If someone has to tell you something is a joke, it isn’t. Similarly, if someone tells you something is “common sense,” you should be skeptical. They are doing what a military person might call “preparing the ground.” They want to plant the suggestion in your mind that you should think of what they’re about to tell you as common sense.
When I read the first sentence of a recent U.S. DOT press release, I immediately became skeptical. It read: “Responding to President Obama’s call for federal agencies to speed infrastructure development through more efficient environmental reviews, U.S. Transportation Secretary Ray LaHood and Federal Transit Administrator Peter Rogoff today announced they are proposing commonsense changes that would significantly cut red tape for certain transit projects under the National Environmental Policy Act (NEPA) and dramatically speed some projects towards completion.
Notice how they “sell the sizzle” of cutting red tape and speeding projects toward completion? Who could possibly argue with that?
“The president has asked us to find new ways to make our government work smarter on behalf of the American people by cutting waste and inefficiency wherever we find it,” said Secretary LaHood. “The changes we’re proposing will allow us to still carefully assess the impact of transit development on the environment, while reducing the time and energy needed to green-light good projects that clearly do not have a significant impact on the environment.”
Again, who could possibly argue with working smarter, cutting waste and inefficiency and green-lighting good projects?
The press release goes on to say more nice-sounding words about such things as helping to “provide transportation solutions to communities more quickly.”
Why am I going on about this? Because such wording sets off so many alarms in my head. I feel like someone is trying to manipulate me, and I get suspicious. I think you should get suspicious too.
I want to know what the U.S. DOT thinks of as common sense. I want to see the steak that’s doing all the sizzling. There is precious little steak in this press release.
Here’s the most substantive statement I can find: “The time-savings would be due, in part, to allowing certain types of transit projects that clearly do not have a significant impact on the local environment—such as projects to be built within an existing right-of-way where transit or other transportation already exists—to potentially undergo a less intensive NEPA evaluation, while still providing for a more thorough review of projects that do have the potential for significant environmental impacts. For qualified projects, less documentation would need to be submitted.”
Who decides what is a “qualified project”? How do they know what is a “qualified project” without doing the study?
I stumble over the phrase, “transit projects that clearly do not have a significant impact on the local environment.” OK, projects built within an existing transportation right-of-way seem OK at first glance. That’s only one example. How many projects are like that?
Here’s another good question the press release doesn’t address: How many projects will be affected by this streamlining?
How can they know whether the project will not have a significant environmental impact without doing the study? That sounds like a case of “begging the question” in the true sense of that phrase: assuming as a premise the conclusion they are trying to prove.
I wish I had the answers to these questions, but I don’t—yet.
But don’t take my word for it. I’m not an environmental policy expert. I encourage you to read the press release (http://www.dot.gov/affairs/2012/fta2012.html) for yourself and see what you think. Then keep an eye on what the DOT does and see whether their actions live up to their words. Then let me know what you see out there.