The role of uncertainty in the costs and benefits and availability and feasibility of control technologies is not well investigated or understood. The evidence base for those factors is not robust. Evaluating case studies of past rulemaking and developing a directed research program on assessing the availability of technologies might be the first steps toward understanding the robustness of technology feasibility assessments and economic assessments as well as the potential for technology innovation.
The U.S. Environmental Protection Agency (EPA) should fund research, conduct research, or both to evaluate the accuracy and predictive capabilities of past assessments of technologies and costs and benefits for rulemaking in order to improve future efforts. This research could be conducted by EPA staff or else by nongovernmental policy analysts, who might be less subject to biases. This research should be used as a learning tool for EPA to improve its analytic approaches to assessing technological feasibility.
The committee did not find any specific guidance for assessing the uncertainties in the other factors that affect decision making, such as social factors (for example, environmental justice) and the political context. The committee also did not find examples of systematic consideration of those factors and their uncertainty when exploring the policy implications of strategies to mitigate harms to human health. In response to requirements in statutes or executive orders that require regulations to be based on the open exchange of information and the perspectives of stakeholders, some EPA programs (e.g., Superfund) work to address issues related to public (stakeholder) values and concerns.
Ecological risk assessments7 have included contingent valuation to help inform policy development. Similarly, economists have explored the values people hold regarding specific health outcomes for the purposes of resource allocation or clinical guideline development. More research is needed into methods to appropriately characterize the uncertainty in those other factors and to communicate that uncertainty to decision makers and the public.
7 Ecological risk assessment is a “process that evaluates the likelihood that adverse ecological effects may occur or are occurring as a result of exposure to one or more stressors” (http://www.epa.gov/raf/publications/pdfs/ECOTXTBX.PDF [accessed January 16, 2013]).