IDEM Myths

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IDEM Myths

• July 27, 2005

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Myth 1

• We are the defenders of the Public health,
  environmental health and natural resources from
  the unnatural actions by humans. The ideal is
  the pre-human air, water and land quality. When
  science is in doubt, when the facts of the
  situation are in doubt, or when assumptions of
  future behavior is in doubt, give preference to
  protection. Cost to the regulated is no object
  for protection from potential threats.

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Myth 2

• The Reason we have laws and regulations is that
  the regulated are not to be trusted. The laws
  and regulations themselves were established under
  the heavy influence of the regulated and thus are
  themselves deficient and should be extended as
  appropriate in permits and compliance. Even with
  laws and regulations, most of the regulated will
  intentionally disobey unless monitored closely by
  government and penalized severely.

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Myth 3

• IDEM is a political agency. If most decisions
  can have political repercussions back to the
  lower staff who make the decision, the staff is
  inclined to postpone any decision as long as
  possible. By definition, political decisions
  involve specific winners and losers. For many
  such decisions the correctness depends on the
  future political opinion of individuals regarding
  their needs and preferences. Unless the staff is
  protected by upper management from political
  repercussions and has crystal-clear directions on
  how to make decisions, a culture of decision
  avoidance will predominate.

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Myth 4

• Customers are simply to be treated with
  politeness and by-the-book openness.
• This does not means that stakeholders are to be
  listened to with seriousness by appropriately
  knowledgeable professionals who hold appropriate
  authority for what is being discussed.

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Myth 5

• Scientific logic is unnecessary when addressing
  and communicating decisions. There is comfort in
  traditional practices without scientific
  underpinnings or personal intuition to assessing
  the relevant facts of a situation and appropriate
  steps. When this involves different people and
  different units of the agency, the absence of
  strong, consistent scientific logic results in
  unpredictability, uncertainty and delay at great
  cost to the stakeholders.

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Myth 6

• The Governor was elected with the strong support
  of the regulated community and wants more
  high-paying jobs to be a priority. To be
  consistent with the Governors direction, IDEM
  should go easy on the regulated during permit,
  compliance and enforcement as well as new
  rulemaking.