State Compliance with Federal Regulations: Using Remote Sensing to Test for Strategic Ambient Pollution Monitor Siting

Corbett Grainger's website

Abstract: In the United States ambient air quality is regulated through National Ambient Air Quality Standards (NAAQS), which are set by the EPA. Enforcement of these standards is delegated to state and sub-state regulators who are also tasked with designing their own monitoring networks for ambient pollution. A state’s monitoring network is then used to determine whether a region, usually a county, is in attainment or nonattainment with the NAAQS. We develop an analytical model to study the incentives a local regulator faces with respect to siting new pollution monitors. We show that, for marginal counties (i.e. those that may be "close" to the NAAQS threshold), the regulator has an incentive to avoid siting pollution monitors in dirty locations. On the other hand, for counties already in nonattainment, the local regulator may have an incentive to target pollution. To test for this type of behavior, we employ monitoring and satellite-derived pollution estimates to characterize pollution at non-monitored locations. We find that, on average, newly-sited monitors in marginal counties are placed in relatively clean areas, which suggests that local regulators strategically avoid pollution hotspots when siting monitors. We conclude with implications for the use of monitoring data as well as policy.