Environmental Ethics
and Public Policy
Ernest Partridge, Ph.D

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Policy-Making By the Numbers1

Ernest Partridge

For The Davis Seminar
University of Colorado
June, 1983

(Also in "Topics" in the "Environmental Educator's Page)


The Homestake II Project -- A Case History: The Holy Cross Wilderness, at the headwaters of the Eagle River in central Colorado, is a place of spectacular beauty, featuring abundant wildlife, rugged mountains, waterfalls, alpine meadows and wetlands, and a pristine natural environment. Rights to the water in the area are held by the cities of Aurora and Colorado Springs. After completion in 1992, the Homestake II Project would draw over twenty-thousand acre feet of water from the area each year. The cities claim that the environmental impact of this project would be minimal. The Holy Cross Wilderness Defense Fund replies that the project would seriously damage the fragile alpine aquatic ecosystems. Thus the issue is joined.

Some Value Issues. Behind the factual disagreements are differing emphases in values. Both sides value unspoiled wilderness. Both sides acknowledge that the basic needs of growing populations should be met. The difference is in emphasis. The cities feel that urgent human needs necessitate immediate action, even though such action must entail some impact upon the wilderness. The preservationists feel that the unique values of the Wilderness mandate caution, restraint and careful review and, ultimately, alternative means of extracting the water. Some may even regard the presence of wilderness as an "urgent human need." The cities feel that decisive action must be taken now to accommodate a rapidly growing population. The preservationists fear that the failure to curb population growth will, through postponement, transform a present difficulty into a future disaster. The project proponents feel they speak for the citizens of their municipalities, and of the region. The opponents perceive their constituents to include, not only some citizens of the cities and region, but also future generations, other species, and perhaps, in a sense, the Holy Cross Wilderness itself.


The Essential Facts and Values: A Summary. The following general facts, relevant to Homestake II Project would presumably be granted by both sides:

  • The cities of Aurora and Colorado Springs have experienced rapid growth of population, a growth that is likely to continue. At current and projected rates, their populations will exceed presently available water supplies around 1994.

  • Ground water tables in the front range are dropping constantly.

  • The cities own the rights to the water in the Holy Cross Wilderness, and have the legal right to divert it for their use, despite the fact that the area of origin has wilderness status.

  • Construction of the project would temporarily improve the local economic conditions in Eagle County, an area affected by mining layoffs.

  • The affected area was designated a wilderness area in recognition of its natural and aesthetic values. These values are recognized and cherished by many citizens of Colorado and beyond.

  • Wilderness areas such as Holy Cross are the source of valuable information to research scientists such as ecologist, hydrologists, geologists, etc.

  • Natural water supply is a result of climate (i.e., rainfall) and is thus relatively constant (within bounds of natural fluctuation).

  • Water diverted from the Western Slope to the Front Range is water no longer available to the population "downstream" in the western states. (All usable water in the Colorado River is consumed. There is virtually no flow into the Gulf of Mexico).

The Project proponents would stress the following value assumptions:

  • Colorado is an attractive place to live and work, which accounts for the growing population. Those who choose to live and raise their families in Colorado, have a right to use the available resources necessary for a secure and abundant life.

  • The Cities own the water rights. And yet, they have agreed to significant concessions and have endured long and costly delays. Further concessions and delays are unacceptable. It is unfair for a few determined "outsiders" to impose upon Aurora and Colorado Springs a "decision by indecision." Such tactics are erosive to orderly civic planning and faith in the efficacy of government.

  • Response to an urgent and present human need for water should not be delayed by the demand of a few for an environmentally "perfect" solution, when a minimally damaging plan is available and ready for implementation.

The opponents of the project might appeal to the following values:

  • Trans-basin water projects, and other expensive and complicated "technological fixes," purchase advantages to ourselves at the expense of harming future generations. Such projects require constant maintenance and are vulnerable to breakdowns. And no matter how extensive and ingenious the engineering, there are limits to water resources. It is better to face those limits now and attempt to curb population growth, than to put off the day of reckoning and place the consequences in the hands of a more numerous posterity.

  • The value of wild areas such as Holy Cross increases as such areas become more rare, while an increasing population desires access to them and to the experience enjoyed therein.

  • Wild areas are best enjoyed when human impacts (noise, pollution, etc.) are inconspicuous and when the use is not intense.

  • Wilderness areas are necessary for civilized humans to maintain a consciousness of their origins and sustenance -- a sense of proportion and of place in the natural order. Without this sense, mankind's arrogance will eventually destroy the natural order, and with it mankind himself.

Dr. Warren M. Hern, Past President of the Holy Cross Wilderness Defense Fund, offers the following reflection on the value issues:

While we are prepared to meet the proponents claims with rigorous science and careful analysis, those of us who oppose Homestake II do not fundamentally see this dispute as a rational choice between alternative engineering approaches. In fact we have a classic conflict of fundamental values. Civic leaders and career bureaucrats of the cities see the Holy Cross Wilderness as a "drainage basin," a "resource" which is there to serve human exploitation and uncontrolled growth of the human community. Maximum runoff flows are to be "shaved."

For us, the Holy Cross Wilderness is a place that is sacred to the point of being a religious sanctuary. In a world that is plastic, false, exploitative, power-oriented, commercial, insincere, and filled with predatory and mindless destruction, this wilderness is real, it is alive, it is the way things were and ought to be; it is a tiny remaining fragment of a world rich in natural heritage containing endless beauty unaffected by human vulgarity. We have seen so many similar places destroyed before our very eyes, we know what will be lost if we do not defend it. And defend it we will.



The Homestake II project presents a hard case for the preservationist. Any way you count it, it seems that there are far more people in Colorado Springs and Aurora desiring to wash their cards and water their lawns, than there are likely to be backpackers in the Holy Cross Wilderness area. Still worse, if there were as many Holy Cross backpackers as Colorado Springs car washers, the wilderness defender would find that the area would have lost the very qualities that he finds most attractive: solitude and undisturbed wildness. And if the environmentalist attempts to enfranchise more hypothetical votes on his side by projecting into the future, he must face the rejoinder that as long as there are backpackers, there will likely be front-range residents wanting, even more, needing that water. After all, as the population increases in the front range, the water will be needed, not merely for such luxuries as clean cars and green lawns, but for the necessities of life.

No, the numbers apparently don't work for the environmentalist -- not unless he awards himself and his tastes a great many bonus points. Suppose he does; then how many proletarian car-washers equal just one high-minded, pure-spirited environmentalist? But we needn't follow this sort of argument very far to discover that, in a democracy, it just won't wash. Is the environmentalist prepared to sacrifice democracy too in defense of his "ecological ethic"? Here we come face to face with the familiar "elitism" charge.

Making environmental decisions "by the numbers" -- that is, by quantifying in monetary terms, then comparing, gains and losses -- characterizes what is known as "cost benefit analysis" ("CBA"). At first glance it seems to be an irresistible method of making environmental policy decisions. After all, how else might we do it? And yet, for all its immediate appeal, some particular aspects of the economic "cost-benefit analysis approach," even the general approach itself, have recently drawn considerable criticism. If, as I suspect, the defenders of the Holy Cross Wilderness will lose the "game" of "standard cost-benefit analysis," then they might do well to reject that mode of decision-making and propose another. Accordingly, the Homestake II Project might well be regarded as the sort of "hard case", which may encourage the environmentalists to refute CBA and then seek and endorse an alternative means of environmental policy decision-making.

Economic cost-benefit analysis, a well-established procedure of environmental policy decision-making, developed out of public works projects in the New Deal, and later in "operations research" during World War II. Historically, this procedure has provided the rationale to justify a myriad of public works projects which have transformed the face of the American West. The use of CBA in public policy appeared to have peaked three decades ago in the "Tocks Island Case," involving a dam project on the Delaware River. (Though the Army Corps of Engineers CBA study yielded a highly positive assessment, the governors of the affected states ordered a deauthorization). However, reports of the demise of CBA have apparently been highly exaggerated. On February 19, 1981, President Reagan published an Executive Order requiring all agencies and departments of his administration to justify their regulations with positive cost-benefit analyses. The CBA approach is likewise prominent in the assessment of the Homestake II Project and its alternatives. CBA remains an important factor in environmental policy-making, and thus deserves our careful examination and scrutiny.


Policy decisions are necessarily (a) Normative, since they involve decisions among graded options that effect the conditions of life of persons, and (b) partially informed, since they are made by fallible and finite persons, and not by the Almighty (or His surrogates). Policy decisions are also generally (c) forced, since "not to decide is to decide." (Many of the methods and presuppositions of policy-making that are discussed and criticized herein follow from the valid complaints "but we've got to do something" and "well, what better way do you propose?" Value-comensuration and future-discounting are prominent among these "forced" practices).

The uses and abuses of "value-free inquiry." Many scholars, scientists, and policy analysts have rigorously attempted to exclude values from their assumptions and their methods. Admittedly, it is difficult to quarrel with the rule of scientific and scholarly research which insists that the researcher confine his reports to what he observes and to exclude from his observations those biases that might arise from what he would like to observe. The business of science, in brief, is to discover and report facts as they are, not as they should be or as we wish they were. Because the task of science is to collect data, to abstract laws, to project hypotheses and to construct theories, human will and choice does not and should not "mix" with the objective reporting, classification and organization of data. Facts are facts, whatever the moral biases of the observer. Communist missiles and capitalist missiles are subject to the same physical laws and their trajectories are plotted with the same mathematical formulae.2

And yet, all too often we find that the discipline of "value neutral inquiry" is carelessly and inappropriately extended beyond empirical science and objective scholarship to applied science, environmental planning, policy-making and legislation. When extended to these fields, "value-neutral inquiry" is unwarranted and can have pernicious results.

And so, many government policy-makers, eager for quick and easy solutions to complicated value-laden environmental issues, have enthusiastically adopted a scheme of economic "cost-benefit analysis" which claims to be "scientifically based" and thus "value-free." Apparently it is neither. On the contrary, moral philosophers who have studied the sort of "cost-benefit analysis" that is enshrined in countless environmental impact statements and items of federal regulation and legislation have generally concluded that such procedures are built upon a structure of presuppositions that are unexamined and, in many cases, highly questionable. The following seem to be the most troublesome of these assumptions:3

  • The "Reliable is Valid" Bias. "The more measurable and discernible a factor, the more 'real' and significant it is." (An engineer of my acquaintance put it this way: "If you can't measure it, it isn't knowledge" -- and he meant it!) This bias is particularly prominent in "educational research" and other varieties of "applied social and behavioral science." But a person's height and weight are more measurable and discernible than his intelligence or his sense of justice and duty. Therefore . . . ? It is much easier to measure, and then to price, "usable" acre feet of water, that it is to measure "ecological values" or "aesthetic values." By this rule, then, water in a conduit is more valuable than water sustaining an alpine meadow.

  • Comensuration: "Values reduce to costs." The value of a "good" to you is what you are willing to pay for it, and of a "bad" what you would pay to avoid it. The plurality of values is thus to be measured in a single dimension: $$$. (This is called "comensuration"). And so, in the Tocks Island Dam Case, the Corps of Engineers devised a handy way of comparing the "recreational value" of the wild river to a canoeist with the value of the reservoir to a power boater; i.e., how much would the user be willing to pay to get to use the area? Well, how many canoes, nylon tents, cars with canoe racks (etc.) equal one Chris-Craft and Winnebago? By this accounting, the lake trumps the river by several orders of magnitude. But there are deeper problems with "comensuration;" for example, by reducing all values to costs (a non-moral value), "moral values" (e.g., virtues, principles, rights, duties, etc.) are "factored out." This rule leads, in turn, to:

  • "The future is to be discounted"; i.e., the further off in the future, the less a given cost or benefit is to "count." (Thus, according to this theory of "discounting the future," at a per-annum discount rate of 5%, one death a year hence is equivalent to over two million deaths three hundred years in the future). The reason this assumption follows directly from the second (i.e., that values reduce to costs) is that monetary costs can be, and appropriately are discounted in the future in view of the capacity of money to accrue interest.

  • "The method of cost-benefit analysis is to be regarded as detached from its subject-matter;" i.e., the analyst shall ignore the effects of the use of his procedure upon the "objects" of his analysis (viz. persons and their choices)" -- otherwise, scientific "objectivity" will be compromised. But what is the moral "price" of regarding persons as objects, and by reducing their values to monetary costs? What does the application of such a methodology do to the persons "analyzed" -- particularly to their value systems? The question itself, because it is a "value question," is inadmissible according to the rules of cost-benefit analysis. A troublesome result of this approach is that it fails to account for, and thus deal with, "the moral paradox" -- i.e., the advantage to the agent of other-directed concern and activity.  (Cf. our discussion of "Moral Psychology," earlier in these topics).

  • The Fallacy of Unfinished Business. This is the assumption that technological and environmental problems have only technical, but not social, ethical, or political solutions. And if a policy question appears unsettled, more "facts" from more "experts" are called for, until, eventually, the matter is resolved "objectively." A list of the "expert witnesses" called to testify on environmental policy matters in Congress will indicate the strength of this fallacy.4  Other examples of "the naturalistic fallacy" follow.

  • "'Valuable' means 'what is valued'" in the subject population (or in "the market"). Prescriptive (or "normative") questions of "what should be valued?" are not allowed, by procedural fiat. Nor are "metaethical" questions allowed, such as "how do we justify our values and moral beliefs?" To include these would be regarded by many policy-makers as "unscientific." The procedure is thus, by design, ethnocentric and conservative, and uncritically accepts the highly controversial meta-ethical theory of cultural relativism.

  • "'Good' is to be defined as 'the maximization of utility,' and 'utility,' in turn, as 'the satisfaction of valued desires.'" (For the denotation of "valued," see the assumption" that immediately precedes this). We find here an uncritical acceptance of the ethical theory of utilitarianism. What we rarely find in the literature of cost-benefit analysis is an argument in support of this highly controversial ethical theory, or even a reply to the criticisms of utilitarianism that are well-known to students of moral philosophy. We search in vain for such discussions in the literature of cost-benefit analysis.

Fortunately (perhaps), when these assumptions and methods are rigorously applied, the resulting policies run sufficiently afoul of "common sense" and intuitive morality that they are blocked, on "unscientific grounds" by legislators and the courts.

When I have presented this list of complaints regarding the questionable methods and presuppositions of policy consultants and policy makers, some economists, and even more political scientists, complain that "this list is a straw man -- terribly over-simplified and unqualified. We don't think or talk like this." They are right, of course. But that's not quite to the point. For while I grant all this, I then ask, "but how much is your policy-theory put into the practice of policy-making? How much of this subtlety, complexity, qualification survives in the summaries that appear before the legislators and the bureaucrats, or the testimony offered in their committees?" (A common response to this challenge is a pained look and a shrug). It is, I think, also fair to ask, "while you, and others, find intuitive fault with this list of (I contend) operative methods and assumptions, how well does your discipline explicitly and systematically deal with the intuitive objections to the above 'straw men?'" All too often, when such intuitive qualms are raised, the expert will write a blank check: "but that's outside the scope of our discipline," following which the objection is set aside and forgotten.

I do maintain, therefore, that my list does indicate some of the operative assumptions made by those who actually make policy decisions, and that these "unfair simplifications" reflect the stronger, "core," assumptions of some of the more influential policy theorists.

The uncritical adoption of "value-free analysis" to planning and policy-making, says the philosophical critic, is unwarranted since planning and policy are essentially about choices. While the scientist asks "What is the case?" What are the facts?" the policy-maker necessarily asks "What should be the case?" "Which of the available options should we choose?" Because the task of the policy-maker is to choose among feasible alternatives, he must ask "Which is the optimum - the 'best' -- choice among the available options?" Listing and explicating the "available options" is an appropriate task of the "value-free" scientist. The problem arises with the four-letter word "best" But what does the policy-maker mean by "best"? "Best" on what grounds? What reasons does he offer us to accept his evaluation or, for that matter, for accepting his method of justifying his claim that such-and-such a policy is "the best" of the alternatives?" These are not scientific questions; they are unavoidably questions of moral philosophy (and of metaethics in particular). Thus the moral philosopher would likely conclude that an uncritical insistence by policy-analysts that their methodology, "like scientific method, is value-neutral" will result, not in "value-free" choices, but in choices that follow from unexamined and unchallenged values. In short, if we think that scientific insight alone will give us adequate guidance in our environmental policy decisions, we will be making -- even worse, continuing -- a dreadful error.


Consumer Preferences and Community Principles: We come, at last, to what may be the most crucial yet controversial tenet of cost-benefit analysis; namely, the disposition of the CBA policy-maker to identify the locus of values with the economist's concept of "satisfaction of preferences." This disposition displays an insensitivity to motives to act on principle and contrary to the motive to satisfy one's personal tastes and desires. It also dismisses "the moral point of view" (a disposition to act "for the good of all") in favor of the egocentric view of the "preference maximizing" consumer. (See "Environmental Justice and Shared Fate," and "With Liberty and Justice for Some," this website). Mark Sagoff's experience while teaching a class in environmental ethics illustrates this point. In one of his undergraduate courses he discussed the celebrated Supreme Court case, Sierra Club vs. Morton which concerned an attempt by the Disney Corporation to build a ski resort at Mineral King Valley near (and since, absorbed into) Sequoia National Park. Sagoff reports:

I asked the students what they thought about the Disney proposal. They hated it. But then I asked how many had visited or would visit Mineral King, supposing Disney were stopped. Very few. I asked who would visit the resort were it built. Almost everybody. The enthusiasm was boisterous. Curious. The students were deeply opposed to the Disney project yet they would not visit the area unless there were a bed, alcohol, a ski tow, and a discotheque. How do you explain that? The students saw no inconsistency. They opposed the resort on principle: they thought it was wrong. But as a matter of personal taste or preference they would enjoy a ski resort much more than a wilderness. The same might be said of adultery -- you would enjoy it, but you know it is wrong.5

Thus we can imagine a hypothetical future skier, thoroughly enjoying himself at the Mikki Maus Alpenhaus, yet regretting that it was ever built. Is this irrational? Or is there, perhaps, alongside our "enjoyments" a place for an adherence and loyalty to the principle that magnificent natural areas have a presumptive claim to be left undisturbed? If so, then essential to this sentiment may be a regard for the Wilderness, apart from any consideration of the "payoff" in human satisfaction for "having" the wilderness, or even in the self respect for being "high-minded" about it all. From a moral point of view, such calculation of the "utility payoff" to oneself of principled sentiments, motives, policies and acts, cheapens the perceived values thereof, since much of the moral quality of caring for another person, place or principle resides in the focusing of attention upon the other, or in the devotion to principle itself. This widely-perceived (and arguably essential) quality of moral commitment leads, once again, to the moral paradox: that the greatest value to human beings is accrued by acts motivated to enhance the good of others -- other persons, places, causes, principles, etc. Sagoff's students exemplified this principle, whether or not they recognize it as such. It was apparently much more important to Sagoff's students (and thus, perhaps, more satisfying) to care about and preserve the wilderness of Mineral King Valley than it was, paradoxically, for them to enjoy it. Perhaps they sensed that a world of diminished intrinsic natural (i.e., non-utilitarian) value is a world less worth living in.

Very few of Sagoff's students would ever see the wild Mineral King Valley, and most would want to visit it as a ski resort. Yet they "hated" the Disney proposal. Why? Perhaps because they made a distinction between utility and principle. The economist making a cost-benefit analysis may be systematically disinclined to recognize this distinction -- much to the ultimate detriment of the cause of preserving wild places. To the economist, it may be sufficient for his analysis that more would prefer skiing at the resort to hiking in the wilderness. That many (most?) of the skiers themselves would have preferred it had the ski area not been built -- this makes no sense to the economist. His theory may thus be unable to account for "actions on principle" -- acts which follow a deliberate decision not to do something that would nonetheless maximize one's enjoyments.

So for the environmentalist, the numbers may not work. But he should remain unmoved. The rules of the CBA game are stacked against him from the beginning. To preserve or not to preserve a wilderness area is a political decision which ought to be decided by reason and appeal to principle, and not by the mechanical application of a technical device which smuggles its conclusions into its premises while masquerading as the value-free instrument of scientific objectivity.


"Science as "Value-Free Inquiry" -- A Postscript.6

I have described the content of science and (in a restricted sense) the methodology of science as "value neutral." It is, I think, a correct description. But lest I be misunderstood, I hasten to add that the moral character of the scientist is relevant to the quality of his work. Even more, I would suggest that the activity of science (that is to say, of science as a human institution) is highly involved with values. Consider an example:

When Gregor Mendel published his studies of the genetic properties of sweet peas, he apparently gave a scrupulously factual account. Moreover, his failures and unanswered questions were reported alongside his verified hypotheses. Had Mendel not been impeccably honest, humble and open with his work, his reports thereof would have been, scientifically speaking, far less valuable. In short, the moral quality of the researcher gave explicit value to his findings. Yet Mendel's scientific papers themselves have not a bit of moral evaluation within them: no prescriptions, no exhortations, no "shoulds" or "oughts" -- only the straightforward exposition of observations and hypotheses. The accounts were value-free; but the conditions required to produce these documents and to give them scientific importance were profoundly moral. In contrast, consider the case of Lysenko, who displayed neither honesty, candor, tolerance or modesty. Because of these very failings, his work was scientifically worthless. Once more: the primary findings of science, and the language that reports it, are value free, but the conditions that permit scientific work and the attitudes of the scientists toward their work, are deeply involved in morality.

In his little book, Science and Human Values,7 Jacob Bronowski gives a masterful presentation of the moral preconditions of science. The fundamental moral premise, says Bronowski, is "the habit of truth": the collective decision by the body of science that "We ought to act in such a way that what is true can be verified to be so." This habit, this decision, gives a moral tone to the entire scientific enterprise. Bronowski continues:

By the worldly standards of public life, all scholars in their work are of course oddly virtuous. They do not make wild claims, they do not cheat, they do not try to persuade at any cost, they appeal neither to prejudice or to authority, they are often frank about their ignorance, their disputes are fairly decorous, they do not confuse what is being argued with race, politics, sex or age, they listen patiently to the young and to the old who both know everything. These are the general virtues of scholarship, and they are peculiarly the virtues of science. Individually, scientists no doubt have human weaknesses. . . But in a world in which state and dogma seem always either to threaten or to cajole, the body of scientists is trained to avoid and organized to resist every form of persuasion but the fact. A scientist who breaks this rule, as Lysenko has done, is ignored. . .

The values of science derive neither from the virtues of its members, nor from the finger-wagging codes of conduct by which every profession reminds itself to be good. They have grown out of the practice of science, because they are the inescapable conditions for its practice.8

And this is but the beginning. For if truth claims are to be freely tested by the community of scientists, then this community must encourage and protect independence and originality, and it must tolerate dissent.


Notes and References

1. Presented originally at a conference at the University of Colorado, June, 1983. Revised for courses in Environmental Ethics, University of California, Riverside.

2. And yet, to characterize science as "value free" or "value neutral" is to employ a simplification that demands qualification. I shall provide this qualification in a postscript to this essay.

3. These charges against common theories and practices of cost benefit analysis are as controversial as they are serious. For a fuller presentation of these and other criticisms of "value-free cost-benefit analysis," see Roszak (ed), The Dissenting Academy (Vintage, 1968); Tribe, Schelling and Voss (eds), When Values Conflict (Ballinger, 1976), and Lawrence Tribe, "Policy Science: Analysis or Ideology?" Philosophy and Public Affairs, 2:1, Fall, 1972.

4. See K. S. Shrader-Frechette, "Environmental Impact Assessment and The Fallacy of Unfinished Business," Environmental Ethics, 4:1, (Spring, 1982), p. 37.

5. In "The Philosopher as Teacher: On Teaching Environmental Ethics," Metaphilosophy, II:3 & 4, (July/Oct., 1980), p. 318. Sagoff cites this classroom discussion to make a different point, namely that "principles are preferences we have not as individuals but as members of communities. . . Principles or social norms are not values upon which we happen to agree; they are values the logical subject of which is the community itself." (319) While I agree with Sagoff regarding the source and locus of principles and social norms, I wish to make a different, though compatible, point; namely, that a loyalty to principles may motivate sufficiently to override utilitarian motives.

6. "Auto-Plagiarized" in "On Scientific Morality," this website, The Northland Issues.

7. Jacob Bronowski, Science and Human Values, (Harper, 1965).

8. Ibid., 58-60.



Dr. Ernest Partridge is a consultant, writer and lecturer in the field of Environmental Ethics and Public Policy. He has taught Philosophy at the University of California, and in Utah, Colorado and Wisconsin. He publishes the website, "The Online Gadfly" (www.igc.org/gadfly) and co-edits the progressive website, "The Crisis Papers" (www.crisispapers.org).  Dr. Partridge can be contacted at: gadfly@igc.org .