ENVIRONMENTAL DECISION-MAKING AND RISK ASSESSMENT

Many of our friends living in cities have a small box of tools in a closet. That box contains the hammer, screwdriver and pliers that they need to fix a sink or put together the computer desk they ordered in a catalogue. One of us (Carolyn) lives on a farm. There are entire barns and quonset huts filled with the tools necessary to work the 3100 acres that comprise this farm. We need those tools to shoe horses, till fields, repair fences and trucks.

It is in the spirit of searching for the right tools for the task that we offer the ideas in this paper: if we want to live in a sustainable world, what environmental decision-making tools can we design or find?

Robert Constanza has said that "[d]efining sustainability is actually quite easy: a sustainable system is one that survives for some specified (non-infinite) time. The problem is that one knows one has a sustainable system only after the fact. Thus, what usually pass for definitions of sustainability are actually predictions of what set of conditions will actually lead to a sustainable system." Wes Jackson adds another axis to Constanza's dimension of time when he says that "[s]ustainability is a spatial-temporal concept."

¥ do not generate pollution any faster than earth's planetary sinks can absorb, dissipate or disperse it.

Environmental regulation is, theoretically, trying to ensure that ecosystems are sustainable and that we protect public health. Since we can not define sustainability (or health, for that matter) we must use the best scientific predictions of the outcome of altering biological or physical systems and then regulate on that basis.

Until now, the best environmental science available has been funneled into risk assessment. The key scientists involved have been toxicologists, chemists and statisticians. Risk assessment has allowed us to predict some outcomes, particularly cancer, when introducing new elements into the environment. It has also helped prioritize what we should clean up first in the case of Superfund sites and some of the large messes created by the Department of Energy. It has not proven, however, to be failsafe.

The reason risk assessment has not been failsafe is that it asks if the possibility of damage to the environment and public health is sufficiently large to warrant government intervention. Paraphrased, risk assessment and risk characterization ask "what can we get away with? How elastic is the environment? How much harm can we tolerate" Whether damage is sufficiently large to regulate is a matter of judgment and ethics, not a matter of science. For the most part, we manage risk rather than act on the precautionary principle and prevent risk.

For example, we have an extensive amount of information about the harm lead, CFCs or DDT causes. But we have never outright banned all manufacture and uses of lead, CFCs or DDT. No matter how much we know about the risks attending a process, chemical or technology, no matter how many fatalities or biospheric disruption might be caused, we do not ban them.

The industrial model is constructed on the presumption that nature functions like a machine and that humanity's role is to force nature's gears. It uses the metaphor of the Model T Ford Factory that makes mass-produced commodities.5 Competition is the primary economic and scientific process in the industrial model: species compete in an ecology and nations compete through their corporations in the global market.

For many, it is difficult to see how we might clothe, feed and shelter ourselves without dominating nature. And for farmers and others who produce our food, it does seem as if the only way to feed the world is to conquer and subdue nature for the benefit of an increasing population of humans - to mass-produce a homogeneous commodity. This kind of production ethic is in fact an ethic: it is a definition of what is good.

3) The economy is not related to the environment except for the benefits to the environment achieved through competing in the free market.

5) Regulation is based on certainty with actions taken on the known, ignoring the unknown.

By some measurements, the industrial model has had incredible successes. It has provided an array of technologies and large financial returns for medicine, agriculture, and information. But it has also caused unexpected and widespread damage to the environmental and public health.6 We are all aware of the litany of environmental problems that include radioactive waste, holes in the ozone layer, endocrine disruption and global warming.

We would submit that risk assessment is the dominant environmental decision-making tool in an industrial model of the world. Because this model favors global economic competitiveness, risk assessment isn't very successful as a tool to protect ecological integrity and public health. While it may be a useful tool for predicting cancer, it is an inept and blunt instrument for novel, cutting-edge technologies or for technologies and processes that have large geographical and temporal reaches. Risk assessments cannot adequately address biospheric implications of chemical mixtures, or new genetically engineered organisms released into the environment, much less global level contaminants. By ignoring the consequences of using the industrial model and risk assessment, we have hot-wired the environment and tried to bypass the rigorous controls nature employs.7

We doubt that other tools exist within the industrial model that could help prevent this kind of damage. However, an alternative model of the world may provide decision-making tools that serve as a tool, not of commerce, but of biology and life. So we ask the single question: are there other environmental decision-making tools than the twin tools of risk assessment and cost benefit analysis that would better create the conditions for sustainability? What would that model and those tools look like?

We would propose that a biosystems model of the world is an alternative model for providing regulators with decision-making tools that could protect the environment and public health. A biosystems model sees a different role for humanity than one of dominating nature--that of the participant. A biosystems model of the world uses natural systems with their complex, mutually dependent parts, rather than the machine, as its instruction guide.

We acknowledge that environmentalists have sometimes adopted a stance that seems to prohibit all production because they wanted to preserve wilderness, and endangered species as well as prevent technologies like incinerators. Paul Thompson, in his brilliant book The Spirit of the Soil, calls this a preservationist critique but not an ethic of production: it does not tell us how humans can live in the environment and provide for basic needs.8 In a biosystems model, humans are part of, and dependent on, the web of life instead of dominating it. But there is still room in this model to provide food and clothing for humanity. It will, however require a different ethic than one of producing as much as possible despite the cost or an ethic which excludes humans from the environment.

We propose the following parameters of a biosystems model for purposes of policy and regulation:

3) Ecological relationships between species should not be disturbed over large geographies or large time spans.

4) The economy is a subset of the ecological system. It is neither coterminous nor independent.

Creating a standard by which we measure the introduction of a novel technology, chemical, force or process could guide analysis for regulation. Here are three formulations of such a standard.

William McDonough proposes that "everything that is received from the earth can be freely given back without causing harm to any living

Aldo Leopold said, "[a] thing is right when it tends to preserve the integrity, stability and beauty of the biotic community. It is wrong if it tends otherwise."10

Wes Jackson furthers these notions when he says, "...that nutrient cycles must be closed; that if we introduce into the environment chemicals with which we have not evolved, we must regard them as guilty until proven innocent; that fossil fuels are finite...that all parts are important to the whole and to other parts."11

We suggest that there are some important environmental decision-making tools arising out of a biosystems model that would help us meet an ecological standard and further the possibility that we might live in a sustainable world.

The standards give us some parameters to consider when designing tools for environmental decision-making: time, energy flows, space and the relationship between economics and ecology. We will pose a set of decision-making tools after the discussion of each of these parameters.

Constanza defines sustainability as a system that has survived for a specified amount of time. The question is, what time frame is appropriate for sustainability?

We note that risk assessment has used very short time frames to determine potential harm for three reasons:

1) Risk assessment uses the very short time frame of business rather than biology (consider the speed at which the stockmarket changes).

2) Risk assessment typically focuses on an individual organism rather than on a population, ecosystem, or the biosphere.

Evolutionary biology can give us some clues for time frames that might work for analysis and regulation. Consider the four time frames E.O. Wilson describes: biochemical time, organismic time, ecological time, and evolutionary time.12 If we are truly interested in sustainability we must expand our time frames to at least ecological time, if not evolutionary time because the consequences of introducing a new chemical or technology into the environment can rarely be observed in biochemical or even organismic time. Endocrine disruption and the appearance of damage in later generations demonstrates the need to expand our time frame.

Expanding our time frame has two implications: the first is that to adequately assess the consequences of introducing some new technology, chemical or process into the environment we need to understand the kind of change that will take place over decades if not centuries. And second, not only do we need to know what kind of change will take place, and how change will take place, but the rate at which change that will take place. Is the rate of change something that is natural in a system? This is a key question for a technology like genetic engineering which dramatically speeds up the rate and kind of change and thus has the capacity, ultimately, to destabilize entire systems.

3) Does this accelerate the rate of change beyond the rest of the system's ability to adapt?

Evolutionary biology and economics, both have developed some tools to track energy flows. Wes Jackson, for instance, has argued that we need to understand the relationship of the photosynthesizers to the concentrators (eg. cows and humans) and that we need to use current energy sources rather than fossil fuels.

Following that kind of logic, Herman Daly suggests that we can measure energy in terms of available stock and flow over time. Hence, solar energy is stock-abundant but flow-limited whereas terrestrial sources of energy are stock-limited but flow-abundant. Peasant societies lived off solar flow whereas industrial societies depend on the limited terrestrial stocks. 13

Some technologies have the capacity to significantly alter energy flows. Rbgh, the recombinant bovine growth hormone which was engineered to increase milk production is an example of a technology which increases the energy flow in a system: cows eat more, produce more milk and more waste.

Mario Giampietro argues that an analysis of relationships can occur on three levels: the individual, the societal and the biospheric.14 He argues that if we are interested in sustainability we have to at least consider the societal impacts, if not the biospheric implications of a new technology. Risk assessment has focused on the individual impacts and through ecorisk assessment is only beginning now to think in terms of communities and populations of species.

The spatial boundaries for analysis are key: looking only at an individual or single species in a laboratory or single field setting will obscure the key patterns instigated by introduction of a novel organism, chemical or technology. As Richard Levins and Richard Lewontin have argued we must examine the relationship between the part and the whole, acknowledging that the part influences the whole and the whole influences the part.15

Providing for humanity's needs is ultimately an economic endeavor in the present world. It is not possible to assess ecological and public health impacts without measuring the relationship of economics to the ecology. In another one of his graphic descriptions, Wes Jackson says that "[I]f we must as a future necessity recycle essentially all materials and run on sunlight, then our future will depend on accounting as the most important and interesting discipline. Because accountants are students of boundaries, we are talking about educating a generation of students who will know how to set up the books for their ecological community accounting, to use three-dimensional spreadsheets."16

In Herman Daly's new book he says that today's emerging economic paradigm "begins with physical parameters....and inquires how the nonphysical variables of technology, preferences, distribution, and lifestyles can be brought into feasible and just equilibrium with the complex biophysical system of which we are a part."17 The reason the economy is central to environmental decision-making is that the "economy, in its physical dimensions, is an open subsystem of our finite and closed ecosystem, which is both the supplier of its low-entropy raw materials and the recipient of its high-entropy wastes."18 The ecosystem acts as a host for the economy.19

Regulation must moderate the throughputs and the outputs because ecological sustainability is not guaranteed by market forces.

9. Does this technology, chemical, force or process generate an end or side product or waste that can be given back to the earth without causing harm to a living system?

Risk assessment coupled with cost-benefit analysis and peer review has been associated with sound science under the industrial model in the political world of the early 1990's. By emphasizing certainty, causality and cancer, risk assessment has ignored patterns of interactions and consequences of technological inventions. Theo Colborn's great genius was in seeing the patterns that were not cancer - and discerning a whole taxonomy of problems that fell under the rubric of endocrine disruption.20 We advocate a traditional notion of science which is pattern recognition. The great astronomers and mathematicians sought patterns and then explanations for patterns rather than a linear, repetition which simply evidenced causality. Breakthroughs in the Kuhnian sense of paradigm shifts have been through recognitions of patterns and relationships.

Patterns of disease and environmental disruption must be accounted for by scientists and regulators. It is no longer enough to say that a cancer cluster is just a fluke. Its time regulators included other disciplines in the process. Different patterns will be discernible to evolutionary biologists then are discernible and measureable by toxicologists and statisticians.

We would invite policy makers to consider the questions science must address, how they must be addressed and who must address them if we are going to have a sustainable future. We would submit that the decision-making tools posed here, in the hands of scientists trained in life sciences, could serve as an alternative to the failed industrial model of the world and its servant risk assessment. These are just a start. We invite dialogue around these important issues.

Of all the things with the name Winona LaDuke on them I found in 1996, this CD is my favorite. I met Winona at the Green Party Nomianating Convention in Denver at the end of June, 2000. When I gave her my little speech, she said "it's important that you are doing that."