Ecologists Question Cost-Benefit Scrutiny

STEADY rain is now falling on the United States environmental movement - not acid rain, but rain filled with enough anti-ecological sourness to bring out a big umbrella.

Faced with clouds of increased criticism from Congress and states because of the burgeoning costs of protecting the environment, a coalition of 15 leading US environmental organizations reacted with an urgent letter-writing campaign launched in early July.

``We have never faced such a serious threat to our environmental laws,'' stated the unusual collaborative letter critical of pending congressional legislation to amend environmental laws.

The new climate involves a major push to analyze risks and to assess the costs and benefits of solutions to environmental issues. It arises mainly from those states and localities facing the high costs of meeting federal mandates for environmental cleanup or preservation. The familiar ``one size fits all'' kind of environmental law adds costly burdens to states with differing needs and regional variations.

Two bills on risk assessment are working their way through the US House and Senate. The Senate Appropriations Committee said in a report the Environmental Protection Agency (EPA) should fund research to improve comparative risk analysis, and it asked the agency ``to provide a report within 60 days'' (after a bill passes) on plans to use comparative risk analysis to set national environmental goals. Behind the pressure is a visible shift in environmental politics. Environmental issues, shaped in the past mostly as national issues with broad laws against heavy industry, now have become more localized.

Home town pollution

Local and state polluters, such as water districts, waste-treatment plants, and local businesses are now under more scrutiny, and face restrictions and regulations.

But environmentalists are leery of the call for change. ``In simple form, risk analysis is a way to subvert regulations, a way to look at fiscal impacts of regulatory actions and decide whether or not they are appropriate,'' says Scott Faber from American Rivers in Washington. ``I think you define risk another way. What is the threat posed to human health and the environment?''

According to estimates from the EPA, states and local governments will spend more than 30 percent of their revenues fulfilling environmental mandates by the year 2000. One requirement of the Clean Water Act is that water systems in every city and town have to be monitored for pineapple herbicides.

The environmental coalition letter was sent to millions of members. Among other issues it criticized the push for extensive cost-benefit and risk analysis as the way to establish environmental priorities in an era of tight budgets.

Typical of the growing criticism of environmental law and regulations, John Graham, director of Harvard's Center for Risk Analysis, said at the recent annual meeting of the National Governors' Association: ``I think what environmental policy needs is a good dose of rigorous risk analysis. Somebody has got to start thinking about how we spend money [on the environment] and whether it makes any sense.''

Environmentalists like Carl Pope, president of the 550,000-member Sierra Club, say they are concerned that if federal agencies like the EPA should establish national priorities after extensive risk analysis, the exercise could become an excuse not to do something.

Making complicated excuses

``It's hard to argue against setting priorities,'' Mr. Pope says, ``but there are two kinds of priorities: those that lead you to do something, and those that lead to an excuse not to do something. And I'm afraid we're looking mostly at the second category.''

Environmentalists know that when Congress passes environmental laws, agencies are mandated to fulfill them. ``Congress didn't say to protect the air or the water or Superfund sites depending on which one you think is more important,'' says David Roe, an attorney for the Environmental Defense Fund in Oakland, Calif. ``Congress said, `Do it.' ''

Dr. Graham said the removal of lead from gasoline was one of the most ``elegant'' risk analyses ever done. He said, ``for every dollar that was spent [for removal of lead], we saved five dollars. Risk analysis is not a conspiracy to create more pollution, and there is no reason to believe we can't have rigorous analysis of environmental policy like we should have for all other policies.''

Pope suggests that the benefits to be gained from removing lead from gasoline ``were known for 40 years.'' He says, ``The people who are advocating risk analysis now were not advocates then. They did not want to take the lead out of gasoline.''

He also says a thorough risk analysis ought to be done ``before a chemical is put into commerce.'' He says: ``Now the position is that chemicals are innocent until proven guilty. The people who advocate this won't say they have such confidence in risk analysis that they want to do it before people are exposed to a chemical.''

``None of the bills [before Congress] are aimed at getting more environmental bang for the same buck,'' Mr. Roe says. ``We should be finding smarter, cheaper ways to reach environmental goals, not saying our resources are limited so we have to do less.''