EPA Sustainability Tools

The National Research Council has issued a new report: Sustainability Concepts in Decision-making: Tools and Approaches for the US Environmental Protection Agency (2014).
While there are some good points about how EPA can do a better job incorporating sustianability considerations into their decision-making, there are a couple recommendations that trouble me:

- Implying that EPA has the wherewithal to deal with the breadth of sustainability.  All they need are a good basket of software tools, right?

- Yes, NRC talks about the need to bring in relevant stakeholders, but.... How likely are the right stakeholders going to be able to take the time (and money) to participate, even if they learn about an EPA effort?

- Oh wait - just use social media and find out "the public's" viewpoints.  Holy cow, building complex regulations on Twitter is absurd.  Pick your favorite celebrity and "Like" their opinion.  The herd mentality of social media scares me.  Anyone can post whatever based on little or no expertise and it goes viral hyping negligible risk, scaring and hurting people and companies.  Check out some of David Ropeik's blogs on How Risky Is It, Really.

- Rigidity.  EPA takes forever to get a rule out and have it reinterpreted by the courts, based on old data and locking in "the answer" for years. NRC recommends lots of real time data gathering (oooh... shades of  NSA) and tracking trends, but rulemaking is a slow slog.  We need to come up with some better ways to review and update regulations based on the best data we can.  Build in some flexibility if basic assumptions supporting a regulation are no longer true.  Maybe we can build in some Plan B or C if new (validated) data becomes available and do an expedited re-proposal or direct final or - heaven forbid - revoke a regulation that no longer makes sense.

- Uncertainty.  This NRC got right.  EPA has to be more clear on the level of uncertainty involved in its models and better characterize what it does and doesn't know about existing risks.

Fortunately, NRC didn't get prescriptive on what EPA should do how.  But if the agency will take the time to think about how to approach sustainability in each of its activities there should be progress.