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I suggest that, to overcome this dif
culty, qualitative criteria correspond-
ing to characteristics that may undermine ecosystem health should be
used as the basis for assessment. The criteria should be formulated to
advance the statutory objective of reducing anthropogenic pressures
on ecosystem functionality by exploring the extent to which an option
would make demands on, or otherwise affect, the natural world. For
example, would it require the consumption of resources? Would its use
result in the emission of greenhouse gases? This approach provides a
means of addressing our inability to identify likely effects of activities
on systemic properties. It is, in any event, well-suited to a legal frame-
work concerned with ecological protection as it displays an appropriate
level of concern for the preservation of what is ecologically valuable. This
can be contrasted with current practices that gamble on the accuracy of
prediction in the misplaced hope that opportunities for economic and
social gain might be maximised without causing ecological degradation.
Commentators on risk management in the face of uncertainty have
argued for decision-making by reference to qualitative criteria. Klinke
and Renn suggest that when potential damage and its probabilities are
unknown or contested, measures of hazardousness such as ubiquity,
irreversibility and pervasiveness should be used
'
as proxies for judging
. 88 Stirling and Harremoës have argued in the contexts of food
and chemicals regulation respectively that assessment should be con-
ducted by reference to
severity
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with criteria such as
bioaccumulativity and persistence being used to determine the extent
of environmental and health concerns presented by a substance. 89 This
means of evaluation might also be used for assessing the characteristics
of different policy options and their consistency with an objective of
ecological protection. Criteria that re
'
intrinsic hazard properties
'
ect the importance of diversity in
ecosystems and of other properties that are believed to promote resili-
ence might be used to assess the extent to which different alternatives
could impinge on the functionality of ecosystems. General criteria such
88 A. Klinke and O. Renn,
A New Approach to Risk Evaluation and Management: Risk-
based, Precaution-based, and Discourse-based Strategies
'
(2002) 22 Risk Analysis, 1091.
See also O. Renn, Risk Governance: Coping with Uncertainty in a Complex World
(London: Earthscan, 2008), pp. 193
'
-
6; and Renn,
'
Precaution and the Governance of
9.
89 A. Stirling, O. Renn and P. van Zwanenburg,
Risk
'
,pp.238
-
A Framework for the Precautionary
Governance of Food Safety: Integrating Science and Participation in the Social
Appraisal of Risk
'
in E. Fisher, J. Jones and R. von Schomberg (eds) Implementing the
Precautionary Principle: Perspectives and Prospects (Cheltenham: Edward Elgar, 2006),
p. 294; Harremoës et al.,
'
'
Twelve Late Lessons
'
,p.189.
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