Comments & Observations: Particulate Matter Case Study

1. Comments & Observations:Particulate Matter Case Study EPA-NSF TransAtlantic Uncertainty Colloquium October 10, 2006 Washington D.C. Justin Babendreier Office of Research and Development, NERL/ERD

2. Overview • Anticipation & Adaptation • Well developed case study comparing outcomes of EU and US regulatory efforts/processes in regulating PM over last 30 years. Excellent e.g. • Some Upfront Conclusions • States the Obvious: adaptive learning = good • An underlying theme not necessarily called out but apparent is the issue of time-scale in A&A • Could better develop quan. & qual. information regarding how UA/SA were incorporated (or not) into policy formulations at different points in t. Disclaimer: This work was peer-reviewed by EPA and approved for publication, it may not necessarily reflect official Agency policy. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

3. Key Issues of Good Policy-Science Interface (similar factors of influence for success) • High Quality Knowledge Assessments • Notable: when stakes are high (vicious) attacks on science/data are unavoidable. • Where lacking = lack of success • Conflict is inevitable. KA has to be sound/honest. • Incentives to Surface Information • Example of how Acid Rain Program influenced process • Notes how post-decision incentives sometimes lacking • Need mechanism to keep process honest/on-schedule. • Opportunity for stakeholder lawsuits appear beneficial • Can be abused by those simply desiring to delay action/decision

4. Similarities between US & EU • “Remarkable” based on same science/data • Note: negative for EU that much was US data • Note: causal inference is associative: actual mechanisms of toxicity/mechanisms of exposure, not well understood…..many confounding issues. • Both have used adaptation (decadal scale) to successfully affect health policies • Both have achieved high levels of transparency

5. Differences between US & EU • US has led in adopting new standards • US standard (PM2.5) more stringent • EU standard (annual PM10) more stringent; US has since dropped their standard (i.e., adapting). • US in this case more precautious….i.e., PP (??) • EU hasn’t had a direct mechanism to allow stakeholder lawsuits to enforce review/schedule (prior to 2001) • One big reason for differences appears to be that CAA does not allow EPA to consider cost of adopting air quality standards • Some EU politics external to decisions on AQ

6. Other thoughts • Mapping of Q/Q UA to policy decision process key • Problem formulation/framing • Stakeholders • Selection of Indicators • Assessment of knowledge • Mapping/assessing relative uncertainty • Reporting UA …Parameter uncertainty is a key but not enough….. • Time Scale for Adaptive Learning/Policy Adjustment • Successful tadaptation ? CCA =5 years; 9 years, 10+ • tadaptation = f (stakescost, stakesbenefit, political cycle, science & technology cycle, peer-review cycle, etc, etc.)?

7. Final thoughts • Data is good….it is the basis of A&A • Isn’t that what we are all really just saying here…. • Whatever happened to post-auditing of model-uses? • Post-decision monitoring….needs to be integral to decision-making process. • On long time scales (10-20+yrs), already is integral….. • Economy, Economy, Economy…. • It drives ultimately everything we do… • Strategically….we might want to concentrate, understand better ways to create (equitable) incentives for data collection as part of the adaptive (policy-making) process.