and impingement caused the decline or that they had nothing at all to do
with the decline.
3.8 Conclusions
We have presented our ideas on how the process of modeling the impacts
of entrainment and impingement on fish populations can serve as a bridge
between science and policy as part of a decision-making process involving
industry, regulators, and stakeholders. Given the litigious nature of 316(b)
determinations, however, this ideal may not be possible or may be only
partially successful. We want to point out, however, that, within individual
organizations involved in the decision-making process, initial agreement
on how to answer the difficult questions that must be answered is rare.
Consequently, even within individual organizations, modeling can effectively serve as a bridge between science and policy.
We have emphasized the importance of viewing the modeling process
from a top-down, decisions-and-values approach and not just a bottomup, find-the-best-model approach. We recommend viewing these two
approaches as complementary, with neither approach dominating. A
primary responsibility of regulators and resource managers is to make
decisions, decisions concerning what to do (or not do), when, and how. Such
decisions commonly benefit if approached within an analysis framework
with explicit consideration of benefits, costs, and uncertainty of alternative
decisions. The discipline of ecological risk assessment emphasizes the
importance of defining endpoints and decision criteria. Definitions of endpoints and decision criteria, in turn, specify the objectives for modeling,
what models are most appropriate, and how and when the modeling process
and results might most effectively interact in the broader decision-making
process.
We have summarized EPA’s framework for ecological risk assessment
and their definitions of key terms (see Sidebar 3.2) to highlight how such a
systematic and rational framework can help put the 316(b) regulatory
process on a constructive path. Science (including modeling) contributes
primarily during the analysis component (see Figure 3.4). However, if that
is the only place scientists contribute, their support of the decision-making
process may be minimal. To be more effective, they also must be part of the
problem formulation and risk characterization components (see Figures 3.2
and 3.4). For the reasons discussed above, this broader influence is essential for 316(b) and for other ecological management decisions as well.
Acknowledgments. This paper has benefitted from discussions with, and
reviews by, numerous individuals, including D.E. Bailey, M.S. Bevelhimer,
J. Chandler, C.C. Coutant, V.H. Dale, D. Dixon, and H.I. Jager, and an
3. Modeling Fish Entrainment and Impingement Impacts
65
with the decline.
3.8 Conclusions
We have presented our ideas on how the process of modeling the impacts
of entrainment and impingement on fish populations can serve as a bridge
between science and policy as part of a decision-making process involving
industry, regulators, and stakeholders. Given the litigious nature of 316(b)
determinations, however, this ideal may not be possible or may be only
partially successful. We want to point out, however, that, within individual
organizations involved in the decision-making process, initial agreement
on how to answer the difficult questions that must be answered is rare.
Consequently, even within individual organizations, modeling can effectively serve as a bridge between science and policy.
We have emphasized the importance of viewing the modeling process
from a top-down, decisions-and-values approach and not just a bottomup, find-the-best-model approach. We recommend viewing these two
approaches as complementary, with neither approach dominating. A
primary responsibility of regulators and resource managers is to make
decisions, decisions concerning what to do (or not do), when, and how. Such
decisions commonly benefit if approached within an analysis framework
with explicit consideration of benefits, costs, and uncertainty of alternative
decisions. The discipline of ecological risk assessment emphasizes the
importance of defining endpoints and decision criteria. Definitions of endpoints and decision criteria, in turn, specify the objectives for modeling,
what models are most appropriate, and how and when the modeling process
and results might most effectively interact in the broader decision-making
process.
We have summarized EPA’s framework for ecological risk assessment
and their definitions of key terms (see Sidebar 3.2) to highlight how such a
systematic and rational framework can help put the 316(b) regulatory
process on a constructive path. Science (including modeling) contributes
primarily during the analysis component (see Figure 3.4). However, if that
is the only place scientists contribute, their support of the decision-making
process may be minimal. To be more effective, they also must be part of the
problem formulation and risk characterization components (see Figures 3.2
and 3.4). For the reasons discussed above, this broader influence is essential for 316(b) and for other ecological management decisions as well.
Acknowledgments. This paper has benefitted from discussions with, and
reviews by, numerous individuals, including D.E. Bailey, M.S. Bevelhimer,
J. Chandler, C.C. Coutant, V.H. Dale, D. Dixon, and H.I. Jager, and an
3. Modeling Fish Entrainment and Impingement Impacts
65