October?, 1999
EPA-SAB-EC-COM-00-002
Honorable Carol Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington DC 20460
Subject: Science Advisory Board Commentary on the Role of Science in "New
Approaches" to Environmental Decisionmaking that Focus on Stakeholder
Involvement.
Dear Ms. Browner:
In recent years the Agency has devoted considerable attention to developing and
promoting new, more flexible, and adaptive approaches to environmental regulation. Many of
these address the problems of specific places, specific economic sectors, or especially vulnerable
populations such as children or the disadvantaged. In all of these efforts, the Agency has worked
hard to develop and use new strategies for enlisting the active advice and participation of relevant
stakeholders. Of course, EPA has always sought and encouraged public input, but this new focus
on stakeholder involvement is a welcome effort to make environmental regulation more
democratically responsive. As a recent review by Yosie and Herbstl has shown, learning how to
most effectively involve stakeholders is an ongoing process which deserves continuing attention.
Involving representatives of specific concerned or affected parties in environmental
decision making is clearly important. However, the Agency also has a responsibility to represent
the broad "public interest" in environmental decision-making. Cynics may argue that there is no
such thing as "the public," only interest groups. But the concept of the general public interest lies
at the heart of many of our most cherished democratic institutions. For example, we don't appoint
a committee of the family of the accused and the family of the victim to try criminal cases. We
appoint an unbiased jury and give them the mandate to determine the facts on the principle that in
the long run justice based on factual truth serves the best interests of the public at large.
F. Yosie and Timothy D. Herbst, "Using Stakeholder Processes in Environmental
Decisionmaking: An Evaluation of Lessons Learned, Key Issues, and Future Challenges," Ruder
Finn, Washington, September 1998.
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In a similar way, the interests of the general public are best served when, in addition to
addressing the interests and needs of stakeholders, environmental decisions are also based on a
full and careful consideration of all available science. Sometimes, such a full and careful
consideration also serves the immediate interests of specific stakeholders. But often it does not.
Polluters may be influenced by compelling short-term economic interests. Environmental activists
may be motivated by their specific political agendas. Affected citizens may be motivated by
perceptions, concerns, and political agendas that are only partially informed by available science.
In short, involving stakeholders in the decision making process does not guarantee that decisions
will be based on a secure scientific foundation and, therefore, does not assure that the broader
public interest will be fully served.
Basing decisions on a careful consideration of all available science is a basic part of the
EPA's mission. However, in the press of day-to-day operation even the Agency may be diverted
from this mission. For obvious and legitimate political reasons, the Agency is interested in
minimizing controversy. Especially in newer decision environments, which involve a greater focus
on consultation and negotiation among directly involved stakeholders, there is a risk that the
broad public interest in assuring that decisions are based on a full consideration of all available
science may receive too little attention.
One way to minimize this risk is to work on evolving better mechanisms to assure that
available science gets adequately reviewed for, and considered in, such decision settings. Equally
important is the need to identify gaps in knowledge uncovered in such decision settings, so that
research agendas can be responsive to these needs.
We enthusiastically support the Agency's efforts to develop and promote new, more
flexible, adaptive approaches to environmental regulation. They are responding to an important
need. As these new approaches evolve and mature, we urge you to lead the Agency in a more
systematic consideration of how science can most effectively be reviewed for, and considered and
used in, these new decision processes.
For our part, to assist in this effort, representatives from the Science Advisory Board
(SAB) have been participating in a series of internal workshops on "New Directions in EPA
Science: Workshops on Innovations in Environmental Protection" being run by the Office of
Research and Development. When these are complete, the SAB Executive Committee plans a
series of its own workshops, to which selected Agency, SAB and outside parties will be invited to
discuss how science is being reviewed and used, and how it might better be reviewed and used, in
each of a number of new programs and offices. In advance of these workshops, we plan to invite
a number of senior Agency officials to give us feedback on this commentary. Are we
inappropriately concerned? Are there mechanisms already in place that adequately mitigate the
risks we have discussed? Are there important aspects of the issue that we have perhaps
overlooked and need to consider?
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We hope you will support and join us in advancing this important agenda.
Sincerely,
/s/ /s/
Dr. Joan Daisey, Chair Dr. Granger Morgan, Chair
Science Advisory Board New Approaches Subcommittee
Science Advisory Board
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NOTICE
This report has been written as part of the activities of the Science Advisory Board, a
public advisory group providing extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency. The Board is structured to provide
balanced, expert assessment of scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency and, hence, the contents of this report
do not necessarily represent the views and policies of the Environmental Protection Agency, nor
of other agencies in the Executive Branch of the Federal government, nor does mention of trade
names or commercial products constitute a recommendation for use.
Distribution and Availability This Science Advisory Board report is provided to the EPA
Administrator, senior Agency management, appropriate program staff, interested members of the
public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is
also provided in the SAB's monthly newsletter {Happenings at the Science Advisory Board).
Additional copies and further information are available from the SAB Staff.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
NEW APPROACHES SUBCOMMITTEE
CHAIR
Dr. M. Granger Morgan, Carnegie Mellon University, Pittsburgh, PA.
MEMBERS
Dr. Richard J. Bull,Battelle Pacific Northwest National Laboratory, Richland, WA.
Dr. Terry F. Young, Environmental Defense Fund, Oakland CA.
CONSULTANT
Dr. William Glaze, University of North Carolina, Chapel Hill, NC.
SCIENCE ADVISORY BOARD STAFF
Dr. Angela Nugent, Designated Federal Officer, Environmental Protection Agency, Science
Advisory Board, Washington, DC
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