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Interactive Public Docket

COMMENT BY: DR. ROBERT T. LACKEY, National Health and Environmental Effects Laboratory
SUBJECT: If Ecological Risk Assessment is the Answer, What is the Question?
DATE: October 27, 1999


Dr. Robert T. Lackey of EPA's National Health and Environmental Effects Laboratory, Corvallis, Oregon, advised CRE of the Internet posting of his paper, "If Ecological Risk Assessment is the Answer, What is the Question?" An abstract of the paper is reprinted below. Click here to link to the full paper on EPA's website:
www.epa.gov/wed/pages/staff/lackey/pubs/question.htm


If Ecological Risk Assessment is the Answer, What is the Question?

Dr. Robert T. Lackey
National Health and Environmental Effects Laboratory,
United States Environmental Protection Agency
Corvallis, Oregon

ABSTRACT -- reprinted by permission

Ecological risk assessment has become a commonly used tool in policy analysis, but its use is controversial. Opinions are diverse; they range from enthusiastic support to caustic dismissal. Much of the controversy with using risk assessment in ecological policy analysis revolves around defining the initial policy question or problem to be assessed. In formulating the "question" in ecological risk assessment, the nature of the analytical technique forces analysts to make assumptions of values and priorities; these assumptions may not be the same as those of the public or their elected or appointed representatives. Specifically, much of the difficulty with applying risk assessment is that, by definition, risk is adverse. Deciding which ecological changes are adverse (undesired) and which are beneficial (desired) is likely to be the primary political debate. Ecological conditions and changes are classified by the values and priorities of the person or administrative body doing the classification; ecological condition or change in itself is neither good nor bad, beneficial nor adverse, healthy nor degraded. One method often used to determine which ecological conditions or changes are adverse is to apply the human "health" metaphor to ecosystems or ecological components. However, application of the concept of ecosystem health is fraught with value-based requirements which are difficult and probably impossible to attain. Formulating the question is, or at least should be, driven by societal values, preferences, and priorities, but this is difficult to do in a pluralistic society. Better ways to evaluate and measure public values, preferences, and priorities in framing ecological questions are needed to enhance the utility of ecological risk assessment.