An Advocacy Coalition Framework Approach: Revealing PCB Policy Actors and Core Beliefs

Polychlorinated biphenyls (PCBs) were first commercially produced in the 1920’s, became popular for their valuable heat transferring properties and were mostly utilized as an additive in oil filled electrical equipment to reduce fire risk. After peak production was reached in the 1950’s and PCBs became a valuable additive in paints, adhesives, plastics, caulking and more, health and environmental concerns arose when PCBs were found widespread in the environment. The first PCB regulations emerged from the Food and Drug Administration after food sources were found to contain PCBs. Congress then moved to ban PCBs in 1976, and charged the Environmental Protection Agency (EPA) to develop regulations implementing the ban on the already widely distributed chemical.

The U.S. PCB policy debate now spans 31 years starting with EPA’s first promulgation of PCB regulations in 1979. Since then 31 rulemakings have altered the regulatory framework with 679 commenters participating in the policy debate via written comments submitted to EPA. As recently as 2010 EPA announced plans to again revise significant portions of PCB regulations found in 40 CFR 761. In 2015, both EPA and Congress announced separate plans to take action impacting PCB policy. EPA announced, the June 2015 Integrated Risk Information System public science meeting will focus on the noncancer effects of PCBs, and Senators Vitter (R-LA) and Udall (D-NM) introduced the Toxic Substances Control Act (TSCA) Modernization Act of 2015 designed to implement a more precautionary approach to chemicals, including PCBs, in the U.S. This complex policy subsystem presents a problem. How can 31 years of policy debate be simplified into a framework that allows for a clear understanding of influential participants and what is driving their policy interests?

Paul Sabatier and Neil Pelkey presented the Advocacy Coalition Framework (ACF) as a lens to simplify complex policy debates spanning a decade or more. The ACF proposed that a policy arena, or subsystem, can be characterized by participants with shared beliefs, and that deep core and policy core beliefs can assimilate policy actors into advocacy coalitions. Understanding these advocacy coalitions and their deep core beliefs, those that don’t change and policy core beliefs, those that can change to support the deep core, will identify potential collaborators or areas of potential conflict.

This gateway project is the first ACF application to the PCB policy subsystem in the U.S. and uses 31 years of original data from 679 public commenters, in the form of letters and e-mails, submitted to EPA from 1979 -2014 to determine regular policy actors. Comments submitted by regular policy actors were coded for trends in statements that reveal beliefs. Longitudinal and cross sectional analysis was then employed to determine deep core beliefs, and policy core beliefs. Finally, recommendations were presented to enable more effective and efficient PCB policy.

Project results revealed a salient PCB policy subsystem with only 91 regular participants dominated by an energy industry coalition with shared deep core and supporting policy core beliefs, as predicted by the ACF. Furthermore, the project revealed increasing salience and convergence of energy coalition and general industry coalition deep core and policy core beliefs.

Recommendations for improved PCB policy were driven by a need to, improve access to public comments for policy analysis, identify latent subsystem actors that may not know how to submit comments, understand the impacts of exogenous environmental events, and increased awareness of ACF value. First, expand the project to include more forms of subsystem participation. This will determine if other subsystem participants are utilizing avenues of policy influence other than the formal written comment submittal avenue analyzed here. Second, Improve transparency in regulatory development process. This project was limited by the availability of public comments that were originally indicated as available via docket indices, but ultimately not provided. Third, Acknowledge dynamic events external to the subsystem. Exogenous events can engage latent policy actors with beliefs that should be considered even if they are not regular policy actors. Fourth, understand that these events change policy core beliefs, but not deep core beliefs. Here a general understanding of the ACF and belief hierarchies will enable a more transparent policy debate. Last, expand the project to include policy learning and impacts of significant environmental events. Over the 31 year policy debate new environmental and human health risk research has emerged, and advocacy coalitions have collected more data to support policy core beliefs. This learning aspect of the subsystem should be explored via the ACF to further clarify the subsystem.