Cal/EPA Risk Study

“EPA’s Newest Hazard: Risks to Peace of Mind” (June 11) reported on a forthcoming Cal/EPA study on environmental priority setting that will emphasize issues affecting the “peace of mind” of communities over priorities based on scientific assessment of risk. The article also pointed out that there is little data to support the Cal/EPA study finding that “pollution hot spots” disproportionately affect minority communities.

“Peace of mind” environmental priorities are not new, and the Cal/EPA study will only make explicit what is already being done. Overwhelming uncertainties in science-based risk assessment have meant that policy-makers have always had to use “peace of mind” concerns to establish environmental policy. In many cases such concerns serve as a suitable surrogate for scientific risk assessments containing unknown uncertainty and statistical bias. Given this reality, and the fact that some communities are more effective than others at voicing concerns, the Cal/EPA report brings forth a critical point; there must be “peace of mind” for all communities--black, white, brown, yellow, Native American, rich or poor.

Few would choose not to improve the scientific basis for policy or to ignore what is known. We suspect that many issues that have not yet aroused “peace of mind” concerns--such as indoor exposure to air toxics--nonetheless pose significant risks. More generally, the way science and analytical disciplines are used in environmental policy-making can be vastly improved. Scientific peer review, systematic data gathering and independent evaluation are rare occurrences in this overly politicized field. The inability to find confirming data for minority community “pollution hot spots” is more a comment on the entire process our society uses to formulate environmental policy than on the validity of this particular issue.

We must explicitly recognize that both scientific assessment and “peace of mind” are important parts of environmental priority setting. The ways in which government utilizes both can be vastly improved.

DAVID S. RUBENSON

RAND, Santa Monica