CONCEPTUALIZING ENVIRONMENTAL PROBLEMS

ENVIRONMENTAL POLICY: BOUNDED RATIONALITY APPLIED TOUNBOUNDED ECOLOGICAL PROBLEMSStahrl W. Edmunds, University of California, Riverside

ABSTRACT

The interaction among myriad species and chemicals in the foodchain often yields potential outcomes which are difficult to foresee. Inpolicy terms, these interactions comprise an information load beyondhuman cognition, resulting in unexpected side effects. The clearestexamples are seen in the invasions of species and epidemics, air pollu-tion, toxic substances, and endangered species. The policy processattempts to deal with the information problem by using (1) an incre-mental approach, (2) a bounding approach, or (3) an uncertaintyapproach. Unfortunately, the bounding approach excludes all data oninteractions outside the apparent cause/effect hypothesis. Possibleapproaches to augment and improve environmental policy, beyond thebounding approach, are to inquire into uncertainties and side-effects,choose complex ecologies over simple ones, and sample for uncertainrisks by probability assessments.

Within the field of policy studies, the formulation of environ-mental and ecological policy is surely among the most complex of ana-lytical problems, if for no other reason than the sheer numbers in-volved. There are at least 300,000 known plants in the flora of theworld, and over one million fauna which have been identified, withhundreds of new kinds being discovered each year. Wtthtn eachphylum and spectes the vartations can run into the thousands. More-over, all of these life forms are interactive in a mutually interdepen-dent ecological regime which forms the food chain. The possible com-binations of interactions within this food chain, with millions of spe-cies, statistically runs into the billions. These statistical combina-tions can be reduced by dealing with ecological communities, but atthe risk of trade-off of losing track of unique or endangered species.

Against this staggering information problem of trying to recog-nize the significance of billions of interactions, the human mind has acapacity to apprehend and relate from two to five variables at a time. -̂Human beings attempt this apprehension by serial data processing,i.e. learning and memory. Unfortunately the reception and acquisi-tion (i.e. learning) rates for data are mtich slower than the trans-mission rates,2r3,4and the result is that the human mind copes withthe informatton overload by such cogntttve processes as filtering,chunking, abstracting, queuing, error, ommtssion, and escape. Fil-tering, chunking, and abstracting are data reduction processes whichmake information more manageable. Beyond these steps, further datareduction is often approached by two apparent remedies which pass forrattonaltty, but really compound the problem. These two remedies are:(I) to create an organization which multiplies (or multiplexes) thechannels or numbers of human receptors capable of receiving data, or

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(2) bounding the problem rationally by limiting the number of variablesto those which can be humanly comprehended.

Both of these remedial approaches are non-solutions because anoverwhelming proportion of data still escape, only to return with newproblems in different form. In the organizational approach, multi-plexing does increase the information load capacity, but also increasesthe abstracting and synthesis requirement to the point where the in-formation about the environment may no longer resemble reality; andit can be shown that organizations lose control of information and in-ternal coordination with the logarithm of their size.^

The bounding remedy suffers from a different kind of error: itpresumes to solve one problem by focusing on a few variables whileunknowingly creating others; hence each new solution becomes a newproblem which requires still another remedy. Frequently in ecologicalissues, the end result of these iterative fixes may be worse than theinitial condition. This paper focuses particularly on applying boundedrationality to environmental problems in the policy process. Illustra-tions will be given to show the unexpected result which emerged as newproblems, and sometimes as a worsened state in the form of damage toecological productivity. But before taking up the illustrative cases,let us try to make the preceding abstract statements about the poltcyproblem in the environment more concrete by eluctdattng what theproblem really ts.

WHAT THE PROBLEM IS. The problem ts that the natural order of theecology ts stable only in very compiex states, like the rain forests inSouth America or the prairie grass communities of the American Plains;but human activity to "manage" nature simplifies the complex states .into monocultures or simpler ecological regimes which are subject to"invasions" or population explosions of invading species.

Every now and then an unexpected environmental event occurswhich prompts us to seek out its causes. In recent decades, forexample, much of the Great Lakes fishery was destroyed by the sealamprey invading the Great Lakes via the shipping locks. The sealamprey, with no natural predators to limit its exploding population,decimated the abundant lake trout fishery within a few years.

Why latent species populations fiare into an explosion is notclearly known, except that (I) a new species invades a differentecology where its predators, or biological control, are not presentin sufficient variety or numbers to contain it in balance with otherspecies, and (2) a host species in the ecology becomes a food sourceto the invaders and Is eliminated. The environment becomes unstable.The cause is usually the deliberate or inadvertent transport by manof a species from one ecological regime to another. Examples of thesetransports and invasions are numerous: Dutch elm disease, the chest-nut blight, a fungus Endothia parasitica from China which destroyedmost of the sweet chestnut trees in the Eastern U.S.; the Europeanstarling, Sturnus vulgaris, whose numbers and droppings have posedhealth threats to smaller communities; cord-grass, Spartinatownsendii, from America which has invaded and clogged the tide-lands of both sides of the English Channel; the mitten crab from

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China which teams in European waterways; the Colorado potato beetle;which infested croplands of Eastern U.S. and Eurx>pe; the Japanesebeetle; the European spruce sawfiy which decimated forests tn Canadaand the U.S.; and the Itst goes on and on (see The Ecology of Inva-sions ^).

In response to these tnvastons, men seek to "solve" the problemby ridding themselves of the pests. A long-term study by entomolo-gists of Nova Scotia found successive waves of new pests; as theytr ied to control one, they inadvertently set off outbreaks of others.Spray used against apple scab was followed by an outbreak of theoystershell scale insect, Lepidosaphes ulmf; and spray against thisscale insect was followed by different scale insects. Then theysprayed to eliminate the codltn moth, only to be beset by hordes ofEuropean red mtte. What they were doing, of course, was kil l ing theenemies and parasites which had formerly kept each of these succes-sive outbreaks tn check.

The problem, then, ts that ecologies are stable only in a verycomplex state. When men create simple ecologies for food and l ivel i-hood, they create instability among species; and when they t r y tocontrol one species of unwanted invaders, they inadvertently releaseothers. Or simply, the information on ecological interactions is toooverwhelming for human cognition.

WHAT SOLUTIONS DO WE USE? These complexities in dealing with theenvironment do not, of course, deter men from t ry ing . The foodneeds of human populations require monoculture which lead people tomodify the environment to make a l iv ing. These simple, man-madeecologies invite invasions of species and damage which then requiregovernment regulations to protect the environment and human healthand to promote equity. The scientific method of relating cause toeffect makes policy makers presume they know what the consequenceswill be when they intercede by regulation, even though the ecologieshave few simple causes or stmple effects, in the sense of controlledexperiments in scientific methodology. Thus the regulators' processcan result in new expected side-effects. The chain of events leadsto an hubris in environmental policy, which would perhaps be harm-less if recognized for what it is; but environmental policy taken as"solutions" to problems can be self-deception.

The self-deception begins with limiting the scope of the environ-mental problems to something informationally and mentally manageable.Simon^ has called this "the principle of bounded rationality." Theprinciple says that the capacity of the human mind for formutattng andsolving complex problems is very small compared with the size andcomplexity of the problems whose solution is required for a reasonableapproximation of objective rationality in the real world. The principaipositive implication, says Simon of his model, is that we should beskeptical in postulating elaborate human mechanisms for choosingamong multiple goals, or diverse needs in a complex environment.The best we can do, where clues exist in the environment sufficientlyfrequently to suggest human survival and species balance, is to se-lect paths with a reasonable probability of achieving a need-satisfyinggoal. In other words, environmental decisions and policies are not

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predictive in the scientific sense, but are probaballstlc as to risk, un-certainty and side-effects. The only rule of thumb, which may behelpful tn policy making. Is to prefer a more complex natural ecologyto a simpler one in the outcome of a policy decision, at least when thatdistinction is possible. The reason ts that a more complex ecology wtllhave its own constraints and balances which wtll limit the emergence ofsurprise side-effects.

All too often, we do not look for the side-effects, uncertaintiesand risks in environmental policy because the prtnctple of boundedrattonaltty has implications for bureaucratic and organizational be-havtor whtch prevent such open-system tnquiry. Thompson^ hasshown that organizations function, achteve predlctabtltty and self-control by regulating or protecting their boundaries, which are basedupon assumed or known cause/effect relations of their mission andtheir goal. The presumed cause/effect relations become the basis oftheir decision process, their expertise, and their rationality for being;and this rationality becomes the domain, the limit, and the boundariesof their inquiry. When bureaucracies are faced with complex ecologiescontaining interactions. Information, species, phenomena, or risks be-yond their rationality (presumed cause/effect relations), the bureau-cracy will first select those phenomena and cause/effect relationswhich conform to their decision structure; and they will try to accountfor environmental behavior with the preconceived model. All else —the uncertainties, contingencies, side-effects, and unknowns — willtend to be isolated and set aside as outside the boundaries of thebureaucracy, i.e. as anomaiies to be dealt with separately or ignored.Thus organizations seek self-control by selecting variables whichcorrespond to their rationality and which affirm the need for their in-stitutional existence and maintenance. Inquiry becomes restricted tothe boundaries of their rational domain; and each piece of informationor task selected supports a monolithic authority network of centralizeddecision-making. That is, organizations seek to do what they knowhow to do and eschew the uncertainties.

Under these circumstances of bounded rationality, limited in-quiry, and organizational rigidity, environmental policy tends to takethree forms: (I) an incremental approach, (2) a bounding approach,and (3) an uncertainty approach. These three forms of decision pro-cess are dtsttnguished by the amount of information content believedto be available for the problem definition and solution. The incre-mental approach presumes a substantial information content in whichthe major causes or agents of the environmental impact are believedknown and in which one or a few significant effects have been ob-served and defined. The bounding approach acknowledges that theinformation content is partial in which several causes are hypothe-sized and enough effects have been observed to cause consternationas to probable damage to health or the ecology. The uncertaintyapproach has minimum information content in which the causes or in-teractions are not clearly identified and only a few effects are knownbut their significance is ambiguous. Each of these approaches will bediscussed and illustrated by brief cases which are, respectively: airpollution, toxtc substance control, and endangered species.

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THE INCREMENTAL APPROACH TO AIR POLLUTION CONTROL. Thetwo main forms of air pollution are sulfur dioxide from fossil fuel burn-ing stationary sources, and photochemical smog orlgtnattng in automo-bile emissions. Auto emissions are acted upon photochemlcally in theatmosphere by sunlight to disassociate a single atom of oxygen, calledthe singlet of oxygen, ozone, or oxidant. The singlet of oxygen is ahighiy reactive element which seeks to recombtne with another mole-cule; and this recombtnant oxygen has an "oxtdtztng" effect, not un-like rust on tron. The oxldant's effect on a tender lettuce leaf is toscar it into a brown scale; and it has similar effects on other plants,often causing losses of yield of up to thirty percent of some crops likecttrus and grapes. The effect of oxtdant on human lung tissue issimilar scarring, thickening, or aging of the cell, which leads to com-plications for those with respiratory problems like asthma, bronchitis,pneumonia, or emphysema.

The first environmental poiicy step to control photochemicalsmog was taken in California in the mid-196O's by trying to reduce oneof the emissions, hydrocarbons, first by crankcase control devicesand secondly by requirtng automobtle manufacturers to change thecompression and atr fuel rations tn the cylinders. At that ttme the ob-served effect was the adverse reactton of hydrocarbons in the atmos-phere on plant and human tissue. The cause was presumed to be theincomplete combustion of hydrocarbons in gasoline vapor as the fiame-front within an automobile cylinder was damped by the cooler tempera-ture of the cylinder wall. The incremental solution was a technicalchange in compression and air-fuel ratios to reduce the unburnedhydrocarbons in the combustion process.

What the environmental p>olicy makers did not know was the sideeffect, which is that the nitrogen oxides have a different emission dis-tribution, in relation to compression ratios, than hydrocarbons. Theresult of the envornmental policy solution was that hydrocarbonemissions were indeed decreased, but unexpectedly the nitrogenoxides were significantly increased, whtch was worse because theycreated even more oxtdants. That meant next that envtronmentalpoltcy had to control. Incrementally, nitrogen oxtde emtsstons, whtchwas eventually cfc>ne by the catalytic afterburner. However, now ttappears that the catalytic afterburner may Increase the emtsston ofheavy metal particles and of sulfur dtoxtde.

In the meantime, standards have been set for five major emts-stons: hydrocarbons, nttrogen oxtdes, carbon monoxtde, sulfurdtoxtde, and oxtdants. These are all monitored atmosphertcally, alongwtth parttculates originating from dust, by instruments which measurein parts per million the degree of control being achteved. ̂ On thtsbasts, then, envtronmental control bureaucracies report progress overthe past decade tn reductng air pollution.

However, there are still some side-effects and uncertainties.One is the recent discovery that diesei emissions may form carcino-genic compounds tn the atmosphere. Another is that particulates areincreasing, from road-dust, industrial emissions, or natural causes;and parttculates wtth motsture form the stte for more acttve photo-chemtcal reactions. Hovering in the background is the fact that an

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automobile tailpipe emits about a dozen primary compunds capable ofabout eighty plK>tochemical reactions, of which only six are regularlymonitored, controlled, or researched. Among the risks and uncertain-ties, which are unknown, is the emission of aldehydes, capable offorming formaldehyde, whtch ts a protein-seeking recombinant.

Legislatures now often view the air pollution problem as on theway to being solved and these solutions are defended and justifiedwithin the boundaries and domain of the Environmental ProtectionAgency and the many air pollution districts. With these boundary-keeping agencies at work, the progress toward improved air quality isfelt to be significant, justifying their decision processes as adequatesolutions to the pollution problem. The problem appears to have beensolved incrementally; then we experience new surprises, such as thefact that in 1979 Los Angeles had the worst air pollution episode in adecade.

THE BOUNDING APPROACH TO TOXIC SUBSTANCE CONTROL. Toxicsubstance control is in a more formative stage than air pollution con-trol because the extent of the problem and its solutions are not asclearly known. What is known is that there are 3i million known chem-icals, of which 25,000 are in significant production, and about 700 newchemicals appear on the market each year. Of these, only 6,000 havebeen tested for carcinogenicity. Yet medical authorities believe thatfrom 60% to 80% of all cancers are environmentally induced. ̂ ^ Thesefacts caused Congress to pass the Toxic Substance Control Act of1976 and to charge the Environmental Protection Agency wtth imple-mentation.

Where, in this large universe of chemicals and their inter-actions, should EPA start? The agency is faced with the classic in-formation problem. Thousands of chemicals interact with a food chain,comprised of millions of species, to yield statistically billions of pos-sible combinations. The number of combinations has to be reduced tohuman scale and the scope of the human mind. Congress providedguidelines for this reductionism, i.e., bounding the problem. Theseguidelines are to identify and categorize ail suspect chemical com-pounds based upon past carcinogenicity tests and theory as to chemi-cal properties causing cancer, to require industry to report produc-tion volumes and testing experience on those suspect categories, totest all new chemicals coming into use in the suspect classes, to l i -cense those that are found by testing to be hazardous, and to controlthe distribution and use of those judged to be toxic. In this process,EPA has listed 90 compounds in 16 structural classes suspected ofbeing carcinogens based upon past testing experience and medicalopinion. This is the beginning list for iaounding the probiem and ispresumed to contain ali of the dangerous chemical classes known atthis time. Other chemicals beyond this list may have toxic effectswhich as yet are unobserved or unknown. Presumably they have areasonable probability of being discovered as the bounding problemcontinues by new tests, by the development of new chemistry theory,and by monitoring mortality. For the suspected chemicals, EPA istrying to institute a simple, rapid testing procedure to screen thelarge array of possible carcinogens.

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EPA seeks to respond to critics by expediting the screening andtesting process. This is based upon new scientific theory whtch hy-pothestzes that most cancers are formed, not by the toxtc chemicalttsetf, but by tts metabolite, whtch ts the reacttve form of the chemtcaltn the btologtcal metabolism of the body. These cancer-causing metab-olites have a common characteristic of electrophiiicity, that is, they areelectron deficient; and their electrophilictty ts what tnttiates the car-cinogenic process. Therefore, the screening of potentially hazardouschemicals proceeds on the assumption that electrophiiicity of the metab-olite is cause for the chemical to be on a suspect list.

Suspect chemicals may then be tested in live organisms to ascer-tain whether they are carctnogentc or not. The tradtttonal chemicaltest has been a two year, two species, two sex chronic animal expo-sure test with Increasing dose rates. Such tests cost from $200,000to $400,000. EPA is trying to short-cut the time and cost in tradi-tional tests by a new procedure known as the Ames tissue test, inwhich the metabolite is placed in a tissue culture. The tissue teststake one to two weeks, cost less than $10,000, and are 90 percentreliable.

The chemical industry is protesting, as might be expected, thatthe testing and control procedure will be costly, unweildiy, slow, un-workable, and raise the price of chemicals. Independent studiessuggest that the overali price increase in chemicals to consumers willbe small, about one percent, but prices for individual chemicals maybe as high as 25%. Also the export of chemicals in foreign trade maybe reduced by 25%. These are, of course, grave consequences. ̂ °

By the reductionism, then, of inventory, classification, elec-trophiiicity, and tissue tests, EPA hopes to narrow the range ofchemical interactions from its billions of potential combinations to afew dozen or score of controlled toxic substances. Then the toxicsubstance control problem will become bounded, as the air pollutionproblem aiready is; and EPA can proceed to controi toxic sub-stances by the incremental approach, probably wtth useful results.All the rest of us have to worry about ts: (a) are there theoreti-cal causes for cancer other than electrophiiicity?, (b) is a 90 per-cent reliable tissue test good enough? and (3) are there otherthings we do not know about the potential intereactions of 3imillion chemicals with I I million species? In other words, in ascomplex a set of interactions as ecological biochemistry, how do weever know what information is pertinent or sufficient, except per-haps by the experience of dying? ^^ Here is where the environ-mental poiicy study of toxic substance control becomes unhinged fromair pollution control, because the former is dealing with death andmortality while the later mainly with morbidity (except for the old,infirm, or those wtth resptratory dtseases). The politics of deathsharpens the issue and can be terminal for poiitical actors as well asthe victims, whereas the politics of morbidity tends toward a newremedy and convalescence.

THE UNCERTAINTY APPROACH WITH RESPECT TO ENDANGEREDSPECIES" Environmentai policy with respect to endangered speciesis on even more tenuous footing than toxic substance control. The

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human encroachment on wild life habitat is so rapid that most largemammals may become extinct in the wild by the turn of the century,except for those preserved in wild animal parks. This gradual realiz-ation has caused the visible and observable species to be placed uponendangered species list for special protection, along wtth a few rareand exotic spectes that are known to extst only tn a specific spot, suchas the desert pup fish. One approach to endangered species is tomaintain counts of minimum numbers of breeding pairs and to protecttheir habitat, or transfer them to more secure areas. This has beendone with whooping cranes, California Condors, whales, etc.

Endangered species lists are often symptomatic of broad envir-onmental impacts adversely affecting an ecological regime, in whichthe damage may extend to other species as well. For example, theAmerican bald eagle has been dimtntshing in numbers for many years,partly due to illegal hunting, and partly to shrinking ranges of remoteland where the eagle's food supply exists. Eagles are predators atthe extremity of the food chain where pollution concentrations becomethe highest. Eagles feed in part on fish, and fish concentrate thepollutants found in water. Some fish and shell fish are known to ab-sorb I part of mineral or pollutant in 70,000 parts of fiuid throughtheir digestion or respiration. Eagles, feeding on fish, have beenfound in remote ranges with high concentrations of DDT, PCB, andother industrial or agricultural pollutants in their blood streams orfatty tissue. Peregrine falcons in North America have all but dis-appeared, due either to destruction of their food supply or to pollu-tion. Pelicans came near extinction on the West Coast as their popula-tion was reduced to a few dozen nesting pairs, due to the destructiveeffect of PCB on the lime in their eggshells. The weakened eggscollapsed under the weight of parents warming them for hatching, andthe offspring were crushed. Pelicans, like eagles, acquired the PCBpollutants from thetr dtet of ftsh. The endangerment of these preda-tory btrd spectes ts the stgnal of a stgntficant damage to the foodchain, tn whtch many other species and interactions — not yetobserved — may be in peril. Human beings, also carnivores atthe extremity of the food chain, are found to have substantial con-centrations of these same pollutants in their tissue.

What can be done in environmental situations where a few ob-servations provide clues to potential damages, but neither the extentof the risk nor the causes and interactions are known? One obviousapproach is to increase the number of observations as a means to ex-tend the data base. This can be done by taking the habitat of theendangered species, like the eagle, and try to trace the interactionssequentially in its food chain, as weil as in reiated or affected spe-cies. This amounts to fairly costly research, because the wholeecological regime of the eagle, for example, needs to be studied to besure that the interactions are understood; and then this whole infor-mation set and model has to be replicated for other species — falcons,pelicans, humans, etc. That is, we are in search of enough observa-tions and information to begin to bound the problem. We are lookingfor the suspect categories of ecological damage. If these can befound, together with sources or potential causes, we can try tobound the problem as in the toxic substance exampie.

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The protection of endanged spectes ts undoubtedly a bene-ficial and conscience-satisfying step to take. Yet It affects only a fewhundred of the more obvious spectes. What of the less vtstble species,including plants and micro-organisms little known to us? Some may bevery crucial to our lives, as is the bacteria Rhizobia which fixes nitro-gen in the soil at plant roots — without which we would be withoutplant protein and many essential foods. What are all the interactionsof our pesticides^, chemicals, and alterations upon the survival ofRhizobia? What is known in this area is smsl! compared with the com-plexities of the entire ecolgqical interactions.

Endangered species lists do not even attempt to bound the prob-lem. They merely list clues as to what the problem may be. Theproblem is basically inadequate observation and information in largesegments of the ecology.

CONCLUSION. If ali this discussion leaves one very uncertain as tohow to proceed in environmental policy, that is what it is supposed todo. Environmental policy is a very uncertain area, at best, becausethe ecological interactions are myriad, beyond human cognttton. Butthat, of course, ts a negattve conclusion. What can be said postttvelyabout approaches to envtronmental poltcy?

Ftrst, envtronmental poltcy dectstons should prefer the mostcomplex ecological system to the simpler, because complex natureecologies as we have seen are the more stable due to their own con-straints, balance, and biological control. This amounts to alwayspreferring a natural ecological regime or adjustment to a man-madeintervention. In practice, this also means maintaining as much wild-land resources as possible. This is more practicable than might beimagined. For example, Elton^ points out that, in a small countrylike England, there are 190,000 miles of roadway and 1,500 miles ofcanal which can and are being maintained in hedgerow and meadowverge plant communities. These are the most complex and variabiehabitats in the country. In the much larger United States with itshuge road systems, rail right-of-ways, national parks, mountains,and greenbelts, the conservation of climax forests, natural savannah,and a few native prairie grass communities may stiil not be too late.By conservancy, we preserve not only stability in the ecology but agene-pool of incalculable importance to the future.

Secondly, always inquire into the unexpected instead of theexpected in environmental policy. That will at least keep uppermostin mind the high risks, uncertainties, and side-effects in poltcy mak-ing; and tt may even blunt hubris with a little humility that solutionsare not likely to be solutions but new problems.

Thirdly, in a few cases we might try a holistic approach toassessing the probability of risk, rather than bounding the problemprematurely by presuming simple causes. In the toxic substancecase, for example, some cursory assessment of a sample of non-sus-pect chemicals might be attempted, rather than wait for unexpectedevidence of toxicity. How to make this assessment is boggling, tobe sure, because we do not even have a methodology to do it. Theclosest is the theory of infinite, two-party games where one party is

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a passive opponent wtth unlimited and uncertain options. Unfortunate-ly, tnfintte strategy games have no mathemattcal solution, even if onehad the data. If preliminary probabitity data can be generated onvarious interactions, the random search or Monte Carlo method of stm-ulation may possibly be a useful methodology. Thts would presumeenough sctenttfic effort to develop a data base, for example, on theprobable carctnogentcity of a random sample of the nonsuspect chemi-cal universe. These probabilities could then be used in random searchto locate Itkely intersections between chemical groups and toxicity.The procedure would be more costly than at present because it woutdaugment the present bounding approach; and it may yield little orno results. But when mortality is at issue, precautions to improvethe environmental decision process any way we can may be warranted.

In summary, then, our greatest hope in improving environmentalpolicy is humiiity, inquiry into uncertainties and side effects, choosingcompiex ecologies over simple, and sampling for uncertain risks byprobability assessments. None of these approaches is very satisfyingto a rationally-minded world, but they are better than what we aredoing. Meantime, of course, we will have to continue with the incre-mental, bounding, and uncertainty approaches to environmentalpolicy, knowing they should be augmented by the risk-minimizingattitudes and techniques suggested above.

NOTES

1. Walter Henry, "Individual Differences in Information Process-ing Ability and its Affect on Processing Accuracy," Journal of Con-sumer Research, forthcoming.

2. James Miller, Living Systems (McGraw-Hill, 1978), 123-69,esp. 157-61.

3. Herbert Simon, "How Big is a Chunk," 183 Science 482-488.

4. J . Brener, 26 Journal of Experimental Psychology 467 (1940).

5. Stahrl Edmunds, "Factors Affecting the Stability, Qualityand Response in Large Scale Human Organizations," Proceedings,General Systems Research Society, London (August, 1979).

6. Charles Elton, The Ecology of Invasions of Plants andAnimals (Chapman Hall, 1958), esp. 15-32, 50-74, 146-159..

7. Herbert Simon, Models of a Man (John Wiley & Sons, 1957),esp. 198 and 267-73.

8. James Thompson, Organizations in Action (McGraw-Hill,1967), 70-82, 159-163.

9. Paul Portney ( ed . ) , U.S. Environmental Policy (JohnsHopkins University Press, 1978), 73-101, 105-43.

10. Stahrl Edmunds, "The Economics of Toxic Substance Con-trol, " 3 Journal of Ecotoxicology and Environmental Sa:fety 101-10(1979).

11. Stahrl Edmunds, Environmental Administration (McGraw-Hill, 1973).

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12. Robert Cahn, Footprints on the Planet (Universe Books,1978).

13. William Thomas, Indicators of Environmental Quality (PlenumPress, 1972).

14. U.S. Senate Hearings (1969) Subcommittee on Environment ofthe Committee on Commerce, "Toxic Substance Control Act," 94th Con-gress, 1st Sesssion on S776, Serial 94-24, Part I , p . 225, U.S. Govern-ment Printing Office, Washington, D.C.

VALUES ANALYSIS IN ENVIRONMENTAL POLICYRichard N.L. Andrews, The University of Michigan

ABSTRACT

The consideration of values in environmental policy decisionsrequires attention not only to substantive matters of environmentalquality, but also to balancing such broader social values as science,democracy and authority. Current methods for values analysis canbe grouped according to their relative emphasis among these valuesin order to better illuminate the implications of adopting such methods.

What values should be considered in environmental poiicy de-cisions, and how may they most acceptably be acknowledged andtraded off? Some of the values in question are substantive mattersof environmental quality: should there be cleaner air or cheaperetectrtctty, habttat protectton or tmpoundments, farmland or stripmtnes? Equatly at stake, however, and tntertwtned wtth the envtron-mental tssues, are fundamental societal values concerntng propertyand governance: who has the rtght to alter environmental conditions,who decides such rights, and what criteria and information provide alegitimate basis for such decisions?

The relevant differences among methods of answering thesequestions are not simple choices among labels and display formats,nor even among alternative academic disciplines and theories. Theyare, rather, choices among philosophies of governance; and morespecifically, among the relative values of science, democracy, andauthority in reaching publtc dectstons. The thests of thts paper tsthat currently prominent methods of values analysts can usefully begrouped according to their relative emphasis among these three majorclasses of values; and that the generic differences among thesegroups of methods, therefore, are at least as important in choicesamong them as are the differences between particular methods with-in a genre. An important issue for further study and innovation ishow these genres can be combined in practice so that each servesto reinforce the strengths and check the flaws of the others.

ENVIRONMENTAL VALUES IN PUBLIC DECIStONS. Vatues anatystsprocedures appear to fall into three primary genres, or tradtttons,

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