Sunday, February 26, 2012

Myth: The CAOs Scientifically Address Ecological Risk

One of the most difficult concepts for many people to grasp is the concept of environmental risk.  For an excellent quick read about environmental risk, peruse this speech given by Ruckelshaus in 1984 at Princeton. Risk is a calculation, and I mean that literally, not figuratively. Risk is an actual number.  Risk is a quantitative measure of the probability of something occurring. For example, you may have a one-in-a-million chance of getting cancer if you are exposed to a certain chemical. Or, there may be a de minimis ecological risk if the hazard index is less than 1.

If your eyes are already starting to glaze over, I suppose I have made my point. Risk is complicated stuff; it is mathematical, probabilistic, and very very scientific. If you don't have a number, you ain't talking risk. You may be talking about someone's perception of risk or fear of the unknown, but you're not talking risk unless you're talking numbers.

When the Council, County staff, and the consultants say that they have developed high, medium, or low-risk scenarios for wetlands and the CAOs, don't buy it. They didn't run the numbers.  In fact, they refused to run the numbers. They can't tell you what quantitative risk level is associated with their high, medium, or low scenarios. Without that, they can't tell you how much risk reduction you get per foot of buffer.

Are you following?  They don't know what risk is present in the environment in the first place because they didn't run the numbers. They can't tell you how much risk reduction the proposed buffers will buy because they didn't run the numbers. This isn't science. The buffer calculator that they have developed is akin to levers that are not connected to anything.  It's all guesswork.

The mantra that you will hear, especially from some members of the Council, is that our current buffers and wetland rules are not based on science, but our shiny new proposed rules are.  Rubbish. Despite spending a bundle on our new rules, they are not based on science either, and they are certainly not based on risk. They are based upon the policy opinions and assumptions of a select few, and in fact, many involved in the development of the new CAOs frequently advocate for eliminating nearly all "risk" no matter how small.

As Ruckelshaus points out in his speech, the ultimate goal of having a rational conversation about risk is to get people to understand the difference between living in a safe world and a risk-free world.  I don't think the proponents of the new CAO rules, including the Council and staff, understand that yet.

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