Why ‘science’ alone isn’t enough for setting environmental policy

October 2, 2015
Century City and downtown Los Angeles are seen through the smog

Century City and downtown Los Angeles are seen through the smog December 31, 2007. REUTERS/Lucy Nicholson

The Environmental Protection Agency announced new, stiffer smog rules on Thursday that will reduce the allowable level of ozone in the air.

Business leaders and state officials point out that many regions of the country still cannot meet federal standards set in 2008, or even back in 1997. The tighter smog regulations, they assert, will likely have job- and growth-killing effects. This has, however, fallen on deaf ears.

The EPA maintains that its new standard is necessary to protect public health, which includes preventing asthma and even death. It insists the new rules are based purely on science, untainted by economic considerations. That’s poppycock.

Supporters and opponents of the new standard have accused each other of using bad science, or politicizing science, to make their arguments. Yet they are all “scientizing policy,” as I show in a new study for the George Washington University Regulatory Studies Center.

dod---la smog skyline b&w

Century City and downtown Los Angeles are seen through the smog December 31, 2007. REUTERS/Lucy Nicholson

Science is vital — but rarely sufficient for making policy decisions. There are two key reasons. First, though scientific information is essential for understanding matters of fact, it can’t be the sole basis for making policy decisions about what should be. Second, when predicting health risks, scientists can never have complete information, so bureaucrats must make assumptions and judgments when they interpret scientific information to set rules.

Yet the Clean Air Act does not recognize this. The law requires the EPA to revisit the smog standard every five years, and then base its decision of whether to revise it on science alone. No other considerations — including economic impact — may be taken into account.

The law says science is the only factor that can legally be considered in setting a standard. Thus the temptation to “scientize” policy by putting a spin on scientific results to advance policy goals, if even subconsciously, is almost inescapable.

Though some judgment is necessary to translate scientific evidence into policy prescriptions, current procedures for doing so are not transparent. They have led to distortions and false precision in the presentation of scientific information. The practices blur the line between science and policy and contribute to the scientization of policy.


Smog obscures view of Chrysler Building from Empire State Building in New York City, 1953. LIBRARY OF CONGRESS/Walter Albertin.

Policymakers and the public are often unaware of the influence of hidden policy choices, or that alternative, equally plausible assumptions predict very different risk outcomes.

The environmental agency presents its new ozone standard as if it were a magic number — exactly meeting the statutory requirement “requisite to protect public health” with an “adequate margin of safety,” but going no further. It provides precise-sounding predictions of the health benefits to be achieved. Its pronouncements, however, don’t acknowledge the considerable uncertainty about the actual risk involved, or the agency’s reliance on biased inferences and assumptions for handling that uncertainty.

The EPA claims, for example, that its new standard would prevent up to 660 deaths annually and thousands of cases of asthma and bronchitis. However, Tony Cox, a mathematics professor at the University of Colorado and editor-in-chief of Risk Analysis: An International Journal, examined the agency’s ozone data and risk assessment carefully. He concluded in an EPA filing that further reductions in ozone levels would make no difference to public health. “Past reductions in ozone,” Cox noted, “have had no detectable causal impact on improving public health.”

File photo of downtown Los Angeles skyline from Hollywood, California

The downtown Los Angeles skyline through a layer of smog is seen from a rooftop in Hollywood, California, May 31, 2006. REUTERS/Fred Prouser/Files

We can all agree that politicians should not politicize science by distorting what scientific studies conclude. But we should also be wary when scientists and unelected officials attempt to exert influence on policy decisions by selectively presenting, or even distorting, scientific findings — which leads to the scientization of policy.

The Clean Air Act’s pretense that science alone can determine the ideal ozone standard virtually guarantees the scientization of policy. It effectively forces those involved in regulatory decisions to hide rather than reveal scientific uncertainty, and to dismiss and denigrate dissenting views. Key policy choices, disguised as science, rest with technical staff, while policymakers charged with making hard decisions avoid responsibility by claiming their hands were tied by the science.

This has evolved into an adversarial process characterized by harsh rhetoric in which each party claims that science supports its preferred policy outcome and questions opponents’ credibility and motives rather than a constructive discussion regarding very real tradeoffs. We won’t know the real reasons why the EPA chose to revise the already stringent standard of 75 parts of ozone per billion parts of air (or 0.0000075 percent) or why it chose 70 parts per billion as opposed to 65 ppb or something in between.

Communities across the nation that will have to sacrifice to implement the new standard deserve better.


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When I read the title of the article, I was so hopeful that someone had finally come around to the notion reasoning alone will not solve a problem or change people’s behavior, but that we must in addition equal amounts of empathy and heart for the vibrant earth that we are part of. This world is such a magical place that surely the heart of an artist must be coupled to the mind of a scientist to make decisions and solve problems in a meaningful way.

How sad I was to see the author take such a limited focus on such an important topic. There is more to life than science, politics, and economics.

Posted by CanyonLiveOak | Report as abusive

Science vs. FUD? The choice is clear to be former in the rational minds.

“.. Communities .. sacrifice .. deserve better..” – author’s conclusion on behalf of the communities is seen as self-serving as the reality of current-day communities and their conscious choices were clearly seen to be in favor of sustainability of future of current and next generation.

Posted by Mottjr | Report as abusive

We need to understand some things that are not rocket science at all… First, that we are ALL in the same boat, called the Earth. Second, if we continue living like there’s no tomorrow, so why have children? Third, that NO ONE can wear ten pants on the same butt, and that obesity, hunger and the environment are a few components of the same problem: ignorance, arrogance and greed.
In order to survive, we need to change our inner environment first.

Posted by UauS | Report as abusive

Haha. George W. Bush’s “Administrator of the Office of Information and Regulatory Affairs.” This writer is the Baghdad Bob of pollution.

“What problem? We are victorious. We have the smog on the run.”

Posted by Solidar | Report as abusive

Had to check the URL and make sure I hadn’t accidentally loaded the Fox News website… surprised to see such anti-intellectual garbage on Reuters.

Posted by Reiser | Report as abusive

Are you still suppressing the speech that get at the heart of this fallacy?

Posted by brotherkenny4 | Report as abusive

Okay, let’s try again. Science is a reasoned method for testing hypothesis’. Humans are mostly not scientists or scientific. Science, or more specifically scientific consensus is not always reached. However, to deny the science which has reached consensus is to be in conflict with reality. To say that because there is some doubt (usually supported by someone in the scientific community who also has financial allegiances to the industry they protect) when a small minority of people do not agree with the consensus is evidence of the non-consensus point is to pervert the scientific process. The corporations and their political minions in both the DFL and GOP pervert the scientific process in hopes of fooling the mostly non-scientific populace.

There is no evidence that our leaders have the kind of humanity necessary to determine the path forward with regard to information gained by scientific endeavor. They consistently worry about the corporations and generally use the jobs scare tactic as if the existence of the corporations is necessary for our existence and happiness. It is just a lie that many fools fall for.

Posted by brotherkenny4 | Report as abusive