7 Jun 2009
Greenhouse Gas Endangerment Finding, Part 4:
Scientific causation
by Richard Belzer
in Regulatory Science
A careful look at parts of EPA's proposed endangerment finding show the causal chain that the Agency believes is scientifically sufficient. This causal chain has interesting implications for air pollution policy more generally.
More...5 May 2009
Greenhouse Gas Endangerment Finding, Part 3:
Distinguishing between 'public health' and 'welfare' effects
by Richard Belzer
in Regulatory Science
EPA's proposed endangerment finding asserts that greenhouse gas emissions from US mobile sources cause or contribute to public health harm. However, the Clean Air Act distinguishes between "public health" and "welfare." EPA proposes to count some welfare-related effects as public health effects.
More...28 Apr 2009
Greenhouse Gas Endangerment Finding, Part 1:
EPA's technical support document
by Richard Belzer
in Regulatory Science
EPA's proposed endangerment finding for greenhouse gas emissions from motor vehicles relies on a small number of references, primarily this technical support document (TSD).
More...21 Apr 2009
The Tradeoff Between Mass and Fuel Economy:
It cannot be wished away
by Richard Belzer
in Regulatory Science
It is a fact of physics that vehicles with greater mass do better in collisions. Wall Street Journal automotive columnist Joseph B. White explores this trade-off from an odd perspective -- one in which he seems to wish that it it weren't so.
More...15 Apr 2009
(A)H1N1 Influenza:
Science and policy collide on defining a 'pandemic'
by Richard Belzer
in Information Quality, Regulatory Policy, Regulatory Science
On June 11 the World Health Organization decreed that the recent outbreak of (A)H1N1 influenza ("swine flue") qualified as a "pandemic." According to reporters for the Washington Post, WHO delayed making this decision long after it technically met its established definition. The reason for delay is that policy officials no longer liked the definition and were concerned that a declaration of a pandemic could lead to panic.
More...30 Mar 2009
Forecasting Economic Depression:
Illustrating the pitfalls of expert elicitation
by Richard Belzer
in Information Quality, Regulatory Science
In recent years there has been a notable increase in the use of expert elicitation in human health risk assessment. The method usually involves empaneling a group of experts and, through a carefully crafted and complex set of procedures, asking each panel member to provide a subjective probability that some phenomenon that cannot be directly observed is true or false. The Environmental Protection Agency has an informative external review draft white paper on the subject.
In environmental health, expert elicitation has been used to quantify the risk of cancer from drinking water disinfection byproducts, the likelihood that routine exposure to particulate matter in air causes premature mortality, and the magnitude of uncertainties related to climate change. Each is a tough scientific question. For example, the risk involved may be quantitatively small, and hence hard to discern, or the scientific uncertainties may be very large. Judgment is required, and the judgments of scientists inevitably reflect a mixture of scientific expertise and nonscientific opinion.
The need for discerning science from policy in expert judgment has been recognized for decades, at least since the 1983 National Research Council Red Book. No consensus yet exists concerning how to do this in practice. As a result, practitioners of expert elicitation typically acknowledge the problem but not much else. The EPA external review draft white paper mentioned above, for example, says that Agency technical support documents relying on expert elicitation should address "[p]ossible correlations with non-elicited components of the overall analysis or policy question" -- a phrase that, when translated into plain English, means the inflitration of experts' policy views into their characterization of science.
Today's Wall Street Journal has an example drawn from a very different arena -- macroeconomic forecasting -- that offers a wealth of insight about the problems with expert elicitation.
More...15 Mar 2009
Gray Wolves:
When does science end and policymaking begin?
by Richard Belzer
in Information Quality, Regulatory Policy, Regulatory Science
Washington Post environmental reporter Juliet Eilperin has a Page One story about Department of the Interior Secretary Ken Salazar's decision to ratify the Bush Administration's decision in December 2008 to delist the gray wolf as an endangered species in parts of the West.
His decision is controversial. Those who support it (including of course Secretary Salazar) say it was based on science. Those who oppose it say the Bush Administration's decision was based on politics and that Salazar should have changed it to reflect the policy views of the Obama Administration. One thing is clear: it is difficult to discern where science ends and policy begins with respect to decisions made under the Endangered Species Act.
More...21 Dec 2008
Obama Science Nominees:
OSTP and NOAA
by Richard Belzer
in Information Quality, Regulatory Policy, Regulatory Science
President-elect Obama has announced that he will make the following nominations to important science-related offices:
John Holdren
Assistant to the President for Science and Technology
Director, Office of Science and Technology Policy
Jane Lubchenco
Administrator, Nationol Oceanic and Atmospheric Administration (NOAA)
Department of Commerce
15 Jul 2008
The Clean Air Act and Climate Change:
First in a series
by Richard Belzer
in Regulatory Economics, Regulatory Science
On July 11, 2008, EPA published for public comment an advanced notice of proposed rulemaking on the question whether, and if so, how, EPA should regulate carbon dioxide as a criteria air pollutant under the Clean Air Act. EPA simultaneously published a letter from Susan Dudley, Administrator of OMB's Office of Information and Regulatory Affairs, publicly distancing the Bush administration from EPA's proposal. Comments sent to EPA by other federal agencies also were made public.
This set of events may be unprecedented in the annals of federal regulatory poliicy. Today we begin a series providing a policy-neutral examination of the documents and the issues presented.
More...4 Jul 2008
Where Does Science End and Policy Begin?
Vitamin D
by Richard Belzer
in Regulatory Policy, Regulatory Science
Washington Post staff writer Rob Stein reports on a controversy over whether the federal government's recommendations for Vitamin D intake are adequate. The story illustrates the perils of delegating policy decisions to scientists. More...
21 Mar 2008
The Revised Ozone Standard:
Simple math and simple constitutional law
by Richard Belzer
in Regulatory Policy, Regulatory Science
The Washington Post's environment reporter says EPA has weakened the national ambient air quality quality standard for ozone. Given that the standard is going down, what does she mean? More...
12 Mar 2008
The Haze of Carbon Dioxide
According to the Washington Post, anyway
by Richard Belzer
in Regulatory Economics, Regulatory Policy, Regulatory Science
The Washington Post says carbon dioxide is visible to the naked eye. More...
19 Feb 2008
The Precautionary Principle in Action:
Is taking or not taking Vytorin 'precautionary'?
by Richard Belzer
in Regulatory Policy, Regulatory Science
A recent study raised doubt about the benefits of Vytorin, a patented combination of two anti-cholesterol drugs, ezetimibe and simvastatin. Some cardiologists say the study is sufficient evidence to stop prescribing it as widely; others disagree.
The decision whether to take Vytorin or its component drugs rests with patients, but they rely heavily on the advice of their doctors? How can patients makes sense of this debate? More...
1 Feb 2008
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 4
by Richard Belzer
in Regulatory Policy, Regulatory Science
The subject of the 2007 National Intelligence Estimate of Iran's nuclear weapons program is not the dominant subject of news reporting that it was when we first posted on it. However, a conventional narrative has developed to the effect that Iran's nuclear ambitions and developmental efforts are no longer a legitimate concern.
Today we hope to finish our series on this subject showing why this narrative is based on value-based preferences that various people and interest groups hold, and is not supported by the NIE itself.
More...
8 Jan 2008
Cancer Risks from Air Toxics:
Remarkably small, even when exaggerated
by Richard Belzer
in Regulatory Economics, Regulatory Science
The Los Angeles Times reports that cancer risks in Southern California from air toxics declined in 2006 by 17%. Any decline in cancer risk is good news. How good is it? More...
