The SMS approach: from ethical issues to providing practical guidance

Bishop, 1978. The SMS approach is argued to apply in situations involving true Knightian un- certainty and irreversibility, but actual applica- tions remain rare. Appeals to the SMS approach are common in discussions of sustainability Folke et al., 1994Turner et al., 1994Castle, 1996, often with respect to protecting at-risk species and biodiversity Randall, 1991Bishop, 1993. In applying an SMS approach to protecting an at-risk species or set of species, the burden of proof lies in demonstrating that the economic consequences of preservation activities are intoler- able. What constitutes intolerable is to be decided by the social or political consensus process in any particular case Farmer and Randall, 1998. How- ever, investigation of the types of considerations that might constitute intolerableness is critical to the SMS approach as a pragmatic policy tool. Following Randall 1991, invoking the intolera- ble cost argument to circumvent preservation ought to require some ‘extraordinary decision process’. Several sources have noted that the general structure of the ESA, as amended, is consistent with the SMS approach Castle and Berrens, 1993Woodward and Bishop, 1997. In reviewing the lengthy ESA process for the northern spotted owl in the Pacific Northwest, Thomas and Verner 1992 p. 637 make a similar argument, albeit without explicitly identifying the SMS approach and see Booth, 1994 p. 238. For the case of endangered fishes in the Colorado River, Berrens et al. 1998 use the results from federal court-or- dered US Fish and Wildlife Service USFWS implementation to illustrate how the ESA was consistent with the SMS approach. Specifically, in the exclusion process for designating critical habi- tat, the lack of severe economic costs was deter- mined by comparing expected aggregate regional economic impacts against historical fluctuations in the regional economy. However, this step to- wards implementing the SMS approach fails to incorporate distributional concerns, which may be important in defining intolerable economic costs of species preservation actions. Endangered spe- cies debates are often focused on the distribution of economic consequences Brown and Shogren, 1998. Randall and Farmer 1995 acknowledge that an SMS approach might be amended to included distributional considerations. The case studies involve results from previous economic analyses done by or for the USFWS in two prominent ESA cases: 1 endangered fishes in the Colorado River; and 2 the northern spot- ted owl in the Pacific Northwest. These cases illustrate the general link between the ESA and the SMS approach, but also bring out the impor- tance of including distributional and compensa- tion issues in considering what might constitute intolerable costs.

2. The SMS approach: from ethical issues to providing practical guidance

Irreversible species losses involve intergenera- tional equity issues Norton, 1987. Present value benefit-cost decision rules neglect fundamental ethical issues such as intergenerational allocation of natural assets. Thus, it may be necessary to go beyond standard efficiency criteria Bishop, 1993. One widely discussed alternative to standard benefit-cost analysis BCA is the SMS approach. While the SMS approach begins with the assump- tion that preservation of at-risk species is a priori beneficial, there is no ‘trump card’ Randall, 1991. With respect to protecting natural capital assets for the future, the SMS approach has been viewed as falling between ‘strong’ and ‘weak’ sustainability perspectives Turner et al., 1994. The SMS approach is a conditional imperative, recognizing the need to protect ‘critical’ natural capital e.g. species habitat, but remaining sensi- tive to costs. Bishop 1980 p. 209 frames the ethical decision problem as: ‘To what extent is it fair for the current generation to bear costs in order to reduce uncertainty faced by future generations?’ Given this ethical decision problem, the condi- tion that economic costs not be intolerable is typically represented as an aggregate condition under the SMS approach. But if costs are borne unevenly, then grappling with the notion of what constitutes intolerable costs may involve current distributional considerations, and potential com- pensation for those adversely impacted. Concern for intragenerational equity is motivated by the same ethical mandate of fairness distributive jus- tice as that underlying intergenerational equity Folke et al., 1994. Farmer and Randall 1998 argue that trying to resolve our obligations to the future while weigh- ing current interests imposes a ‘responsibility to seek consensus’ across moral arguments; thus, a shift away from strict benefit-cost decision rules is not logically inconsistent. Certainly, potential ir- reversibility coupled with a high degree of uncer- tainty and complex environmental goods that are not priced and traded in markets imposes an exceptional burden on regular decision-making processes. 1 Standard BCA assumptions may be violated. BCA is strongly consequentialist and welfarist Berrens and Polasky, 1995Randall and Farmer, 1995, requiring identification of all out- comes, assuming complete individual preference orderings, and depending on accurate measure- ment and aggregation of individual values. Assigning monetary values to species preserva- tion benefits may be especially problematic. Both supporters and critics of nonmarket valuation, including controversial applications of the contin- gent valuation CV method to measure nonuse values, call for further exploration of the SMS approach Vatn and Bromley, 1995Loomis and White, 1996. In their recent meta-analysis of endangered species CV results, Loomis and White 1996 argue that there is important systematic information about preservation benefits. How- ever, acknowledging various composition and adding-up problems, they stop short of endorsing the use of such values in strict benefit-cost deci- sion rules, and instead support an SMS approach to protecting endangered species. Others argue that a valid SMS approach should necessarily require the measurement of preserva- tion benefits including nonuse values in the defining the net social costs of preservation e.g. Crowards, 1998. 2 While one can support the logic for including estimated species preservation benefits in defining net social costs, the practical concern lies with validly estimating nonuse values. Economists remain highly divided on the validity of CV for estimating nonuse values Diamond and Hausman, 1994Hanemann, 1994. As indi- cated by recent history with natural resource dam- age law Jones and Pease, 1997, the potential for formally requiring inclusion of nonuse values in ESA economic analyses would appear unlikely. 3 Whether or not the full range of nonmarket and social values are included in defining the net social costs of preservation actions, the protection offered by the SMS approach is not absolute, and this poses a conundrum. An SMS approach ini- tiated out of concern for incomplete articulation of our obligations to the future, and even current social policy objectives 4 , must be checked by a measure of what costs are tolerable. As such, the SMS approach often appears to be a muddle through process Hohl and Tisdell, 1993Rolfe, 1995. This might appear to leave real world practi- tioners with little guidance, and condemned to oversee a slow, cumbersome process. But, by not 2 Crowards 1998, p. 308, argues for including the ‘rela- tively near-term quantifiable benefits’ of preservation. Gowdy 1997, p. 38, argues to extend the SMS to include the preser- vation benefits of ‘evolutionary potential’. 3 Brown and Shogren 1998, p. 13 argue that despite ex- traordinary analytical difficulties, ‘‘determining at least a plau- sible range for these values would seem to be essential if we are to make judgements about the benefits of preservation.’’ Berrens et al. 1998 argue that while the SMS approach is not dependent on nonmarket valuation information, estimates of preservation benefits could be considered within the ESA process, as a kind of separate piece of economic information which may have its own distributional issues. Further, if economic studies are impact analyses, then this presents ques- tions of consistently combining with estimates of preservation benefits. 4 For example, a recurrent ESA policy question is what is the exact preservation objective e.g. individual species, ecosys- tems or genetic diversity? Metrick and Weitzman 1998 provide evidence that agency actions have tilted toward pro- tecting ‘charismatic megafauna’. 1 Several recent theoretical investigations provide support for the SMS approach as rational public policy in situations of Knightian uncertainty and irreversibility Woodward and Bishop, 1997Palmini, 1999. taking seriously the ambiguities that initiate con- sideration of the SMS approach, attempts to rec- oncile to pre-articulated social objectives miss the point. Ambiguities about how to balance current concerns with duties to the future ‘compels a resource manager to regulate by consensus’ Farmer and Randall, 1998. Consensus processes can be focused by anchoring to relevant and familiar issues. To the extent that the dimensions of preservation costs size and distribution are immediate, these costs can serve as a touchstone. Some scholars express legitimate concern that an unarticulated value for the full range of social benefits of preservation disadvantages those pro- tections against clearly articulated costs Norton, 1995; e.g. in the rush to get something done the difficult-to-measure benefits of preservation may not be fully considered. An alternative concern is that management practices for species preserva- tion may frequently be delayed as is common under the ESA in measuring impacts and their distribution. Such delay risks unnecessarily over- riding protection actions in the political consensus process, since unmitigated costs can mount. The sooner these costs and their distribution are artic- ulated, the less muddled the consensus process can become. Thus, working to some political con- sensus on what constitutes intolerable cost is a central issue. Properly conceived, the SMS ap- proach is a collective choice process and not just identification of safety standards.

3. Linking the ESA and the SMS approach