What Do We Really Know: The Effect Of Reporting Thresholds On Inference Using Environmental Right-To-Know Data, Regulation and Governance, vol. 2 no. 3 (2008), pp. 293-315.
Environmental right-to-know data such as the Toxics Releases Inventory (TRI) are used by regulators, NGOs and other organizations to prioritize their efforts to protect communities and natural systems. However, right-to-know regulations are complicated and not all information about environmental performance are required to be disclosed by all facilities. Understanding the value of right-to-know data for decision-making requires a clear understanding of the exactly what information the data convey. Using data from a state program, the Massachusetts Toxics Use Reduction ACT (TURA), this paper assesses what may be accurately concluded from frequently used environmental right-to-know data. The author examines the effect of reporting thresholds–levels of chemical use and manufacture below which a facility does not need to disclose releases of a chemical–on policy inferences that are frequently made with right-to-know data. She finds that the reporting thresholds create artificial declines in toxic chemical releases and can result in serious errors in comparing facilities’ relative environmental performance. Environmental right-to-know data continue to be a critical source of information but must be reviewed with an understanding of how reporting thresholds impact conclusions drawn from these data.