Technocracy and Ideology
I intend to write a post spelling out my thoughts on Andrew Gelman's recent post on economists (pointed out to me by Dice). But first I want to comment on the next post on Gelman's blog, concerning the EPA's proposed rule imposing new standards on the scientific evidence that can be used to support environmental rules.
I'll start by saying that I haven't seen the rule proposal. As far as I can tell, it has not yet been published in the Federal Register, and the EPA's press release doesn't link to the text of the proposed rule. So my assessment of the situation is necessarily abstract.
Based on what we know so far, this is highly reminiscent of the old cost-benefit debates. Some people believe that there is a kind of technocratic rationality that can be codified and that will lead to better regulations. They see their agenda as nonpartisan, and when people make partisan arguments ("this change will only result in weaker regulations"), they high-mindedly insist that such arguments must be dismissed. Surely the point is not to have more regulations but rather to have smarter regulations, and for that we must adopt a rational rulemaking system.
The contrary view is essentially that these people are useful idiots helping to implement a deregulatory agenda. The central argument here is that cost-benefit analysis (CBA), heightened standards for scientific evidence, etc. are pretextual and will be applied in a way that serves the ideological agenda of the decision-maker. (In the case of CBA, often the relevant ideologue would be a judge overturning a regulation on the grounds that the regulator has not considered some relevant cost.) In the interest of disclosing my own bias, I am in this camp.
The debate comes down to a factual dispute about the functioning of the regulatory agencies and the courts. Advocates of CBA, high evidentiary standards, etc. either believe that regulators and courts act in a fairly non-ideological way, or they believe that ideology is inescapable and things like CBA improve the outcome anyway. But anyway those are the terms on which the debate should be carried out.
The interesting twist in the case of the new EPA rule proposal is that people like Gelman have dogs in the fight that have nothing to do with environmental regulation. Gelman is angry that scientific papers are sometimes published without publicly sharing the underlying data, and so he has weighed in with arguments in favor of Pruitt's move. (He says his views are "mixed" and much depends on how the rule is implemented. To me, this stance seems hopelessly naive about Pruitt's agenda, but I suppose it makes sense for someone like Gelman to remain agnostic until we've seen the text, and in the meantime to give public support to the rule, provisionally.)
I'll revisit this topic when the rule is published.
I'll start by saying that I haven't seen the rule proposal. As far as I can tell, it has not yet been published in the Federal Register, and the EPA's press release doesn't link to the text of the proposed rule. So my assessment of the situation is necessarily abstract.
Based on what we know so far, this is highly reminiscent of the old cost-benefit debates. Some people believe that there is a kind of technocratic rationality that can be codified and that will lead to better regulations. They see their agenda as nonpartisan, and when people make partisan arguments ("this change will only result in weaker regulations"), they high-mindedly insist that such arguments must be dismissed. Surely the point is not to have more regulations but rather to have smarter regulations, and for that we must adopt a rational rulemaking system.
The contrary view is essentially that these people are useful idiots helping to implement a deregulatory agenda. The central argument here is that cost-benefit analysis (CBA), heightened standards for scientific evidence, etc. are pretextual and will be applied in a way that serves the ideological agenda of the decision-maker. (In the case of CBA, often the relevant ideologue would be a judge overturning a regulation on the grounds that the regulator has not considered some relevant cost.) In the interest of disclosing my own bias, I am in this camp.
The debate comes down to a factual dispute about the functioning of the regulatory agencies and the courts. Advocates of CBA, high evidentiary standards, etc. either believe that regulators and courts act in a fairly non-ideological way, or they believe that ideology is inescapable and things like CBA improve the outcome anyway. But anyway those are the terms on which the debate should be carried out.
The interesting twist in the case of the new EPA rule proposal is that people like Gelman have dogs in the fight that have nothing to do with environmental regulation. Gelman is angry that scientific papers are sometimes published without publicly sharing the underlying data, and so he has weighed in with arguments in favor of Pruitt's move. (He says his views are "mixed" and much depends on how the rule is implemented. To me, this stance seems hopelessly naive about Pruitt's agenda, but I suppose it makes sense for someone like Gelman to remain agnostic until we've seen the text, and in the meantime to give public support to the rule, provisionally.)
I'll revisit this topic when the rule is published.
posted by James | 11:16 AM
1 Comments:
Wow, you really haven't looked into this much. This is nothing like Cost Benefit Analysis. That, at least in theory, laid out some rules to attempt to ensure rulemaking had benefits commensurate with its costs. Due to a number of structural and institutional factors, the rule set leans in a certain direction, but one could easily imagine rule sets that lean in a different direction. For the EPA situation, in seems like the rule has nothing to do with any attempts at increasing rigor or academic transparency or anything else. In the EPA case, medical data protection laws establish standards of confidentially if you are collecting data about people who are or might be sick. Pruitt's aim is to pick a disclosure standard that is mutually exclusive with data protection standards such that data about sick people cannot be used in making decision about if an environmental hazard will make people sick.
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