Keeping Pace with Science and Engineering Case Studies in Environmental Regulation (1993) / Chapter Skim
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Introduction
Introduction
Pages 1-7
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How such costs are distributed is itself a contentious issue, as amply demonstrated by the estimate of costs of the recent amendments to the Clean Air Act. When environmental regulatory costs turn out in retrospect to have been unwarranted because regulatory decisions were based on inadequate or inaccurate scientific information, it's only natural to express concern, since costs will have been borne without deriving the projected environmental benefits.
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Issues of this type arise in two of the case studies presented in this volume, one on compliance strategies for meeting ambient ozone standards in urban areas across the country, and the other on meeting ambient water quality standards in Chesapeake Bay. The conflicts between national standards and regionally variable implementation raise important issues in their own right.
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On the one hand, all regulatory policies promulgated legislatively or by executive actions are based on scientific and technical information that is only a snapshot of our knowledge at the time of decision. Our scientific understanding and our technologies for measurement or remediation are continuously changing, however, sometimes at a very rapid rate, unfettered and uninfluenced by the politics of the moment or constituency concerns except as politics might affect federal funding for research and develop ment.
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Physicists may know the value of the speed of light to eight or nine significant digits, but in environmental affairs, we must often deal with uncertainties in the first or at best the second significant digit. One reason that uncertainties are high is that environmental regulations address issues at the cutting edge of current scientific understanding.
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Our understanding of acid rain was greatly improved, but it is not at all clear that NAPAP provided, on a timely basis, the relevant information that Congress wanted in order to set acid precipitation policy. It is well and good that we want to base environmental regulations on the best available technical understanding, but we need to recognize that that understanding is inherently dynamic.
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However, doing so not only takes time but also involves capital expense. Within their frameworks for planning and executing capital investments in pollution abatement technology or alternative production processes or product formulations, regulated industries prefer-and deserve predictable regulatory regimes.
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Its purposes are to shine a spotlight on the competing demands for keeping regulations in step with current knowledge and for maintaining regulatory stability and to serve as a catalyst for further consideration of and debate about the appropriate balance between these goals. My hope is that the case studies and essays in this volume will stimulate additional analytic examination of current policies and past practices, leading to a better understanding of whether the current regulatory system does about as well as can be expected or, if not, what alternatives might be considered.
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