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A Comment on 'Analysis of Firm Compliance with Multiple Environmental Regulations'

This paper offers comments on a paper recently posted on the Social Science Research Network (“SSRN”), “Analysis of Firm Compliance with Multiple Environmental Regulations.” The paper’s abstract concisely described its basic premise as follows:"When a firm is regulated under multiple environmental programs, its compliance behavior under these programs can be complementary or substituting – regulations of one program either increase or decrease firm compliance with other programs. This paper examines the existence and the nature of such cross program effects...using data on facilities regulated under both the [United States] air program (Clean Air Act, CAA) and the hazardous waste program (Reservation and Conservation Recovery Act [sic], RCRA)."The paper purported to examine these effects, but anyone familiar with its sources of data and the applicable environmental programs would quickly discern that the paper was fatally flawed. Indeed, because of the limitations of those data, it is impossible to validly conduct the analyses that the paper desired, and thus those analyses and their conclusions are invalid. This comment describes the paper’s most significant flaws.