Three easily missed points on risks with respect to failure scenarios

  1. When defining risk of failure as the product of the probability of failure (Pf) times the consequences of failure (Cf), Pf and Cf are NOT independent of each other, as conventional risk analysis would have it.

a. Both are connected indirectly by the “intervening variable” of their shared failure scenario. It’s Pf and Cf with-respect-to the same failure scenario.

b. Further, the more granular the failure scenario, the more likely that Pfs and Cfs are directly interconnected. In the case of interinfrastructural cascades, one consequences of infrastructure1 failing (Cf1) may be to increase infrastructure2’s probability of failure (Pf2).

  1. Less rather than more granularity in the failure scenario might account for fewer criteria with respect to what qualifies as “effectiveness” in normal operations under conditions of high turbulence.

a. We have argued, for instance, that an explosion at a gasline section in a utility’s natural gas transmission system has to be analyzed in terms of its consequences within the system and inter-system levels as well. (The same could be said for fires induced by a utility’s electricity transmission system.)

i. It may be that the natural gas system operated reliably at the systemwide level, where the infrastructures that depended on natural gas provision also operated reliably during the explosion/fire.

ii. The negative consequences of the explosion are, in other words, offset by the positive consequences of maintaining systemwide reliability and intersystem dependencies.

b. The point here is that a failure scenario exclusively focused at the site-level within a system can miss scenarios (and related criteria) for maintaining normal operations at the systemwide and intersystem levels under disturbance conditions.

  1. Identifying risk(s) in the absence of first defining the operational system and the reliability standard(s) being managed to ends up with having no stopping rule to the possible failure scenarios and types of risks/uncertainties that matter.

a. Accordingly, all manner of things end up posing risks and uncertainties, e.g.

…different assets; multiple lines of business; with respect to system capacity, controls and marketing factors; in terms of the risks’ time-dependence versus independence; in terms of the risks associated with emergency work as distinct from that planned; investment risks versus operational ones; risks with respect not only to system safety and reliability, but also organizationally in terms of financial risk and regulatorily in terms of risks of non-compliance….ad infinitum

b. This lack of a stopping rule for failure scenarios to be worried about represents a hazard or is its own failure scenario, when it discourages (further) thinking through and acting on failure scenarios about which more is known and can be done.

The next Constitutional Convention (longer read)


Whenever I argue for a new Constitutional Convention and the break-up of the United States, I’m met with disbelief or condescension. All manner of insurmountable legal difficulties are pointed to. More express the dread that quarantines any real discussion: To talk about breaking up the country opens the Pandora Box of horrible knowns and the horribly unknown; we already tried that and look how that ended, the US Civil War; how could a professional, such as myself, even think this….

My entry point here centers around an exchange of letters between critic, Edmund Wilson, and novelist, John Dos Passos, during the Great Depression in the first half of the 1930s. Their interchange focused on the need for radical structural change in the US government and the Constitution. The picture I recast with this interchange from the Republic of Letters is the entrenched institution of the US constitution and these fifty states.

One of Edmund Wilson’s biographers calls the Wilson/Dos Passos correspondence “in its scope and dramatic interest second in American letters only to that of Jefferson and John Adams”. High praise indeed. Their letters are my squeegee to blur the persisting resistance to redescribing our government in any other fundamental way.

It is true this entry’s proposal for a new Constitutional Convention fails to consult the best minds of our time—those experts in constitutional law, economics, and political science. The wider truth is that we are in today’s political and economic straits because other minds, like Wilson and Dos Passos, were ignored in considering the case for new constitutional arrangements and the country’s break-up.

The start

The correspondence was provoked by Edmund Wilson’s 1931 Appeal to Progressives in the New Republic [NR], parts of which read:

Not only are the people in a capitalist society very often completely ignorant as to what their incomes come from; it is actually sometimes impossible or very difficult for them to find this out. And as long as a fair proportion of the bankers, the manufacturers, the middle men, the merchants and the workers whom their capital and machines keep busy are able to make a little more money than before, no matter how unscrupulously or short-sightedly, we are able, as a nation, to maintain our belief in our prosperity and even in our happiness….

[T]he manufacturer raises the workers’ wages only in order to create a demand for the gadgets which for better or worse he happens to have an interest in selling them, while agriculture goes hang, and science and art are left to be exploited by commercial laboratories…or to be fed in a haphazard way by a dole from the fortunes of rich men who have been conscience-stricken or simply overpowered at finding themselves at the end of their careers with enough money on their hands to buy out an old-fashioned empire….

Is it not obvious…that a government like our present one…is incapable of acting in good faith in even the simple matter of preserving the water power which is supposed be operated for the general benefit from being exploited by private profiteers? Our society has finally produced in its specialized professional politicians one of the most useless and obnoxious groups which has perhaps ever disgraced human history—a group that seems unique among governing classes in having managed to be corrupt, uncultivated and incompetent all at once….

Outdated? Hardly, when the bankers have metastasized into global finance, when our public utilities have been sold off to corporate risk-takers, and when the best news we have is that the rich like Bill Gates and Warren Buffett, wearying of empire, try to make good in the happy-talk of philanthropy what we once demanded and expected of government.

Edmund Wilson’s proposal? “It may be that the whole money-making and -spending psychology has definitely played itself out, and that the Americans would be willing, for the first time now, to put their traditional idealism and their genius for organization behind a radical social experiment.”

Whoa! you say: We’ve tried those Big Experiments! What more do we need than the intervening decades to convince us that the more radical the social experiment, the deadlier the bolt-hole utopia realized?

Wilson’s point still holds: “[W]ith the kind of administrations that the country has lately been getting, do not all our progressive proposals, however reasonable or modest, seem utopian?” So too Slavoj Žižek more recently: “We all silently accept global capitalism is here to stay. On the other hand, we are obsessed with cosmic catastrophes: the whole life on earth disintegrating, because of some virus, because of an asteroid hitting the earth, and so on. So the paradox is, that it’s much easier to imagine the end of all life on earth than a much more modest radical change in capitalism.”

Yet I believe it’s easier to dismiss a huge social experiment than it is to ignore the huger laboratory of modern life created for ourselves. (If utopias fail and if utopia and failure go together, when then does recovery from failed utopianism end and a new normal begin? Answer: There is no normal, when this very big laboratory can’t tell the difference between the experiment and recovery.)

But what then to do in today’s laboratory? Stay with Edmund Wilson and his then-friend, John Dos Passos, and their interchange over the NR manifesto and its follow-on. Dos Passos’s response to the publications, his increasing disillusionment with the machinations of left politics in the early 1930s, and the disagreements between Dos Passos and Wilson help identify a direction ahead for us.

From the Republic of Letters

“Just read your battlecry,” Dos Passos writes a few weeks after Wilson’s 1931 piece appears,

Of course all the [New Republic] can do is stir things up and try to smoke out a few honest men who do know something about industrial life as she is lived…If you can keep up a series like this you really will have started something—though I’m beginning to think that every publication ought to be required by law to print at the bottom of each page:


. . . .[T]he trouble with all our political economic writing and the reason maybe why it doesnt interest the ordinary guy who hasn’t joined the fraternity of word-addicts is that it is made up right in the office and springs from neither experience nor observation…

True enough, and Wilson eventually circulates a more urgent manifesto. “The present crisis of the world—and specifically the United States—is something more than a mere crisis of politics or economics; and it will not pass with the depression. It is crisis of human culture. What faces us today is the imperative need for new social forms, new values, a new human order.”

What is needed, Wilson feels, has moved beyond experiment to revolution. “Sure I’ll subscribe to it,” Dos Passos writes Wilson in reply to the new battle cry,

—but I don’t think it’ll cause any bankers to jump out of fiftieth story windows—what are you going to do with it?—post it up on billboards? it might go well on toilet paper like [ laxative] advertizing—or is it going to be laid on [President] Hoover’s breakfast table?….Where is it going to be used—?

Wilson ends up forwarding material to Dos Passos from another periodical, New Masses, and Dos Passos writes back in March 1934,

I think it’s very important not to add to this mass of inept rubbish on this subject—what is happening is that the whole Marxian radical movement is in a moment of intense disintegration—all people like us, who have no taste for political leadership or chewing the rag, can do, is to sit on the sidelines and try to put a word in now and then for the underdog or for the cooperative commonwealth or whatever….

The only alternative is passionate unmarxian revival of AngloSaxon democracy or an industrial crisis helped by a collapse in the director’s offices—That would be different from nazi socialism only in this way: that it would be a reaction towards old time Fourth of July democracy….How you can coordinate Fourth of July democracy with the present industrial-financial setup I dont see.

Late 1934, Dos Passos writes to Wilson about recent events in the Soviet Union, including the murder of Stalin’s intelligence chief,

This business about Kirov looks very very bad to me. In fact it has completely destroyed my benefit-of-the-doubt attitude towards the Stalinists—It seems to be another convolution of the self-destructive tendency that began with the Trotski-Stalin row. From now on events in Russian have no more interest—except as a terrible example—for world socialism—if you take socialism to mean the educative or constructive tendency rather than politics. The thing has gone into its Napoleonic stage and the progressive tendencies in the Soviet Government have definitely gone under before the self-protective tendencies….Meanwhile I think we should be very careful not to damage any latent spores of democracy that there still may be in the local American soil.

These remarks provoke Wilson to respond in early January 1935:

…I don’t think you ought to say, as you do, that a country which is still trying to put socialism into practice has ceased to be politically interesting…One doesn’t want to give aid and comfort to people who have hopped on the shootings in Russia as a means of discrediting socialism. Aside from this, you are right, of course, in saying that Americans who are in favor of socialism oughtn’t to try to import the methods of the Russians….

Dos Passos fires back,

[N]o government is in good shape that has to keep on massacring its people. Suppose, when that curious little [Italian] Zangara took a potshot a Franklin D. [Roosevelt], the U.S. Secret Service had massacred a hundred miscellaneous people, some because they were [Italians], others because they were anarchists and others because they had stomach trouble, what would all us reds be saying…What’s the use of losing your “chains” if you get a firing squad instead…Some entirely new attack on the problem of human freedom under monopolized industry has to be worked out—if the coming period of wars and dictatorships give anybody a chance to work anything out….

About Russia I should have said not politically useful rather than politically interesting….By Anglo Saxon Institutions I mean the almost obliterated traditions of trial by jury common law etc—they don’t count for much all the time but they do constitute a habit more or less implanted in Western Europeans outside of Russians….

Intellectual theories and hypotheses dont have to be a success, but political parties do—and I cant see any reason for giving the impression of trying to induce others to engage in forlorn hopes one wouldn’t go in for oneself.

“Don’t agitate me, comrade, I’m with you,” Wilson countered at the end of that January,

Surely it’s entirely unnecessary to worry about the possibility of a Stalin regime in America. I can’t imagine an American Stalin. You talk as if there were a real choice between Henry Ford on the one hand and [American Communists] on the other; but who outside the Communists themselves has ever seriously entertained the idea that these individuals would every lead a national movement?

“But” responds Dos Passos in February 1935,

it’s not the possibility of Stalinism in the U.S. that’s worrying me, it’s the fact that the Stalinist [Communist Party] seems doomed to fail and to bring down with it all the humanitarian tendencies I personally believe in—all the while acting as a mould on which its obverse the fascist mentality is made—and this recent massacre is certainly a sign of Stalinism’s weakness and not of its strength. None of that has anything to do with Marx’s work—but it certainly does influence one’s attitude towards a given political party. I’ve felt all along that the Communists were valuable as agitators as the abolitionist were before the Civil War—but now I ‘m not so happy about it.

Dos Passos then shifts his letter to a point Wilson had made to the effect that Marx belonged to a group of romantics that “came out of a world (before 1848) that was less sick, had much more spirit.” “By the way,” Dos Passos continues,

I don’t agree with you that a hundred years ago was a better time than now—they had a great advantage that everything was technically less cluttered and simpler—but dont you think perhaps in every time the landscape seems somewhat obstructed by human lice for those who view it? We have more information to go on, more technical ability to carry ideas out and ought to produce a whale of a lot of stuff—if I was a European I wouldn’t think so, but here we still have a margin to operate on—

Later that February Wilson writes Dos Passos another letter, the parting shot of which is its own “By the way,”

it is being rumored that you are “rubbing your belly” and saying that “the good old Republican party is good enough for you.” Maybe you ought to make a statement of your present position.

…which Dos Passos does. The month after, he writes Wilson,

I finally consented, against my better judgement, to put my name down on the [leftist] Writers Congress roster. I’m going to try to write them a little preachment about liberty of conscience or freedom of inwit or something of the sort that I hope will queer me with the world savers so thoroughly that they’ll leave me alone for a while. I frankly cant see anything in this middleclass communism of the literati but a racket….People haven’t any right to make a living out of politics—It’s selling stock in a corpse-factory.

“It’s selling stock in a corpse-factory.” “Some entirely new attack on the problem of human freedom under monopolized industry has to be worked out.” “Intellectual theories and hypotheses dont have to be a success, but political parties do.” “How you can coordinate Fourth of July democracy with the present industrial-financial setup I dont see.” That said, at least here in the US, according to Dos Passos, “we still have margin to operate on”.

What margin do we have today?

My proposal

In reply, start with the margin that the framers of the US Constitution saw fit to endorse in Article 5—a new constitutional convention. Oh no, no that won’t work, you say. How would most of our state legislatures or Congressmembers ever agree to hold a Constitutional Convention?

Answer: We hold it for them. We don’t wait. We start our own constitutional convention.

The idea here is this: We have 465 congressional districts, and 465 delegates to a Peoples’ Constitutional Convention sounds about right. Anyone on the voter rolls or adult able to show district residency would be eligible to vote and any voter from the district could run as a convention delegate. Party affiliation or endorsement would, of course, not be required. The candidate with the greatest vote plurality would be the district’s delegate. The cost of this nationwide election and delegate process would be, say, US$1-2 per person, or some $600 million, with another $50 million to hold the actual convention. The US government won’t finance this, and corporate funding would for obvious reasons be ruled out. One can imagine a consortium of individuals, foundations and overseas governments willing to defray what we can’t pay ourselves. (To put these numbers in some kind of perspective, Forbes estimated in 2017 that the net worth of author and large charity giver, J.K. Rowling, was roughly $650 million.)

The charge of the Peoples’ Constitutional Convention: To redraft the US Constitution through a series of amendments.

What a waste of time and money, you interject, since the real government—the states and feds—would just ignore the work of any Peoples’ Constitutional Convention.

Let them. Let them say the peoples’ mandate is illegitimate. Let them ignore a convention that represents no government, no court, no army, and none of the techno-managerial elites, just those elected to come together to hold our government, our courts, our military, and our techno-managerial elites to account. Let them ignore the Peoples’ Constitutional Convention and if they do, we’ll hold a different-premised one, and if that also does not work, we’ll go global and elect a World Parliament and then let them ignore that too. (As some readers may have realized I am adapting and paraphrasing George Monbiot’s proposal in The Age of Consent.)

But Americans could never, never, never support something as utopian—so Fourth of July democracy—as that!

Which takes us back to Edmund Wilson. Late in his life, he published a slim volume, The Cold War and The Income Tax. Pursued by the US Internal Revenue Service for non-payment of taxes and appalled at what his federal tax dollars were going to once paid—namely, the interdigitated grip of war and commerce—Wilson only could muster mordant wit in a way that the early 1930s’ Dos Passos would have appreciated:

I have always thought myself patriotic and have been in the habit in the past of favorably contrasting the United States with Europe and the Soviet Union; but our country has become today a huge blundering power controlled more and more by bureaucracies whose rule is making it more and more difficult to carry on the tradition of American individualism; and since I can accept neither this power unit’s aims nor the methods it employs to finance them, I have finally come to feel that this country, whether or not I continue to live in it, is no longer any place for me….

How to get rid of this huge growth, which is no longer a private organization, like one of Theodore Roosevelt’s old trust that could be busted, that is not even a thriving corporation protected by a business administration but an excrescence of government itself which officially drains our resources and which stupidly and insolently threatens our lives?…But now that things have gone so far, is there any chance, short of catastrophe, of dismembering and reassembling this image and constructing a nobler one that answers better to what we pretend to?

Wilson was right, as was Dos Passos before him, and their questions still hold. It’s long past time for 4th of July democracy to get constitutional. But instead of stopping here, push our thought experiment further, and assume the Peoples’ Constitutional Convention, its delegates having met, resolves that the country should break up.

The break-up

Just hold on buddy! Stop right there. Break up the country? No, no, and again no: absolutely not. After all, our current Constitution is a living document. . .


I do not see how anyone can pretend that the Constitution we now have is a living organism, able to evolve into the reliability mandates we demand of it. “You would have to be an idiot to believe that,” said Justice Scalia, who to my mind was right on this point. When it comes to the legal document that I can vote for with my feet, I want privacy rights guaranteed constitutionally and, puh-leese, none of that bald canard about corporations being fictive, immortal individuals.

Yes, of course, we all must avoid a replay of the mass migration and slaughter that followed the 1947 partition of India and Pakistan. As a sign of willingness to compromise, I for one am quite willing to let the wee boys keep beltway Reaganland and its airport; if they want Bozo the Prez as their own, let them; I really don’t care whether the schismatics call another breakaway, Prophetland or Profitland. As for Mexifornia, it’s ok by me. If any one of new entities wants to keep parallel wording of the present Constitution, so be it.

Then what? “It is hard to imagine [this] happening without a certain amount of civil war,” Edmund Wilson admitted, and the last time we tried that…well, need we say more?

Yes we do need to say more, and now is the time to say it. Now as then, the priority is to fund and run any new government with all ingenuity available, and not just in drafting new policies but also in doing things differently.

If our Civil War over southern separatism is a guide to the coming break-up, most state constitutions will remain in place as governing documents, while any interstate confederation would most probably be modeled on parts of the current US Constitution—though with the significant changes. Constitution-making in the Confederacy witnessed not just further entrenchment of unconscionable chattel slavery, but also the first Department of Justice, a national citizenship requirement for voting, no functioning supreme court, a six-year term limit for president, civil service reform, strictures against protective tariffs, a district court structure, and provisions for a presidential item veto, executive budget, and no recess appointments. How else are we to get an isomorphic version of this range of changes without breaking up the country?

(And those appalled by any appeal to the Confederacy might want to remember that four states—Vermont, Texas, California and Hawaii—opted to give up their sovereignty to join the Union–so why is the reverse out of the question?)

Be that as it may, when the-now US breaks up, a cadre of professionals will be needed who keep the government services operating under the new conditions. The immediate decline in security and economic growth that comes with the break-up means priority would have to be to keeping the control rooms of our critical infrastructures in hospitals, energy, water, telecommunications, transportation, and public safety operating as reliably as possible. These systems frequently cross current state borders, and the challenge will be to continue inter-regional collaboration for their operation until alternatives—if needed—are devised.

I can think of no more important a task than that the delegates at the Peoples’ Constitution Convention grapple with and address the logistics involved and ingenuity required in keeping critical services provided in a reliable fashion, doubtless as messy as it will be, as the nation undergoes the Great Scission into differing constitutional arrangements. Even today’s reliability professionals like those needed when the US breaks up are presently imagining the unimaginable, thinking the unthinkable, and balancing imponderables all over the place and in real time.

Yes, there is no room for complacency here. But the next constitutional convention everywhere an unthinkably bad mess? Everywhere then the drip-drip-drip of calamities-on-tap? This unimaginably worst mess is just another carking conceit of decline-and-fall (decline-and-stall).

Principal sources:

The letters are in: Edmund Wilson (1977), Letters on Literature and Politics, 1912-1972, Farrar, Straus and Giroux, New York, NY and John Dos Passos (1973) The Fourteenth Chronicle: Letters and Diaries of John Dos Passos, Gambit, Inc., Boston, MA. I’ve followed their spelling and grammar throughout, while editing in one case still-offensive ethnic expletives.

Four other key sources are: (1) L. Dabney (2005), Edmund Wilson: A Life in Literature, Farrar, Straus and Giroux, New York, NY; (2) G. Monbiot (2003), The Age of Consent, Flamingo, London: Chapter 4; (3) E. Wilson (1963), The Cold War and the Income Tax: A Protest, Farrar, Straus and Company, New York, NY; and J. Israel (2017), The Expanding Blaze: How the American Revolution Ignited the World, 1775-1848, Princeton University Press: Princeton and Oxford, Chapter 3.

My Confederacy cites are from: (1) W.B. Yearns (1960), The Confederate Congress, University of Georgia Press: Athens, GA; R. Bensel (1990), Yankee Leviathan: The Origins of Central State Authority in America, 1859-1877. Cambridge University Press: Cambridge, UK: Chapter 3; P. Van Riper and H. Scheiber (1959), “The Confederate Civil Service,” The Journal of Southern History, 25(4): 448-470; C.R. Lee (1963), The Confederate Constitutions, Greenwood Press Publishers: Westport, CN; and E. Thomas (1979), The Confederate Nation: 1861-1865, Harper & Row: New York, NY.


–To anyone such as myself, a product of the Sixties, it’s clear that the belief in and practices of revolution have dropped off the so-called change agenda in the US.

One under-recognized consequence has been the occlusion of revolt as more than reform but less than revolution. More, revolt—if you prefer, “tumult”—is taking place all over the world, in case you didn’t notice it.

But rather than scripting better what has been happening to the beliefs in and practices for revolt, what’s been going on? Ironists, catastrophists, and the post-apocalyptics battle among themselves in putting the right corpse to rest.

What to do instead when it comes to really-existing scenarios of revolt and tumult?

–I suggest that it’s better to ask where to start any such scenario, namely: before or after the peak has been reached? Let me explain.

For Gotthold Ephraim Lessing, 18th century German Enlightener, the point is not for the sculptor or painter to portray a crisis at its climax, when visualizing a single moment. Better to choose a moment before or after the apex of destruction, so as to allow the viewers’ imaginations freer reign over what is to come. That way, Lessing argues, the narrative continues in an arc of further reflection that is not cut short by any climax’s overpowering intensity:

since the works of both the painter and the sculptor are created not merely to be given a glance but to be contemplated. . .it is evident that the single moment and the point of view from which the whole scene is presented cannot be chosen with too great a regard for its effect. But only that which allows the imagination free play (freies Spiel) is effective. The more we see, the more we must be able to imagine. And the more we add in our imagination, the more must think we see. In the full trajectory of an effect, no point is less suitable for this than its climax. There is nothing beyond this, and to present to the eye what is most extreme is to bind the wings of fancy and constrain it, since it cannot. . .shun[ ] the visible fullness already presented as a limit beyond which it cannot go.

Rather, the moment chosen should be pregnant—fruitful, suggestive—of possibilities that are not foreclosed because imagination has been arrested by catastrophizing the worse. Instead of picturing Ajax at the height of his rage and slaughter, better he be depicted afterwards in the full realization of what he has done and in the despair leading him to what must come next.

–One problem with today’s dystopian scenarios is the preoccupation with or fixation on a visualized climax. Obviously, the worst can vary for the crisis scenario—post-apocalypse can be pictured as even deadlier. But the point holds: In today’s scenarios, the worst is imagined and imagination stalls there, like shining deer at night, with the enormity of it all.

The truth of the matter is that before or after the climax, imagination and thought are still at work and fully so. Before in the sense of thinking or imagining about the roads not taken; after in terms of the what-ifs ahead. Indeed today’s unrelieved stream of crisis scenarios proves imaginations’ inability to let a prophesied climax do all the talking.

But where does this leave us?

Empirically, it’s far better to study revolt and tumult before or after they happen than it is to be in the grip of their climaxes. For all we know, the Occupy Movement, Yellow Vests Movement, Hong Kong protests, the Extinction Rebellion and more are the apex of their respective revolts. To push belief and practice further, the entire point of revolt may be revolts. Any disappointment that one or more have not (yet) culminated into revolution or other “far-reaching substantive change” is but one scenario—which on reflection may not be the most fruitful, suggestive moment to focus on anyway, let alone be overawed by.

Principal source.

Gaiger, J. (2017). Transparency and imaginative engagement: Material as medium in Lessing’s Laocoon. In: A. Lifschitz and M. Squire (eds) (2017). Rethinking Lessing’s Laocoon: Antiquity, Enlightenment, and the ‘Limits’ of Painting and Poetry, Oxford University Press: Oxford, UK: 279 – 305. Other essays in this wonderful volume also discuss Lessing’s notion of “the pregnant moment.”


And though one says that one is part of everything,

There is a conflict, there is a resistance involved;
And being part is an exertion that declines:
One feels the life of that which gives life as it is.

Wallace Stevens, “The Course of a Particular”

If there were ever a term in need of greater differentiation, granularity and detail, it is “interconnected” (as in interconnected critical infrastructures).

–Our research on a Vessel Traffic Service (VTS) of the US Coast Guard (USCG) found at least five major kinds of “interconnected” at work having sharp differences in the VTS’s real-time operations:

  • Interoperability: Like the textbook interoperable energy utility (where electricity is crucial for the natural gas operations and vice versa), the VTS manages both vessel traffic and the regulated waterways that the vessels use (where managing the water ways affects management of the vessels and vice versa);
  • Shared control variables: Water flows are a major control variable not just for VTS navigation purposes, but also for other infrastructures (most notably large water supplies and hydropower systems). This means that unexpected changes in how one infrastructure manages water flows can affect the management of the water flows by the other infrastructures (indeed, inter-infrastructural coordination around shared control variables was reported to us);
  • Combined cycle of infrastructure operations: The USCG has a range of missions and operations, two of which are the VTS and the SAR (Search and Rescue) units. VTS combines with SAR to represent stages of this infrastructure’s operational cycle—normal operations and disrupted operations (VTS) along with failure and recovery (SAR). Not only are normal operations of the VTS already inter-infrastructural (by virtue of the shared control variables), but also the USCG’s Command and Control mission, including that for SAR, has an incident command facility and function for inter-infrastructural coordination during system failure and recovery;
  • Variety of real-time configurations of interconnectivity: The VTS manages by virtue of resorting to a variety of interconnections with the vessels concerned. When VTS management of a common pool resource (the waterways) on behalf of inter-related users is disrupted or fails (e.g., because of defect in VTS communications), the interconnection configuration defaults over to the reciprocal one of vessel-to-vessel communication; and
  • Inter-organizational linkages: USCG operations, including a VTS, are not only linked with other infrastructures through reliance on the Global Positioning System (GPS), but the Coast Guard’s position within the Department of Homeland Security makes it strategically located with respect to focusing on GPS vulnerabilities and strengths when it comes to the nation’s cyber-infrastructure.

Further detailing can be sketched, but the point remains: Once differentiated interconnectivities are taken as the serious, really-existing starting point—”the life of that which gives life as it is”—we better understand how some major approaches to risk management of critical infrastructures can be so mis-specified and misleading.

–What could seem more reasonable than a focus on chokepoints when it comes to risk assessment and management at an interconnected critical infrastructure level? And the most obvious way to do that is by focusing the attention on where major infrastructures intersect or lie adjacent to each other on the ground, right? Wrong.

It’s wiser is to focus on how spatially adjacent or collocated structures and facilities are actually managed within their respective infrastructure systems. It is possible that a system’s chokepoint may be elsewhere than at any site of collocated facilities, and that the element collocated could be lost without its respective system flipping into failure. Just because elements from two or more infrastructures are spatially adjacent does not mean automatically mean those infrastructures have “to coordinate” unless, say, shared control variables are involved or interoperability challenged.

A huge category mistake is committed when conflating (1) the unfolding and interrelated consequences on life, property and markets of, say, a hazardous liquids pipeline explosion on adjacent populations and property and (2) the explosion’s consequences for the interconnected critical infrastructure system (ICIS) for those hazardous liquids, which includes not just these pipelines and associated refineries, but also just as significantly the electricity and water infrastructures that the former depends upon in real time.

Why does differentiating the two “systems” matter? To equate the relevant system definition with the spread and interaction of knock-on population-and-property consequences of failure (Cf) is to identify as a problem the lack of systemwide management of Cf (as if “systemwide” meant jurisdictional and administrative). Yet and even so, the ICIS is in fact manage in real time—and reliably so—by the control rooms of the respective infrastructures (which in turn are regulated systemwide by fewer regulators of record). To repeat, “coordination” can be taking place within the ICIS around shared control variables, albeit not (or to a lesser) extent in the “system” of interconnected Cf per se.

–Economists, engineers and system modelers with whom I’m familiar often conceptualize interconnected critical infrastructure systems along the lines that Garret Hardin did 50 years ago for what he called the Tragedy of the Commons: In our case, imagine an ICIS open to all manner of vulnerability and complex interconnectivity. Our research insists that too is precisely what you cannot assume empirically or conceptually. Rather, the starting point is that these systems are far more differentiated than they are alike when it comes to “interconnectivities.”

The market failure economists don’t talk about

Economists tell us there are four principal types of market failure: public goods, externalities, asymmetric information, and market power. They do not talk about the fifth type, the one where efficient markets actually cause market failure by destroying the infrastructure underlying and stabilizing markets and their allocative activities.

Consider here the 2010 flash crash of the U.S. stock market. Subsequent investigations found that market transactions happened so quickly and were so numerous under conditions of high-frequency trading and collocated servers that a point came when no liquidity was left to meet proffered transactions. Liquidity dried up and with it, price discovery. ‘‘Liquidity in a high-speed world is not a given: market design and market structure must ensure that liquidity provision arises continuously in a highly fragmented, highly interconnected trading environment,’’ as a report by the Commodity Futures Trading Commission (CFTC) put it for the crash. Here, efficiencies realized through high transaction speeds worked against a market infrastructure that would have operated reliably otherwise.

The economist counters by asserting, ‘‘Obviously the market was not efficient because the full costs of reliability were not internalized.’’ But my point remains: Market failure under standard normal conditions of efficiency say nothing about anything so fundamental as infrastructure reliability as foundational to economic efficiency.

The research challenge is to identify under what conditions does the fifth market failure arise empirically. Until that is done, the better part of wisdom—the better part of government regulation—would be to assume fully efficient markets are low-performance markets when the stabilizing market infrastructure underlying them is prone to this type of market failure. Put positively, highly reliable markets are productive and sufficiently efficient when the underlying market infrastructure is not prone to the destabilizing fifth type of market failure.

But what, then, is “prone”? Low-performing market infrastructure results from the vigorous pursuit of self-interest and efficiencies that hobble real-time market infrastructure operators in choosing strategies that ensure longer-term high reliability of the market infrastructure.

There is another way to put the point: High reliability management of critical infrastructures does not mean those infrastructures are to run at 100% full capacity. Quite the reverse. High reliability requires the respective infrastructures not work full throttle: Positive redundancy or fallback assets and options—what the economists’ mis-identified “excess capacity”—are needed in case of sudden loss of running assets and facilities, the loss of which would threaten infrastructure-wide reliability and, with it, price discovery. To accept that “every system is stretched to operate at its capacity” may well be the worst threat to an infrastructure and its economic contributions.

In this view, critical infrastructures are economically most reliably productive when full capacity is not the long-term operating goal. Where so, efficiency no longer serves as a benchmark for economic performance. Rather, we must expect the gap between actual capacity and full capacity in the economy to be greater under a high reliability standard, where the follow-on impacts for the allocation and distribution of services are investments in having a long term.

Ammons and regulation (longer read)

The proposition I write to support is: “When having less knowledge is key to knowing more.” I want to demonstrate how tomorrow we might get all manner of official regulations right—when today we rethink “regulation” as a category of knowledge. In arguing so, I appeal to the poetry of A.R. Ammons.

Ammons, a great American poet of the last half of the 20th century, was tenacious in returning again and again to a set of topics he felt he hadn’t gotten quite right. One of the subjects was how knowing less entails “knowing” more. It’s his analytic sensibility in persistent revisiting a topic from tangents affording different insight and nuance that I rely on as an optic to parse my own topic of government regulation.

Policy types typically fasten to knowledge as a Good Thing in the sense that, on net, more information is better in a world where information is power. Over an array of accounts—and his tenacity meant he wrote a great deal—Ammons insists that the less information I have, the better off I am—not all the time, but when so, then importantly so. (To be clear, he is not talking about “ignorance is bliss.”)

For those working in policy and management—and I include myself—how could “the less we know, the more we gain” be the case and what would that mean when it comes to the heavy machinery called official regulation? Is there something here about the value of foregrounding inexperience—having less “knowledge”—as a way of adding purchase to rethinking difficult issues, in this case, regulation?


Start by dispensing with popular meanings of “the less I know, the more I know.” It is easily reversed to “the more I know, the less I really know.” This is the conventional wisdom that “data and information” are not knowledge—in fact the opposite. I also do not pursue another sense of “the less I know, the more I know” that Ammons foregrounds from time to time: the hiving off what we thought we knew creates the stuff from which new knowledge is formed. It is my failing—not Ammons’s—that I cannot see how “from-ruins-and-waste-come-something-altogether-better” applies to the 70,000+ paged IRS code and other volumes of government regulations.

My focus instead is on a very difficult set of insights in some of his poems. Let’s jump into the hard part—Ammons’s poem, “Offset,” in its entirety:

Losing information he
rose gaining
till at total
loss gain was
extreme & invisible:
the eye
seeing nothing
lost its
(that is a mere motion)
fanned out
into failing swirls
slowed &
became continuum.
(TCP1, 418)

Please reread the poem once more.

Part of what Ammons seems to be saying is that by losing information—the bits and pieces that make up “you”—you gain by becoming whole and continuous. As it were, “loss gain” becomes one term. You cease to be separate, your bits and pieces slow down, fan out, spread into a vital one. We empty our minds so as to attend to what matters—emptying the eye to have the I. An obvious example others have noted: If obsessive thoughts, compulsive behaviors, and restraining inhibitions are, in their own ways, altogether absorbing forms of self-knowledge, then this is knowledge we need not to know in order to have more to know better.

How, though, is this different from ignorance is bliss or, less pejoratively, seeking to know only what you need to know? Part of Ammons’s answer appears to be getting to the point where you know enough to be naïve again, to be open to the wonder of it all, to give yourself up to the kind of attention that is, if you will, self-reabsorbing. To telegraph ahead, naïveté does not center around knowing and not-knowing for Ammons: There’s feeling and living, wishing and dreaming, desire and more, and such are different kinds of “knowing,” as if thinking feels and feeling thinks.

Naïveté here is the adult version of child-like, decidedly not the childish that gutters out early on. It is positive, because adult wonder and curiosity are the space for noticing and being alert to more—an orientation that gains from the loss of information. Compare this, however, to what is expected of government regulators: Whatever happens, they must not be uninformed or naïve—in a word, inexperienced—and when they are, shame on them.

The ways in which this wonder and inexperience do matter for regulation means keeping with Ammons longer. For him, staying uninformed and open to new experiences is the hard work of affirming study,

….my empty-headed

contemplation is still where the ideas of permanence
and transience fuse in a single body, ice, for example,
or a leaf: green pushes white up the slope: a maple
leaf gets the wobbles in a light wind and comes loose

half-ready: where what has always happened and what
has never happened before seem for an instant reconciled:
that takes up most of my time and keeps me uninformed:
(TCP1, 497-498)

Being empty-headed is part of knowing enough: having to know less so as to be ready for whatever the next experience you proved to have been half-ready for in hindsight. It’s as if Ammons is asking us to be smart enough to see it’s more than about a knowing doubt and a knowing certainty.

Living is the space for feeling, which is where “knowing,” writ large belongs: “how can I know I/am not/trying to know my way into feeling/as//feeling/tries to feel its way into knowing,” he asks in “Pray Without Ceasing” (TCP1, 779). This notion of a half-readiness open to new experience and the wonder awaiting is nicely caught in the ending lines of one of my favorites, “Cascadilla Falls”:

I do
not know where I am going
that I can live my life
by this single creek.
(TCP1, 426)

By the time you surge to those lines, there is so much feeling in that “Oh” you might miss how living takes place beyond not-knowing.” Or better, the line break of “do/not know” intimates that the doing of “not know” is a good part of living that life.


Regulation from this viewpoint is never a case of regulators starting with knowledge and assuming what matters for living resides elsewhere. Regulation isn’t about expunging naïveté as inexperience but—in ways not yet clear—cultivating it. What is clear is the starting point, however: Wonder is not dread; naïveté is not ignorance; and no-longer-knowing is not not-knowing, full-stop.

In this way, Ammons makes a frontal attack on what policy types hold very dear: the notion of usefulness. In his essay, “A poem is a walk,” Ammons defers to a paradox: “Only uselessness is empty enough for the presence of so many uses”. Only uselessness is a sufficiently capacious category to embrace all the uses that come and go with experience and ensuring space for more feeling and living.

What could better capture all the many uses as they shift to the wayside than uselessness, “an emptiness/that is plenitude” (TCP1, 503)? Less and less information, against this backdrop, empties us and thereby makes us—leaves us open—differently. It is, in Ammons’s wonderful turn of phrase, to be “emptied full” (TCP2, 4). To seek more and more knowledge and information and never waste what has already been gotten leads to in Ammons’s acid throwaway, “total comprehension is/a wipe-out” (TCP1, 659). It’s a wipe-out because this totality leaves no room for more. 

Where, then, does this leave us when it comes to “knowing” regulation better?


In answer, I ended up going back to Ammons’s “The Eternal City”—“After the explosion or cataclysm, that big/display that does its work but then fails/out with destructions, one is left with the//pieces. . .” (TCP1, 596)—lines that resonate with what I had read in one of Rainer Maria Rilke’s letters. He is writing about the sculpture studio of Auguste Rodin:

It is indescribable. Acres of fragments lie there, one beside the other. Nudes the size of my hand and no bigger, but only bits, scarcely one of them whole: often only a piece of arm, a piece of leg just as they go together, and the portion of the body which belongs to them. Here the torso of one figure with the head of another stuck onto it, with the arm of a third. . .as though an unspeakable storm, an unparalleled cataclysm had passed over this work. And yet the closer you look the deeper you feel that it would all be less complete if the separate bodies were complete. Each of these fragments is of such a peculiarly striking unit, so possible by itself, so little in need of completion, that you forget that they are only parts and often parts of different bodies which cling so passionately to one another.

I read the passage—at least one other translation captures the same sense—as suggesting that Rodin’s “cataclysm” incorporated fragments that were, in a sense that matters for our purpose, more complete as separate fragments. So too Ammons’s “cataclysm” in “The Eternal City” refers to pieces that are themselves whole—asynoptic, unassimilable, piece after piece. Another of Ammons’s lines, “all the way to a finished Fragment,” catches the sense I am after here (TCP1, 366).

By extension, we’d have to believe that official regulations ad seriatem, while appearing a growing shambles, are in fact more complete as the piece-work of individual regulations than they would be were they improvised into something new or part of, in policy-speak, a more integrated body of regulations for use over time.

How could this be?


One way ahead, Ammons implies, is to see how the waste of regulation isn’t decline-and-fall, but rather the rearguard action against such declension narratives: an argument for creating room for us to recast decline. Ammons directs our attention, for example, to waste-as-generosity in “The City Limits,”

. . . .when you consider
the abundance of such resource as illuminates the glow-blue

bodies and gold-skeined wings of flies swarming the dumped
guts of a natural slaughter or the coil of shit and in no
way winces from its storms of generosity; when you consider

that air or vacuum, snow or shale, squid or wolf, rose or lichen,
each is accepted into as much light as it will take, then
the heart moves roomier. . .
(TCP1, 498)

The “heart moves roomier” not because the pile is any less shite, but because it opens to being more—certainly more than that mortal coil of Hamlet. This is the hot mess of feeling and living expansively, of being somatically sprawled all over the place, now. Regulatory waste in this mode is a spectacularly, can’t-keep-our-eyes-off-it sight/site to behold, maverick and inciting at the same time.

The hot mess that you can’t keep your eyes—our inner and physical I’s—off and the incitements it offers take us to Ammons’s late, long poem, Garbage (TCP2, 220-306). (Famously, Garbage, for which Ammons won the 1993 National Book Award for Poetry, was inspired by his passing an immense heap of garbage alongside the Florida Interstate.) Mountains and mountains of garbage are “monstrous”; in fact

… a monstrous surrounding of
gathering—the putrid, the castoff, the used,

the mucked up—all arriving for final assessment,
for the toting up in tonnage, the separations

of wet and dry, returnable, and gone for good:
(TCP2, 234)

For Ammons “gone for good” is decidedly ambiguous, in the sense of begging the question about just to what good has garbage gone for. An answer—and Ammons resists being pinned down to any one answer—lies in the garbage that human beings themselves are:

we’re trash, plenty wondrous: should I want

to say in what the wonder consists: it is a tiny
wriggle of light in the mind that says, “go on”:
(TCP2, 245)

Nothing integrated about this! For: “Go on” to what in a world where garbage and waste conjure a meaninglessness of things and of our own existence, as we too are trash? In the case of Ammons, the garbage we are and the meaninglessness that poses, like capacious uselessness, offer up the wonder of being more—of meaning possibly—once we leave space for such feelings and experience:

we should be pretty happy with the possibilities

and limits we can play through emergences free
of complexes of the Big Meaning, but is there

really any meaninglessness, isn’t meaninglessness
a funny category, meaninglessness missing

meaning, vacancy still empty, not any sort of
disordering, or miscasting or fraudulence of

irrealities’s shows, just a place not meaning
…there is truly only meaning,
only meaning, meanings, so many meanings,

meaninglessness becomes what to make of so many
(TCP2, 277)

That word, “becomes”—that insistence on meaning-less possibility as a “funny category”—is, we see by way of conclusion, core to having room to recast regulation.


Richard Howard, himself no mean commentator on Ammons’s poetry, points the way: “How often we need to be assured of what we know in the old ways of knowing—how seldom we can afford to venture beyond the pale into that chromatic fantasy where, as Rilke said (in 1908), ‘begins the revision of categories, where something past comes again, as though out of the future; something formerly accomplished as something to be completed’”.

The importance of this revising categories of thinking and living is captured in an interchange Ammons had with Zofia Burr. When pressed by Burr, he summed up: “I’m always feeling, whatever I’m saying, that I don’t really believe it, and that maybe in the next sentence I’ll get it right, but I never do”.

Imagine policymakers and regulators, when pressed, recognizing that not getting it right today places them at the start of tomorrow’s policymaking—not its end but its revision as “policymaking” and “regulation.” For that to happen, they’d have to understand just how funny-odd a category regulation is.

Ammons, if I understand him, is insisting that in the compulsion and not just desire to “get it right the next time around,” there at least be a next time (room) to make it—this revision of categories—better. Ensuring (risking) there is a next time is the way we keep open to—empty for—the feeling and living and participating that, in the process, push conventional notions of regulation to the periphery, changing their milieux, rendering regulation less and less meaningful and thus returning it as a concept and instrument to us re-freshed and re-wondered about; in short: recasted.

Again, how so? Let’s jump into Ammons’s deep-end one last time:

Yield to the tantalizing mechanism:
fall, trusting and centered as a
drive, falling into the poem:
line by line pile entailments on,
arrive willfully in the deepest

fix: then, the thing is done, turn
round in the mazy terror and
question, outsmart the mechanism:
find the glide over-reaching or
dismissing—halter it into

a going concern so the wing
muscles at the neck’s base work
urgency’s compression and
openness breaks out lofting
you beyond all binds and terminals.
(TCP1, 535)

(You may want to re-read the poem one more time. I return to that “deepest//fix” momentarily.)

Ammons commented on this poem, “The Swan Ritual”: “The invention of a poem frequently is how to find a way to resolve the complications that you’ve gotten yourself into. I have a little poem about this that says that the poem begins as life does, takes on complications as novels do, and at some point, stops. Something has to be invented before you can work your way out of it, and that’s what happens at the very center of a poem”.

Ammons touches on the major implication extended here: If rendering any regulation useless takes us closer to reinventing what “regulation” is, so too reinventing “regulation” can render an existing regulation useless. Regulating to reduce risk and inequality or improve economic growth and statecraft is that way we rethink these ends so to make those other means or ends no longer useful.

To rethink (revise, redescribe, rescript, recast, refashion, recalibrate) the categories of knowing and not-knowing is to resituate—make room for—the cognitive limits of “knowing” that matter. The eye is no longer fixed on where it had settled before, but with a new focal point in sight (this being today’s version of our wager on redemption). That, truly, is the fix we want to be in, “the deepest//fix.” It is where wonder renders dread incomplete, where knowledge is unlearned, where knowledgeable gives way to refreshened inexperience, and, in Ammons’s earlier astonishing lines, “where what has always happened and what/has never happened before seem for an instant reconciled”.

Principal sources:

Ammons, A.R. (1996). Set In Motion: Essays, Interviews, & Dialogues. Ed. Zofia Burr, The University of Michigan Press: Ann Arbor, MI.

—————— (2017). The Complete Poems of A.R. Ammons, Volume 1 1955 – 1977 and Volume 2 1978 – 2005. Edited by Robert M. West with an Introduction by Helen Vendler. W.W. Norton & Company: New York, NY. [The volumes are referred to in the blog entry as TCP1 and TCP2, respectively.]

Howard, R. (1980). Alone With America: Essays on the Art of Poetry in the United States Since 1950. Atheneum: New York, NY. Rilke, R.M. (1988). Selected Letters 1902-1926. Transl. R.F.C. Hull, Quartet Encounters, Quartet Books: London.

Rilke, R.M. (1988). Selected Letters 1902-1926. Transl. R.F.C. Hull, Quartet Encounters, Quartet Books: London.

A new standard for societal risk acceptance

–It is understood that “acceptable-risk” standards, based on past failure frequencies and commitments of “never again,” can be fleeting and ephemeral. Refinery explosions, stock market flash crashes, and massive identity theft lead to calls for government action. Something is done in response, but the sense of urgency and never-again is rarely sustained. There is always a fresh disaster or crisis scenario to reclaim public attention. Worse, the retrospective orientation to letting past (in)frequency set the standard has led to complacency and the very accident to be forestalled, as in: “Well, it hasn’t happened in the past, so what’s the problem…”

It’s worthwhile then to ask what can be offered by way of a prospective orientation—“we are no more reliable than the next failure ahead”—to identifying standards of acceptable/unacceptable societal risk. What does societal risk acceptance look like if instead of being based on (in)frequency of past events, it is grounded in the expectation that all manner of accidents lie in wait unless actively managed against?

I suggest the following thought experiment, the aim of which identifies a proxy for “acceptable societal risk.” To telegraph ahead, the proxy proposed is the aggregate curve of the major real-time control room risks of society’s critical infrastructures.

–Assume: that society has identified critical infrastructures indispensable to its survival; that the key infrastructures have central control rooms for operating the entire system; and that the respective control room operators have a set of chief risks that they must manage in order to maintain systemwide reliability (which includes safety), at least in real time. While huge assumptions, their virtue is trying to operationalize the unworldly premise of current approaches—most notably ALARP (“as low as reasonably practicable”)—that somehow “society sets acceptable and unacceptable risks,” leaving the somehow utterly open.

Under the precluded-event standard of reliability (i.e., the event to be prevented must never happen, given the society-wide dread associated with system failure), we found that control operators need to be able to maneuver across four performance modes so as to maintain even normal operations. Each performance mode has its own chief risk, we found in our interviews with operators.

The four modes range from anticipatory exploration of options (just in case) when operations are routine and many management strategies and options are available, to a real-time improvisation of options and strategies (just in time) when task conditions are more volatile. Reliability professionals may have to operate temporarily in a high-risk mode (just for now) when system volatility is high and options few. They may also be able, in emergencies when options have dwindled, to impose onto their users a single emergency scenario (just this way) in order to stabilize the situation.

The chief risk in just-in-case performance is that professionals are not paying attention and become complacent—reliability professionals have let their guard down and ceased to be vigilant, e.g., to sudden changes in system volatility (think of system volatility as the degree to which the task environment is unpredictable and/or uncontrollable). As for just-in-time performance, the risk is misjudgment by the operators with so many balls in the air to think about at one time. The great risk in just-this-way performance is that not everyone who must comply will comply with one-off measures to reduce system volatility.

Last, just-for-now performance is the most unstable performance mode of the four and the one managers want most to avoid or exit as soon as they can. Here the risk of “just keep doing that right now!” is tunneling into a course of action without escape alternatives. What you feel compelled to do now may well increase the risks in the next step or steps ahead (in effect, options and volatility are no longer independent dimensions).

–Step back now and further assume that estimates have been computed by control room operators in consultation with subject matter experts for the risks of complacency, misjudgment, non-compliance and closing off alternatives, within the infrastructure concerned. Such then is done for all the society’s key infrastructures with control rooms.

There is no reason to believe the estimates of any one of the four key risks are the same for the same performance mode across all infrastructures during their respective normal operations. Different precluded events standards are operationalized very differently in terms of the thresholds under which they are not to operate. Complacency or misjudgment could empirically be more a problem in some control rooms than others.

Assume the performance-mode risk estimates (or stratified/weighted sample of them) have been rank ordered, highest to lowest, for these infrastructures operating to a precluded-event standard by their respective control rooms. A plot of points is generated in the form of a downward sloping function. This function would be the revealed allocation of acceptable societal risks at the time of calculation for the critical infrastructure services of interest in their really-existing normal operations to preclude different dreadful events from happening with respect to vital societal services.

The downward sloping function would, by definition, be a prospectively oriented standard of acceptable risk for society’s (sampled) critical infrastructures operating to the precluded-event standard by their control rooms. It is prospective because the unit of analysis isn’t the risk of system failure—again, typically calculated retrospectively on the basis of “the past record”—but rather the current risks of real-time control operators failing in systemwide management, now and in their next steps ahead.

–Even though all this is difficult to operationalize—but less so than the traditional ALARP!—two implications are immediate.

First, because control rooms manage latent risks (uncertainties with respect to probabilities and consequences of system failure) as well as manifest risks (with known Pf and Cf), any such downward-sloping function will necessarily have a bandwidth around it. That bandwidth, however, is not one that can be chalked up to “differences in societal values and politics.” Rather the bandwidths reflect moreso the control room uncertainties (often technical and procedural, but related also to unstudied or unstudiable conditions).

It is true that some real-time uncertainties to be managed are linked directly to societal values and politics—think here of those new or revised compliance regulations that followed from the last disaster—have their greatest real-time impacts. Even then, the challenge is to show how the application at this time and for this case of any compliance procedure follows from said societal values. That is no easy task because analysis would also drive down to the case or event level and not just up to the policy or regulatory level where societal values are (or so it is said) easier to identify.

A related, second implication is noteworthy as well. The bandwidth around a societal risk acceptance function as defined above varies because not every critical infrastructure manages to a precluded-event standard. Other standards can be managed to. Even so, note how remote this acknowledgement is from any argument that societal values determine directly (or even primarily) the operative standards managed to.

An example will have to suffice. A primary reason why critical infrastructures manage to an avoided-events standard today—these events should be avoided, albeit they cannot always be in practice—is because their inter-infrastructural connectivity does not allow individual control rooms to preclude failures or disruptions in the other infrastructures upon which they depend or which depend on them. It is better to say that in these cases the shift from one (precluded-event) to another (avoided-event) reliability standard reveals societal preferences for interconnected critical infrastructures before it demonstrates any first-order derivation from more generalized or abstracted “societal values” per se.