Comment on Environmental Enforcement in Dire Straits: There Is No Protection for Nothing and No Data for Free

摘要

While I take issue with the title, suggesting that environmental enforcement is in "dire straits," the body of Professors Flatt and Collins' article does not actually evaluate enforcement, but rather enters the oft-discussed world of attempting to find metrics for measuring the effectiveness of state environmental enforcement actions. Using selected Clean Water Act (CWA) and Clean Air Act (CAA) enforcement data, the authors' four-year survey compares certain enforcement indicators with two parameters: state per capita environmental spending and the type of state government. While the survey methodology could be challenged, their statistical analysis raises some interesting points and several of their conclusions are consistent with my own observations.