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respected. The result is a clearer comparison but less specificity for practical applications.

Criteria for Comparing Environmental Management

Until recently, environmental management represented a marginal activity of public policy. In many countries, environmental agencies did not have the status of a ministry or remained subunits of some ministry which handled matters that were considered more important—typically health or housing. From an economic perspective, environmental affairs were viewed as a minor issue, of concern mainly as a possible impediment to the priorities of economic growth in terms of GDP. The steady increase in the importance of environmental management as a government priority tended to occur as a result of unremitting public pressure, a forceful expression of changing societal priorities.

Until the late eighties, differences in environmental management between countries were a curiosity rather than a serious problem. It was perhaps useful to understand how other countries conducted their environmental affairs, since these may certainly have some indirect impact on the conduct of policy elsewhere, but it was not essential. In recent years, environmental issues have multiplied and their interrelationships have become more evident. Our understanding of the fragility of many ecosystems has increased. Environmental protection measures have become more extensive both because human activities have continued to increase in volume and because their environmental impacts have been better understood. How other countries manage "their" environment has become a matter of growing concern. Failure to control chlorofluorocarbons in New Zealand will deplete the stratospheric ozone layer over Frankfurt. Continuing deforestation will contribute to global warming, threatening Dacca and Rotterdam alike with inundation. Extensive use of DDT in Mexico will contaminate fish in the Great Lakes (through air transport), and the ocean dumping of sewage sludge threatens a food chain that ultimately reaches Europe, Japan, and North America alike. Moreover, economic actors constantly fear that their competitors elsewhere are advantaged by less rigorous regulatory requirements, and superficial analyses lend themselves to false conclusions.

In addressing the emerging environmental challenge, most countries sought to supplement an existing policy structure for water management, public health, worker safety, and land use planning. Consequently, the first phase of environmental management can be described as a patchwork approach to a common problem, again complicating comparisons between countries.

Environmental policy in the nineties is different from policies pursued in the previous decades. These differences frequently reflect perceived inadequacies of earlier policies. The new approach has several important characteristics that distinguish it both from the early and disjointed efforts to contain industrial pollution and the first stage of more systematic environmental management. Environmental

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