Quality Assurance of Models. Validation of the models
we use for managing the environment has never not been a problem.
There is today as much interest in the subject as there was
three decades ago more so, in fact. Federal government
scrutiny has been bearing down in recent years on assuring the
quality of the data on which the EPA bases its regulatory decision
making. This dogged pursuit of quality assurance (QA) now applies
to data used in, and generated by, models. It has led in no
small part to the creation of EPA's Council on Regulatory Modeling
(CREM) in 2000. In turn, one of CREM's first official actions
was to issue a draft Guidance Document (2003/4) on matters
of model evaluation (validation) for peer review through
the Agency's Science Advisory Board (SAB) and as the platform
for a National Academies review of the use of models in regulatory
decision-making. Validation is thus clearly not merely a theoretical,
or epistemological, problem of the philosophical basis
for the corroboration or refutation of scientific hypotheses.
It is also of immense practical significance. Disputes and litigation
over controversial decisions and regulations founded on predictions
from models will eventually turn on just how valid are these
models. But why should validation (model QA) be perceived now
as such an acutely difficult challenge? It is in part because
of the increasingly common requirement for grand extrapolation
into conditions not previously encountered, wherein the conventional
assessments based on the "matching of history" and
peer review are proving not to be wholly adequate. It is also
in the nature of modeling environmental systems to advance towards
very high order models (VHOMs), which are especially difficult
to evaluate, according to both conventions (of peer review and
matching history). We are therefore engaged in developing a
protocol for assuring the quality of "predictive"
models, such as those used, for instance, to predict the environmental
impacts of entirely novel chemical substances. Within this setting
we believe there is scope for developing new forms of quantitative
testing procedures. The key is to conceive of models not as
truth-generating machines, but as tools designed to fulfil specified
tasks (like hammers, screw-drivers, and so on). The key will
also be to accommodate "extension of the peer-community
for quality assurance" within the protocol, which is only
to be expected under a regime of Post Normal Science, socially
robust science, or Sustainability Science, if these come to
prevail.