Ecological Risk Assessment ------- Ecological Risk Assessment1 Robert T. Lackey1 Environmental Research Laboratory U.S. Environmental Protection Agency 200 SW 35th Street Corvallis, Oregon 97333 The Issue A short time ago, the President, Vice President, six cabinet secretaries, the administrator of the Environmental Protection Agency, four governors, and a cast of thousands met for a full day to resolve an ecological issue that has created gridlock in the Pacific Northwest. Ecological issues -- and ecological risk assessment ~ have moved from the fringes of science and policy to center stage. Some observers even propose that formal risk assessment be the core organizing principle for all ecological management and protection. Papers on "risk assessment" are now found in many ecological 1 Adapted from a presentation given at a symposium "Cntical Issues in Risk Assessment and Management," Tulane University, New Orleans. Apnl 13-14, 1993 This manuscript has been submitted to Fisheries, Bulletin of the American Fisheries Society, for possible publication This paper has been subjected to scientific peer review, but does necessanly reflect policy positions of the Environmental Protection Agency. 2Dr Lackey is Deputy Director of EPA's Environmental Research Laboratory, located in Corvallis, Oregon The Laboratory conducts a national and international research program on a variety of ecological and nsk assessment problems Dr Lackey holds a courtesy professorship at Oregon State University in his academic specialty, fisheries and wildlife science He also serves as Associate Director of the Center for Analysis of Environmental Change, a joint research unit of Oregon State University, the EPA Corvallis Laboratory, the Forest Service Pacific Northwest Forest and Range Experiment Station, and Battelle Pacific Northwest Laboratories ------- Robot T. Lackey Ecological Risk Xsstannent ^ Sapumbor 8. 1993 journals. Entire books on ecological risk assessment have been published within the past year. The previous two EPA administrators have given major policy talks on the subject. Congressional committees have publicly endorsed the concept as the approach of choice. The National Academy of Science has commissioned panels of experts to pass judgement on the merits of the concept and it's application. Conversely, there has been a different view — less charitable: risk assessment is a form of techno-speak that will be used to justify the destruction of more and more of our nation's natural environment. Further, risk assessment is a tool used by the scientific and technical elite to impose their values and priorities on the general public under the guise of scientific objectivity. Ecological risk assessment in this view is undemocratic at best ~ immoral at worst. The sudden interest in ecological risk assessment is a dramatic development. Clearly something has changed, and changed quickly and profoundly. There are several reasons. My purpose here is not to be an advocate for, or be a detractor of, any of the various assessment concepts, approaches, or procedures, but to summarize the issues. How Well Are We Doing? How well are we doing in developing and implementing public policy to protect ecological resources? The fundamental measure of success in any ecological protection regulation is: how well are the resources in question doing. How well are we doing? First, and most important, many people feel that the condition of ecological resources in this country has deteriorated in spite of all our best efforts. For example, tall grass prairie ecosystems have disappeared. The acreage of wetlands in the United States has declined precipitously. A number of species, such as the northern spotted owl, Florida panther, ------- Robert T Lackey Ecological Risk Assessment O September 8. 1993 and California condor, are struggling for their very existence. Biological diversity is purportedly declining throughout much of the nation. Others have a different view. The quality of our ecological resources is actually improving. Some species may be endangered, but we are generally doing a good job of balancing competing societal demands. Where we do deviate from carefully thought-through decision making, it is often because "scare tactics" have been used to sway the process and, as a result, irrational and excessively costly environmental protection decisions have been made that are counter to the best interests of the majority. Things aren't perfect, but they are getting better. With such divergent views, you might wonder if it is the same planet that is being evaluated! Risk assessment is often offered up as a formal and systematic procedure to forge consensus from these very divergent opinions about the status and trends of our ecological resources. A second stimulus for the development of risk assessment is the sheer cost of complying with environmental regulations. Since the formation of the Environmental Protection Agency in 1970, the total cost of complying with environmental regulations has been one trillion dollars. Annual compliance costs are now somewhere between $125 and $150 billion. I am not saying that we necessarily need fewer regulations, but those we do have, cost a lot of money. The type of regulation being used is also changing. Command and control regulations were typical when pollution problems were fairly straight-forward in the 1960s and 1970s. More recent environmental problems require changes in human behavior if pollution is going to be reduced. Such tools as the tax code, land use laws, and market incentives are costly and they often are very intrusive. For example, few people appreciate a government agency telling them what they can and cannot do with their property. ------- Robert T Lackey Ecological Ride Assessment 4 September 8, 1993 Whether it is the total cost of complying with environmental regulations, or the intrusiveness of some of the newer types of regulatory approaches, a formal procedure that could evaluate regulatory effectiveness would be very useful. Is the money being spent on regulations doing as much good as it should? If government must intrude in our lives to protect the environment, is it actually protecting the most important ecological resources? Risk assessment offers at least the potential of answering these questions in an objective way. A third stimulus is the question of priorities, illustrated by a recent EPA exercise. A committee of scientific experts appointed by the EPA Administrator evaluated the risks facing ecological resources in the United States, and ranked them in order of risk from greatest to least. The top four were habitat alteration, global climate change, stratospheric ozone depletion, and decrease in biological diversity. The presence of these four at the top of the list was a real surprise to many. Even more surprising were the issues ranked lowest by the experts — the effects of herbicides, pesticides, acid deposition, airborne toxics, oil spills, and groundwater pollution. The disconnect between ecological risk as defined by the experts, and risk as defined by the focus of current regulatory efforts, is striking. According to the panel, we are spending our money, time, and energy on ecological risks of lesser importance. Formal risk assessment has the potential to carry the ranking process much further. Theoretically, we could focus our regulatory efforts on threats thought to pose the greatest risk. With a given level of dollars or intrusion into people's lives, we could obtain the maximum ecological payoff. A fourth stimulus is uncertainty. Scientists and policy analysts are generally not effectively conveying ecological options to decision makers and the public. Conveying uncertainty is clearly difficult. Conveying the importance of the interconnectiveness of ecological systems and human uses is another difficulty. ------- Robert T Lackey Ecological Ridt Asssssmeni Q September 8. 1993 For example, if the question arises as to the ecological consequences of moving toward alcohol-supplemented gasoline to help decrease our dependence on oil, how do we convey the ecological consequences of this to decision makers in a way that is useful? Burning alcohol produces byproducts that will have ecological effects. Putting more land into agricultural production to grow more corn to produce alcohol will have additional ecological effects. Runoff from these new corn fields will affect streams and rivers. Converting wetlands to corn fields to grow more corn will have additional consequences for migratory waterfowl. Very quickly, everything is related to everything else and nothing makes sense without extensive study, or we must rely on the subjective opinions of scientific or policy experts. Formal ecological risk assessment has a lot of appeal for addressing these kinds of problems in an organized way. We all know that there is no free lunch in ecological systems or decision making. The trouble is that the cost of lunch is often very difficult to determine, and may be nearly impossible to explain to someone. Risk assessment is often touted as a tool to solve this problem. A fifth stimulus for applying formal risk assessment is to try to break decision-making gridlock. For example, the public forests of the Northwest are nearly shut down in many places due to various law suits over endangered species and other environmental issues. The use and abuse of science in courts and other forums is rampant. The public, perhaps most of us, doesn't know who to believe. Are northern spotted owls truly going the way of the dodo bird, or is the concern for the spotted owl just a vehicle that environmentalists are using to achieve a more fundamental political objective? Or, are industry and timber workers using the spotted owl as an excuse for problems caused by automation and harvests in excess of the rate of regeneration? The public must form opinions, but does so without great confidence in the available scientific and technical information. The issue tends to get couched in jobs vs. owls. Risk assessment might be able to bring some consensus on difficult public choice issues such as this. ------- Robert T. Lackey Ecological Ride Assessment O September 8, 1993 A sixth reason deals with the programmatic performance measure of the benefits of regulatory choices — specifically who should receive them? One charge is that the affluent drive decision-making in managing and protecting ecological resources. In the bureaucratic jargon of the day, this is "environmental equity." Should environmental programs primarily benefit the upper middle class? Or should environmental decision-making be democratized? "Environmental justice" is the rallying cry. Can ecological risk assessment help? What about benefits for this generation vs. future generations? In ecological terms, how do you compare the alternatives over time? Risks of ecological catastrophe may be small in any one year. Over 50 years things look much riskier. Over 200 years they make look absolutely frightening. There is no simple analog to the discount rate, which actually may be a good thing. And, of course, who are the losers and how much should they be compensated? The legal "taking issue" is very important in protecting ecological resources. If Government must "take" a piece of property, then there had better be a very defensible reason — preferably a formal, objective one. Risk assessment might be very useful in providing that justification. Why Risk Assessment? Why conduct risk assessment for ecological problems? Assessing risks has an intuitive appeal to most people. If we can Quantify risks, or at least rank risks, we can allocate our efforts and regulations toward protecting those ecosystems under greatest threat. After all, there has been a general acceptance of this approach for health risk assessment — why not for ecological resources? Before we become too complacent let me point out that one prominent environmentalist has recently called decisions based on risk assessment the moral equivalent of murder. The same thought process leads to the conclusion that risk assessment applied to ecosystems is ------- Robert T Lacks? Ecological Ride Assessment 7 September 8. 1993 equally unacceptable. I will not spend any time discussing this philosophical position, but its importance and influence in current ecological debates, such as the Northwest forest and salmon faceoffs, should not be underestimated. Which Paradigm to Follow? Which paradigm should we follow? Once a basic risk assessment paradigm is defined and accepted, many of the scientific and technical issues will fall into place. We ecologists usually don't spend enough time on paradigm selection, but usually jump right into arguing about details in the techniques of conducting assessments. The tried and true paradigm is the basic political process — sometimes pejoratively referred to as "muddling through." The strongly rational amongst us often do not trust this process. Decisions are rarely cost effective. Efficiency is not of great importance. Compromise between competing views often appears to take the worst from each. In short, the process offends our — at least among scientists — sense of order or rationality. A second basic, but very different, approach would be to follow the insurance analog. After all, if uncertainty is the problem, then there is a good record of success in the insurance business. The average person can relate to this. There is a large body of procedures for measuring risk for all kinds of activities. The problem with this approach is that very few ecological risks can be measured with any accuracy. I am always struck by the despondent look that comes across the face of a policy analyst when he realizes the broad confidence intervals on all the ecological predictions that we ecologists are even willing to provide. The third approach is the human health analog. In this approach we generally define the human and the ecosystem as the analogous items at potential risk. Using this analog it is easy for most of us to ------- Robert T Lackey Ecological Ruk Assessment 8 September 8. 1993 understand risk as applied to ecosystems. The approach works pretty well when applied to simple ecosystems exposed to single stresses where one species can be used as a surrogate — say bobwhite quail used as a surrogate for agroecosystems. The problem is that bobwhite quail do not respond to a chemical in the same way that an entire agroecosystem does. And chemical stressors are just one of many stressors. In most cases chemicals are not the most crucial cause of ecological changes. Remember the ranking of risks to ecological resources (habitat alteration, global climate change, stratospheric ozone depletion, and loss of biological diversity). To use this analog, we must simplify ~ often to the point where the relevance of the results may be in question. Another critical problem is that, contrary to individual humans who die, and in most cases people think this is a bad situation, ecosystems change dramatically over time, have no optimal condition, and are only healthy when compared to some desired state specified by humans. Ecosystem "health" is strictly an anthropocentric term. Fundamental Assumptions There are two core views of the world that compete for the basic assumption of ecological risk assessment. The first, most comfortable to most us and the most amenable to scientific information, is the assumption that all benefits of decisions affecting ecological systems are accruable to humans — the human- centered view of the earth and it's biotic resources. To be sure, we may preserve wilderness that few visit, protect from extinction obscure species that have no demonstrated utility, and spend vast sums to restore habitats for species of very limited economic value. All these efforts provide benefits to people — the benefits may be non-economic, may be non-monetary, may only be to buy some ------- Robert T Lackay Ecological Rui Amassment 9 September 8. 1993 indeterminant form of future insurance, but they all benefit man. Nature may benefit, but only as a byproduct of the primary decision. The entire regulatory framework to protect ecosystems is set up under this assumption. We protect biodiversity because some people feel that bad things may happen to future generations if we don't. We preserve wilderness areas because just knowing that unaltered ecosystems exist has value to people. The alternate world view is ecocentered. This is the realm of deep ecology and certain religious or philosophical creeds. It is often called earth-centered. The basic tenet is that benefits accrue to all species — humans are only one species and are no more important than the others. Thus all species are equal. We protect ecosystems because all animals and plants have a right to exist. The importance of biodiversity is because it is morally right, not because biodiversity might be important to man. Risk assessment is an anathema to those holding this view. The mere discussion of ranking risks to ecosystems would be similar to deciding which humans should live and which should die. The intensity of the debate over the morality of aborting humans is similar. The debate is morally based; rational argument plays little or no role. From this philosophy comes uncomfortable questions such as: "should we be subjecting thousands of animals to suffering so the fragrances of our shampoos do not sting our eyes?" It is easy to dismiss this view in a room full of rationalists, but the ecocentric view is becoming increasingly important in the political process. For those individuals who hold an ecocentric worldview — or those who lean in this direction ~ risk assessment will not be useful. In fact it will likely be perceived as a form of ecological triage. ------- Robert T Lackey Ecological Ride Assessment 10 September 8. 1993 Approaches to Assessing Ecological Risk What then do we mean by ecological risk? Risk implies that there is a "desired" condition and a "less desired" condition. Human values define both. Terms like degraded, destroyed, and sick imply an undesired ecosystem state. Perhaps a more accurate term for this paper would be ecological "consequence" analysis rather than ecological "risk" analysis. I have always been envious of scientists working in health risk assessment because there is a generally accepted view that healthy humans were clearly better than sick ones — that living humans were generally better than dead ones. In ecological risk assessment a corn field, a short grass prairie, a mountain lake, a river flowing through southern Louisiana, are only healthy when compared to the desired condition of those ecosystems. They all may be healthy or may all be degraded. There are a half-dozen or so basic tools that are used to conduct risk assessments. Each has many variations. Many risk assessments use a combination of these approaches. First, the most commonly used approach is the bioassay and its many, many permutations. The basic idea is simple and straight- forward. There is a stressor of concern, usually a chemical. A surrogate for an ecosystem is selected — often a species of fish, a representative bird, or perhaps a combination of plants. The chemical is tested for toxicity, usually under laboratory and highly controlled field conditions. The basic approach is very similar to the animal tests run in health risk assessment. The assumptions are that the chemical exposure applied under laboratory or controlled field conditions can be related to that found in nature, that the surrogate animals or plants represent the ecosystem or ecosystems of concern, and that a factor can be added to allow for a ------- Robert T Lackey Ecological Ride Assessment 11 Stpwmber 8. 1993 margin of safety — whatever the concept of "safety" means in ecology. This approach has some real advantages. It is relatively simple to use. It is easy to understand. There is a large data base for many chemicals and many species. There are many laboratories and qualified people who can perform these kinds of tests. And it is very similar to the data used in health risk assessment The problems with the approach are also readily apparent. It works best for chemicals but many, perhaps most, of the major risks to ecosystems are from stressors other than chemical. It assumes that a simple surrogate (one or a few species) will respond in the same way as an ecosystem. It does not work well in complex ecosystems, over large regions, or with chemicals that cause low level, but persistent ecological effects. In short, it works well for a very narrow, though important, set of concerns. A second approach is the environmental impact analysis and its derivatives. This approach has generally been used to assess the ecological risk of "projects" such as proposed dams, highways, logging, and so on. The approach involves identifying the ecological consequences of the various options without value judgement. It may be somewhat quantitative or simply a best guess. The heyday of this approach was in the 1970s. Many variants were developed, particularly to add a sense of quantification and standardization. In practice, the "process" of developing the environmental impact statement often became more important than the actual document and its conclusions. Environmental impact statements are often described now in terms of the number feet of shelf space occupied. Volume of information is often inversely related to the confidence that ecologist's have in the accuracy of the predictions. The more confident we are in what will happen, the shorter the document. The real advantage of environmental impact analysis is that the full ------- Robert T. Lackey Ecological Ride Assessment 12 September 8. 1993 range of ecological effects can be addressed. All types of data can be included. Lack of good predictions is the major disadvantage. A third approach is the use of models. This approach tends to be heavily quantitative with use of computers, mathematical analysis, and, more recently, geographic information analysis, visualization, and animation. This approach rapidly caught on widely in the late 1960s and early 1970s. Some of the luster has dulled because several very famous models turned out to make terribly inaccurate predictions — one prominent example is the Club of Rome 1972 model that predicted worldwide famine and environmental disaster within a decade, at least according to their critics. Others examples abound. Proponents are often as strident as critics. There are some real advantages of a modeling approach to ecological risk assessment. Complex ecological systems can be evaluated. The most sensitive data and relationships can be identified through sensitivity analysis, and then data collection efforts focused on acquiring the most critical missing data. A fourth approach is the use of expert judgement. It can be used alone or in combination with others. In a sense this is the original approach to risk assessment. Find a technical expert that you trust and have him estimate the risk of the stressors of concern. More recent modifications have focused on organizing expert opinion in a way that provides consensus results, or even quantitative results. An appropriate example is the "panel of technical experts" assembled by EPA to rank ecological risks. This example also illustrates a potential problem ~ the "experts" ranked risks very different than did the general public. The experts gave bottom ranking to hazardous waste and chemical pollution. The public gave top ranking to the same risks. Political choice, the^/r approach, is the tried and true decision- making method in a democracy. It is strongly value laden. Scientific information and scientific "truth" may or may not have a significant role. ------- Robot T. Lackey Ecological Risk Assessment 13 September 8, 1993 It is able to resolve almost any type of issue — those few that it fails at, turn out to be civil wars. Many scientists are offended by this approach because answers are almost never "right." The 20-year acid rain controversy is a good example of the use and misuse of science in the political process. The final approach to ecological risk assessment is the most difficult to describe and appreciate ~ at least for rationalists like me — the ecocentric approach. It as a totally alternative approach. "Ecocentric" is not really a great descriptor — neither is deep ecology — an alternative one. In this view, benefits do not all accrue to man. All species receive benefits. Decisions tend to be made on what is right, not what analyses tells us is optimal, most probable, or most efficient. One example of the concerns that people who hold these views may have is that language is power (jargon, if you will), and that language keeps the public out of the decision-making process. Generally you cannot participate in ecological decision-making unless you know the jargon. Simple, moral questions get lost in the language of the technocrats. The process of risk assessment and risk management can (and does) control the language of the discussion, and thus disenfranchises those who do not speak the language, or trust the people or institutions who do. Another example of concern is the charge of "speciesism." This concern hits close to home with me. For example, there are 50 million pet dogs in the United States — what is more American than having a pet dog? An ecocentric view is that pet ownership is slavery. One species has enslaved another. Worse, pets do not help us meet our survival needs, but are merely kept for personal gratification. It is easy to make fun of these views and show how illogical they are to rationalists like probably most readers, but when we spend ------- Robert T Lackey Ecological Ride Assessment 14 September 8. 1993 millions of dollars to save three whales stranded in shelf ice in Alaska, as happened several years ago, any rational analysis would have shown that this taxpayer money was totally wasted. Yet at the same time we cause thousands of rabbits to suffer painful corneal lesions, infections, and pain so that our eye shadow doesn't make our eyes red, though some spend twice as much and buy "cruelty-free" products. All of us are a mixture of both human-centered and ecocentered worldviews — only the ratios vary. Future Research Needs in Ecological Risk Assessment What kind of research is needed to help solve current and future ecological problems? The most important research needed is not easy to define, much less fund. Worse, it is usually not safe research — especially for scientists early in their careers and attempting to build reputations. Publication in the "best" ecological journals will be difficult. It is usually impossible to become the world's expert on the most important risk assessment topics because the range of material is too broad. Another aspect of the problem is perhaps best illustrated by a short story involving an ecologist and a policy analyst. As dedicated public servants, they were both working late one night in Washington on the great ecological risk issues of the day. Very late that night the policy analyst left work and walked the two blocks to the corner bus stop. It was very dark except for a single bright street light illuminating the bus stop. As he approached the bus stop and emerged from the darkness, the policy analyst noticed the ecologist on his hands and knees searching for something. He was crawling in a rigorously systematic fashion along transects from one edge of the light to the other. The policy analyst, always the helpful soul, asked the ecologist what he was looking for and if he could help. The ecologist had lost his keys and wanted all the help he could get to find them before the bus arrived. They both searched for several minutes — the ecologist in a systematic, disciplined fashion - the analyst in kind of a random, disjointed search. After several minutes without success, the analyst said: "We've completely covered the bus ------- Robert T Lackey Ecological Risk Assessment 15 September 8. 1993 stop without any luck. The bus will be here shortly. Let's go back to first principles and see if we have overlooked something — to start with, where was the last time you actually remember HAVING your keys?" "That's pretty easy to answer" said the ecologist ~ "about a half a block back, they fell out of my pocket." With considerable exasperation, the analyst asked: "Then why in God's green earth are we wasting our time looking here at the bus stop for your keys?" The ecologist quickly responded with a mixture of conviction and tolerance: "Simple, look back up the street - it's dark; we'll NEVER find anything there!" Having said all that, here are several candidates for research: (1) The first and most critical need is to develop and refine a risk assessment paradigm that deals with "consequences," not "risks." Most ecological "risks" are not really risks at all, but simply probability of the consequences of certain actions or inactions. We don't measure the "risks" of global climate change, we measure the "consequences" of global climate change. We don't measure the "risks" of converting much of mid-continental North America to agriculture, we measure it's consequences. We don't measure the risks of converting a swamp to a corn field, we measure it's consequences. A consequence becomes a risk only when we apply societal or individual values. After all there is nothing intrinsically ecologically good or bad about climate change. Or converting prairie to wheat fields. Or swamp land to corn fields. (2) A second critical research need is to more realistically link ecology and policy. In my experience, many policy analysts have an unrealistic expectation of what role ecology can play. The questions often asked of ecologists are: "What is the health of such and such ecosystem?" "What kind of information will you need before you can determine if something is safe for the environment?" "When will you have enough research to recommend a decision?" "How much biodiversity do we need?" "What do we need to do to make our ecosystems sustainable?" ------- Robert! Lackey Ecological Ride Assessment 16 Septembers. 1993 These are all value-based questions that cannot be answered by scientists without applying values — their's or someone else's. (3) A third research need — and one that I have some doubts about — is ecological currency. A "metric" for ecological risk assessment would be very useful. You could rank consequences. You could measure ecological health. You could compare the "value" of a corn field and the value of a prairie pothole — the value of an old growth forest and second growth, and so on. It might even be possible to add some credibility to "green accounting." Although important and potentially highly useful — I do not have much confidence in the likelihood of a major breakthrough in this area. Regardless, it ought to be pursued. (4) A fourth research need is to better factor in the dynamic nature of ecosystems. The gulf between ecologists and most other people is substantial. Ecologists know ecosystems to be dynamic, highly chaotic, and often unpredictable. For many reasons ecosystems change a lot over time. Without any human involvement, ecosystems have massive fires, disease outbreaks, invasions of new predators and diseases, shifts in the earth's climate, shifts in local climate, population booms and crashes, floods, earthquakes, droughts, and more. There is really no "natural" state. Many people, perhaps most I think, have a view of ecosystems characterized by Ansel Adams photographs ~ natural ecosystems are "perfect" — an equilibrium condition in which all the pieces operate in a predictable, desirable way. Most views of ecosystems are of "natural, unspoiled" panoramas. They are frozen in time and any deviation from this timeless condition is "degradation." This is not the way the natural world is. ------- RobortT Lackey Ecological Ruk Aswsnnenl 17 September 8, 1993 The Major Challenges Ahead What does the future hold for ecological risk assessment? Two safe predictions are foremost: (1) First, ecological risk assessment will continue to stimulate controversy and debate — sometimes very strident and divisive as we see in the Pacific Northwest. Tension will be particularly severe with issues where the desire of some to achieve environmental benefits comes at the cost of individual rights. After all, the critical habitat of the endangered silver-bellied, rough-legged, lesser nocturnal snail is also someone's backyard. (2) Second, the paradigm of choice for assessing ecological risk, a modified version of that used in assessing health risk, will continue to be widely used. The paradigm will work reasonably well for fairly simple ecological and political problems, particularly those dealing with chemicals and simple ecosystems. It will not work well for more complex ecological and political problems, unfortunately these are the most important. Conversion of natural ecosystems to agricultural use, to places for human habitation, and for human transport, dwarf the changes caused by most other environmental stresses. Conclusion In conclusion, the ecological journals will continue to publish more and more ecological risk papers, more books will be written on the subject, there will be more talks on which is the best paradigm to use, Congress and the Executive Branch will continue to look for ways to prioritize ecological risk, and more panels will be commissioned to pass judgement on approaches and methodologies — but the real challenge for applied ecologists will continue to be: how best to put the right information on the table, in the right form, and at the right time to best factor in ecological consequences in the decision-making process. econdc afs ------- |