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Journal of Political Ecology:
Case Studies in History and Society
VOLUME 8 (2001)
Making Better Environmental Decisions: An Alternative to Risk Assessment by Mary OBrien, Cambridge, MA: MIT Press (published with Environmental Research Foundation), 2000, 283 pp.
Reviewed by Branden B. Johnson, Research Scientist, Division of Science, Research and Technology, New Jersey Department of Environmental Protection*
*The views expressed here are not necessarily those of the New Jersey Department of Environmental Protection.
Dr. OBrien, a botanist and environmental activist,
has written a brief for changing the basis for environmental decisions
that is impressively written and argued but still disappointingly flawed.
Implementation of her proposed "alternatives analysis" could
well improve such decisions, but less than she expects. Despite her refreshing
candor about the limits of environmental management, she ignores many
political and logical constraints on alternatives analysis (AA) and unduly
demonizes risk assessment (RA).
Her main point is that we should examine two or more
alternatives for a given decision, and choose the option that is least
damaging. She believes most current environmental decisions focus only
on whether a single option poses an acceptable risk or is "safe,"
findings that she sees as scientifically impossible, immoral, and damaging
OBrien devotes a chapter to reviewing less-than-perfect
current examples of AA, ranging from environmental impact statements to
Consumer Reports® evaluations of consumer products. A secondary theme
of the book is that "risk" or biological outcomes are unduly
narrow criteria for environmental decisions; a wider look at the adverse
impacts and benefits of alternatives would provide society with a better
sense of the tradeoffs entailed in any choice, "[b]ecause the differing
benefits of the various alternatives remind us of divergent considerations
[and] we will ask a broader range of questions about the alternatives"
(p. 135). She ends with barriers to adoption of AA (e.g., fear of "changes
in business as usual" and of "a public process"; concern
about "having to consider an infinite number of outlandish alternatives"),
and proposes solutions.
There is quite a bit to be said for these theses, and
OBrien says most of it, eloquently, passionately, and with selective
evidence. I agree with her that much environmental decision-making focuses
on how much harm can be endured rather than avoided; opportunities for
avoiding many harms are plentiful, if at certain costs; "risk"
is only one of many attributes of decision alternatives, and only one
of their consequences that people care about. While AA might sound potentially
chaotic, I believe she is correct that "risk-based decision making
is just as socially messy as decision making based on [AA]. Its
just that [AA] helps make visible the non-scientific elements that are
always behind risk-influenced decisions regarding who will be allowed
to do what to the environment" (p. 243). OBrien also acknowledges
that "permitting of hazardous activities is unavoidable to some degree"
(p. 79), and that some hazards, such as those from nuclear wastes and
persistent chemicals such as PCBs, cannot be removed (pp. 110, 116). For
such inevitably damaging, irreparable situations, OBrien suggests
that society analyze options that allow "for the greatest possible
cleanup or restoration," even if the action chosen "will finally
be based on economic and social costs, ethics, and political will,"
and identify "related production, technologies, or behaviors that
could cause the same problems in the future" (pp. 210-211).
Although I endorse OBriens call for more
AA, I am much less sanguine that it will greatly improve environmental
decision-making, based on what I see as undue assumptions or illogic in
some of her discussions of AA, RA, and environmental policy.
The first half of her book concerns "What Is Wrong
with Risk Assessment?" The scope of this term is somewhat ambiguous,
making it a bit difficult to evaluate the accuracy of her criticisms.
Although she says RA includes any estimate, however informal or
non-quantitative, of "the safety of a hazardous activity or substance
without considering the benefits and drawbacks of a decent range of options"
(p. 39), her discussion focuses mostly on quantitative risk assessment
for toxic chemicals (particularly the probabilistic variety, although
she does not use this term), with a few ecological examples thrown in.
OBrien says RA is invalid because it omits or analyzes inadequately
diverse adverse effects, cumulative effects of multiple exposures, differing
exposures and vulnerabilities across people, and "all indirect and
interrelated consequences within our complex environment" (pp. 67-72).
Safety is impossible to determine, "because all consequences cannot
have been considered" (p. 69). (Oddly, OBrien says that "[m]ost
risk assessments are unscientific because they cannot estimate how much
of a damaging activity poses no risks or insignificant risks"
[p. 59, emphasis added], although she correctly notes elsewhere that defining
the "insignificance" of risk is a political, not a scientific,
finding.) The uncertain quantification of RA helps "timid regulatory
agencies" gain psychological distance from their decisions
meaning (e.g., some people will die) and increase their discretion, while
reducing disproof given the methods uncertainty, manipulability
and demand for rare expertise (pp. 106-108). Businesses welcome the chance
"to fight for years over the exact details of risks of each toxic
chemical" while they continue to pollute and profit (p. 242). RAs
esoteric nature means agencies work mostly with business and thus "avoid
dealing with many other groups who know about alternatives to the proposed
activity and about unquantifiable benefits and hazards of the activity
and of the alternatives" (p. 107), while "[a]ll sectors of the
society can participate and can reinforce the efforts of other sectors"
(p. 202) in AA. The AA method also frees analysis from the abstractions
of numerical risk estimates:
I have worked with risk assessors for several years,
including detailed discussions of the limitations of their craft. Despite
the ambiguity in how well particular criticisms apply to the very diverse
approaches she has grouped as RA, I largely agree with OBriens
points about RA. I am a bit more optimistic about the safety margins in
their estimates than is OBrien, although perhaps Im biased
by seeing more competent and honest analyses than the examples she cites.
However, my main problem with her arguments about technical, moral and
practical flaws is that she limits these to RA, when they apply equally
to any effort--including AA--to predict the likely positive and negative
outcomes of future events that might or might not occur. Uncertainty is
inherent in such prediction, and numerical estimates of uncertainty are
one tool (neither the only nor always the best) to help us make decisions
in the face of ignorance, not merely ploys to serve self-interest. Although
OBrien says for AA "the existence of uncertainty about any
one option [is] a valuable piece of information," she only mentions
the undesirability of options whose damages are quite uncertain (pp. 217-218,
220). She offers no discussion about uncertainty that risks might be over-
rather than under-estimated, uncertainty of benefits, or uncertainty in
the preferability of "alternatives" to "business as usual."
Perhaps this gap in her argument is explained--but not, in my view, justified--by
her view that "all our efforts to allow ecosystems and organisms
to retain or regain integrity are reversible. Only adverse consequences
of our activities seem to have the potential for being essentially irreversible,
at least short of geologic time" (pp. 194-195). And attempts by business,
government, activist and other analysts to achieve desired results are
not only also likely with AA, they are almost guaranteed, since compared
to RA there are more variables to manipulate and more parties participating.
She mentions at great length the ability of business to use arguments
over RA details to delay changing their behavior (e.g., pp. 103-104),
but does not notice that the benefits of protective actions could be delayed
similarly until an AA is completed. Oddly, except for a criticism of NRDCs
use of risk assessment to attack Alar (p. 242), OBrien seems unaware
that contending parties can shift their views of risk assessment depending
on whether they like the answers (for example, business seems uneasy about
quantitative analysis of "disparate adverse impacts" on minorities,
as part of "environmental justice" initiatives). Only two of
the defects OBrien lists for RA might not occur, or occur as often,
for AA: (1) the declaration that a given action will be "safe,"
and (2) the public inaccessibility of the debate over alternatives. But
I disagree that a safety determination is inherent to RA: reputable risk
assessors would argue that risk assessments greatest strength, and
its best use, is to determine relative, not absolute risk, and risk communication
researchers have long urged institutions to abandon such usually faulty
claims. Furthermore, the nature of policy debates almost guarantees that
participants in AA will make the same erroneous claim about their preferred
option. As for accessibility, she is probably correct, but this is hardly
an unmixed blessing, as I discuss below. In short, AA will be fraught
with the same technical flaws and strategic use of data and analytic techniques
that OBrien accuses RA of having or promoting. Curiously, she acknowledges
several times in the book that RA--supposedly fatally flawed, technically
and morally--is in fact a part of the analysis required for AA (pp. 129,
172, 177-178, 236), as long as multiple rather than single options are
covered. (Her book would be a lot more convincing to otherwise skeptical
audiences if she had dropped this false notion that RA can only be used
to analyze the risks of one option at a time.) That AA shares RAs
drawbacks is not critical, because I believe reviewing more than one option
will, on balance, be an improvement; but these drawbacks do reduce AAs
Overall, OBriens implicit thesis is that
more information is better, a semi-delusion nearly universal among analysts
and policy actors ("if they only had the facts citizens would agree
with our position" is a mantra Ive heard from all sides). For
example, she says that "[AA], like cost-benefit analysis, clarifies
choices among alternatives by evaluating consequences in a systematic
manner (Ashford and Caldart 1991).... What constitutes systematic
evaluation of these consequences, of course, is a judgment call"
(p. 143). As a researcher, in self-interest and ideologically, I must
agree to a point that more information is better. Strategically, she also
is probably correct, since the dimensions she seeks to add to analysis
will most likely favor activist over institutional positions. For example,
discussing recombinant bovine growth hormone for increasing milk production,
she mentions among other factors to consider "farmers personal
relationship to and enjoyment of farming, ...pesticide use, ...use of
public money, ... long-term condition of agricultural soils, and...water
quality" (p. 135). But the "more is better" thesis has
been attacked by decision theorists, political scientists, and others
for decades, since people neither can nor will use all available information
beyond a certain limit, nor use it in a "rational" manner (e.g.,
Lindblom 1959, Nisbett and Ross 1980, Kahneman and Tversky 1984). RAs
results, as limited as OBrien thinks the method to be, have been
criticized by decision-makers as being difficult to use (CRARM, 1997:85-92);
AA will be more challenging. She also argues that "[AA] forces the
decision maker to assume responsibility for choosing among various explicit
political and value tradeoffs" (p. 145). I agree that this is technically
easier with AA than RA, but both policymakers and ordinary citizens will
resist making any but the most banal tradeoffs explicit. Too many tradeoffs
are "taboo," and yet at some point (exactly which point is controversial)
society needs to make them, without paying much attention to the nasty
details (Fiske and Tetlock 1997).
The biggest problem raised by OBriens thesis
is one still unresolved by the environmental and policy communities at
large: what are proper decision-making roles for organizations and individuals
in a republican democracy? The "safety" decisions that OBrien
attributes to risk assessors and their organizational superiors are largely
determined by legislation and the conflict designed into the American
political system, just as the single-option analysis often is. Demand
for a simple "yes-no" decision partly reflects pressure from
interest groups, as she argues, but also reflects public wishes. Many
citizens simply want to know whether something is safe, and assume that
any amount of a chemical will cause harm (e.g., Kraus et al. 1992; Johnson
and Slovic 1998); claims that a given action is "least damaging"
of the available alternatives will not be acceptable to these citizens.
As a long-time proponent of a greater public voice in environmental decision-making,
I am sympathetic to OBriens concern that government and business
officials decide that certain risks are acceptable on behalf of "victims"
who disagree and do not believe they have delegated that decision to institutions
(p. 79). She makes some good arguments for more citizen involvement in
this book, and does even better in an exchange of views on the Citizen
Nature Project in two Oregon cities, of which she is a volunteer coordinator
(OBrien 2000). However, the apparently easy choice in favor of democracy
and self-determination is not that simple. For example, OBrien claims
She notes elsewhere that "[t]hose who reap the
monetary benefits are not necessarily those who pay the monetary costs"
(p. 142), but does not recognize the subsidy imposed without consent on
taxpayers and consumers elsewhere implied by local activists success
in getting extra wetlands cleanup. Implementing their own judgments of
acceptable risk means that non-locals might have to forego reducing their
own high-priority risks. Shifting burdens in this way is not by itself
illegitimate, but should entail at least implicit citizen consent through
votes for legislators who enact such policies. From whence does this consent
arise in the wetlands case? Without it, locals should tax themselves for
the extra desired cleanup, but this rarely happens. This problem of consent
and representation has challenged political science and practice for decades;
rhetorical assertions about democracy do not help. Certainly agencies
should limit themselves to claiming that an impact is "acceptable"
for public policy; I agree with OBrien that agencies should not
claim that the individuals who suffer that impact should believe that
it is acceptable to them. But that step will not resolve the deeper conundrum
of who deserves to choose the alternative that becomes public policy.
Dr. OBrien acknowledges that
I agree with this potential, even if I disagree with her on its magnitude or the obviousness of what counts as "better." I look forward to seeing the fruits of this campaign to widen our consideration of alternatives for maintaining and improving environmental quality.
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