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| Waterloo Recreation Area in Pinkney, MI 2010 Photograph by Ian Tran |
Honorable Governor Snyder and Honorable Senators of the Michigan State House:
I provided ecological economic advisory for the City of Dearborn’s sustainability master plan and was nominated subsequently for the Dearborn Mayor’s Environmental Commission in 2010. I remain an ardent proponent for examining issues by their existing and potential consequences they have on people affected by the intermingling of social, economic, and environmental challenges. I’m a realist rather than an environmentalist. I oppose and urge you to oppose SB78, which strives to amend the Michigan Natural resources and environmental protection act, for the following reasons.
I provided ecological economic advisory for the City of Dearborn’s sustainability master plan and was nominated subsequently for the Dearborn Mayor’s Environmental Commission in 2010. I remain an ardent proponent for examining issues by their existing and potential consequences they have on people affected by the intermingling of social, economic, and environmental challenges. I’m a realist rather than an environmentalist. I oppose and urge you to oppose SB78, which strives to amend the Michigan Natural resources and environmental protection act, for the following reasons.
Summary of contentions:
1) SB78 would create uncertain and ambiguous risks to the state, businesses, and citizen taxpayers
2) Economic and scientific research provide compelling if not clear reason for environmental conservation
3) Underutilized or unconsidered alternative consensus processes exist for sound risk governance, programming, and policy solutions to ensure benefit for all stakeholders
1) SB78 would create uncertain and ambiguous risks to the state, businesses, and citizen taxpayers
2) Economic and scientific research provide compelling if not clear reason for environmental conservation
3) Underutilized or unconsidered alternative consensus processes exist for sound risk governance, programming, and policy solutions to ensure benefit for all stakeholders
1) Removing
regulatory capacity for conservation from state agencies create ambiguous risks
which can negatively impact the state, local businesses, and citizen taxpayers
in the long-run
The International Risk Governance Council
(IRGC) categorizes uncertain and ambiguous risk [0] as follows:
■ Uncertainty refers to a lack of clarity
or quality of the scientific or technical
data.
■ Ambiguity results from divergent or
contested perspectives on the justification,
severity or wider
meanings associated with a given threat.
SB78 facilitates uncertain risk because we lack
proper baseline data for accurately recognizing state-level benefits of
biodiversity and conservation management, yet the legislation seeks to reduce
the state’s ability to maintain and manage the areas crucial for data
collection and analysis. We also have
few guarantees that unforeseen consequences of resource extraction (i.e.
natural gas, shale oil) will have proper and thorough remedial response. Many of those who testified to the committee
or submitted comments presented perspectives that contested the nature and
potential repercussions of SB78; these perspectives exemplify both the
ambiguity and uncertainty associated with this bill. The legacy of negative consequences from
disastrous events remain real risks for the Michigan citizen from an economic
and environmental health perspective.[1] Furthermore, the state remains unprepared to
thoroughly mitigate these disasters.[2] DNRE policies and programs regarding our
natural resources may require further clarification; however, removing the
DNRE’s regulatory capacity is certainly excessive.
The typical citizen would rarely take issue
with an individual, business, or government that strives to save money for the
sake of the people's current and future well-being. Doing conservation for the
sake of appropriate, ecologically informed biodiversity and long-term economic
security ought to do the same. In this
sense, conservation facilitates opportunity through discipline. In other words,
conservation remains a proper priority in fiscal and environmental matters
alike, even if we cannot (and ought not) assume everything we live with can be
approximated to a dollar value.
The principles for the origins of
conservativism are shared between political, economic, and environmental
practice: we conserve to know that we may live well now, and ensure that others
may live well in the future. Everyone can agree with true conservative
principles regardless of political background.
Conservation management looks to foster well-being for us and for things
beyond our own species; the ability to exercise proper stewardship of the land
we live with does not detract from our own well-being but rather supports it.
2) Economic and scientific research provide compelling if
not clear reasons for environmental conservation
The bill misses an important nuance of the
environmental-economic issue at hand: the two aren't necessarily opposed to one
another. Economic studies of states with
sound environmental policy demonstrate [1]:
●
The impacts of new
environmental regulations are small if not negligible
●
Had greater rates of job
growth
●
Had lower rates of business
failure
●
Foster a
resilient economy
The economic benefits of biological
conservation outweigh the costs, even under consideration for forestry,
agriculture, tourism, hunting, etc.
[i.e. 2, 3, 4, 5].
Scientific and economic research demonstrates
findings which stand opposed to the revised language proposed in SB78: economic forces, spurred by intentional human
actions, drive extinctions and environmental degradation [2]. In SB78, the bill's revisions would turn away
from vigorously established science and economics at the expense of the
people's and state's ability to ensure long-term social, economic, and
environmental well-being. The concepts
conveyed by the Michigan Environmental Council and Dr. Burton Barnes are sound
and commonly found in the theory and practices utilized by undergraduates and
professional practitioners of the environmental field such as those in the
Michigan Department of Natural Resources and Environment alike.
3) Underutilized or unconsidered alternative consensus processes exist for sound risk governance, programming, and policy solutions to ensure benefit for all stakeholders
Based on my independent assessment of
testimonies submitted on the 14th of February, and the ambiguity inducing risks
which arise from the possible root intentions for SB78, I suggest utilizing
consensus processes to harness comprehensive stakeholder ownership of policy
and programmatic decisions as a preliminary alternative to this legislation.
While I oppose the bill, it has summoned
precious information that’s crucial to making Michigan a more resilient state
in its policy, economy, and environment.
Companies like Louisiana-Pacific clearly demonstrate valid requests for
better policy and programmatic outcomes that can work for them. While these companies do not comprehensively
represent Michigan’s citizen base and the state’s economy, their possible needs
are worthy of consideration and can carry very real consequences for the people
and communities they may employ. The
Feb. 14 and 21 testimonies of the Michigan Environmental Council (MEC) offered
assistance to the Senate committee to review, clarify, and consider revisions
to improve proposed BSA/Living Legacy programs.
While I support the MEC’s motion and affirm the insight, I believe the
diversity of perspectives found in the testimonies of the bill should be put to
a collaborative workgroup to explore and resolve the concerns raised by
existing and potential environmental policy and programs. Organizations such as The Engineering Society
of Detroit Institute (ESDI) can help facilitate strategic solutions-oriented
dialog and actions.[3]
As the potential impacts of the language found in this bill
risks compromising aspects of Michigan’s social, economic, and environmental
well-being, I strongly encourage you to halt its immediate passage. Instead,
both supporters and opponents of this bill should view this as an opportunity
to bring the many organizations, corporations, and individuals that may be
impacted by its passage together to develop a robust and coherent environmental
policy. In doing so, we can foster
authentic and exemplary outcomes for a civil and sensible Michigan.
Thank you for your consideration.
Sincerely,
Ian D. Tran
---
B.S.
Environmental Science, Political Science Minor
Class of
2012
The
University of Michigan-Dearborn
[0] IRGC, 2005
“An Introduction to the IRGC Risk Governance Framework”
http://irgc.org/wp-content/uploads/2012/04/An_introduction_to_the_IRGC_Risk_Governance_Framework.pdf
Additionally, see: IRGC, 2005 “White Paper on Risk Governance, towards an integrative approach” for strategies
Additionally, see: IRGC, 2005 “White Paper on Risk Governance, towards an integrative approach” for strategies
[1] Meyer, S. "The Economic Impact of
Environmental Regulation" MIT Press
[2] IUCN, 1994 “The economic value of
biodiversity” The World Conservation
Union
[3] Pimentel et al.,1997 “Economic and
Environmental Benefits of Biodiversity” BioScience
[4]
Naidoo &
Adamowicz 2005 “Economic benefits of biodiversity exceed costs of conservation
at an African rainforest reserve”, Proceedings
of the National Academy of Sciences of America
[5]
For more, see
“Economic Benefits of Biodiversity” page of the Conservation Tools website
[1] For
example, the record of remediation and response from the industry remains poor.
i.e. the Enbridge Oil spill in Marshall, MI.
While we may have a history of safe mining operations underway in
various parts of Michigan, we also have the toxic remnants of mining operations
from times even in the recent past--the Upper Peninsula underwent acid mine
pollution (water turns to sulfuric acid), and heavy metal (particularly
selenium) contamination. Taxpayers shoulder the burden of these events.
[2] According
to reports and first-hand accounts from peers who work in the field of
remediation for the environmental clean-up industry, the cleanup efforts
enacted by the government and contracted firms remain insufficient either due
to insufficient State funds, or due to the nature of our economic system,
environmental consulting firms foremost vested in making profitable but not
necessarily thorough clean-up. Yet well
maintained environments can help remediate up to 75% (by weight) of chemical
pollution [5].
[3] Full disclosure: I worked with the ESDI in the
past and cite them because it’s the only entity in the state I know of with
keen experience in facilitating complex technical initiatives. The Michigan Roundtable for Diversity and
Inclusion may be a valuable facilitator for delicate dialogs, but I’m
unfamiliar with their actions.
