Chapter 9
Environmental Impact Assessment Applied to Decision Making

Sergio F. Galeano

Georgia-Pacific Corporation

The topic of environmental impact assessment applied to decision making is a greater challenge when it involves a whole product system interacting with the ecosystem that provides the raw material. The challenge in this chapter is twofold: first, to present the topic in a way that covers its breadth and depth—the diversity of assessment applications across the product system, the specific disciplines developed for such applications, and their limitations. The second element of the challenge is to stress the role of impact assessments in helping decision making strike the proper balance with many other factors in decision making—economics, product functionality, sustainable development, cultural values and others.

Decision-Making Areas

In a wood product system, including the wood as raw material, there are three important areas of decision making to address: forest management, product preferability, and general issues of sustainability and ''ecoefficiency.'' They are broad enough not to be labeled as endpoints for assessment but rather as decision-making areas. For the past two or three years forestry management and certification issues have been debated worldwide. Likewise, efforts to assign preferability or superiority to products via labels or to regulate preferential purchases are very much alive. General issues of sustainable development and "ecoefficiency" are gaining impetus in decision-making sectors. In the product system, the emerging concept of extended product responsibility is one example of impact assessment applied to decision making.



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Chapter 9 Environmental Impact Assessment Applied to Decision Making Sergio F. Galeano Georgia-Pacific Corporation The topic of environmental impact assessment applied to decision making is a greater challenge when it involves a whole product system interacting with the ecosystem that provides the raw material. The challenge in this chapter is twofold: first, to present the topic in a way that covers its breadth and depth—the diversity of assessment applications across the product system, the specific disciplines developed for such applications, and their limitations. The second element of the challenge is to stress the role of impact assessments in helping decision making strike the proper balance with many other factors in decision making—economics, product functionality, sustainable development, cultural values and others. Decision-Making Areas In a wood product system, including the wood as raw material, there are three important areas of decision making to address: forest management, product preferability, and general issues of sustainability and ''ecoefficiency.'' They are broad enough not to be labeled as endpoints for assessment but rather as decision-making areas. For the past two or three years forestry management and certification issues have been debated worldwide. Likewise, efforts to assign preferability or superiority to products via labels or to regulate preferential purchases are very much alive. General issues of sustainable development and "ecoefficiency" are gaining impetus in decision-making sectors. In the product system, the emerging concept of extended product responsibility is one example of impact assessment applied to decision making.

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Communications and Common Sense It is important not to lose perspective in the discussion. Despite the improvements made in the field of impact assessment, the fact remains that decisions must be made, and are being made, in the face of uncertainty, and that there must be a balance between different and sometimes competing factors. My company, Georgia-Pacific, strives to balance shareholders' demands for superior financial returns with society's desire for a clean and sustainable environment. It is natural that we are actively involved in developing and applying different assessment methodologies to help our decision making in all links of the chain of our product system. More accurate information reduces uncertainty, which in turn helps in decision making and in communicating to other stakeholders the preferred alternatives and solutions. Common sense and good communications help advance projects where the exact cost-benefit ratio or the assessment of impacts are not completely clear. Some decisions made by Georgia-Pacific and others in the complex area of forest management are offered as examples. The need to protect bald eagle nesting areas in Maine, the red-cockaded woodpecker in the Southeast, and the coho salmon and the steelhead trout in the Pacific Northwest were included in our decisions made as part of good management practices. Our joint effort with the Nature Conservancy to manage and protect 21,000 acres along the lower Roanoke River in North Carolina is another example of decision making through good communication, acceptable information, and good common sense. All of these projects are essentially the result of identified sources of harm for the species which likelihood make them potential risks. They fit well in the forest management decision-making area mentioned above. In these projects, the impact assessment and subsequent decision making were done, for each specific ecosystem, through a clear communication process. This process allowed for the identification of the ecologic endpoint—protection of wildlife or of endangered species. Assessment of the potential risk in doing nothing was part of the ultimate decision. Our company's employees, university researchers, and representatives of government and interest groups reached a consensus on a decision about these initiatives. In all honesty, we did not have, and yet do not, a tool that would have indicated to us which one was the best project or that would delineate the magnitude of benefits in carrying each of them. Essentially, they all make good sense to us and to our partners. This volume does not focus on the forest as the source of raw material. It does focus on the product system—wood as raw material, its industrial uses, its products, and its consumption. As such, any portion of this chapter on impact assessment for decision making must address the different assessment tools and applications available for each major element of the product system.

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Environmental Impact Assessments No environmental decision, whether made by a corporation or by a national policy body, can be based solely on the results of an environmental impact assessment—regardless of the advanced stage of the methodology used. Many other factors will impact the final decision. These realities were recognized more than 25 years ago when Congress enacted Public Law 91–190, the National Environmental Policy Act (NEPA), in 1969 (National Environmental Policy Act of 1969). NEPA was perhaps the best first example of environmental leadership and concern for sustainable development from any country in the world. Among NEPA's specific ends, it demands balancing the protection of the environment with the use of resources in a manner that will permit high standards of living. It can be said that the ends sought in NEPA, explicitly stated in Section 102, are our national equivalent of and an analogue to the balance sought in the more recent global sustainable development declaration of the Brundtland Commission (World Commission on Environment and Development, 1987). The NEPA went farther than the Brundtland Commission did by requiring the assessment of environmental impacts using an interdisciplinary approach in any planning and decision making with an impact on the environment. In identifying and developing this interdisciplinary approach, NEPA makes clear the need to give appropriate consideration in decision making to environmental, economic, and technical considerations (42 U.S.C., Section 103). The reference to NEPA here is important because it aptly reminds us of the need for interdisciplinary approaches and the balancing of environmental, economic, and societal goals whenever decisions are made regarding a product and its raw materials. NEPA also formalized the development of impact assessment methodologies and terminology that are reviewed here. Risk Assessment and Analysis The terminology of risk assessment can be particularly confusing if, as in our case, we move from ecosystem assessment to the assessment of individual organisms. Typically, a hazard is the source of a harm. The likelihood of harm from exposure to or occurrence of a hazard makes it a risk. Many consider risk analysis to be the whole process and risk assessment to be the portion that assigns magnitudes and probabilities to the adverse effects of human activities or natural catastrophes (Cohrssen and Covello, 1989). In the regulations implementing NEPA, "effects" are equated with "impacts" (Code of Federal Regulations). Thus, impact assessment defines the magnitude and probability of the effects of human actions on resources and the environment. The implicit recognition of uncertainty and the probability associated with any risk are central to impact assessment and environmental decision making. They make it possible to obtain a balance of competing interests and to set priori-

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ties. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); Toxic Substances Control Act (TSCA); Federal Food Drug and Cosmetic Act (FFDCA); and Occupational Safety and Health Administration (OSHA); for example, in similar fashion address the issue of unreasonable risk that implies the notion of the magnitude and probability of an impact. Assessment of the risk of given impacts is achieved by focusing on endpoints. Endpoints Any assessment must define endpoints. The endpoint in the expression of the value to be assessed or protected. Some assessments—for example, one that examines the health effects using of a specific product—use specific, discernible, and available endpoints. We could be talking about specific chemicals and recognized endpoints in the area of human health. However, the assessment of impacts and effects on ecosystems—those that affect resource use, for example—is different because the endpoints are less evident and harder to measure, and the values to be protected are numerous and conflicting. There are no recognized models for integrating the multitude of variables that influence the biologic organizational hierarchy that exists in an ecosystem. Endpoints are important in the description of the wood product system because they vary according to the different elements of the overall product system. They also pose definitional challenges. Endpoints must be descriptive of the values or attributes to be protected or that are at risk, and they must be able to define the values or attributes in operational terms. If not measurable or estimated, the assessment is incomplete (Sutter, 1993). It is easier to define the values we want to protect than it is to measure or estimate them. In the area of human health, the effects of radiation, food contamination, and exposure to airborne chemicals, among others, are easier to relate to endpoints. In contrast, in ecosystem assessment, the selection of endpoints and their operational terms is more difficult. Values expand over a broad range of aesthetic, social, economic, and environmental considerations on which clear agreement must first be obtained. Different endpoints apply for each stage in the product life-cycle. The convenience of using a product system model to explain impact assessment and endpoints is discussed in the next section. Product System The model of a product system allows us to focus on the product, its raw materials, and its societal uses and consequences. The model consists of three primary systems: the ecosystem, the product system itself, and the social system. The product system interacts and links itself with the ecosystem and the social system. Figure 9-1 shows how the product system is connected to and interacts with the other two primary systems (Galeano, 1996a).

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Figure 9-1 Model for the product system. The ecosystem supplies the abiotic and biotic resources. In our case, wood is the primary biotic raw material for wood products, including paper products. The industrial use of wood results in the supply and distribution of products to the third system, the societal system. The societal system creates the demand for the products, which it uses and discards in different ways. Releases from the product and societal systems go back to the ecosystem, affecting it in different ways, along with the effects resulting from the processes and operations involved in the supply of raw materials. Different approaches and methods are required for the purposes of environmental impact assessment and decision making for each system. The tools available for assessment of each system are in different stages of development. Impact assessment methods are mostly site specific in concept and application. Only one, life-cycle assessment, attempts to quantify relevant environmental aspects along the whole chain of the product system. The simple model of the product system advanced here will better permit a clear explanation of the different assessment methods and endpoints and their relationship with the decision-making areas we are focusing on. Major Impact Assessment Approaches There are many approaches to impact assessment, and there are quite a number of terms, some of which overlap when used to describe similar approaches. A simplification is used here. Table 9-1 is a summary of the breadth and depth of impact assessment methods and applicability. It illustrates, for each element of the product system model, the applicable major assessment methods, as well as the endpoints and distinguishing characteristics from the other elements of the model. There are four major assessment approaches that deserve a brief description here. These approaches are either the ones most applicable or the ones subject to controversy and discussion.

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TABLE 9-1 Assessment methods for elements in the product system model Ecosystem Product system Social system Assessment method     Environmental impact assessment Life-cycle analysis, life-cycle inventory Human health risk assessment Ecological risk assessment Extended product stewardship Toxicology Ecology Product stewardship Epidemiology Aquatic toxicology Risk assessment—human health   Environmental toxicology Site environmental impact assessment   Endpoint     Changes in species diversity Source reduction Carcinogenecity Changes in community structure Pollution prevention Genotoxicity Physical destruction Food packaging safety Aesthetic values Wildlife preservation, endangered species Waste minimization Recreational values Forest management certification Energy conservation Property damage An environmental impact assessment (EIA) as demanded by NEPA, includes effects or impacts on ecology (natural resources, components, structures of ecosystems) and human health and on economic, social, and aesthetic considerations. It is a comprehensive concept that requires the use of interdisciplinary approaches. Although deterministic models are used in EIAs, stochastic models that provide an estimate of uncertainty also are acceptable. EIA is not precisely a methodology, but a term developed by NEPA to address the need for assessing impacts by means of already established or new assessment methodologies. Human health risk assessment. Although NEPA resulted in new fields of expertise, such as ecological risk assessment, other statutes and interests have formalized assessment in the areas of human health. In 1983, the National Academy of Sciences recommended that government agencies publish risk assessment guidelines (National Research Council, 1983). The Environmental Protection Agency responded in 1986 with five guidelines covering areas of human health. It is important to realize that here we refer primarily to chemicals that impact on recognized endpoints, a classic toxicologic task. From a toxicological point of view, the Environmental Protection Agency (1986) defines human health risk assessment in terms of four components: hazard identification, dose—response assessment, exposure assessment, and risk characterization. It must be understood that this type of assessment is mostly concerned with discrete chemical or physical stressors on individuals and populations. Ecological risk assessment. The ecosystem and organisms within it are different from human in terms of exposure pathways, metabolic rates, energy flows, and other characteristics. This is why there is a need to address these areas

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under a more specific and applied methodology, ecological risk assessment, in which the degree of complexity and difficulty in obtaining the proper information for a risk assessment is proportional to the rank or level of the organization under consideration (an ecosystem is the highest, an individual is the lowest). Closely connected to ecological risk assessment is ecology itself. The assessment of human effects on the ecosystem must address the impacts and variations that occur even in the absence of human intervention. Ecology has been evolving from a descriptive discipline to one more interested in describing the mechanisms that explain interactions. This transition to an experimental science still needs improvement. Price et al. (1985) call for a more consistent application of the scientific method and for the appreciation for negative data in experimental ecology. Life-cycle analysis is a more recent attempt to assess impact in a whole product system. The methodology was designed to incorporate several phases. The phase in which an inventory of data is gathered uses mass loading expressed in terms of functional units defined for the specific product system under study. Impact assessment has not yet been fully developed, but it attempts to explain the results of the inventory phase by means of stressors—conditions that could lead to impairment of human health or the environment or to resource damage. The Society of Environmental Toxicology and Chemistry (SETAC) advances five methods for assessing stressors for potential harm to human and ecological health: loading assessment; impact equivalency assessment; loading factoring, toxicity, persistence, severity; generic exposure—effect assessment; and site-specific risk assessment. Level 5 will bring us back to more traditional, already developed assessment approaches. SETAC is placing emphasis on developing an acceptable methodology around Level 4. This would lead, at best, to one more of the already existing "ranking" or "scoring" approaches, which perhaps could be used as screening tools for future assessment studies (SETAC, 1993). Still, the lack of exposure data and spatial differentiation of impacts would make unrealistic any application to the forest product system. It is important to recognize that SETAC has admitted that life-cycle analyses cannot be used to predict loss of biodiversity (SETAC, 1993), nor would the stressors indicate a cause-and-effect relationship. A more recent study report on research needs in life-cycle analysis for the European Union (Groupe des Sages, 1995) states that spatial differentiation of impacts is a critical issue specifically as it relates to equivalence factors. Equivalence factors were thought initially appropriate for life-cycle analysis. Spatial differentiation of equivalent factors is another area not yet developed but necessary for use in the attempt to assess forest systems that can encompass various ecosystems. Finally, the nonthreshold

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assumption, well embedded in life-cycle analysis impact assessment, uses the circular reasoning that, although impacts cannot be ascribed to a product or to parts of the product system, the loadings and consumption associated with the system could contribute to impacts and thus must be considered. Ecosystem Of the three elements of our product system model, the ecosystem element requires the most attention. It is undeniable that concerns and interests about how forests are managed are very much present and reflected in public opinion. It is important for all of us to avoid unfounded demands or overexpectations on assessment methods. Decisions made with erroneous inputs or based on exaggerated "cautionary principles" are bound to be inefficient and contrary to the concept of sustainable development. The above discussion cites the reasons for eliminating life-cycle analyses for purposes of ecosystem environmental impact assessment. Most of the comments made here about ecosystems are applicable to the use of other resources, including the use of wood as a raw material. The needed research in these areas would be more efficient and effective if conducted first at the level of generic resource use. This chapter stresses resources and human and ecological values. Nevertheless, forests are valuable for many reasons, such as for recreation, for economic return, for aesthetics, and for their social and cultural importance. Assessments for the purposes of decision making are thus never made on the basis of achieving a single environmental assessment result. As mentioned earlier, the ecosystem assessment presents peculiarities of its own, one of which—the use of organizational levels—deserves special attention. Hierarchy of Organizational Levels When discussing ecosystems, we should keep in mind that the levels of organization of the ecosystem are important. This is a characteristic that distinguishes the ecosystem element from other elements of our product system. The organizational levels are as follows: individual organisms; populations of organisms; communities, groups of populations; ecosystems, communities in a given environment; and regions, groups of ecosystems. The hierarchy is important for impact assessment in more than one sense. First, it introduces a major difference for toxicologic approaches in individual organisms—the classic situation in human health assessment. In nature, individual welfare is subordinated to higher interests. In addition, the endpoints that

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can be defined, and even measured, at any level of the hierarchy, are nevertheless of different importance at each level. This peculiarity creates problems for their practical use in assessment or measurement. Furthermore, the cost and complexity of testing and monitoring at higher levels of the organization, usually populations or larger groups, increases while the precision and accuracy of the data decrease. Finally, temporal and spatial scales are more critical in ecosystems, such as forests, both for stressors and for endpoints, than they are in individual organisms. At a glance, this description of assessment characteristics of ecosystems should indicate the problems in trying to apply a generalized and comprehensive impact assessment methodology that would provide a clear direction for decision making. Life-cycle analysis is not the tool to assess natural resources or land uses because of its lack of spatial differentiation of impacts and time functions. As indicated earlier, experts developed the concept of stressors and specific levels of assessment methods for alternative forest assessments. To implement Level 5, we, of course, do not need to talk so much about life-cycle impact assessment but instead we should evaluate other assessment methodologies, such as those described in Table 9-1. Endpoints And Their Measurement The importance of identifying proper endpoints and their measurement is clear. All use of resources, biotic or abiotic, entails an interaction with an ecosystem or region (group of ecosystems). Let's consider the following as examples of ecosystem endpoints: physical destruction or major alteration, changes in ecological community structure, changes in biodiversity, endangered species selection and protection plan effectiveness, and quantitative sustainability of renewable and nonrenewable resources. It is easier to list these endpoints than it is to reach consensus on their definition and measurement. For that reason, in the area of ecosystem impact assessment there is a dire need to conduct more applied research. Better Assessment of Ecosystems Georgia-Pacific's voluntary efforts on ecosystem protection have as a defined endpoint endangered species protection. This could give the impression that this is a clearly definable and measurable endpoint. That is not the case. The process for listing endangered species in our country is complicated—driven by politics, observation, and some science. When considering the issue of sustainability of resources as an endpoint, the

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complexity increases, perhaps exponentially. Is sustainability a value to be protected or a measurement itself of other values? Sustainability is not an inherent characteristic or property of a resource but the result of a management or policy decision about a resource. In the case of biotic resources, with their inherent and scientifically demonstrated ability to reproduce the consequences of a management or policy decision are reversible. Can the reversibility of given effects make their methodologic assessment inappropriate for decision making? How to treat these differences in defining endpoints should be the subject of comprehensive research for all resource use. Such research would indicate the differences between definable endpoints for biotic and abiotic resources. Measurement Even in the measurement of timber there are different approaches to estimating the amount of merchantable wood on a tract of land or region. The California Area Timber Survey (CATS), the Timber Inventory Growth and Harvest (TIGH) and the Forest Inventory Assessment (FIA) projections are examples of some of these approaches, and they often result in different estimates of timber amounts for the same tract land (Wildland Resources Center, 1993). Resolution of differences is important, but more critical is the decision about their use in estimating long-term, regional system yields. The merchantable wood measurement methods are not balanced for harvest and growth measurements. Harvest and mortality estimates do not establish any preconceived threshold that excludes wood volumes from measurements. Instead, the growth measurement excludes growth smaller than breast height diameters of six or eight inches. Biodiversity Conservation Moving into biodiversity conservation as an ecosystem endpoint could also prove fraught with imponderables. Before experts lay out conservation plans, there is a need to know what to conserve and why. At a given time in the decision-making process, biodiversity conservation areas might need to be defined as a proportion of the country's available land area. Today, around 10.5 percent of the continental United States land area is, to some extent, protected. This proportion is one of the largest for any country in the world. Nevertheless, in these areas biodiversity conservation plans are not fully developed, and where plans exist, there are not suitable ways to have them analyzed. It seems that these areas should be ideal for research and analysis before demanding cross-country demonstration of biodiversity. It is apparent that human intervention creates a reduction in diversity index for specific situations, depending on the severity of such intervention. The perception is that a higher diversity index means a greater number of species and that

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this is good in all circumstances. Nevertheless, the index create a mathematical trap. If the number of species is low but evenly distributed, the diversity index will show high. In addition, the sampling or testing methods can influence results. The notion that low diversity results only from human intervention is not true in all cases. Remmeft (1980) cites the example of central European beech forests as the result of logging. This is not to say that biodiversity is not important, but that it needs to be defined for a given ecosystem or region, at a given time. Miner and Lucier (1993) have discussed these complexities. Measurements Of Biodiversity Protection Plans In terms of measurement, biodiversity offers technical and economic challenges that cannot be ignored. The most recent effort to provide a surrogate for biodiversity measurements is the gap analysis system (Scott et al., 1993). It is intended to identify gaps in the protection of biodiversity in management areas. It is no panacea, and its limitations have been advanced candidly by it proponents. However, it could be expanded to other areas or used as a productive mechanism to anticipate areas needing such management protection. Manufacturing, USE, and Disposal Systems In the processing of raw materials, resources are consumed and environmental loadings—in the form of emissions, releases, or both—take place. Both in the paper and in the wood product system, chemicals are released into the environment at different stages of the product system. Impacts could occur in ecosystems other than forests, such as woodlands, desert areas, or in regions composed of different ecosystems. For those cases, the earlier discussion on ecosystems is applicable. Product Stewardship We have spent considerable time on the issue of ecosystem impact assessment as applied to decision making because it is by far the most complex impact assessment for purposes of decision making. By definition, product stewardship involves understanding the resources consumed and the environmental, safety, and health impacts of the products we manufacture, to ensure these impacts are controlled or minimized (Galeano, 1995). As depicted in Figure 9-2, product stewardship relies on two assessment tools: risk assessment and life-cycle analysis. The most traditional human health risk assessment techniques are applicable either at the manufacturing site or during distribution, use, and disposal of the product. It is possible to say that regardless of the debate about these assessment tools, they provide input that is to a large degree adequate for decision making.

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Figure 9-2 Product stewardship. Extended Product Responsibility The concept of extended product responsibility (EPR) considers the entire life-cycle of a product, from design to disposal, to identify opportunities for resource conservation and pollution prevention. EPR is based on the principle of shared responsibility among suppliers, manufacturers, users, disposers, and policy making entities (legislatures, regulatory agencies). The greater opportunity for stewardship rests in the links of the product chain with the greater ability to influence the life-cycle impact of the specific product system. In the upcoming report of the president's Commission on Sustainable Development, EPR is the second policy recommendation of the commission. This is the result of lengthy and careful examination of new concepts and approaches in policy making and with the participation of a wide representation of interest groups and government representatives (Galeano et al., 1995). This new concept is based on the search for more ''ecoefficient'' approaches, and it requires impact assessment methodologies to help in decision making. Figure 9-3, which depicts the position of EPR in a structure for sustainable development, illustrates the need for assessment tools in reaching decisions. All of the above discussion on methodologies and the balancing of competing factors is applicable to EPR in a more complex fashion. Life-Cycle Inventory Analysis Life-cycle inventory analysis is a useful portion of the analysis of a product system as presented in Table 9-1. The inventory phase of life-cycle analysis methodology provides information that, with proper qualifiers and interpretation, will be useful for manufacturers and business in general. Lately, for forest prod-

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Figure 9-3 Expanded product responsibility within the sustainable development structure. ucts, the inventory methodology has been enhanced to better reflect characteristics and operational features particular to our products and operations (Galeano, 1996b). Table 9-2 lists the six basic enhancements, which make possible a more credible and reasonable interpretation of results from the inventory phase. They also provide the conceptual framework under which system boundaries are drawn in a manner that justifies the proper expression of important forest products characteristics and operational factors. For example, extending the boundaries of the product system to the seedling allows for interpretations about CO2 sequestration. renewability of the raw material, renewability of the biomass energy, and allocations for coproducts and recycling. In this sense, the life-cycle inventory is about a trade-off. In the context of product stewardship, it is a tool that helps in decision making. Source reduction, pollution prevention, waste minimization, and resource conservation could benefit from proper life-cycle inventory studies. Beyond that, efforts to use the in- TABLE 9-2 Enhancements to the life-cycle inventory Proper product system boundaries to justify Renewability of the material Renewable biomass energy Carbon dioxide sequestration Solid-waste management practices Allocation procedures Interpretation of results

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ventory as a tool to establish a product's overall environmental superiority or preferential purchases have not been successful. The methodology can assess, in a comparison, specific parameters and reach qualified comparative assertions between products. Conclusions The above analysis permits several conclusions: The implications of impact assessment for decision making about wood as a raw material and about its products can be better ascertained by evaluating a model of the entire product system. No single method of impact assessment alone can provide the input for final decision making. Rather, balancing environmental, economic, technical, and societal values will provide the best sustainable development decision. Environmental impact assessment approaches are applicable to different elements of the product system model. Not all assessment approaches are applicable to the entire system. The different endpoints and biologic organizational levels in each system impede the use of a one-size-fits-all assessment methodology. Life-cycle analysis, in its inventory phase, is a tool with potential for analysis of trade-offs and hypothetical situations. The impact assessment phase, even if an appropriate methodology is developed, will not be of use in evaluation of ecosystems. For wood products, specific enhancements in the life-cycle inventory methodology are in development to properly reflect characteristics of biotic resources. Only in this manner will life-cycle inventories be useful for wood products assessment in product stewardship and extended product stewardship situations. Impact assessment approaches applicable to ecosystems are eminently site specific and eventually consist of different subelements or approaches. Their input into decision making is piecemeal and still subject to improvement. No single risk assessment approach can cover all of the major recognized endpoints. We have advanced examples of areas for future research to improve evaluation of ecosystems and in particular of the forest. They are given to focus attention on their need. Certification of forest management schemes should not factor in requirements that involve assessment endpoints for which the methodology and measurements have not yet been developed. References Code of Federal Regulations, Section 1508.8, Parts 1500 to 1508. Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA). Cohrssen, J. J., and V. T. Covello. 1989. Risk Analysis, Council on Environmental Quality, NTIS O.N., PB 89-137772.

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Environmental Protection Agency. 1986. The Risk Assessment Guidelines of 1986.51 FR 33992–34054. Washington, D.C.: Government Printing Office. Galeano, S.F. 1995. Product stewardship. Proceedings Technical Association of Pulp and Paper Industry (TAPPI) International Environmental Conference, Atlanta, Georgia. Galeano, S. F. 1996a. Extended product stewardship. Proceedings Technical Association of Pulp and Paper Industry (TAPPI) International Environmental Conference, Atlanta, Georgia. Galeano, S. F. 1996b. Enhancements of the LCI methodology to reflect forest products characteristics. Proceedings Technical Association of Pulp and Paper Industry (TAPPI), American Forest and Paper Association (AF&PA), National Council of the Paper Industry for Air and Stream Improvement (NCASI) Symposium on LCA Applied to Forest Products. Atlanta, Georgia. Galeano, S. F., G. Davis, and F. H. Brewer. 1995. Extended Product Responsibility. Draft proposal to PCSD's Eco-Efficiency Task Force. Groupe des Sages. 1995. Research Needs LCA for Ecolabeling. Report to the European Union Commission. Leiden University, Centre of Environmental Science. Miner, R., and A. Lucier. 1993. Considerations in Performing Life-Cycle Assessment in Forest Products. NCASI technical paper 93-01. National Environmental Policy Act of 1969 as Amended. Public Law 91–190, 42 U.S.C., Section 103. National Research Council. 1983. Managing the Process: Risk Assessment in the Federal Government. Washington, D.C.: National Academy Press. Price, P. W. et al. 1985. New Ecology. New York, NY: John Wiley & Sons. Remmert, H. 1980. Ecology. Springer-Verlag. Scott, J. M. et al. 1993. GAP Analysis: A Geographic Approach to Protection of Biological Diversity. Wildlife Monographs, No. 123. The Wildlife Society (Jan.). Society of Environmental Toxicology and Chemistry. 1993. A Conceptual Framework for Life-Cycle Impact Assessment. March, p. 51. Sutter, G. W. 1993. Ecological Risk Assessment. Lewis Publishers. Wildland Resources Center. 1993. Timber Industry Growth and Harvest Study—Final Report from CDFFP Contract 8CA06732. University of California. World Commission on Environment and Development. 1987. Our Common Future. Oxford University Press.