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Models in Environmental Regulatory Decision Making
Clearly, EPA faces many difficult challenges in making its models, particularly its complex models, accessible to the diverse interests. Nevertheless, EPA has taken a major step in the right direction through the CREM database of models. This information further enhances the transparency and understandability of models to a wide array of interested participants. Despite these efforts, however, stakeholders with limited resources or technical expertise still face substantial barriers to being able to evaluate EPA’s models, comment on important model assumptions, or use the models in their own work.
EPA should place a high priority on ensuring that stakeholders and others have access to models for regulatory decision making. To ensure that its models database contains all actively used models, EPA should continue its support for the intra-agency efforts of CREM. A more formal process may be needed to ensure that CREM’s models database is complete and updated with information that is at least equivalent to information provided for models currently contained in the database.
Yet, even with a high-quality models database, EPA should continue to develop initiatives to ensure that its regulatory models are as accessible as possible to the broader public and stakeholder community. The level of effort should be commensurate with the impact of the model use. It is most important to highlight the critical model assumptions, particularly the conceptual basis for a model and the sources of significant uncertainty. Meaningful stakeholder involvement should be solicited at the model development and model application stages of regulatory activity, when appropriate. EPA could improve model accessibility through a variety of activities, such as requiring an additional interface for each model to help to identify the assumptions and sources of parameters and other uncertainties and providing additional user and stakeholder training.
However, even if full information on a model is available, technical expertise will still be required to judge independently its quality and suitability for regulatory application. Each of these recommendations requires staff time and resources, which may be considerable. Thus, EPA’s efforts to enhance opportunities for public participation in any particular case must be balanced against other agency priorities.