HOW MANY REASONS are there for not protecting the environment? And is there a handy list?

None of us environmentalists has actually seen such a piece of paper, as far as I know. But then, that doesn't prove much. For a checklist of anti-environmental arguments to be useful, it can't be visible. If it were, people might get the idea that all the various opponents of environmental protection were reading from the same script.

If it does exist, it's fair to assume that it's been a popular item. And it's not hard to guess that the contents look something like this:

TO: Client List -- CONFIDENTIAL

FROM: (illegible)

RE: How to Respond to Environmentalists

After many years in the business of environmental consulting, helping clients who have been under every imaginable kind of attack, we have decided to seek new stimulation (and even higher profits) in the field of investment banking. However, so as not to leave our valued clients in the lurch, we are providing the following checklist for your use in future controversies.

Short as this list may seem, it covers every type of situation in our experience. The argument can be tailored many different ways for different cases, of course, but it will always be a version of one of these 10.

1. We need more study.

This is the all-time granddaddy of reasons for not taking action now. The acid-rain argument is just its latest incarnation. Who can object to more knowledge? It also drives the environmentalists crazy, since they're the ones who got the "more study" idea written into the law in the first place, in the form of Environmental Impact Statements. Even Rachel Carson was a great studier. Nothing negative about it, either; we'll take action just as soon as we know enough, won't we?

Warning: Do not, under any circumstances, let yourself be drawn into a discussion of what should be done about the problem in the meantime during the uncertainty. The idea is that nothing should be done -- but if you say so out loud, someone might think of other possibilities. Even a halfway step -- like the provision in new hazardous waste law that eventually shuts down a dump site if its owner can't come up with good-enough data -- is dangerous.

Cut-off dates like that could change the whole incentive structure of environmental science.

2. It would hurt the economy.

The polls keep showing public support for environmental issues, yet environment-bashing has consistently been part of President Reagan's popular appeal.

Why? Because of the strong impression that environmental protection and economic growth are at opposite ends of a seesaw. Raise one and you automatically lower the other. "Environmentalism" thus becomes a code word for "antigrowth." Remind your audience of the seesaw, and you're home free.

The seesaw relationship isn't necessarily true, of course, so avoid calling for more study on this one. Remember what happened when the Environmental Protection Agency called for more study of cutting down on lead in gasoline and found that the economy would be better off.

Over the last 10 years, a few environmentalists have actually been coming up with schemes that help the environment and the economy at the same time. But nobody in either party noticed during the 1980 elections, or again in 1984. For now, this argument remains a solid winner.

3. It would cost jobs.

A variant of (2), to appeal specifically to labor sympathizers. Don't hesitate to use this argument even when the environmental action you're trying to stop would create more jobs than it would eliminate. Back when the late Rep. Phil Burton (D-Calif.) was trying to buy up forest to expand Redwood National Park, timber companies were very successful with the jobs issue, even though there were going to be a lot more new rangers than laid-off lumberjacks. Lesson: the public doesn't distinguish between loss of a particular job, which is a legitimate argument but a local one, and "jobs," which sounds like unemployment and economic woe. (In the end that park went through, because the companies got a high enough price for their land and the workers got a special fund to be spent on a combination of retraining and buyout.)

Keeping the issue general, rather than focusing on the jobs of specific workers, also avoids embarrassment when the environmental action would benefit those same workers (e.g., pesticide restrictions and farm workers).

4. The risk is exaggerated.

Lots of environmental issues involve small risks of a big disaster, like people getting cancer or a dam breaking or a nuclear plant melting down. Until it happens, which it probably won't, you can always argue that the other side is being alarmist.

This arguments works particularly well with toxic chemicals, where the evidence comes in funny numbers that the public doesn't understand, and where the toxicologists can't keep up with the demands for analysis. Don't forget to mention saccharin. "Chemophobia" is another good word to throw around -- it implies that concerns about chemicals are not only exaggerated but also irrational.

This argument is also a good fit with "more study"; see (1) above. If every chemical in the environment is entitled to a presumption of innocence until proven guilty, trial could take a long time.

5. The damage is trivial.

The flip side of "exaggerated risk": even if the risk is real, and the consequence does happen, it's not such a big deal. This is usually referred to as the Snail Darter theme, after its most famous incarnation in the case of the Tennesee Valley Authority's Tellico Dam, where the builder's argument was "What's a three-inch fish, compared to a giant dam?"

In fact, fish seem to make a natural target for this argument. Dave Stockman's Office of Management and Budget came up with a winner when it announced that the cost of cleaning up acid rain would amount to $6,000 a fish -- a brilliant combining of the Snail Darter theme with the theme of "hurting the economy." See (2) above. Stick to small fish. The developers of New York's Westway didn't do so well with the striped bass. We've always been grateful that the endangered species at Tellico Dam didn't turn out to be a sturgeon.

"Trivial damage" is very often a good argument to make against regulatory programs or in favor of land development, and it's been a mainstay with pesticides. But be careful when you're dealing with a risk of cancer.

6. You can't keep changing the rules.

This is a simple appeal to fairness, one that everybody can understand. The nuclear industry has used it the most, but it turns up in every context where environmental and health protection are delegated to some technical set of regulations.

The bureaucrats who wrote the regulations (or agreed to them) in the first place are almost always on your side with this one. Since they already spent lots of time knitting a set of rules together and probably then had to go to court to defend them, they're hardly eager to unravel and start again -- much less admit that a fleet of trucks is driving through their loopholes, or that they overlooked some important hazard the first time around.

Warning: keep in mind the assumption behind this argument -- that the problem was thoroughly studied and all the information was on the table back when the rules were written. This is the opposite of the assumption behind the "more study" argument. See (1) above. Don't let these two lines of argument cross.

7. Trust us to handle it ourselves.

In a nutshell, deregulation.

Who's in a better position to know what the risks are than the industry itself? And who better to know how to cope with them?

The regulators are against you on this one, since if the system trusted you instead of them on technical issues, they'd be out of a job. But they know the secret that, at bottom, even the toughest regulatory programs have to trust the industry for something -- and that most of the time they're trusting you across the board because they can't keep up.

Don't be intimidated when something goes wrong, either. After the Bhopal catastrophe in India, and even after a toxic-gas release or two in Institute, W. Va., Union Carbide was still in effect being trusted to prevent future leaks at its plants since no one else knew how, and no one had the nerve to shut them down.

Of course, you can't keep blowing it forever, but you get more chances than you think.

Warning: sooner or later, some economics grad-student type from the environmental side is going to counter you on this one by saying, "Fine, you go ahead and decide how careful to be, but then you accept the risk if something goes wrong." For this you need the next argument.

8. We can't afford to accept liability.

A helpless spreading of the hands.

You simply can't stay in business if you "accept" such a burden. Therefore, that smart grad student is trying to shut your industry down (which would, it goes without saying, hurt the economy).

The nuclear industry led the way on this argument with the Price-Anderson Act, which protected them from liability above a $560 million ceiling (and was very useful at Three Mile Island). The asbestos manufacturers are using a form of it in their bankruptcy proceedings. And everyone who put hazardous wastes in a leaking dumpsite is busy rehearsing.

The real issue, of course, is insurance, since this argument only comes up when insurance companies decide that what you're doing is too risky for them to write a policy. No one likes insurance companies, so it's easy to complain about them. But stay away from any discussion about whether they might be right.

9. You've got to make hard choices.

The tough-minded approach, a la James Watt. The idea is that we can't have everything, and that if we want economic growth we have to sacrifice some environmental quality. Anyone who thinks otherwise is soft in the head.

This argument has been overworked, and the polls suggest that the public doesn't really buy it. Should be saved for rare appearances. Also, it sets up those environmentalists whose strategy is to prove that "hard choices" is a fallacy and that you can do both. See (2) above. Use only when theyre not around.

10. If you've seen one tree, you've seen 'em all.

Don't be fooled. There's a brilliant argument lurking behind this discredited old one-liner, and the modern version of it is very powerful.

The point of the old version was that trees shouldn't be saved for their own sake. They were there to be used.

The modern version has to do with pollution loading and the point is the same. One of the great resource values of the air, water, and land is their ability to soak up pollution, at least to a certain level, without causing a lot of harm. That value is there to be used. Anyone who thinks otherwise is being a purist, trying to protect nature for its own sake.

Admittedly, maximum pollution loading is a point that requires delicate wording. Our favorite, from a distinguished lawyer, is the concept of "achieving efficient utilization of the absorptive capacity of the environment." Who could argue with that? Those who insist on some ideal of "non-degradation" are just being tree-huggers.

That's the complete list. Use it with our best wishes. And if anyone discovers a line of argument that we haven't mentioned, please let us know. The chance to try a fresh move, for once, might even entice us back into the game.