Improving How Science is Used in Environmental Regulation
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Effective regulatory policy that focuses resources on addressing real threats to public health and the environment depends on reliable scientific information and transparent policy choices. But often these regulations are the subject of heated debate, involving accusations of “politicized science.”
In a recent teleforum, I suggested that while no one wants science to be “politicized,” no one is immune to the temptation to spin science to advance a pre-determined policy goal. A new working paper I coauthored with Marcus Peacock argues that, while we should be concerned when political decision-makers attempt to distort scientific findings, we should also be concerned when scientists and other analysts attempt to exert influence on policy decisions by how they present scientific information. We focus on this latter phenomenon and identify two problems that current regulatory institutions tend to aggravate.
Using a case study of EPA’s national ambient air quality standards, we show that institutional arrangements in the regulatory development process tend to aggravate this latter problem. They threaten the credibility of the scientific process and harm regulatory policy. Many of those involved in regulatory decisions have incentives to hide policy preferences, such as how to deal with the uncertainty in assessments of risk, and to dismiss and denigrate dissenting views. Key policy choices, disguised as science, too often rest with technical staff; meanwhile, policy makers charged with making hard policy decisions can avoid responsibility by claiming that their hands were tied by “the science.”
Our paper offers ten recommendations for addressing these problems and I summarized a few of them on the recent Federalist Society teleforum.
Click here to access the working paper coauthored by Susan Dudley and Marcus Peacock.
Director, GW Regulatory Studies Center & Distinguished Professor of Practice, Trachtenberg School of Public Policy & Public Administration, The George Washington University
Susan Dudley is the Founder and Director of the George Washington University Regulatory Studies Center, established in 2009 to raise awareness of regulations’ effects and improve regulatory policy through research, education, and outreach. She is also a distinguished professor of practice in the Trachtenberg School of Public Policy and Public Administration. She is past-president of the Society for Benefit Cost Analysis, a senior fellow of the Administrative Conference of the United States, and on the Regulatory Transparency Project Regulatory Practice Working Group. Her book, Regulation: A Primer, with Jerry Brito, is available on Amazon.com.
From April 2007 through January 2009, Professor Dudley served as the Presidentially-appointed Administrator of the Office of Information and Regulatory Affairs in the U.S. Office of Management and Budget and was responsible for the review of draft executive branch regulations under Executive Order 12866, the collection of federal-government-wide information under the Paperwork Reduction Act, the development and implementation of government-wide policies in the areas of information policy, privacy, and statistical policy, and international regulatory cooperation efforts.
Prior to OIRA, she directed the Regulatory Studies Program at the Mercatus Center at George Mason University, and taught courses on regulation at the George Mason University School of Law. Earlier in her career, Professor Dudley served as an economist at OIRA, as well as the Environmental Protection Agency and the Commodity Futures Trading Commission. She was also a consultant to government and private clients at Economists Incorporated. She holds a Master of Science degree from the Sloan School of Management at MIT and a Bachelor of Science degree (summa cum laude) in Resource Economics from the University of Massachusetts, Amherst.