Misunderstanding Models in Environmental and Public Health Regulation
Wendy E. Wagner
University of Texas - School of Law, The Center for Global Energy, International Arbitration, and Environmental Law
Elizabeth C. Fisher
University of Oxford - Faculty of Law
affiliation not provided to SSRN
April 3, 2010
NYU Environmental Law Journal, Vol. 18, 2010
Energy Center Research Paper No. 11-10
Computational models are fundamental to environmental regulation, yet their capabilities tend to be misunderstood by policymakers. Rather than rely on models to illuminate dynamic and uncertain relationships in natural settings, policymakers too often use models as “answer machines.” This fundamental misperception that models can generate decisive facts leads to a perverse negative feedback loop that begins with policymaking itself and radiates into the science of modeling and into regulatory deliberations where participants can exploit the misunderstanding in strategic ways. This paper documents the pervasive misperception of models as truth machines in U.S. regulation and the multi-layered problems that result from this misunderstanding. The paper concludes with a series of proposals for making better use of models in environmental policy analysis.
Number of Pages in PDF File: 65
Keywords: model, environmental law, science, EPA
JEL Classification: K32, K23Accepted Paper Series
Date posted: November 19, 2010 ; Last revised: November 30, 2010
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