To frack or not to frack? That is the question

After a year’s work between Texas and New York studying the science, politics, and ideology of natural gas development–I present my Master’s thesis: To Frack or Not to Frack. Here is the abstract:

The modern vision of the Good Life—indistinguishable from the idea of progress—is energy intensive. We go to extreme lengths to harness energy resources, conducting vast technological socio-environmental experiments to satiate the human demand for energy. But energy development is risk-laden, and people approach the risks of progress differently, which manifests as political contention.

Bookending the continuum of risk-related ideology, the precautionary and proactionary principles have become pillars of philosophic and political debate. Natural gas development—hydraulic fracturing for natural gas, or “fracking”—is particularly risky and, in turn, the politics of fracking have become correspondingly controversial. On one hand, precautionaries about natural gas development spurn fracking as guaranteed disaster, while on the other, proactionaries hail natural gas development as an ideal energy opportunity.

But why are people precautionary and proactionary about natural gas development? To Frack or Not to Frack explores this question using an international survey instrument and statistical causal analysis. Evidence indicates that precautionary and proactionary regulatory preferences about natural gas development are a function of relevant knowledge, values, and beliefs.

Precautionaries about natural gas development tend to be knowledgeable of the risk-related scientific literature on fracking and to especially value environmental stewardship and public health and safety. Proactionaries, on the other hand, tend to principally value economic growth, believe that technology is generally trustworthy, and believe that either plenty of scientific research has already been
done on natural gas development orthat more science is still needed.

When determining specific permitting and operating requirements for natural gas development, policymakers should directly engage the relevant knowledge, values, and beliefs that drive the precautionary and proactionary regulatory preferences of their constituents via regular, open participatory policymaking procedures and statistical analysis of risk-related preference data gathered through public polling. Natural gas development policy should reflect the moral nuances of its constituency. Natural gas development policy should also reflect that developers are morally responsible for researching and internalizing the risks of harm related to development, including literal physical or environmental harm and exposure to risk of harm.

Congress’ assault on knowledge

Last month, half of Congress decided that political science isn’t worth NSF funding unless it advances economic development or national security. Imagine, politicians making it more difficult to study politics. Senator Tom Coburn (R-OK) and the 72 other senators who voted for the bill seem to have forgotten that knowledge is the foundation of the economy and the root of our security. But the congressional assault on knowledge does not stop at political science. Science itself is now the target.

Under the guise of impartial austerity, Rep. Lamar Smith (R-TX) has drafted a bill—ironically named the “High Quality Research Act” (HQRA)—to replace the National Science Foundation’s (NSF) peer review process with an arbitrary value-latent euphemistic circumlocution of funding criteria. Instead of peer reviewing the broader impacts and intellectual merit of scientific research to decide what projects deserve funding, Smith would rather cut the NSF budget and micromanage.

Jeffrey Mervis of Scientific Insider reports:

(FTA): “Specifically, the HQRA draft would require the NSF director to post on NSF’s website, prior to any award, a declaration that certifies the research is:

1) ‘…in the interests of the United States to advance the national health, prosperity, or welfare, and to secure the national defense by promoting the progress of science;

2) … the finest quality, is groundbreaking, and answers questions or solves problems that are of utmost importance to society at large; and

3) …not duplicative of other research projects being funded by the Foundation or other Federal science agencies.’

NSF’s current guidelines ask reviewers to consider the ‘intellectual merit’ of a proposed research project as well as its ‘broader impacts’ on the scientific community and society.”

Regarding HQRA’s first criterion: Is there a nefarious ploy playing out within the scientific community to stagnate national health, prosperity, welfare, or security? Progress in science is a bulwark for national security, so shouldn’t we increase NSF’s budget and make funding more, rather than less, available? Innovation takes freedom. So unless Smith (et al.) can clearly identify other-regarding harm that stems from NSF research, national policymakers should not further limit, i.e. regulate, innovators freedom to innovate. If anything, HQRA would stifle innovative liberty.

To the second criterion: Not all science can or should be “groundbreaking.” Scientific advance is piecemeal. Some research is groundwork for groundbreaking discovery. Think of outwardly banal research like infrastructure: the state must invest in roads before sports cars can cruise. Roads might not be flashy, but they are necessary—and their construction is actually profound when studied in any depth. The seemingly insignificant of today is the foundation for tomorrow’s profundity.

To the third criterion: Duplication is essential to the very nature of science. “Groundbreaking” results should be duplicable. Scientific redundancy hedges against fraud. If results are neither duplicable nor duplicated, how can we tell what research is trustworthy? Precluding scientific duplication de jure strikes me as creating a quack haven. Unless HQRA sponsors intend to protect quackery, stipulating non-duplication is nonsense. More cynically, HQRA’s non-duplication clause would shrink publicly funded competition for “science” advanced by wealthy private political interest groups—re: Oreskes, Conway, & Fox’s concerns about climate change deniers and frackademia.

HQRA smacks of big government—and given its Republican sponsors, libertarian hypocrisy. Congress should not decide what science is worth doing. Natural demand generated within the scientific community should guide research priorities—the invisible hand of the scientific marketplace, in a sense. If Congress shouldn’t “pick winners and losers” in business, why should it in science? Scientists, not Congress, should be the authority on what science is worth doing.

HQRA constitutes an arbitrary imposition of its sponsors’ beliefs pertaining to the value of science—the value of knowledge—in society and policymaking. If HQRA sponsors want to debate the value or proper role of science in society and policymaking, then we should explicitly talk about those values and beliefs. We should discuss the principles underlying the policy. Smith (et al.) should not pretend their motivation is financial. To frame HQRA as a fiscal issue insults public intelligence.

We’re talking about an annual NSF budget of less than 7 billion dollars, people ($6.9B appropriated in FY2013—cut down from the full $7B in FY2012). The US spends $7 billion on defense every three days. Not that defense spending isn’t money well spent, but let’s keep things in perspective when discussing national financial expenditure—and might I reiterate the importance of scientific progress to national defense. NSF’s budget is not the source of US financial woes. In fact, scientific research is among the safest of investments.

Science policy should build roads and get out of the way—unless there are obvious risks of harm related to experimentation, which by rule of the harm principle, can and should be regulated. Scientific innovators do their best work when free to experiment, free to fail without accost, and free to prune the mysteries of the mundane. Of course, freedom means funding. But we, the people, provide that funding via taxes—NSF funded scientists included. We deserve sound public investment with high rates of return. Science satisfies both.

Congress is constitutionally empowered to appropriate the national budget, but to do so on the basis of arbitrary values and beliefs disguised as objective financial necessity is morally questionable at best. Congress is not a group of generous feudal benefactors with absolute prerogative over we peasantry as it seems to have forgotten. Our representatives must be held accountable and to a higher standard of moral sense, which this recent assault on science—on knowledge—offends.

Science is iconic of American idealism: exploration, new frontiers, adventure, accomplishment, mystery, unexpected wealth, innovation, freedom and progress. Unless Congress is in the business of curtailing freedom and progress, the Coburn and Smith policies are a mistake. For all our sakes, Coburn’s anti-political science amendment should be rejected in the House and Smith’s anti-science policy should never see the congressional floor. But only time will tell. Progress in science may be a fact, but progress in ethics is often phantasmal.

jmk

Does being anti-fossil fuels mean being anti-modern?

To be adamantly anti-fossil fuels and then go home to happily relax in luxuries enabled by fossil fuels is an exercise of hypocrisy. But it is not hypocritical to be anti-fossil fuels and still be modernistic. Being anti-fossil fuels is not the same as being anti-modern. Exxon Mobil’s CEO thinks precautionary greens may as well curl up in a cave, but I don’t think the Fossil Fuel Resistance’s motivation is anti-modern at all. On the contrary, it’s hyper-modern. Perhaps even unrealistically so. Greens nurture a futuristic techno-utopian vision where society abandons fossil fuels entirely, renewable energy is dirt cheap, super efficient, infallibly reliable, and everybody in the world enjoys an extremely high standard of living while we coexist in perfect harmony with the ecosphere and ride bikes built from recycled bits of Al Gore to our well-paying jobs knitting organic sweaters out of diplomacy and human rights.

That last bit is obviously a joke, but unless you live on a commune far removed from society, you just can’t speak out against modernity and simultaneously live in the modern world without a profound level of cognitive dissonance–and people naturally avoid cognitive dissonance. Which is why the Fossil Fuel Resistance can’t be protesting modernity. They’re protesting the continuation of what they see as an obsolete model of modernity.

In fact, most greens would probably turn it around and argue that fossil fuels are anti-modern because we’ve been burning them for nearly two centuries now, they’ve served their purpose, and its time to progress to renewable alternatives because they’re having unintended yet still unethical ramifications for people and the planet as a whole. I’ll admit, it does come off as unappreciative and hypocritical, perhaps ignorant, to virulently demonize and criticize fossil fuels when they are undeniably the cornerstone of modernity and we all take their pervasive benefits for granted. But the Fossil Fuel Resistance isn’t protesting Keystone, fracking, and mountain top removal coal mining because they want humans to live like the stone ages. They’re being driven to the streets by their optimistic hopes for the future, their eco-egalitarian values, and their beliefs about how human beings should interact with the rest of the natural world.

But we could all do a better job of showing appreciation for the hard work and good intentions of others–greens, fossil fuelers, everyone. Partisanship and adversarial politics have become so ordinary that we forget the lives we’re so privileged to enjoy today are the result of centuries of collaborative innovation and cooperation. Modernity would not be possible without people working together, without amiable and constructive competition, without idea sharing, and without constantly and actively trying to grasp, appreciate, and respect the perspectives of those who think and see the world differently than ourselves.

Fossil fuels probably aren’t going anywhere anytime soon–and no amount of protesting will change the basic infrastructure of society instantaneously. But there is a place in this world for radical idealism. And in the face of catastrophic climate change, there is a need for it. Revolutionaries don’t earn that title by pursuing the indisputably realistic, but by challenging the status quo with dreams of what’s to come—of what should come. But no less, we need the realists, the traditionalists, and the pragmatists to remind us of our origins and keep our wheels turning in the here and now.

With a little mutual understanding and effort, there are commonalities to be found even between greens and fossil fuelers. In fact, they may not be so different at some deeper philosophical levels. Both sides believe human beings are bound for greatness, moving purposively through history toward our grand cosmic destiny. Both are interested in alleviating global poverty and human suffering through the perpetuation and dissemination of a modern standard of living, for which all agree energy is vital. Both are confident that advances in science and technology will deliver humanity to these new eras of prosperity. And both believe in the importance of democracy, liberty, fairness, and free expression in the political process. We may see reiterations of the customary story of obdurate politics like the protest on February 17th, but the differences between the poles, fundamentally, are rather superficial.

Being anti-fossil fuels does not mean being anti-modern—it means being anti-fossil fuels. The vast majority of people support modernity as a worthy end, greens and fossil fuelers simply envision different means for accomplishing that end. But there’s often dramatic miscommunication when conveying their respective positions to each other. People get dismissive, conversations breakdown acrimoniously, and the full senses of both perspectives are lost. But if greens can keep a realistic handle on hypocrisy about their own fossil fuel use, and fossil fuelers don’t pretend that coal, oil, and natural gas are just innocent, misunderstood miracle substances, then maybe we can talk constructively. Just maybe we’ll circuitously arrive at mutually agreeable policies to combat climate change, develop renewables, and mitigate the negative externalities of resource extraction without unfairly disadvantaging or appearing unappreciative of the hard work that fossil fuel developers have done for society since the industrial revolution.

Optimistic? Naïve? Sophomoric? Perhaps. But someone needs to think through a middle way.

jmk

Listen up utilitarians! Friedman’s “win-win-win-win-win”

Putting a tax-based price on carbon emissions would be, literally and figuratively, a bold and explicit valuation of life itself–both of biodiversity’s preservation and of its fundamental elemental building block. It’d be nice if we could get some significant explicit value ascribed to the natural world after all this time. Putting Pigou to work on the cornerstone of biology might be an attempt to quantify something invaluable–but the unfortunate reality is that without a number, neoliberal capitalism defaults its value to zero and we all suffer a tragedy of the commons. But, oh yea, Friedman’s article is about the budget. Just think of the REVENUE and incentive to innovate! Come on you instrumentalist utilitarians, push for the win-win-win-win-win. Waxman can’t do it alone.

A hybridized market-based carbon credit trading system with a tax-based “catch-all” (like the one developed by McKibbin and Wilcoxen discussed at greater length here) could also satisfy eco-egalitarians still left wanting and free marketeers looking for a new generation of economic value. A carbon price would be precautionary move toward humanity’s softer treatment of the Earth and a proactionary incentive for technoscientific innovation toward progress as sustainability.

The sequester is just obdurate silliness anyway.

Let’s get it together, humans.

Cheers! JMK

Sierra Leonean prodigy comes to MIT

Last night I came across this MyScienceAcademy gem featuring Kelvin Doe, a 15 year-old Sierra Leonean who is nothing short of an engineering, mechanical, and technological prodigy. For years this kid (and I use the term “kid” loosely when referring to such a fine mind) has been rooting through “dust bins” in his neighborhood to scavenge old electrical components that he has used to construct his own radio station, where he goes by the performer name DJ Focus.

A radio station may sound small at first, but this is a community where electricity is available for maybe an hour each week. From discarded materials Kelvin engineered his own batteries, electrical circuitry, broadcasting apparatus, and audio equipment, all for two reasons: 1) So that he could play fantastic music for his friends and family. Everyone should listen to this song by Bobby Fala, which DJ Focus endorsed and played over his station — Fala has now also made it to SoundCloud, largely I bet, because of Kelvin’s success and publicity. And 2) So that the community could use his radio station as a forum for public political discourse – a chance for the unheard to find their soapbox, a place for issues on the ground to find their voice.

Without question, Kelvin’s enthusiasm, passion, genius, and focus are an inspiration. Imagine if more teenagers shared Kelvin’s clarity of thought, his drive and his heart, his sense of commitment to community and to improving the lives of his friends and loved ones. Hopefully, with help of non-profit programs like Global Minimum Inc: Innovate Salone, the group that discovered Kelvin, more youthful brilliance will show itself.

Kelvin’s story gives us all reason to be optimistic about humanity’s future. What’s he’s done is truly astounding — and if he continues to receive the support he needs, I bet this radio station and his trip to MIT won’t be the last time this young man makes headlines — particularly if he starts working on something like sustainable energy technology, improving batteries and energy efficiency, or developing small-scale alternatives to traditional electrical grids (though admittedly, he’ll probably come up with better ideas all his own). I wouldn’t put anything past him.

To Kelvin! Cheers!

JM Kincaid

A prognosis of T. Boone Picken’s LNG vehicle future

I stumbled across this piece by Alan Krupnick this morning while browsing Real Clear Energy (one of my stops along my daily morning news adventure). Essentially, he offers us an evaluation of the state of play for T. Boone Picken’s vision of a LNG vehicle future. The prognosis, by Krupnick’s account, is still to uncertain to call, but I think we can make something of it.

Liquid Natural Gas is cheaper than gasoline or diesel because of its newly accessible abundance via hydraulic fracturing and horizontal drilling, but it also has drawbacks. The vehicles themselves are more expensive than gasoline or hybrid alternatives (e.g. – Honda’s new LNG Civic as compared to its gasoline and hybrid counterparts) so the payback point takes longer to reach through savings on fuel costs alone. Of course there are subsidy programs that could bring down the cost, but they expired in 2010, and the prospect of getting Congress to agree on much of anything is, well…bleak, let’s say.

LNG vehicles also have significantly shorter range than gasoline or hybrid alternatives — and that’s before mentioning that LNG fuel tanks can take up to 50% more space than gasoline tanks or hybrid batteries, and even with severely reduced cargo or passenger space they still have shorter ranges (LNG: 218 miles per tank v. Gas: 383 mpt v. Hybrid: 504 mpt [looking again at different models of the Civic]). So, given the space issue, it may make more sense to focus on using LNG in large trucks, vans, and buses. But forecasts of the costs of maintenance are unclear, so fleets of LNG vehicles will have to struggle with uncertainty on that front for some time.

Finally, there is the question of infrastructure for LNG vehicles, which Krupnick frames as a ‘chicken or the egg’ conundrum. Infrastructure developers want there to be plenty of LNG vehicles on the road before taking on big projects, but consumers want infrastructure to be in place before they’ll be willing to take the risk of buying a non-gasoline or non-hybrid vehicle. Perhaps this gap can be bridged through commercial cooperation, where prospective LNG truck fleet purchasers coordinate with infrastructure developers to start building refueling stations in strategic locations along pre-established routes. Maybe if LNG starts showing up at Love’s or Buc-ee’s it’ll start making more sense for people to make the change (the same applies for electric vehicle plug-in stations, or even hydrogen powered vehicles), but until that happens most will probably see it as too risky, especially considering the reduced range of LNG vehicles.

Of course, there are still plenty of concerns worth raising about how we get our natural gas these days (fracking), the actual economic ripples of the industry, and the climate change/air pollution impacts of carbon dioxide and methane emissions associated with natural gas production. But T. Boone Pickens is convinced that LNG should be the future of transportation and Krupnick nods toward optimism, despite citing “uncertainties” about the environmental dimensions of such a transition.

So ask yourself — what is the real issue at hand? Cheap energy? Energy security? Environmental stewardship? Climate change mitigation? Energy independence? Economic growth?

At its core this represents one of the latest technological stabs at perpetuating our energy intensive standard of living while attempting to accommodate other competing values — but for all that it’s worth, we’re still talking about a short-term fix. And it’s one with many uncertainties surrounding it. Switching from oil to natural gas, at best, is like a first stitch in mending a deep wound. It may stop the bleeding a little, but we’re still lost in the woods if sustainable energy is our goal. Natural gas is, in many ways, desireable, questionable, risky, and perhaps inevitable (though not in some cases re: Longmont, Boulder, Yellow Springs, Broadview Heights, Meyers Lake, Cincinnati & the State of Ohio), so if we are going to use it, we ought to use it as best we can to pave the way for or to buy us time until sustainable, renewable energy technologies become competitive. In the meantime, I would still recommend going the Hybrid route or carpooling if you must drive — and even further, consider alternatives to personal automobiles like walking, biking, or public transit. Of course this isn’t always feasible, practical, or compatible with our established ways of life (especially living in places like North Central Texas) but small steps eventually traverse the world. We must, in this case and many others, take Ghandi’s advice and be the change we wish to see.

Cheers,

JM Kincaid

Science Progress publicizes study of beliefs about hydraulic fracturing for natural gas

http://scienceprogress.org/2012/12/technology-and-society-fracking-ideology/

As a follow up to the Science Progress article I co-authored with Dr. Adam Briggle earlier this July, we have written another short piece that again explains the subject of our study, Technology and Society: Fracking Ideology, and requests reader participation. You can find the article linked here and above.

Cheers!

JMK

To Frack or Not to Frack

The survey component of To Frack or Not to Frack is now closed–many thanks to all who participated. Results will be publicly available here and through Bard CEP. Stay tuned…

To Frack or Not to Frack

A survey of beliefs about hydraulic fracturing for natural gas

Dear energy consumers,

Hydraulic fracturing, or “fracking,” for natural gas plays an important role in the debate about our energy future. As an energy consumer, you may have beliefs about, or beliefs that relate to, the use of hydraulic fracturing technology. Given the prominence of natural gas in today’s energy discourse, I am using my Master’s thesis at the Bard Center for Environmental Policy to study the political and ideological dimensions of hydraulic fracturing. My goal is to develop a more thorough understanding of the relationships between socioeconomics, political alignments, philosophical beliefs, and support or lack thereof for the use of hydraulic fracturing technology – but my research depends on your participation. Here and below you will find a link that directs you to a survey with questions related to the current debate about hydraulic fracturing and natural gas:

To Frack or Not to Frack

To help me with my research, I ask that you complete the survey and then share this message and link with your friends, family, colleagues, coworkers, and other contacts so that they might do the same. If you have any questions please email them to jmk.frackingideals@gmail.com and I will answer you promptly. Thank you for your participation.

Sincerely,

Jordan M. Kincaid

Geo-ancestral politics

Steve Pinker recently published this NY Times piece on the geo-ancestral cultural roots of contemporary political divisions – my advisor at BCEP was kind enough to bring it to my attention. The underlying point of Pinker’s paper is common sense: understanding our nation’s geo-ancestry can help us understand the political divides of today. We are all vestiges of cultures past. But our cultural heritage stems not just from people, but also from place or topos (hence, “geo”-ancestry). Depending on where your ancestors came from, there’s a certain likelihood that your political allegiances will take one form or another because that place so influenced your ancestral culture and way of life that its remnants have trickled through history all the way to you.

I really recommend reading this piece for yourself because the next few thoughts won’t do his reasoning or research justice (nor will it fully capture all of his ideas), but the upshot is this: Pinker contends that if your colonial ancestors were from England, they were probably farmers, and moved to the Northern/Northeastern US, which translates today into a form of left-wing progressive liberalism. On the other hand, if your ancestors were Scots-Irish, they were probably herders, and moved to the Southern colonies/states, which translates today to right-wing (religious) conservativism.

Of course, many (if not most) Americans hail historically from places other than England, Scotland, or Ireland – this, I presume, is part of why Pinker’s next generalization is useful: forget particular countries; if the place and culture shared by your distant family was herding-based, chances are your ancestors’ relationship with the state partly resembled anarchy. If your family’s heritable culture was farming-based, it’s likely that your ancestors lived somewhere that the government’s role was more prominent. The former (herding and anarchical cultural heritage) corresponds with conservative and libertarian beliefs. The latter tends to correspond to left-wing progressive liberalism. So, the relevant political question then becomes: were your distant relatives herders or farmers?

And then, post-colonialism, Pacific-bound trailblazers were re-exposed to the anarchy of Westward expansion, reinforcing conservative and libertarian views in the mountain and southwest desert states. So this adds yet another dynamic to the system.

At the root of it all, however, Pinker and political philosophers theorize, is a contest between views about human nature – that is, whether you think human nature is fixed, flawed, and must be controlled as if by a strict parent through tried-and-true cultural and religious practices, or if you think human nature is malleable through wisdom and reason, and that public institutions can guide the progress of society like a nurturing care-taker. Pinker refers to these points of view, respectively, as the Tragic Vision and the Utopian Vision of human nature. The Tragic Vision, he suggests, grows out of the anarchical experience, whereas the Utopian Vision stems from living in closer relation to the state. Both of these, again, he says are largely determined by one’s geo-ancestry.

So this line of thought is an interesting one! But how accurate is it? How does it hold up “on the ground?” How about a case study?

In fact, I think I personally make for an odd case for Pinker’s theory — my Scottish ancestors (herders) moved to West Virginia (a northern state) in the early-to-mid 1800s. My relatives moved to Louisiana in the early 20th century, and then my grandfather moved the family to Texas in the 70s (both southern honor culture, with Texas culture being especially anarchical). So how does my geo-ancestry line up with my politics and ideals today?

I think something in between the Utopian Vision of humanity and the Tragic Vision of human nature is probably closest to the truth: human nature is malleable by reason and cultivated skill to an extent, so certain tendencies like violence, while innate and a constant struggle, are largely suppressible or ready to be channeled in constructive ways like martial arts.

I would say children are closer to being Rousseau’s noble savages than Hobbes’ nasty brutes (re: Montessori education). I believe that free markets usually make for freer people than command economies – the state is not omniscient, or really even close enough to make reliable guesses with economic policy. I believe faith has the potential to make individual people nicer and more compassionate, but I certainly don’t think religion has proven to be a work-around for shortcomings like violence and intolerance writ-large. I believe in the purity and sanctity of the body (both human and Earth), and I believe that providing care and avoiding harm are both important.

If you believe the character of the state should be parental (and I’m hesitant to admit that it should), we probably need it to fill both parental roles: one strict, the other nurturing. I think protecting the environment is among the most fundamental, non-arbitrary interests we can fulfill. I believe that a powerful military is necessary and desirable. And I believe that individual freedom in culture and sexuality is paramount for a healthy society.

So, maybe Pinker’s “herder-shepherd : right-left” analogy is more flexible than a strict dipole – beliefs from one set aren’t necessarily inconsistent or incompatible with beliefs from the other. I for one seem to fall on both sides of the distinction in terms of topos and present beliefs. In either case, it’s an interesting topological framework through which to conceptualize today’s politics – here’s to contemplating the politico-ideological impacts of geo-ancestral heritage! What story does your geo-ancestry tell?

Cheers,

JM Kincaid

Ambiguous policy language

“…as is feasible…”
“…as nearly as practicable…”
“…as needed…”

Environmental policy language of this sort creates loopholes that undermine the strength of regulation. The problem is a lack of consensus on the meaning of terms like “feasibility” and “practicability.” What we have here is a Confucian problem of naming; the meaning of labels like “feasible” and “practicable” hinge upon the values of the interpreter. We ought to openly discuss these underlying values, but more to the point, we should avoid wording of this sort in policy language so that regulations are enforceable. At a principle level this is a contest of values, and at a policy level it is a problem of enforcement.

JMK