FROM PUBLIC DISCLOSURE TO PUBLIC ACCOUNTABILITY:

FROM PUBLIC DISCLOSURE TO PUBLIC ACCOUNTABILITY: WHAT IMPACT WILL IT HAVE ON COMPLIANCE?

Frances Irwin¹and Mary Frances Repko²

¹Director, Pollution Prevention Program, World Wildlife Fund - US, 1250 24th Street, NW, Washington, D.C. 20037 (USA)

²Research Fellow, Pollution Prevention Program, World Wildlife Fund - US, 1250 24th Street, NW, Washington, D.C. 20037 (USA)

SUMMARY

Governments, industry, and citizen groups are experimenting with different ways to develop, distribute, and use public information to reduce pollution and protect the environment. It is still early to evaluate these rapidly changing information tools. However, it is already clear that a significant expansion is occurring in the role that making information public play in environmental policy. Earlier stages have incorporated self-monitoring and self-reporting by companies into pollution control legislation in some countries^([1]) and also introduced "freedom of information" provisions that give the public a route of access to government-held documents. In these laws the emphasis is on "public disclosure" by companies to the government. The public can then request the information. The characteristics of the new information tools are still emerging but they share developing and getting information about sources as well as effects of pollution or degradation to a wide range of users, particularly communities and individuals. They also get data beyond environmental specialists to other managers in companies and government.

This paper discusses three environmental information tools which move on the spectrum from public disclosure to public access including in some cases closer to public accountability through a "right-to-know": 1) public inventories of uses and release of toxic chemicals based on the "right-to-know"; 2) Eco-Audits, as proposed by the Commission of the European Communities (EC), including a public environmental statement; 3) Eco-labeling programs that identify products with preferable environmental characteristics. Table 1 highlights provisions of these tools. Although this paper does not discuss accident information tools in depth, this area is one of the seedbeds of accountability and "right-to-know".

The three information tools discussed are on the cutting edge of clarifying our understanding of the sources of environmental problems and how to solve them in a sustainable way. These three tools are beginning to provide a means of public accounting for the contribution to pollution and habitat degradation by specific facilities and products. They are helping put the emphasis on reducing at the source the environmental impacts of the "whole" facility and the entire "life-cycle" of a product.

At the same time, environmental information tools are just one instrument of environmental policy. Thus decisions about their use are caught up in debate about the appropriate roles of companies, governments, and citizen groups in developing and

Implementing environmental policy and the potential of these tools for misuse. Citizens point out that some companies advertise extravagant environmental claims for there

Products sometimes based on methodologies that are still being developed. They are concerned that information and voluntary approaches might undermine enforcement.

Companies fear provision of data to citizens will endanger their market share or increase the threat of attack in the media or prosecution. Enforcers and technical assistance staffers in government programs each fear that their program will be undermined by the other program's approach. The debate often focuses on access to information and becomes entangled in choosing the appropriate mix of "carrot" and "stick" measures.

1 FROM PUBLIC DISCLOSURE TO PUBLIC ACCOUNTABILITY?

Disclosure provisions can help to create a climate that deters violation of environmental laws and encourages compliance. Self-monitoring, reporting, and recordkeeping requirements are an important element in the compliance system in countries such as the United States. Drinking water supplier’s sample water and hazardous waste managers keep track of waste shipments and monitor the groundwater. They both keep records that are used by inspectors to achieve compliance. The U.S. Freedom of Information Act was adopted in 1966. By using it, citizens can now obtain these and other data. Plans are also underway to make some of these data available through the National Technical Information Service. The European Community directive on freedom of information goes into effect at the end of 1992. Some member states already have experience with access provisions. The United Kingdom is introducing public registers of monitoring data from its major industrial facilities, for example.

As the statements in Table 2 illustrate, however, governments, industry, and environmental groups are engaged in a debate about taking a broader approach to information policies. Impetus for this shift comes from both the past and the future. Past practices have resulted in severe accidents including Seveso and Bhopal as well as habitat destruction and pollution that has diminished forests and damaged the stratospheric ozone layer. Scenarios of the earth's future foresee a doubled population and economy five times the present size by the middle of the next century. As the global nature of the environment and the economy become more evident, the need for better information and wider participation in decisions at levels from the community to international organizations is also growing.

The EC's introduction to its proposed Eco-Audit regulation notes that in providing information on industrial accidents, the Commission found a "strong public demand for general information . . . on measures to prevent pollution . . . and on emissions from industrial establishments into the environment."⁽⁾ Responding to similar pressures, the U.S. Congress adopted an Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986. Although "image" frequently drives corporate action and many managers still argue that the experts should just provide their interpretation of the hazards, some company leaders also recognize that this is not enough. Notes a UNEP industry and Environment Office report prepared with corporate cooperation, a company needs "to provide the public with information on what it is doing to limit the impact of its activities on the environment. This is not about projecting an image but about providing real information to staff, neighbors, environmental groups, consumers, the media, and others to meet the different levels of interest and understanding, taking into account local practices and cultures."

The Sofia Statement, issued at the January 1992 conference of non-governmental organizations in Bulgaria, stressed the need for stringent national environmental legislation and effective monitoring and enforcement. At the same time, participants urged western

Firms operating in Central and Eastern Europe to act in advance of such legislation by accepting public accountability through information provision and public participation in

Decision-making. NGOs have also emphasized the importance of the right-to-know in statements at meetings in Hungary, Austria, and at the preparatory meetings leading up to the Earth Summit in Brazil. Among many items adopted in Rio in Agenda 21's chapter on toxics was a call for governments, in cooperation with international organizations, to consider adoption of community right-to-know and other public information-dissemination programmes.

2 THREE EXAMPLES OF MOVING FROM DISCLOSING INFORMATION TO PUBLIC ACCOUNTABILITY FOR ENVIRONMENTAL CHOICES

Three examples illustrate how information policy is broadening from disclosure to access and accountability, sometimes in the form of the right-to-know, about sources and effects of pollution and habitat degradation. Two examples relate mainly to industrial facilities and one to products.

2.1 Inventories of toxic chemicals at facilities

The U.S. adopted its Community Right-to-Know Act in the wake of the accidental release of methyl isocyanate in Bhopal, India, that killed 2000 people and injured thousands more. Drawing partly on the EC's directive adopted after the release of dioxin from a pharmaceutical plant in Italy, the U.S. law requires companies to plan for emergencies, provide notification about accidents, and inform citizens about the presence and release of chemicals in their community. Building on experience of labor unions and states such as New Jersey, EPCRA establishes a Toxics Release Inventory (TRI). The TRI is a distinctive information tool in at least three ways.

Information for citizens. Enhancing the "right-to-know" is the goal of the inventory.⁽⁾ In contrast, the U.S. waste law, the Resource Conservation and Recovery Act, generates data to develop a system of cradle-to-grave regulations and to allocate federal funds. The public may obtain the information but that is a secondary purpose. The TRI works in reverse. Its primary purpose is to make the data about the presence and release of chemicals available to the public and government officials. In practice, the TRI data are beginning to provide an accounting system and an impetus for source reduction when combined with the U.S. Pollution Prevention Act and state pollution prevention planning laws.

Information for source reduction and cross-media pollution control. The TRI data are chemical and facility specific. They can be aggregated for a geographic region. The TRI requires companies to report releases to air, water, soil, or underground wells of any of 300 chemicals and 20 chemical categories that it manufactures or processes in quantities of over 25,000 pounds a year or uses in quantities of 10,000 pounds per year. Unlike other EPA databases, the TRI is multi-media. All data

Are reported in pounds rather than in different units of measure

For air and water. In addition, it includes the maximum amounts of chemicals stored during the year, the names and locations of off-site facilities to which toxic wastes were shipped; the treatment or disposal methods used for wastes, along with estimates of their efficiency.

Information distribution by computer. Companies submit the data to states and the federal government, and the federal government makes it available to the public by computer and actively promotes its use. But the federal Environmental Protection Agency has no monopoly on the data. Any one with a personal computer can analyze the data and all kinds of institutions as well as individuals are doing so. "If we don't name the top 50 facilities, Clean Water Action or someone else will--so we put them in. . . . One of the unique features about TRI is that there's no way that EPA can control the spin on this database," comments Warren Muir who has been involved in the production of EPA's national report on TRI data.⁽⁾

More than five years of experience with the national inventory has illuminated both the opportunities and the problems. Although about 23,000 facilities reported 1990 data, non-reporters continue to be a problem. EPA has conducted about 2,330 on-site inspections since 1989 and issued 550 civil complaints and proposed penalties over $16 million.⁽⁾ This enforcement effort highlights that reporting is required; it is not voluntary. EPA, companies, and citizen groups are still sorting out what data should be reported. The list of chemicals needs to be expanded to include both other toxic chemicals and other sources of releases besides industrial manufacturers. So far ozone depletors have been added. As of July of 1992, the Pollution Prevention Act requires additional reporting on prevention and recycling activities. However, the data do not yet include the amount of information coming into the facility (the amount purchased or made) which would enable accounting for materials through balancing the inputs and outputs as the New Jersey inventory allows. Nor does the TRI yet include the amount of a substance that goes into products.

The TRI is clearly having some effect on compliance, although this is not a one-to-one relationship because the law is not directly related to existing laws. The chemicals it includes are controlled in different ways under many different laws. Some releases are not regulated under any laws. Much of the TRI's effectiveness is in getting more people in on the action.

· Environmental groups have used it to challenge industries and individual facilities to reduce or stop using toxic chemicals on the TRI. In Silicon Valley, a group worked with the media to highlight the large releases of the electronics industry. The companies reduced these releases, and an industry association now reports its own analysis of the data to the public. In Northfield, Minnesota, residents joined workers in using the TRI data to convince a plant to phase out use of methylene chloride by the year 2000. Workers had been unsuccessful until the data became available and a larger coalition was built.

· Companies themselves have taken the lead in using TRI data. Best known is the pledge of Monsanto's chairman to reduce air releases by 90 percent by 1992 when TRI figures were first released in 1988. Now the Monsanto chemical company also has a 70 percent multi-media waste release reduction program.

· EPA enforcement staff are using TRI data to target inspections at large emitters and identify opportunities to do multi-media inspections or inspections of particular industries. At the same time, exemplifying the tension that exists between compliance and voluntary programs, the data are being used for a voluntary project run by the EPA Office of Pollution Prevention and Toxics in which, as of March 1992, 734 companies had pledged to reduce releases (by either treatment or source reduction) of 17 chemicals by 304 million pounds. The goal is to achieve reductions of 700 million pounds by 1995. While participation in the reduction program is voluntary, the reporting of releases is not and requirements under the Clean Air Act provide an additional incentive to participate.⁽⁾

2.2 Eco-Audits for industrial facilities

Principles of Environmental Enforcement notes that many countries and international organizations including the International Chamber of Commerce and UNEP advocate using environmental auditing to build the environmental management capability of companies. Auditing has become such a useful tool since it was developed in the U.S. to encourage compliance with new environmental laws that proposals to extend its functions have been made frequently. Sweden proposed an environmental auditing system in 1988 that would have included an annual environmental report on compliance to the government by 6000 facilities. The report would be available to the public. The reports of the 600 largest establishments would be checked by an independent auditor and provide the basis for an inspection program. This proposal was withdrawn but the requirement for annual environmental reports was adopted. About 3500 to 4000 reports are now prepared by Swedish companies. The UNEP report on public communication by companies includes the summary of an annual Environment Report by a Nobel Industries plan, for example. One section lists the maximum levels of some types of chemicals the plant can consume. Other groups have also supported making audit results public in some way. The Valdez Principles developed by CERES after the Exxon oil spell in Alaska call for an annual independent audit to be made available to the public.⁽⁾ The NGO conference in Bulgaria called for western firms to carry out comprehensive, annual, and publicly available environmental audits.⁽⁾

While some companies are beginning to issue environmental reports, the predominant view among industry has been that audits are performed to help industry managers to ensure compliance with laws. The results are used internally, not made public. Companies are concerned that if audits must be made public they will no longer be as useful in candidly examining a company's problems and might result in prosecution.

Just how many companies now actually perform audits is unclear. The U.S. EPA sometimes requires companies to perform audits as part of enforcement actions as a means of identifying and correcting management problems that led to a violation. One observer

Thinks most of the Fortune 500 companies do now audit on a regular basis. Others think

That most companies are still in a fire-fighting mode and that only a handful of larger companies in sectors with significant environmental, health, and safety vulnerability such as chemicals are using formal auditing programs.⁽⁾ The regulation of CFCs and hazardous waste has also brought some large chemical user companies into the picture.

The EC Commission has proposed a version of auditing that would include public disclosure. The Commission submitted an Eco-Audit regulation to the EC Council in January 1992. Although it started as a mandatory system, the final version provides for voluntary participation by the industrial sector. In the spring, the Commission also issued a second draft of a proposed directive on integrated pollution prevention and control that would apply to major industrial plants. The Commission considered including an inventory, drawing on U.S. experience with the Toxics Release Inventory, in both these proposals. As of mid-summer, it planned instead to issue a third proposal on an inventory. The Eco-Audit regulation and integrated pollution prevention and control draft still include remnants of inventories. The three proposals illustrate the struggle to improve compliance and increase public accountability by establishing environmental management systems at facilities in EC member countries.

What will emerge is unclear at this stage. The integrated pollution prevention and control directive may move forward first and require development of multi-media best available technology standards for major facilities with self-monitoring. As ENDS Report has noted in discussing the auditing proposal:⁽⁾ "Few items of EC environmental legislation have begun so ambitiously . . . and few have been whittled back so comprehensively by the time they reached the stage of a formal legislative proposal." Although no longer a mandatory requirement for annual self-assessment requiring outside validation with parallels to a financial audit, the regulation would still, if the Council adopts it, extend the audit beyond an internal check on compliance for a company's managers by requiring a public environmental statement validated by an outside auditor.

The Eco-Audit proposal would require an initial environmental review by the company to make a comprehensive analysis of the site including the choice and management of energy, raw materials and water; the selection of production processes; the life-cycle impacts of products; waste management; accident prevention; training; and public information and participation. This review is similar to the assessment of the potential impact of new large-scale operations, which is made public under the EC's 1985 directive on environmental assessment. Eco-Audits would be made at intervals between one and three years. Standards for the audit and auditor accreditation would be set by the International Standards Organization.

Under the proposed Eco-Audit, environmental statements based on the findings of the environmental review and on the subsequent audits would include a summary of data on pollutant releases; waste generation; material and energy inputs and other significant environmental issues; a presentation of the company's environmental policy and programme for the site; and an evaluation of the performance of the environmental protection system. The statement is to be "kept at the disposal of the public" and submitted to the competent body in the EC Member State.

At the moment, it appears likely that company environmental reports will become more common. It is less clear how they will relate to compliance auditing and the increasing use of auditing as a means of identifying opportunities to prevent pollution. Some companies such as Polaroid are issuing environmental reports that document specific

Changes in chemical use and release. The usefulness of corporate environmental reports

In increasing compliance and in improving the environment is likely to be directly related to the extent that they provide data that systematically account for the relationship of a facility to the environment.

2.3 Eco-Labeling for products

Product design is one of the issues to be covered under the Eco-Audit. Similarly, numerous groups are focusing on the need to include products much more systematically in programs aimed at pollution prevention and control.⁽⁾ Improving Material Safety Data Sheets, as a means of communicating between manufacturers and product users is one measure. Some countries such as Sweden, Denmark, and the Netherlands are also developing the idea of a product impact declaration or statement. Sweden has a product register that lists the chemical composition of about 60,000 products. France also has a product register. UNEP sponsors a Clean Production Programme. U.S. EPA has begun a Design for Environment Program.

One product information tool already in long-term use is eco-labeling. Germany and Canada, among others, have had extensive experience with eco-labeling programs. Germany's blue angel program is credited with providing the incentive for companies to lower solvent levels in their products. These programs aim to inform consumer choice and introduce a market-based incentive to raising the environmental quality of a class of products.⁽⁾ The EC's Eco-labeling directive, adopted at the end of 1991, will provide a uniform eco-labeling program for the EC. The program will award an eco-label for environmentally less harmful products in order to encourage manufacturers to design and produce products with reduced impact and consumers to buy them. The directive applies to imported products so will put some pressure on manufacturers elsewhere to compete.

In the U.S. so far eco-labeling is in the hands of private groups such as Green Seal which certifies products designed and manufactured in an environmentally responsible manner. The non-profit group evaluates a product's impacts and develops standards aimed at encouraging environmentally preferable products such as compact fluorescent lamps.⁽⁾

Eco-labeling is one means of informing consumer choices. However, it will cover only certain product groups and is based on a still developing methodology. The effectiveness of labeling programs is frequently questioned. Environmental labeling in its broader sense is also particularly prone to abuse, which is one reason to develop labeling standards. In the U.S., a report prepared by attorneys general from ten states highlights the problems with the national green marketing craze of the 1990's and reports on a 1990 Public Forum held jointly with EPA and the Federal Trade Commission. The Forum called for federal standards for environmental marketing claims used in labeling, packaging, and promotion of consumer products. It highlights terms such as "degradable" and "recyclable" as particular problems. The Green Report II makes four recommendations:

· Environmental claims should be as specific as possible, not general, vague, incomplete or overly broad;

· Environmental claims relating to the disposability or potential for recovery of a particular product should clearly disclose the general availability of the advertised option where the product is sold;

· Environmental claims should be substantive;

· Environmental claims should be supported by competent and reliable scientific evidence.⁽⁾

Despite the obstacles to product labeling, broad consumer demand for environmentally preferable products is an opportunity to use the market to improve the ability to assess the relationship of products to the environment and use purchasing power for environmental purposes.

3 FACTORS THAT INFLUENCE EFFECTIVENESS OF INFORMATION STRATEGIES

Information tools interact with existing regulatory systems and enforcement of their provisions. If there is weak enforcement, the tools can be a place to initiate action. However, they are much more likely to be effective if there is a strong system that, for example, clearly designates liability for mismanagement of waste and includes stringent air and water standards. Besides the state of the regulatory system, two other factors influence the effectiveness of information tools.

3.1 Designate responsibility for developing and reporting information

The three tools described above go beyond disclosure of information by requiring generation of data that industry, government, and the public need. Uncertainty continues to pervade understanding of environmental problems. Any tool that requires development and distribution of reliable information and encourages improvement in methodology can have a significant effect.

The Toxics Release Inventory provides new information (specific chemical releases from specific facilities) in a useful form. The Chief Executive Officers of most companies reporting these data and their surrounding communities previously had no base estimates about the chemicals being stored and released. Although there was much concern about the likely accuracy of the reports before the inventory was initiated, in fact that has not been a major problem. Instead the data are providing a starting point for improving methods and undertaking broader projects to estimate and monitor releases. When Amoco looked systematically at releases at one of its refineries it found that some of the largest sources such as barge loading had not previously been identified.⁽⁾

Auditing in its proposed EC guise also has the potential to increase the information developed about sources of pollution and habitat destruction and disclose it to the public. An important role in developing auditing standards is being played by the International Standards Organization. Key questions are the level of specificity of the standards and the diversity of participants in the process of developing them.

The increased attention to labeling is driving the development of life cycle assessment. This tool is just beginning to go beyond a rough calculation of amounts of common pollutants released. In the past, in has not addressed toxic chemicals or looked at environmental impacts. The demand for eco-labeling is making better life cycle

Assessment methods essential.⁽⁾ Ways must also be devised to involve a diverse group in developing assessments and to make their assumptions and results public. Thus the TRI, Eco-Audit, and eco-labeling are driving the development as well as the public availability of more usable information particularly about the sources of pollution and ecological disruption.

3.2 Use information management capabilities and provide for active distribution

Accessibility is the other side of disclosure. How do different publics obtain the information in a form that is usable to them? What infrastructure exists to educate the different publics on the issues and facilitate distribution and use of the information? With product labeling, the information comes with the product but understanding it is likely to be enhanced by education campaigns and public access to the data on which it is based. Whether environmental statements prepared under the proposed Eco-Audit program would actually be distributed and analyzed is unclear. No active distribution and analysis is required by the regulation. Some university programs are analyzing the green plans being developed by governmental units in the United Kingdom.⁽⁾ Similar analysis of environmental reports would be important to ensure that they improve company performance.

The TRI demonstrates how accessibility by computer can turn public disclosure into right-to-know. Nevertheless, the TRI would not work by itself. It is effective at bringing change in the U.S. because many companies care about their environmental image, the communications media circulates the information widely, states are using it as the basis for pollution prevention, and citizen and environmental groups are organizing on the basis of the information. For example, a Working Group on the Community-Right-to-Know issues a regular newsletter and tracks implementation of the law. Groups such as the Natural Resources Defense Council have used the data and helped other groups use it to get provisions to regulate toxic releases to air in the 1990 Clean Air Act. These groups are engaged in a "right-to-know-more" campaign to obtain information on chemical use and production and broader coverage of sources and types of chemicals.

Although it can help raise public awareness, public access to data is more likely to increase compliance with existing laws or push companies to obtain environmental results if the importance of the environment is high on the public's agenda. The types of organizational structures may vary but infrastructure is necessary for any information tool to make a significant difference. This may mean civic or environmental groups analyzing data and pointing out surprising inconsistencies among companies. It may mean professional associations donating their scientific and information management skills. It may mean investigative reporters competing for environmental stories in the press or on television. The strength of governmental environmental programs is a crucial factor in this mix that results in requirements to improve, disclose, and use information.

4 WILL SHIFT FROM PUBLIC DISCLOSURE TO PUBLIC ACCOUNTABILITY IMPROVE COMPLIANCE AND ENVIRONMENTAL RESULTS?

These new information tools are strengthening compliance in three related ways: widening participation, framing a broader interrelated approach to environmental policy, and

Providing information for reduction of pollution and degradation at the source.

First, they are increasing the numbers and types of people participating in pollution prevention and environmental protection. The TRI is not just being used by one EPA office (as most medium-specific databases are) but across the agency and by other agencies of government such as the Bureau of Mines and the Department of Energy. It is being used by investors and community groups and most importantly by the companies themselves. This wide use increases the likelihood that environmental problems will be identified and solved. A Monsanto manager notes this as a particular advantage. Making information public means more people to work on solutions.⁽⁾ The TRI, environmental reports, and eco-labels are still early but also significant steps toward developing a public accounting system for environmental impacts useful for people ranging from product designers to community advocates.

Second, these tools, particularly the TRI and the environmental report, begin to frame environmental problems as a whole. Notes a Rohm and Haas manager: "For the first time, engineers have had to scrutinize their processes as a whole and quantify wastes released to all media."⁽⁾ Eco-Auditing is similarly aimed at the need to develop integrated, multi-media approach to environmental management in the EC. Current compliance programs in countries such as the U.S. are caught in a fragmented regulatory legal system. These programs draw on a model such as the TRI to help decide how to transform their own databases into more accessible, multi-media tools.

Third, these environmental information tools are particularly important in beginning to provide data about sources as well as about wastes and environmental contamination, the subject of most compliance data. Source data are what is needed to develop new technologies and reduce environmental impact. A monitoring report of parts per billion in water is not as useful to a production engineer as screening data from a product life cycle assessment that compares amounts and types of waste generated at different steps in the manufacturing process. In some cases, especially at the beginning of the reduction process when relatively easy changes in practices can be made, these data can save manager’s funds rather than costing more.

The relationship between pollution reduction and compliance is a thorny one but two examples demonstrate how it is being worked out in using sector and whole facility approaches. In the Netherlands, governments have been developing a process of Target Group Consultation for most of a decade. Agreeing on covenants to reduce waste and conserve energy with target groups is a major way in which the Netherlands aims to achieve its reduction of about 60 percent of pollutants called for by the National Environmental Policy Plan. The relationship of these covenants to the regulatory system has been a continuing question. As of the spring of 1992 the covenants were expected to have a status in civil law and reductions to be written into permits.⁽⁾ Similarly, a whole facility approach in the U.S. state of Massachusetts is working out the sometimes tense relationship between inspectors and staff providing assistance in pollution prevention. The Department of Environmental Protection trained a team to inspect electroplating facilities along the Blackstone River, which is contaminated with metals. The project included 28 inspections and resulted in 19 notices of non-compliance, many of them with recommendations to consult with the state's Office of Technical Assistance. The project not only demonstrated the effectiveness of using single inspectors or a team of two inspectors but re-visits showed that 23 facilities had implemented some type of reduction or prevention measure, much higher than the expected five percent.⁽⁾

New kinds of information, widely distributed, often using rapidly developing computer and communications technology are one important key to the next generation of environmental policy. Many kinds of information--about health and ecological effects and about uses of toxic chemicals in products and processes and releases from them--are needed. Innovative measures for sharing information among companies, government, and the public will need to be developed to handle some types of data. The road from "disclosure" to "accountability" and the "right-to-know" is likely to continue to evolve along a tension-filled but fruitful path as better information about sources and effects and broader participation expand our understanding of how to achieve a sustainable society.

REFERENCES