1. Use of a Net Environmental Benefit Analysis (NEBA) Approach in Demonstrating and Maximizing the Benefits of Site Cleanup Joe Nicolette Vice President EcoValuation Practice Director

2. Agenda NEBA – Background and Overview Evaluation Metrics In the Context of Site Cleanup and Reuse Maximizing Metric Values During the Remedial Alternative Evaluation Process NEBA Pilot Study for USEPA –Post-Remedy Sites (Metric Evaluation) –Active Site (Approach for Maximizing Benefits) NEBA – Background and Overview Evaluation Metrics In the Context of Site Cleanup and Reuse Maximizing Metric Values During the Remedial Alternative Evaluation Process NEBA Pilot Study for USEPA –Post-Remedy Sites (Metric Evaluation) –Active Site (Approach for Maximizing Benefits)

3. What is a Net Environmental Benefit Analysis (NEBA)? Analytical framework to quantify and compare the ecosystem service benefits and/or losses associated with an action (e.g., remedial action, site re-development design) –Using formally quantified values Goals include: –Quantify the ecosystem benefits of an action; –Compare benefits between actions; –Modify action to maximize the benefit –Encourage the selection of actions that offer the greatest ecosystem service benefits to the environment and public. Analytical framework to quantify and compare the ecosystem service benefits and/or losses associated with an action (e.g., remedial action, site re-development design) –Using formally quantified values Goals include: –Quantify the ecosystem benefits of an action; –Compare benefits between actions; –Modify action to maximize the benefit –Encourage the selection of actions that offer the greatest ecosystem service benefits to the environment and public.

4. Habitat Direct Human Uses (e.g., Recreational, Commercial) Bird watching Fishing Swimming Hunting Commercial Fishing Existence value Aesthetic value Preservation of diversity T&E spp Passive Use Ecological Nesting Area for Birds Breeding Area for Fish Sediment Stabilization Water Quality Enhancement Many Others Services Functions a natural resource (e.g., habitat) provides for other resources and for humans. Ecosystem Services

5. Ecosystem Functions Ecosystem Services RegulatingClimate and Atmospheric Regulation Disturbance Moderation Freshwater Regulation Waste Treatment Biological Control Habitat Refuge SupportingNutrient Regulation Soil Formation and Retention ProvisioningFood and Raw Materials Water Supply Genetic and Medicinal Resource Pollination Ornamental Resources CulturalRecreation and Amenity Inspirational and Historic

6. Table 1. The general effect of an action can be evaluated.

7. Comparing Environmental Values (Cost Benefit Analysis of Design/Site Alternatives) % Services Years Baseline Services

8. Comparing Environmental Values (Cost Benefit Analysis of Design/Site Alternatives) % Services Years Baseline Services B1

9. Comparing Environmental Values (Cost Benefit Analysis of Design/Site Alternatives) % Services Years Baseline Services B2 B1

10. Comparing Environmental Values (Cost Benefit Analysis of Design/Site Alternatives) % Services Years Baseline Services B3 B2 B1 Develop $/credit Fiscal merit Conservation/natural resource benefits

11. EPA Study - Benefits of Cleanup EPA needs a way to demonstrate the benefits associated with its cleanup program Recent attempts have met with criticism (e.g., house prices, NRDA settlements) Policy Analysis and Regulatory Management Staff, OSWER Benefits Quantification Study EPA needs a way to demonstrate the benefits associated with its cleanup program Recent attempts have met with criticism (e.g., house prices, NRDA settlements) Policy Analysis and Regulatory Management Staff, OSWER Benefits Quantification Study

12. Project Purpose and Scope Post-Remediation (“mature”) Sites –Homestead Air Reserve Base –Rocky Mountain Arsenal –For several metrics, quantify values for the “with” and “without” remediation condition…a NEBA with two alternatives –Evaluate the potential for each metric to express benefits Post-Remediation (“mature”) Sites –Homestead Air Reserve Base –Rocky Mountain Arsenal –For several metrics, quantify values for the “with” and “without” remediation condition…a NEBA with two alternatives –Evaluate the potential for each metric to express benefits

13. Metrics Ecological Service Value (services per acre per year in dSAYs) Human Recreation Use Value (User Days) Human Recreation Use Value ($$$) Ecological Service Value ($$$ per acre) Economic Measures (e.g., tax revenue increases) Ecological Service Value (services per acre per year in dSAYs) Human Recreation Use Value (User Days) Human Recreation Use Value ($$$) Ecological Service Value ($$$ per acre) Economic Measures (e.g., tax revenue increases)

15. Benefits of the Air Force Remedies Water and sediment quality increases in Boundary and Outfall Canal Reductions in risk to macroinvertebrates; increase in prey base Improvement in habitat for rare species Reduction in freshwater pulse to Biscayne Bay Wetland restoration Waste assimilation associated with wetlands Cultural service – education opportunities with pilot wetland Incremental improvement to Biscayne Bay National Park Land redevelopment opportunities Water and sediment quality increases in Boundary and Outfall Canal Reductions in risk to macroinvertebrates; increase in prey base Improvement in habitat for rare species Reduction in freshwater pulse to Biscayne Bay Wetland restoration Waste assimilation associated with wetlands Cultural service – education opportunities with pilot wetland Incremental improvement to Biscayne Bay National Park Land redevelopment opportunities

16. Maximizing Benefits Incorporation of a NEBA Approach into the Remedial Alternative Selection Process

17. Table 1. The general effect of a design, including remediation, can be evaluated.

18. Marginal Risks/ Uncertainty C leanup to Criterion (Cost/Benefit) Effort/Cost ($) Concentration/Risk Criterion Level High Risk Areas Lower %Higher % Larger Reduction in Risk Smaller Reduction in Risk Provides formal basis for alternative selection using quantifiable metrics Allows For offsetting restoration Assists with risk management decisions NEBA: Compares residual risks in marginal areas to gains from alternative implementation

19. When to consider a NEBA? Balance of risks and benefits of remediation are ambiguous –Site retains significant ecological value –Remediation will cause environmental damage –Ecological risks are small, uncertain, or limited –Remediation or restoration may fail or not truly change risk scenario –Costs appear disproportionate to changes in the risk scenario Balance of risks and benefits of remediation are ambiguous –Site retains significant ecological value –Remediation will cause environmental damage –Ecological risks are small, uncertain, or limited –Remediation or restoration may fail or not truly change risk scenario –Costs appear disproportionate to changes in the risk scenario

20. Case Study: NEBA Used to Compare Natural Attenuation and Sediment Dredging Estuarine system Lead contamination Hot spot removal conducted AO stipulated dredging of residual risk areas Evidence of limited risk Evidence of attenuation Used NEBA to compare remedial alternatives Estuarine system Lead contamination Hot spot removal conducted AO stipulated dredging of residual risk areas Evidence of limited risk Evidence of attenuation Used NEBA to compare remedial alternatives

21. Residual Risk Area: Natural Attenuation The red area represents marginal risks (“potential” injury) associated with the no- action alternative 0% 25% 50% 75% 100% % Services Baseline 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Year 30 Acres Affected - 50 Net dSAYs Marginal Risk Note: Hot spot removal already conducted

22. Dredging Impacts 0% 25% 50% 75% 100% % Services Baseline 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Year 30 Acres Affected - 40 Net dSAYs Note: Hot spot removal already conducted

23. Natural Attenuation with Restoration (Balance Risks) 0% 25% 50% 75% 100% % Services Baseline 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Year Debit = - 50 dSAYs Credit = +166 dSAYs NET = +116 dSAYs A Certain Gain An Uncertain Loss Note: Hot spot removal already conducted

24. NEBA Table Remedial Action Cost ($) Net Envir. Benefit Dredging 16 M $ -50 dSAYs +10 dSAYs Net -40 dSAYs Natural Attenuation 0.5 M $ -50 dSAYs Natural Attenuation With Restoration 1.0 M $ -50 dSAYs +166 dSAYs Net +116 dSAYs

25. Evaluating NEBA Alternatives (the Win-Win Solution) Scale of Effort No Further Action Alternative A “Win-Win” Alternative B A NEBA can demonstrate that a third alternative, a “Win-Win” solution, may exist that maximizes environmental benefit while maintaining protection of human health and the environment.

26. NEBA Consistent With Regulatory Guidance Examples: –DOI-EPA Guidance –EPA’s Ecological Benefits Assessment Strategic Plan –Risk Management Objectives –OSWER Directive 9285.7-28 P 1999 –State rules (e.g., Texas risk reduction rules, ESA provision) –Interstate Technology and Regulatory Council (ITRC) Examples: –DOI-EPA Guidance –EPA’s Ecological Benefits Assessment Strategic Plan –Risk Management Objectives –OSWER Directive 9285.7-28 P 1999 –State rules (e.g., Texas risk reduction rules, ESA provision) –Interstate Technology and Regulatory Council (ITRC)

27. Risk Management Objectives EPA Superfund ERA Guidance (Step 8) –“The risk manager must balance (1) residual risks posed by site contaminants before and after implementation of the selected remedy with (2) the potential impacts of the selected remedy on the environment independent of contaminant effects.” –“In instances where substantial ecological impact will result from the remedy (e.g., dredging a wetland), the risk manager will need to consider ways to mitigate the impact of the remedy and compare mitigated impacts to the threats posed by the site contamination.” EPA Superfund ERA Guidance (Step 8) –“The risk manager must balance (1) residual risks posed by site contaminants before and after implementation of the selected remedy with (2) the potential impacts of the selected remedy on the environment independent of contaminant effects.” –“In instances where substantial ecological impact will result from the remedy (e.g., dredging a wetland), the risk manager will need to consider ways to mitigate the impact of the remedy and compare mitigated impacts to the threats posed by the site contamination.”

28. For Maximizing Benefits, Fit NEBA into the FS Process NEBA should be conducted after RA process Supplements 9 NCP evaluation criteria Could be done as part of FS Could be included as an appendix or referenced NEBA should be conducted after RA process Supplements 9 NCP evaluation criteria Could be done as part of FS Could be included as an appendix or referenced

29. Project Purpose and Scope Conduct a NEBA at an active site where stakeholders are beginning the FS process For remedial alternatives, net change in… –ecological services (dSAYs) –human use value (user days and $$$) Will provide information that stakeholders can use when selecting a remedy Searching for candidate sites! Conduct a NEBA at an active site where stakeholders are beginning the FS process For remedial alternatives, net change in… –ecological services (dSAYs) –human use value (user days and $$$) Will provide information that stakeholders can use when selecting a remedy Searching for candidate sites!

30. Benefits Maximize benefits to public Reduce costs (private and public $) Expedite site closures Manage existing and potential long-term risks Create and manage natural resource assets for current or future use Facilitate good relationships with stakeholders (public and private sectors) Maximize benefits to public Reduce costs (private and public $) Expedite site closures Manage existing and potential long-term risks Create and manage natural resource assets for current or future use Facilitate good relationships with stakeholders (public and private sectors)

31. Joseph P. Nicolette Vice President, CH2MHILL EcoValuation Practice Director Atlanta, Georgia Office: 770-517-9154 joe.nicolette@ch2m.com Questions