Heather Hansen with Red Lodge Clearing House has a well-written article today on High Country News about a topic we’ve been exploring: the role of economic analysis in environmental regulations (see here and here for previous posts). Heather writes about a proposed rule from the U.S. Fish and Wildlife Service (FWS) that appears to elevate the role of economics in the decision-making process for designating critical habitat.
When FWS determines that a species warrants listing as threatened or endangered – a very serious statement about the status of a species – the FWS is to follow that listing with a designation of critical habitat. Critical habitat is the geographic area(s) that the government has identified as essential to the conservation of the listed species. Critical habitat is not the same as a “refuge” for endangered species. Threatened and endangered species are protected by federal law no matter where they may occur, but most experts consider the designation of critical habitat a key to the successful conservation of a listed species.
Designation of critical habitat has always been the most controversial aspect of an already controversial law – the Endangered Species Act – and Heather recounts the relevant history in her article. The concern with the FWS’s proposed rule, according to Heather’s analysis, is that presenting the economic analysis alongside the critical habitat designation will lead decision-makers to overweight the economic costs of designating critical habitat. As Heather points out:
This is a touchy time to put economic impacts on par with scientific imperatives, and the proposed rule sets the stage to subject critical habitat designations to a cost-benefit analysis. This plus or minus approach is helpful in many areas, but not in regard to biodiversity. While the costs of reserving an area of land as habitat are often easily quantifiable, benefits require an unsatisfying, abstract non-market valuation.
As we have discussed before on Free the Commons!, the appropriate role of economic analysis is to inform the process, not dominate it. We have argued that cost-benefit analysis often assigns highly suspect economic values to largely intangible environmental goods and services, like public health and species preservation, and therefore is highly unreliable. While a difference certainly exists between trying to cost out benefits for regulations that protect human health, and regulations like this FWS one that benefits species, we still must acknowledge that the assigning of value is an inherently flawed undertaking. Further, we have found fault with the overwhelming focus on economics when many of our environmental policy questions should revolve around fundamental questions of ethics. The preservation of species is foremost a question of ethics.
While I have not read through FWS’s proposed rule (maybe, if I find the time!), I agree with Heather’s assessment. The ultimate decision whether we designate critical habitat for an endangered species – a step which essentially represents our last-ditch effort to save the species from extinction – should not be bound by economic calculations.