Final Report: Promoting Sustainable Pollutant Control Policies Through Consideration of Social and Biological Indicators: An Application to Mercury Control in New England

EPA Grant Number: R833401
Title: Promoting Sustainable Pollutant Control Policies Through Consideration of Social and Biological Indicators: An Application to Mercury Control in New England
Investigators: Borsuk, Mark E. , Howarth, Richard B. , King, Andrew A. , Ranco, Darren J. , Turaga, Rama
Institution: Dartmouth College
EPA Project Officer: Hahn, Intaek
Project Period: May 1, 2007 through April 30, 2010
Project Amount: $299,969
RFA: Collaborative Science And Technology Network For Sustainability (2006) RFA Text |  Recipients Lists
Research Category: Sustainability , Pollution Prevention/Sustainable Development


Actions to protect the environment usually require an investment of time, effort, or money.  This seems to imply that such actions are not in an individual's or organization’s self-interest, yet we undertake them voluntarily all the time: we recycle, reduce our waste, contribute to environmental organizations, and pay premiums for eco-friendly products. Understanding what motivates such voluntary pro-environmental behaviors is essential for developing effective incentives for further promoting sustainable action. One of the most prominent explanations of voluntary pro-environmental behavior that has emerged from social scientific research is a concept called values-beliefs-norms (VBN) theory. This theory recognizes that moral motivations, including personal values, beliefs, and norms, strongly induce many of our environmental actions.

We hypothesize that intelligent use of environmental indicators can strengthen the sense of moral motivation among individuals and organizations, thus increasing their willingness to undertake pro-environmental behaviors. Therefore, we have the following objectives for our project:

  1. To identify meaningful indicators of sustainability that can be linked with mercury control policies using available knowledge and data.
  2. To determine whether the establishment of an explicit connection between mercury policy and sustainability indicators will increase the motivation for individual and organizational stakeholders to act in ways that promote ecological, economic, and social well-being.
  3. To assess whether the monitoring and reporting of sustainability indicators is likely to improve resilience in the human-environment system by improving stakeholder perception of ecological change, enhancing learning, and facilitating the process of adaptive management over time.

We also are interested in assessing whether our findings are applicable to the diverse set of stakeholders affected by mercury contamination.  A particular focus is on Native American communities, who may have unique livelihoods, cultural traditions, and exposure situations and who have been traditionally under-represented in regulatory decision making.

Summary/Accomplishments (Outputs/Outcomes):

We achieved important outputs/outcomes in five broad areas:

  1. Identification of candidate sustainability indicators
  2. Evaluation of the role of individual responsibility on sustainable behavior
  3. Examination of the motivations for sustainable corporate behavior
  4. Identification of public concerns expressed in written comments on CAMR
  5. Consideration of concerns expressed by Native American communities

Each will be discussed in below.

  1. Identification of candidate sustainability indicators: We reviewed four general criteria for developing indicators of sustainability related to mercury control policy:
    1. Consistency with system theory: According to Bossel (1999), the sustainable viability and performance of any system can be gauged according to seven fundamental criteria: Existence (Is the system compatible with and able to exist in its environment?); Effectiveness (Is it effective and efficient in its processes and operations?); Freedom of action (Does it have the freedom and ability to respond to environmental variety?); Security (Is it secure, safe, and stable despite a variable and unpredictable environment?); Adaptability (Can it adapt to new challenges from its changing environment?); Coexistence (Is it compatible with interacting systems?); Psychological needs (Is it compatible with the psychological needs relevant to this system?).  We examined these criteria in detail and established their relevance to mercury control policy.
    2. Consistency with sustainability theory: We examined alternative views of sustainability including a Strong definition (e.g., Goodland and Daly 1996), a Weak definition (e.g., Pezzey 1992), and Schematic definitions (Norton, 2005). We finally decided to adhere, for the purposes of our project, with the Operational definition given by Howarth (2007), which emphasizes intergenerational fairness (specifically rights of future generations to share the net benefits of resource extraction by the current generation), the maintenance of “life opportunities” over time in the form of a “structured bequest package,” and the idea that specific natural resource stocks do not need to be permanently conserved, but rather that “safe minimum standards” be used to guide resource extraction decisions in the face of uncertainty about the costs to future generations.  The practical consequence is a hierarchy of sustainability objectives that identify the environmental, economic, and social features that need to be sustained or developed.
    3. Stakeholder salience and motivational potential:  The ability of indicators to motivate sustainable stakeholder behavior can be informed by a combination of economic and social psychological theory.  In particular, motivational strength depends on the correspondence of the indicator with the stakeholder’s values, awareness of consequences (AC), and ascription of responsibility (AR). This issue developed into a major research question of our project and is described below.

    This first component of our project did not lead directly to any publications, but greatly informed all of our subsequent work by providing a strong theoretical foundation.

  2. Evaluation of the role of individual responsibility on sustainable behavior: VBN theory predicts that voluntary action of individuals to protect the environment will be largely driven by their sense of moral obligation. Such feelings of moral obligation are, in turn, a function of the values held by the individuals, as well as: (i) their beliefs regarding the potential adverse consequences of their actions (AC) and (ii) their feeling of responsibility to alleviate those consequences (AR). The implication is that indicator information that addresses both AC and AR beliefs can have a positive influence on individual pro-environmental behavior. Accordingly, we set out to test two hypotheses:

    H1: Indicators that enhance a sense of moral obligation by providing both AC and AR information are more likely to motivate sustainable behavior than indicators that simply describe the current state of the environment (AC only).

    Additionally, VBN theory predicts that a personal altruistic value plays a strong role in activating a sense of personal obligation, or moral norm.  In particular, this theory suggests that AC and AR beliefs will activate moral norms only for people who hold strong altruistic values.  Based on this, our secondary hypothesis is:

    H2: Indicator information that increases the sense of moral obligation (by influencing AC and AR beliefs regarding the environment) is more likely to motivate sustainable behavior of individuals with strong environmental altruism values than others.

    We define environmental altruism as a deep sense of concern toward the environmental health of other humans, toward the biosphere, and toward future generations.  This value orientation might also be referred to as a sustainability value.

    To test our hypotheses, we designed, extensively tested, and implemented a survey instrument, both as a mail survey of New England residents and an internet survey of a representative U.S. national sample. Mercury contamination is a particularly salient concern in New England as all six states have statewide fish advisories for mercury.

    For the mail survey, we sent questionnaires to a random sample of 2000 residents in the six states of the New England region. To test our first hypothesis, half the surveys contained indicators of mercury contamination intended to strengthen beliefs concerning personal responsibility, and half contained state indicators (e.g., indicators normally used by the EPA) without any explicit link to personal action.  Respondents then were asked questions about their willingness to engage in certain mercury reducing behaviors (including correct disposal and recycling of mercury containing products and enrollment in a green energy program). Excluding approximately 150 questionnaires that were returned blank because of wrong address, we received 312 responses for a response rate of 16.9%. 

    The internet survey was conducted by the organization Knowledge Networks (KN) through a panel of respondents recruited by KN.  For this survey, we added a control version to the two versions used in the mail survey.  Again, these versions differed only by the type of mercury information provided to the respondents.  Questionnaires were sent to 1,250 panel members (nationally), out of which 774 completed the survey, for a response rate of 61.9%.

    To test our second hypothesis, both versions of our survey also included questions regarding people’s values. For this purpose, we developed a novel 15-item scale to measure sustainability value orientations. Other questions on the survey asked about individual characteristics such as household income range, household size, age, gender, existing AC and AR beliefs, perceptions of ease and effectiveness of the three elicited behaviors, sources of information on mercury, and trust in those sources.

    If, after controlling for other variables, the respondents who receive AR indicators are more likely to engage in mercury-reducing behaviors than the respondents who receive conventional indicators, then we will consider our first hypothesis to be supported.  Additionally, if we find a statistically significant interaction effect between value orientation and indicator information received then we will consider our second hypothesis to be supported. Unfortunately, since collecting and electronically entering the results of our surveys in mid-2010, we have experienced an extended delay in analyzing our data, reporting the results, and completing this aspect our project.  This has been largely due to important personnel changes and is currently being addressed.  We hope to have a paper describing the results of our survey submitted for publication within the next six months.

  3. Examination of the motivations for sustainable corporate behavior:  Scholars have long argued that industries impose self-regulation in order to constrain corporate actions that might harm an industry as a whole. For example, those who share in common pool resources such as fisheries or forests will unite to create an institution that helps them avert the “tragedy of the commons.”  However, the theoretical and empirical foundations of this claim have remained uncertain and contradictory.  In this part of our project, we extended theories of the physical commons to analyze the intangible commons of the collective reputation of a particular industry. We posited that when the action of one firm can cause “spillover” harm to others, firms share this type of commons and that the need to protect this commons can motivate self-regulation. Using data from the U.S. chemical industry, we found that spillover harm from industrial accidents increased after a major industry crisis and decreased following the formation of a new self-regulatory institution. Additionally, our findings suggest that the institution lessened spillovers from participants to the broader industry. These results, which have important implications for understanding why organizations may willingly undertake pro-environmental behavior, are published in King, et al. (2008).
  4. Identification of public concerns expressed in written comments on CAMR:  In 2005, the U.S. Environmental Protection Agency (EPA) promulgated a cap-and-trade program, called the Clean Air Mercury Rule (CAMR), to control mercury emissions from coal-fired power plants.  CAMR turned out to be a controversial regulation and was opposed by a number of states as well as national environmental groups and Native American tribes. CAMR was eventually rejected by court on the grounds that, in regulating mercury using a cap-and-trade program, EPA did not follow the processes set forth under the Clean Air Act.

    In this part of our project, we analyzed the written comments submitted by the general public on CAMR to understand their concerns associated with mercury impacts and control.  Given the wide ranging impacts of mercury, we are particularly interested in the question of what impacts of mercury are most salient to the public.  We categorize impacts as related to either: (a) human health, (b) ecology, (c) recreation, or (d) sustainability.  A secondary interest relates to the public’s concerns regarding the CAMR regulation itself. Because the regulatory process was among the main reasons for the opposition to CAMR, this second question focused on process issues such as fairness in the process of developing the regulation and trust in the EPA/government.

    Written comments from the general public to the EPA were of two types: form letters and comments written on their own by private individuals. Our interest was in analyzing the letters sent by individual citizens to express their own views regarding the regulation. To identify the comments of independent private citizens, we relied on two summary documents produced by EPA. These two documents identified commenters by their affiliations and assigned an identification number (ID) to each of the commenters. Form letters were identified as “mass campaign mailings” to separate them from independent private citizen comments.  The review of these two EPA documents revealed that a total of 4,322 private citizens commented on CAMR. We extracted the IDs associated with these 4322 commenters and randomly selected a sample of 1000 comments for our analysis.  We downloaded all the selected 1000 comments from the website.

    As explained above, we classified the expressed concerns into four types. Accordingly, we identified a set of keywords that sufficiently characterizes each type and then coded the 1000 comments according to the presence of these keywords.  We still are analyzing the resulting data, but preliminary findings indicate the following:

    • Only 13 individuals out of all the comments we analyzed, supported the cap-and-trade program proposed under CAMR.
    • Human health was the overriding concern in our sample.  The human health impact of mercury was raised by 86% of the commenters. The health of their children was found to be especially important with close to 40% of the comments referring to a concern for their children’s health due to mercury contamination. Impact on women of childbearing age was a concern for 16% of the commenters. With respect to health impacts, 20% referred to neurological disorders while only 2% referred to cardiovascular impacts. Finally, 23% of the sample referred to fish consumption as a pathway for human health impacts of mercury.
    • The second most important concern was ecological impact with close to 60% of the commenters referring to one of identified keywords for ecological concern.  Ecological concerns were generally expressed with a broad reference to “environmental protection” (22% of the sample).  Another important reference was to the impacts on wildlife with 10% of the sample sharing that concern.
    • Sustainability concern was expressed by close to 20% of the commenters.  An explicit concern for “future generations” was expressed by 10% of the sample.
    • Among process concerns, 18% of the commenters viewed the proposed cap and trade mercury policy as yet another anti-environment policy of the Bush administration.  About 15% of the commenters thought that the process leading to the proposed regulation did not involve all the stakeholders and was thus unfair.  Another 14% of commenters thought that by proposing a cap-and-trade program instead of stringent abatement standards, EPA failed in its responsibility to protect public health and the environment, as mandated by law.

    As stated above, we currently are completing our formal analysis and writing up our results for publication.

  5. Consideration of concerns expressed by Native American communities: A particular focus of our project was on identifying value orientations and indicator sets that are appropriate to traditionally under-represented fractions of the American population, including Native American communities. These groups have historically been alienated both legally and socially from the institutions that frame environmental policy in the United States.  They also may have unique livelihoods, cultural traditions, and exposure situations relating to mercury in the environment.  We believe that only by explicitly involving such groups can the full implications of sustainability be properly addressed.

    In this component of the project, we assessed public comments and a petition on CAMR received from Maine Tribes, as well as results of interviews we conducted with the Penobscot Indian Nation.  Our aim was to assess the key concerns with CAMR for tribes and how to make environmental regulation in these communities more sustainable.  Some key points were the following:

    • The most frequent comment by Tribes during the CAMR and delisting notice and comment period was that EPA had violated its Trust Responsibility to Tribes while making the changes in how they would regulate mercury.
    • It is widely believed that tribal treaty fishing rights to subsistence fishing and hunting were not adequately addressed in the process.
    • Tribal sovereignty and rights to protect the health, safety, and welfare of tribal citizens and their ability to regulate water quality were believed to be ignored.
    • The Regulatory Impact Analysis (RIA) that went along with the CAMR was believed to misunderstand and misconstrue the true costs and benefits of the proposed regulation on Native peoples.

    We currently are writing up a summary of our assessment for publication, including a set of lessons learned for the purposes of the regulatory process and risk communication.


Our project has important implications for both environmental regulatory programs and public behavior. Our set of proposed sustainability indicators, tailored to a particular region and regulatory context, can be used directly by state and federal agencies to track progress and evaluate the success of policies in both the environmental and social dimensions. Based on the findings of related studies, we expect that even without initiation of new programs, when sustainability indicators are explicitly considered, opportunities for improving upon current programs will be identified.

We also believe that our research should be able to support policies that use information as a means for promoting sustainable public behavior.  By emphasizing issues of direct concern to citizens and appealing to a sense of moral obligation, environmental agencies and organizations might better motivate pro-environmental behavior.  Such efforts are increasingly critical to managing global problems such as climate change, disease transmission, and resource use, which require individuals and organizations to assume principal responsibility. Further, our work on corporate behavior suggests that government programs on information disclosure could be improved by considering their indirect effect on the formation and function of self-regulatory institutions.

Finally, our work with Native American communities suggests that environmental agencies should be particularly attentive to tribal sovereignty and the role of the Federal Trust Responsibility when making changes in how they regulate environmental contaminants.  This consideration pertaining to perception and process may be as important as estimations of the risk level itself.

Journal Articles on this Report : 6 Displayed | Download in RIS Format

Other project views: All 17 publications 6 publications in selected types All 6 journal articles
Type Citation Project Document Sources
Journal Article Barnett ML, King AA. Good fences make good neighbors: a longitudinal analysis of an industry self-regulatory institution. Academy of Management Journal 2008;51(6):1150-1170. R833401 (2007)
R833401 (Final)
  • Full-text: Academy of Management Journal-Full Text PDF
  • Abstract: Academy of Management Journal-Abstract
  • Journal Article Ranco DJ. The trust responsibility and limited sovereignty:what can environmental justice groups learn from Indian Nations? Society & Natural Resources:An International Journal 2008;21(4):354-362. R833401 (2007)
    R833401 (Final)
  • Abstract: Taylor & Francis-Abstract
  • Journal Article Ranco DJ, O’Neill CA, Donatuto J, Harper BL. Environmental justice, American Indians and the cultural dilemma: developing environmental management for tribal health and well-being. Environmental Justice 2011;4(4):221-230. R833401 (Final)
  • Abstract: Mary Ann Liebert, Inc.-Abstract
  • Journal Article Turaga RMR, Howarth RB, Borsuk ME. Pro-environmental behavior:rational choice meets moral motivation. Annals of The New York Academy of Sciences 2010;1185:211-224. R833401 (2007)
    R833401 (Final)
  • Abstract from PubMed
  • Full-text: Wiley - Full Text HTML
  • Abstract: Wiley - Abstract
  • Other: Wiley - Full Text PDF
  • Journal Article Turaga RMR, Howarth RB, Borsuk ME. Perceptions of mercury risk and its management. Human and Ecological Risk Assessment 2014;20(5):1385-1405. R833401 (Final)
  • Abstract: Taylor&Francis-Abstract
  • Other: USDA-Abstract
  • Journal Article Turaga RMR, Noonan D, Bostrom A. Hot spots regulation and environmental justice. Ecological Economics 2011;70(7):1395-1405. R833401 (Final)
  • Full-text: ScienceDirect-Full Text HTML
  • Abstract: Ideas - Abstract
  • Other: ScienceDirect-Full Text PDF
  • Supplemental Keywords:

    risk assessment, health effects, ecological effects, sensitive populations, environmental justice, pollution prevention, public participation, decision making, preferences, public good, socio-economic, Northeast, tribes, Native Americans, mercury , sustainability, cap-and-trade policies

    Progress and Final Reports:

    Original Abstract
  • 2007 Progress Report
  • 2008