LETTERS TO THE EDITOR: KINDER'S SENATE BILL MUST BE DEFEATED

To the Editor:

I am writing to express my deep concerns with respect to your article of March 4 discussing Senator Peter Kinder's Senate Bill 809. I have received a copy of this bill from the Senator's office. As it is written, it must not be allowed to become law in the state of Missouri.

As you noted in the March 4 article, the bill "...would require the Missouri Department of Natural Resources to calculate how much environmental regulations will cost to implement. Such a requirement will enable officials to determine whether the environmental benefit is worthwhile in light of the cost to implement the regulation, Kinder said. 'Missouri business owners can tell you that whenever DNR issues a regulation, it passes along a compliance cost,' said Kinder."

Economic impact analyses are nothing new to environmental regulation, but the Kinder Bill is so vague in its detail, and so hopelessly naive in its view of the science of economic forecasting, that it would leave the fate of environmental protection to the whims of whoever designs the economic survey. Senate Bill 809 requires, "An estimate, performed with as much specificity as practical, of the risk to the health and safety of individual members of the public addressed by the rule and its effect on human health or the environment and the costs associated with implementation of, and compliance with, the rule...." Far too many of Kinder's terms are subject to interpretation:

(1) "...as much specificity as practical...." Who will determine the degree of specificity? What parameters will be included in this ecological cost-benefit analysis? Will it look simply to business costs over the short term? Will it examine the potential loss of non-renewable natural resources?

(2) "...the health and safety of individual members of the public...." If the Senator means "individuals" in the literal sense, I must point out that studies of potential and/or actual harms to individuals often ignore broader epidemiological effects which are only manifest across whole populations .

(3) "...the costs associated with implementation of, and compliance with, the rule...." What kind of costs will be considered? Short term business costs will most certainly be considered, but what of projected medical costs, and the expense of lost productivity, due to environmentally-related illness and disease? Do we consider the cost to the non-human environment? Will nature be permitted to have intrinsic value under the Kinder Bill?

The Kinder Bill states that DNR analyses will use the "...best available scientific data," in order to determine the degree to which proposed regulations will advance the cause of human health and environmental protection. I respectfully ask Senator Kinder what scientific data he was referring to when he issued the following statement in your newspaper:

"Another example is Missouri Electric Works, which was determined several years ago to have PCBs, a substance which Kinder says has never been proven to have killed anyone or to have made anyone sick."

If your newspaper misquoted the Senator, shame on you (he is, after all, your Associate Publisher); but if this is indeed what Senator Kinder said, then we as his constituency already have answers to my questions above, and they do not reflect a sensitivity, in either a scientific or an ethical sense, toward long-term human health or the environment.

PCBs are a collection of substances, known otherwise as "polychlorinated biphenyls." They are not one substance, but many. They have myriad industrial uses due to their rather unique chemical and physical properties. PCBs are, on the other hand, suspected carcinogens (cancer-causing substances), mutagens (substances capable of altering genetic material) and teratogens (substances capable of causing birth defects). There are few if any immediate, or acute, physical effects of PCB ingestion or exposure, but when dealing in ecological matters, one must look at chronic, and thus long term, effects.

Teratogenicity has been demonstrated in birds, and so when Senator Kinder refers no one being sick from PCBs, he obviously holds that humans are the ultimate standard against which all harms, economic, ethical and otherwise, will be judged. Finally, PCBs have been demonstrated to have adverse chronic effects upon humans, in the form of kidney and liver maltunction, abnormal weight loss and chlorine-induced acne. When we consider that PCBs have the ability to accumulate in body fat, we must realize that any assertions of harm from PCBs must look in the long-, rather than the short-, term.

I have no quarrel with economic impact studies, in principle. They are even excellent tools for aiding the protection of our ecological resources. However, when entered into with such blind disregard for the complexities of economic analyses and ecological interconnectedness, we leave economic and ecological decisions to the misinformed. Both economy and ecology stem from the Greek word oikos, meaning home. There is absolutely no reason why they must be mutually exclusive. The goal of promoting economic prosperity and ecological protection is an admirable and essential one, but Senate Bill 809 falls far short of that goal. It must be defeated.

WILLIAM J. McKINNEY, Ph.D.

Department of Philosophy and Religion

Southeast Missouri State