must be returned to the district for
correction. Any rule or amendment adopted by the AQMD requires a "completeness" review by the
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CARB and ultimately the EPA, prior to inclusion in California's State Implementation Plan (SIP).
The 1994 plan seeks to utilize a more efficient communication process by "piggybacking" the more
limited control measures with rule amendments.
All in all, the Air Quality Management Plan is an ambitious outline of hundreds of specific
control measures the district hopes to implement. The plan has been hailed and vilified. Clearly,
the plan evokes passionate responses due to perceived gains -- improved air quality -- and losses -greater regulatory involvement. The following section assesses the overall success of the plan.
V. Analysis: Implementing the Model
The model analyzes the plan as an organic whole, rather than any single specific control
measure. Since the plan delineates the control measures in relation to one another, it is most
appropriate to evaluate the plan in its entirety.
I Breadth
To what extent do these policies address the breadth of related environmental
problems, and unrelated environmental controls?
The Air Quality Management Plan addresses a wide spectrum of air quality issues, and
consequently possesses great breadth. In developing an overall approach to air quality management,
from emission standards and deadlines to energy efficiency guidelines, the plan contributes a
positive model to environmental policy designs. By integrating several air quality mandates from all
levels of government the plan allows for rational policy planning. Further, by bringing each of these
elements into a single regulatory subsystem, the plan allows greater mediation of sometimes
competing controls.
None-the-less, like most environmental policies the AQMP focuses entirely on one area -air quality management -- and fails to assess directly the impact of the plan's recommended controls
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on other environmental areas. It would be appropriate, for example, to implement a modified
environmental impact report (EIR) to assess the impact of these controls on water quality and solid
waste management.
II Federalism
To what extent do these policies comply with federal regulations; To what extent
does California maintain respect for local autonomy and attempt to maximize local
and regional initiative?
As a regional agency, the South Coast Air Quality Management District (AQMD) reflects
the representation of the 65 member cities of the Southern California Association of Governments
(SCAG). The plan covers the South Coast Air Basin (Los Angeles, Orange, San Bernadino, and
Riverside Counties), as well as the Antelope and Coachella Valleys. In this sense, the plan may
reflect greater local autonomy and initiative.
The plan accommodates the California Clean Air Act (1988) mandates, as well as the federal
Clean Air Act (1990) mandates. To the degree that these mandates give California's Air Resources
Board and the federal Environmental Protection Agency oversight responsibilities the autonomy of
the AQMD is limited. Still, the district's regional control offers a counterbalance to state and
federal control.
The AQMP achieves a high level of federalism. The plan complies with federal and state
mandates, relying to a large extent on local and regional initiatives to meet these mandates. Thus,
the district enjoys greater autonomy and flexibility.
III Policy Flexibility
This component evaluates the degree to which the policy is flexible. Policy flexibility is
important both to maximize local initiative and to allow room to navigate unanticipated
events in the future.
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It is in the area of policy flexibility that southern California's air quality management plan
best illustrates the lessons learned and the lessons lost in past policy discourses. The AQMP
anticipates that no single approach can be successful, and therefore designates hundreds of controls
in dozens of different areas. And, more importantly, the AQMP requires systematic reassessments
every third year to identify the "overall effectiveness" of the program, and to determine the "quality
of emission reductions achieved" (SCAQMD 1994:7-33).
The monitoring report will be used to reprioritize the plans measures to achieve the fifteen percent
over three years reduction required by the California Clean Air Act (CCAA).
Still, it might be more appropriate to reassess our position more frequently. Seamanship
skills can best be demonstrated, not by reacting in a crisis, but by avoiding the crisis in the first
place. Similarly, policy success may best be demonstrated in its ability to constantly correct for
drift, and thereby maintain an efficacious course throughout its life. In this sense, the plan, like
other plans, fails to create a day to day mechanism for navigating toward the stated policy goals.
Federal law requires that an officer be on the bridge of any vessel under way to avoid crisis. Surely,
complex policies such as the AQMP require the same degree of care. Annual assessments might be
a useful first step.
IV Economic Environment
This component evaluates the degree to which the policy anticipates the economic
environment during the life of the policy.
The plan anticipates the economic consequences of air quality management. In attempting to
minimize the impact the plan relies on a variety of incentive based programs and controls. These
are discussed in some detail below under Compliance Strategies. However, the plan does not
explicitly assess the unfolding economic conditions of the southern California basin. California's
reliance on defense spending suggests that the current recessionary climate may continue for some
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time. If this is true, future drives to maximize economic growth may undermine the policy. To
some degree this has already begun to occur. The RECLAIM program has come under fire for
utilizing 1991-1994 average emissions as a baseline. Since production is down due to the recession,
emissions are down. Manufacturers prefer to use 1990 as a baseline, accommodating a higher
production rate, and a consequential increase in emissions.
V Behavior
Environmental improvement relies on technical improvements, and perhaps more
importantly, corporate and citizen behavior changes. This component evaluates the
degree to which these policies encourage behavior changes, both on the commercial
and residential level.
This component may reveal the area that the plan is most successful. In addition to
imposing a variety of emissions control equipment and technological changes, the plan encourages
behavior changes in a variety of ways. Command and control measures institute standards and
deadlines, which require cleaner industrial processes. The RECLAIM program's bubble policy
requires management initiative in lowering overall emissions of participating facilities. Economic
incentives such as the pollution rights market and other tax credits motivate specific behavior
changes including replacing higher emissions equipment earlier than required by statute. Still, these
mechanisms may only encourage short term behavior changes because they rely on specific carrot or
stick type inducements. There is some question as to whether behaviors will remain beyond the
inducements and penalties.
Two specific programs are especially useful in meeting long term behavior change goals:
educational outreach for small source categories; and the transportation control measures (TCMs).
The outreach programs intended to educate newly regulated small emission sources will give small
businesses the knowledge and assistance necessary to make long term behavior changes. The near
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term and long term transportation control measures will change transportation behaviors by
requiring government agencies and other large employers to develop ride sharing programs, funding
greater mass transit programs, and ultimately, limiting specific transit routes to carpools and low to
zero emission vehicles. Collectively, the plan encourages behavior changes at the commercial,
organizational, residential, and individual levels.
The net result will be greater environmental awareness, lower per capita vehicle miles,
higher average vehicle occupancy, and higher public transit ridership. Anecdotal data suggests that
in many agencies the organizational culture is beginning to frown on single occupant car travel.
Such cultural changes may be the most significant factor in shifting long term behavior patterns.
While most cultural changes are directed at getting people out of cars, transportation behavior
changes are critical because vehicle emissions continue to account for a significant share of air
borne pollutants in the basin. In the 1990 base year, on road vehicles contributed approximately
52% of volatile organic compounds, 57% of nitrogen oxides, 79% of carbon monoxide, 26% of
sulfur oxides, and 8% of particulate matter (SCAQMD 1994:3-6).
VI Strategy
To what degree do these policies employ rational strategic mechanisms to maximize
compliance?
The two tiered approach of the 1994 plan is based on currently available technologies (short
and medium term measures) and technologies reasonably expected to be developed by 2010 (long
term measures). Compliance is sought through a combination of command and control measures,
increased use of permitting and the pollution rights market, economic incentives, the RECLAIM
bubble policy program, educational outreach programs and public service announcements seeking
behavior changes, and efficiency and emission standards on equipment manufactured for use in the
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basin.
The strategy has not been free of controversy. Some argue that allowing facilities to sell
unused pollution rights is both inefficient and contrary to the intent of the plan. Rigorous
enforcement of command and control mechanisms may be more effective in achieving greater
emissions reductions. In this sense, the concept of a pollution rights market may be more of an
appeasement to the business community than an effective tool for air quality management. Still, it
may be too soon to determine the usefulness of a pollution market in building a supportive
partnership with the business community, making future policy compliance more likely.
Overall, the plan utilizes multiple strategies to accommodate the shortcomings of traditional
policy models. As discussed above (see "Alternative Implementation Approaches"), the plan
establishes minimum parameters of standards and deadlines, but seeks to beat these parameters
through a variety of inducements. The plan utilizes much of the strategic planning model outlined
by Cohen and Kamieniecki (1991), and thus provides one of the best models of strategic public
policy.
VII Implementation
To what extent does the policy framework employ mechanisms to maximize
implementation potential?
Following the Mazmanian and Sabatier (1989) criteria discussed above reveals that the plan
has a moderate likelihood of successful implementation:
Clear Policy Goals: The plan clearly identifies substantive goals, with timetables for meeting those
goals.
Implementing Agencies Possess Adequate Jurisdiction: This is less clear. The South Coast Air
Quality Management District is a state mandated regulatory agency created by the Lewis Air Quality
21
Management Act in 1976. The district covers over 12,000 square miles, and regulates over 65 cities
in four counties, including over eleven million people. It is therefore not surprising that the district
is overburdened and unable to respond quickly to compliance problems. Thus, while regulatory
jurisdiction is maintained by the district, staff and resources are insufficient to fully oversee the
region.
Implementing Agencies are Sympathetic to Policy Goals and Have
22
Adequate Resources: This is similarly problematic. While the district maintains overall
implementation responsibility for the plan, the specific controls fall within the jurisdiction of several
agencies on every level of government. EPA and other federal agencies oversee federally controlled
sources in the basin, including ships and aircraft. The state Air Resources Board (CARB) regulates
motor vehicle emissions and fuels. At the local level city agencies, county agencies, and the
Southern California Association of Governments (SCAG) implement the plan's transportation
measures (SCAQMD 1994). Clearly, EPA, CARB and CalEPA, and the AQMD share the mission
of the policy and are sympathetic to policy goals. Local governments, however, vary in their
support of the policy goals, depending on competing policy influences, such as economic
development needs. Resources vary from agency to agency. Federal and state agencies, and the
AQMD, have limited, but solid financial and staff support. Local governments in southern
California, as in most other regions, have been suffering under brutal deficits, and therefore provide
minimal resource support. The AQMD can therefore expect widely varying degrees of commitment
by local government agencies.
Agency Managerial Skills and Commitment: As above, federal and state agencies possess adequate
organizational and political skills. Local government agencies often do not. Cities and counties,
particularly smaller ones, are notoriously weak in organizational and political skills. This makes
many local agencies vulnerable both the faddish organizational theories (e.g., reinventing
government or TQM), and more importantly, to strong economic interests within the community.
This, in part, may explain the AQMD's move to expand the RECLAIM program.
Policy Maximizes Constituent and Key Government Support: The plan goes far to build constituent
and governmental support. The AQMD and SCAG are extremely sensitive to business concerns
23
and thus have sought significant input from the business community. Similarly, through SCAG, and
through its regional representatives the AQMD has sought input from its member cities and
counties. Additionally, in order to satisfy federal Clean Air Act and California Clean Air Act
requirements, the district has maintained communication with EPA and CARB administrators. As a
regional plan, the support of key federal and state legislators and key executive agency personnel is
not a central issue. More important is the support of key city and county government leaders. This
support varies.
Policy Goals are Not Undermined by Conflicting Policies: The
priorities of the AQMP are well established in federal and state laws. As a federal air quality
standard non-attainment area the south coast basin is required to make emission reduction a major
policy priority. The Federal Implementation Plan (FIP) reemphasized this priority. It is highly
unlikely that emerging policies will conflict with the plan's goals.
VIII Outcomes
To what extent have/ will these policies result in the anticipated outcomes?
Future outcomes are difficult to measure, but the previous indicators suggest some success.
Based on the seven indicators above it is likely that the plan, if not altered, will make a significant
contribution to air quality in the south coast basin, though it will not fully meet its goals. The
weakest indicators include breadth and implementation. The lack of explicit analysis on how the
plan may impact other environmental areas, such as water and solid waste, may allow unintended
consequences to occur. And, the problem of competing goals within city and county government
agencies may minimize the plan's implementation potential. Continuing measurements of air
24
quality will determine the degree of success of the air quality management plan over time.
VI. Conclusion
The Air Quality Management Plan is a significant departure from traditional clean air policy
models. And, like any innovative plan, it is not problem-free. As with the various federal Clean Air
Act Amendments, industry, particularly automotive and petrochemical companies, has consistently
argued that the AQMP presents an unreasonable intrusion of government, and that the emission
standards are unattainable.
In addition, the plan fails to address population growth and urban development -- the most
significant roots of southern California's air problem. By the plan's implementation deadline of
2010, southern California's population is expected to grow by 37% -- from 11.3 million to nearly
15.5 million (SCAQMD 1989). The expected improvement in stationary and mobile emissions will
be offset to some degree by an increase in total vehicle mileage and industrial growth. Furthermore,
because the AQMP depends on new technologies that are yet to be fully developed the expected
success of the plan may be somewhat optimistic. (Kamieniecki and Ferrall 1991)
Nonetheless, the commitment of California to lower emissions through a four point plan of
conservation, alternative fuels, mass transit, and a shift in residential and economic social patterns,
makes the plan the strongest clean air program in the world. The continued reliance on petroleum
based fuels, private transit, and resistance to conservation make the federal model weak by
comparison. It is possible that those regions suffering through critical air quality problems may
have to follow California's lead in leaving the federal model in order to achieve significant
improvement in air quality.
25
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