SHOSHONE TERRAPIN, March 26, 2003, pages 6, 7.
Hero Science — No Thanks!
EPA Science Read as a Morality Play

Of the Shoshone Terrapin

     In the field, EPA science rests on a morality play. The play has three players:  a villain, a victim, and a hero. The villain is a large and powerful but selfish and immoral business — an entity that has wrongly and culpably harmed the environment and those inhabiting it, human, animal, or plant.
     EPA’s bland acronym for these villains is “PRPs,” for “Potentially Responsible Parties.” The victims are the local townsfolk. Townsfolk have little power — financial, political, or technical — and require the help of the hero to get the PRP to stop polluting and to repair environmental and human health damage already done. The hero is EPA, a burly federal bureaucracy armed with the considerable powers of the CERCLA or Superfund statute.
     This moral scenario subtly sets limits on the play’s action. For example, the villainized status of offending business weakens its ability to scrutinize and challenge EPA science, since such actions risk being interpreted as signs of further villainy. (A PRP executive recently noted in private: How do we criticize dubious child health science without coming off sounding like monsters?)
     On the other hand, victims are free to encourage the hero’s intervention by exaggerating harm claims or perceptions of the villain’s malevolence. The play’s underlying moral assumptions help create an uncritical context for EPA’s science.
     Here in North Idaho’s Coeur d’Alene Basin, however, this moral structure doesn’t fit our situation. Our mining industry isn’t rich and powerful but instead is teetering on the edge of extinction. Local citizens don’t believe EPA assertions that their children have a mining-related lead health problem and they are deeply suspicious of an EPA computer simulation model that says children do.
     Unlike a hundred years ago — when mine unions and mine owners were locked in a fierce struggle — nowadays mine workers and the local populations wish the mining industry well. Few relish the prospect of exchanging skilled and well-paying mining jobs for unskilled and minimum-wage jobs in an emergent tourism trade. EPA — like an actor who has accidentally walked out on the stage of the wrong play — continues to hawk its hero solution even though the moral preconditions for that performance are nowhere to be seen.
     The result is heightened local scrutiny of EPA’s science-based claims.
     Here in the Silver Valley we formed a citizens’ group called the Shoshone Natural Resources Coalition (SNRC), which in turn soon created a subcommittee charged with reviewing and critiquing EPA science.
     The learning process was slow — at least at first — and EPA officials were not particularly helpful in pointing us to counter-evidence or other problematic aspects of their enterprises (perhaps they were ignorant of them, too). The internet and the web are great resources for a small community, however, and before long we were making discoveries.
     For instance, we soon discovered the story of the Smuggler Mountain Superfund Site in Aspen’s Pitkin County, Colorado, where locals disputed the same EPA computer simulation model.
     There, locals managed to empanel a distinguished group of impartial scientists to evaluate EPA’s model-based claims. Though the fight was long and hard, in the end the scientific panel rejected the EPA’s main conclusions and EPA reluctantly withdrew. Reading the evenhanded and intelligent prose of the Smuggler scientific panel’s 1993 final report was like chancing on a cool oasis after trudging through miles and miles of EPA’s hot, goal-driven prose.
     We also discovered that EPA’s lengthy report bibliographies somehow managed to exclude important scientific papers with critical messages about their model. Moreover, by alerting EPA to the presence of such critical papers we learned how indifferent EPA research contractors were to including critical substantive content and cautions in their analyses. At least once — and astonishingly — a scientific paper we had identified as critical of the EPA’s model was cited back to us as one of several papers supporting the model!
     When the revised final version of EPA’s human health report was published, it contained a one-sentence acknowledgment of the model-critical papers we had pointed out but no substantive discussion of their content appeared in the report’s chapter devoted to “uncertainties in risk assessment.”  More might be added to the list of what we learned.
     The goal of our citizen-scientist assault on the human health science EPA offered was not particularly radical: we wanted a state-of-the-art epidemiological survey to be done to confirm or disconfirm the predictions or estimates generated by EPA’s computer simulation model. The survey might cost up to a quarter-million dollars — chickenfeed in contrast with the 90 million dollar yard-soil-replacement plan EPA was going to carry out.
     And yet EPA stoutly resisted this request — which resistance in turn slowly educated us as to EPA’s preference for inferential methods employing soil measurements over direct public health measurements. Our argument that EPA in the end had created an unfalsifiable and self-contained scientific approach for itself has to date fallen on deaf ears. Mere philosophy of science appears to be pretty far down the ladder of EPA’s concerns — doubtless one of the byproducts of that agency’s sense of heroic purpose.
     A 1992 National Academy of Sciences report (Safeguarding the Future: Credible Science, Credible Decisions) concluded that EPA science was frequently troubled by uneven quality, by a failure always to offer contrasting scientific views, by a conflict of interest between the agency’s scientific and regulatory roles, and by a prevailing perception that the outcomes of EPA science are adjusted to fit, consciously or otherwise, the needs of EPA policy.  Here in the Coeur d’Alene Basin we believe that an NAS review will confirm that these same tendencies, ten years later, still plague EPA science.