IB KNUDSEN approached the subject by searching through the literary sources for a definition of the precautionary principle. He found that the principle had found its way into German legislation for the first time in 1976 in the term ‘vorsorge-prinzip’, i.e. care for the environment and had since then changed names to the English ‘precautionary principle’, that is prevention. After this he mentioned and discussed a series of specific cases in which the principle had been used in an international context.

Then he referred to Cameron who divides the principle into three elements, each corresponding to the manner in which it is used. First of all the idea that if no action is taken, it can lead to damage. Secondly, the fact that there is a lack of exact scientific knowledge concerning cause and effect. And finally, as a consequence of this, that it will be difficult to justify the absence of regulation.

Mr Knudsen emphasised that when dealing with such a situation, one must base one’s actions mainly on science. How does one deal with a situation in which a relationship can be established but not definitively proven?

This gives rise to two questions. 1. How can science fix a scale with which to asses different risk levels? The precautionary principle is supposed to take into account that new knowledge is forever being obtained, and that different groups of experts might differ in their assessment of the validity of this knowledge with regard to a specific problem. 2. How is this precaution to be managed in the most reasonable manner? How does one choose between a total banning, restoration, and a demand for better or alternative technology?

These considerations were seen in a broader perspective through the three elements of risk analysis. First of all, experts must assess the risk, most often by way of mathematical models and safety factors. Secondly, politicians have to manage the risk which in part means that the safety aspect of the problem must be identified, and that a level for this safety must be fixed. Finally, the risk must be communicated to the consumer, producer, and society.

In general Mr Knudsen pointed out the absence of a policy regarding risk assessment, that is the need to stipulate which substances in which areas should be assessed. Things are continuously being rejected on both scientific and value assessments. The public and science have different ways of assessing the risks involved in traffic and mad-cow disease!

Mr Knudsen emphasised that the precautionary principle is primarily an instrument in risk management. It has nothing to do with the much more specific use of scientific uncertainty in risk assessment that the director of the EPA, Erik Lindegaard, mentioned. He then moved on to stress the need to assess how advantages, disadvantages and acceptance are experienced and he referred to a report from the American Congress in which directives for the management of risk in environmental cases are stipulated.

Finally, he emphasised yet again that even though there are a great many, and very different, bases for assessment, be they scientific or determined by values, the decisive factor in the use of the precautionary principle must always be objective data. There must be a continuous interaction between scientists’ budding doubts about a safety level and society’s subsequent implementation of the necessary research and investigations.

PROFESSOR POUL HARREMOËS analysed how the precautionary principle was applied to risk assessment of a substance and took as his starting point the two extremes. 1. Is it hazardous? And 2. Is it harmless?

His point of departure was the paradox that whilst it at all times can be proven whether a substance is hazardous, it is impossible to establish the same clear-cut proof that it is harmless. The solution to this lack of scientific deduction is, according to Professor Harremoës, induction, that is the individual’s own experience.

When all is said and done it is about rendering probable whether a substance is hazardous. A prerequisite for this is confidence in the efficiency of the existing procedures. This is one of the fundamental problems in the environmental debate.

Professor Harremoës stressed that the precautionary principle can not conjure up solid evidence in areas where science skates on thin ice, but as a general principle it transposes the burden of proof to the person performing the activity. It is thus the polluter who must create a confidence by rendering it probable that an activity is harmless. As an example of this he brought up the conflict between the demand for clean drinking water and the environmentally idealistic proposal that untreated water be reused in households.

The precautionary principle is rather a question of assessing uncertainty and consequences of making a mistake. This is so when considering both the postulate that a substance is hazardous as well as the postulate that it is harmless, and therefore, at the bottom line, it is an acknowledgement of our insufficient knowledge. The final outcome is that political decisions have to made in a universe of categories of error - from determinism’s ideal of an all-encompassing knowledge, to uncertainty and ignorance, to the worst possible: unpredictability.

He emphasised that ignorance and unpredictability are central problems, in how we are to ‘take the range of possibilities available to future generations into account’. He stressed the need to assess future developments in a manner that is based on society rather than traditional life-cycle analysis.

He then moved on to talk about the relationship between utility and damage as seen with eyes of the general public, and reached the following criteria for intervention. Probable fear of serious and widespread damage which outweighs other social consequences of intervention . That the definition might seem a little unclear was, according to Professor Harremoës, a direct reflection of the process’ lack of exact scientific solutions.

He dealt briefly with risk analysis which he found in part both too reductionist and detailed at the cost of patterns, and also specialist. Finally he urged the speakers to form a Danish backing group which can clarify the theoretical foundation for the precautionary principle at European level. The objective is to create a system as science’s contribution to the political process.

PEDER ANDERSEN began by noting that economists regard the environment as consumption and investment benefit. He then pointed out that economic theory supports the view that we have to be cautious. In this context the precautionary principle indicates that a decision must take both the size and character of the risk, and uncertainty into consideration.

He then moved on to maintain that economic theory is relevant in connection to the precautionary principle, which, in economic terminology, is about ascertaining one’s position, creating future possibilities, compounding/connecting these possibilities and making the right decisions in the most optimum sequence - sequential decision-making. He summed up that the fundamental idea with the precautionary principle was to enhance our options in the future.

According to Mr Andersen it is not possible to make rational decisions in any manner based on the precautionary principle without applying economic theory and methodology. To illustrate this, he went over a simple economic model for optimising environmental policies concerning safety, risk, and uncertainty.

He especially emphasised that with regard to decision-making concerning uncertainty factors, there can at times be some sense in polluting a little bit more than is necessary, because the activity not only creates pollution, but also pleasure and usefulness, such as, for example, with transportation. The point with the model was the importance of sequential decision making , i.e. to be cautious now when investing in new knowledge.

Subsequently he put some major principles forward that will lead to a more strict environmental policy, but at the same time he stressed that, as all other things worth having, protecting the environment does not come cheaply. The major principles can be summed up as following:

1. Increased uncertainty entails a more strict environmental policy
2. Increased risk aversion entails a more strict environmental policy
3. Increased emphasis on future generations entails a more strict environmental policy
4. Increased irreversibility entails a more strict environmental policy
5. Assess what it will cost society to comply with the precautionary goals
6. Assess the advantages and disadvantages of reduced risk/uncertainty

According to Mr Pedersen what is needed in order to be able to use the principles is, first of all, factual knowledge focused on giving priority by way of the economic management instruments. Developments must lead to obtaining greater knowledge and better methods with which to reduce to the inadequate knowledge of cost-benefit analyses. He concluded his talk by recommending that priority be given to fundamental research in environmental economy.

The general ‘no discharge’ requirement in an American Federal Water Pollution Control Act in 1972 (‘discharge of pollutants are bad and should be reduced to the limits of available technology’) A moratorium concerning commercial whaling was proposed in the 1970s (‘uncertainty whether whaling could safely continue’) The passing of an act in 1971 in Denmark concerning the establishment of a positive list for foodstuff additives The passing of an act in 1979 in Denmark concerning the requirements made of new chemical substances and products The passing of an act in 1985 in Denmark concerning the environment and genetic technology (the first in the world!) The proposal of a general limit on pesticide residues in baby and children’s food in the EU in 1997 Out of concern for children, the American Congress introduced an extra factor of 10 in the safety factor for pesticide residues in food if there is insufficient data (‘extra factor due to special concern such as nature of toxicity’)

In Denmark we already began to consider in the beginning of the 70s that instead of having a ‘negative list’ for food stuff additives we would rather have them all on a ‘positive list’. It was thus required that they be assessed. This is actually a precautionary principle. Correspondingly, we have already heard that the Chemical Substances Act is also, in spirit, based on the precautionary principle, and that this became particularly evident in the Genetic Technology Act that was passed in 1985 as the first of its kind. In this act it was stated that, before taking further action, it was desirable to take a closer look at products using genetic technology.

Within the EU a proposal to introduce a general limit for pesticide residues in food for babies and children is currently being discussed. This limit is 0.02 milligrams. This is actually also an indication of the precautionary principle when considering that if we are to improve the risk assessment of the 600-800 active substances in pesticides it will take the next many years, and many children will have eaten the food long before that. So it is this assumption that has led to the proposal of this general limit.

Out of concern for children, the American Congress has introduced an extra safety factor for pesticide residues in food if there is insufficient data. They state it thus: ‘Extra factor due to special conditions such as the nature of toxicity.’ This is also an expression of the precautionary principle. The US EPA deals with the issue by eliminating the special factor once they receive sufficient knowledge about the individual substances, and subsequently introducing the traditional safety factors.

According to Cameron the precautionary principle contains three elements:

	1) If nothing is done to regulate matters non-ignorable damage can occur.
	2) There is insufficient knowledge regarding the connection between cause and effect.
	3) In the two circumstances mentioned in the above, to not regulate is not justifiable.

In reality this is also the order in which things are done. What often happens is that something is suspected of entailing a risk of some sort. Once suspicion has been aroused, scientists are approached and asked whether they know anything about it. Something is often known, but there is no scientific evidence of a connection. In such cases the decision can be to introduce legislation so as to play it safe.

Dr H. Reichenbach, Directorate General XXIV, which is the EU’s consumer directorate, states clearly: "The precautionary principle must be based on science. Otherwise it is impossible to use". The means that science is the central axle that everyone uses as a frame of reference when decisions are to be made.

The precautionary principle can be used in risk management - what Erik Lindegaard called risk control. The word ‘control’ makes it sound as if someone is in charge, and that is rarely the case - this is why ‘management’ is better. The precautionary principle can be used when, in a given situation, we do not have a quantitative risk assessment, when we are unsure of the scientific data, and when science still can not offer a certain answer that can shed light on what has been called into question based on the current methods.

In the Paris Commission it was established that it can be necessary to act when science presumes there is a connection, even though there is no definitive proof of such a connection.

The precautionary principle raises two questions:

Firstly: Which risk level justifies application of the precautionary principle? Is it when the risks are huge or when the risks are unacceptable? I will not try to answer these questions here, but I will say that what we must begin with are risk levels that seem to be acceptable so as to have some sort of scale of comparison.

At the same time we must acknowledge that we, as scientists, can not see further that the eye and thought and instrument can reach. There will always be discoveries tomorrow that we know nothing of today. This is one of the things that could be behind a desire to use the precautionary principle. Scientific assessment will be based on the so called weight-of-evidence principle and the available data. When we have all the data, some data will show that a substance is carcinogenic in some animal tests but not in others, and that it functions in some mutagenic test systems but not in others. Then we carry out a complete assessment of these data - weight-of-evidence - and a group of can experts make a decision. However, I am sure that a different group of experts would, based on the same data, find that they should be assessed differently. This can lead to management’s desire to include the precautionary principle.

The second question is which actions based on precaution are reasonable? Should preventive measures be introduced? Should there be a switch to the best possible technology or a clean production, and should alternative possibilities be considered? The examples we have been presented with today reflect all types of activity. Erik Lindegaard mentioned the example of BAM that has not been banned, but it is being considered whether some preventive action and cleaner production should be introduced. About food additives it can be said that preventive actions are being introduced by limiting the amount used as seen in the positive list, but it is not forbidden to use them. This is actually also the case for pesticides.


These considerations take place in a larger context. The structure of risk analysis is based on three elements (see fig. 2):
1) Risk assessment
2) Risk management
3) Risk communication

Risk assessment consists of a) assessment of hazards, b) characterisation of hazards, c) assessment of exposure, d) risk characterisation. It is in this phase that the experts, with the aid of various safety factors and mathematical models, can calculate an acceptable or tolerable daily intake.

Risk management: The decision itself concerning what the safety factor should be is actually an element of the risk management. It here that it is decided whether to use a standard safety factor of 100, an extra safety factor for children and so on. It is a decision based on politics. In the same phase the safety related problems that are to be subjected to a risk assessment are identified. The experts do not begin to assess something unless they have been instructed to do so - they do not have the resources to do this! In the risk-evaluation phase the problem is described and given a priority with regard to the risk assessment, and then a risk-assessment tactic is chosen. This is often done in collaboration with the experts. Then the actual risk assessment is put into action and finally the result of this is managed. The latter takes place without consulting the experts. The other phases in risk management involve possibilities for management, implementation of management, and finally a total view assessment, that is installation and evaluation.

Fig. 3

Important issues in the interface between risk assessment and risk management (From S. Slorach, 1998) Expert consultations on risk analysis. Risk management and risk communication Establishment of a risk assessment policy Separate science and value judgements Clear communication of uncertainty in risk assessment reports -default assumption Use of the precautionary principle Establishing ‘appropriate levels of protection’ Acceptable Daily Intake - ‘notional zero risk’ ‘As low as reasonably achievable’ (carcinogens) Total view assessment ‘Consumer concerns’ Need for better risk communication

Risk communication: In the third element it is crucial to communicate with consumers, producers and other interested parties. This communication should be clear, open and interactive. Consultations should preferably take place and all parties should be informed of what has been planned before the procedures are actually implemented.

Thus there are many elements that have to fall into place in the process. Not all of it has been settled at the present time - there are still some things that are under discussion. Slorach from the Swedish Food and Nutrition Institute has set up a long list (see fig. 3). There should be more consultation about risk analysis and assessment, management and communication. There is no consensus of opinion in this matter.

A risk assessment policy should be established as part of the risk-management process, that is, what it is one wishes to assess, because some things are not assessed at all at the moment. Should we also assess biological control agents? It is being done now, but this is a fairly recent measure. The focus has primarily been on chemical agents. It is typical of a risk-assessment policy that some areas are left alone and some are subjected to regulation.

Fig. 4

Also, scientific assessment must be distinguished from value judgements. That people find some things more important than others - for example mad-cow disease or traffic - must be distinguished from the actual scientific assessment.

The stating of scientific uncertainty - default assumption - in risk assessment and application of the precautionary principle in risk management, are two different stages in the process - once again I completely disagree with Erik Lindegaard. The precautionary principle is definitely an instrument to be used in risk management and it is inextricably bound to those tasks that the EPA must deal with. This does not mean that science can not take part in the discussion, but that the decision concerns something far greater than risk assessment. This is also the case when considering such tasks as establishing reasonable safety levels, defining what the Acceptable Daily Intake means, and management of carcinogenic substances.

Finally, the total view must not be forgotten, this not only concerns risks or advantages, but also a complete assessment of the advantages, disadvantages and acceptance. In the assessment of acceptance, the public’s attitude regarding whether the risk in question is especially unacceptable must be taken into consideration whether or not the risk is deemed quantitative in the eyes of science.

A commission appointed by the President of the United States and the American Congress wrote a report in 1997 in which guidelines for risk management of environmental cases are laid down. A lot is done to present a cyclic process (see fig. 4). First of all, the problem and the context in which it appears must be identified. Then, the risks involved are analysed and the possibilities for managing these risks are examined more closely, a decision is made and carried out, and, finally, the result is evaluated. This evaluation can lead to repetition of the process in order to improve the result. Interested parties should be involved in all of these decisions. The industrialist, the worker, the consumer, in short all stakeholders or interested parties should be involved in an ongoing discussion of the problem. This is probably what we have neglected most in Europe.

The American report calls attention to the advantages of involving all interested parties:

1. It supports a democratic decision-making process.
2. It ensures that values which the public find important are assessed and included.
3. It leads to a better understanding of what leads to the best decisions.
4. The knowledge on which decisions are based is improved.
5. Time and cost of the decision are reduced by avoiding unexpected repercussions.
6. The credibility of the authorities involved can be improved.
7. Generally, there is a greater acceptance so that people - to be understood as the man in the street, the man with the garden, the industrial worker and the industrialist -really implement what has been decided.

The EPA has asked me to answer what level of scientific knowledge or substantiated suspicion should lead to taking the Principle into use. The examples I mentioned show the types of legislation that repeatedly apply the precautionary principle as a basic principle without actually mentioning it.

The examples illustrate that the application of the precautionary principle is based on incredibly varied scientific standards. Other values play a very important part, namely what the general public thinks and therefore what politicians think. This again influences what the authorities think and, finally, the producers’, workers’, etc. influence is not to be forgotten either.

However, the decisive factor in the application of the precautionary principle is nevertheless objective scientific data. An excellent example of this are oestrogen-like substances. Some notions concerning possible problems with these substances appeared in scientific literature. The EPA began to investigate the matter and this led to the production of quite a lengthy scientific report, the first of its kind, which was later published in an international scientific journal.

This report presented scientific state-of-the-art knowledge. It illustrated how little we know about these substances and that we do not even have methods with which to establish how we should assess them. Scientists even managed to disagree on whether they affected the quality of semen or not. Questions were raised whether the data could even be seen to be a true reflection of reality.

But the debate did lead to society, in the guise of the EPA, applying the precautionary principle. A great deal of research was begun in the area, and as an initiative this research was given prominence - there was a great deal of focus on obtaining as much knowledge of the presumed oestrogen-like effect of these substances as possible. So, in this situation manifestation of the precautionary principle was the implementation of research programmes.

 

Question time with Ib Knudsen

 

Philippe Grandjean, Odense University:
To what extent are the uncertainties that you have presented actually considered when presenting a risk assessment - be it the Veterinary and Food Control Service, the EPA or other expert authorities that are responsible for these things?

Do you think that the uncertainties are presented clearly enough, or do the authorities take them into consideration in a concealed manner and weigh the problems themselves so that the democratic processes that you refer to do not actually take place?

Ib Knudsen:
In the 60s, a group of experts would get together in a room and look at the available data concerning pesticides, etc. They would stay in the room until smoke would come out of the chimney in the form of a number, and that was the number. In the 70s and 80s there has been an increasing desire amongst all other possible interested parties to know just how the experts arrived at this number. It is a process still in action and it still has not reached its conclusion. Philippe Grandjean can find numerous examples in the last 20 years of Danish risk assessment of how difficult it is to find the documents that were used, and the reasoning that these numbers are based on. This is not because the experts do not want to be checked up on, but because it simply was not done at the time.

Today the public can read about the scientific basis of these decision in a series of reports published by the EPA. Correspondingly, risk assessments from scientific committees in the EU are published as reports on the Internet. Today, things are so advanced that all reports and decisions made are available on the Internet no later that three weeks after we have held the meeting, so that anyone can see what we have decided.

In the mad-cow disease case we also prepared a draft assessment of meat and bone meal, which we published because we were not sure that we, in the group which had been appointed to assess the question, knew enough about how meat and bone meal are produced, and how to ensure that the prions which cause BSE were not in the products. We put this draft on the net and invited everyone to comment on it within a period of three weeks. At the same time we sent the draft to some people we felt might have a particular interest in the matter. Within three weeks we had received 24 comments of which many included elements that we could include in our assessment and thus contributed to improving the final assessment.

I think this is something we will see more and more of. In the States they have a Federal Register. The FDA’s and EPA’s proposals for assessment and their attitudes towards various issues are published in the Federal Register and have been so for the past 20-30 years. This has made it possible for anyone to comment on the issues, and everyone receives an answer, even though not all opinions are taken into consideration. This process is just getting started in Europe and it is a process that we must all learn to work with and try to make positive use of.

I think it is safe to say that none of us have fully mastered it yet, but we are trying as best we can to answer all the questions we receive. It will be the trend in our information society in that everything should be made accessible, it should be seen on TV, heard on the radio, and be available on the net. Yes, that will be the future.

Peter Skov, Confederation of Danish Industries:
You began by saying both ‘yes’ and ‘no’, but I think you managed to express some views about risk analysis and risk conditions. I agree with, and am a little surprised, that Erik Lindegaard thinks that the precautionary principle is an element in risk assessment or risk analysis.

However, my question concerns something completely different. You mentioned two reports, one from the Swedish Food and Nutrition Institute and one from the States. I understood it as if they were in favour of opening the system up a bit, and you touched upon that towards the end of your talk. If one considers the debate in Denmark concerning risk and risk conditions, do you have any idea as to how such a debate and openness could be systematised?

Ib Knudsen:
I have mentioned the EPA’s reports that include different risk assessments. In the Veterinary and Food Control Service we also publish a series of reports. Finally, the entire EU system is gradually looking forward to more openness.

I will take this opportunity to show you one of the overheads I did not use earlier (fig. 5). In connection with the case about mad-cow disease, where both the Commission and the EU lost consumer confidence, the scientific committees that gave advice on these matters were all brought together in the consumer directorate , DG 24, comprising 140 experts in nine committees.

The advice they offered the Commission was in the form of opinions which were available to the public and could be criticised, attacked and so on. In Denmark we must discuss the many different modes of openness and how to use them in practice.

Peter Skov:
I would like to add something to my initial question. With all due respect, the EPA’s publications regarding risk assessment will probably never make it to the best-seller list. When we talk of risk communication how will the basics in risk assessment be communicated comprehensively to the public?

It may seem a little naive, but if we consider your presentation of the American way, the first step was to call attention to the problem, the next step was an assessment and finally there was some form of action. This is a fairly simple procedure, but I know in fact it is not simple no matter how it is done. At some point there must be some input on how to see, assess and lay down regulations. The EPA’s risk assessments are quite advanced technical reading, and it is my judgement that they are not exactly the media’s, nor politicians’, most quoted sources of information.

Ib Knudsen:
The weekly terror stories shown on TV actually deal with this problem. Here, we see a great many Danish experts trying to communicate some things more or less successfully, depending on what your personal opinion to each case is.

Television plays a very important part, but, other than the formal risk-management process, I think the authorities have to be better at involving many interested parties, and releasing questions for the general public to consider, before actually reaching an administrative decision. The Internet and e-mail have enabled the quick dispatch of assessments and proposals to a great number of people who can then express their opinions regarding the matter, thus provoking debate. I think that is the way to go about it.

Can risk analysis be applied in connection with the precautionary principle?

Poul Harremoës
Professor in Environmental Technology at the Danish Technical University

Thank you for this opportunity to speak about the precautionary principle. It is exciting that as a direct result of what has already been said I have obtained a reasonably clear understanding of what is meant by the three last concepts, that is, preventive efforts, intervention at source, and the polluter pays. On the other hand, I am relatively confused about what is meant by the first concept; the precautionary principle. My point of departure is therefore that confusion is greater than understanding in relation to this principle.

If we talk to people on the street about what the precautionary principle is, we can easily receive the banal reply that it is something to do with taking precautions. If we talk to someone who is a little more in the know, they will say that it is something to do with better protection of the environment and that, in fact, is quite a sensible reply. If we ask the experts, the most frequent reply is that the precautionary principle is a desire to shift the burden of proof from the complainant, who previously had to prove that a given action was harmful, to the defendant, who must prove that the action is harmless, that is a shift to the polluter. A shift of weight which I will take as my first point of departure for closer analysis.

EU 1992: Principles The precautionary principle Preventative efforts Intervention at source The polluter pays

What does the principle say? The precautionary principle shifts the burden of proof: from the complainant to the polluter

Claim: The substance is harmful It is difficult to lift the burden of proof. Only one example is enough - then the theory is proven.

Claim: The substance is harmless This burden of proof cannot be lifted. It impossible to say that all circumstances have been investigated. This can only be made likely by induction - (experience). Just one contradiction falsifies the theory.

I will discuss two instances at both ends of the scale. One involves a claim that the substance is harmful. Now, we assume that we have fully clear criteria. Should there be a ban or not? In this instance the burden of proof for the claim can be raised. In fact the claim can be proven. If we conduct sufficient investigations, we can prove that the criteria laid down have not been complied with. So the substance is harmful, and as a result should be banned. It is immediately more complicated to raise the opposite burden of proof: ‘the substance is harmless’. Harmlessness cannot be proven. There is so much harm which can be caused, and so much harm to children, the weak, the elderly, ecosystems, rare species, or similar we do not know about yet.

A claim of harmlessness can only be made likely by induction, which in scientific theory means experience. I would like to offer an example of this, as it is certain that there are several who are strangers to this view. In order to be sure that everyone understands, I would like to refer to the philosopher Popper, who in 1972 wrote a book on philosophy which gave an example. If you look at swans in Denmark you will see that they are white. As a result of travelling in Denmark you could think that swans are white. You could perhaps be tempted to claim that all swans are white. In order to test this hypothesis you could go to Europe and onwards to America and Asia. You will still find confirmation of the claim by induction, but in Australia there is an exception, for there are black swans. The claim was wrong!

This is induction. It is not a result of deduction; it is a result of experience. In this way the attractive statement of shifting the burden of proof suddenly stands in a completely different light. Therefore, as a direct result of what has been said, I am of the opinion that it is a question of confidence. It is showing likelihood, not proof. Lawyers will possibly say circumstantial evidence.

Sufficiently appropriate procedures are in this way decisive factors in developing confidence. My last claim is that in recent years there have been too many contradictions which have broken down confidence. This is, in fact, the fundamental problem facing us. As an example of how the precautionary principle can be interpreted, I have chosen a quote from the North Sea Convention. ‘Discharges of a substance which can lead to serious damage should be limited as far as possible, even if there is no scientific evidence of a connection between the discharge and its harmful effect on the environment.’

We have heard this many times, but I would like to highlight the word ‘evidence’. Now we are at the end of the scale where we can, in fact, produce evidence, rather than the opposite end where we cannot. At this end of the scale, where we can produce evidence, we do not need to. That is, at both ends of the scale it is only necessary to show likelihood as a basis for the decisions we are talking about. Therefore the precautionary principle is not a mantra which can be called upon, a deus ex machina which can be called up as a magic potion to provide a scientific absolute. It is a consideration which ‘builds on’ things, and not a fixed dimension which can be called in or ignored at will. In this way I am entirely in agreement with Ib Knudsen in that it is an overall principle which shifts attention but which has been there all the time. We cannot have risk assessment without its presence as an overall principle, no matter what the problem.

If we now are to follow this up with evidence, of which there is not much left, then what is the consequence of shifting? It is that this shift makes it obvious that it is the polluter who must make efforts to show that it is likely that a substance is harmless and to create the desired confidence. This is not what is happening today, but can it be done?

As part of the ‘competition’ here amongst those holding lectures, on who can cite the precautionary principle furthest back in time, I will beat everyone by saying that it has, in fact, applied for 150 years. This is an example of how the precautionary principle has worked and still works. Over 150 years, water supplies have been made so that we can open a tap and drink the water without becoming ill. And the Danish population has confidence in this, despite the fact that now and then accidents happen, such as in Uggerløse some years ago. This occurs when an engineering student did not pay attention at the first tutorial on technical hygiene when it was said that a prerequisite for uncontaminated water supplies is that there is always complete separation between dirty and clean water, and this can sometimes not be the case.

Confidence Make likely by induction. Sufficiently appropriate procedures to create confidence. There have been too many contradictions for too many years.

Declaration of Sustainable Development in the ECE, 1990 Quote: ‘Discharges of a substance which can lead to serious damage should be limited as far as possible, even if there is no scientific evidence of a connection between the discharge and its harmful effect on the environment.’

Showing likelihood Therefore, likelihood must be shown at both ends of the scale. There is a balancing of relevant considerations. This must be done in a way which creates confidence Traditional risk analysis is too esoteric to satisfy this demand.

The precautionary principle - what is it then? All that is left to ‘prove’ is: The polluter must demonstrate the likelihood of harmlessness and create the desired confidence.

An old principle, but: We have 150 years’ tradition of precaution with water supplies so that disease from water is rare. The population have confidence in water supplies with regard to contamination, despite occasional accidents. Today, ‘idealists’ are trying to save water with new installations which increase the danger of contamination. They believe that the authorities must show the likelihood of harmlessness although the ideas come from the ‘idealists’.

Risk of errors The precautionary principle should manifest itself as a demand to assess the uncertainty and consequences of possible errors.

Assertion Harmless: What is the uncertainty and the consequence of error? (the false negative) Harmful: What is the uncertainty and the consequence of error? (the false positive) Balance

However one looks at it, the decision is political - hopefully based on appropriate information to aid in balancing.

Categories of error Determinism Calculated risk Uncertainty Ignorance Unpredictability

If we measure the coliform index of water, the precautionary principle crops up again. It starts the great hunt for where the bacteria came from. Until this is found we are unable to drink the water without boiling it. This has worked satisfactorily for a 100 years, even though everyone recognises that there is a risk. If you wish to expose yourselves to this risk, then travel to Cairo, open the tap and take a slurp! Then the precautionary principle is inverted. Today, some people who wish to save water, that it for environmental reasons, will set up installations in buildings so that unpurified water comes into close proximity with clean water with the undoubted increased risk that they could come into contact with each other. When bodgers do this in their own home, the risk is increased.

Now comes the interesting point. The people who make these installations expect the authorities to prove the harmlessness of them. In my opinion, the precautionary principle would say that they should do this themselves. This is an interesting point of view which could possibly help the authorities to handle these ‘idealists’.

There is no doubt that with this example I have diluted the content of the precautionary principle considerably. I would like to develop it by wording the principle in another way. There is a risk of error.

The precautionary principle should manifest itself as a demand to assess uncertainty and the consequences of possible error. I will do this by again addressing two assertions. The assertion of harmlessness and the assertion that it is of harmful.

In both cases: What is the uncertainty, and what are the consequences of error?

In the first case, this is called the false negative, in the second the false positive. In all situations it ends with a question of balancing the fact that we do not know things well enough. This means that ultimately there must be a political decision and there are examples of how earlier these political decisions took place behind closed doors. We heard of white smoke as part of the process once the experts had finished bickering. During this process, which I think the lawyer spoke about well, the decision is hopefully based on very specific knowledge which can be provided by specialists, technology, science, and so on.

After this I cannot help bringing up a number of categories of error. We must now analyse explicitly what could happen if we made an error. We do not like admitting this, but like gymnastics, it is healthy.

Let us start with determinism, which assumes that there is a crystal-clear connection between the influence and the result. It is never found in practice, but is an ideal.

We can make a calculated risk which is that we know the uncertainty, we can quantify it, and we have the statistical tools to treat it in an appropriate manner. This is a well-established discipline which is also applied in risk analysis.

After this I talk about uncertainty. This is where we have identified the uncertainty, but we have no data to quantify it. Therefore we must go over to a qualitative assessment of how we will stay on the safe side.

From this we move straight on to ignorance. An example is the oestrogen-like effects which no one knew of five years ago.

To be a little provocative, what will come up in the next ten years? It will clearly be a problem which we will have difficulty in addressing, but which some will want us to make a decision on.

It is even worse with unpredictability, and here I am not thinking of the weather forecast, or chaos theory. We learn that we must consider many things in the future. The question could be put, can we predict at all what will happen when under sustainability we must ‘consider the possible consequences for future generations’? This can only be done as an extrapolation of our own daily lives.

Imagine that someone at the turn of the century had to carry out actions which took account of how we have turned out today, and do this on a basis that was known in the 1890s. There would be a great deal of guesswork, and I regard the two last factors - ignorance and unpredictability - as fundamental in this problem. How can the precautionary principle be applied when we do not even know what it is about, and can not predict social conditions in 50 years?

In the European Environmental Agency we are working with this based on what is called the D.P.S.I.R approach. Here we find our driving forces, that is our desires for well-being, for example to drive a car, through pressure on the environment. What does this lead to in our surroundings, that is, what impact does this have on us and ecosystems? Then there are the responses which in society we arrange in the light of an objective based on criteria and indicators with which we can intervene at all levels. Here is an established way to view this which is reminiscent of life-cycle analysis, but which is based on society’s view, not on the manufacturer’s view of its product. About the connection between ‘measure’, ‘state’, and ‘impact’, I will say that one must add a certain measure of causality to the concept if it is to have any meaning at all, and this has in fact been said already.

Balancing usefulness against damage. I dare make the assertion that people are well acquainted with the likelihood of damage in many cases. Smoking has been mentioned, or what about driving? I drove here in my car this morning. The risk of doing this in the Copenhagen traffic is greater than anything else I expose myself to during the day. I choose to drive despite this knowledge.

The other factor has already been mentioned by Erik Lindegaard. People react when uncertainty is involuntary and usefulness is doubtful. I do not believe that people are as stupid as specialists make them out to be.

The DPSIR approach to environmental management Criteria, indicators, targets Ultimate objectives Driving forces Responses Pressures, States, Impacts Physical, chemical, and biological cause-effect relationship Usefulness against damage People can be well acquainted with the likelihood of damage: Smoking: Smokers know the damage and accept the risks Driving: We all know and accept the risk Usefulness against damage People react when the risk is involuntary and usefulness is doubtful. Examples: Pesticides and nitrates in drinking water and mad-cow disease to make agriculture which over produces more efficient.

The example of pesticides and nitrates in groundwater has already been mentioned, and the same applies to mad-cow disease. These things in my opinion also relate to the fact that usefulness has something to do with agriculture which over produces at the same time as it pollutes in order to become more efficient. People well realise this. In the case of mad-cow disease, I am sure that most of the Danish population realise that the risk is incredibly small. However, it is unacceptable when we hear that it applies to us because cows must eat the corpses of other cows. I have a certain sympathy with this. Usefulness and damage come into play when assessing the risk one wishes to expose oneself to. Therefore, I will stick my neck out with the following statement of the criteria for intervention:

Probable fear of serious and widespread damage which outweighs other social consequences of intervention.

If you think that this is nebulous, then in my opinion it is a reflection of the changed emphasis in the balance in a process where one cannot claim to have precise scientific solutions. However, one can hopefully obtain data and information as a basis for this balancing.

I have two things to say about risk analysis with which I would like to influence the debate in a way which I hope does not sound too critical. One is that traditional risk analysis is very reductionist. It must go into detail in order to be extrapolated to an assessment. There is a need for wholes, I call them patterns, and we could discuss this for a long time. The second thing I would like to say is that traditional risk analysis is too esoteric. Ib Knudsen said a lot about this, and we agree that we must go this way.

Finally, for some time I have been renewing the precautionary principle because I think it is nebulous. In the Scientific Committee in the European Environmental Agency, we have gathered the best minds in Europe to outline a theoretical foundation. The objective is to come up with a system which will contribute to the ultimate political balancing.

It is about a theoretical outline of examples from the past ten, twenty, perhaps 150 years of how it has, in fact, worked, when it has gone wrong, and when it has been successful. We have taken the initiative to arrange this, and if there is anyone who can give me some good advice, I would like to hear it. We are arranging the first meeting in the autumn, so there is still time to make a positive contribution.

Finally I would say that, in order to develop this at European level in the European Environmental Agency, it would be exciting if we could form a Danish backing group, for example with speakers from this hearing, so that there is input from Denmark as part of this European analysis. I will gladly accept comments.

 

Question time with Poul Harremoës

Peter Skov, the Danish Confederation of Industries
You said that there were not adequate appropriate procedures to create the necessary confidence in the decisions which are made based on the precautionary principle. However, before you further explain this, I would like to mention something which you said, and try to justify it.

In your discussion of the burden of proof, you concluded that the polluter must show how likely a result is. If it were true that in a court of law one could show how likely one’s claim were, I would agree with you that this is a simple solution to the problem. However, the fact is that things must be solved by a political process, we have agreed on this today. Politicians must make decisions, and when they consider our topic today, they probably have the same confidence in the statements of industry about the state of the environment and impacts on the environment as the public have. And I can say that this is not especially great.

Therefore, politicians employ experts in authorities and they pay researchers. What is the role in this debate of particularly the latter group, to which you belong, apart from delivering profound works?

Poul Harremoës
Thank you for your confidence in our profound works! You ask first what basis I have for stating that the procedures must be improved. This is purely inductive. There are many conflicting examples of people’s political opinions and what they will tolerate. We must join in helping risk analysis advance by making more analyses - and here I think it is more the social aspects than the chemical and biological. This is my reaction in reductionist practise.

The report which was issued three years ago in England called ‘Risk’ has two concluding paragraphs. One is a traditional risk analysis, and the other includes a social element. Each wrote their report, and each made their interpretations with their own specific scientific bases. They were never able to agree during committee work. Bridges must be built between the two parts.

It is relatively rare to see a report from the Royal Society in England where the groups so totally disagree. This made interesting reading, based solely on this view. My claim is that we must help to get this going by widening each horizon, but this is purely inductive. It is not deductive that this is the basis for saying there must be improved procedures. It is simply by observing the effects over the last ten years. I do not know how we should tackle this precisely, but the precautionary principle must play a part in such a development, as well as inter-disciplinary co-operation.

With regard to the role of researchers, then Peter Gjørtler’s words as a lawyer were perfect. It is lawyers and courts which say this. It is not specialists who must make political decisions.

Peter Skov
That is just what you should not be doing………

Poul Harremoës
Yes, but I have a reason to say this, also through induction. Peter Gjørtler’s wording is entirely correct. Specialists offer, hopefully, the most objective input they can, so that the political and administrative system have a basis for finding a political balance which some specialists also like to contribute to, but which they are neither qualified nor responsible to do. In this regard, for many years I have said - and shocked many of my colleagues in doing so - that experts are dangerous.

Lone Johnsen, the Danish Society for the Conservation of Nature
I agree that, although we in Denmark, and especially at EU level, have taken many initiatives, the current chemical legislation and regulations in Denmark have to a great extent gone wrong. It is positive that this perception is not merely shared by the green organisations, but is also discussed in the Council of Ministers and in the Commission. Three weeks ago there was a meeting of Ministers of the Environment where it became clear that the Commission had already been asked to provide a draft for a new framework directive on regulation of chemicals in the EU.

Further to what Peter Skov has said, this is at least proof that the chemical industry must also look forward to ‘a whole new ball game’ and the industry has perhaps not done so well in this process up to now.

What would you emphasise in a new framework directive for the chemical area? You started on something important that natural sciences and social sciences must be combined with a view to operationalising this area further. Do you have some good examples that this has already happened, or are we starting from scratch?

Poul Harremoës
I would like to answer that in two years’ time, as a result of the initiative we have taken in the European Environmental Agency to make this analysis. Furthermore, I am not so sure that we need more fine declarations on principles.

Rather, we need to interpret the principles which already exist, and apply them in a practical and common-sense way, in accordance with the principles, so that we pave the way for their administration. The problem is only at the level that we need support. Just as environmental employees in a private company need support from the board. Things happen at a lower level, but we can not get things done here unless there is support from above. This is already happening in industry to an impressive extent.

Ole Vinther Christensen, GEUS
You talked a lot about the logical, the rational, and the irrational. In the Ministry of Environment and Energy we have looked at media treatment of these things. I share your observations about confidence. In certain areas we can see that the press are irrational. It is very good that we, as engineers, make some rational procedures which are published on the Internet. But, when we see that the media are irrational, I would like to hear your comments on this situation, on how we can tackle the irrational elements, and, if I may say so, how we can control them.

Poul Harremoës
You cannot control them. I think that I can briefly come up with an answer. By beating them to the post in the long term. I can give a good example of this. I have taken part in relationships between NGOs and stakeholders in Hong Kong, Sydney, and Auckland.

I will not speak further about Hong Kong and Sydney as the situations here were hopeless, but I was very impressed in Auckland, New Zealand. In connection with extending a very large sewage plant, relationships were developed to all stakeholders who had any interest or desire at all to take part. These relationships were built up over many years.

This meant that no one was surprised that the press could not come up with any great controversies. This was not possible, because those with an interest in the matter had already been fully informed. It was extremely impressive co-operation, and I can recommend anyone who is interested to take a trip to New Zealand. However, I would not recommend Australia, and certainly not Hong Kong.

I would claim that here in Denmark we are nowhere near. If we suggested to the Lynette sewage works, which I have close contact to, that we should work with the stakeholders for three years in order to build up such relationships, they will shake their heads and say, " this is not part of our normal practice". In this regard we are ahead of Australia and Hong Kong, but far behind New Zealand.

Hans Sanderson:
What changes in recognised theories in natural and technical sciences are necessary in order that we may achieve these sustainable solutions, and in order that ignorance and unpredictability can become relevant subjects in a scientific debate, and not subjects to be avoided all the time? In this way integration of natural and social sciences would be achieved, instead of merely parallel co-operation. I believe this is vital if we are to meet these challenges within risk assessment and regulation.

Poul Harremoës
This question is so interesting, that unfortunately I have no answer to it, just some comments. Firstly, I do not have much respect for people who speak with great confidence of how the population and its needs will develop over the next 100 years. Everything can change in this time.

On the other hand, I believe that from what you said, with a scientific approach, it is possible to ascertain some things which will apply, even at that time. That is, we can tackle some of the fundamental things.

It may sound far from social aspects, but I can guarantee that Newton’s laws will also apply in the year 2100; thermodynamics will also apply. Induction over many years make it safe enough for me to make these predictions. Are there corresponding social, economic, and legal rules that we can be just as certain about in 100 years? I do not think so.

No one has made this analysis, and it would be extremely interesting to do so. If it was prepared and published, the author would be criticised immediately, as it is an incredibly complicated task. I have no solutions, but you hinted at the appropriate direction in your question.

 

Can economic theory be applied in connection with the precautionary principle?

Peder Andersen
Head of Secretariat, the Economic Council

When economists meet non-economists, it is hard to accept the fact that environmental benefits can also be considered as consumption benefits, benefits to investment, or frameworks for production. My point of departure therefore, is that the environment should be perceived as a benefit or a framework for future consumption, investment, and production opportunities.

It will also surprise some that economic theory supports the view that it is important to take care. Application of economic theory in this connection corresponds to what we say to our children when they ride their bikes. "Watch out when you cycle in traffic. Leave in good time and cycle slowly because you don’t know the way." When they come home and say, " that was no problem, it was easy to find the way, and there were traffic lights at all the junctions", then we can say, "OK, then you can go a little later next time and cycle a little faster".

A corresponding balance is the point in economics. By cycling slower when we approach something unknown there is a price because we do not advance quickly, and because we are perhaps a little bored on the way. However, we create/buy greater security at the same time. This balance can be explained more precisely using economic terms and considerations.

An economist’s view of the precautionary principle is that it states the fact that when a decision is to be made, account must be taken of the extent and nature of risk and uncertainty. That is, risk must be included, and risk must be distinguished from uncertainty.

Account must also be taken of risk aversion, that one is a little careful because one does not want to just apply average consideration or an almost deterministic model. In addition, account must be taken of the conditions connected with sustainability, namely distributing resources between generations.

I do not wish to address the whole discussion on strong and weak sustainability, but I will just emphasise that there are four factors (risk, uncertainty, risk aversion, and distribution between generations) which must be considered when balancing or setting priorities for costs and benefits.

The answer to the question, "is economic theory relevant to the precautionary principle?", is, "yes". Why? Because economists know a lot about actuarial theory and option theory, i.e. how to establish future possibilities. They know a lot about portfolio theory, that is how to put a number of options together. Finally, they also know something about sequential decision-making, and I would like to talk about this in a little more detail.

Some believe that if, in some way, one has perfect knowledge, not so that the world becomes deterministic, but that one has a distribution of probabilities which are known, then one can merely apply normal deterministic models. But this is not certain. By being cautious, one buys an option, a future possibility, from which one will be able to benefit.

The fundamental idea in applying the precautionary principle is to increase possible future choices. Everyone also knows that if we wish to increase these, then there is a cost. When we buy insurance, we pay a premium, but what do we get? In fact we increase our future choices because we insure against accidents, and others are willing to take on this risk.

Can rational decisions can be made based on the precautionary principle, without applying economic theory and methods? The answer is "no". I will only talk about the theory, but of course the methodology is also relevant in implementation. The fundamental environmental-economic model can be used as a starting point. In the deterministic simple one-period model, the marginal damage from contamination (F), and the marginal cost of reducing contamination, can be reproduced (see figure 12). That is, the more we wish to reduce the contamination, the more expensive it will become, marginally. Economists focus on optimal contamination, Foptimal (the intersection). At this point marginal damage and marginal cost in preventing the damage are the same. With this model the precautionary principle can be discussed in other situations.

The next figure, (see figure 13) can be read in the following way. The figure resembles the previous figure. However, now we have: expected marginal damage, the best estimate of the damage, given current knowledge. Suppose we now have a known probability distribution for the damage, in this way we can find the expected value. The distribution is drawn in a three-dimensional space. Optimal contamination under risk-neutrality for a rational decision-maker will be at point F*, corresponding to contamination with complete certainty.

And why is this? Because, for the rational decision-maker, with no risk aversion, the rational choice will be the choice which maximises welfare. Risk-neutrality is often the case because there are thousands of decisions for society to take, and in the long term they counter balance each other. This is perhaps not true for the individual, who can go bankrupt, For the State, which must take many decisions, however, it will be rational in the long term to apply expected values if there are sufficiently many projects.

If there is already some form of risk aversion, the precautionary principle will be manifested in that one will take out insurance. That is, one will avoid the difference between the cost of reducing contamination and marginal damage becoming very big. The model is designed so that it covers 90 per cent of the probabilities, but there is also a five per cent risk of things getting even worse. So, the optimal decision will be to place oneself somewhere to the left. How far to the left of F* this is, depends on how risk-averse one is.

In addition to this there is the situation where one takes account of future generations by giving them options. This will pull us further in the same direction. This is straight from the text books. It is a quite simple theoretical method of interpreting the precautionary principle in economic theory.

The next problem is uncertainty (see figure 14). In this case we cannot set a probability distribution, even with expert knowledge. Uncertainty has many different aspects. It can be ‘yes/no’, i.e. things will go completely wrong, or nothing will happen. Here we can perhaps set probabilities, but if so, they are probabilities which can very quickly change with new knowledge.

The figure shows a simple model: marginal damage is known up to a given point, (F)threshold, but to the right of this point we do not know what happens. Things can go completely wrong and damage can be very extensive. For purely pedagogical reasons I am only discussing uncertainty of damage.

If things go completely wrong, then the function goes up vertically. As shown on the model, it is assumed that marginal damage does not fall at the same time as contamination increases. However, this can in fact be the case, for example, if a lake and stream are already lifeless, it does not matter much if more contamination occurs.

Figure 12

Figure 13

Figure 14

We have therefore the curve marginal threshold cost, and if we have this picture, it is not easy to see more than that the precautionary principle will draw us towards the threshold value.

If we imagine that new knowledge becomes available, the (F)threshold value moves. If we apply the precautionary principle according to the threshold value, but at the same time intensify research, it is possible that we will obtain important new knowledge. For example it can appear that it is better to contaminate a little over the threshold value, a completely absurd idea for non-economists, that it could be good to pollute more. This is because non-economists forget to think about the pleasure involved in activities which in fact create pollution, at the same time as the damage now appears to be less that at first assumed.

What is important here is sequential decision-making. If it is possible to obtain new knowledge in the future, there is in fact something to be said for being careful now, while investing in new knowledge. This is also the reason that some economists say that in a number of areas it is better to search for new knowledge rather that spend money on combating pollution.

The important thing about protection is to create options. At society level this means that society must ensure options by making regulations today, but the other important thing is that when new knowledge comes, it does not necessarily follow that environmental regulations must be tightened. It could very easy follow, that on the basis of new knowledge we can relax environmental regulations.

This presentation has been extremely brief, and the form of the presentation has not been entirely loyal to the text books or journals. However, I believe that I have outlined some central elements which provide a foundation for understanding the following main principles.

1. Increased uncertainty involves tighter environmental policies.
2. Increased risk aversion involves tighter environmental policies.
3. Increased emphasis on future generations involves tighter environmental policies, but this will cost the current generation.
4. Increased irreversibility - i.e. the more difficulty the environment has to return to its normal condition, the tighter environmental policies must be.
5. It is important to calculate the social-economic costs of applying precautionary objectives. Precaution is not free, it is not a free benefit as some believe. There are perhaps areas where it is almost free, and it is important to identify these areas because benefits must be reaped here immediately, rather than addressing areas which are more expensive.
6. It is important to calculate the costs of reducing risk and reducing uncertainty, and it is important to calculate the benefits of such reductions.

There is thus recommendation that when we set some goals, we must at least try to identify what they cost. In fact there are some economic models, including some general models of equilibrium which can be applied. In the Economic Council we have tried to calculate the costs of CO2 goals.

My answer to the question which was raised in connection with my talk must be, use as much factual knowledge as possible. Use of knowledge reduces social-economic loss. Increased use of the precautionary principle is for the common good, free for the individual, but not without a social-economic price. We must recognise that increased demand for certainty means higher taxes and/or reductions in other public services. We must make priorities.

There is imperfect natural-scientific and social-scientific knowledge of the cost-benefit analysis, but we cannot justify writing off such analyses. We must concentrate more on producing knowledge and methods. Therefore, basic environmental-economic research should be offered higher priority.

Question time with Peder Andersen

Jesper Hermansen, Danish Environmental Protection Agency
It is interesting how in practice one can make cost-benefit analyses when addressing some narrow risk balances. You did not say so much about this, apart from that there is still a great lack of social and economic knowledge on this point.

It is very interesting for further discussion of the precautionary principle to decide, what is the state of the art of using economic methods in assessments? When, as an authority, we must make decisions, what are the social-economic consequences of either making a decision, or not making a decision? How do you assess the current situation, and what do you think the trends are in this discipline?

Peter Andersen
I fully recognise that it is not easy the make benefit calculations, that is, attempt to put monetary values on the benefits of reducing contamination or uncertainty. On the other hand, on the cost side I believe that for far too many years the authorities have tried to calculate costs based on the costs of fulfilling these things.

Last Monday, there was a discussion in the Ministry of Finance on the environment and environmental assessment in the Finance Act. It is my opinion that we can come a long way towards putting figures on the cost of fulfilling some specific environmental objectives in the same way as we can put figures on so much else we invest in or decide on in society.

On the benefit side, we are moving into the same world when we must look at what the social benefits actually are of treating people in hospital. We can easily do this by considering the value of death. We can calculate what a death costs using some specific methods. There is no one who will accept this, but the simple method is to say what does the person’s loss mean to future production? In addition there is the question of what the person himself would have paid to avoid death.

This is also unacceptable for two reasons. Firstly, it does not place sufficient emphasis on the future because this is not part of demand. We must say that we ourselves are willing to do a lot in order to get him to do something. Secondly, it is unacceptable because income distribution plays a far too important role.

Cost-benefit analyses are justifiably ridiculed when we see some important recreation areas destroyed to make way for golf courses. A cost-benefit analysis can simply show what is rational because golf players have greater incomes than others. Demand for a free area to be converted to a golf course is greater than demand to make it normal parkland for people to walk in because, in contrast to a golf course, it is difficult to issue tickets as there is no entry price.

So, I am entirely in agreement that we will never reach home in this area. But, instead of jumping into very advanced things on the benefit side, I think that the first step is to try to use expertise to present some cost calculations and leave the rest to the political process.

There are a number of American and other studies where in various ways there are attempts to calculate the benefit of these things, and I do not underestimate their theoretical foundation. I am merely very doubtful about their practical application. There are such things as people’s willingness to visit and be close to recreational areas.

The questionnaire technique is what I most believe in, where in some sort of sneaky way we find out about people’s willingness to pay. I would just like to repeat that if we all consider these things as free benefits, then demand for them will be much greater than it would be socially rational to supply. We can promote popular awareness of these things, if it is done in an appropriate way, but I do not believe in a referendum on them.

Peter Skov, Confederation of Danish Industries
I entirely agree with considerations of the cost side, but if we look at the benefits, you only mentioned the environmental benefits, and not those connected with using a substance, a product, or in your own example, a car.

So, my question is, when you calculate benefits, is it just as difficult to calculate the value of walking in the forest as to calculate the benefits of driving a car?

Peder Andersen
This must be attributed to my lack of precision. The overhead on marginal costs by reducing benefits contains what you are looking for. You say that by reducing pollution we must take measures which can either cost something, in the form of pure clean-up costs, changes in production, changes in consumption, etc. However, you are right that they are not all equally easy. Pure clean-up costs are very easy. But most will suggest that activities are not in the form of cleaning up, but rather preventive or protective activities.

Peter Skov
Some of the benefits we are speaking about are almost as intangible and idealistic as the benefits of a better environment.

Peder Andersen
You mean that some of the costs to be put into the formula can be just a difficult as the benefits? This is true. We have a mass of studies, for example on traffic, which to some extent or other are based on travelling time.

Take all the cost-benefit analyses and other analyses which have been made on the Great Belt bridge. Reduced travelling time is included in these, and one can use hourly salary after tax, or the price of leisure time, or other factors, but there are many other situations where we have a reasonable idea what people are willing to pay for time. A number of studies have been made to explain the demand for dishwashers by time saved. Here there are some good examples of what people’s time is worth. Or time at the limits when people scream and shout if child-care facilities close half-an-hour earlier.

But I agree, and therefore my final overhead showed that in Denmark we are poorly equipped in this regard, so the concept of utilisation-oriented environment and economy is weak against other arguments which are not quite as scientifically well-based.

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