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CHAPTER IV. PROBLEMS AND PITFALLS Having formulated the panel's basic objectives, we seek now to identify and analyze the major obstacles to their achievement. The analysis will be clarified at the outset by drawing a distinction between conceptual and institutional limitations upon the ability of any set of assessment-decision processes to attain the objectives set forth in Chapter III. I t will be noted, as both sets of limitations are considered, that this distinction cuts across the technology-supporting system and perception response dichotomies discussed in Chapter I . CoNCEPTUAL CoNSTRAINTs SHORTCOMING S OF MODE S OF ANALYSIS As the discussion in Chapter III suggests, much work is needed to refine our ways of th.inking about the central theoretical problems in technology assessment : how to evaluate and balance conflicting interests ; how to ascribe semi-quantitative worth to such elusive goals as the preservation of future choice ; how to allocate, between the innovator and his opponents, the burdens of uncertainty with respect to harmful effects ; how to divide, between the beneficiaries of an innovation and the rest of the public, the costs of evaluating and over coming such effects ; how to assess and strengthen the adequacy of the representation accorded potentially af fected individuals and groups while assuring that inadequate or incomplete technical information, or misperceptions of the situation by affected groups, do not unduly influence final outcomes ; how to measure and enhance the consistency with which technology 43 Digitized by GoogIe
assessment is conducted and enforced . Viewed in part as an effort to identify the sorts of questions that can usefully be asked about technology assessment-those enumerated above, for example-this report is but a small step in the evolution of an urgently needed con ceptual base for the assessment enterprise. FAILURE S OF IMAGINATION Technology assessment, like every intellectual enter prise, tends to be bounded by contemporary assumptions, habitual patterns of thought, and the difficulty of making more than first-order extrapolations. Particularly when an emerging technology appears to represent a merely incremental advance over its antecedents, as was the case . when the automobile was still perceived as a "horseless carriage," old habits of thought are projected into areas in which they may prove dangerously mis leading. Paradoxically, the demands on creative imagina tion may be least severe when the technology in question poses an obviously radical departure from precedent. Even the most open-minded approach, however, can not guarantee that an assessment will ask the right questions or suggest helpful answers. It is extremely difficult, for instance, to foresee the convergence of several technological developments or of one such devel opment with other trends·. Insecticide residues, for ex ample, can stimulate the liver to produce abnormally high levels of certain enzymes, which may then render a number of drugs ineffective at normal dosages (31) . Various sources of sensory overload may combine to yield unexpected levels of anxiety. Transportation and construction technologies in the cities may collide with production technologies on the farm to aggravate urban unemployment. It is obviously of great importance, therefore, to devote special attention to the potential 44 Digitized by Goog Ie
convergence of various technologies with one another or with related social trends. This is not to suggest that an appropriate exercise of imagination, coupled with a healthy dose of political wisdom, would have made it easy long ago to disentangle and to deal with the converging technological compo nents of something so complex as the urban crisis. But it might at least have made the crisis somewhat more man ageable. It is generally conceded, for example, that the drift to the suburbs has contributed significantly to current urban problems. The many technological amenities that made suburban life more attractive better communications ; the ⢠automobile ; automatic heating systems ; the household refrigerator, freezer, and washer ; power equipment for individual lawn care and snow removal-have all contributed to the exodus to suburbia and hence to the problems of the central cities. To be sure, the technological advances making such suburban amenities possible cannot them selves be "blamed" in any meaningful way for the large social changes of which they have become a part. Thus, even if influential individuals could have known some decades ago precisely how these technologies would converge-and how they would interact with tech nological trends in agriculture and in transportation, con tributing to the migration of the rural poor to the cities they could hardly have responded with remedies directed at the contributing technological trends themselves. But they might at least have recognized sooner than they did the prospects of a major population shift. And they might have understood that, in light of the cumulative effects of emerging technological tendencies, certain social policies required serious re-examination-social policies such as local control of welfare and education, a free market in land, housing-finance schemes favoring single-family suburban dwellings, minimum-wage laws, 45 Digitized by Goog Ie
and governmental passivity with respect to housing and job discrimination. Almost as difficult as conceiving of cumulative trends is imagining the effects of scale. Barely I 00,000 television receivers were in use in the United States in 1 948. In the next year there were a million. A decade later the re were 50 million. The social and psychological con sequences of such phenomenal growth are hard even to contemplate, let alone predict. Indeed, in the case of television these effects are still a matter of debate, and apparently adequate research tools for measuring or evaluating them do not yet exist. Often the baseline data from which to measure changes are inadequate, and it is difficult to separate the effects of a particular technology from social or cultural trends that were present for other reasons. Such problem'\ aside, failure to imagine the scale of use can wholly preclude adequate perception of social and environmental consequences. The history of asbestos, for example, demonstrates the effects of scale in one of its most insidious forms (32). As a result cf the tre mendous diversity of its uses, asbestos has become prac tically ubiquitous. It has found its way into literally every automobile, airplane, train, factory, home, and farm across the land-and thence into the lungs of man, where, remaining as indestructible as it is in nature, it can wreak terrible havoc. So, too, with the proliferation of internal-combustion automobiles : to predict that such vehicles would chemically pollute the atmosphere more than vehicles driven by steam cr electricity would have been simple ; to predict that the automobile (of which there were four in the United States in 1 895 and some 80 :million in 1 968) would become the chief source of urban air pollution would have been far more difficult. 46 Digitized by Goog Ie
In such cases, the exercise of trying to imagine the multiplication of a technology and its applications by several different orders of magnitude may be quite useful. Even if one cannot predict whether the correct multiplier will be 1 0 or 1 (}3 or 1 06, it will still be valuable for policy purposes, and for identifying potential hazards and suggesting research needs, to visualize the con sequences of a wide range of possible alternatives rather than regularly to assume that growth will be merely linear. A frequent and closely related problem has resulted from failure to imagine the supporting systems new technologies would demand. Witness, for example, the surface-traffic problems associated with airports, or the vast judicial backlogs resulting from the litigation of automobile-accident claims (33). To the extent that such conceptual failings have resulted from erroneous assump tions of scale, the multiplication exercise suggested in the latter connection might prove useful here as well. A final difficulty, that of reliably foreseeing advances in technology itself, is perhaps less important than it might initially seem. First of all, comprehensive efforts to assess the consequences of a technology can often be effective even if they are delayed until the initial stages of research and development have been completed and the technology is at the threshold of commercial intro duction. So long as one does not wait until very sub stantial interests have vested in a particular mode of application or use , one still has a reasonable opportunity to influence the eventual outcome by a careful examina . tion of alternative possibilities and their implications. Indeed, even after fairly widespread distribution, the general political climate in which an innovation is introduced can have a profound effect on the thinking of the innovators themselves. Recent withdrawals 9f defective cars by automobile manufacturers demonstrate 47 Digitized by Goog Ie
how public opinion and the threat of possible regulation or legal liability can modify corporate behavior far beyond the early stages of development. Second, although it is true that the options for intervention are reduced as a development moves along the spectrum from research to introduction, social intervention very close to the research end of the spectrum may foreclose unperceived future options of far greater significance and potential benefit than the harmful consequences successfully prevented . Third, whatever one's theoretical resolution of the trade-off between premature and tardy interven tion, our political system simply cannot address itself intelligently and vigorously to problems that are essen tially speculative and remote in time. Given a political process that responds only to relatively proximate and demonstrable difficulties, any effort to design a truly anticipatory assessment structure would almost surely fail to provide a realistic link between such a structure and the making of policy. In general, it is easy to misconceive the role of tech nological forecasting as a means of controlling technological development. In the final analysis, it may be more important to foresee the full range of possi bilities than to predict the most probable direction of development. The understanding of possibilities at an early stage enlarges the range of choice in the phase of innovation in which choice is still relatively easy and cheap. It also facilitates redesign of measures to evaluate effects, and thus to discern such effects before they pre cipitate an environmental or social crisis. If we had developed deeper understanding and better methods for monitoring DDT in the environment, for example, it seems likely that its build-up would have been antici pated earlier, its use better controlled, and alternative more selective methods of pest control more promptly 48 Digitized by Goog Ie
encouraged-with relatively little of what can properly be called "technological forecasting. " INADEQUACIE S OF FUNDAMENTAL UNDERSTANDING One can often invent and introduce a new technology on a largely empirical basis, but a far deeper theoretical understanding of the scientific underpinnings of the technology and of its interactions with the environment is necessary if one is to make reasonably trustworthy predictions of its secondary and tertiary effects. And even if one could predict adequately without such under standing, one might not be able to demonstrate the reliability of such predictions to the satisfaction of laymen and public officials. Causal relationships will often conv�ce when statistical correlations do not ; public acceptance of warnings against smoking, for example, would almost surely have been greater if the specific causal connection between smoking and various diseases could have been established . As matters stood, elaborate and massive statistical investigations were required. For a long time it was possible to ascribe the observed correlations to factors other than smoking, especially if one were disinclined to accept the data. But the demonstration of causes requires a great deal of basic research conducted well in advance of wide spread application. Much remains to be learned about how various pollutants disperse in the environment, for example, or about how children react to various kinds of television programs. Such phenomena, whether bio chemical or psychological, are often so complex that we cannot rely on empirical testing to elucidate their character. Nor can we wait to solve specific problems by research strategies designed when the problems have already become acute. We need sufficient funda mental research to guide us in the anticipation of likely problems and in the choice of the most promising 49 Digitized by GoogIe
remedial measures, as well as in the selection of applied research options as unanticipated difficulties materialize. Indeed the very detection of unwanted environmental effects may require sophisticated measurement techniques and �heory, which can come only from fundamental theoretical understanding. Finally, in designing a re search program around the introduction of a new tech nology, we must anticipate the worst much more often than we do now, not with the idea of slowing the develop ment, but to ensure early detection and maximum understanding of any undesirable effects. For such understanding usually leads to the possibility of control. It is also the best form of insurance against technological surprise. We need to know much more thari we do today not only about specific technological developments and their consequences, but also about the process of technological development itself and how its direction and velocity are affected by changes in rules or incentives or by the general political and intellectual climate. How, for ex ample, might the many parameters influencing such development be expected to reflect various changes in administrative practice or regulatory policy? A number of economists have urged that taxes be levied on auto exhaust and industrial stack emissions in order to induce behavior leading to acceptable levels of air pollution. But as recently as 1 967, Ronald Ridker could state in his book, Economic Costs of Air Po/lq,tion, that "no one has ventured to suggest what the magnitude of such a charge should be. " Such operational questions, Ridker wrote, "have not been addressed because they require empirical information far beyond our current understanding of the problem" ( 34) . Empirical information of this kind is badly needed . Research projects should be designed to ascertain the ways in which various organizations have in fact re- 50 Digitized by Goog Ie
sponded to different modes of regulation and to various ways of modifying incentives so that the impacts of various institutional arrangements can be better under stood . Our historical experience with alternative arrange ments has probably been too limited to permit confident generalizations based upon any coherent theory until we have conducted carefully controlled experiments with a number of different possibilities. Some such experiments, at least, can be performed by applying new techniques of organizational analysis in conjunction with computer simulation models. Although one must guard against putting too much faith in any model, the intelligent use of simulation methods can greatly improve upon the biased sorts of judgments that emerge from intuitive extrapolation from past experience, especially if analysis and experience can be blended in balanced judgments. DE FICIENCIE S IN THE DATA BASE In addition to major gaps in data with respect to the actual operation of alternative modes of assessment and control, there have often been grave inadequacies in accessible information with respect to the specific con sequences of particular technological developments, espe cially when such consequences have been diffuse and have not yet attracted widespread public interest. It seems clear that our theoretical understanding will never be so complete as to obviate the need to install and maintain comprehensive and sensitive monitoring sys tems, necessarily global in scope for the many technol ogies that generate effects over great distances, to detect low-level perturbations and thereby to make possible reliable early warnings of potentially deleterious trends, biomedical or environmental or societal, which our basic research did not enable us to anticipate. In the absence of reliable and reproducible information for this purpose, the process of technology assessment 51 30-973 0-69 - 5 Digitized by Goog Ie
becomes a matter of reconciling highly imprecise pro fessional hunches, and the final judgment becomes highly susceptible to the influence of extraneous subj ec tive factors. The ultimate cost is incalculable, but one can reasonably surmise that assessments made in ignor ance have cheated society of many benefits that un exploited technological options had to offer, just as they have imposed on society many injuries that unwisely exploited technological options brought in their wake. To increase the likelihood that the needed information will be systematically obtained, there must be ample feedback from assessment processes to monitoring proc esses. To make this possible, one must be able to identify what prior and ongoing assessments have disclosed, to locate critical gaps in available information, and to design ways to fill them. All these tasks are extremely difficult and require an ability not yet provided by cur rent systems to marshal the available data in an orde rly manner for decision-making. Thorough understanding, built on an imaginative program of basic research and an evolving body of critical data, can only be approximated in any given case. But it is crucial that a close approximation be sought, for, in the end, good technology is ethical technology based on a sound theoretical foundation and "dedicated to careful observation, honest reporting, and open discus sion of results" ( 35) . I N STITUTIONAL CON STRAINTS CONSTRAINTS UPON THE SCOPE OF INDIVIDUAL INTERESTS We have already seen that each of the many decision makers whose choices collectively determine the direc tion of technological development typically selects from among available alternatives according to criteria that tend to underemphasize potential deleterious impacts 52 Digitized b y Goog Ie
upon large segments of the population or important sectors of the environment. The resulting divergence between the interests that the decision-maker identifies as his own or those of his clients or constituents and the larger set of concerns that he ought to take into account clearly demonstrates that existing institutional arrange ments and professional attitudes leave something to be desired. Occasionally power is delegated to the wrong decision-maker-for example, to the speculative builder rather than the city planner. More often, however, the problem does not lie with the choice of decision-maker but with defects in the institutional setting within which decisions are made. Inadequacies of this sort seem to arise from several basic sources : Market Externalities The price system often accounts inadequately for benefits enjoyed or costs suffered by those who are not parties to a transaction. Such non-parties become particularly important for our purposes because the primary beneficiaries of technological change are seldom the same as-or at most are only a small portion of those who suffer from its deleterious secondary con sequences. Thus many of the costs and benefits of a product or process are not reflected in the economic calculations of technologists, investors, or consumers. The concern of economists with the implications of such "externalities" for the efficient allocation of re sources is comparatively recent in origin. Even the 1 936 revision of Alfred Marshall's classic work on the price system discussed only those externalities that created benefits, not those that created injuries (36) . It has been speculated that "the late recognition of the importance of external diseconomies was due as much to the associa tion of those effects with increasing population and ad vanc ing technology-which combined to make external- 53 Digitized byGoogle
1t1es a most urgent concern of modem applied eco nomics-as it was due to fascination with the unfettered market" ( 37). Whatever the reason, it remained for Arthur Pigou to introduce the concept that external social costs and benefits both must be considered in any discussion of economic efficiency ( 38) . And, following Pigou, econo mists have generally agreed that excessive resources will be invested in activities that impose costs that private producers do not have to pay, and madequate resources in activities that confer benefits for which no payment is received, so that efficient resource allocation requires that external costs and benefits be attributed to, and brought to bear upon the price frameworks of, those firms and practices responsible for producing them. Proposals to internalize external costs and benefits have taken several forms : tax and subsidy schemes whereby activities are charged to the extent of their uncompensated net social costs or subsidized to the ex tent of their unremunerated net social benefits ; expansion of the size of decision-making units, so that all otherwise external costs and benefits accrue within the unit and are thus included in its profit-maximizing calculations ; varying degrees and kinds of government appropriation and regulation ; or various other redefinitions of legal rights. Indeed, there is a sense in which all legally es tablished subsidies may be regarded as mechanisms for internalizing "external benefits," while all legal restraints may be viewed as mechanisms for dealing with the "ex ternal costs" that individuals may inflict upon one another. Tort liability, criminal sanctions, and contract damages-all are means by which the law forces one party to "internalize" the costs that his actions might otherwise cause another in the society to bear. But when a large number of disparate actions contribute in a cumulative and gradual way to the same costs (for 54 Digitized by Goog Ie
example , multiple sources, over a period of years, of a severe air-pollution episode) , or when certain costs are imposed thinly over a dispersed and unorganized group of people (for example, low-level disturbance of all persons in the flight path of a supersonic aircraft) , the legal mechanisms now available tend to break down. Measures to improve these mechanisms in order to internalize external costs or benefits require both scientific research, to provide objective assessments of cause and reliable quantifications of damage, and political action to compel decision-makers to bear the costs they cause. Such action in turn involves an equi libration of power among competing interests that is not very closely related to optimum resource allocation. It is not our purpose here to develop the details of the relevant economic, legal, and political theory ; it is our purpose only to emphasize that such issues play an important role in the technology-assessment problem. For most of us would agree that the objective of heightened sensitivity in technology assessment should, whenever possible, be achieved by structuring the incentives. o individual decision f makers so that the are induced to alter their cost-benefit cal y culations to encompass wider concerns than have heretofore been given consideration. What kinds of incentive alterations might be necessary to bring about such a result, how such alterations might be achieved, and what the admin istrative and other costs of such alterations might be, obviously depend strongly upon the consideration of externalities. It cannot be assumed that a workable solution to the problem of externalities is readily available. No one has yet furnished a blueprint for a system that does not cost more than it saves, in which each individual decision maker automatically reaps the full benefits that his decisions confer on others and pays the full costs that his decisions impose. If the problem were purely economic 55 Digitized by Goog Ie
or legal, its solution would be difficult enough. But the problem cuts deeper. For even if we could design a legal and economic environment in which supersonic aircraft, for example, were charged the full costs that their operations would impose upon society, executives with a professional stake in the flight of an American SST, engineers with a career commitment to supersonic transport technology, economists worried about the future balance of payments, and politicians concerned with national prestige, might well turn pre-deafened ears to the sonic boom. Such tendencies, which can be over come, if at all, only by important changes in the values and aspirations of policy-makers and .technologists, generate their own externalities, whatever the price structure and the legal setting may seem to dictate. Indeed, these considerations illustrate how deeply the decision criteria for a particular technology are em bedded in the whole society and its institutions. Competitive Pressures In some respects the problem of externalities is aggra vated by the role of competition in directing investment and innovation. Insofar as it promotes technological progress and matches the direction of such progress to the preferences expressed in the market, competition, of course, performs a val.uable function. But competition rarely rewards and often penalizes behavior that is socially desirable in a larger context. Thus, for example, the chemical plant that ignores pollution will have lower costs than the plant that treats its effluents, and will thus prosper at the expense of its more responsible competitors, unless there is some sort of intervention in behalf of broader interests by a political body. Moreover, the same phenomenon appears whenever there is competition for scarce resources, be they con ·su mer dollars or tax dollars or political po�er. Thus, 56 oi9,tized by Google
for example, competition is an important fact of life in the relationship of government agencies to one another. Each federal department tends to behave in a manner calculated to enhance its own relative influence and, however good its intentions, tends to overlook or at least to minimize those factors in its favorite technologies that might ultimately lead to undesirable social or environmental consequences. This phenomenon is aggravated when particular tech nologies are monopolized by particular agencies. There seems ample evidence, for example, that the Federal Aviation Agency, assigned the task of promoting the SST, cannot be fully trusted to evaluate the sonic boom objectively. It is true that th� Atomic Energy Commission ultimately came to recognize the dangers of fa\lloUJt from atmospheric nuclear testing, but it did so only after heavy and sustained public pressure. With respect to the environmental dangers of underground nuclear ex plosions-including radiation leakage, seismic shock, and water contamination-the objectivity and thoroughness of the Commission's assessments have recently been brought into serious question (39) . In a similar vein, the Bureau of Public Roads has hardly been noted for its devotion to the preservation of the natural beauty of the countryside. The Bureau of Reclamation has been reluctant to consider development of power sources alternative to building dams and hydro-electric stations. And the military services are rarely critical of major new weapons systems that promise to enhance their role in the defense posture of the nation vis-a-vis the other services, even though the net contribution to the national security may be doubtful, especially in the total context of foreign policy. It should be noted, more over, that, by and large, each of these federal agencies is strongly supported in its views by a specialized con gressional committee, which often commands the respect . 57 Digitized by Goog Ie
of the entire Congress and behind which one often finds an economic interest or professional constituency in the private sector that furnishes the committee with moral support and tangible data and arguments. The competitive phenomenon cuts both ways, for there are vested interests not only in the continuation of some technologies but also in the suppression of others. Some regulatory agencies, for example, anxious to maintain their record of "good performance" and hence their share of power and influence, develop a dangerous bias against innovation, seldom giving ade quate weight to the possible denial to society of benefits that the agencies are not chartered to foster and often giving excessive weight to the possible exposure of society to hazards that the agencies are charged to prevent. More important, such negativism tends to be supported and reinforced by private constituencies whose economic position would be threatened if their markets should be invaded by competitive technologies. This does not mean, of course, that the reduction or elimination of competition automatically guarantees socially more responsible behavior. If the allegations of the Department of Justice are correct, for example, the introduction of anti-pollution devices by the automo bile industry was delayed by an agreement not to compete in this field (40) . In a larger sense, however, the industry was behaving competitively in its desire not to reduce its total share of the consumer's dollar by increasing the cost of automobiles by installing equipment offering little or no tangible benefit to the individual consumer. It should be repeated that the negative effects of com petitive behavior in this broad sense are not unique properties of the business-enterprise system or of profit making organizations. Any human society in which human groupings with human aims are in competition with each other for social rewards or prestige and in- 58 Digitized b y Goog Ie
fluence is subject to the same problem, whether one is considering profit-making ente1 prises, universities, federal agencies, political subdivisions, or nations. Thus, for example, if one nation is competing with another for the same market and uses a technology that is cheaper but more socially or environmentally harmful, the other nation may feel compelled to do the same. Or, at another level, a development like SST might (rightly or wrongly) be deemed critical for survival in an inter national contest, though dubious on a domestic basis. The root of the matter is that no enterprise, private or public, can afford indefinitely to assume costs that its competitors will not likewise assume. The only solution lies in the direction of a mutual assumption of costs-either by contractual agreement, domestic or international, or by submission to externally imposed constraints that directly or indirectly compel all to assume costs that none could afford to assume alone. Contraction of Goals I t has often been said that administrative bodies, surrounded by the interests they are supposed to evaluate and regulate, tend gradually to lose sight of the large purposes that attended their birth and eventually to make common cause with those interests. To the extent that this occasionally exaggerated observation reflects reality, it may be regarded as representing a special case of a general human phenomenon. Any human institution has tendencies that, unless counteracted, will over time cause it increasingly to be run for the benefit of people inside the organization and for those special outsiders with whom they have found it easiest to identify themselves. In part� such tendencies follow from ra ther simple failings ; a lofty mandate is no guarantee against the triple danger of self-serving, habit, and subservience. In part, the tendencies in question stem 59 Digitized by Goog Ie
from the fact that the regulated have real problems with which the regulators, with increased familiarity, become more sympathetic. And in part, they reflect the ability of regulated institutions to adduce more effective evi dence and summon more articulate, coherent, and con tinuous arguments for their points of view than can be marshaled by the diffuse public, even in those cases in which the public is organized and motivated to speak. Finally, the appropriate ground rules and criteria may change with time as technology changes or values shift, and these changes may not be reflected either in the statutory mission of an agency or in its own perception of that mission. Too often lacking is a set of countervailing processes to offset such tendencies. The processes required are intricate and subtle, but they can often be assisted by specific measures. such as more vigorous rotation of personnel ; erection of buffers between the institution being evaluated and its closest "clientele" ; effective modes of special intervention, such as the ombudsmen of the Scandinavian countries and New Zealand ; and arrangements better calculated to expose for scrutiny the ground rules under which the institution is operating. Three institutional patterns are particularly vulnerable to the dangers outlined here. The first entails the linking of evaluative and promotional responsibilities, as in the Atomic Enet gy Commission, the Public Health Service, or the Federal Aviation Agency. The second entails the linking of assessment authority with a regulatory mission focused exclusively on the prevention of abuses, as in the Food and Drug Administration. And the third entails the entrusting of a regulatory agency with the task of controlling an industrial activity whose mission looks very different to the regulated industry than it does to it'i users. Because the revenue of TV station owners or networks, for example, comes from advertisers, 60 Digitized by Goog Ie
the rmsswn of TV programming as perceived by the regulated "insider" is, · essentially, the delivery of the largest possible number of viewers per advertising mes sage. To the viewer-the "outsider" in the regulatory scheme-this mission is incidental at best, and, at worst, it is incompatible with good programming. Given the initial decisions (or indecisions) that led to the funding of television through advertising rather than through viewer charges or otherwise, the regulator in the Federal Communications Commission finds himself confronted with an intrinsic conflict of goals that aggravates the already strong inclination to equate the "public interest" with the interest of the regulated industry. One might seek to counteract the unfortunate tenden cies of all these patterns in a number of ways-most importantly, perhaps, by insisting upon multiple assess ment and by devising effective mechanisms for assessing the assessors. But, whatever remedial measures are taken, one must no t overlook the fact that the vulner ability of such institutional patterns, and of many others, may extend to all those who work with the institutions in question. The Public Health Service, for example, is responsible for much of the monitoring and evaluation of the effect� of underground nuclear testing, but funds for its work come from the Atomic Energy Commission itself, creating, as one observer delicately put it, "some thing of a self-policing situation" (41) . Both the Depart ment of Agriculture with respect to pesticides and the Food and Drug Administration with respect to drugs similarly rely upon tests funded or conducted by in terested parties. Indeed, even when an ostensibly neutral assessment body with no promotional or regulatory functions of its own is charged with the duty of conduct ing assessments at the behest of other agencies, great care must be taken concerning the authority to which the assessment body reports and the method of financing its 61 oi9,tized by Google
work . For if the assessment institution (or it'i staff) is financed by, works closely with, or reports to an agency with a promotional or restrictive mission of its own (as is ordinarily the case, for example, with committees of the National Research Council), the assessment may be colored by the agency mission. This circumstance suggests a clear need for a source of assessment funds independent o the f institutions or agencies whose interests will be affected �Y the outcome of the assessment. Jurisdictional Limitations When governmental entities exercise powers pertaining to the promotion andjor regulation of technological applications, the scope of their legitimate concern may be jurisdictionally confined in ways that conflict with the objective of broadening the interests that each decision maker is encouraged to treat as his own. Territorial boundaries, both internal and international, present perhaps the most obvious example of such jurisdic tional constraints. As in the case of water-borne DDT that finds its way from a farm in the United States or a field in Africa to the farthest reaches of the Antarctic, the consequences of many technological applications are no respecters of political demarcations. Yet such de marcations, not the winds and currents of the physical environment, define spheres of power and interest in the world. Thus, when we see a community discharging untreated sewage into a river without concern for its effects on cities located downstream, or when we see a nation engaging in a cloud-seeding experiment or con ducting a nuclear test without concern for its conse quences to neighboring countries, we are witnessing essentially the same phenomenon : any decision-making u nit smaller than the area seriously affected by its deci sions tends to view those effects as someone else's head- 62 Digitized by Goog Ie
ache rather than its own-a kind of "political exter nality. " Nationally, we are beginning, though very slowly, to evolve new kinds of regional entities in response to pre cisely this kind of problem . For obvious reasons, progress at the international level has been more halting. The International Union of Air Pollution Prevention Associa tions held its first Congress in London in 1 968, the United Nations has scheduled a Conference on the Human Environment for 1 972, and two maj or international agreements with respect to nuclear weapons suggest promising possibilities for cooperation in other fields. But the fragile character of the present world order poses a formidable obstacle to the kind of international action that will become increasingly necessary as technological options with truly global consequences present them selves with ever greater frequency. Even when political boundaries present no problem, jurisdictional limitations of other forms can still frag ment technological power and responsibility-by nar rowing the kinds of interests that organizations are authorized to advance. The Atomic Energy Commission, for example, recently granted a provisional construction permit for a nuclear power reactor on the Connecticut River. The states of New Hampshire, Vermont, a nd Massachusetts had attempted to introduce, at public hearings before an atomic safety and licensing board, evidence that operation of the contemplated facility would harm the river through inj ection of heated water. The board , however, ruled such evidence inadmissible as beyond the Commission's jurisdiction , and the Com mission agreed . In affirming the Commission' s order, the United States Court of Appeals for the First Circuit concluded from the history of the 1 954 Atomic Energy Act that "Congress, in thinking of the public's health and safety, had in mind only the special hazards of 63 Digitized by GoogIe
radio-activity," not the additional hazards of thermal pollution . The court reached its decision "with regret that the Congress has not yet established procedures re quiring timely and comprehensive consideration of non radiological pollution effects in the planning of installa tions to be privately owned a nd operated" (42). We do not intend to suggest that the Atomic Energy Commission should necessarily be given jurisdiction over all environmental effects of nuclear-reactor operations . Indeed, conferring such jurisdiction today would lea d to another pr oblem, suggested earlier, th at nuclear power would then be penalized relative to fossil-fuel power not subj ect to similar regulation . Ideally, however, all power-generating technological applications would be subj ected to careful assessment with respect to the full range of serious environmental effects. The present legal structure clearly fails to assure attainment of this obj ective. In another recent case, a federal district court ruled that the Corps of Engineers and the Secretary of the Army had acted beyond their statutory authority when they denied the owners of dry land in Florida a permit to dredge a nd fill navigable waters to create an artificial island in an adj oining bay. A local health board, as well as state and federal conservation agencies, had opposed the proj ect because it would injure fish and wildlife in the area, and the Army had accordingly denied the requested permit, following a procedure laid down in a 1 967 memorandum of agreement between the Secretary of the Army and the Secretary of the Interior. But the court ordered that the permit be issued, concluding that the applicable statutes make interference with naviga tion-not injury to fauna or other kinds of environmenta l deterioration-the only lawful basis for refusing per mission to dredge and fill (43). In this instance, as in that of the Atomic Energy Commission and many others, 64 Digitized by GoogIe
the legal definition of an agency's interests with respect to a technology may create artificial jurisdictional barriers to the broadening of technology-assessment criteria. CONSTRAINTS UPON THE REPRE SENTATION OF AFFECTED INTERE STS Insofar as the course of technological development represents the sum of a number of different choices by a variety of decision-makers, our ultimate obj ective is not necessarily that each decision-maker consider every con sequence of his choices, but rather that the process as a whole somehow take every consequence into account. If every potentially affected group accurately perceived its interests and were appropriately represented at a suitable point in the process, constraints upon the individual interests of each decision-maker-because of market externalities or basic attitudes or other considerations would present no serious problem. Such constraints are troublesome only when the process as a whole fails to assure adequate . representation. But this will unfortunately be the case whenever the process in question remains wholly private. For if a technology is supported entirely by private investment, with no gov ernmental involvement whatever (promotional or reg ulatory or otherwise) in its development or use, then some affected groups will inevitably have had no opportunity to bargain with, · or otherwise to influence, the decision makers responsible for the lines along which the tech nology has evolved. The government is always involved, of course, in some indirect way-even if only by providing the rules and facilities for bringing suits for damages, the threat of which forces individuals to consider at least some of the potential effects of their activities upon others. More over, whenever a governmental body expressly chooses 65 oi9,tized by Google
to take-or to avoid-an even more active role with respect to a given technology, it creates a decision-point at which the whole range of affected interests might, at least theoretica lly, have an opportunity to be heard . The action or inaction a t each such point will affect a broad variety of individuals and gr oups in the future, not sim ply those with currently recognized stakes in the tech n ology. Perhaps an idealized system of technology assess ment would provide effective representation for every potentially affected interest at every such point . In practice, however, this is impossible. Whatever effort is made to alert them� many individuals and groups will remain unaware of developing technologies or of their potential effects upon them. Others may be misinformed or may react emotionally or irresponsibly. Often the people affected may belong to future generations, or may be among those who, like ghetto residents until recently, are not politically articulate . The adjustment of con flicting interests and values is time-consuming and costly, and may be so to a degree not justified by the gains, particularly in light of benefits foregone as a result of the discouragement of innovators or as a result of delays in the progress of technology. Far from being the inevitable and autonomous process often pictured, technological innovation often depends on a delicate balance of in fluences that are not afways on the side of beneficial change. Both to avoid cumbersome delays and to assure the representation of inarticulate interests or diffuse public concerns such as the preservation of future options, it may be necessary to create surrogate representatives public intervenors-to speak on behalf of such interests and values. Having such representatives closely involved in the decision process may forestall mobilized political opposition to a development at a later date simply by 66 Digitized by Goog Ie
anticipating the sorts of obj ections that might be raised and redirecting the development so as to meet them. The earlier the stage at which remote interests are in jected into decisions with respect to the development or application of technology, the less likely it is that more costly changes in plans will be required later. Highway planning furnishes a good example of the application of this principle . At present such planning reflects largely engineering and economic considerations, with only minor attention to social and environmental concerns. Increasingly, plans are being disrupted or abandoned at late stages as a result of political agitation by suddenly alerted groups. Thus, what should have been an integral part of the planning process itself becomes the subject of political in-fighting, with all the distortions and misper ceptions that such conflicts usually involve. These considerations imply that broad public partici pation in the assessment process ought to be encouraged, and public apathy overcome, in the early stages of maj or technological developments, at least in those instances in which such stages can be identified in advance . Ac cordingly, although the panel does not believe it either practical or desirable to open the whole process of tech nological assessment and decision-making to public view, we do believe it important to assure that the evi dence and arguments on which maj or decisions are based will be open to public scrutiny and will be subject to timely review in appropriate public hearings. C ONSTRAINTS UPON THE COORDINATION AND FOCUSING OF RELEVANT E F FORTS Despite the many institutional deficiencies thus far identified , the present system might still be improved significantly with respect to the broad objectives out lined in Chapter I I I but for serious li mitations upon the 67 30-973 �69----6 Digitized by Goog Ie
system's capacity to direct its diverse energies in any coherent way toward the achievement of such obj ectives. An instructive contemporary example is furnished by a 1 968 legislative proposal (S. 2658) to increase the size and weight limits for motor truck carriers and thus to permit the expansion of an existing technology (44) . The Senate Committee on Public Works, supported by the analyses of the Bureau of the Budget and the Depart ment of Transportation, recommended the proposed increase in a report that considered only the physical capacity of the interstate highway network to accom modate the larger trucks and the possible contribution of such trucks to traffic accidents. Just as the President' s Advisory Committee on a National Highway Program and the relevant congressional committees had given no consideration whatever, in recommending the ori ginal Federal Highway Act of 1 956, to the kinds of environmental deterioration that might result from the proliferation of highways and the g,rowth of automotive traffic, so too the relevant agencies and committees ignored environmental concerns in assessing the 1 968 legislation . The President' s Advisory Committee in its 1 955 study had attempted to justify its failure to consider alterna tive modes of transportation by noting that "other Government agencies and special committees" were concerned with other transportation media (45) , and the entities responsible for evaluating the 1 968 proposal could likewise claim that an imposing array of organiza tions had examined and were still exploring Sl..J.C h prob lems as air pollution from automotive exhaust fumes and aesthetic debasement from ever larger trucks on ever wider and more extensive highways . In light of all other pertinent assessments, who was right : those who defended the narrow scope of the Senate's 1 968 assessment or those who insisted that a broader range of impacts should have 68 Digitized by GoogIe
been evaluated and, in effect, a wider circle of constit uencies alterted and consulted? The fact is that one cannot really decide, on the basis of the information available, precisely what questions the Senate Committee should have asked when S. 2658 came before it. For there existed then and there exists today no reliable source to which the Congress-or anyone else--can tum for a "snapshot" of the assessment situation even with respect to so uncomplicated a tech nological proposal as that embodied in S. 2658. One simply cannot· obtain a clear picture of what prior and contemporaneous evaluations have been or are being made, what their frames of reference and findings were or are, and what issues remain inadequately explored . Without such a picture, one is tempted either to pass the buck-to assume that somebody, someplace, has asked or will ask the right questions-or to dissipate one's efforts in as "comprehensive" an evaluation as one can imagine, while paying the inevitable price of duplicated effort and, worse still, superficial analysis. The natural tendency is to err on the side of buck-passing, and the inevitable result is that incremental decisions, such as periodic increases in truck size and weight, may accu mulate so much momentum and consolidate so many interests that continuing technological development may pass beyond any effective control even by those who ap propriate the funds that fuel its progress. Because such evolutionat y processes are the rule rathe1 than the exception-recall the ubi quitous "tyr anny of small decisions" ( 46) -and because incremental choices can result in cumulative adverse impacts and opportunity costs as serious as those caused by "one shot" decisions made on th e basis of inadequate assess ments: the panel believes that a critical obstacle to improved assessment and response is the lack of any mechanism to monitor and coordinate the many assess- 69 Digitized by Goog Ie
ment and decisional systems-fragmented in location, in responsibili ty, and over time-that together comprise the technology-assessment apparatus of our society. Without such an integrative mechanism for comprehen sive information management, the basic flaws in existing systems-such as narrowness and inconsistency of cri teria ; lack of detachment, professionalism, and conti nuity ; inadequate representation of diffuse or subtly affected interests-are virtually certain to persist. Nor will it suffice to bring the myriad activities of fragmented assessment systems into intellectual and in formational focus. I t must be recalled that our diffi culties with respect to the ma nagement of technological change derive less from inadequate perception tha n from defective response. In the long run, a broadening of factors and a readjustment of priorities are needed within the innumerable cost-benefit analyses that are continually being made wherever technological change is engineered-throughout the private sector and the ex ecutive branch. Such a broadening and readjustment can ultimately be effected only by those at the front line of decision-making, working at industrial drawing-boards and on executive balance sheets. But individuals and organizations disposed toward such a realignment will be unable to achieve it unless the present play of forces within government and industry is significantly altered . If such an altet ation is ever to be accomplished, it will require incentives and pressures originating in public concern and flowing into the political process, where they can be shaped and directed toward key points of decision in executive agencies and departments and in the private sector. It is primarily through the legislative and judicial branche s that such incentives and pressures can receive the necessary direction and impetus, for it is Congress and the courts that can most readily become forums for 70 Digitized by GoogIe
the dissident and the disadvantaged in our society, and it is in the legislative chamber, acting as a committee of oversight, and in the courtroo�, acting as an instrument of accountability, that the concerns for human values and a healthy environment can most vigorously be pressed upon a system otherwise notoriously loathe to move. The difficulty is that at this level, too, there exists no mecha nism to integrate and focus the many disparate strands of concern and sources of pressure-to mold them into a powerful constituency for more responsible and respon sive technology assessment. We have merely a spate of proposals in Congress, an occasional note of alarm from the Executive , and a few sporadic lawsuits brought by aroused citizens. Only when the energies represented by these diverse sources are orchestrated creatively and channeled continuously toward the tasks at hand will there be real hope of eventual progress. 71 Digitized by Goog Ie
