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Is There a Scientific Basis for Environmental Decision‐Making?

THIS PRESENTATION is titled with a question that I am probably foolish and presumptuous to pose. I certainly do not know the answer. My only justification for offering it is that I often find myself thinking in this direction as I observe the work of the Congress and the entire political system in dealing with technical questions of standard setting. Issues in which I have been involved raise the question vividly-protection of the ozone layer, problems of acid rain, storage of nuclear waste, the implication of atmospheric carbon dioxide increase, as well as others. Whether or not a scientific basis for standard setting exists in any of these areas, one thing is certain: there is great pressure currently to look for or create one, or to believe that a scientific basis can exist. This pressure or hope can be sensed in a great many forums. Legislative language, for instance, now frequently mandates studies and decisions based explicity on cost/benefit or risk/benefit analysis. Issues ranging from the snail darter to nuclear safety bring forward this concern, and dozens of topical conferences and workshops on risk assessment analyze and theorize about the scientific basis for health and environmental regulation. The House Subcommittee with which I work even has legislation before it that proposes to formally mandate the use of comparative risk analysis in federal regulatory decision-making.’ To me, attempting to use the methodology of cost or risk/benefit analysis, especially on a comparative basis, implies a hope for a scientific basis for regulatory decisions. It presumes an understanding of the full ramifications and interconnections of the environmental and social phenomena under consideration, and a real ability to identify cause and effect relationships. It implies faith in an accurate quantification of environmental and control strategy risks and costs, which, in turn, signifies some sort of “common currency” or similar measurement units for very different kinds of stresses or perceived problems. Arguments can be made as to whether this trend of thought is “good” or “bad,” useful or foolish, but in any case it certainly has great significance for both science and politics. This significance is what I would like to discuss with you. Before beginning this analysis, however, I think we should remind