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Cost-Benefit Analysis
ADER-FRECHETIE

the result of science itself. Rees, for example, criticizes


economi .cs as guilty of scientific materialism , yet this
essay wtll show that economics (benefit-cost analysis)
can be interpreted in terms of many frameworks, not
just scientific materialism. Similarly, Sagoff criticizes
benefit-cost analysis as utilitarian, yet this essay will
show that the technique is neither purely utilitarian, nor
utilitarian in a flawed way, because those who use ben-
efit-cost analysis can interpret it in terms of Kantian val-
ues, not just utilitarian ones. If this essay is right, then
the ethical problems with economics are not with the
science itself but with us, humans who interpret and use
it in biased ways. In other words, the real problems of
economics are the political and ethical biases of its users,
not the science itself. To paraphrase Shakespeare: The
fault, dear readers, is not with the science but with our-
selves, that we are underlings who use it badly,
Consider the case of risk-cost-benefit analysis and
attacks on it. Risk-cost-benefit analysis (RCBA), the
target of many philosophers' and environmentalists'
criticismsJ is very likely the single, most used economic
method, at least in the United States, for evaluating the
desirability of a variety of technological actions-from
building a liquefied natural gas facility to adding yellow
dye number 2 to margarine. The 1969 National
Environmental Policy Act requires that some form of
RCBA be used to evaluate all federal environment-
related projects. 4 Also, all U.S. regulatory agencies-
with the exception perhaps of only the Occupational
Health and Safety Administration (OSHA)-routinely
use RCBA to help determine their policies,5
Basically, RCBA consists of three main steps. These
are (1) identifying all the risks, costs, and benefits asso-
ciated with a particular policy action; (2) converting
those risk, cost, and benefit values into dollar figures;
and (3) then adding them to determine whether benefits
outweigh the risks and costs. Consider the proposed
policy action of coating fresh vegetables with a waxy,
carcinogenic chemical to allow them to be stored for
longer periods of time. Associated with such a policy
would be items such as the risk of worker carcinogene-
sis or the cost of labor and materials for coating the
vegetables. The relevant benefits would include factors
such as increased market value of the vegetables since
the preservative coating would reduce spoilage and
losses in storage.
Those who favor RCBA argue that this technique-
for identifying, quantifying, comparing, and adding all
factors relevant to an economic decision-ought to be

A Defense of Risk-Cost-Benefit Analysis 507


one of the major considerations that any rational person know because humans arc not like calculating machines;
they cannot put a number on what they vnlue.lD A final argument against criticisms of RCBA
takes into account in developing social policy. To my spend 20 minutes searching for a parking place. If
f
anna I . , as a
metI1ocI, IS that Dreyfus and others are i c _ to
knowledge, no economist or policymakcr ever has Although these criticisms of RCBA arc thought pro- . . . 11 om

argued that RCBA ought to be the sole basis on which voking, they need not be evaluated in full here, in part p 1cte uustng po Ic1y arguments that ignore the real- omeone asked Susan to put a monetary value on pay-
world unportance of making decisions among finit m? $200 more per year for parking in a garage, she
any social or environmental choice is made. Despite the because they arc analyzed elsewhcrc.ll Instead, it might might say this change was worth an additional $100
alternatives and with finite resources. Wisdom may tel
fact that RCHA, an application of welfare economics, be good merely to sketch the sons of arguments that, and that, even if the fees increased by $300, would
us tIhat huma.n hfeIhas an infinite value , but the scicntifIC
dominates U.S. decision making regarding environmen- when developed, are capable of answering these objec- rather have the parking garage. That is, Susan would
anc economtc rea ity is that attaining a zero risk society
tal and technological issues, it continues to draw much tions to the use of RCBA. There arc at least six such say her CV was +$100 because she would gain from the
is impossible and that there arc not enough resources for
criticistn. Economists, industrial representatives, and arguments, new plan. However, suppose Sally also drives to cam-
sa:ing all lives.. In dismissing RCBA, Dreyfus and others
govcmmcntal spokespersons tend to support usc of The first is that, since Dreyfus and others merely point pus each day and suppose her welfare is affected nega-
fad to gtve their answers to the tough question of what
RCBA, but philosophers, environmentalists, and con- to deficiencies in RCBA without arguing that there is ttvely by the increase in parking fees and the proposed
cl'itcl'ion to usc in distributing environmental health and
sume•· activists tend to criticize its employment. some less deficient decision method superior to RCI\A, parktng garage. Because Sally lives at an inconvenient
safety. 12 If we do not use RCBA, what informal method
This essay (l) st1111marizes the three main lines of crit- they provide only necessary but not sufficient grounds location two hours away, she must drive to campus and
icism of RCBA, (2) outlines arguments for objections to consequences likely to follow ft·om them; they for rejecting RCBA. A judgment a bout sufficient grounds RCI\A answers these questions iu a methodical way.
RCBA, (3) shows that the allegedly most devastating don't for rejecting RCBA ought to be based on n t•clntivc eval-
criticisms of RCBA arc at best misguided and at worst uation of all methodologic alternatives because reason-
inconect, and (4) reveals the real source of the alleged able people only reject a method if they have a better
deficiencies of RC!lA. Let us begin with the tlH·ce main alternative to it. Showing deficiencies in RCI\A docs not
criticisms of RCBA. These arc objections to RCBA (1) as establish that a better method is availahle,
a formal method, {2) as an eco1tomic method, and {3) as A second argument is that Dreyfns, Tribe, Socolow,
an ethical method. and others have "proved too much." If human decision
making is unavoidably intuitive and if benefits at·e indis-
tinguishable from costs, as they say, then no rational,
Ol3JECTION 1: RCBA AS A FORMAL debatable, nonarhitrary fot·m of technologic policymnk-
METHOD ing is possible. This is because rational policymaking
presupposes nt least that persons can tlistinguish what is
The most strident cntlctsms of RCBA {as a (or111al undesimble from what is desirable, costs fmm benefits.
method for making; social decisions) come from phenom- If they cannot, then this problem docs not count against
cnolog;kally oriented scholars, such as Hlt bert and Stuart only RCBA but against any method. Moreover, Dreyfus
Dreyfus at Berkeley. They argue that, because it is a rigid, and others ignore the fact that no policymaking meth-
formal method, RCHA cannot model all in. tances of ods, including RCIIA, nrc pcl'fect. And if not, then no
uhuman situational understanding. nti For example, say theory should be merely criticized separately, since such
Stuart Dreyfus, l.nwrence Tribe, and Robert Socolow, criticisms say nothing about which theory is the least
whenever someone makes a decision, whether abour dcsirnblc of all.
playing chess or driving an nutomohile, he or she uses Anothct· argument, especially relevant to Dreyfus's
intuition and not some analytic, economic "point claims that RCBA is not useful fot' individual tasks, such
count. "7 They claim that formal models like RCBA foil as the decision making involved in driving a car, is that
to capture the essence of human decision making. The many of the objections to RCBA focus on a point not at
models nrc too narrow and oversimplified in focusing on issue. That RCBA is not amemtble to indit'ithllll decision
allegedly trnnsparcnt rationality and sciemific know- making is not at issue. Tlw real issue is how to take into
how. Rather, say Dreyfus and others, humnn decision account millions of individual opinions, ro make socie/<11
making is mysterious, unfonnalizable, and intuitive, decisions. This is because societnl decision making pre-
something dose to wisdom.R This is because the perfor- supposes some unifying perspective or method of aggr ·
mance of human dedsion making requires expertise and gating preferences of nHtny people, a problem not faced
human skill acquisition that cannot be taught by means by the individual making choices. Of wurse, accnnt·
of any algorithm or formal method like RC:IlAY plishing RCIIA is not like individual decision making,
Moreover, say Robert Coburn, Amory Lovins, and that is pt·eciscly why social choices require some for-
Alasdair Macintyre, and Peter Self, humans not only do mal analytic tool like RCIIA.
not go through nny formal routine like RC:BA, but they Criticisms of RC:BA as a formal method arc al1o
could not, even if they wanted to. Why not? Humans, qucstionahle because Dreyfus and others provide an
they say, often can't distinguish costs ft·om benefits. For incomplete analysis of sodet" I decision making in mak-
example, generating increased amounts of electricity ing appeals to wisdom and intuition. They fail to spec·
represents a cost for most envimnmcntalists, but a ben- ify, in a politic"I and pmcticnl conrcxt, wlwsa wisdom
efit for most economists. Lovins and his colleagues also and intuitions ought to be followed and what criteria
claim rhat people don't know either the pmbahility of ought to be used when the wisdom and imuitions of dif·
certain events, such as cncrgy rchucd accidents, or the fercm persons conflict in an cnvironnwntal comrover;y.
is a bigger help? This realistic question they do not
park her car every day. But because she lives so far
answer. If not, RCBA may be the best method among
many bad methods. aw y, has no part-time job, and is going to school with
avmgs, Sally wants to pay as little as possible for park-
Ing and prefers the existing muddy, uncovered parking
lots: If someone asks Sally to put a monetary value on
OBJECTION 2: RCBA AS AN ECONOMIC p ymg $200 more per year for parking in a garage, she
METHOD mtght say this change harmed her by $200. That is,
Sally would say her CV was -$200. Economists who
Although these six argument-sketches arc too brief to be
use RCBA believe that, in order to determine the desir-
conclusive in answering objections to RCBA as a formal ability of building the parking garage and charging
method, let us move on to the second type of criticism so $200 more per year, they should add all the CVs of
that we can get to the main focus of this essay. gainers (like Susan) and losers {like Sally) and see
Philosophers of science and those who are critical of whether the gains of the action outweigh the losses.
mainstream economics, like Kenneth Boulcling, most Or consider the case of using CVs to measure the
often cl'iticizc RCBA as a deficient economic method. effects of building a dam. The CVs of some persons will
Perhaps the most powerful mcthodologic attack on be positive, and those of others will be negative. Those
RCBA deficiencies focuses on its central mcthodologic in the tourism industry might be affected
assumption: Societal welfare can be measured as the alge- positively,
braic stun of compensating variations (CVs). By analyti- whereas those interested in wilderness experiences might
cally unpacking the concept of compensating variation, be affected negatively. The theory is that the proposed
one can bring many RCBA deficiencies to light. dam is cost-beneficial if the sum of the CVs of the gain-
According to RCBA theory, each individual has a CV ers can outweigh the sum of the CVs of the losers. In
that measures the change in his or her welfare as a more technical language, according to economist Ezra
consequence of a proposed policy action. For example, Mishan, a CV is the sum of money that, if received or
suppose n university was considering raising the price of paid after the economic {or technologic) change in ques-
student parking permits from $200 per year to $400 per tion, would make the individual no better or worse off
year and using the additional money to build a parking than before the change. If, for example, the price of a
garage on campus. Suppose also that the uni- versity bread loaf falls by 10 cents, the CV is the maximum sum
would decide whether this act or policy was dcsirn hie a man would pay to be allowed to buy bread at this
on the basis of the way it affected all the stu- dents. lower price. Per contra, if the loaf rises by 10 cents, the
Raising the parking fees and building a garage would CV is the minimum sum the man must receive if he is to
affect the welfare of each student differently, depending continue to feel as well off as he was before the rise in
on her {or his) circumstances. According to economic price,l3 Implicit in the notion of a CV are three basic
theory, the CV of each student would mea- smc her presuppositions, all noted in standard texts on welfare
particular change in welfare. To find exactly how each economics and cost-benefit analysis: {1) the compensat-
student would measure her CV, her change in wclfm·c ing variation is a measure of how gains can be so dis-
because of the changed parking fees, we would ask her to tributed to make everyone in the community better
estimate it. For example, suppose Susan drives to off14; (2) the criterion for whether one is better off is
campus each day and has a part-time job off campus, so how well off feels subjectiveJyl5; and {3) one's feelings
she cannot carpool or ride a bus because she needs her car of being well off or better off are measured by a sum of
to move efficiently between campus and work. Susan money judged by the individual and calculated at the
wants to have the parking garage, how- ever, because she given set of prices on the market.l6
has to look nice in her part-time job. If the university According to the critics ofRCBA, each of the three pre-
builds the parking garage, she will not get wet and muddy suppositions built into the concept of a CV contains con-
walking to her car and will not have troversial assumptionsP The first presupposition, that
CVs provide a measure of how to make everyone better
suppositions and consequences of the assumptions built Because it is unavoidably consequentialist, however, :vould prevent them from doing so and from recogniz-
off, is built on at least two questionable assumptions:
into the notion of compensating variation. Chief among means neither that RCBA is consequentialist in some dis- mg thiS deontological value,
Gains and losses, costs and benefits, for evety individual
in every situation can be computed numerically.18 A sec- these ways of improving RCBA are use of altemative pm:nging sense, nor that it is only consequentialist, both Third, one could weight the RCBA parameters to
ond questionable assumption built into this presupposi- weighting schemes and employment of various ways to pomts that are generally begged by deontological critics reflect whatever value system society wishes. As Ralph
tion is that employing an economic change to improve the make the controversial aspects of RCBA explicit n nd of RCBA. Of course, RCBA is necessarily consequential- Keeney has noted, one could always assign the value of
community welfare is acceptable, even though distribu- open to evaluation. Use of a weighting scheme for RCIIA ist, but so what? Anyone who follows some deontologi- negative infinity to consequences alleged to be the result
tional effects of this change are ignored. Many people would enable one, for example, to "cost" inequitably dis- cal theory and ignores consequences altogether is just as of an action that violated some deontological princi-
have argued that the effect of this assumption is merely to tributed risks more than equitably distributed ones. Also, simplistic as anyone who focuses merely on consequences le.28 Thus, if one wanted to avoid any technology
make economic changes dtat let the rich get richer and the if one desired, it would be possible to employ Rawlsian and ignores deontological elements. This is exactly the hkely to result in violation of people's rights not to be
poor get poorer, thus reflecting the dominant ideologies weighting schemes for promoting the welfare of the lenst- point recognized by Amartya Sen when he notes that caused to contract cancer, one could easily do so.
of the power groups dominating society. well-off persons. One of the chief reforms, importnnt for Jeremy Bentham and John Rawls capture two different Fourth,,RCBA is not necessarily utilitarian, as Patrick
The second presupposition built into the notion of addressing the economic deficiencies of RC!lA, would he but equally important aspects of interpersonal welfare Suppes pomts out, because the theory could, in principle,
CV, that the criterion for whether one is better off is how to employ a form of adversary assessment in which a lt •·­ considerations,26 Both provide necessary conditions for be adopted (without change) to represent a "calculus of
one feels subjectively, as measured in quantitative terms, native RCBA studies would be performed by groups ethical judgments, but neither is sufficient. obligation and a theory of expected obligation"; in other
also embodies a number of doubtful assumptions. Some sharing different ethical and methodologic presupposi- Althougb RCBA is necessarily conscquentialist, there words, RCBA is materially indifferent, a purely formal
of these are that, as Kenneth Arrow admits, individual tions. Such adversary assessment has already hc n nre at least four reasons that it is not only consequcn- calculus with an incomplete theory of rationality.29 This
welfare is defined in terms of egoistic hedonism19; that accomplished, with success, in Ann Arbor, Michigan, tialist in some extremist or disparaging sense. First, any being so, one need not interpret only market parameters
the individual is the best judge of his welfare, that is, that and in Cambridge, Massachusetts.24 l-Ienee, nt least in application of RCBA principles presupposes that we as costs. Indeed, economists have already shown that one
preferences reveal welfare, despite the fact that utility is theory, there are ways to avoid the major economic dcfi· make some value judgments that cannot be justified by can interpret RCBA to accommodate egalitarianism and
often different from morality20; that summed preferences ciencies inherent in RCBA. utilitarian standards alone.27 For example, suppose we intuitionism as well as utilitarianism.JO More generally,
of individual members of a group reveal group welfare 21 ; are considering which of a variety of possible actions Kenneth Boulding has eloquently demonstrated that eco-
and that wealthy and poor persons are equally able to (e.g., building a nuclear plant, a coal plant, or a solar nomic supply-demand curves can be easily interpreted to
judge their well-being. This last assumption has been OBJECTION 3: RCBA AS AN ETHICAL facility) ought to be evaluated in terms of RC!li\, A util- fit even a benevolent or an altruistic ethical framework,
widely criticized since willingness to pay is a function of METHOD itarian vnluc judgment would not suffice for reducing not merely a utilitarian ethical framework.Jl
the marginal utility of one's income. That is, rich people the set of options. It would not suffice for deciding
are more easily able to pay for improvements to their The most potentially condemning criticisms of HC:lli\ which of many available chemicals to usc in preserving
welfare than poor people are. As a consequence, poor come from the ranks of moral philosophers. Most of foods in a given situation, for example, because we THE REAL SOURCE OF RCBA
persons obviously cannot afford to pay as much as rich those who criticize RCBA on ethical grounds, as om· would not have performed the utility weighting yet. PROBLEMS
persons in order to avoid the risks and other disamenities might suspect, are deontologists who employ standard Usually we use deontological grounds for rejecting some
of technology-related environmental pollution,22 That is complaints against utilitarians. Philosophers, such as option. For instance, we might reject chemical X as a If these four arguments, from experts such as Suppes
why poor people are often forced to live in areas of high Alasdair Macintyre and Douglas MacLean, claim that food preservative because it is a powerful carcinogen and Keeney, are correct, then much of the criticism of
pollution, while wealthy people can afford to live in some things are priceless and not amenable to and usc of it would threaten consumers' rights to life. RCBA, at least for its alleged ethical deficiencies, has
cleaner environments. risk-benefit costing. Alan Gewirth argues that c •·tnin Second, RCBA also presupposes another type of been misguided. It has been directed at the formal, eco-
Continuing the analysis of CV, critics of RCBA point commitments-for example, the right not to be t:ilWit'd nonutilitarian value judgment by virtue of the fact that nomic, and ethical theory underlying RCBA, when
out that the third presupposition built into the notion of to contract cancer-cannot be traded off (via RC!Ir\) it would be impossible to know the utilities attached to apparently something else is the culprit. This final sec-
CV also involves a number of questionable assumptions. for some utilitarian bcnefit,25 In sum, the claim of these an infinity of options because they are infinite. To tion will argue that there are at least two sources of the
The presupposition that one's feelings of being better off ethicist critics of RCBA is that moral commitmcllls, reduce these options, one would have to make some problems that have made RCBA so notorious. One is the
are measured by money, and calculated in terms of mar- rights, and basic goods are inviolable and incommensu- non utilitarian value judgments about which options not dominant political ideology in terms of which RCBA has
ket prices, includes at least one highly criticized assump- rable and hence cannot be "bargained away'' in a utili to consider. For example, suppose chemical Z (consid- been interpreted, applied, and used. The second source
tion-that prices measure values. This assumption is tarian scheme like RCBA, which is unable w take ered for preserving food) were known to cause death to of the difficulties associated with RCBA has been the
controversial on a number of grounds. For one thing, it adequate account of them and of values like distriblltil'<' persons with certain allergic sensitivities or to persons tendency of both theorists and practitioners-econo-
begs the difference between wants and morally good justice. with diabetes. On grounds of preventing a violation of a mists and philosophers alike-to claim more objectivity
wants. It also ignores economic effects that distort Of course, the linchpin assumption of the argumcms legal right to equal protection, analysts using RCBA for the conclusions of RCBA than the evidence war-
prices. Some of these distorting effects include monopo- of Gewirth, MacLean, and others is that RC!lA is indeed could simply exclude chemical Z from considerntion, rants. Let's investigate both of these problem areas.
lies, externalities, speculative instabilities, and "free utilitarian. If this assumption can be proved wrong, rht·n much as they exclude technically or economically infea- Perhaps the major reason that people often think,
goods,, such as clean air.23 (whatever else is wrong with RCBA) it cannot he sible options for consideration erroneously, that RCBA is utilitarian is that capitalist
Because methodologic criticisms such as these have attacked on the grounds that it is utilitarian. Also, in the course of carrying out RCBA calcula- utilitarians first used the techniques. Yet, to believe that
been a major focus of much contemporary writing in phi- tions-one is required to make a number of nonutilitar- the logical and ethical presuppositions built into eco-
losophy of economics and in sociopolitical philosophy, ian value judgments. Some of these are: (1) There is a nomic methods can be identified with the logical and
discussion of them is extremely important. However, Misguided Ethical Criticism of RCI3A cardinal or ordinal scale in terms of which the conse- ethical beliefs of those who originate or use the methods
economists generally admit most of the preceding points RCBA is not essentially utilitarian in some dnmaging quences may be assigned some number, (2) a particular is to commit the genetic fallacy.32 Origi11s do not neces-
but claim that they have no better alternative method to sense for a number of reasons. First of all, let's adill i discount rate ought to be used, (3) or certain values sarily determine co11tent. And, if not, then RCBA has no
use than RCBA. If their claim is at least partially correct, that RCBA is indeed utilitarian in one crucinl respect: ought to be assigned to certain consequences. For exam.. built-in tics to utilitarianism.33 What has happened is
as I suspect it is (see the previous section of this essay), The optimal choice is always determined by some func- pic, if policymakcrs subscribed to the deontological, that, in practice, one interpretation of RCBA has been
then many of the preceding criticisms of RCBA are beside tion of the utilities attached to the consequences of all evaluative judgment that future generations have rights dominant. This interpretation, in terms of capitalist util-
the point. Also, both economists and philosophers have the options considered. l-Ienee, t'casoning in RC:!IA is equal to our own, then they could employ a zero dis- itarianism, is what is incompatible with nonutilitarian
devised ways of avoiding most of the troublesome pre- unavoidably consequentialist. count rate. Nothing in the theory underlying RC!lA values. But this means that the problems associated with
the dominant po\itical ideology, in terms of which Okrent, and other practitioners of RCBA use the same ethical and epistemological sensitivity among those who George Washington Law Review 45, no. 5 (August
RCBA is interpreted, has been confused with RCBA terminology; they even claim that· those who do not interpret RCBA, and we need to recognize practical, 1977): 913-916,925-926. See also Robert Coburn,
problems. Were the methods interpreted according to a accept their value-laden interpretations of RCBA arc fol- political problems for what they are. The problem is "Technology Assessment, Human Good, and
. . ,. . 41
different ideology, it would be just as wrong to equate lowing merely ''su bJecttve mterpretattons. with us, with our values, wilh our politics. The problem Freedom,'' in K. E. Goodpaster and K. M. Sayereds.,
RCBA with that ideology. Given that both moral philosophers and practitioners is not with RCBA methods that merely reflect otir values Ethics and Problems of the 2Ut Century (Notre Dame:
Confusion about the real source of the problems with of RCBA claim that their utilitarian analyses arc objec- and politics. University of Notre Dame Press, 1979), 108; E. J.
RCBA has arisen because of the difficulty of determin- tive, they create an intellectual climate in which RCBA Mishan, Cost-Benefit Analysis (New York: Praeger,
ing causality. The cause of the apparent utilitarian biases is presumed to be more objective, value-free, and final 1976), 160-161; Gunnar Myrdal, The Political
in RCBA is the dominant ideology in terms of which than it really is. Hence, one of the major problems with Element h1 the Development of Economic Theory, Paul
RCBA is not that it is inherently utilitarian but that its
Notes
people interpret it. The cause is not the method itself. Steet.en, trans. (Cambridge: Harvard University Press,
This is like the familiar point, which often needs reitera- users erroneously assume it has a finality that it docs not 1. k. S. Shrader-Frechette, Nuclear Power and Pnblic 1955), 89: and A. Radomysler, "\Xfelfare Economics
tion, that humans, not computers, cause computer possess. It is one of many possible techniques, and it has Policy (Boston: Kluwer, 1983),.54-60. and Economic Policy," inK. Arrow and T. Scitovsky,
errors. Given this explanation, it is easy to see why C. B. many interpretations. Were this recognized, then people 2. K. S. Shrader-Frechette, Burying Uncertailtty (Berkeley: eds., Readings in Welfare Economics (Homewood, IL:
MacPherson argues that there is no necessary incompat- would not oppose it so vehemently. University of California Press, 1993), 239-241. Irwin, 1969), 89.
ibility between maximizing utilities and maximizing 3. K. S. Shrader-Frechette and E. McCoy, Method in 11. SecK S. Shrader-Frechette, Scietrce Policy, Ethics, and
some nonutilitarian value. The alleged in ompatibility Ecology (New York: Cambridge University Press, Economic Methodology (Boston: Reidel, 1985), 38-54.
arises only after one interprets the nonutilitarian value. SUMMARY AND CONCLUSIONS 1993), 175-185. See also K. S. Shrader-Frechette, Risk and Rationality
In this case, the alleged incompatibility arises only when 4. See Ian G. Barbour, Tech1wlogy, Environment, a1td (Berkeley: University of California Press, 1991),
one interprets utilities in terms of unlimited individual RCBA has many problems. As a formal method, it sug- Human Values (New York: Praeger, 1980), 163-164. 169-196.
appropriations and market incentives.34 gests that life is more exact and precise than it really is. 5. Luther j, Carter, "DiSptlte over Cancer Risk 12. Shrader-Frechette, Science Policy, op. cit., note 11,
If the preceding view of RCBA is correct and if peo- As an econo111ic method, it suggests that people make Quantification," Science 203, no. 4387 (1979): 36-54; K. S. Shrader-Frechette, Risk mod Rationality,
ple have erroneously identified one-of many possible- decisions on the basis of hedonism and egoism. As till 1324-1325. op. cit., note 11, 169-183.
interpretations of RCBA with the method, then ethical method, people have interpreted it in utilitarian 6. Stuart E. Dreyfus, "Formal Models vs. Human 13. Mishan, Cost-Benefit A11alysis, op. cit., note 10, 391.
obviously they have forgotten tha; RCBA is a formal ways, in ways that serve the majority of people, but 1101 Situational Understanding: Inherent Limitations on the 14. !hid., 390.
calculus to be used with a variety of interpretations. But always the minority. Modeling of Business Expertise," Technology and 15. Ibid., 309.
if they have forgotten that RCBA is open' to many dif- Despite all these criticisms, RCBA is often better than People 1 (1982)j J33-165. See also S. Dreyfus, "The 16. E. J. Mishan, Welfare Economics (New York: Random
ferent interpretations, then they have id ntified one most environmentalists believe. It is better because riti- Risks! and Benefits? of Risk-Benefit Analysis," unpub- House, 1969), 113; see also 107-113.
dominant political interpretation with RCBA itself, then cisms of RCBA often miss the point in two importnm lished paper p esented on March 24, 1983, in Berkeley, 17. For a more complete analysis of these points, seeK. S.
they have forgotten that, bec pse of this dominant inter- ways. First, the criticisms miss the point that sodcty California, at the Western bivlsion meeting of the ShraderFrechette, "Technology Assessment as Applied
pretation, RCBA is politically loaded. And if they have needs some methodical way to tally costs and benefits American Philosophical Ass'ociation. Stuart Dreyfus and Philosophy of Science," Scieuce, Technology, m1d
forgotten that they are employing a utilitarian interpre- associated with its activities. While it is true that RC:IIA his brother Hubert Dreyfus share the beliefs attributed Human Values 6, no. 33 (Fall 1980), 33-50.
tation that is politically loaded, then they probably have has IJr?blems because of its being a formal, econmnk to Stuart in theSe and other publications. They often co- 18. M. W. Jones-Lee, The Vallie of Life (Chicago:
assumed that RCBA is objective by virtue of its being method, this criticism of it 111isses the point. The point is author publications. See, for example, S. Dreyfus and University of Chicago Press, 1976), 3; and R. Coburn,
part of science. that we humans need some lear, analytic way to help us 1-J. Dreyfus, "The Scope, Limits, and Training (<Technology Assessment,') inK. E. Goodpaster and
Utilitarian philosophers and welfare economists have with environmental decision making. Most people Implications of Three Models of ... Behavior," ORC K. M. Sayer, eds., Ethics mod Problems of the 21st
been particularly prone to the errors of believing that would not write a blank check in some area of pct·sonal 79-2 (Berkeley: Operations Research Center, University Cent11ry, op. cit., note 10, 109. See also Oskar
utilitarian interpretations of decision making are objec- life, and no one ought to write a blank check for solving of California, February 1979), Morgenstern, On the Accuracy of Economic
tive and value-free. Utilitarian R. M. Hare argues in his societal problems. Not using some technique like RCIIA 7. S, Dreyfus, "Formal Models," op. cit., note 6, 161. See Observations (Princeton, NJ: Princeton University Press,
book, for example, that moral philosophy can be done means that we would be writing a blank check, maki111: also Lawrence 1-1. Tribe, "Technology Assessment and 1963), 100-101.
without ontology35; he also argues that moral philoso- decisions and commitments without being awm·e of the Fourth Discontinuity," Southern California Latv 19. Cited in V. C. Walsh, '<Axiomatic Choice Theory and
phy can be done objectively and with certainty, that their costs, benefits, and consequences. All that RCBA Review 46, no. 3 (June 1973): 659; and Robert Values," in Sidney Hook, ed., Htmza, Values aud
there are no irresolvable moral conflicts36; and that asks of us is that we add up all the risks, benefits, ami Socolow, "Failures of Discourse," in D. Scherer and T. Economic Policy (New York: New York University
objective moral philosophy is utilitarian in character.37 costs of our actions. It asks that we not make decisions Attig, eds., Ethics and the Environment (Englewood Press, 1967), 197.
Hare even goes so far as to argue that a 20. See R. Coburn, "Technology Assessment," inK. E.
without considering all the risks, costs, and benefits. The Cliffs, NJ: Prentice Hall, 1983): 152-166.
hypothetical-deductive method can be used to obtain Goodpaster and K. M. Sayer, eds., Ethics a11d Prob ems
point is that RCBA dqes not need to be perfect to be usc· 8. S. Dreyfus, "Formal Models," op. cit., note 6, 161-163;
moral evaluations and to test them.38 Hare, one of the of the 21st Cent11ry, op. cit., note 10, 109-1_10; ,?.all
ful in societal and environmental decision making; it and Douglas MacLean, "Understanding the Nuclear
best moral philosophers of the c ntury, equates utilitar- Kennedy, "Social Choice and Policy Format1o , Ill S,
needs only to be useful, helpful, and better than other Power Controversy," in A. L. Caplan and H.
ian tenets with value-free, certain conclusions obtained Hook, ed., Human Values m1d Economic Poltcy, op.
available methods for making societal decisions. Englehardt, eds., Scientific Controversies (Cambridge:
cit., note 19, 142; and John Ladd,.,'jThe Use of
by the scientific method of hy11othesis-deduction. His Second, criticisms of RCBA miss the point bccatlsc Cambridge University Press, 1983), Part 5.
error here means that we ought not be surprised that Mechanical Models for the Solution of Ethical
they blame RCBA for a variety of ethical problems, 9. S, Dreyfus, "The Risks! and Benefits?'' op. cit., note 6, 2.
lesser minds also have failed to recognize the evaluative Problems," inS. Hook, ed., Humatr Values and
mainly problems associated with utilitariat1ism. RCBA, 10. Peter Self, Econocrats and the Policy Process: The
Ecotromic Policy, op. cit.) 167-168. See also Mark Lutz
and interpretational component in utilitarianism and in however, is merely a formal calculus for problem solv· Politics and Philosophy of Cost-Benefit Analysts
and Kenneth Lux, The Challenge of Hummtistic
the utilitarian interpretations of RCBA. Numerous well- ing The users of RCBA arc responsible for the capita lis· (London: Macmillan, 1975), 70; Alisdai:,Macintyre,
known practitioners of RCBA have argued that the tech- Eco11omics (London: Benjamin/Cummings, 1979).
tic, utilitarian interpretation of it. If so, then what nec1h "Utilitarians and Cost-Benefit Analysts, m D. Scherer
Finally, see Richard Brandt, "Personal Values and the
nique is objective, and they have failed to recognize its to be done is neither to abandon RCBA, nor to condemn and T. Attig, eds., Ethics and the Environment, op.
Justification of Institutions," inS. Hook, ed., HmiWfl
value component. 39 Milton Friedman calls economics it as utilitarian, but to give some philosophical lessons in cit., note 7, 143-145; and Amory Lovms, . '' Values and Ecol!omic Policy, op. cit., note 19, 37; and
objective,"4° and Chauncey Starr, Ch is Whipple, Pavid the value ladenness of its interpretations. We need more ' Cost-Risk-Benefit Assessment in Energy Pohcy,
John Ladd, "Models/' inS. Hook, ed., Human Values
and Economic Policy, op. cit., note 19, 159-168.
21. G. Kennedy, "Social Choice," S. Hook, ed., Human
Values and Economic Policy, op. cit., note 20, 148,
makes the same point.
22. PeterS. Albin, "Economic Values and the Values of
Human Life," inS. Hook, ed., Human Values and
Economic Policy, op. cit., note 19, 97; and M. W.
Jones-Lee, Value of Life, op. cit., note 18, 20-55.
23. See J. A. Hobson, Confessions of an Economic Heretic
(Sussex, England: Harvester Press, 1976), 39-40; and
Benjamin M. Anderson, Social Value (New York: A.M.
Kelley, 1966), 24, 26, 31, 162. See also Kenneth
Boulding, "The Basis of Value Judgments in
Economics," inS. Hook, ed., Human Values and
Economic Policy, op. cit., note 19, 67-79; and 0.
Morgenstern, Accuracy of Economic Observations, op.
cit., note 18, 19. Finally, see E. J. Mishan, Cost-Benefit
Analysis, op. cit., note 10, 393-394; and E. F.
Schumacher, Small Is Beautiful (New York: Harper,
1973), 38-49; as well as N. Georgescu-Roegen, Energy
and Economic Myths (New York: Pergamon, 1976), x,
10-14.
24. See Shrader-Frechette, Science Policy, op. cit., note
11, Chapters 8-9; Shrader-Frechette, Risk and 3
Rationality, op. cit., note U; and B. A. Weisbrod, 3
"Income Redistribution Effects and Benefit-Cost 3
Analysis," inS. Chase, ed., Problems in Public
Expenditure Analysis (Washington, D.C.: Brookings,
1972), 177-208. See alsoP. Dasgupta, S. Marglin, and
A. Sen, Guidelines of Project Evaluation (New York:
UNIDO, 1972); and A. V. Kneese, S. Ben- David, and
W. Schulze, "The Ethical Foundations of Benefit-Cost
Analysis," in D. MacLean and P. Brown, eds., "A
Study of the Ethical Foundations of
Benefit-Cost Techniques, 11 unpublished report done
with funding from the National Science Foundation,
Program in Ethics and Values in Science and 4
Technology, August 1979.
25, Lovins, ''Cost-Risk-Benefit Assessment," op. cit., note
10, 929-930; Douglas MacLean, "Qualified Risk 4
Assessment and the Quality of Life,'' in D. Zinberg, ed.,
Uncertain Power (New York: Pergamon, 1983), Part V;
and Alan Gewirth, "Human Rights and the Prevention
of Cancer," in D. Scherer and T. Attig, eds., Ethics and
the Environment, op. cit., note 7, 177.
26. Arnartya K. Sen, "Rawls Versus Bentham,u inN.
S
Daniels, ed., Reading Rawls (New York: Basic Books, 1
1981), 283-292.
27. Ronald Giere, "Technological Decision Making," in M.
Bradie and K. Sayre, eds., Reason and Decision 2
(Bowling Green, OH: Bowling Green State University
Press, 1981), Part 3, makes a similar argument.
28. Ralph G. Keeney mentioned this to me in a private con- 3
versation at Berkeley in January 1983.
29. Patrick Suppes, "Decision Theory," in P. Edwards, ed.,

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