The perils of command and control and the pathology of Natural Resource Management

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By David Salt

As a younger man I honestly believed that sustainability was a tractable problem; a difficult challenge no doubt but one that was solvable with hard work coupled with science and technology. And, as a confident young thing, I thought I could contribute to this outcome by serving in the area of science communication and education; get more talented young people into science, and increase community acceptance of emerging technological solutions so they can be effectively implemented.

How might science and technology save us? By providing us with insights on the many problems being faced by humanity and the environment, and by helping humanity lighten its footprint on Planet Earth. Well, science has definitely provided ample insights on the plight of our planet, and technology has given us so many ways to be more efficient in how we do things.

For all that, however, we are moving away from being sustainable; indeed, we seem to be accelerating away from it. In the last half century, humanity has pushed the Earth system over several planetary boundaries, unleashed a sixth extinction event, and seems unable as a global community to do anything about greenhouse gas emissions which are remorselessly on the increase (as a by-product of our addiction to economic growth).

Science and technology has underpinned so much of our wealth creation and economic activity, and many techno-boosters are fervent in their belief that science and technology is the solution to the many problems facing our environment (indeed, I heard Australia’s Chief Scientist say this exact thing on the radio this morning, as I write.)

As I grew older and watched the natural world decline around me (on a number of scales; think of weed infestation in your local bush reserve, glacial retreat or the bleaching of the Great Barrier Reef), my enthusiasm for (and faith in) science and technology also declined. I could see the potential of all these new discoveries (think renewable energy, nanotech and biotech as examples) but could never see where the outcomes were creating a more sustainable future. For example, for every 10% improvement in efficiency in process X, we seemed to see 100% increase in people using that process resulting in more waste, more consumption and more damage (albeit less impact per capita, see the Rebound Effect for a discussion on this).

The dangers of partial solutions

It’s not that I’m anti science and technology and I do believe increasing efficiency is important. However, by themselves they are not enough.

Then I was asked to write a couple of books on resilience science (Resilience Thinking and Resilience Practice) and my doubts on the belief that ‘science and technology is the solution’ crystallised into a new way of looking at the world. The experience of writing about resilience opened my eyes to ideas of complexity, and the capacity of a complex systems to absorb disturbance and retain their identity (the definition of resilience). The consequences of these ideas are deep and far reaching. In a range of different ways, I’ve been attempting to articulate them in my stories for Sustainability Bites.

One major consequence of acknowledging the complexity around us is to be aware of the cost of partial solutions sold to us as complete answers. Science and technology (and endlessly increasing efficiency) are not only not enough to move us to being sustainable, an exclusive reliance on them (and belief in them, think ‘technology not taxes’) will actually reduce resilience in the systems we depend upon and make us more vulnerable to disturbance.

There are many lines of evidence supporting this contention (see Resilience Thinking and Resilience Practice) but in the space I have here I’d like to discuss how natural resource management agencies decline over time. Improving science and technology (and efficiency) is often touted as the solution but only fuels this decline. This discussion is based on a landmark paper by CS Holling (one of the founding fathers of resilience thinking) and Gary Meffe, written a quarter of a century ago: Command and Control and the Pathology of Natural Resource Management.

The command-and-control pathology

Holling and Meffe point out that when command and control is applied in natural resource management, the initial phase is nearly always quite successful. Insect pests are reduced by pesticide use; fishing and hunting are enhanced by stocking or predator removal; forest fires are suppressed for years; floods are minimized by levees and dams.

But what follows on these initial successes is rarely acknowledged. The agencies responsible for management shift their attention from the original social or economic purpose towards increasing efficiency and a reduction in costs. (Of course, all agencies/companies do this over time not just NRN agencies. It’s a pattern well described in the idea of ‘adaptive cycles’ first proposed by Holling.)

NRM agencies search for better and more efficient ways to kill insects, eliminate wolves, rear hatchery fish, detect and extinguish fires, or control flows. Priorities thus shift from research and monitoring (why ‘waste’ money studying and monitoring apparent success?) to internal agency goals of cost efficiency and institutional survival.

Holling and Meffe contend that as this happens, there is a growing isolation of agency personnel from the systems being managed and insensitivity to public signals of concern. They describe this as institutional myopia and increased rigidity (again, something well described by the theory of adaptive cycles).

At the same time, economic activities exploiting the resource benefit from success (of more fish, or water or whatever) and expand in the short term. We see greater capital investment in activities such as agricultural production, pulp mills, suburban development, and fishing and hunting. There’s nothing wrong with this, they say, within limits.

But the result is increasing dependency on continued success in controlling nature while, unknown to most, nature itself is losing resilience and increasing the likelihood of unexpected events and eventual system failure. When natural systems are ‘controlled’ they invariably lose their natural diversity and processes, which leads to a declining ability to absorb disturbance (while maintaining its identity).

With dependency comes denial and demands by economic interests to keep and expand subsidies, and pressure for further command and control.

So, the initial successes of command and control come with a costs that are usually never acknowledged. Command and control reduces natural variation and erodes resilience, environmental managers aim for efficiency rather than connection with the system they are managing, and economic interests that benefit from original command and control distort the system to maintain it. The composite result is increasingly less resilient and more vulnerable ecosystems, more myopic and rigid institutions, and more dependent and selfish economic interests all attempting to maintain short-term success.

Holling and Meffe point out that solutions to this pathology cannot come from further command and control (for example, stronger regulations) but must come from innovative approaches involving incentives leading to more resilient ecosystems, more flexible agencies, more self-reliant industries, and a more knowledgeable citizenry.

Back in the ‘real world’, you’ll largely hear our political leaders deny the complexity of this and simply say science and technology will save us. Unfortunately, in a complex world, simple solutions have a habit of only making the situation worse.

Don’t get me wrong, I still love science and technology. However, by themselves, they are not the solution. To contribute to a sustainable world, they need to work with complexity, not subjugate it.

Banner image: Dams are an important piece of human infrastructure offering many valuable short-term benefits by controlling our rivers. In the longer term they come with a range of often unacknowledged costs. They reduce the natural variability of the river; they encourage human settlement in areas subject to flooding; and allow food production in areas that normally wouldn’t support agriculture. Over time, the agencies managing the dam become myopic and rigid, the economic sectors depending on the dam become increasingly reliant and selfish, and the river system becomes increasingly vulnerable to disturbances. (Image by David Salt)

Thinking resilience – navigating a complex world

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By David Salt

Our world seems to be coming unstuck at the moment. Climate fuelled weather extremes – floods, droughts, heatwaves and fires – are crippling large parts of humanity. Many people are grappling for answers; What do we do? Why haven’t we already done something about this? It’s not like we haven’t been warned (repeatedly and with comprehensive detail by our climate scientists and others).

I believe many of your problems lie in our inability to deal with the complexity of the world around us (my last two blogs discussed this very thing – we can’t fix this because it’s complex and complicated vs complex). One way of better appreciating that complexity and navigating a way through lies in the area of resilience thinking.

The word ‘resilience’

The word ‘resilience’ is now common in many vision and mission statements. But ask the people who use these statements what they think it means and you get a range of different answers, most of which relate to how something or someone copes with a shock or a disturbance.

Concepts of resilience are used in all sorts of disciplines, but it has four main origins – psycho-social, ecological, disaster relief (and military), and engineering.

Psychologists have long recognised marked differences in the resilience of individuals confronted with traumatic and disastrous circumstances. Considerable research has gone into trying to understand how individuals and societies can gain and lose resilience.

Ecologists have tended to describe resilience in two ways; one focused on the speed of return following a disturbance, the other focused on whether or not the ‘system’ can recover. People engaging with resilience from the perspective of disaster relief or in a military arena incorporate both aspects (ie, speed and ability to recover). Indeed, there is a lot of commonality in the understanding of resilience in the three areas of psychology, ecology and disaster relief.

In engineering the take on resilience is somewhat different. Indeed, engineers more commonly use the term ‘robustness’ with a connotation of designed resilience. It differs from the other three uses in that it assumes that the kinds of disturbances and shocks are known and the system being built is designed to be robust in the face of these shocks.

Resilience thinking

The ‘resilience’ that is being invoked in vision and mission statements relating to Australia’s environment is largely based on the idea of ecological resilience, and it’s all about the ability to recover.

The science underpinning our understanding of ecological resilience is often referred to as resilience thinking. The definition of resilience here is: the capacity of a system to absorb disturbance and reorganize so as to retain essentially the same function, structure and feedbacks – to have the same identity. Put more simply, resilience is the ability to cope with shocks and keep functioning in much the same kind of way. 

A key word in this definition is ‘identity’. It emerged independently in ecological and psycho-social studies, and it is both important and useful because it imparts the idea that a person, a society, an ecosystem or a social-ecological system can all exhibit quite a lot of variation, be subjected to disturbance and cope, without changing their ‘identity’ – without becoming something else.

The essence of resilience thinking is that the systems we are dealing with are complex adaptive systems. These systems have the capacity to self-organise around change but there are limits to a system’s self-organising capacity. Push a system too much and it changes its identity; it is said to have crossed a threshold.

The systems around us that we depend on (and are embedded in) are linked systems with social, economic and bio-physical domains, operating over multiple scales. To understand what enables these complex systems to retain their identity, what keeps them resilient, we need to appreciate the linkages between these domains and scales. We also need to understand how the system is behaving within each domain and scale, because over time these components go through their own cycles (known as adaptive cycles) in which the capacity for change (and the ability to hang on to their identity) shifts.

Many ideas, many insights

Resilience thinking involves all these ideas. It is the capacity to envisage your system as a self-organising system with thresholds, linked domains and cycles.

Each of these ideas take a bit of explaining, something I’ll attempt in upcoming blogs (for a good guide, see Resilience Practice*). However, when you begin engaging with ideas relating to a system’s resilience, you begin to appreciate the world in a different way.

Some of those insights have been for me that no-one is in control, and you can’t understand a system by understanding the components that make it up – complex systems have emergent properties (for example, the whole is greater than the sum of the parts).

We also need to appreciate that the narrower concept of ‘efficiency’ – ie, holding a part of our system in a state that delivers optimal returns (eg, food or fibre) without considering interactions with other domains or scales – leads to a loss of resilience, making it less likely that these systems will continue to deliver into the future. Efficiency is important but, by itself, it is not the solution to the challenge of sustainability.

We live in a complex world facing enormous challenges. Too much of our efforts so far have been directed to command-and-control approaches, techno solutions and improving efficiency. If the problems we were dealing with were simple and tractable, such approaches would work well. Unfortunately, our current approaches to sustainability are not working at all, and the problem is growing significantly.

Could it be we’re trying to solve the wrong problem? We’re managing a complex world as if it were a simple system.

*Walker B & D Salt (2012). Resilience Practice: Building Capacity to Absorb Disturbance and Maintain Function. Island Press. Washington.

Banner image: Forests begin their recovery after Australia’s Black Summer of 2019/2020. (Image by David Salt)

Washing off the virus

Will we throw the environmental baby out with the bathwater?

By Peter Burnett

In canvassing our recovery from the COVID-19 crisis, Prime Minister Scott Morrison has made bold statements about giving first priority to growing the economy through a business-led recovery. Finance Minister Mathias Cormann has deployed equally strong language about an ‘aggressive’ deregulation agenda.

The strength of such language must give anyone concerned about the environment pause for thought. There’s no doubt the economy will need some heavy duty kick-starting as we recover from the COVID-19 disaster.

However, might this crisis be used to justify a political narrative about environmental regulation being ‘green tape’? Could we, in the name of curing the current big crisis, end up accelerating the next big crisis, brought on by environmental decline?

Wrapped in green tape

Federal Environment Minister Sussan Ley already has a predilection for the green tape narrative. Announcing the current review of the Australia’s national environmental law, the Environment Protection and Biodiversity Conservation Act (EPBC Act) last October, she cast the review as an opportunity to cut ‘green tape’ and increase certainty for business.

The environment itself was only mentioned in the context of ‘maintaining high environmental standards’. Ley expressed no concern about the ongoing decline of the environment itself. And this was well before the COVID-19 crisis.

It is fair enough for the Government to look for increased efficiency, including in regulatory processes, as part of a plan for environmental recovery.

In federal environmental regulation, my first suggestion for efficiency would have been to fund the regulatory process properly. Successive governments have reduced efficiency by whittling departmental resources away through inflated ‘efficiency dividends’, code for general cuts. As a result, delays have gotten longer and longer, but of course they could have been reduced again by restoring the money.

But it seems that the Government is already on top of this one.

In November 2019 (ie, still before the crisis), it announced a $25m ‘congestion busting’ initiative to reduce delays in federal environmental assessments, including by establishing a major projects team ‘to ensure assessments can be completed efficiently and thoroughly in accordance with the Act.’

Recently, Ley announced that this initiative was delivering what appears to be significant progress. As of December, only 19% of ‘key assessment decision points’ were being met. But by March 2020 this had improved dramatically, to 87%. What’s more, the Minister says that figure should reach 100% by June 2020, all without relaxing any environmental safeguards under the EPBC Act.

In other words, the problem of slow environmental approvals will be solved in a couple of months.

I must admit to scepticism about this claim. I suspect that the assessments are much more superficial than they once were, more reliant now on accepting information provided by proponents and state regulators.

I also suspect that the introduction of user-charging for federal environmental assessments a few years ago, together with limited resources for compliance, mean that there are fewer projects under assessment. This is because proponents abandon a bias towards referring projects on a ‘just-in-case’ basis, in favour of a risk management approach, under which proponents weigh the costs of referral against knowledge that compliance action for failure to refer is unlikely.

However, let’s take the Government’s claims at face value for the moment and accept that regulatory delays, at least at the federal end, are on the way out. What else could they do to speed up environmental approvals?

More juice in the efficiency lemon

Even if individual statutory timelines are met, overall timelines can still be reduced, first by removing duplication between federal and state processes and also by removing delay at the proponent’s end. This latter kind doesn’t count as regulatory delay but is, of course, still delay.

Duplication is a complex issue and reform is a medium term task. But short-term gains could be achieved administratively, by forming federal-state task forces, ie by putting regulatory staff from both levels of government into a single team, tasked with shepherding the project through all processes as quickly as possible.

In the past I would have said the politics wouldn’t allow this, but I would also have said that a thing called ‘National Cabinet’ would never work. These are extraordinary times.

Proponents could also contribute to a task force model. I wouldn’t recommend direct secondment of proponent staff to task forces, as this is mixing the foxes in with the hens, but by increasing resources for their own project teams proponents could improve quality and responsiveness, both of which are essential to timely environmental assessment.

Avoiding the temptations of short-termism

So there are some gains to be had. Yet the temptation in a crisis is to grab onto anything and everything that might conceivably help deal with the problem at hand, taking a ‘tomorrow-can-look-after-itself’ attitude to any longer term consequences. And this is no ordinary crisis.

Beyond the marginal gains of efficiency, trading parts of the environment itself for a short term economic hit could look very tempting.

The OECD is alive to this issue and has come out with all guns blazing. In a recent statement, OECD Secretary General Angel Gurría argues, not just against weakening environmental standards, but in favour of stronger standards. In his view, governments should seize ‘a unique chance for a green and inclusive recovery … a recovery that not only provides income and jobs, but also has broader well-being goals at its core, integrates strong climate and biodiversity action, and builds resilience.’

In other words, kill two birds with one stone. Use your spending on post-virus economic recovery to advance longer term environmental recovery. Gurría has a three point plan for this:

First, align short-term emergency responses to long-term economic, social and environmental objectives and international obligations (ie, leverage your investment).

Second, prevent lock-in, not only of high-emissions activities, but also of impacts on vulnerable groups, who have been the worst affected by COVID-19. A key way to do this is through a fair transition to a low-carbon economy.

Third, policy integration. Integrate environmental and equity considerations into the economic recovery. This means that infrastructure investment, as well as government support to virus-affected sectors, should pass the test of contributing to a low carbon economy.

Don’t throw the baby out with the bathwater

The OECD is often described as a club for rich nations. And rich nations, including Australia, could be expected to take a conservative view about maintaining wealth.

Yet this advice sounds rather left of centre. In fact, in an Australian context, it is redolent of the mostly unlamented Rudd/Gillard/Rudd Government, which aligned its short term emergency responses to long term environmental objectives (think Pink Batts, 2008) and also pursued a fair transition to a low-carbon economy by compensating low income earners for the impact of the carbon price (think Clean Energy Future, 2011).

In my view the OECD is right but, in Australia, its advice may be cruelled by our recent political history. If the Government were to take the OECD’s environmentally-responsible but mildly collectivist advice it would be accused of taking the Rudd/Gillard path to disaster.

On the other hand, if the Australian Government follows through on its current rhetoric of a growth-led recovery and aggressive deregulation, we may be headed for solutions that throw the baby out with the bathwater.

Which will it be?

Image by Pezibear from Pixabay

Environmental regulation and the Productivity Commission

Is ‘efficiency’ the sole solution to the challenge of ‘sustainability’?

By Peter Burnett

Last week the Australian Government announced a new inquiry by the Productivity Commission (PC) into regulation of the resources sector. While not confined to environmental regulation, in announcing the review Treasurer Josh Frydenberg made specific reference to improving the efficiency of environmental approvals to reduce the ‘regulatory burden’ on business. Frydenberg also said that the review would complement the forthcoming statutory review of national environmental protection law, the Environment Protection and Biodiversity Conservation Act. (For more on this review, see my recent blog).

In his media release, Frydenberg repeated the mantra of recent governments: that the aim was to ensure that projects were assessed efficiently while ‘upholding robust environmental standards’. This largely reflects the terms of reference of the PC inquiry, which talk of removing unnecessary costs while ‘ensuring robust protections for the environment are maintained’.

The week before the inquiry was announced, the new chair of the Minerals Council of Australia, Helen Coonan (a former Howard Government minister), identified efficient regulation as one of her top priorities. She claimed that if project approvals were sped up by one year, this would release some $160 billion and 69,000 jobs to the economy. I’m not sure where this figure came from, but it may have been based on a PC inquiry into the upstream oil and gas industry in 2009, which estimated that expediting the regulatory approval process for a major project by one year could increase its net present value by up to 18%. In any event, that’s a juicy target for efficiency savings.

The PC’s role on sustainability

On its website, the PC advertises itself as ‘providing independent research and advice to Government on economic, social and environmental issues affecting the welfare of Australians’. That’s not bad for a slogan but the substance is a little more complicated.

Under the Productivity Commission Act 1998 the substantive functions of the PC are all cast in terms of industry development and productivity. And the PC’s statutory policy guidelines, to which it must have regard, are dominated by considerations of improving economic performance through higher productivity; reducing regulation and increasing efficiency.

The statutory guidelines do, however, include considerations relevant to sustainability. Beyond a direct reference to the need ‘to ensure that industry develops in a way that is ecologically sustainable’, there are also references to other things connected to sustainability such as regional development; avoiding hardship from structural change; and meeting Australia’s international obligations. Further, one of the Commissioners must be experienced in sustainability and conservation while another must be experienced in social issues.

So, while the PC is definitely about efficiency and growth, it doesn’t have a one-track mind. Environmental and social impacts are definitely members of the cast, though in supporting roles. As we’ll see below, the problem doesn’t seem to be the PC but what the government does or doesn’t do with its recommendations.

We’ve been here before

Industry keeps complaining about inefficiency and duplication in environmental regulation, and governments keep returning to this theme, often through references to the PC. In recent years, in addition to sector-specific reports on regulation (including environmental regulation) of transport, agriculture, fisheries, water, upstream oil and gas, and mineral exploration, the PC has produced general reports on native vegetation and biodiversity regulation (2004); planning, zoning and development assessment (2011); COAG’s regulatory reform agenda including environmental regulation (2012); and major project assessment (2013).

This is in addition to the statutory review of the EPBC Act itself by Allan Hawke in 2009, which also included significant recommendations for regulatory streamlining.

The PC has also conducted other relevant review activities, such as convening a roundtable on Promoting Better Environmental Outcomes (2009).

And it looks like we’ll do it again

The terms of reference for this latest review focus on identifying practices for project approval that have led to streamlining the process without compromising environmental standards. This is rather unimaginative and I think will simply lead the PC back to places it has already gone, such as recommending increased use of regional plans and other landscape scale approaches; increased regulatory guidance; and a single national threatened species list.

In response to past recommendations, governments have done some of all these things. For example, there is a process underway to adopt a common assessment method for threatened species listings.

But governments don’t seem to tackle the issues in a fulsome and vigorous way, to deal with them once and for all. In fact, they attempt to walk on both sides of the street, pursuing reforms in an incremental way while simultaneously cutting environment department budgets. On this basis, one must even question their appetite for reform.

So much at stake

So is environmental regulation just a convenient whipping boy? There’s so much at stake that I don’t think so. Perhaps governments are wedged between their own policies and the politics: they don’t want to increase spending and can’t be seen to water down existing standards, yet remain frustrated by the processes that those standards bring with them.

If governments want real improvements to regulatory efficiency, without simply winding environmental laws back, they have to front-load the regulatory process with information and guidance and resources, ie with things that the PC and others have already recommended. These boil down pretty much to landscape-scale approaches such as regional planning (done comprehensively) supported by increased levels of regulatory service, including detailed guidance on what will and won’t be approved.

It’s not rocket science, but it will take serious money. But keep in mind that such an investment would lead to saving even more serious money.

And there’s an incidental benefit in such an approach. Proper environmental information and planning will also improve the quality of decision-making, which should improve environmental outcomes.

Image: Image by Gerd Altmann from Pixabay