65 Pages Posted: 19 Nov 2010 Last revised: 30 Nov 2010
Date Written: April 3, 2010
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.
Keywords: model, environmental law, science, EPA
JEL Classification: K32, K23
Suggested Citation: Suggested Citation
Wagner, Wendy E. and Fisher, Elizabeth C. and Pascual, Pasky, Misunderstanding Models in Environmental and Public Health Regulation (April 3, 2010). NYU Environmental Law Journal, Vol. 18, 2010; Energy Center Research Paper No. 11-10. Available at SSRN: https://ssrn.com/abstract=1711766