Effects of a Polluted Environment Research and Development Needs (1977) / Chapter Skim
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GENERAL RECOMMENDATIONS
GENERAL RECOMMENDATIONS
Pages 22-33
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From page 22... ...
RESEARCH STRATEGIES FOR SCME RELATIVELY INTRACTABLE SCIENTIFIC PBCELEMS Many of the most critical scientific issues related to decision making on environmental problems probably cannot be resolved by research efforts within the next several years. Some fundamental questiors about effects of environmental changes that fall into this category include: • identifying effects of pollution on climate; • identifying no-effect levels in plants, animals, and humans; • predicting changes in whole eccsystems; - 22
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Some of the effects involved, such as climatic change or long-term perturbations of ecosystems, may be irreversible; and their consequences, such as changes in world agricultural productivity or a decline in the yields of ocean fisheries, might render many current environmental concerns trivial in comparison. Yet, because of the continuing need for information to support a shifting array of more immediate decisions, and because the time reeded to produce answers tc most of these currently intractable problems generally cannot be estimated with any confidence, regulatory agencies such as EPA have tended to assign such investigations low priority in the allocation of research funds.
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From page 24... ...
IMPORTANCE OF EFFECTS CN NONHUMAN OPGANISMS The National Environment Policy Act calls for a balanced commitment to the protection and enhancement of both huiran health and ecosystems. However, because of the relative ease of recognizing direct threats to human health and the great social weight attached to them, policy decisions are most heavily influenced by evidence of hazards to man, and a large proportion of research has been directed toward assessment of such impacts.
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From page 25... ...
, the current level of effort to provide sound economic analysis for environmental decision making is, in our judgment, still seriously inadequate. The need for improved economic analysis in EPA is also examined in the report of the Panel on Sources and Control Techniques cf the Environmental Research Assessment Committee, (NRC 1977a)
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If research were designed and carried out tc collect primary (scientific) data appropriate for economic analysis, improved estimates of pollution damages cculd be obtained for effects "such as impacts on water-based recreation, deterioration of materials, and damage to agricultural crops.
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; the intense pollution of the area around Hopewellr Virginia with the pesticide Kepore; and the severe episodes of urban air pollution produced by unusually stable weather conditions in different parts of the country on several occasions in recent years (Storer 1975)
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To date, the desirable level cf interaction has rarely been achieved, tte recommend strongly that more formal institutional arrangements be developed to provide for joint rapid-response efforts by EPA and CDC to study the effects of future pollution incidents. PUBLICATION OF THE EASIS FOR SCIENTIFIC JUDGMENTS ^he bgs 4g for _its_scient if ^,g_ judgments jeg§rding_the_guality._cf_evidence_of ign Scientific evidence of actual or potential adverse effects on man or on the environment carries great weight in EPA's regulatory decisions.
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For example, the Federal Court cf Appeals for the 3rd Circuit in 1975 remanded effluent limitations guidelines for the iron and steel industry to EPA because "other information available to the agency", cited,in the Administrator's decision document, was not specified, and consequently meaningful judicial review cf the Administrator's decision was impossible.2 Similarly, the Federal Court of Appeals for the ttth Circuit in 1976 reversed EPA's effluent limitations for the tanning industry, and castigated the agency: "The record, however, implies that these conclusions are the product of guesswork, and not of reasoned decision-making... No scientific data or other demonstrative evidence was given to substantiate these final effluent levels11.3 Such conclusions by the courts are, unfortunately, net isolated; many of these EPA decisions that have been reversed have been faulted for improper or inadequately supported use of scientific information.*
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Vie believe that a policy of this sort should be followed at all stages of the sequential processes of decision making, adjudicatory hearings, ard judicial review of EPA actions.
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These papers are available in limited numbers upon request from the Environmental Studies Eoard of the National Research Council, 2101 Constitution Avenue, Washington, E.C.
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Sources of Residuals and Techniques for Their Control: Research and Cevelopaent Needs. A Report cf the Panel on Sources and Control Techniques to the Environmental Research Assessment Committee, Environmental Studies Board, Commission on Natural Resources.
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From page 33... ...
Volume III. A Report of the Environmental Research Assessment Committee, Environmental Studies Board, Commission on Natural Resources.
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