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Applying Net Environmental Benefit Analysis to Contaminated Sites

Exxon Valdez oil spill site

Exxon Valdez oil spill site.

First, do no harm….

Or at least don’t do more harm than good.

That’s the idea behind NEBA—Net Environmental Benefit Analysis—as applied to the cleanup of contaminated sites. As defined by a vintage 1990s Department of Energy paper on the subject, net environmental benefits are:

“…the gains in environmental services or other ecological properties attained by remediation or ecological restoration, minus the environmental injuries caused by those actions.”

Spills like Exxon Valdez Spurred the NEBA
The NEBA concept originated with the cleanup of large marine oil spills. One of the first formal considerations of Net Environmental Benefits was the cleanup of the Exxon Valdez oil spill in Prince William Sound, Alaska in 1989. After the spill, the U.S. National Oceanic and Atmospheric Administration (NOAA) looked at whether high-pressure, hot water washing of unconsolidated beaches might actually do more harm to the intertidal habitat—and the plants and animals that depend on it—than just simply letting the oil degrade naturally.

Since then, NEBAs have been used for a few other types of cleanups, including metals contamination in wetlands and organic contamination in sub-tidal sediment, but only infrequently and on an ad hoc basis.

No current NEBA Guidelines, However…
Formal consideration of net environmental benefits has not been more widespread in cleanup decisions, probably because federal and state cleanup frameworks, such as Washington’s Model Toxic Control Act (MTCA), do not explicitly allow consideration of the harm of the cleanup itself and don’t provide guidelines for when the process would apply and how the benefits and impacts should be evaluated.

But that might be changing. At least it is in Washington State, where the Department of Ecology thinks that the NEBA’s time has come. Ecology is working on new draft Terrestrial Ecological Evaluation (TEE) guidance that, for the first time, lays out the implementation of NEBA at cleanup sites under MTCA.

NEBA and Abandoned Underground Mines
In conjunction with Ecology, Hart Crowser has already “test driven” the NEBA concept as it applies to the cleanup of abandoned underground mines. Many of these sites pose risks to terrestrial plants and animals because of the toxic metals such as copper and zinc left behind in tailings and waste rock.

Although the risks to individual organisms living on the waste material might be high, the overall risk to plant or wildlife populations are often fairly low because the extent of the waste material is so small. Nonetheless, the remedy selection process under MTCA would typically lead to a decision to cap the contaminated material with clean soil or to dig it up and haul it away to be disposed of elsewhere.

Bringing Common Sense into Cleanup Decisions
But what if the cleanup involved building an access road? Through mature forest? Or up a steep, exposed mountain side? Or across a stream or wetland? How are those habitat or ecosystem injuries balanced against the benefits of the cleanup itself? Ecology’s upcoming NEBA guidance should go a long way to addressing these dilemmas and bringing some common sense into certain cleanup decisions.

“Especially Valuable Habitat”
The new guidance is expected to introduce the concept of “Especially Valuable Habitat” and how to use it as a threshold for judging whether or not a NEBA may be appropriate for a particular site. It’s also expected to allow some flexibility regarding how injuries and benefits are quantified and balanced.

In the meantime, check for updates on when the new guidance is expected at Ecology’s website.

Digital Coast Act Introduced to Aid Communities with Coastal Planning and Disaster Response

Digital Coast Website Snapshot

Those of you involved with GIS or coastal mapping may be familiar with NOAA’s Digital Coast Project, which consists of a free, online database of the most up-to-date coastal data throughout the U.S. Established in 2007, this project not only provides essential data, but also the tools and training coastal communities need to respond to emergencies and make sound planning decisions. Due, in part, to its collaborative nature and broad datasets ranging from land use to aquatic habitat to socioeconomics, the Digital Coast has quickly become one of the most widely used management resources in the coastal management community.

Accurate and up-to-date coastal information is becoming increasingly important in the U.S. Coastal watershed counties were home to nearly 164 million Americans in 2010, approximately 52% of the U.S. population. This number is expected to increase by more than 15 million by 2020. These counties also contribute over 58% ($8.3 trillion) of our gross domestic product. As vital as our nation’s coasts are to the local and national economy, they are equally as vulnerable. In the Pacific Northwest, growing demand for coastal development, combined with an increase in natural hazards such as sea-level rise, extreme weather, and flooding events, will continue to exert significant pressures on coastal communities. Storm damage from coastal flooding and erosion result in response costs, lost productivity, and lowered economic productivity that we all pay for one way or another. The Digital Coast Program provides accurate data and integrated information that enables coastal communities to adapt to changing environmental conditions and protect their local economies.

In September 2014, U.S. Senator Tammy Baldwin, with support from Senator Maria Cantwell (WA) and others, introduced the Digital Coast Act of 2014. This legislation authorizes further development of the Digital Coast Project by increasing access to uniform, up-to-date data, identifying data gaps, and ensuring that coastal communities get the data they need to respond to emergencies, plan for economic development, and protect shoreline resources. The bill would provide funding for a national mapping effort of coastal waters that includes improved data on coastal elevations, land use/land cover, structures, habitat data, and aerial imagery, all of which could be of great benefit to Puget Sound and the Pacific Northwest. This legislation has been assigned to a congressional committee but it is unclear if and when it will be enacted. However, many coastal planners and scientists view the Digital Coast Act as critical legislation that is needed to help ensure the protection of coastal resources and communities in the Pacific Northwest and throughout the nation.

More information on NOAA’s Digital Coast Project or pending legislation to enact the Digital Coast Act