Editor’s note: This is part two of a two-part op-ed published in the Coeur d’Alene Press. It appeared July 27th, 2003. (Part one, here.)
The new study chiefly justified its existence on two grounds: first, earlier studies had focused on fillets rather than “whole fish” consumption, which included bone and other fish body parts, and second, previous studies had not examined the fish consumption risks associated with a so-called “subsistence lifestyle” — that is, something approximating the aboriginal lifestyle of the tribe.
The desirability of such a study — indeed, the identification of the gap that such a study would fill — can be found all the way back in the text of the Human Health Risk Assessment (HHRA) for the Coeur d’Alene Basin, published (as noted above) in June, 2001.
But was Tribal fish consumption so crucial an aspect of the Tribe’s public health wellbeing as to merit this sort of additional study?
Are whole-fish consumption and aboriginal or modern “subsistence lifestyle” so prevalent among the Coeur d’Alene Tribe as to constitute significant realities in assessing their environmental health risks?
The singularly astounding fact of the matter, freely admitted in EPA’s documentation, is that “subsistence lifestyles” are not currently practiced by the Tribe.
To quote the HHRA’s Executive Summary:
The subsistence scenario pertains to children and adults engaged in traditional (aboriginal) or modern subsistence lifestyles in the floodplain of the lower Coeur d’Alene River. These are future scenarios, as subsistence lifestyles are not known to be currently practiced in the floodplain.
Why — in this historical moment of a federal budget deficit of over $500B and a vanishing Superfund balance — would EPA justify a study in terms of the risks of a lifestyle that is not currently in practice?
Why would EPA address a putative risk that exists in a virtual reality when, according to that same agency, there are credible non-virtual (or real) environmental and human health problems around the nation that are calling for funds?
Indeed, where did the call for the study of this virtual “subsistence existence” focus come from and why did EPA respond positively to that call?
According to the HHRA, it was the Tribe that called for this focus. To quote: “…Coeur d’Alene Tribal authorities…requested that two specific tribal [contamination] exposure scenarios be investigated, developed, and utilized within the Coeur d’Alene Basin…Human Health Risk Assessment….” These two scenarios were (1) the traditional Tribal subsistence lifestyle and (2) the modern subsistence lifestyle — neither lifestyle, to say again, is presently practiced.
The general results of the EPA’s “subsistence lifestyle” human health assessment was that subsistence practices were riven with significant contamination risks. So high were overall exposures that EPA’s computer simulation model’s assumptions could not be fitted to the tribal situation.
What, then, were the contamination risks and blood lead circumstances of the Tribe’s actual living arrangements and practices?
The HHRA falls eerily silent on this issue.
Why would EPA agree to study a virtual reality for the Tribe, focusing its empirical attentions on the seemingly tangential question of fish-consumption risk, when the obvious public health question to be answered — the obvious scientific gap to be filled — was what is the current blood lead status of the children in tribal residence?
To answer that question we must enter the world of EPA’s politics of myth. EPA’s actions appear to accord the Tribe a right to its aboriginal circumstances and lifestyle. That right, in turn, may be parlayed into a would-be obligation on the U.S.A. to create such circumstances or at least quantify the environmental deficit between present and a presumed idyllic past.
Never mind about whether anyone truly wishes to return to such a lifestyle, inside the Tribe or out. Never mind what the life expectancy was for Tribal members in pre-European contact eras.
The myth guiding EPA’s fish study is sometimes called the “naturalistic fallacy.”
Even fallacies, however, can provide symbolic and political leverage.
EPA may have turned its back on the current health circumstances of Tribal children, but its embracing of the Tribe’s virtual reality, as requested, creates manifold ways in which both EPA and the Tribe can milk trumped up environmental issues for all they are worth while at the same time imposing no inconvenience on tribal households or (dare we say it!) lifestyles.
— SNRC Science Committee