Effective Coordination and Cooperation Between Ecological Risk Assessments and Natural Resource Damage Assessments: A New Synthesis

Abstract

Although ecological risk assessments (ERAs) and natural resource damage assessments (NRDAs) are performed under different statutory and regulatory authorities, primarily the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as currently practiced, the activities typically overlap. ERAs performed as part of the response process (typically by the US Environmental Protection Agency [USEPA]) should be closely coordinated with the natural resource trustees' (trustees') NRDAs. Trustees should actively participate in the early stages of the remedial investigation (RI) and work with USEPA, including the potentially responsible parties (PRPs), when appropriate, to coordinate NRDA data needs with those of the RI. Close coordination can present opportunities to avoid inefficiencies, such as unnecessary resampling or duplicate data gathering, and provide the opportunity to fulfill both process requirements with a few well-designed investigations. Early identification of opportunities for practical combined assessment can save money and time as the restoration process proceeds and facilitate a cooperative resolution of the entire site's CERCLA liability. The Society of Environmental Toxicology and Chemistry (SETAC) convened an invited workshop (August 2008) to address coordination between ERA and NRDA efforts. This paper presents the findings and conclusions of the Framework Work Group, which considered technical issues common to each process, while mindful of the current legal and policy landscape, and developed recommendations for future practice.