risks. In particular, the ERA should be a source of performance metrics and restoration goals for use in an adaptive management strategy.

Establish an independent external scientific review panel with multidisciplinary expertise to provide ongoing evaluations and advice to the relevant agencies on remediation decisions at mining megasites. Although this recommendation may appear to add to the bureaucratic process, at particularly complex sites it may well speed cleanup, avoid excess costs, and provide a mechanism for resolving technical disagreements.

Broaden the goals of the cleanup to include restoration of habitat for ecologic resources to the extent required to meet biological performance goals. For affected communities, provide economic assistance and comprehensive medical support services that acknowledge the broad effects that toxic waste sites have on health.

Encourage development of alternative and innovative technologies, including responsible re-mining as remedial strategies. Consider offering indemnification to private or nonprofit entities that participate in cleanup, agreeing that their liability will be limited to problems resulting from the remediation activity.3

Look for opportunities to provide long-term support for implementing and maintaining the cleanup activities and stewardship of the land. Possible sources of such support might include special appropriations by Congress, trust funds, or partnerships with private organizations.

Both risk assessment and risk management activities should be structured according to the natural environmental system boundaries; they should not represent the aggregation of policies previously used at smaller, simpler locations.


Such relief should not be afforded to any responsible party at the site who has not entered into a binding settlement agreement with EPA regarding its cleanup liability.

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