The costs of a cost-benefit analysis on fracking

I have been writing about hydraulic fracking for more than a year now.

Several of my commentaries calling for a ban on fracking have been published and utilized in public advocacy efforts. Last year when I spoke at a faith-based meeting at the Association for the Advancement of Sustainability in Higher Education, all of my materials were taken by campus representatives of many faith-based colleges and universities. This was especially true of the interest level of evangelical Protestant colleges, who took many of my stickers calling for a ban on fracking. 

Since then I have worked to get more materials out, with some special focus on New York and its governor Andrew Cuomo. My efforts have also focused particularly on Cardinal Timothy Dolan of New York, whom I have known since he was a graduate student in Catholic history at Catholic University, and have been in touch with for more than 20 years.

Dolan did his dissertation on the founder of the National Catholic Rural Life Conference, the late Bishop Edwin Vincent O'Hara, and I was the executive director of the Edwin Vincent O'Hara Institute for Rural Ministry Education for six years. I also served as executive director of the National Catholic Rural Life Conference for thirteen years.

In addition, I have known Bishop Howard Hubbard for almost the full 35 years he has been the bishop of Albany, and have served on diocesan committees in his service. The same is true of Bishop Emeritus Matthew Clarkof Rochester, New York, who retired as the diocese's bishop in September.

I wrote to all encouraging them to support a ban on fracking in New York. In response, Clark sent me a copy of public comments from the New York State Catholic Conference published in January on the issue of fracking.

I read it carefully and offer the following comments.

The statement offers some cautionary notes based upon a reading of Catholic social teaching's seven principles: human dignity, solidarity, subsidiarity, the common good, the option for the poor, the universal destination of goods, and care for creation.

The statement puts some emphasis on care for creation as especially relevant to the issue of fracking. The bishops' advisors in the New York State Catholic Conference also utilize cost-benefit analysis.

In some ways, it appears that their methodology depends more on the cost-benefit analysis than it does on any of the principles, especially since they weigh the principle of care for creation of higher value in this analysis than other principles, but rely upon taxation as the solution to remediating damages rather than continuing and enhancing their previous advocacy of a moratorium by advocating an outright ban.

It doesn't take too much imagination to see what can likely happen based upon prior experience of earthquakes, polluted water, damaged landscapes, problems to agriculture production and the loss of values to housing and tourism.

Harms that have already happened will unlikely be mitigated in the approach fostered in the bishops' advocacy of taxes as a remedy to harms. The realization of harms makes reasonable remedies like taxation policy an inadequate solution in my evaluation.

Examinations of the effects of mountain top removal in Appalachia and of tar sands extraction in Canada already have given enough evidence that the care for creation principle will be violated.

Not to mention the fact that the seven principles are, as the bishops' acknowledge, interconnected; and while the environmental effects can be evaluated on their own merits, the costs beyond the economic costs deserve a closer scrutiny than the bishops' advisors provide.

I suggest the standards provided by a cost-benefit analysis are woefully less helpful than others. A higher level of scrutiny should be provided of the implications of human rights in this regard, particularly the right to food and the right to water and the inherent rights of earth. 

In addition, other parts of the universal Church and other Catholic conferences have practiced a higher level of scrutiny by utilizing the standard of the precautionary principle.

This principle, when used with Catholic Social Teaching, is both more rigorous and comprehensive than cost-benefit analysis, which seems to count only economic costs, where the precautionary principle includes economic, social, environmental and cultural costs together.

The North Dakota Catholic Conference uses this standard in its analysis of the adoption of genetically modified seeds for wheat production in the state. The important issue here is "by what standard should a moral evaluation of a technical solution to energy production be made?"

In his recent commentary to the Food and Agriculture Organization of the United Nations, Pope Benedict XVI seems to prefer the precautionary principle to the cost-benefit analysis' more pragmatic and utilitarian approach more utilized in America.

The precautionary principle is a mode of analysis formalized at the 1992 United Nations Conference on Environment and Development in Rio De Janeiro that emphasizes the discipline of precaution be carefully exercised to avoid potential harm and unforeseen and unintended consequences.

This principle:

  • requires that precaution should prevail whenever questions of human and environmental health are involved;
  • mandates restraint until cause-and-effect relationships are properly understood;
  • places the primary burden of demonstrating safety upon the developer;
  • thorough examination for the potential for harm is a prerequisite in determining and demonstrating such safety.

The precautionary principle is a different policy and regulatory regimen than what is currently practiced in our nation, which tends more toward the cost-benefit analysis as utilized by the Catholic conference of the New York bishops in their review of hydraulic fracking.

Recently, the pope used the precautionary principle in his comments on technical developments in food production (genetically modified organisms). The standard of analysis has relevance as well to energy production:

"It is an alternative vision to that determined by internal and international measures which seems to have as their sole objective profit, the defense of markets, the use of agricultural products for ends other than food, and the introduction of new techniques of production without the necessary precaution," Benedict said in his 2012 World Food Day message. 

The Holy See continues to exercise the principle of precaution when it comes to endorsing new technologies, one can surmise, including fracking rather than the more American standard of cost-benefit analysis. 

I assert that the standard of the precautionary principle is more adequate than cost-benefit analysis. The prinicple asserts that one should weigh a fuller and more holistic framework of costs involved beyond the price of a practice. The harms of hydraulic fracking can be much more damaging than taxation can remedy.]

The failure to recognize and give due weight to the potential harms in fracking provide me the conclusion that the New York bishops' standard is inadequate, even as they provide lip service to Catholic social teaching.

[David Andrews is the senior representative for Food & Water Watch, a nonprofit organization that advocates for safe, accessible and sustainably produced food and water.]