increases criteria air pollution compliance by 10% at the evaluated facility for the year following the evaluation.” Note that this is a specific deterrence statement for a single sector, with attribution in an average sense. (b) “Among large pulp and paper mills, an additional fine reduces aggregate BOD water pollution discharges within a state (across all facilities) by 7 percent in the year following a penalty in that state.” Note that this is a general deterrence statement for a single sector, with attribution in an average sense. (c) “Among large refining facilities, an additional non-pecuniary enforcement action (like warning letters, telephone calls, and notices of non-compliance) has no statistically detected impact on criteria air pollution emissions.” Note that this is a specific deterrence statement for a single sector, with attribution in an average sense. (d) “Across a wide range of air polluting industries characterized by large and relatively homogeneous facilities, an additional inspection reduces SO2 emissions by 3 percent at the evaluated facility for the year following the evaluation, an additional non-monetary sanction reduces SO2 emissions by 1 percent at the sanctioned facility for the year following the sanction, and an additional financial administrative penalty reduces SO2 emissions by 10 percent at the fined facility for the year following the sanction. Monetary fines also induce general deterrence, and an additional fine reduces SO2 emissions at other facilities in the same state and sector as the fined facility by 3 percent in the year following the fine. Non-monetary sanctions induce no general deterrence.” Note that this statement combines both specific and general deterrence impacts for a number of industries, with attribution in an average sense (across facilities in multiple industries).
The type of assessments in the previous paragraph may eventually help internal management, along with other relevant factors. Such assessments may help Agency personnel identify sectors where monitoring and enforcement actions may induce particularly significant changes in environmental performance. Further, such assessments may help Agency personnel identify the regulatory instruments (inspections, non-monetary sanctions, fines) within a sector that may induce particularly significant changes in environmental performance. When combined with rough regulatory action cost estimates and other appropriate considerations, these assessments may help augment internal decisions like inspection and enforcement targeting considerations within and between sectors.
In the longer run, the type of assessments discussed above may also help OECA and related offices make justifiable statements to external stakeholders about the impacts of monitoring and enforcement on measured environmental outcomes. Many current methods for evaluating the effectiveness of environmental regulatory activities are incomplete. Outcome measures like pounds of pollution directly reduced through consent decree agreements and court settlements do not typically capture deterrence, and especially general deterrence. For example, if a specific facility agrees to reduce pollution by some number of tons in response to a regulator action, this reduction is important but may considerably understate it’s the action’s overall impact since it fails to capture the impacts of this signal of