A METHOD FOR EXAMINING POLICY IMPLEMENTATION: A STUDY OF DECISIONMAKING FOR THE NATIONAL AMBIENT AIR QUALITY STANDARDS, 1964-1984

A comparison of selected decisionmaking requirements for six environmental statutes was undertaken to examine policy implementation behavior. The comparative study revealed that the procedure an agency uses to arrive at decisions accounts most directly for the implementation of decisionmaking requirements.;To reinforce and extend the finding that agency decisionmaking (policymaking) is primarily a function of its procedural process and to demonstrate the research method, the decisions on the National Ambient Air Quality Standards (NAAQS) required by the Clean Air Act were reconstructed from the public record for 1964-1984. The purpose was to identify the origins and measure the accomplishment times of the steps of the NAAQS decisionmaking process; isolate the main causes for delays; and highlight the strengths, weaknesses, and behavior of the process. The NAAQS decisionmaking process evolved from a 13-step process in 1971 to a 57-step process by 1983. In 1971 EPA officials using the process took 120 days to arrive at a NAAQS decision. In 1983 the process appeared not to produce decisions because of its enlargement. The quantification of the process shows it to be an inefficient use of government time and ineffective in complying with Clean Air Act requirements. The main factors contributing to the proliferation of decisionmaking steps was found to be the EPA's concern of how the courts might eventually judge the process and the constant involvement of Congress and pressure groups outside the Agency. Litigation and the courts appear to be the driving forces behind decisionmaking when decisions are made.;A method was devised for examining policymaking (decisionmaking) processes. The method uses an agency's decisionmaking procedures as a framework in which to identify and quantify the steps of an implementation process. Recurring steps of the process are identified in public or published records. Their origins are noted. The steps are quantified in terms of accomplishment time. They are then sorted by computer in sequence. The sort reveals the structure of the process. This method allows researchers to measure the "time efficiency" and "implementation effectiveness" of a policymaking process and isolate those factors which contribute to policymaking and delays.