Is Environmental Impact Analysis Useful? State Doesn't Know, but Wants to Make it More Complex.
Let's say you used a tool every day to solve a problem. Don't you think you'd wonder if that tool actually did the job?
For more than three decades, the state has required environmental impact analysis for a range of projects as part of the State Environmental Policy Act (SEPA). The purpose of the analysis is to understand potential environmental problems of projects and proposals.
As noted physicist Niels Bohr said, "Predictions are hard, especially about the future." Given the difficulty and supposed value (not to mention cost) of these analyses, has the state ever looked at the accuracy of the predictions at the center of SEPA analysis?
Three weeks ago, Governor Inslee met with the Association of Washington Business to outline his climate policy. After he left, his top environmental policy advisor stayed to answer questions. I asked if the state had ever checked the accuracy of SEPA reports. After explaining that he had previously been in charge of the SEPA analyses, he said simply, "I don't think they have ever been ground truthed."
So, we've never taken the time to see if the information being used to make decisions is even close to accurate.
I can attest that SEPA analysis is far from a science-based effort. While at the Department of Natural Resources, I was part of writing the Environmental Impact Statement for forestry on state lands for Western Washington. I remember talking with the various analysts about their assumptions and how tiny changes in assumptions could result in large changes in the results. When multiplying several variables, each with a margin of error, you also multiply that error. They always had reasons why one assumption was better than the other, but ultimately, each desision was subject to discussion.
Despite the failure to understand whether the current process works, the state is now looking to make the analysis even more complicated and uncertain.
The Governor and the Department of Ecology have been arguing that we should expand analysis of environmental impact to consider impacts of exported goods used in other countries (well, some goods, at least). This would be tremendously complex, of course. Just by way of example, it would have to consider:
- Will others simply replace our product by substituting their own?
- Is the environmental impact of substitutes larger or smaller than our product? For example, would substitutes be shipped longer distances?
- Will other countries substitute more expensive alternatives, leaving less funding for other environmental priorities?
All of these things are extremely difficult to predict and measure. Ecology would have to project these answers decades into the future. As a result, any prediction will be extremely subjective and any relation to reality would be accidental.
Ecology Director Maia Bellon has already hinted this system will force her to make decisions in a somewhat arbitrary way, acknowledging that the analysis is uncertain and costly. In a legislative work-session earlier this year, she told legislators that although there was no information available to analyze the impact of exporting, say, the Boeing 777X, she thinks Ecology would likely find the impact "insignificant."
Based on what? Well, based on "assumptions," information that is "speculative," and "expectation." If she can tell us what the outcome is likely to be before we've even started, why do the process in the first place?
Ultimately, this means the data is not really useful. Adding additional speculation, assumptions and expectations to a system that has never been ground truthed isn't the basis for rational policy-making.
Ultimately, we'll end up following the advice of Randy Hayes of the Rainforest Action Network on how to deal with science: "Go with your gut."