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This article was downloaded by: [University of Connecticut] On: 08 October 2014, At: 17:44 Publisher: Taylor & Francis Informa Ltd Registered in England and Wales Registered Number: 1072954 Registered office: Mortimer House, 37-41 Mortimer Street, London W1T 3JH, UK Human and Ecological Risk Assessment: An International Journal Publication details, including instructions for authors and subscription information: http://www.tandfonline.com/loi/bher20 Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective S. M. Bartell a a Cadmus Group, Inc., Oak Ridge, TN 37830 Published online: 03 Jun 2010. To cite this article: S. M. Bartell (1998) Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective, Human and Ecological Risk Assessment: An International Journal, 4:4, 843-851, DOI: 10.1080/10807039891284848 To link to this article: http://dx.doi.org/10.1080/10807039891284848 PLEASE SCROLL DOWN FOR ARTICLE Taylor & Francis makes every effort to ensure the accuracy of all the information (the “Content”) contained in the publications on our platform. However, Taylor & Francis, our agents, and our licensors make no representations or warranties whatsoever as to the accuracy, completeness, or suitability for any purpose of the Content. Any opinions and views expressed in this publication are the opinions and views of the authors, and are not the views of or endorsed by Taylor & Francis. The accuracy of the Content should not be relied upon and should be independently verified with primary sources of information. Taylor and Francis shall not be liable for any losses, actions, claims, proceedings, demands, costs, expenses, damages, and other liabilities whatsoever or howsoever caused arising directly or indirectly in connection with, in relation to or arising out of the use of the Content. This article may be used for research, teaching, and private study purposes. Any substantial or systematic reproduction, redistribution, reselling, loan, sub-licensing, systematic supply, or distribution in any form to anyone is expressly forbidden. Terms & Conditions of access and use can be found at http:// www.tandfonline.com/page/terms-and-conditions

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Page 1: Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective

This article was downloaded by: [University of Connecticut]On: 08 October 2014, At: 17:44Publisher: Taylor & FrancisInforma Ltd Registered in England and Wales Registered Number: 1072954 Registered office: Mortimer House,37-41 Mortimer Street, London W1T 3JH, UK

Human and Ecological Risk Assessment: AnInternational JournalPublication details, including instructions for authors and subscription information:http://www.tandfonline.com/loi/bher20

Ecology, Environmental Impact Statements, andEcological Risk Assessment: A Brief HistoricalPerspectiveS. M. Bartell aa Cadmus Group, Inc., Oak Ridge, TN 37830Published online: 03 Jun 2010.

To cite this article: S. M. Bartell (1998) Ecology, Environmental Impact Statements, and Ecological Risk Assessment:A Brief Historical Perspective, Human and Ecological Risk Assessment: An International Journal, 4:4, 843-851, DOI:10.1080/10807039891284848

To link to this article: http://dx.doi.org/10.1080/10807039891284848

PLEASE SCROLL DOWN FOR ARTICLE

Taylor & Francis makes every effort to ensure the accuracy of all the information (the “Content”) containedin the publications on our platform. However, Taylor & Francis, our agents, and our licensors make norepresentations or warranties whatsoever as to the accuracy, completeness, or suitability for any purpose of theContent. Any opinions and views expressed in this publication are the opinions and views of the authors, andare not the views of or endorsed by Taylor & Francis. The accuracy of the Content should not be relied upon andshould be independently verified with primary sources of information. Taylor and Francis shall not be liable forany losses, actions, claims, proceedings, demands, costs, expenses, damages, and other liabilities whatsoeveror howsoever caused arising directly or indirectly in connection with, in relation to or arising out of the use ofthe Content.

This article may be used for research, teaching, and private study purposes. Any substantial or systematicreproduction, redistribution, reselling, loan, sub-licensing, systematic supply, or distribution in anyform to anyone is expressly forbidden. Terms & Conditions of access and use can be found at http://www.tandfonline.com/page/terms-and-conditions

Page 2: Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective

Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

Reproduction of this material without the consent of the publisher is prohibited.

Ecological Risk Assessment and the NEPA Process

Human and Ecological Risk Assessment: Vol. 4, No. 4, pp. 843-851 (1998)

Ecology, Environmental Impact Statements,and Ecological Risk Assessment:A Brief Historical Perspective

S. M. Bartell*Cadmus Group, Inc., Oak Ridge, TN 37830

ABSTRACT

Ecological risk assessment will continue to increase in importance as aconceptual and methodological basis for evaluating environmental impacts asrequired by the National Environmental Policy Act. Understanding the histori-cal strengths and limitations of more traditional environmental assessmentsperformed in support of the NEPA can facilitate the effective incorporation ofecological risk assessment into the NEPA process. Such integration will alsobenefit from a knowledge of the historical and continuing development of theecological risk assessment process, as well as from a recognition of the contri-butions from modern quantitative ecology and ecosystem science. Adopting arisk-based approach can improve the NEPA process by providing a frameworkfor consistent and comprehensive ecological assessment and by providing aconceptual and methodological basis for addressing the varied uncertaintiesattendant to environmental assessments. The primary concern in integratingecological risk assessment into the NEPA process is that ecological risk assess-ment not merely become a new name for traditional environmental impactassessments. While the integration of ecological risk assessment into the NEPAprocess occurs, it is important to begin to outline the next transition inenvironmental assessment capabilities. Operationally linking ecological riskassessment methods with formal decision models appears as a worthwhileobjective in beginning this transition.

Key Words: risk-based environmental assessments, risk-based decision making,uncertainty in ecological assessments

* Cadmus Group, Inc., 136 Mitchell Road, Oak Ridge, TN 37830; Tel: 423-425-0401;Fax: 427-425-0482

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Page 3: Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective

Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Bartell

INTRODUCTION

The process of assessing potential environmental impacts as required by theNational Environmental Policy Act of 1969 (NEPA) can be improved byincorporating ecological risk assessment as the conceptual and methodologi-cal framework that guides assessment.

The following discussion addresses the potential contribution of ecologicalrisk assessment to the NEPA process. The discussion begins with an overviewof the NEPA, highlighting several strengths and limitations of the NEPAprocess. The development and evolution of ecological risk assessment are thendescribed. The discussion continues by underscoring contributions from ecol-ogy that might further advance ecological risk assessment in relation to theNEPA process. After identifying several unresolved issues in the developmentof ecological risk assessment, the discussion concludes by suggesting somespeculations concerning future assessment of environmental impacts.

AN HISTORICAL PERSPECTIVE OF NEPA

An in-depth, comprehensive review of the NEPA lies beyond the scope ofthe present discussion. A detailed and comprehensive discussion of the role ofNEPA in environmental assessment is provided by Hildebrand and Cannon(1993).

The National Environmental Policy Act of 1969 was offered as a legislativeresponse to public concerns regarding environmental degradation. Approxi-mately 35 separate bills were introduced to the 90th and 91st Congress toaddress such concerns. Senate Bill 1075, submitted on February 18, 1969eventually became Public Law 91-190, signed by then President Richard Nixonon January 1, 1970 (Caldwell, 1993). The primary purpose of the NEPA was toencourage harmony between humans and their environment. The NEPA wasfurther intended to promote efforts aimed at preventing or eliminating envi-ronmental damage, while stimulating improvements in the health and welfareof humans. Importantly, NEPA [Section 102(2)(c)] established the basis forrequiring federal agencies to prepare environmental impact assessments andimpact statements. It was hoped that the NEPA would furthermore foster anincreased understanding of ecological systems to technically support the re-quired assessments. Finally, the NEPA established the Council on Environ-mental Quality.

Despite the environmentally positive intentions written into the NEPA, thislegislation drew considerable criticism in the 1970’s, largely from the ecologi-cal scientific community (e.g., Schindler, 1976; Eberhardt, 1976; Fairfax, 1978).Schindler (1976) suggested that the NEPA process had by and large backfired.Instead of promoting environmental assessment of the highest technical qual-ity, the NEPA process had produced a gray literature of reports that containedmassive amounts of incomplete, descriptive, and often, uninterpreted data.These data were commonly collected using outdated ecological textbookmethods that did not reflect the current quantitative capabilities of the eco-

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Page 4: Ecology, Environmental Impact Statements, and Ecological Risk Assessment: A Brief Historical Perspective

Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Ecological Risk Assessment and the NEPA Process

logical basic research and development community. Such technical shortcom-ings, combined with a largely absent peer-review process, provided for seriousconcerns about the scientific credibility of assessments performed under theNEPA and the defensibility of environmental decisions based on scientificallyinadequate Environmental Assessment’s (EA’s) and Environmental ImpactStatement’s (EIS’s). These and other evaluations of the NEPA environmentalassessment process contributed in large part to a review commissioned by theNational Science Foundation concerning the efficacy of NEPA regardingenvironmental protection (Hildebrand and Cannon, 1993).

Such criticism did not, of course, go unnoticed by practicing environmentalimpact assessors. Their response raised new issues concerning the role ofscience in environmental assessment and recognized that the assessmentprocess differed fundamentally from basic ecological research and develop-ment. That is, while the nature of environmental assessment under the NEPAwas not necessarily or entirely scientific, scientifically defensible assessmentswere nonetheless a NEPA objective. The NEPA process afforded an opportu-nity to integrate ecology, social science, policy, and economics in a decision-making framework. Ecologists were forced to learn how to practice and applytheir professional skills within the legal context of the NEPA, often in court-room situations.

This overview, albeit necessarily superficial and incomplete, sets the stagefor presenting a parallel perspective concerning the development of ecologi-cal risk assessment, a new approach to assessing environmental impacts that,if implemented in support of the NEPA, might redress some of the recognizedlimitations of environmental assessments and environmental impact state-ments produced in accordance with the NEPA.

AN OVERVIEW OF ECOLOGICAL RISK ASSESSMENT

Quantitative risk assessment attempts to answer three basic questions:”What can go wrong? How likely is it to happen? and, So what if it does?”(Kaplan and Garrick, 1981). An ecological risk is the conditional probabilityof a specified (usually undesired) ecological event occurring, combined withan evaluation of its consequences (Bartell, 1996). Ecological risk assessment is,therefore, the process of estimating the probabilities of such ecological eventsand evaluating their consequences. It should be recognized, however, that asa component process used in a broader decision making context, ecologicalrisk assessment includes qualitative aspects. For example, indentifying andselecting ecological impacts to be assessed are often influenced by consider-ations of underlying social, political, and economic values relevant to theassessment. Importantly, the estimation of ecological risks should be quantita-tive and explicitly incorporate any bias and imprecision that result from, forexample, incomplete understanding of ecological systems, sparse data, andpoorly developed stress (dose)-response relationships. Conditional probabili-ties were just mentioned as a quantitative framework for risk; however, other

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Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Bartell

approaches that characterize and propagate uncertainties through the assess-ment (e.g., interval analysis, fuzzy arithmetic, distribution-free orcomputationally intensive statistics) can serve as justifiable alternatives forquantitative ecological risk assessment. The following discussion provides anhistorical perspective concerning the development of ecological risk assess-ment. As with the previous discussion of the NEPA, the following overviewmight be regarded as overly simplistic; an exhaustive treatment lies similarlybeyond the scope of the presentation.

The development of ecological risk assessment in the US has not surpris-ingly been influenced by the human health risk assessment model (i.e., the“red book”, NRC, 1983). The components of the risk assessment process forecological effects and human health concerns are similar in concept and interminology. The ecological risk assessment components and process areperhaps best articulated in the USEPA framework documents (USEPA, 1992,1995), although alternative approaches have been offered (e.g., Parkhurst,1993).

Several products and events can be identified as important in the historicaldevelopment of the ecological risk assessment process; this process continuesto change to more effectively address both environmental regulatory andplanning needs. The enactment of RCRA/CERCLA “Superfund” in 1980provided a major impetus for developing ecological risk assessment by requir-ing baseline risk assessments. One of the first symposia on ecological riskassessment convened as a session in the 1981 annual meeting of the (thenfledgling) Society for Environmental Toxicology and Chemistry (SETAC). Aprobabilistic method for estimating ecological risks using Monte Carlo simu-lation and an aquatic ecosystem model was presented at this symposium andpublished (O’Neill et al., 1982) in volume one of Environmental Toxicology andChemistry. This method was one of several being developed during the early1980’s by investigators in the Environmental Sciences Division, Oak RidgeNational Laboratory. During this time period, Levin and Kimball (1984)published a key contribution to the development of ecological risk assessmentin the Journal of Environmental Management. This publication emphasized theneed to inject scientifically defensible ecological concepts and quantiativemethods into the risk assessment process; this work reflected major efforts indeveloping ecological risk methods that were underway at the then CornellUniversity EPA-sponsored Center of Excellence.

Several workshops held during the late 1980s and early 1990s were criticalin providing the fundamental conceptual and methodological components ofwhat was to emerge as the USEPA approach to assessing ecological risks. Twosuch workshops included one held at the Aerlie House in 1989 and anotherat the University of Miami in 1991. The Aerlie workshop addressed the simi-larities, and more importantly the differences between human health andecological risk assessment. The Miami workshop produced a multi-dimen-sional framework for structuring ecological assessments of different stressorsat different levels of ecological organization for different ecosystem types.

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Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Ecological Risk Assessment and the NEPA Process

A landmark in ecological risk assessment was the publication in 1992 of theUSEPA Framework for Ecological Risk Assessment. Several case studies thatexercised the proposed Framework were constructed and evaluated in thecontext of the newly proposed EPA risk assessment approach (USEPA, 1993).

Two books on ecological risk assessment were published in the early 1990s.The Bartell, Gardner, and O’Neill (1992) work, Ecological Risk Estimation,appeared as the first book devoted to this topic. This book expanded on theaquatic ecosystem methods for ecological risk assessment that they developedduring the 1980s (e.g., O’Neill et al., 1982, 1983). Particular emphasis wasplaced on quantitative sensitivity and uncertainty analyses of the risks esti-mated using an aquatic ecosystem model, as well as on the comparison ofpredicted and measured ecological effects of phenolic compounds in experi-mental ponds. Soon thereafter Suter’s (1993) now familiar edition, EcologicalRisk Assessment, appeared. Suter’s volume has proven particularly valuable forits comprehensive and detailed discussion of the components of an ecologicalrisk assessment. The year 1993 also saw the presentation of an alternativeapproach to assessing ecological risk, sponsored in large part by the WaterEnvironment Research Foundation (WERF) (Parkhurst, 1993). The WERFmethodology emphasized a sequential or “tiered” approach to assessment,beginning with a simple screening-level assessment (Tier 1) and proceeding,as necessary, through more detailed analyses using existing (Tier 2) or newlyacquired site-specific (Tier 3) data and information. Recently, the EPA draftguidelines for ecological risk assessment were peer-reviewed and published(USEPA, 1996). Much of the discussion of the proposed methods and ap-proaches for assessing ecological risks, including more strategic consider-ations of the pro’s and con’s of ecological risk as a bone fide discipline forassessing environmental impacts , have appeared in the new journal on Humanand Ecological Risk Assessment (HERA). Other events overlooked in this briefhistorical account might undoubtedly have been identified by other partici-pants in the development of the current state of ecological risk assessment.The main point is that the process has been more than a decade in the makingand it continues to evolve through periodic review by its developers andthrough the collective experience gained by its practitioners.

ECOLOGICAL RISK ASSESSMENT IN SUPPORT OF NEPA

Other authors might reasonably highlight events other than those justdescribed as hallmarking the development of ecological risk assessment. How-ever, consensus might be expected in describing the possible contributions ofecological risk assessment to the NEPA environmental impact assessmentprocess. Importantly, ecological risk assessment provides an organized processtoward ensuring comprehensive and consistent assessments of environmentalimpacts. If NEPA assessments adhere to the prescribed components of theEPA Guidelines, each assessment will include and document the stages ofproblem formulation, exposure analysis, effects assessment, and risk charac-

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Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Bartell

terization. Following the guidance described for each of these components ofthe risk assessment process (e.g., USEPA, 1992, 1996) will, in addition, increasethe likelihood that previous concerns of ecological sophistication, currentmethods of sampling and analysis, defensible interpretation of data, andquality assurance will be successfully addressed in future assessments per-formed in support of the NEPA.

Ecological risk assessment was designed to explicitly address the manysources of uncertainty associated with analyzing environmental impacts. Eco-logical risk assessment provides a powerful conceptual and methodologicalframework to technically improve environmental impact statements preparedin support of NEPA. Uncertainties have always been present in assessingpotential environmental impacts; ecological risk assessors did not discover orinvent this uncertainty. Unfortunately, the historical approach to assessingenvironmental impacts, including the prescribed report format, largely con-signed the characterization of uncertainties and evaluation of their potentialimplications for the assessment to appendices of an EIS. Such uncertaintieswere often either ignored, omitted, described in qualitative terms, or merelyimplicit in the assessment and reflected correspondingly in the EIS. Theecological risk assessment process moves uncertainty explicitly to the forefrontand makes every attempt to quantify such uncertainties (including modelstructure uncertainties) and explicitly determine their impacts on the overallquality and utility of the assessment. Using methods described in the riskassessment process (e.g., sensitivity/uncertainty analyses), assessment uncer-tainties can be examined quantitatively to identify and rank-order the neces-sary data and information that will provide the greatest refinement in theassessment per unit investment.

CONTRIBUTIONS FROM ECOLOGY AND ECOSYSTEM SCIENCE

The science of ecology, like the history of the NEPA and the developmentof ecological risk assessment, is also dynamic. A resulting challenge has beento incorporate modern quantitative ecology into the conceptual and method-ological development of environmental assessment, including ecological riskassessment. A developmental history of ecology relevant to environmentalassessment appears certainly as a worthwhile endeavor. However, the currentscope limits historical considerations to several highlights from ecology andecosystem science. More detailed expositions have been provided, for ex-ample, by McIntosh (1985) and Golley (1993).

The history and science of ecology should teach those who assess environ-mental impacts that there are different ways to view and measure the naturalworld. Various disciplines organized within the broader field of ecology re-spectively emphasize individual organisms, populations, communities, land-scapes, and ecosystems as tangible or abstract entities worthy of descriptionand measurement. None of these perspectives appears inherently more or lessjustifiable in environmental assessment. Each viewpoint has, by design, its

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Copyright © 1998, CRC Press LLC — Files may be downloaded for personal use only.

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Ecological Risk Assessment and the NEPA Process

particular and characteristic simplifying assumptions; each viewpoint has ledto the development of particular concepts, methods, and measurements; eachviewpoint has its strengths and limitations in relation to environmental assess-ment. Each of these different disciplines in ecology should be explored fullyto determine the potential contribution to environmental assessment, particu-larly risk assessment. The temptation to view nature as a simple nested modelof ecosystems that occupy the landscape, and that consist of communitiesmade up of populations of individual organisms must be resisted. This modelis valid in a sense, but trivial.

The evolution of ecosystem science has provided valuable input to theenterprise of environmental assessment (1) by emphasizing the importance ofrelationships between and among organisms and their biotic and abioticenvironment in determining ecological response to disturbance, and (2) bydemonstrating the asymmetry of hierarchical ecological systems: not all eco-logical system components and processes are important all the time (O’Neillet al., 1986). In addition, methods of systems analysis and mathematical mod-eling of ecological systems have, of course, contributed to the arsenal to toolsavailable for quantitative environmental assessment and probabilistic ecologi-cal risk assessment (e.g., O’Neill et al., 1982, Bartell et al., 1992).

LIMITATIONS OF ECOLOGICAL RISK ASSESSMENT

Ecological risk assessment, as currently conceived and practiced, is notnecessarily the panacea for previous concerns regarding environmental assess-ment under the NEPA (e.g., Schindler, 1976). Increasing the effectiveness ofERA will require overcoming several limitations, including the vague languageof environmental legislation, imprecise specification of the decision-makingprocess, use of assessment methods of unknown performance (e.g., the quo-tient method), and a proliferation of jargon that erodes credibility and discon-nects ecological risk assessment from more formalized risk assessment prac-ticed in other fields (e.g., Helton, 1993; Kaplan and Garrick, 1981).

Using the current framework (i.e., USEPA, 1992, 1996) is made difficult bythe absence of a clearly stated environmental baseline or a prescription fordefining such a baseline or selecting reference environments. This difficultyoriginates in part from different human perceptions of the environment(Holling, 1986). Under current environmental regulation, a constant environ-ment and a corresponding ecological status quo seem to define an implicitbaseline environment. However, ecological risks cannot be easily or convinc-ingly assessed in relation to such a static model. There is also a concern thatuncertainty in ecological risk assessment can paralyze decision making orbecome an excuse for indecision.

As these limitations are removed through continued practice and refine-ment, ecological risk assessment can become increasingly effective in improv-ing environmental impact assessments performed in response to NEPA re-quirements.

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Bartell

QUANTITATIVE ENVIRONMENTAL DECISIONANALYSIS — A NEXT STEP

While the process of ecological risk assessment evolves in concept andpractice, it is important to think about the progression from risk assessment towhat might follow in a continuing effort to improve environmental assess-ments. Ecological risk assessment can be classified as one form of decisionmaking under uncertainty (Rubenstein, 1975). Therefore, a logical successionwould take ecological risk assessment and more formally integrate it with thescience of quantitative decision making. This next step might be called “quan-titative environmental decisioneering” (QED), the name emphasizes the con-tribution of risk assessment to the decision making process and recognizes thatdecision making is a technical discipline at least as rigorous as ecological riskassessment.

One tangible first step in the development of QED would replace theconceptual model described in the current USEPA Framework for EcologicalRisk Assessment (USEPA, 1992, 1996) with an operational decision model, forexample, an influence diagram or decision tree. The objective of problemformulation in QED would be to provide initial values, including ecologicalrisks, and execute the decision model. The sensitivity of selecting among thedecision alternatives to uncertainties associated with the preliminary ecologi-cal risks could be determined along with the decision sensitivities to the otherinputs (e.g., Darkin et al., 1994). The resulting sensitivities could then be usedto assist in an economical and effective design for the ecological risk assess-ment that would best support the decision process represented by the opera-tional decision model. Of course, such analyses might also revise, modify, orrefine the decision model.

SUMMARY

Ecological risk assessment has developed mainly as a process that parallelshuman health risk assessment. Alternatively, ecological risk assessment can beviewed as a logical improvement of environmental impact assessment capabili-ties in support of the NEPA. The main advantages afforded by integratingecological risk assessment into environmental assessments and environmentalimpacts statements include: (1) the introduction of a consistent and compre-hensive guideline for assessing the potential environmental impacts (i.e., risks)related to human activities; and (2) an emphasis on explicitly addressing theuncertainties attendant to each assessment.

It might prove useful to view ecological risk assessment as a response toprevious technical criticism of NEPA. At the same time, it is imperative thatecological risk assessment not simply become the new name for traditionalNEPA environmental impact assessment.

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Ecological Risk Assessment and the NEPA Process

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