IDEM Myths July 27, 2005

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.

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.

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.

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.

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.

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 Governor’s direction, IDEM should go easy on the regulated during permit, compliance and enforcement as well as new rulemaking.