Presentation on Data Gaps at 1999 RTK Conference

Hello, my name is Rich Puchalsky; Iím here for the environmental group National Environmental Trust, and I also have my own consulting business, Grassroots Connection. Welcome to the panel on data gaps. We have a large and varied group of panelists; weíre planning on each of us doing a presentation, then weíll have a half-hour question and answer session. Iíll be introducing each of our panelists just before their presentation. First Iíll be giving a short overview.

Data gaps are areas in which data are needed but are not available. For instance, if the Federal Reserve Board couldnít collect key economic statistics before making decisions about interest rates, that would be a data gap.

[Overhead 1: need and availability]

Discussions of possible data gaps usually start with the two parts of my definition: are the data really needed? And are they already available? Deciding on whether they are needed is usually the more difficult of the two questions because different stakeholders have different needs. Governmental regulatory agencies tend to view data as being needed so that they can make informed decisions in carrying out their mission to protect the public. Since this is a Right-To-Know conference, Iíll use a broader definition: data are needed in order to permit members of the general public to make informed decisions. Environmental decisions are basically political decisions involving acceptance of risk, value judgements, and goals for the future of the community. These decisions canít be left to regulatory agencies alone, they are matters that affect elections and lead to direct political involvement of individuals.

If data are collected, but are either restricted in distribution, or in a format that is not easy to use, the data are effectively not available to the public. In that sense a data gap could exist even if the data are being collected and some people are using it.

[Overhead 2: Technical, economic, moral, and political considerations]

Once past the initial questions of whether the data are needed and available, there are additional considerations that can affect the decision about how to address a data gap. Collection of the data could be flatly impossible with our current level of science and technology. Data might be too expensive to collect. And moral and legal considerations affect these issues. Common examples of moral decisions are easily seen in non-environmental fields; for example, privacy concerns often restrict collection or distribution of personal data about individuals. These issues of technical ability, economics, and moral or legal judgement are the three factors that are most often formally taken into account when a data collection or distribution decision is made.

Informally, political considerations are inescapable in decisions about these issues. Data, or its absence, favors some political entities within society and disfavors others.

Letís look at a few examples of what I think are data gaps. Then our panelists will explore some of these issues at greater length.

This Right-To-Know conference is an outgrowth of a series of conferences on the Toxic Release Inventory. Environmental Right-To-Know started because of public concern about toxic chemicals. Since this conference has a broader focus, I thought Iíd give an example from each major branch of current environmental concern Ė ecological problems like habitat destruction or species extinction, global problems like stratospheric ozone depletion or global climate change, and the more familiar toxic chemical concerns.

[Overhead 3: Toxic chemicals: persistent bioaccumulative toxins]

Letís start with toxic chemicals. One of the more current Toxic Release Inventory disputes is about persistent bioaccumulative toxins: chemicals that are toxic, persist in the environment for long periods of time, and bioaccumulate up the food chain. What do we really know about these chemicals?

Well, for a start, we donít really know which chemicals are PBTs. Research is still ongoing about the effects of endocrine disruption, but we havenít even put most chemicals in use through a standard battery of screening tests for well-known toxic effects. According to a 1997 Environmental Defense Fund report, nearly 75 percent of high-volume commercially used chemicals have not completed basic toxicity testing. That doesnít even count byproducts of commercial use or products of incomplete combustion.

So letís leave aside the question of which chemicals might be PBTs. What do we know about the sources and distribution of well-known PBTs? Again, not very much. The chart on the overhead compares EPA estimates of total annual releases of some PBTs with how much of those chemicals are reported released within TRI. As you can see, the sources of only 8 percent of Mercury and 35 percent of Lead releases are identified in our premier environmental database. Non-metallic PBTs are even worse: 5 percent for Hexachlorobenzene and 3 percent for PAHs. Some PBTs that are toxic in very small amounts, such as dioxin, are not reported in TRI at all, because TRI doesnít require reporting quantities less than half a pound.

So data gaps exist within the even most well-known areas of environmental concern. EPA has already decided that these particular issues represent data gaps, and they have recently been addressed by rules for expanding toxicity testing of high volume chemicals, and by the facility expansion and PBT reporting TRI rules. Other panelists will be speaking about other possible data gaps within TRI. So, how much worse are other areas of environmental data?

[Overhead 4: Global issues: global climate change]

Since the 19th century, scientists have known that carbon dioxide traps heat near the Earthís surface, raising the average surface temperature. According to the most recent estimates of the International Panel on Climate Change, increasing levels of CO2 caused by use of fossil fuels will raise the average temperature, causing global changes in the Earthís climate. Clearly we want to know how much CO2 is being released from all sorts of entities: from countries, from industrial and agricultural processes, from specific types of transportation and so on.

Rather than going into the data gaps in all of these areas, letís look at this question from a local Right-To-Know context. How can a member of the public find out how much CO2 their personal activities are contributing to the atmosphere? Many members of the public are interested in the question from both a purchasing and a public policy perspective.

The largest source of CO2 is from transportation, about a third of the total. So letís say that a member of the public knows their carís mileage, how many miles they drive in a year, and can convert fuel use into CO2 emissions. Next, they come to their electric bill. They would like to figure out how much CO2 they are generating. That knowledge might affect their choice of which electric utility to buy power from, which is now possible in the U.S. due to deregulation. Can they find out how much CO2 is released because of their electricity use and how much that might change with a different source of power?

Maybe they can. The EPA maintains a cutting-edge new database called EGRID, which combines CO2 release data from the Acid Rain program with electricity generation data from the Department of Energy. EGRID is now at about the same stage that TRI was in in 1987, though with far less fanfare.

EGRID, if made available to a member of the public, can tell them how much CO2 was released for each kilowatt-hour of electricity their electric utility generated, and the types of power sources used by the utility to generate electricity Ė coal, oil, solar, and so on. Seemingly that would be all that the user needs. Unfortunately, EGRID doesnít take into account sales of power from one utility to another, nor, due to Department of Energy policy, are data on nonutilities currently released. So the user really has no way of knowing for certain just where their power is coming from, or how their utility compares to others in its mix of power sources. For instance, one current trend is for utilities to sell off their dirtiest coal-burning plants to nonutility spinoffs, and then buy the power back.

These data could easily be collected, especially as the utilities themselves already know what kinds of power they are purchasing, and collection and distribution of the data would seem to be morally supported as being analogous to truth in labeling laws. Therefore I think that this represents a data gap that might easily be filled.

[Overhead 5: Ecological issues: habitat destruction]

One of the most important areas of environmental concern is habitat destruction. Species extinction can happen for many reasons, but destruction of habitat ensures long-term losses of species. We are often presented with habitat destruction as something that mainly occurs in poor countries, but almost every country, including the U.S., has important ecological areas and suffers habitat loss. How well can a member of the United States public find out about local habitat destruction? Local conflicts over development of natural areas are a major political issue in many regions of the country, so there would seem to be a need for local data.

There are a few publicly accessible data systems that have information on this subject. One of them is "Surf Your Watershed", an EPA Web site that focuses on watershed protection. Surf Your Watershed contains many good things, but it is frustratingly vague about habitat destruction. For instance, if you try to see how much riparian or forest habitat your watershed contains, the answer is there as one of only three possible ranges: less than 20 percent, 20-50 percent, or more than 50 percent. The watershedís healthiness is evaluated on an overall 1 through 6 scale, and there are many pointers within the Index of Watershed Indicators towards possible problems with the area, but there isnít anything systematic that tells how much habitat is there and how much is in the process of being lost.

Another database from the U.S. Corps of Engineers is available through an Environmental Working Group Web page. It tracks permits for destruction of wetlands. But the database doesnít actually track how many acres of wetlands each permit affects, so itís impossible to quickly see which permits are the more important ones.

Why is it so difficult to find these data? We are generally very good at tracking transfers and uses of property; I would guess that there is no great technical difficulty in collecting information about wildlife habitat and about specific plans to develop it. If not at the Federal level, all sorts of zoning, development, and property deed data are available at the local level. Yet I havenít heard about Right-To-Know systems that inventory habitat at the local level and numerically track projects to build on it. Morally, it would seem that the public accepts that these data should be collected and distributed, since there are various laws regarding public notification through signs and newspaper notices. There may be economic problems associated with collecting and distributing these data, but the major obstacles are probably political.

I hope that these three examples have provided a framework for the discussion of environmental data gaps at the Federal, state and local levels, and across a broad range of environmental problems. With that Iíll turn the presentation over to the other members of the panel.

Overhead 1


What is a data gap?

An area where data are both needed and not available.


A Right-To-Know definition:

Members of the general public need data in order to make informed decisions.

Overhead 2

Filling data gaps

  1. Technical considerations
  2. e.g. data canít be collected

  3. Economics
  4. e.g. data too expensive to collect or distribute

  5. Moral/legal issues
  6. e.g. privacy concerns, business secrets

  7. Politics


Overhead 3

Toxics issues: PBTs

75% of high volume commercial chemicals are not screened for health effects

(in 1997)

Percent of PBTs with known sources in TRI:


8 %


34 %


5 %


3 %



Overhead 4

Global issues: global climate change

EGRID shows data on electric utilities:

  1. amount of CO2 produced
  2. sources of power

But it doesnít show sales of power from one utility to another, and non-utilities donít report.

Overhead 5

Ecological issues: habitat destruction

How many acres will be lost locally?

Federal wetlands destruction permits donít show acres, and other available Federal databases donít track habitat in detail.

Although local data exists, itís not readily available.