Course:ECON371/UBCO2011WT1/GROUP3/Article3

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Summary

The Center for Biological Diversity and counterparts, the Sierra Club, and the Grand Canyon Trust, argue that the Arizona Department of Environmental Quality’s action to issue three air and one aquifer pollution permits in early March of 2011 to three uranium mines located on public land within the Grand Canyon National Park’s watershed risks damage to the environment and human health. The public, the Center for Biological Diversity, and allies oppose the action citing adverse environmental and social impacts such as more radiological contamination of soil and water of the Grand Canyon region, and potential for human exposure to toxic fine particulate matter uranium dust. While still subject to federal approval prior to opening, the permits move the mines one step closer to operation.

Further, they believe that the Arizona regulators’ decision to issue the mines “general” permits, “the kind used for gas stations and other common facilities”, undermines their very own duty to protect the environment. These permits do not require monitoring for fine particulate matter uranium dust or water quality down-gradient of the mines and lack a remediation plan in case aquifer contamination does occur. They emphasize that under the former administration, Arizona regulators were more stringent in permitting mines in the region. Citing a bad track record of contamination by uranium mining the region and an equally inadequate cleanup effort, they are outraged Arizona regulators are not only allowing the activities to proceed but loosening up on restrictions placed on the permits.

Analysis

This article is clearly a subjective account of uranium mine permitting in the Grand Canyon region, jointly released by three environmental organizations opposed to the activity. This fact is noted to preface and caution that the economic issues presented therein and analyzed herein are largely one sided. However, the article raises some pertinent concerns with regard to environmental economics, including issues of risk, public policy, monitoring and enforcability, and social costs. All of these factors are considered in the following analysis with some speculation as to why the other side made the choice to issue “general” permits to the proposed uranium mines located in the Grand Canyon region, and culminate in the determination of the activity’s efficiency.

Risk

Remember that risk is the potential that an activity will lead to some sort of an undesirable outcome. It entails known outcomes and probabilities as opposed to uncertainty, which entails unknown outcomes and probabilities. The article maintains there are many risks associated with permitted uranium mines including those which could harm air, water, and humans. A U.S. Geological Survey report issued in 2010 "elevated radioactivity is evident at all sites" where previously mined or explored around north Grand Canyon. And increased amount, which exceeds maximum contaminant level for drinking water, of dissolved uranium was found from springs and wells. Affected parties should measure these risks via cost-benefit analysis in order to determine the mine’s net benefits. However, if the majority of stakeholder's groups wish to be risk averse and avoid any and all probability for a loss with respect to environmental and human health, granting federal approval of the mines may be in the best interest of society. Again, uncertainties remain in projects like these; therefore diligence is an important step to take.

Public Policy

A main focus of the article is on centralized environmental policy in Arizona, at the state level, and the United States, at the federal level. Permitting is a policy exercise undertaken by governments in order to deal with environmental problems such as and highlighted in this case, air and water pollution. Point sources, such as air and water pollution from uranium mining activities, may have continuous emissions, which are consistent with this operation, and episodic emissions, which may occur if toxic substances are released accidentally. The article also pinpoints the persistent nature of pollutants from uranium mining activities as described by “elevated radioactivity” and “concentrations of dissolved uranium that exceed… maximum contaminant level for drinking water”. With the sensitive and seemingly lethal nature of these pollutants, one must question if “general” permits really are the best policy. Moreover, two statements within the article seem to suggest the newer administration in Arizona has either changed the standard of emissions from uranium mining or that they don’t know where the standard is or should be… “Under the Napolitano administration… regulators required a more stringent “individual” permit” and “Arizona regulators are… risking even more radiological contamination of the soil and water”. It seems apparent that the analytic tools should be employed to evaluate this policy's effectiveness and to ensure that the United States makes the appropriate decision with regard to the opening and operation of these uranium mines.

Monitoring & Enforceability

The permits that have been issued to mines located within the Grand Canyon National Park have been deemed inefficient in controlling emissions by the Center for Biological Diversity. Efficiency occurs where the marginal abatement cost and marginal damage are equal. This cannot be determined effectively without enforceability as it is said that, “in issuing the permits, the state refused to require monitoring,” which would measure the amount of pollutants as compared to the requirement set out in the relevant law. Monitoring would allow one to ensure that firms are meeting requirements and are usually essential. The state, not monitoring the amount of fine particulate matter uranium dust, may lead to more common violations of the “general” permits that have been issued.

Social Costs

Without monitoring, many social costs may arise out of the mining of uranium. There have already been traces of elevated “radiological contamination of the soil and water of the Grand Canyon region,” where it has been previously mined or explored. Fine particulate matter uranium dust, along with alpha radiation, have several health impacts on people such that it is linked to toxicity in humans and genetic defects respectively. People who live in this area would thus be affected. “The aquifer pollution permit [also] lacks aquifer water-quality monitoring down-gradient of the mine,” which means that there is potential threat to the groundwater and thus the springs of the Grand Canyon. A remediation plan also does not exist, thus indicating that there is no solution in the prospect of a possible contamination of regional aquifers. This mining proposal is thus inefficient as there are a number of social costs through the lack of any form of monitoring or back-up plan.

Difficulties

Issuing mining permits are risky in terms of possible risks and social costs. The monitoring and back-up plan are needed to minimize the social and environmental damages. However, there are also several difficulties in damage control.There are difficulties in monitoring emission. Monitoring could be proceed by self-report from mining sites. But the self-report could be fake in order to get rid of government control. Government could monitor the emission, but it is hard to measure wide area around Grand Canyon accurately and it also takes cost for monitoring.

Prof's Comments

Good. Your comment about risk is a bit off. Efficiency, when it is appropriate to be risk neutral, occurs where marginal expected benefit equals marginal expected cost.

9/10