The committee that was convened in response to the request from EPA, FWS, NMFS, and USDA included experts on salmonid biology, ecology, hydrology, geospatial analysis, exposure analysis, toxicology, population dynamics, statistics, uncertainty analysis, environmental law, and ecological, pesticide, and mixture risk assessment (see Appendix B for biographical information). The committee was asked to evaluate EPA’s and the Services’ methods for determining risks to listed species posed by pesticides and to answer questions concerning the identification of the best scientific data, the toxicological effects of pesticides and chemical mixtures, the approaches and assumptions used in various models, the analysis of uncertainty, and the use of geospatial data. See Box 1-1 for a verbatim statement of the committee’s task.
The committee held five meetings to assist it in accomplishing its task. The first three included open sessions during which the committee heard from the sponsors and invited speakers from academe, professional organizations, nonprofit organizations, and consulting agencies. The committee submitted written questions to the sponsors to clarify the charge questions, discussed their responses in an open session, and reviewed extensive literature on various aspects of ecological risk assessment and materials provided by the sponsors and stakeholders. As directed in its statement of task, the committee used the recent consultations between the NMFS and EPA as a reference for its evaluation of assessment methods used by EPA and the Services. It emphasizes that it did not specifically evaluate the biological opinions or EPA’s effect determinations on Pacific salmonids; that would have been outside its charge. For ease of discussion, the committee has designated the steps in the ESA process—“may affect,” “likely to adversely affect,” and “likely to jeopardize”—as Steps 1, 2, and 3 in this report.
The committee does not take a position on any legal or regulatory policy issue, provide any legal or policy advice, or comment on the merit of any particular court ruling or other legal or policy decision. Furthermore, it recognizes that the agencies must make regulatory policy choices, and it has consciously avoided commenting on regulatory policy. In fact, the committee concludes that science and regulatory policy need to be kept separate to the extent possible and that there should be transparency where policy is involved. The present report evaluates the science of ecological risk assessment. Once an assessment is conducted, the involved agencies are responsible for making policy decisions pursuant to their legal mandates. The committee uses the generic term decision-maker to indicate a person who will use the results of a risk assessment to inform a decision. The committee makes no statements on who such a person should be; that is a policy issue.