Assessment of the U.S. Outer Continental Shelf Environmental Studies Program: III. Social and Economic Studies (1992)

by R. Rappaport

This appendix to Assessment of the U.S. Outer Continental Shelf Environmental Studies Program: Part III, Social and Economic Studies, discusses possible impacts of outer continental shelf oil and gas development (OCS) on the ''human environment.'' Any understanding or assessment of the full range of such impacts requires the integration of social, cultural, political, psychological, and economic analyses. Furthermore, although every human environment is in important respects unique and although its unique features must be considered analytically, a generally consistent mode of analysis should be adopted if studies are to be useful.

The first section discusses the concept of the human environment. The second section lays out some general considerations, principles, and assumptions that underly the approach taken here to examining effects on the human environment. The third section presents a framework for organizing materials when considering potential impacts and makes specific suggestions for dealing with the effects. The third section contains three subsections, the first of which considers activities that are likely to produce impacts at each of the several stages of OCS activity, the second the dimensions of those impacts, and the third their distribution. The final section of the appendix presents a mode of analysis sufficiently general and flexible to accommodate the particulars of any region and at the same time to permit meaningful extrapolation, comparison, and generalization of results.

The Outer Continental Shelf Lands Act as amended in 1978 (43 U.S.C. §§1331-1356, §§1801-1866) mandates consideration of impacts on the human environment in all decisions concerning the leasing and development of offshore tracts. The term "human environment" was meant to include not only features of ecosystems as perceived by, related to, or modified by human populations, but those human populations and their social and economic systems as well.¹ Because

this simple characterization masks enormous complexity, it is necessary to enlarge on the distinctive nature of human environments before considering the possible effects on them from OCS leasing.

Human systems are complex not only because they include innumerable forces in continuous interaction but because some of the components included are categorically different from others. To be more specific, some of the components of human systems (including humans themselves) are the natural products, as it were, of the processes of genetics, geology, and ecology. Others, however—the socioeconomic elements of such systems—are symbolically conceived and socially constructed. This latter class includes the more-or-less distinctive political, legal, economic, social, religious, recreational, and aesthetic conventions of human communities. "Conventions" are rules, practices, ways of doing things standardized by law, custom, or habitual usage and, furthermore, the conceptions, perceptions, and understandings on which these rules and practices are founded. Several points follow.

First, human systems include a range of demographic, economic, physical, and social features and activities that are no less important for their being relatively obvious and straightforward. We can list here as examples population size and specific demographic and sociocultural composition; birth, death, and morbidity rates; and general conditions of health; patterns and rates of immigration and emigration; areal extent of populations; dominant economic activities; economic diversity (with special attention to tourism, fishing, and other maritime usages); employment and unemployment patterns and rates; household income; land-use patterns; transportation routes; traffic patterns and capacities; the tax base; government services such as education; infrastructure maintenance; police protection; and recreational facilities. Socioeconomic research done by the Minerals Management Service (MMS) of the Department of the Interior has been, in the main, confined to these more concrete and measurable features.

Second, it does not diminish the importance of demographic and economic aspects of human systems to make explicit, as has already been implied, that any adequate description of such systems must also take into account their social, symbolic, and conceptual elements. Indeed, economic systems are subsets of social systems and inasmuch as they are conventionally established and not "naturally" constituted, they are themselves social and symbolic in nature. An "economy" is, after all, a set of conventions—institutions, rules, understandings, and practices—for organizing the extraction, production, distribution, and consumption of goods, and the value of money is purely conventional.

It has already been noted that symbolically conceived and socially constructed conventions organize all aspects of human life. It is important to make explicit that the understandings on which conventional rules and practices are founded include not only those narrowly focused on specific aspects of human affairs but also more general and, from the point of view of the actors, more fundamental conceptions that govern morality, equity, justice, honor; religious doctrine; ideas concerning sovereignty, property, rights and duties; aesthetic values and what constitutes quality of life.² There also are distinctive understandings concerning the nature of nature, of the place of humans in it, of proper behavior with respect to it, and of equitable distribution of its fruits, its costs, and its dangers. At levels deeper than those occupied by substantive understandings and values, conceptions include assumptions about the nature of reality: what is given, what requires

demonstration, what constitutes evidence, how knowledge is gained. Such loosely structured bodies of understandings and the conventions and practices they inform are what anthropologists call "cultures," and what laypeople probably mean by such looser phrases as "way of life" or "traditions." It should be clear that although the demographic and economic aspects of human systems are relatively amenable to numerical representation, other aspects of society and culture, including some of those just listed, are not. They are no less real for that, however, nor are they less compelling as factors in human affairs for, as vaguely articulated as they sometimes are, they command great loyalty.

Third, although it is proper to speak of a generalized American society and culture, it must be kept in mind that regional, ethnic, class, and other differences play variations on that common theme. In some instances—native American groups stand out in this regard—the local version diverges widely from generalized American culture. In all instances the divergence is significant. It follows that the features of sociocultural systems in any area in which OCS development is being considered cannot be taken for granted: They must be explored.

Fourth, the last two points imply that it is necessary to develop understandings of the sociocultural systems in areas where there is a possibility of OCS development because sociocultural impacts are always in part relative to the particulars of the affected sociocultural system. For instance, it would be one thing for a spill to decimate fish and other marine life in an area exploited only by white American commercial fishermen and quite another to decimate an equivalent fauna in Bristol Bay, Alaska, which is fished and hunted by Yupik-speaking Eskimo. In the instance of the white fishermen the loss of the fishery is an economic loss. In the case of the Yupik the loss is not simply economic, because subsistence activities are central to Yupik cultural reproduction—the Yupik maintain that the destruction of their fishery would constitute genocide. It would be more accurate to call it "ethnicide": the people would live, but the quality of their lives would be badly damaged by the death of their culture.

Given this complexity, the conception of the human environment on which MMS studies have been based seems impoverished. To the extent that the concept has been formulated at all, it seems to have been conceived only terms of economics, demographics, and government. But adequate consideration of ultracomplex human systems, constituted as they are of conventions, rules, practices, and conceptions, as well as physical structures and features of the landscape, must rely on social, cultural (anthropological), and even psychological analyses as well. An integrated approach is required if information that is adequate to the gravity of OCS leasing and development is to be available to decision makers. This framework needs to be sufficiently comprehensive to allow the full range of phenomena constituting human systems to enter into the analyses and it must be inclusive enough to take into consideration the concerns of all interested parties—especially those who are likely to experience the impacts most directly. It should, furthermore, be sufficiently consistent to make for reasonably commensurate studies, thus facilitating extrapolation, comparison, and generalization—in short, to encourage learning from experience.

Before considering impacts on human environments, some general observations, principles, and assumptions that follow from the nature of human environments need to be made explicit.

1. Because socioeconomic systems are ultracomplex, and because they are always unique in at least some particulars (although possessing in common certain very general features), the range of

possible social, cultural, and economic effects on them of activities such as those related to recovery of OCS oil and gas resources cannot be specified, even in principle, in advance of studies that include empirical research, judicious extrapolations from experience, and methodologically sound projections.

Given this intrinsic complexity and particularity it is not legitimate to stipulate beforehand any limitations on what qualifies as social, cultural, or economic impacts. The establishment of such limitations constitutes an attempt to legislate reality, although the degree to which reality is amenable to such legislation is slight. Consequently, any limitation on the nature of what counts as a "real" impact (that it is physical or that it is amenable to representation in quantitative terms generally or in monetary terms specifically, for example) only misrepresent actual conditions. Given the responsiveness of human systems such misrepresentations are likely to have political, legal, and social effects that extend beyond those that attend the initial effect being defined.

2. Humans respond not only to events themselves but to information concerning events. Indeed, in this age of rapid communication, the overwhelming preponderance of response is not to the direct impact of events, but to news of those events. When information concerning physical events, rather than the events themselves, act as a stimulus, the physical events need not have yet occurred for there to be significant effects. Thus apprehensions about aesthetically unpleasing developments, for instance, or about decreased recreational possibilities, environmental pollution, or other diminishments of life's quality—and not simply the actual developments themselves—are real and immediate effects, and they are likely to lead to further ones. Moreover, uncertainty concerning the future of a region ineluctably increases from the moment a tract appears on a five-year plan until the failure of a lease sale or until exploration ends in either abandonment of the leasehold or in drilling. Such uncertainty also constitutes a real impact of OCS activity.

   Both apprehension and uncertainty about OCS activities and their predicted consequences are properly construed as impacts in the present because they alter the current psychic, social, and perhaps economic well-being of a community and because they stand in causal relationship to the future attitudes and behavior of that group of people.

3. It follows, but it is worth making explicit, that in ultracomplex systems in which humans are actors, some effects, particularly social effects and political actions, are not simply linear results of actions, as they may be in simple physical systems. Between causes and effects—that is, between perturbing factors and responses to them—lie understandings and evaluations not only of how the world is constructed and how it works but of how it should be constructed and how it should work. It is in terms of the latter (values) that the former (perceptions of actual states of affairs) are interpreted and evaluated. These values, it is hardly necessary to say, are socially constructed and are culturally and even subculturally variant.

4. The relationship between the news of an event and the physical characteristics of the event is not simple. News is not a simple function of an event; it is subject to amplification, dampening, editing, distortion, etc. in whatever channels it passes through, and requires interpretation by the receiver. Interpretation takes into account the reliability of the transmitter (source) and the channel (medium).

   It is well to emphasize here that maintenance of credibility can be a serious problem for both transmitters and channels, and the loss of credibility can be a consequence of these actors' responses to events. For instance, OCS EISs that an affected public takes to be inadequate or misleading can discredit their source, which can be interpreted to be MMS, DOI as a whole, the federal government as a whole, or even the party or person occupying the White House. Furthermore, there are grounds for believing that ill effects are perceived to be both more likely and more severe when information

sources are distrusted. Such perceptions can lead people to oppose even a project that could benefit them.

5. If impacts include responses of systems to perturbations, then the legal, political, and organizational responses of states, municipalities, industrial and trade associations, native American tribes, or environmental groups to announcements of OCS plans must be regarded as impacts. So must their opportunity costs, as must any conflicts that develop among state, local, and other groups as incompatibilities in their interests or positions become apparent. Conflicts between any and all of the other party and the federal government must be considered effects as well.

6. The previous points suggest that it may be possible to discern a general sequence in which impacts of different nature become dominant. Earliest effects, those following soon after the listing of a region on a five-year-plan, are likely to include, most prominently, increased apprehension and uncertainty about subsequent ecological, aesthetic, recreational, economic, and other alterations that could attend future OCS development. Apprehension is unevenly distributed in the population, of course, and immediately subsequent effects are likely to include attempts by more sensitive elements of the population (environmentalists, fishermen, state environmental agencies) to raise concern among the less sensitive. Increased legal and political activity by state and local agencies and already existing environmental groups and trade associations can soon follow, but often special state and local bureaucracies and special purpose grass roots organizations can spring into being. Conflict among those taking various positions comes next. All of this happens before any sale takes place. Subsequent to the sale, exploration and production have their own effects, including disaster and its possibility, and so, finally, does termination, subsequent to which there may be as yet unexplored residual effects.

7. That certain important consequences of gas and oil related OCS activity can be strongly felt well in advance of any actual physical activity on the part of oil companies may contradict some recent court decisions. It could be that the general failure to recognize prelease sale effects of OCS activities is related to their typical resistance to plausible quantitative representation. More easily quantifiable impacts—those most directly available to quantitative or even monetary representation—generally come later in the sequence. Because the early effects resist representation in terms with which many or most administrators are accustomed to approaching them, public discussion of early impacts has been hampered.

8. It is clear that some events or developments, and their consequences, seem to be in their nature metrical, or at least such as to make it possible to represent some of their aspects in numerical terms. An increase, for instance, in local population as a consequence of immigration of workers in connection with the construction and operation of a new industrial facility lends itself to numerical representation, and precise numbers may be plausibly and sometimes accurately predicted. So, perhaps, may be the monetary costs of expanding municipal services sufficiently to cope with the projected expansion of population. The effects of the uncertainty attending the possibility of OCS development on the value of beach-front real estate can often be precisely, accurately (and painfully) ascertained.

   Other aspects of the same events, however (for instance, possible tension arising out of disparities between the ethnic or socioeconomic backgrounds of newcomers and established residents), cannot be represented numerically, and it should be clear that a good many significant effects of OCS and other developments—the psychic and social tensions that attend uncertainty, or anger at and alienation from the government—cannot be represented adequately, or even at all, in quantitative

terms of any sort, let alone monetary terms. This is not to say that the prevalence of various opinions cannot or should not be sampled.

It is one thing, however, to quantify the prevalence of particular opinions on particular issues as they may be indicated by responses to the limited range of choices offered by particular questions asked at particular moments in an ever-changing history, and another to grasp the underlying structures of understanding out of which these opinions (and those with more nuance) emerge in response to unfolding events. Attempts to force the representation of such structures of understanding into inappropriately quantitative terms or, alternatively, to dismiss them because they cannot be so represented is to misrepresent reality. The aesthetic considerations of affected populations, for instance, or violations of their religious beliefs, or of their conceptions of equity, or even of their vague conceptions of the good life, cannot be ruled inadmissible because they resist monetary representation, or even quantitative representation of any sort, for they could well be—are even likely to be—the most significant factors for those populations in developing attitudes and taking action. These considerations cannot be disqualified as mere prejudices of uninformed laypeople. They are embedded in views of the world no more and no less arbitrary than other views of the world, and as such have valid claims to reality. They are social facts that will serve as grounds for action.

In sum, metrical representation (including the results of opinion surveys) should be pushed to the limits of plausibility but no further, and it is necessary to recognize that other considerations, often decisive ones, lie beyond the reach of plausible numerical representation. Attempts to reduce radically unmeasurable components of the world to common metrics as a preliminary to "bottom-line" calculations are not justified as an aid to clear thinking—the clarity and certainty so claimed is false.

9. The phrase "significant effects" requires comment. The term "significant" is taken here in both of its major senses. It means both "important" or ''consequential" on the one hand and "meaningful'' on the other. To say that a phenomenon is meaningful in this context is to say that it enters into the motivational processes of actors. This implies that values are of crucial importance in the arena of impact assessment and, therefore, that their consideration cannot be avoided. Risk assessment cannot be value free because values define what is at risk, and what is at risk may be values themselves.

   There are numerical approaches to value and values—indeed, in some of its aspects the conception of value, particularly when accompanied by a modifier ("food value" or "monetary value") seems intrinsically metrical. But the term also refers to conceptions like "truth," "honor," "beauty," "equity," "honesty," "wholeness," "integrity," "sanctity," "trustworthiness," "life," "liberty," and "happiness." Two subsidiary points are to be made here.

   First, most, if not all, of these values are not merely nonmetrical in nature; there is a radical incompatibility between them and metrics of any sort, and there is an absolute contradiction between some of them and monetary valorization. This contradiction is indicated by such questions as "How much money is your integrity (or trustworthiness or honesty or vote) worth?" Such values are misrepresented if they are represented metrically; the assignment of monetary values to them renders them false. Attempts to mitigate violations of them through cash awards are likely to be taken by those to whom they are offered as insults heaped on previous injuries. Thus, for instance, the Shoshone have refused to accept a cash award of tens of millions of dollars as compensation for what they construe to be seizure of their lands by the federal government in violation of the Ruby Valley Treaty of 1863, and the amount has remained in escrow for more than 30 years. Similarly, many people in Nevada characterized as attempted bribery the suggestion that they receive large cash payments in return for accepting the national nuclear waste repository.

   The second subsidiary point: fundamental or basic values tend, in their nature, to be very low in specificity. What is it, after all, that constitutes "liberty" or "happiness," or for that matter,

"life?" To say, however, that values are not specific or even vague does not say that they are not cogent, or even decisive, in the formation of positions on which social actors stand, from which they define the general conceptual, social and geographic territory which they feel is rightfully theirs, and from which they will act. It could well be that there is a direct correlation between the vagueness of a value and the strength of the motivations it engenders. People will put their lives in danger to protect whatever they mean by "liberty" or "democracy," but not to balance the budget.

0. A general value of sufficient significance to warrant special mention is fairness, because Americans are likely to take OCS oil and gas related activity to be in its nature unfair. Two aspects of equity can be perceived as under attack. First, there is the question of distributional equity. Affected populations seem quick to perceive that the most substantial benefits of development are likely to flow to parties other than those most directly exposed to the risks. Second, and even deeper, it seems that the attitude of publics to public land is that it is in some sense theirs. That a private interest, or an alien interest, can curtail or endanger their use of what they see as their own (whether it is their private property or a public amenity) violates not only a deep sense of right, but possibly a deep sense of connection to place: "Who are they that they can endanger our wetlands (or ducks, or fish or beach)?" A public sense of violation and its attendant feelings of outrage and alienation are properly regarded as possible impacts of OCS activity, as are any political reactions that ensue.

1. The next point is related. Communities can take projected OCS developments to endanger something that may seem even vaguer and more general than fundamental values. They can refer to whatever it is as their "way of life," or they might use the slightly more complicated term, "culture." At the heart of a "culture" or ''way of life" are symbolically mediated and socially constructed sets of assumptions about the nature of the world and its inhabitants, and they are realized and maintained through customary action. Among certain native Americans, and the inhabitants of coastal Alaska are prominent in this regard, the customary actions through which indigenous culture is maintained and reproduced are in the main those surrounding subsistence activities. This is to say that hunting and fishing are of importance not only, or even any longer primarily, as the way to obtain food and fur. They are the main means by which Eskimo, Aleut, and other indigenous cultures are kept alive, and perceived threats to them will be bitterly resented and resisted.

   Given their cultural centrality, there is no way to compensate such peoples for the loss of their subsistence bases. As already reported, Eskimo informants say that developments that would make traditional subsistence practices impossible would be equivalent to genocide. It need hardly be said that there is no valid way to assign a monetary value to a culture, or to its disappearance. Such impacts are, Eskimo informants insist, unmitigable.

   Violations of a community's values or threats to its way of life must be understood to constitute, in and of themselves, serious impacts on that community. It can be suggested as a hypothesis that the less amenable to metrical representation and the vaguer the threatened value is, the stronger will be the response to its violation, for in such instances the defenders understand themselves to be acting on general principle rather than from a personal interest.

2. It follows, and indeed may be in the nature of human systems generally, that violations of a community's conceptions of its rights in its local surroundings, or of its conceptions of justice and equity, or perceived threats to its general "way of life," or to its basic canons of reality, frequently will take precedence over material considerations in the conduct of community affairs. It could further be characteristic of human systems that actions undertaken in the name of justice, say, or environmental integrity, or in defense of a way of life, or of basic conceptions of reality are likely to be more highly charged emotionally, more physical, and more aggressive than are those undertaken

in the service of economic or material advantage. It is of interest that the "higher principles" invoked in response to perceived threats to a way of life or its highly valued constituents license, or even sanctify, forms of action that the actors themselves would in other circumstances condemn, or at least declare illegitimate. Examples include the civil disobedience campaigns in the American south, and of otherwise law-abiding citizens breaking laws in "pro-choice" versus "pro-life" confrontations. But even when such actions are illegal or criminal, they are viewed by their partisans as legitimate or even heroic—and their partisans are often legion.

3. This account proposes that when a community's concerns are ignored by analysts and decision makers the matters at issue change. The dominant issues become matters of "high principle." When issues are escalated to the level of high principle, they are no longer objective items of dispute that can be resolved through the establishment of fact or through the logic of costs and benefits; in the "principled mode" self-sacrifice is more highly valued than is material benefit. The issues might already have so escalated in California and Florida (OCS Leasing and Development Task Force, 1990). Escalation into the "principled mode" should be counted among possible impacts of OCS activity.

4. An implication of the discussion so far is that whether or not a community's understanding of the world's nature, or whether or not their values concerning it are "realistic" in terms of "objective" canons of reality established by disinterested analysts, or whether or not the community's fears are, in the view of analysts or officials, fanciful is, in some degree, beside the point. Impacts are, in considerable degree, to be understood relative to the affected community's definitions of reality.

   It follows that analysts and decision makers must assume that the views of an environment held by those living in it are realistic even if community views differ from those of the "outsiders. Analysts and decision makers must not, therefore, dismiss the apprehensions of local populations concerning risks and their probabilities as paranoid or misinformed. To put it a little differently, the concerns of local people must be given full and respectful treatment because it is the environment as they conceive it that, as far as they are concerned, will be affected, and it is in terms of these understandings that the community will respond to OCS activity. An exploration of these conceptions is, therefore, a necessary part of any adequate analysis. Failure to give full and respectful treatment to local conceptions, perceptions, and apprehensions has, in the past, led to widespread citizen alienation and anger; to political and legal action; and even to threats of violence. Such responses are themselves to be considered impacts of OCS activity, and often grave ones at that.

5. At an even deeper level, such questions as "Our concerns are so obvious, why can't MMS understand them?"—a question asked of the Socioeconomics Panel by people as diverse as Yupik-speaking Eskimos on the coast of Bristol Bay, Alaska and state and local officials in southern Florida—suggest that failure to take seriously or to consider respectfully citizens' concerns are perceived as challenges to their fundamental understandings of reality. It can further be suggested that for a community to have its understandings of reality disregarded by a powerful authority is profoundly alienating, for it leaves no common ground on which the community and the authority can stand. There is nothing left to do but fight.

6. Note, however, the qualifications "in some degree" and "in considerable degree." It would be a serious error to suppose that impacts are to be defined only in relation to the community's understandings, for many serious consequences can be unforeseen by those who will be exposed to them. It is the responsibility of those who prepare environmental impact statements not only to grant

reality to the concerns of affected communities but to bring to the attention of those communities effects that they might not anticipate.

7. It is important to note that unforeseen as well as foreseen impacts may well include beneficial as well as harmful effects. Thus, for instance, onshore infrastructural developments associated with offshore installations, such as new or improved roads, not only increase the amenities available to people living in remote areas, but even make positive contributions to the quality and length of their lives by making medical care more accessible. That this discussion has not emphasized positive impacts does not constitute a claim that positive impacts are inconsequential or do not deserve attention. It reflects what appears to be the dominant orientation of populations in regions affected by OCS activities. Possible positive as well as negative impacts should be honestly represented in both environmental studies and environmental impact statements.

8. It follows from all of the points so far noted that impact studies themselves are not devoid of possible impacts. For an impact statement to ignore, dismiss, disqualify, underestimate or, in the view of affected parties, misrepresent or represent inadequately their concerns is for the statement itself to provide evidence to those affected parties that they are being unjustly treated. It is both plausible and prudent to assume that the community will respond to perceptions of injustice in whatever ways are available and that they deem appropriate. Active responses can include emigrating—likely when strong opposition combines with the sense of powerlessness and failure of trust in the institutions responsible; voting those viewed as responsible out of office as soon as possible; or more aggressive forms of political activism, such as forming ad hoc organizations, demonstrating, or even committing sabotage. Such responses are themselves to be include among possible social consequences of OCS activity likely to be evoked by inadequate impact statements.

   That such overt actions fail to materialize should not be taken to indicate unambiguously that projected developments or officially published environmental impact statements have elicited no responses, for responses can be passive. "Passive responses" are cognitive and attitudinal effects unaccompanied by overt action. The operative cognitive and attitudinal stance resulting from impact studies that the affected community finds inadequate, unfair, or dishonest may well combine feelings of powerlessness and increased cynicism (concerning public institutions and their control) into a sense of alienation. From such a perspective any and all action may seem futile. That people come to believe the adage about the impossibility of fighting city hall, and act—or do not act—accordingly, is itself a possible response to, and thus an effect of, impact statements.

   Increases in certain forms of social pathology (substance abuse and domestic violence) may be related to, or even aspects of, passive responses in situations of powerlessness.

9. Among the most significant components of environmental impact statements, as far as affected communities are concerned, may well be estimates concerning the probability of spills and the magnitude of their effects. If the probabilities of spills are represented (rightly or wrongly) to be much lower than the common sense of the community projects, or if their effects are, in the community's view, significantly underestimated, and if these projections cannot be effectively defended, the trustworthiness of the institutions responsible for the preparation of the impact statement will come into serious question. In the cases at hand these institutions include, in the first instance, MMS, but unless clear instances in which the general DOI position has varied from (if not resulted in the reversal of) the MMS position are known to the community, the integrity, or even legitimacy, of DOI generally may be impeached coincidentally with that of its constituent agency. DOI, in turn, is itself an agency of the federal government, and deterioration of trust in it may undermine confidence in the federal government generally. Higher agencies and authorities increase their vulnerability in

this regard when they themselves enter into the decisions concerning such matters as lease sales. They become yet more vulnerable when they enter into the processes through which such decisions are reached, as in the case of the presidential task force on the California and Florida leases (OCS Leasing and Development Task Force, 1990). Undermining the confidence of the community in agencies of the government, or even questioning the legitimacy of government itself should be regarded as a possible impact of impact studies themselves.

0. The last point alluded to "affected communities," but full analytical isolation of "affected communities" from those that are not affected is impossible if the term "affected communities" is understood to mean all of those that take themselves to be in some way threatened and all of those in which active or passive responses take place. It is obvious that communities in Alaska, for instance, have been much more directly and seriously affected by recent events in Prince William Sound that resulted from the Exxon Valdez oil spill than have communities elsewhere, but there have been, and will continue to be, responses to the Alaskan events in communities and among people far distant from Alaska. Thus, for instance, the Alaskan events were continually alluded to by citizens speaking at the first presidential task force workshop in Carlsbad, California in May 1989 in opposition to the southern California lease sale, and by officials and citizens speaking during the Socioeconomics Panel hearings in both northern California and southern Florida. There have also been responses across the nation. Such nonlocal responses must, of course, be included in any serious and comprehensive account of the impacts of OCS oil and gas leasing activities.

   The responses of those distant from the site of an event have varied in ways that could not have been fully predicted, and they can be fully grasped only through empirical research. It can be suggested with some confidence, however, that the responses have combined to produce a cognitive, social, political, cultural, and perhaps even economic environment increasingly hostile to OCS activity. To use a medical metaphor, the Exxon Valdez may have "inoculated" the society against OCS activity, stimulating organizational, cultural, cognitive, and political "antibodies" against further OCS development throughout the entire society. The Kill van Kull spills and the Mega Borg rupture could be regarded as booster shots. The antibody effect must be included among the possible impacts of OCS activity.

1. Discussion of the antibody effect, which entails extrapolation from actual events to future possibilities, raises questions concerning the extent to which knowledge of actual effects of OCS activities and their comparison with earlier projections of what those effects would be is used in the preparation of new environmental impact statements. These questions raise, in turn, further questions concerning the extent to which actual effects—social, cultural, cognitive, economic, political, and environmental—have been studied during and subsequent to exploration, production, and termination in areas in which OCS activity is longstanding. In the absence of such corroborative studies, affected communities could well find the projections advanced in impact studies to be at best questionable. Environmental as well as socioeconomic effects are listed here because the publication of an impact statement that advances questionable ecological projections is likely to elicit at least as negative a public response as is the publication of dubious social and economic projections. Impact statements that ignore previous experience and treat the case at hand as if it were the first to be examined are likely to be distrusted by affected parties, and their publication is likely to reinforce general distrust of the institutions responsible for their preparation. Such distrust is justified, of course, for any study that ignores relevant experience of the very agency that authorized it is deficient.

This section considers potential impacts in more specific terms. In addition to a detailed baseline description of particular human environments, the framework for doing this has three elements. It includes, first, activities that can produce impacts and possible reactions to them; second, the dimensions of these impacts; and third, the distribution of these impacts throughout the human environment. Any continuing presentation of potential impacts of particular OCS activities cannot do justice to the complexity of any particular case. The effect of a particular activity in a particular human environment is highly likely to have further impacts. Effects become causes that branch out through ultracomplex systems, but how they do so is to such a degree contingent upon the particulars of each system that general statements by themselves are likely to be meaningless. Although experience gained in one area will always be relevant in others, particular area studies are always required. In any instance, the elements constituting the model should be integrated into a systemic analysis.

In systems in which information is causal—a class that includes all human systems—the apprehension about events can, as we have already noted, cause effects before their occurrence. Apprehension and forethought are characteristic of adaptive processes and it is, therefore, not surprising that the impacts of OCS leasing invariably commence years before any leasing actually occurs. Should leasing take place and exploration ensue, impacts continue and their scope changes, as they do further if hydrocarbons are discovered and development and production are undertaken, nor is termination without effect. Although impacts obviously vary from region to region depending on the specific characteristics of human and natural environments, it is possible to make some broad generalizations about the effects that are expected at each stage of activity.

Prelease activities include publication of five-year plans, announcements of intention to lease, preparation of supporting documents (EISs, SIDs) and the lease sale itself. Responses to these activities are likely to be widespread and have increased in both intensity and magnitude since the policy of region-wide sales was inaugurated during the Reagan administration. Responses are likely to engage local, county and state governmental agencies, fishing and resort industries, chambers of commerce, coastal real estate interests, citizens' groups, and environmental organizations. The responses are not confined to the locality, for the environmental organizations most active in resisting OCS activities are national. The national public is informed of developments not only by such organizations but also by the national news media. The public in coastal areas distant from the events could consider itself less immediately threatened but read the news as warnings about possibilities in its own future and, consequently, begin to develop attitudes toward development of the outer continental shelf off their own shoreline.

Responses that can commence with such psychological effects as fear and anxiety with publications of five-year plans and that may intensify with announcements of lease sales, include, first, organizing to deal with what is generally taken to be a threat. Organizational efforts may entail

setting up new agencies with substantial payrolls and therefore may include substantial monetary as well as opportunity costs. Activities undertaken by governmental agencies may include legislative, administrative, legal, lobbying, and public relations elements, and environmental and citizens' groups may also engage in public relations, lobbying, and legal action as well as electoral politics and direct action (e.g., demonstrations). While apparently there have been no cases of civil disobedience with respect to OCS development, it has occurred in opposition to nuclear development, and the rhetoric of active, forceful, and even armed opposition to OCS development was used in both Mendocino County, California (which barred the president's task force from even holding a hearing within its boundaries) and southern Florida (where the task force was met by large and hostile demonstrations in both Miami and Key West).

It is of interest that, outside the Gulf of Mexico, local, state, and regional reactions anticipating OCS development have been predominantly negative if not downright hostile. Some of the reasons for this will be addressed below in "Distribution of Effects." It should be noted that resistance to development, mobilized in response to MMS prelease OCS activities, has impacts on MMS itself. For one thing, its Environmental Studies Program has become driven by the requirements of litigation rather than by the need for scientifically adequate information. Moreover, the impacts are not confined to MMS or even DOI. In the absence of effective procedural means for postponing or canceling lease sales, Congress has routinely intervened in OCS activities by imposing moratoria. Congress is thus affected, for demands are made on its time and attention, and its ultimate authority is, misused when it is continuously invoked in what should be routine procedural matters. When issues that should be decided on ecological, economic, and social grounds are passed to Congress for decisions, they become vulnerable to decision in terms of political considerations, that is in terms of considerations having little to do with either regional ecology or the nation's energy needs. To the extent that a decision is made on political grounds it is likely to be a poor one, or, at best, right for the wrong reasons.

It is plausible to argue that there will always be at least a residue of differences of opinion about and interest in OCS activity. It nevertheless seems that the conflict that has characterized OCS development almost everywhere it has even been contemplated both grows out of and nurtures a deep public distrust of MMS, DOI and, through them, the federal government as a whole, not to mention the oil industry and, through it "big business" generally. This distrust, and the anger and alienation related to it, must be counted among the impacts of OCS activities, and they probably reach their fullest expression during the prelease phase.

Some degree of public distrust is probably an unavoidable consequence of conflicting interests, but much of it may be engendered by EISs that the public believes to present unduly optimistic risk estimates. MMS is in a seriously vulnerable position in this regard because it has not studied the actual effects of its own previous activities, much less brought them into consideration in the preparation of new EISs. It could be argued that the public is being no more than prudent in distrusting the products of an agency that has not evidenced an ability to learn from its own experience.

A further product of this distrust and the lack of substantial information concerning actual effects that, in part, grounds that distrust, perhaps combined further with the generally held belief that a decision to lease is a decision to produce, is an escalation of issues from objective matters of economic and ecological costs, risks, and benefits to matters of high principle. As discussed above, matters of high principle are more difficult to adjudicate than are objective concerns and their defense may seem to their partisans to legitimize actions otherwise outside acceptable bounds. Such escalation already characterizes resistance to OCS development in California and Florida, and perhaps other areas as well. It is to be counted among prelease impacts.

Responses that immediately follow lease sales but that precede exploration need to be studied.

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a substantial proportion of the OCS labor force, also peaks. Purchases of goods for the project increases and, depending on the area's pre-existing facilities, these purchases may have a significant effect on the local economy. Indeed, in some instances the local community may turn into a boom-town, manifesting all of the tensions and problems characteristic of such places.

Whether or not the full range of boom-town features materialize, OCS activities during the development stage do have the potential to transform the social and cultural characteristics of the community for reasons beyond the obvious influx of new and perhaps subculturally distinct workers, infusions of money into some sectors of the community, new strains on existing structures and services, and so on. Less obvious but, in the long run, possibly more profound: A large development presents opportunities and imposes constraints on community and individual choices that previously did not exist. For individuals the decision may now be between taking high-paying jobs in the hydrocarbon industry and continuing one's high school education, or going on to college. Communities may not have had a decisive, or even very significant voice in the decision to develop, but once the decision to extract OCS hydrocarbons has been made, decisions to develop other industries, such as tourism, may be effectively precluded.

Such decisions not only have opportunity costs but may also result in what Freudenburg and Gramling (1992) have called "overadaptation" and others (Bateson, 1972; Rappaport, 1977, 1979; Slobodkin and Rapoport, 1974) have characterized as "loss of adaptive flexibility." The individual or community so specializes itself that it finds it difficult or impossible to adapt to changed circumstances—such as the disappearance of an industry—that are inevitable for those industries that are based on the extinction of nonrenewable resources. Some Louisiana coastal communities, for instance, Morgan City, which were heavily engaged in the support of inner continental shelf activities, provide classic examples of the process. It is worth noting that overadaptation or loss of adaptive flexibility could well account for the extinction of most of the species that have disappeared from the earth.

During production, the preponderance of OCS activities begins to shift from the field itself to processing areas. Production is technology-and capital- rather than labor-intensive, and local employment is likely to drop during this phase from its peak during development. Moreover, the production economy is an enclave economy. The Gulf of Mexico aside, operating rigs are likely to be manned by employees from outside the locality who fly in for two-week shifts and fly out for breaks. Onshore facilities obviously vary with the amount and type of product extracted. Gas comes ashore in pipelines, but the onshore facilities do not require large numbers of employees. Oil can be brought to shore by either pipeline or tanker. If it is brought to shore in tankers it may be landed for processing outside the production area altogether. This may spare the locality an undesirable shore facility but it also reduces the contribution that the hydrocarbon industry makes to the local economy.

In sum, the contribution of OCS activity to the economies of local areas is likely to reach its peak during the development phase. It is then that employment is highest and that the largest sums of money are disbursed locally for services and supplies as well as for wages. It is then, consequently, that the local multiplier effect of the industry's expenditures is highest. Less money is likely to be disbursed locally during production and local employment declines, leaving perhaps significant unemployment. Suppliers of goods and services who have expanded to meet the needs of OCS development might need to contract. In short, if development generates boom characteristics in the towns or regions in which it occurs, a bust can begin with production.

It is obvious that production constitutes the ground for the full realization of conflicts over

space use and other matters, such as air and water pollution and between oil and gas producers and other interests, and with production the likelihood of spills becomes much higher than during earlier periods, when it is very low. The magnitude of the hazard also becomes much greater. These risks are very difficult to calculate but do depend to some degree on the means chosen to store extracted gas or oil in the field and to bring them ashore. Although pipelines can leak, tankers are more likely to.

It might be obvious but it should nevertheless be made explicit that these brief outlines of likely impacts of development and production propose entailments of these two types of activities. It is unlikely that so stark a contrast will be realized so clearly or abruptly in the actual history of any region because the two phases are not likely to be temporally distinct. Exploration and development can continue even after production is well under way, and even after some production platforms are no longer in use.

The process of termination itself requires more and different labor from that employed in production, and employment rates may rise in the short run while it is taking place. The effect of this increased labor demand on local unemployment rates, short-run at best, may further be minimized by the employment of experienced workers from outside the area.

To the extent that the economic and social characteristics of regions have been shaped by the petroleum industry, its phasing out and ultimate disappearance will cause further difficulties, and their solutions may be hampered by overadapted labor forces and landscapes that have been polluted and transformed by large onshore facilities that become increasingly unsightly as they fall into disrepair. It is not only that an important part of the economic base has disappeared, but its disappearance has left in it wake conditions that may hinder alternative uses and repel those who might invest in their development. Investment in the development of other industries may also be hindered because there is likely to remain, even after termination, considerable uncertainty concerning the future of gas or oil extraction in the area. Termination is not generally a consequence of wells running dry but of their becoming unprofitable under prevailing or foreseeable technological, pricing, and competitive conditions. Given increasing scarcity of gas and oil, and given the likely developments in technology with consequent radical changes in costs and revenues, shut-in fields could be brought back into production on relatively short notice. Continuing uncertainty thus compounds other difficulties that are the legacy of hydrocarbon production.

OCS activities can, as discussed above, affect not only the physical features of human environments but also their demographic, economic, political, social and cultural processes. These effects are likely to be extraordinarily complex for several related reasons.

First, primary impacts such as the influx of workers, produce secondary impacts, such as strains on municipal infrastructures, interethnic tensions, increase in certain forms of crime, windfalls for suppliers of certain goods and services, realignments of real estate values, and increases in the anxiety levels of long-term residents.

Second, various primary and secondary effects can operate synergistically not only to intensify each other but to produce further effects.

Third, human systems are not inert masses capable of remaining passive while they are being

shaped by outside forces. Like all living systems, people and their communities respond to these effects and their responses can be diverse and difficult or impossible to predict. These responses may have impacts on the program or agency impacting them, but not only on them, and ''counter-impacts" are not likely to be confined to the region of development. As was argued above, for instance, the Exxon Valdez disaster, subsequently reinforced by the Mega Borg and Staten Island spills, might have inoculated populations of the entire American coast against OCS development.

Fourth, impacts—and this is especially the case in the class of impacts labelled here "responses"—are always, in some considerable degree, culturally and even subculturally relative.

All of these considerations join to underlie the need not only for intensive and detailed studies of particular aspects of the human environment in each region under consideration for lease sales but for their integration into comprehensive analyses. These studies should not, of course, be limited to listing possible impacts but should attempt, to the degree possible, estimate what may be called their "dimensions." Such estimates must be based on the best information available, including previous experience in other areas and analogous cases from other industries where it is applicable, and may dictate changes in the phases of OCS activities at which the requisite studies are undertaken.

There are several dimensions. The list presented here is, to some degree, arbitrary and overlapping and may be incomplete.

The likelihood of an event's occurring is most tangible for physical events, especially spills. These are uppermost in the minds of the public. Risk estimates, if they are to earn the respect of the public taking itself to be at risk, must be grounded in experience, and these grounds must be made public. In the absence of experience one does not operate in the world of probability but of uncertainty. Whereas risk can properly be expressed in numerical terms, uncertainty cannot, and to represent uncertainty as probability is to invite distrust, which constitutes a serious impact in its own right.

Although the likelihood of disaster may be uppermost in the public mind, uncertainty and probability also surround other aspects of development. There is, for instance, an effect on the market for beach front property of uncertainty about the location and nature of onshore facilities. The differences between tanker spills, earthquake-related blowouts, and the location of onshore facilities makes it clear that we can identify two classes of uncertainty: "essential uncertainty," which cannot be reduced because there might not be any way to obtain the data requisite to estimate probabilities (earthquakes 20 years in the future, for example) and "contingent uncertainty," which can be reduced by a decision or action (locating a shore facility).

One complication must be noted here. Uncertainty is not only a characteristic of some possible impacts. It itself is an impact in its own right, with consequences as concrete as decisions not to invest in real estate and as intangible as continuing feelings of anxiety and anger. As an impact, uncertainty itself has a probability that approaches 1.0.

Some impacts are highly likely but not very consequential. Others are unlikely but very severe. The magnitude of impacts is in some degree independent of their likelihood and the two must be conceived and approached separately, at least in the beginning.

No single metric is in itself adequate for the estimation of magnitude. Monetary values can

be plausibly estimated for some but not all forms of impact. Employment rates, health statistics, cultural consequences, number of people affected, duration of effects, and reversibility of effects are all aspects of magnitude, some of which are not plausibly metrical although very real.

Magnitude has spatial aspects. There is, first, a continuum between concentration and diffuseness but the two are not mutually exclusive. The Exxon Valdez disaster had a concentrated effect on more than 1,000 miles of coastal Alaska and the on livelihoods and ways of life of people living in that region. It had more diffuse effects throughout the United States and even, with some attenuation, in other parts of the world, with some increase in focus in areas like southwestern Florida, the northern and southern California coasts and New England—all of which were especially sensitive because they were facing lease sales. There were obviously impacts on New York and Houston, where Exxon's headquarters are located, and so on. The magnitude of impacts may be widely dispersed in this era of instant communication and social amplification must be considered in its assessment.

There are several temporal aspects of impacts, two of which are noted here. There is, first, as already noted under magnitude above, the matter of duration, occurring on a continuum from evanescent to everlasting. Second, some effects are continuous, perhaps rising and falling through time; others are intermittent. In cases in which possible effects are intermittent there are the further questions of whether periodicity is regular or irregular, and what the frequencies are.

Some impacts pass away leaving, soon after their termination, few if any marks of their occurrence (e.g., the impact of exploration that has not succeeded in discovering gas or oil, for example); the effects of other activities can accumulate. This is obviously the case for some physical events (oil deposition in wetland fish spawning grounds), but also can be characteristic of more purely sociocultural impacts. Thus, the repetition of confrontations between local citizens' groups and government agencies may cumulatively abrade public trust in government.

The effect of accumulation does not always conform to expectations derived from simple arithmetic. For example, the impact of one offshore support vessel working out of a small harbor might be slight; the impact of a second might double it but still be slight. After some increase in the number of vessels, however, qualitative changes can begin. New docks, new fuel delivery routes, and changes in the proportions of persons employed in the petroleum versus the fishing industry and in their consequent places in the local economies and political arena could result.

Some impacts may be self-limiting and self-correcting. Given enough time, a fishery could recover from the effects of a spill even if no remedial action is taken. Other effects can be offset or

minimized by corrective action and, when they cannot, cash compensation is feasible if not always satisfactory.

On the other hand, in some cases mitigation is not possible. The destruction of wetlands that constitute hatcheries for commercial species may do irremediable harm to commercial, subsistence, and sports fisheries. Compensation can make partial restitution, but cannot restore the ecosystem or a lost way of life, and in some instances such a loss may be inestimable. It has already been noted that the Yupik speaking natives of Bristol Bay, Alaska, believe that a spill in the area's wetlands would be likely to destroy the species on which their subsistence fishing depends. Inasmuch as their culture is, in the main, maintained and reproduced through subsistence activities, such a loss would not be simply a loss of food, which could easily be compensated for, but a loss of the means by which their culture is reproduced, which could not be compensated or otherwise mitigated.

The benefits and costs of OCS development are never shared equally by all elements of any human system. There are almost always some who benefit and others who are harmed. Some inequities resulting from OCS development are obvious. Those who derive livelihoods by providing support to OCS activities with goods and services obviously benefit, as do the previously unemployed who find jobs in the offshore fields or in onshore support and those who, although previously employed, find higher-paying jobs in the petroleum industry. Losers can include coastal industries that are more or less incompatible with oil production: the resort industry, for one, and also, perhaps, the fishing industry. Also among the losers are other employers who, unable to pay competitive wages, must either suspend operations or go out of business. An instance of such circumstances is provided by Alaska's experience when Exxon paid extremely high hourly rates for unskilled labor in its attempt to clean shorelines following the Exxon Valdez spill. Somewhat less obviously, entire communities can lose if OCS development is temporary and results in radical declines in employment and leaves behind rusting and crumbling shore facilities.

Within communities there are further inequities that, although consequences of OCS development, are not necessarily entailed by them. Gramling (1980), for instance, found that white males have benefitted disproportionately from the increasing employment associated with the growth of OCS activities in the northern Gulf of Mexico. The possibility of inequities among the benefits and burdens suffered or enjoyed by different classes, ages, sexes, races, and other sectors of communities in the vicinity of OCS activities will always vary in some degree from case to case and must always be studied. Explicit mention needs also to be made of questions of intergenerational equity. These questions may be ethical rather than political, legal, or strictly economic questions because future generations are obviously not on hand to contest the rate at which resources are extracted, the environment contaminated, and the landscape scarred.

Inequities are not confined to a region. The environmental risks and the social, economic, political, and cultural stresses attending OCS activity are largely borne within the region of development, whereas much of the benefit of OCS activity and the hydrocarbons produced by it accrues to the national system. This understanding does have some merit. ''Warrilow's Law" (proposed by Christopher Warrilow with respect to open pit mining in Papua New Guinea), states that the distribution of the benefits of large scale mineral extraction is inversely proportional to distance from it, whereas the distribution of its costs and damages is directly proportional to proximity to it. But the easy and vague assumptions that the national system accrues only benefits while costs and damages are largely confined to the area of development and that it is the national system as a whole, rather than particular components of the national system, that benefit, cannot be left unquestioned. It

can be argued that the national system not only benefits but suffers costs in relation to most OCS developments. These may include endangerment of fisheries, resulting in higher seafood prices for consumers, cost to the federal government of environmental cleanup, a reduction in public or legislative pressure to find alternative ways to meet long-term energy needs, and alienation of citizens in immediately affected areas. It is furthermore not sufficient merely to assume that the benefits of OCS development are simply diffused throughout the national system in the form of less expensive and more reliable fuel supplies and enhanced national security. It is plausible to suppose that, in addition to such diffuse general benefits, more concentrated and significant benefits accrue to certain elements in the national system, especially oil and gas producers. Whether or not—or at least to what extent—such suppositions conform to the facts is not the point here. The point is that the distribution of benefits and costs outside as well as inside the region of development are matters for research and analysis and not for supposition or assumption.

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