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Environmental Science, Policy, and Management
Why risk assessment is flawed beyond the point of acceptability and how we fix it
In the wake of America’s election, the scientific community and its allies have expressed grave concern over the new administration’s disregard for the environment. Less sensationalized, but perhaps more relevant, are the science-policy interface’s fatal methodological flaws, which have been reinforced and reproduced for decades. While research extends legitimacy to proposals and provides insight about issues and solutions, it can also instill in policymakers a dangerous comfort with risk and unknowns. When research leaves questions unanswered—as it often does—policymakers are reliant upon scientists’ and economists’ calculations of the incalculable; estimates regarding acceptable levels of risk are taken at face value and weighed against the benefits of the policy at hand (classic risk analysis within cost-benefit analysis). I will argue that this approach to incorporating research results into regulatory policymaking is not only malicious, but also perpetuates a short-sighted environmental ethical framework. An alternative approach to environmental regulatory policymaking must be taken using an ecofeminist framework.
First, using risk analysis to justify risking environmental health is malicious. Risk analysis, praised as objective and truthful, never explicitly characterizes the risk-taker, when in reality those subject to the most health risk factors are those with the least financial—and, consequently, political—capital. Risk analysis—a process which excludes the voices of poor communities—posits certain landscapes and populations as disposable, all in the name of technically or financially progressing others. Cost-benefit analysis conducted as a precursor to the creation of devices which will end up as e-waste, for example, characterizes the “cost” or negative externality of toxic waste processing as distant and worth the environmental risk. This logic is exemplified in a 1991 memo from the former Chief Economist at the World Bank, Lawrence Summers. He states:
“The measurements of the costs of health impairing pollution depend  on the foregone earnings from increased morbidity and mortality. From this point of view a given amount of health impairing pollution should be done in the country with the lowest cost, which will be the country with the lowest wages. The economic logic behind dumping a load of toxic waste in the lowest wage country is impeccable… The demand for a clean environment for aesthetic and health reasons is likely to have very high income elasticity.”
By rationalizing selectively compromising certain populations’ health, governments and researchers are mutually responsible for explicitly discriminating against populations with the least resources—poor populations which oftentimes intersect populations of color. Brazil’s former Secretary of Environment echoed critique in response to Summers’ memo, saying “[such] reasoning is perfectly logical but totally insane”, and that it demonstrated “the arrogant ignorance of many conventional 'economists'”. For many parts of the global south, this insanity is a reality, wherein industrial production and waste processing are concentrated, and negative health impacts are experienced firsthand at a disproportionately high rate.
Next, monetizing the potential losses we face by vandalizing nature during risk analysis is a facet of a short-sighted environmental ethical framework. Valuing nature and its conservation only to the extent that it is useful to humankind risks disrupting relationships in nature that we are yet to even understand. By isolating certain natural entities to conserve based on cost-benefit analysis, we fail to acknowledge nature’s interconnectedness and interdependence (see Commoner’s “four laws of ecology”). Ecofeminist environmental ethics offer an alternative, prioritizing the preservation of natural entities on the basis off not only their intrinsic value, but also their functional value within a larger system of relationships which comprise an organismal Earth. Under this frame of ethics, risking certain portions of the environmental for the sake of others becomes a non-option, and the systemic functionality of the Earth is prioritized, even if it is not yet widely understood. Ecofeminist environmental ethics align well with classic conceptions of the precautionary principle, which dictate that any risk of harm, rather than proof of harm, should act as the stimulus for action. The only way to uphold the precautionary principle as well as ecofeminist environmental ethics is to strive to understand how each portion of the Earth impacts others before taking actions which may compromise the integrity of the system—something that will require an immense campaign towards regulatory policymaking reform.
As a reflection of our values and priorities, the ethical framework we employ to make policy decisions needs to be re-evaluated and replaced with one that is holistic, preserves accountability, and ensures precautionary approaches to co-development with the environment. Only then can regulation become truly solvent, rather than yet another perpetuator of destruction, classism, and racism in the Trump era.