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-3- tt~ ~I1ttP~-1~t¢~/FIfCIJ Mday, April 1U,1992 EPA's Shoddy Science The United States currently spends about $115 billion annually on environmental protec- tion. At least some of that huge expense is necessary. But billions of dollars in unnecessary costs have been imposed on Americans be- cause the so-called science behind many Envi- ronmental Protection Agency regulatory ef- forts would flunk even a high school-level test. At the EPA, "science" too often is fudged in order to make political regulatory decisions look good. So says an expert scientific panel appointed by EPA Administrator William Reilly in a recently released report. "Regulations based on unsound science have led to unneeded eco- nomic and social burdens, and that unsound science has sometimes led to decisions that expose people and ecosystems to avoidable risks," the panel's report says. "[Sjtudies fre- quently are carried out without the benefit of peer review or quality assurance. They some- times escalate into regulatory proposals with no further science input, leaving EPA initia- tives on shaky scientific ground..., " the report says. It should be no surprise, then, that the panel also concluded: "Science never should be ad- justed to fit policy. Yet a perception exists that EPA lacks adequate safeguards to prevent this from occurring." Furthermore, "science activi- ties to support regulatory development ... do not always have adequate, credible quality as- surance, quality control or peer review" and the agency "does not give sufficient attention to validating the models, scientific assumptions and databases it uses." "In the absence of sound scientific informa- tion," the panel concluded, "it is likely that high-profile but low-risk problems will be tar- geted, while more significant threats will be ignored." It was not within the panel's charge ,q,pite specific instances of politicized science, ut Exhibit A ought to be the agency's National vir Quality and Emissions Trend Report of L989, which set the baseline for Clean Air Act colnpliance. The EPA rushed to press with its dat3 on air pollution back when the Clean Air Act was being debated, even though an unusu- APR 16 1992 ally hot summer in 1988 caused abnormally high ground-level ozone readings in many areas. That report put numerous metropolitan areas - including Richmond and the Washing- ton. D.C., area - into technical "non-compli- ance" with the new Clean Air Act. Such areas must adopt expensive mitigation strategies - such as the California car emissions standards, refueling vapor recovery and strict industrial emissions requirements. But now the EPA is sitting on 1989-91 data (technically, it is available if you know what questions to ask of whom at the agency) that would give a more realistic picture of the urban ozone problem, one that puts many fewer cities in non-compliance. Richmond, for example. would no longer be subject to the most strin- gent Clean Air Act requirements, and Roa- noke would drop completely off the charts. Many other cities across the United States would be reclassified from "severe" non-com- pliance to merely "moderate," and some cities would be moved from "moderate" to "margin- al," according to a CATO Institute analysis by environmental consultant K. H. Jones. The updated data show that California still is where the most serious air pollution problems are to be found. That seriously challenges the foundation of the EPA's precious Clean Air Act, which requires the entire continental United States to adopt similar pollution standards. The General Assembly's Clean Air Study Committee should make acquiring the revised EPA data its first order of business. Using real data - vs. the politicized data used as the basis for the Clean Air Act - could save Virginians millions, perhaps billions, of dollars in compli- ance costs. The EPA and its friends on Capitol Hill suggest correcting the agency's serious scientif- ic deficiencies, naturally, with a 50 percent boost in its research budget. Scientific integrity, however, doesn't cost anything. When huge costs so often are involved in environmental regulation, it does not seem too much to ask that the EPA refrain from letting politics dic- tate the results of its science. COMP A93(5)