Jack Mendelsohn is certainly right about “nuclear amnesia” (“Delegitimizing Nuclear Weapons,” Issues, Spring 2006). Even in official administration documents, there is a rather casual attitude about the possibility of using nuclear weapons in limited conflicts. I hope his article will be widely read.
The threat of nuclear-armed terrorism is real and it must be addressed by means other than classical Cold War deterrence theory. Mendelsohn’s appeal for “delegitimizing” nuclear weapons is designed to scale back the appeal of nuclear weapons as instruments of power or prestige. More nuclear weapons in the hands of more nations will lead to weapons in the hands of terrorists at some point. The ideas Mendelsohn presents would raise barriers against that process.
I particularly liked his discussion of nuclear weapons testing. A moratorium on testing is a flimsy device to prevent future testing, but it is better than nothing. Pushing ahead with Reliable Replacement Warheads would jeopardize even that flimsy barrier.
I think that Mendelsohn also has written a very convincing case for why “a nuclear war cannot be won and must never be fought,” to cite Ronald Reagan’s judgment about nuclear weapons. Paul Nitze once told me that nuclear weapons should not be used “even in retaliation—and especially in retaliation.” This opinion was not derived from a pacifist outlook but from a considered judgment about the effect of a U.S.-Soviet nuclear exchange.
Mendelsohn says that the United States should “remove nuclear weapons from the quiver of threat responses and war-fighting scenarios.” But he evidently supports their potential use as “weapons of last resort.” If there is a use for them in retaliation or in a case where the survival of the nation is at risk, then some planning will have to be directed toward their use in “threat responses.”
This leads me to a point that has troubled me about declarations about use policy; Mendelsohn’s quotation ascribed to Linton Brooks sums it up: “We can change our declaratory policy in a day.” My concern is that a policy that can be changed in a day is no substitute for physical changes that make nuclear use less likely. Radical reductions in warhead inventories have a long-term effect on how nuclear weapons are viewed in war planning. Placing less reliance on prompt launch procedures also has this effect. I share Mendelsohn’s basic outlook, but I have always believed that the principal objective of U.S. policy should be to work toward progressively lower levels of nuclear weapons and fewer weapons on high alert. I suspect that Mendelsohn agrees with this but has little hope that it can be achieved. He may be right, but I hope not.
Jack Mendelsohn is right to emphasize the desirability of the United States delegitimizing the use of nuclear weapons and abandoning its nuclear first-use policy. His arguments also apply to the other four established nuclear-weapon powers (China, France, Russia, and the United Kingdom), all of which are modernizing their nuclear forces. (Only China has declared a no-first-use nuclear policy.) Making qualitative improvements in nuclear weapons is usually much more destabilizing than increasing the number of nuclear weapons in the arsenals.
The UK government has said on several occasions that it will need to make a decision on the future of the British strategic nuclear deterrent during this Parliament—that is, before 2009–2010. The United Kingdom operates Continuous-at-Sea Deterrence, which requires four Trident strategic nuclear submarines to ensure that there is one at sea at any given time. The current UK government seems intent on replacing the Trident system without putting forward any convincing arguments for keeping a nuclear force. Moreover, Britain has threatened, like the United States, to use nuclear weapons preemptively in some circumstances.
The UK nuclear policy is described in the governmentÕs 1998 Strategic Defence Review. As Commodore Tim Hare, the former Director of Nuclear Policy in the British Ministry of Defence, says (Royal United Services Institute Journal, April 2005, page 30): ÒThe policy makes it clear that the role of nuclear weapons is fundamentally political and that therefore any rationale for their retention is political. The UK does not possess nuclear weapons as part of the military inventory, they have no function as war-fighting weapons or to achieve lesser military objectives.Ó
This statement from an extremely well-informed and authoritative source brings home the fact that there is no military reason for the United Kingdom to retain its nuclear weapons and to replace its Trident submarines. Why then is it virtually certain that Britain will replace them rather than doing what Mendelsohn recommends: completely delegitimizing its nuclear weapons by doing away with them?
Many suspect that the main, if not the only, reason is that the UK government believes that the possession of nuclear weapons is necessary to keep BritainÕs permanent seat on the UN Security Council: each of the five permanent members is a nuclear-weapon power. The other argument often made is that the United Kingdom already has nuclear weapons and it would be unwise to give them up in a world in which the future is uncertain. Those who make this argument usually admit that if the United Kingdom did not actually have nuclear weapons, it would not now acquire them.
Britain faces no significant external military threat and has a very close friendly relationship with the United States, the world’s only superpower. If Britain cannot give up its nuclear force today, it is unlikely ever to do so. Nor, so far as I can see, will any other nuclear-weapon power. Much though I wish it were otherwise, I am afraid that Mendelsohn, eminently sensible and desirable though his ideas are, is, for the foreseeable future, whistling in the wind.
Respect for China
In “Don’t “Dis” Chinese Science” (Issues, Spring 2006), Alexander P. De Angelis characterizes the U.S. government’s apparatus for focusing on China’s science and technology (S&T) policy as “woefully inadequate and scattered.” It is not the apparatus so much as the blindness of the administration to the power of science to build bridges, even in times of great hostility abroad to U.S. policies. This blindness is accompanied, as De Angelis points out, by the administration’s abysmal failure to press Congress for adequate funding for our science diplomacy and for the cooperative research programs that should be supporting it. As for apparatus, George Atkinson, science advisor to the Secretary of State, does yeoman work in the cause of our S&T relationships around the world. In early April 2006, he spent several weeks visiting a broad range of Chinese research establishments. He sees the great opportunities for U.S. science to collaborate with nations like China and India, whose scientific achievements are growing very fast, as well as with our traditional friends in Europe and Japan.
Ronald N. Kostoff at the Office of Naval Research and his coauthors have made detailed studies of the quantity, scope, and quality of research in both China and India. Americans are relatively familiar with the high achievements of science in India, probably because we share a common language. Kostoff notes that from 1980 to 2005, India’s output of research articles (science and social science Citation Index references) grew from 10,000 to 25,000. During that same period, he reports, Chinese research output (measured the same way) grew by a factor of 100!
The power of science to open doors and smooth out hostile feelings about other countries is illustrated by some very modest efforts in the past that had very large rewards. Yet sometimes successful private initiatives, assisted by government funding, lose that support when the agencies assume that relations are “normal” and the initiatives will take care of themselves. De Angelis cites the Committee on Scholarly Communications with the People’s Republic of Science (CSCPRC), which I chaired, following Eleanor Sheldon in the 1970s. De Angelis notes that once diplomatic relations were established between the United States and China, government agencies started cutting back their support of CSCPRC, just when it could be most effective. A similar problem faces us today, when the fear of terrorism and all things foreign has us looking inward, not out toward the opportunities to build new relationships that can make us safer and more secure. Surely the maturing of China and India must shake us out of our complacency and chauvinism, which are too often masked as patriotism.
Alexander P. De Angelis certainly got it right in his commentary about the sluggishness of the U.S. government in responding in a concerted fashion to the emerging technological prowess of China. Almost three decades have elapsed since the signing of the original Sino-U.S. bilateral agreement for cooperation in science and technology (S&T). It seems that while Washington has tended to view the S&T cooperative accords as the “icing on the cake” in terms of America’s relations with China, the Chinese have viewed S&T cooperation with the United States as the cake itself! Since the visit of Deng Xiaoping to the United States in 1979, the Chinese leadership has seen the country’s growing international S&T relations in very strategic terms; since the full launch of the “open policy” in the early 1980s, S&T ties with countries such as the United States and Japan have been treated as an essential ingredient in China’s efforts to close the prevailing technological gap between itself and the industrialized nations as represented in the Organization for Economic Cooperation and Development.
In contrast to the impression left by some current observers of China (both inside and outside the U.S. government), however, there has not been nor is there now a Chinese conspiracy or hidden agenda lurking beneath the surface of China’s stated foreign policy initiatives or S&T policies. The Beijing government has made it clear to the outside world since the announcement of the so-called “four modernizations” in the late 1970s that advances in S&T were the key to the modernization of agriculture, industry, and national defense in China. In addition, the leadership has made no secret of its interest in importing foreign scientific and technical knowledge to upgrade national R&D capabilities in universities, the Chinese Academy of Sciences, and industrial enterprises. The fact that few, if any, took the Chinese stated intentions seriously until the past 3 or 4 years is an error of omission that may yet come back to haunt the United States as the Chinese march ahead in their quest to join the world’s leading nations at the frontiers of scientific discovery and technological innovation.
Perhaps the best example of missed opportunities was the withdrawal of direct government support for the U.S. China Management Training Center in Dalian in the mid-1980s. With the U.S. Department of Commerce as the lead agency, the United States had been a leader in working with the Chinese to inaugurate one of the first bilateral programs focused specifically on management education for China’s emerging new enterprise and government leadership. However, it seems that neither the Congress nor the Commerce Department was about to come up with the $80,000 to $100,000 needed to continue the program, and thus after several successful years it almost collapsed. Were it not for the vision of the management school at the State University of New York at Buffalo, which took over the running and financing of the program at the point of its near demise, the entire effort might have simply disappeared. Today, whereas the European Union (EU) has spearheaded the founding and supported the operation of the China Europe International Business School (CEIBS) and has helped to make it into to one of the finest management schools in the Asia-Pacific region, the United States is conspicuous by the fact that it lacks a similarly supported institution in China.
Of course, there are a large number of scientific exchanges and cooperative R&D projects taking place through universities and other private auspices in the context of the overall expanding ties between the United States and China over the past several decades. The benefits of these ties in terms of building trust and confidence between and among members of the Chinese and American scientific and engineering communities should not be ignored. But, as De Angelis suggests, the U.S. government does not seem to recognize the enormous opportunities that exist for win-win outcomes by building stronger and deeper S&T collaboration with China. As a result, the United States no longer seems to be at the top of the Chinese list of preferred bilateral partners. On a recent trip to Beijing this year, I was told quite explicitly that “the United States is now number 4, below the EU, Russia, and other international S&T organizations in terms of S&T cooperation.” Moreover, a young Chinese official speaking quite candidly confided in me that she had aggressively sought to work in the government department concerned with U.S. S&T cooperation, because in the past it had been a fast-track path to career advancement. To her great chagrin, however, that no longer seemed to be the case because of the unmet expectations from the limited nature of bilateral S&T cooperation with the United States.
Now, some may cheer that this is all to the good because the United States seems to have protected its “crown jewels” in terms of scientific and technological assets. However, the reality is that China’s S&T system continues to move ahead with its plans to strengthen indigenous innovation, build world-class universities, and revitalize organizations such as the Chinese Academy of Sciences through important initiatives such as the Knowledge Innovation Program (KIP). Don’t get me wrong—many problems continue to persist across the S&T landscape in China, such as the country’s still-immature regime for protecting intellectual property and the shortage of experienced managerial talent to operate China’s growing number of R&D and engineering centers. Nonetheless, in a world of globalization, where national systems of innovation are giving way to a more global system of new knowledge creation and commercialization, collaboration and cooperation have become the new hallmarks of success. The fact that there are now over 750 foreign corporate R&D centers in China is testimony to the fact that the private sector in the United States and abroad understands this and is not shy about pursuing access to China’s brainpower as a way to enhance their own innovation potential. It is time for the U.S. government to move its attention from the icing and on to the cake, and to find ways to strengthen the potential for broader and more sustainable engagement in the S&T field with China. This means cultivating a cohort of specialists on S&T policy and programs in China as well as offering a more coherent vision, stronger leadership, and greater funding from the White House and Congress as we seek to figure out the precise parameters of the Sino-U.S. relationship in the years ahead.
Iran’s nuclear threat
“Controlling Iran’s Nuclear Program” by Joseph Cirincione (Issues, Spring 2006) makes little mention of the two issues that today motivate all Iranian factions to want nuclear weapons. The first is the fear of attack by the United States, given the U.S. aggression against another member of the “Axis of Evil”: Iraq. The second, mentioned in the last paragraph, is the presence of a potent nuclear power in the Middle East—Israel—a country that has been in defiance of the United Nations for more than 30 years.
Although it is to be hoped, as emphasized by Cirincione, that the present crisis can be settled by diplomacy, in the long run the only solution is a regime change in the United States to a government dedicated to the rule of law. As stated in Cirincione’s last paragraph, the goal should be a nuclear weapons–free zone (NWFZ) in the Middle East. Although he states that the United States has long supported such a policy, the fact is that the United States has never done anything to discourage the Israeli nuclear weapons program. The United States has limited tools to pressure Iran, but, given the dependence of Israel on U.S. support, there is the possibility of inducing Israel to gradually eliminate its nuclear arsenal as part of a NWFZ agreement.
Nowadays, it is extremely difficult to find a balanced article about Iran’s nuclear program. Joseph Cirincione has written one such article, for which he should be thanked. There are, however, a few points in the article that I would like to comment on.
First, Cirincione states that, “The danger [of Iran’s nuclear program] is that a nuclear-armed Iran would lead other states in the Gulf and Middle East, including possibly Saudi Arabia, Egypt, Syria, and even Turkey, to reexamine their nuclear options.”
This is, of course, a subject of many ongoing debates, for which no definitive conclusion has been reached. For the record, however, I point out that, as a member, Turkey is protected by the NATO alliance. Syria has been Iran’s strategic ally for 25 years and, thus, why would it be worried about a nuclear-armed Iran, when it is still in a formal state of war with Israel, which still occupies a part of its territory? Egypt, far from Iran and never threatened by it, should be worried about nuclear-armed Pakistan, the main source of Islamic radicalism. Iran’s relations with Saudi Arabia are even better than when the Shah was in power. Saudi Arabia is protected by the United States, anyway.
Perhaps Cirincione should address the following key issue: Why does he believe that these Arab nations might seek nuclear arms if Iran develops a nuclear arsenal, when they never tried to do so while they were (in Egypt’s case), or still are (in the case of Saudi Arabia and Syria), in a formal state of war with nuclear-armed Israel? More important, would the United States allow, for example, Egypt to do so, when it relies so heavily on annual U.S. economic aid just to barely survive?
Second, Cirincione argues that it is not economical for Iran to have a uranium enrichment program. Iran’s estimated uranium ore deposits are at least twice what Cirincione quotes, but it is also not prudent to consider the economics of enrichment in isolation, as it is only one component of the complete fuel cycle and a small part of nuclear reactor–generated electricity. It was also claimed for years that it is not economical for Iran to have a nuclear energy program, but as my article in the Winter 2005 Harvard International Review demonstrated, it is indeed economical. Moreover, (a) Japan and the European members of the URENCO consortium have no natural uranium deposits, but have vast uranium enrichment programs. (b) In the 1970s, the Shah signed an agreement with the Soviet Union whereby, in return for receiving natural gas, the Soviets built Iran’s first steel plant. The Shah was told that it would be much cheaper for Iran to import steel. Today, Iran produces 75% of its steel. (c) Cirincione laments that Iran is not willing to rely on Russia for nuclear fuel. There is historically deep mistrust of Russia in Iran. Russia took over by force large parts of Iran’s territory in 1813 and 1827 and never relinquished them. It helped the counterrevolutionaries during Iran’s Constitutional Revolution of 1906–1908. The Soviet Union refused to evacuate parts of Iran at the end of World War II, until it was pressured by the West. Iranians also see how easily Russia shuts off its natural gas pipelines to Ukraine, Western Europe, and Georgia.
Third, it is often said, as Cirincione also mentions, that the world does not trust Iran because it hid its Natanz and Arak facilities for 18 years. But Iran’s only obligation was to inform the International Atomic Energy Agency 180 days before it introduced any nuclear materials into those facilities, which it did. It is also erroneously said that Iran has violated the provisions of the Nuclear Non-Proliferation Treaty (NPT). The only way to do so is by either using nuclear facilities to weaponize or by secretly helping another nation to do so; Iran has done neither. It has only been found in breach of its Safeguards agreement, a far cry from violating the NPT agreement. South Korea, Taiwan, and Brazil have committed far more serious violations than Iran.
Fourth, people across Iran’s political spectrum believe that the United States never recognized the legitimacy of the Iranian revolution of 1979 and has been trying ever since to overthrow the regime. They also worry about Talibanization of Pakistan. If President Pervez Musharraf is assassinated and the Taliban’s sympathizers in the military take over, they will pose a grave danger to Iran’s national security. So long as such legitimate concerns are not addressed, no Iranian government, regardless of its political leanings, would dare to abandon the nuclear program. But Cirincione makes only a passing reference to these all-important issues at the very end of his fine article.
The crux of the issue is not, as Ciricione states, whether “other nations trust that Iran’s program is, as they claim, peaceful.” In the absence of any credible security guarantees, Iranians perceive the capability to enrich uranium as vital for Iran’s national security (as does North Korea). But such a capability would make Iran, a large country with rich resources located in the most strategic area of the world, unattackable; a prospect not acceptable to the United States. Now, that is the real crux of the issue.
Aquaculture and the environment
As a team leader working “on the ground” of a major interdisciplinary, multi-institutional effort to demonstrate the technological feasibility of offshore aquaculture in the southeastern United States and Caribbean regions, I would like to provide a few comments in rebuttal of some of the criticisms expressed by Rosamond L. Nay-lor in “Environmental Safeguards for Open-Ocean Aquaculture” (Issues, Spring 2006) and in support of the National Offshore Aquaculture Act of 2005.
Naylor’s claim that the ecological effects of marine aquaculture have been well documented is correct, but the two references she cites are biased, offering a one-sided, negative view of the activity. There have been numerous reports and publications showing that the ecological impacts caused by net-pen aquaculture are low when compared to the yields produced.
Naylor claims that there are no environmental safeguards in place for obtaining permits for open-ocean aquaculture in the United States only because she never applied for one. During our permit application for the development of one such project in Puerto Rico in 2001, we had to fulfill the requirements of 13 agencies [including the U.S. Environmental Protection Agency, National Oceanic and Atmospheric Administration (NOAA), and Fish and Wildlife Service], each one competently justifying its existence. When applying for the permits for the expansion of the project in 2005, the list of agencies involved increased to over 20. The permitting process is complex, lengthy, and expensive, requiring a great deal of scientific and legal expertise. The Offshore Aquaculture Act of 2005 proposes to organize the permitting process, with NOAA as the leading agency centralizing applications. This is clearly the right and sensible path to follow.
The offshore aquaculture demonstration projects currently being conducted in Puerto Rico, Hawaii, New Hampshire, and the Bahamas have completely submerged cages stocked with hatchery-reared fingerlings of endemic native species such as cobia, snapper, amberjack, moi, and cod: species whose fisheries are mostly depleted. After four years, we have enough data to show that the nutrients and suspended solids generated by the cage systems do not dramatically affect the oligotrophic offshore environment, because of its carrying capacity. There were no significant differences in any of the water-quality parameters measured in the area surrounding and beneath the cages. The reports are available, and resulting manuscripts are being submitted for publication and/or have been published (references are available on request).
Naylor is a respected environmentalist, and most of the suggestions offered in her article are admittedly sound. However, none of the suggestions is new to aquaculture scientists or the industry. Most have been or are already being implemented by NOAA and other agencies involved in the process.
The offshore areas of the United States and its islands and territories have extraordinary potential for the development of an environmentally sustainable offshore aquaculture industry. We are ahead of the world in technology for open-ocean aquaculture and cannot afford to lose the edge as we are already doing in other fields. U.S. entrepreneurs and venture capitalists are interested in investing in the industry, but in light of the negative perception that Naylor and many other environmentalists are selling to the public, are already beginning to look abroad. We must simplify the process and move ahead with this legislation so as to keep the industry within our control, and the National Offshore Aquaculture Act is the first step toward U.S. autonomy in seafood supply.
Naylor and other environmentalists are also quick to criticize what they hear and read about what a handful of U.S. entrepreneurs are doing to develop a new, environmentally sustainable, and economically viable industry that will help alleviate our dependency on seafood imports and reduce an escalating trade deficit that currently is almost $10 billion per year. We have created the opportunity in the United States and must capitalize on it. Moving the industry offshore is the right path to the development of a low-impact high-yield industry that will produce most needed seafood while creating jobs and other socioeconomic benefits. Beyond economics, the importance of developing the offshore aquaculture industry in the U.S. Exclusive Economic Zone may become a matter of national food security soon. We cannot afford not to do it.
Rosamond L. Naylor issues a timely call for high standards for open-ocean aquaculture. Aquaculture is being pushed hard by industry and the federal government as a solution to the U.S. seafood deficit and the crises facing our oceans from depleted fisheries, pollution, and habitat destruction. However, two recent national ocean reports and numerous studies by Nay-lor and others document the significant risks posed by ocean fish farming from pollution; the use of chemicals, drugs, and fishmeal; the genetic alteration of wild fish stocks; the spread of disease and parasites; and others listed in the article. If not properly and sustainably managed, with precautionary safeguards, aquaculture may become yet another cause of ocean degradation.
It is therefore extremely disappointing that the Bush administration and Sens. Ted Stevens and Daniel Inouye have introduced federal legislation (S. 1195) that utterly fails to provide such safeguards.
At a recent Senate hearing on S. 1195, the Bush administration continued to insist that environmental concerns be addressed in regulations issued after the bill is enacted. This completely ignores the precautionary approach touted by the National Oceanic and Atmospheric Administration (NOAA), the same federal agency that wrote S. 1195. Nor are other federal agencies stepping up to the plate. The Environmental Protection Agency recently issued effluent guidelines for ocean fish farms without any numeric limits on pollutants commonly discharged by those farms (such as fecal coliform bacteria, pesticides, drugs, nitrates, phosphates, metals, and suspended solids).
Congress should propose specific standards to guide the development of a sustainable fish farming industry, such as is currently being considered in California. In 2003, California banned raising salmon, non-native, and genetically modified organisms in state ocean waters (which extends three miles offshore) to protect native fish stocks. This year, California is going one step further and enacting legislation (SB 201), sponsored by The Ocean Conservancy and State Senator Joe Simitian, to provide comprehensive standards that address specific risks posed by farming native species. These standards were developed through extensive negotiations with nongovernmental organizations, the state legislature, the Schwarzenegger administration, and industry to establish a transparent process to minimize pollution and the use of drugs and chemicals; select appropriate lease sites; prevent disease and the escape of farmed fish; avoid conflicts with fishing and other public trust uses; use sustainable feeds; monitor and assess impacts; avoid conflicts with fishing and other ocean uses; protect wildlife; and repair damage to the marine environment.
The California legislation is supported by more than 30 business, conservation, and fishing organizations, most of which oppose the weak standards in S. 1195 developed with little stakeholder buy-in. Fish farming operations in federal waters (3 to 200 miles offshore) will affect state ocean resources. Congress and the Bush administration should follow the lead of California and states like Alaska, and go back to the drawing board to develop strong and responsible standards for a sustainable fish farming industry to protect our declining ocean health.
The future of aquaculture most certainly lies in the offshore environment, and Rosamond L. Naylor has rightly identified the potential risks of this new technology. Offshore aquaculture won’t have a bleak future if the lessons learned from coastal net-pen farming of salmon are broadly applied and if sufficient precaution is used to direct the development of this nascent industry. It is far easier to establish and apply rigorous environmental safeguards now, before environmental degradation is evident, than it is to attempt to modify the industry once it is fully capitalized.
I propose that we set our expectations high for offshore aquaculture. All the major environmental issues must be adequately addressed, including the use of wild fish for feed, escapes, disease amplification and transmission, and nutrient impacts. Government policy should promote the use of trimmings from sustainable food-grade fisheries (and other innovative measures) to reduce the reliance of aquaculture on distant pelagic ecosystems for feed inputs. Sound policy should also ban the use of genetically modified organisms and require the farming of native species, while maintaining strict genetic parity between farmed fish and wild stocks, for escapes will inevitably occur. Past experience suggests that fish will likely need to be grown at densities below optimal commercial densities to reduce the probability of disease amplification in these inherently open systems. Vaccines against disease must be developed quickly to eliminate the use of antibiotics and other therapeutic treatments. Comprehensive ecosystem studies must be commissioned by the federal government and funded by industry to quantify and adequately limit the cumulative impact of offshore farms as the industry expands.
As Naylor rightly states, the United States has the opportunity to be a global model of sustainable fish production. There is a growing constituency of consumers and businesses eager to purchase sustainably caught and farmed seafood. Over the past six years, Seafood Watch at the Monterey Bay Aquarium (www.seafoodwatch.org) has distributed over 7 million pocket guides that identify these sustainable choices. These science-based tools are raising awareness and changing consumer’s purchasing habitats. Seafood businesses (including the nation’s largest retailer, Wal-mart) have heard the message, and they too are reforming their purchasing policies toward more sustainable seafood. Should the National Oceanic and Atmospheric Administration and the federal government develop and enforce strong environmental standards for offshore aquaculture, a large and growing body of consumers will be willing to reward these businesses in the global marketplace. Should these standards be weak and should environmental problems ensue, con-sumer support for this new industry will rapidly dissolve.
The subject of “Federal Neglect: Regulation of Genetic Testing,” by Gail H. Javitt and Kathy Hudson (Issues, Spring 2006) is clearly an important one as advances in genetics and genomics contribute to the development of new genetic tests and services, driven by physician and patient demand for these diagnostic services. The number of genetic tests available is rising as the technology develops, as is the significant contribution that these tests make to individualized personal health care. Genetic tests can detect disease early, before the onset of symptoms, when treatment can be more effective; and can specifically target therapy for existing disease that is more effective for the individual patient. It must be the shared objective of all of us to ensure that patients obtain the full benefit of this revolutionary technology, to continue to encourage innovation, and to regulate in ways that are appropriate and do not create barriers to either patient access or innovation.
I must take exception to the article’s alarmist premise that federal “neglect” in the oversight of genetic tests “represents a real threat to public health.” In fact, the regulatory gap referred to by the author is illusory. The clinical laboratory industry is one of the most highly regulated health care–delivery sectors. All clinical lab services are regulated under the Clinical Laboratory Improvement Amendments of 1988 (CLIA). CLIA regulations are documented by hundreds of pages of specific and general requirements for laboratory quality, such as obligations to have appropriately trained personnel, establish quality-control programs, and engage in proficiency testing, which all apply to laboratories performing genetic testing. More important, CLIA regulations require that before a laboratory introduces a new method or test that does not use a commercially available test kit, it must establish and document the performance specifications for accuracy, precision, analytical sensitivity, analytical specificity, and quality of results for patient care: all essential parameters of quality and performance. These requirements are enforced by onsite inspections every two years. The penalties for noncompliance are severe and can lead to the revocation of the lab’s CLIA certificate, without which a lab is unable to provide services.
The record indicates that laboratory tests are accurate and reliable and provide information relevant to the patient and his or her doctor. It is important that any proposed regulatory changes focus on risks specifically related to genetic tests and those that are targeted, realistic, and effective to meet any legitimate issues or risks. It is incumbent on all of us to work together to identify specific concerns and regulatory responses that will address those concerns without creating undue burdens that will stifle innovation or restrict patient access to new technology.
Taxes and highways
As the U.S. Chamber of Commerce Foundation concluded in its November 2005 report, the only real problem facing the gas tax at present is that it has been 13 years since it was last adjusted. Since 1993, it has lost 30% of its purchasing power. Recent spikes in the price of steel, concrete, asphalt, and petroleum compound this problem. What may force Congress to take action, is the fact, confirmed by the president’s 2007 budget, that the spending authorized by the federal transportation bill will exhaust Highway Account reserves and confront the Highway Trust Fund with insolvency in just three years. Industry observers have concluded that this crisis will either force Congress to adjust fuel taxes come 2009, or funding for the federal highway and transit programs as we have known it will collapse.
Meanwhile, the Highway, Bridges and Transit Conditions and Performance Report released by U.S. Department of Transportation (DOT) in March 2006 shows that annual highway capital spending needs to ramp up from the $68.2 billion invested by federal, state, and local governments in 2004 to $118.9 billion to meet national needs. AASHTO puts this figure at $125.6 billion, but the overall conclusion is the same: The United States needs to increase highway investment by 70 to 80% to keep us competitive abroad and meet mobility needs at home.
That sounds like an enormous challenge, but recent history shows that achieving it is possible. Between 1981 and 2004, highway spending for capital, maintenance, administration, and debt service increased from $42.5 billion to $145 billion. Over that period, federal funding increased from $12 billion to $31 billion, while state and local investment increased from $30.5 billion to $114 billion. Leaders at all three levels demonstrated the political will to produce the resources needed.
In “For What the Tolls Pay: Fair and Efficient Highway Charges” (Issues, Spring 2006), Rudolph G. Penner accurately describes the difficulty ahead in convincing Congress “to return to its historical practice of occasionally raising the fuel tax when the federal highway program is reauthorized,” as it did in 1982, 1990, and 1993. What he does not mention is that the political difficulty of increasing revenues at the state and local levels will be just as great as that at the federal level. Medical costs funded by states have been growing at 11% annually and are expected to continue to grow. This may crowd out what states can put into transportation from any but dedicated transportation revenues. The good news is that in the 2004 elections, 76% of transportation measures on the ballot across the nation passed. In 2005, a $2.6 billion bond measure for transportation passed in New York, and voters in Washington state by a 53% margin voted to reject the repeal of a 9.5-cent gas tax hike approved by its legislature earlier that year.
The long and short of it is that if we are to ramp up annual highway capital investment to the level of over $118 billion that the U.S. DOT in March 2006 stated is necessary, all levels of government—federal, state, and local— will have to continue to fund their share of the increase. Today’s federal share of 45% will have to be sustained. The federal government can help state and local governments to fund their 55% share by removing obstacles to bond financing and tolling and by encouraging public/private ventures. A total of 90% of federal Highway Trust Fund revenues come from fuel taxes and the balance from truck fees. To sustain their own vital contribution to highways and transit in 2009 and beyond, Congress may have to make some necessary but courageous decisions.
Some in the transportation community have criticized the Transportation Research Board (TRB) committee headed by Rudolph G. Penner for not calling for a large increase in highway investment. Though committee members were of mixed views on whether doing so would be wise, we decided early on that the level of highway investment was not what the committee had been asked to address.
However, our recommendations are certainly consistent with better targeting of highway investments (which I believe will lead to a net increase, for reasons explained below). As Penner points out, despite the merits of the user-pay principle still embedded in highway finance, the politics of centralized administration and the political distribution of highway funds lead to wasteful spending—not merely “bridges to nowhere” and other earmarks, but numerous projects done simply to make sure that every congressional district gets its share. It’s not surprising that aggregate figures show declining rates of return on highway investment.
One unanticipated but tragic consequence of this system of resource allocation is that large “lumpy” projects, such as adding high-productivity toll truck lanes to intercity highways and adding value-priced networks of congestion-relief lanes to urban freeways, seldom get funded. And this at a time when trucks carry 90% (by value) of all goods and major interstates are both wearing out and short of lanes, and when motorists waste $63 billion a year stuck in urban traffic congestion.
If public policy facilitates the use of toll finance (to address the funding problem) and public/private partnerships (to foster innovation), as the report recommends, many such projects are likely to be implemented over the next 20 to 25 years. And that will provide a wealth of experience for all transportation stakeholders in the use of per-mile charging for highway finance.
Thus, by the time the nation has to begin a serious transition from fuel taxes to per-mile charging, the users, providers, and policymakers will be dealing with familiar concepts rather than having to debate a leap into the unknown.
Rudolph G. Penner did a great job of making sense of the several challenges confronting our surface transportation system and the many solutions that have been proposed to address them. I can’t disagree with any of his key points, and commend him for avoiding the alarmist rhetoric common to many in this business, specifically as it relates to the adequacy of the revenues likely to be generated by the fuel taxes that now fund a big chunk of federal and state road and transit projects. Nonetheless, he does make the case that more revenues will be needed in the future to accommodate expected growth in population and economic activity, and that we should begin thinking about revenue alternatives (or supplements) to the state and federal fuel taxes.
Anyone familiar with surface transportation trends is also familiar with the key problems confronting the system. Chief among them is the absence of any meaningful increase in capacity over the past few decades, while usage and the number of users rise at a rapid clip. Rep. Don Young said it best when he observed a few years ago that while the numbers of licensed drivers (up 71%), registered vehicles (up 99%), and miles driven (up 148% percent) have all soared since 1970, “new road miles have increased by only 6 percent.” That’s it? Six percent? This is an astounding indictment of a federal program that has spent (in inflation-adjusted dollars) more than $700 billion in taxpayer money since 1970 on top of an even larger amount spent by the 50 state transportation departments over the same period.
Chief among the reasons for this pathetic state of affairs is that the federal highway program morphed into an all-purpose spending program once the interstate system was completed in the early 1980s. The recently enacted transportation act—one of the worst pieces of legislation ever passed by any Congress—will apply only about 60% of motorist fuel tax revenues to general-purpose roads. As a result, adding more revenues to the system will only serve to inflame Congress’s increasingly bizarre obsession with wasting transportation money at the expense of any improvement in mobility.
Take the federal transit program: Although as much as 25% of federal trust fund dollars go to transit, nationwide only 2% of surface passengers use it, a figure that falls to just 1% when the New York metropolitan area is excluded. Indeed, 75% of transit ridership occurs in just seven metropolitan areas, thereby forcing motorists throughout the nation to support a tiny fraction of commuters in a nationwide application of trickle-up economics. The new transportation act continues this trend toward more and more diversions by creating new federal responsibilities covering sidewalks, truck parking lots, and the dissemination of information about bicycles. Until the federal surface transportation program is terminated, as Sen. Jim DeMint’s new legislation would allow, taxpaying motorists should “just say no” to any more revenue-raising schemes.
I read with great interest Rudolph G. Penner’s essay on funding future highway improvements in the United States.
Although Congress and our state legislatures indeed have a multitude of scenarios, considerations, options, and issues to ponder, one abiding, overwhelming constant remains: a pressing need. In my own state of Georgia, our 20-year statewide transportation plan for federal and state highways will require $55 billion just to maintain current levels of service, yet we project only $36 billion in revenues from existing funding mechanisms. Nationally, effectively maintaining our collective transportation infrastructure requires $91 billion a year; yet only $74 billion is appropriated.
These disparities underscore the need for elected leaders and transportation planners to carefully and expeditiously examine transportation funding; not simply the efficacy of federal and state motor fuel taxes, but also concepts such as managed lanes, public/private partnerships, and frankly, any other option we can think of that might help close this gap.
The centerpiece of a stronger national commitment to expanding domestic ethanol production must be sustained and adequate federal funding for research, development, and demonstration (RD&D) of biorefineries and related technologies. Federal RD&D partnerships with both the forest-products and agriculture industries are vital to accelerating development of the U.S. domestic lignocellulosic ethanol industry.
Adequate federal funding for RD&D could substantially influence the adoption of new technologies in the forest-products industry, which is poised to become a major contributor to the emerging ethanol industry. By deploying key fermentation and thermochemical technologies, our existing pulp and wood products mills could be converted into integrated biorefineries to produce ethanol and other biofuels in conjunction with our traditional product lines. We have much of the infrastructure and expertise—feedstock harvesting, transportation and storage; manufacturing and conversion infrastructure; waste handling and recovery— needed to rapidly implement biorefineries at a commercial scale. By and large, our mills are located in rural communities where important synergies with agricultural feedstocks, including energy crops, can be realized. Since the biorefineries would be installed at existing mills, many of the transportation and infrastructure costs that currently exist for ethanol production would be reduced or eliminated. Finally, the dispersed geographic location of our mills would enable ethanol production throughout the country, contributing to a more diversified and secure energy supply.
With on-again/off-again federal RD&D support, our industry finds it difficult to make progress in address-ing technical barriers in the core technologies needed to implement these biorefineries. Thus, our industry is tentatively encouraged by the president’s State of the Union announcement of additional funding to foster technology breakthroughs in cellulosic ethanol. The test will be whether this evolves into truly sustained funding priority, and thereby help to mitigate the risks faced by our early adopters.
A national policy that promotes ethanol imports, as suggested by Lester B. Lave and W. Michael Griffin (“Import Ethanol, Not Oil,” Issues, Spring 2006), could have a place as a transitional strategy to develop U.S. ethanol markets. We share their assessment that the total ethanol demand is such that both domestic production and imports could be accommodated. However, unless a policy encouraging imports is accompanied by a strong and realistic long-term commitment to federal RD&D investment in technology for domestic production, we may simply wind up replacing one foreign fuel dependency with another.
Protecting the West
From my perspective, “Protecting the Best of the West” by Wendy Vanasselt and Christian Layke (Issues, Spring 2006) appears to touch on many of the issues that beset the Bureau of Land Management (BLM). The BLM is an agency charged with multiple responsibilities but lacks both funding and staff to complete their myriad missions. However, noting that more funding and staff are needed doesn’t make it happen. More focus is needed on possible solutions, and I offer the following observations.
(1) Local people need to be actively lobbying for their public-lands agency. Organizations such as the Park Service on both the local and national levels have effective lobbying support whereas the constituencies for the BLM tend to be diverse and often focused on fighting with each other rather than helping the agency. People need to be visiting with their local newspapers and local congressional representatives. They need to be represented in Washington, DC, attend funding hearings, and carry the word as to what the BLM needs. For example, Land and Water Conservation Funds, which have been for years a keystone for ongoing BLM acquisition projects, have been cut by over 90% during the Bush administration, but I see little public outrage.
(2) The BLM needs to allow decisions to be made in a timely manner. Often, because of the various political and paperwork obstacles, nothing is done.
(3) We need to be able to reward the hardworking, competent, and committed members of the BLM staff. Equally, we need to be able to dump the deadwood. People who are barely competent often appear to do as well in the agency as those who are truly dedicated and effective.
(4) Partnerships, partnerships, partnerships, partnerships. A key focus question needs to consistently be who can partner with the BLM? In our area, there are partnerships with the U.S. Forest Service to co-manage lands and co-mingle staff, partnerships with local cities to provide funding for law enforcement needs, partnerships with trail-user groups, and partnerships with conservation organizations to lead in BLM land acquisitions. Partnerships are possible, but they have to be a central focus for the agency.
(5) Find ways to allow staff to remain beyond the normal rotation of duty. Often people who have finally established effective partnerships with the locals find themselves sent off to another part of the United States in order to continue to advance their careers and increase their meager salaries.
The BLM has always been the stepchild of the resource agencies, allowed to protect “what’s left of the west” that wasn’t wanted by other agencies. The BLM needs to have our constant attention and care, and we need to view it as an organization that we welcome with pride in our local communities.