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NRDA: Process, Pitfalls and Possibilities
1. Natural Resource D
Nt lR Damage A
Assessment (NRDA)
t (NRDA):
Process,
Process Pitfalls and Possibilities
Joseph C. Steinbacher
Versar, Inc.
U.S
U S Army Environmental Cleanup Workshop
12 March, 2009
San Antonio, Texas
2. Overview
• Who is this guy?
• Wh is NRDA?
What i
• Who are the Trustees?
• Why should I care about NRDA?
• What can I do to mitigate NRD liability?
5. Office of Response & Restoration (OR&R)
• OR&R Mission: Protect and restore coastal resources by countering
and responding to environmental threats and p
p g promoting sound
g
decision-making in the coastal zone.
6. O ce of espo se
Office o Response & Restoration (O & )
esto at o (OR&R)
OR&R
Hazardous Material
H d Mt il Coastal Protection &
C t l P t ti
Damage Assessment
Response Division Restoration Division
Center (DAC)
(HAZMAT) (CPRD)
7. Office of Response & Restoration (OR&R)
CPRD
HAZMAT DAC
Emergency NRDA Ecological Risk
Response
R Assessment
A t
(Oil Spills) (Waste Sites)
8. O ce of espo se
Office o Response & Restoration (O & )
esto at o (OR&R)
OR&R
Emergency Response Assessment & Restoration
Division (ERD) Division (ARD)
10. Damage Assessment, Remediation and
Restoration Program (DARRP)
g ( )
DARRP
Assessment &
A t General Counsel for
G lC lf
Restoration Center
Restoration Natural Resources
(RC)
Division (ARD) (GCNR)
13. NRDA
• Superfund’s wicked step-sister…
•R
Restoration i the f
i is h focus of NRDA
f NRDA.
• NRDAs are conducted to calculate the monetary cost of restoring
natural resources that have been injured as a result of the
releases of hazardous substances or discharges of oil. Not
punitive…
•D
Damages t natural resources are evaluated by id tif i th
to t l l t d b identifying the
ecological functions or “services” provided by the resources,
determining the baseline level of the services provided by the
injured resource(s), and quantifying the reduction in service levels
resource(s)
as a result of the contamination.
• Regulations for assessing NRD have been p
g g promulgated under
g
both CERCLA and OPA.
14. CERCLA Statutory Authority
• The Comprehensive Environmental Response, Compensation
and Liability Act (
y (CERCLA) p
) provides a comprehensive g p of
p group
authorities focused on one main goal:
– to address any release, or threatened release, of hazardous
substances, pollutants, or contaminants that could endanger human
health and/or the environment.
• CERCLA's response provisions focus on the protection of human
health and the environment.
– The statute also provides authority for assessment and restoration of
natural resources that have been injured by a hazardous substance
release or response.
15. OPA Statutory Authority
• The Oil Pollution Act (OPA) was enacted in response to the
Exxon Valdez oil spill and p
p provides authority for oil p
y pollution
liability and compensation, as well as for the Federal government
to direct and manage oil spill cleanups.
• Similar to CERCLA, OPA contains authorities to allow the
CERCLA
assessment and restoration of natural resources that have been
contaminated by the discharge, or threatened discharge, of oil.
17. Natural Resources
• Both CERCLA and OPA define quot;natural resourcesquot; broadly to
include quot;land, fish, wildlife, biota, air, water, ground water,
, , , ,, ,g ,
drinking water supplies, and other such resources...quot;
• Both statutes limit quot;natural resourcesquot; to those resources held in
trust for the public termed “Trust Resources.”
public, Trust Resources
• Generally, both CERCLA and OPA state that a quot;natural resourcequot;
is a resource quot;belonging to, managed by, held in trust by,
gg g y y
appertaining to, or otherwise controlled byquot; the United States, any
State, an Indian Tribe, a local government, or a foreign
government [CERCLA 101(16); OPA 1001(20)].
18. Baseline
• The condition or conditions of the natural resources and their
services that would have existed at the assessment area had the
release of hazardous substances not occurred [43 CFR 11.14(e)].
• Baseline data may be estimated using historical data, reference
data,
data control data or data on incremental changes (e g number
data, (e.g.,
of dead animals), alone or in combination, as appropriate.
• Different than remediation approach of addressing unacceptable
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risks; NRDA focus is ‘prerelease’ condition – conditions that
would have existed in the absence of a release.
19. Damages
• The amount of money needed to satisfy a claim in court. The
measure of damages is:
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– the cost of restoring injured resources to their baseline condition
– compensation for the interim loss of injured resources pending
recovery
– and the reasonable cost of a damage assessment [43 CFR Part 11;
15 CFR Part 990]
• Damages continue to accrue until restoration and replacement
projects result in the complete recovery of resources or services
to baseline conditions.
• “Residual damages” refers to any damages that remain after
remediation is complete.
20. Interim Losses
• Injuries and associated service losses that accrue until injured
resources and the services they provide are returned to baseline
yp
conditions.
• The start date for calculating interim losses is either the time of
release or December 1980, following enactment of CERCLA,
1980 CERCLA
whichever comes later.
21. Injury
• A measurable adverse change, either short or long-term, in the
chemical or physical q
py quality, or the viability of a natural resource
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resulting either directly or indirectly from exposure to a release of
a hazardous substance [43 CFR 11.14(v)].
• Definitions of injuries to specific natural resources are provided in
the NRDA regulations [43 CFR 11.62].
22. Services
• The physical and biological functions performed by the resource,
including the human uses of those functions [ CFR 11.14(nn)].
g [43 ( )]
• Habitat services include:
– The provision of food and shelter for numerous and varied organisms
– Nutrient cycling
– Contaminant filtering
– Sediment and soil erosion control
– Aesthetic and recreational services for humans
23. Service Flows
• The services provided by a resource over time.
– Restoration or remediation activities may increase the service flows
y
provided by natural resources over time
25. Restoration
• Actions undertaken to return injured resources and the services
they provide to baseline conditions, and additional actions to
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compensate for interim losses of natural resources and their
services.
• May refer to direct restoration of injured resources replacement
resources,
of injured resources, or acquisition of the equivalent of such
resources.
• Restoration actions can take place off-site, away from the
assessment area, or on-site, if the restoration actions improve the
condition of the injured resources above levels necessary to
satisfy baseline conditions.
27. Trustees
• No one “owns” a natural resource
• H ld i trust f the public - T
Held in for h bli Trustees
– Federal
– State
– Tribal
– Foreign (OPA only)
28. Federal Trustees
• Designated in National Contingency Plan (NCP) and Executive
Order 12580
• Secretaries of:
– Agriculture
– Commerce
– Defense
– Energy
– Interior
• EPA is not a Trustee
29. State Trustees
• Governor of each State designates State Trustees
•U
Usually d
ll departments responsible for fish, game, wildlife and
ibl f fi h ildlif d
environmental protection
• Varies by State
32. Trust Resources
• Department of Commerce (NOAA) Trust Resources
– Coastal environments, including salt marshes, tidal flats, estuaries, or
, g , , ,
other tidal wetlands
– Designated Estuarine Research Reserves or Marine Sanctuaries
– Endangered marine species
– Marine mammals
– Rivers or tributaries to rivers which historically support or presently
support anadromous fish (fish that spend a portion of their lifetime in
both fresh and salt water; e.g., salmon)
33. Trust Resources
• Department of Interior (USFWS, BIA, BLM, USGS, NPS) Trust
Resources
– Certain anadromous fish
– Certain endangered species
– Certain marine mammals
– Federally-owned minerals
– Migratory birds
– National Wildlife Refuges and Fish Hatcheries
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– National Parks and Monuments
– Tribal resources, in cases where the U.S. acts on behalf of the Tribe
34. Trust Resources
• State Trust Resources
– State forest lands
– State-owned minerals
– State parks and monuments
– State rare, threatened, and endangered species
– State wildlife refuges and fish hatcheries
– Ground and surface water
– The resources supporting ecosystems, that are:
resources'
Within the boundary of the State; or
Belonging to, managed by, controlled by, or appertaining to the
State
35. Trust Resources
• Department of Defense Trust Resources
– The Secretary of Defense has trusteeship over the Natural
y p
Resources on all lands owned by DOD or the Army, Navy, Air Force,
and Defense Logistics Agency. These lands include military bases
and training facilities, research and development facilities, and
munitions plants
– Deputy Assistant Secretary of the Army for Environment, Safety and
Occupational Health (DASA(ESOH)) is responsible for acting as the
Army Natural Resource Trustee
37. Trustee Responsibilities
• Participate in the National Response System preparedness and
response activities to avoid or minimize injury to natural resources.
p jy
• To ensure restoration of natural resources that are injured by the
discharge of oil or release of hazardous substances.
39. NRDA Process
• DOI and NOAA regulations provide similar standardized
p
procedures for p
pursuing NRD claims.
g
• Trustees are not bound by these procedures.
• Following procedures enables Trustees to obtain “rebuttable
rebuttable
presumption”
– If the Trustees conduct the assessment in accordance with the NRDA
rules, the assessment is presumed to be correct unless the PRP can
p
prove otherwise through a preponderance of evidence
41. NRDA Process – DOI Regulations
• DOI regulations provide a framework and standards for the NRDA
p
process under CERCLA
– Type A – coastal and marine environments (model)
– Type B – other environments (site-specific)
– Four sequential p
q phases:
Pre-assessment Screen
Assessment Plan
Assessment Implementation
p
Post-assessment
42. NRDA Process – DOI Regulations
• Pre-assessment Screen (PAS)
– Conducted to determine if additional action is warranted
– Trustees must determine whether an injury has occurred and if an
exposure pathway exists
– Prerequisite to conducting a formal NRDA
43. NRDA Process – DOI Regulations
• Assessment Plan
– Confirm exposure of Trust Resources
p
– Develop injury assessment plan
– Draft assessment plans must be made publicly available for review
44. NRDA Process – DOI Regulations
• Assessment Implementation
– Gather data necessary to q
y quantify injury and determine damages
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Identify services provided by resources
Determine baseline conditions
Quantify reduction in service levels
– Injury determination
– Injury quantification
– Damage determination
45. NRDA Process – DOI Regulations
• Post-assessment
– Prepare an Assessment Report based on Assessment
p p
Implementation findings
– Identify restoration options
46. NRDA Process – NOAA Regulations
• NOAA regulations provide a framework for conducting NRDAs
that achieve restoration under OPA
– Pre-assessment
– Restoration Planning
– Restoration Implementation
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47. NRDA Process – NOAA Regulations
• Pre-assessment
– Determine if injury due to release is likely
jy y
– Determine if response actions will adequately address injuries
– Determine if feasible restoration options exist
48. NRDA Process – NOAA Regulations
• Restoration Planning
– Injury assessment
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Has release resulted in adverse change to natural resources?
Quantify magnitude, and spatial and temporal extent of injury
relative to baseline
– Restoration selection
Determine the need for and scale of restoration
Develop a Draft Restoration Plan that identifies p
p primary and
y
compensatory restoration options
Draft Restoration Plan must be made publicly available for review
49. NRDA Process – NOAA Regulations
• Restoration Implementation
– Final Restoration Plan is made available to responsible p
p parties (
(RPs)
)
for implementation, or to fund the Trustees’ costs for implementation
50. NRDA Process – Damages
• Restoration is the focus of NRDA.
•C i
Contingent V l i M h d (
Valuation Methods (stated value and willingness to
dl d illi
pay surveys) replaced by Habitat Equivalency Analysis (HEA)
and other valuation methods that focus on using restoration
costing.
costing
• Cooperative assessments and negotiated settlements.
•S
Spend th money on restoring th resources!
d the t i the !
51. Typical Assessment Costs vs.
Representative Restoration Costs
Artificial Marsh Oyster Reef Migratory Cattle Boat Ramp
Reef Creation Creation Waterfowl Exclusion Construction
Construction ($75k- ($154k/acre) Habitat Acq. from Salmon ($100k each)
($200k/acre)
$ 126k/acre) in Midwest Habitat for 75
US years
($320/acre) ($200k/mile)
Sediment
8.7-14.7
Contamination 5.5 acres 7.1 acres 3,478 acres 5.5 miles 11 ramps
acres
Survey ($1.1 M)
Sediment
Toxicity Testing 3.8 acres 6-10 acres 4.9 acres 2,344 acres 3.8 miles 7.5 ramps
($750k)
Fish
15.9-26.7
Reproduction 10 acres 13 acres 6,250 acres 10 miles 20 ramps
acres
Testing ($2.0 M)
Fish Health
4.8-8
Survey ($600k) 3 acres 3.9 acres 1,875 acres 3 miles 6 ramps
acres
Bird Egg
3.7-6.1
Gradient Study 2.3 acres 3 acres 1,438 acres 2.3 miles 4.6 ramps
acres
($460k)
Conner and Gouguet, 2004. Getting to Restoration. The Environmental Forum, Wash., DC, May/June issue.
52. NRDA Process – Restoration
• NRD funds from settlements must be used to restore, replace, or
acquire the equivalent of injured natural resources
q q j
– Direct – return the injured resource to its baseline condition
– Replacement – provides a substitute for an injured resource or
service
– Acquisition – provides for purchase, trade, or protection of resources
that are similar or related to injured resource
• On-site restoration is preferred unless:
preferred,
– Cost is grossly disproportionate
– Restoration is not possible
– Natural recovery will quickly return resources to baseline condition
54. NRDA and DoD
• 25 million acres of land
• Wid variety of terrestrial and aquatic h bi
Wide i f il d i habitats
• Numerous species including threatened and endangered
• Limited access has created incidental wildlife preserves
• Potential liability may be considerable…
55. NRDA and DoD
• Estimates of DOE Liability
– FY‘97 Defense Authorization Act required DOE to study its NRD
q y
liability
DOE estimated its liabilities between $1.4 – $2.5 Billion
– ‘96 GAO report estimated liabilities for DOE of between $1.7 - $24.9
Billion
• Based on applied ratios of past damage awards to response
costs at private sector sites
56. NRDA and DoD
• DoD as a Trustee
– DoD must, with certain exceptions, comply with NRDA p
, p , py provisions
– DoD is responsible for identifying potential natural resource injuries
(NRI) on its facilities
• DoD as a PRP
– DoD must address damage claims made against them
– DoD may be affected by claims made against DoD contractors and
facility tenants
– States are becoming more familiar with NRDA process
Massachusetts Military Reservation
Twin Cities Army Ammunition Plant
Rocky Mountain Arsenal
58. NRDA and Army – NRI Policy
• Army Natural Resource Injury (NRI) Policy Goals:
– Army Lead Agent should be knowledgeable enough about NRI,
y g g g ,
known or potential, at a site to notify the appropriate Trustees and
coordinate their investigations and remedial plans
– Army Lead Agent should consider NRI information along with all other
NCP selection criteria and select a response action that results in the
least amount of residual NRI, while evaluating actions that may be
taken during the execution of the remedy to reduce or eliminate
potential NRI
59. NRDA and Army – NRI Policy
• Army Natural Resource Injury (NRI) Policy Requirements:
– Identify p
y potential NRI at Army sites when investigating the release of
y g g
a CERCLA hazardous substance
– Notify natural resource trustees of potential injury
– Coordinate with the appropriate trustees for assessments,
investigations, and planning, and help identify response actions that
could, when implemented, reduce or minimize injury to natural
resources
– U th services of qualified natural resource professionals when
Use the i f lifi d t l f i lh
performing necessary assessments, investigations and response
action planning activities
– Whenever practicable, appropriate and consistent with the NCP,
ensure response actions are evaluated and selected that limit the
potential for NRI
60. NRDA and Army – NRI Policy
• Army Natural Resource Injury (NRI) Policy Applicability:
– There must have been a release of a CERCLA hazardous substance
resulting from Army operations at the site
– The release of a CERCLA hazardous substance must either have
injured the natural resources or have the potential to injure the natural
resources
– The CERCLA release at issue must pose an unacceptable risk that
requires remediation to protect human health and/or the environment,
as per CERLCA and NCP requirements (notification)
– There must be an ongoing response action at the site that has not
reached the implementation of the selected remedial action
(
(retroactive notification)
)
61. NRDA and Army – Lead Agent
• Lead Agent Responsibilities:
– Identify a release of a CERCLA hazardous substance
y
– Identify natural resources
– Identify NRI
Pre response
Pre-response injury (direct effect of release)
Response-related injury (effect of remediation)
Residual injury (effect of residual contamination)
– Notify Trustees
CERCLA 104(b)(2) requires Trustee notification when there has
been a hazardous substance release
– Coordinate with Trustees
– Consider NRI during investigatory process
– Lead Agent/Trustee cooperation
– Coordinated development of remedial alternatives
p
62. NRDA and Army – Mitigating Liability
There’s many a slip between the cup and the lip…
Old English Proverb
63. NRDA and Army – Mitigating Liability
• Exclusions
– Irreversible and irretrievable commitment in an EIS or comparable
p
environmental analysis
– Release wholly occurring before enactment of CERCLA (December,
1980)
– Regulated pesticide used legally under FIFRA
– Federally permitted release
64. NRDA and Army – Mitigating Liability
• Build and maintain good working relationships with stakeholders
– Community y
– Trustees
– Installation resources
– Contractors
• Identify specific sites where NRI may be an issue
– Prioritize preventative actions
– Develop contingency plans
– Inventory natural resources
– Establish baseline measurements
• Incorporate NRD issues into EMS and INRMPs
• Conduct NRD audits
65. NRDA and Army – Mitigating Liability
• PARTICIPATE!!
– Pre-assessment
– Injury determination
– Restoration planning
• Respond to Trustee Notice of Intent
• Take advantage of Trustee status
• Seek cooperative assessments and negotiated settlements
• Incorporate NRD claims into remedial response
• Covenant not to sue
• Expedite the process
68. Athos I
• 750 ft Panamax Tank Vessel – 1983
• D bl Sid d Si l B tt
Double-Sided, Single-Bottom
• Carrying 13 million gallons heavy crude oil
• Citgo Asphalt Refinery – Paulsboro, NJ
69. The Incident
• November 26, 2004 ~ 2130
• Struck submerged object
during docking procedures
• Created two holes
• Anchor
• 264,335 gallons
g
71. The Oil
• Venezuelan heavy crude (Bachaquero)
• Specific Gravity: ~ 0.975 (FW 1.000 SW 1.025)
• API Gravity: 13°
• Viscosity: >5,000 cSt @ 100F (cold honey)
• Composition: hmw compounds (asphaltenes, resins), unresolved
complex mixture (UCM)
• Little evaporative loss (~3%)
• Weak emulsifier
• Adhesive
• Primary injuries due to fouling
72. Extent and Degree of Oiling
• 115 river miles
• 280 miles of
il f
shoreline
Collision
Site
73. Resources at Risk
• Birds – migratory, peregrine falcons, bald eagles
• Fish – juveniles a d larvae, shortnose stu geo
s ju e es and a ae, s o t ose sturgeon
• Shellfish – crabs, bivalves
• Wildlife – turtles, mink, otters
, ,
• Lost use – hunting, boating, fishing
• Sh li – marshes, wild rice
Shoreline h ild i
80. Proposed Aquatic Injury Assessment Plan
Benthic Habitat
e c b Biological Resources
o og c esou ces
HEA Oysters
Sturgeon
Existing Data Striped Bass
Fish
Direct
VSORS/Snare Shad
Delineation Service Loss
UDE
Interim Horseshoe
Crabs
DE Triad
Blue
Benthic Sampling
Submerged Oil (?)
Habitat Injury Estimate Biological Injury Estimate
Aquatic Injury Estimate
86. Athos I Source Oil
Oil Toxicity
• Athos I Source Oil
– Dominated by the
unresolved complex mixture
(UCM)
– Depleted in light
hydrocarbons and alkanes
Alaska North Slope Crude Oil
87. Oil Toxicity
• Three subclasses of chemicals of potential concern (COPCs):
– Monocyclic aromatic hydrocarbons (MAHs)
y y ( )
– Polycyclic aromatic hydrocarbons (PAHs)
– Trace metals
88. MAHs
• Rixey (2001) – benzene content of 69 unweathered crude oils
– ND (<~1ppm) – 5,900 ppm; mean = 1,340 ppm, median = 780 pp
( pp ) , pp ; , pp , ppm
• Athos I benzene:
– 14, 33, 50 and 128 ppm
– MAH = 0.02% (mass basis)
103. Sediment Survey
• Determine if Athos I oil is likely to have degraded sediment quality in
the Delaware River:
– Obtain PAH data from 180 sediment sampling sites using ultraviolet
fluorescence (UVF) screening analysis
– Verify UVF results through laboratory analysis of sample subset
– Collect and archive sediment samples from each sampling station for
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possible future toxicity studies and further chemical analysis
105. Sediment Survey
• Stratified random sampling plan
• 162 sediment samples collected
• UVF results ranged from <1 ppm to 744 ppm
– Mean = 32.8 ppm
– M di = 9 1 ppm
Median 9.1
107. Sediment Survey
• 20 samples selected for laboratory analysis
– Collected from depositional zones
– Collected from water depths ranging from 3 to 38 ft.
– UVF PAH values ranged from 2.0 to 352.0 ppm
Mean = 81.1 ppm
Median = 47.7 ppm
– Lab PAH values ranged from 1.5 to 32.2 ppm
Mean = 13.0 ppm
Median = 10.9 ppm
– TOC values ranged from 1.1 to 7.3%
Mean and median = 3.0%
108. Impacted Area Delineation
• Option 1 – based on data generated by the sediment survey
• O i 2 – mirrors the shoreline TWG degree of oiling approach
Option i h h li d f ili h
109. Impacted Area Delineation - Option 1
• Hartwell et al. (2001) data used to estimate pre-spill average subtidal
PAH concentrations (7.6 ppm)
• Sampling zones with PAH concentrations exceeding 7.6 ppm are
summed to generate a total area of impact
• 9 samples exceeded ‘background’ concentration to produce a total
l d d ‘b k d’ t ti t d ttl
area estimate of 563 acres
111. Impacted Area Delineation - Option 1
• Option 1 Pros:
– Largest, most comprehensive post-spill data set
– Stratified random sampling design
– Includes adjustment for pre-existing conditions
• Option 1 Cons:
– Data collected 10 months after the spill
– The adjustment is simplistic
– Hartwell data collected almost 7 years before the spill
112. Impacted Area Delineation - Option 2
• Relies on SCAT shoreline oiling data
• Assumes subtidal impacts most likely in areas adjacent to heavily
oiled shoreline habitat
• Injured areas are assumed to extend from lower edge of the intertidal
zone to the 18’ depth contour
18
– This estimate reflects the observation that the highest sediment PAH
concentrations were found at depths less than 20’
• The estimate of injured area using this approach is 412 acres
113. Impacted Area Delineation - Option 2
• Supporting evidence:
– Subtidal areas adjacent to heavily oiled shorelines are depositional
(Sommerfield and Madsen, 2003)
– Toxicity testing on sediment samples collected from subtidal habitat
adjacent to heavily oiled shoreline (Tinicum Island) found statistically
significant impacts
115. Impacted Area Delineation - Option 2
• Option 2 Pros:
– SCAT data best captures the movement of oil immediately following the spill
– Consistent with shoreline injury quantification
– Double-counting with shoreline TWG is clearly avoided
• Option 2 Cons:
– Some subtidal areas adjacent to heavily oiled shoreline may not have been
injured
– Some areas adjacent to moderately or lightly oiled shoreline may have been
injured
ij d
– Pre-existing PAH contamination is not addressed
117. Service Loss
• Establish ‘background’ impairment
• Develop ecological effects curve
• Back of the Envelope
• Weight of Evidence
–CComparison of sediment PAH concentrations to site-specific effects
i f di i i ifi ff
thresholds derived from whole sediment chemistry and toxicity data from
the Delaware River
– Similar comparisons to thresholds derived from national data sets
p
– Equilibrium partitioning sediment benchmarks – toxic units (ESB TU)
118. Baseline Service Loss
• EMAP and NS&T sediment PAH data (avg. 3.4 ppm)
• Avg. control-adjusted survival of amphipods (Ampelisca abdita)
90.1% (10-day st d )
90 1% (10 da study)
• Simplifying assumption of a 10% reduction in benthic service levels
associated with baseline conditions
120. Service Loss Estimates
• One month post-spill: 39% control-adjusted survival = 61% service
loss; minus ‘background’ (10%) = 51% service loss
• Three months post-spill: 62% control adj sted s r i al = 38% ser ice
post spill control-adjusted survival service
loss; minus ‘background’ = 28% service loss
• Ten months post-spill: 10% service loss based on sediment survey
results (avg. [PAH] 2.8ppm)
• Fourteen months post-spill: full recovery, i.e., no spill-associated
service losses
123. Habitat Equivalency Analysis (HEA)
• Resource-to-resource scaling method to determine compensation for
lost resources based on the quantification of incident-related NRI
• The loss of ecological services is expressed in discounted ser ice
ser ices e pressed disco nted service-
acre years (DSAYs)
• DSAYs – the amount of ecological service provided by 1 acre of
habitat over 1 year, discounted (3%) to account for the time value of
the services
126. Injury Summary
• Shoreline – 1,729 acres oiled
• T ib
Tributaries – 1 899 acres oiled
i 1,899 il d
• Aquatic – 412 acres exposed to Athos I oil
• Birds – 11,869 estimated dead (direct and indirect losses)
• Recreational Services – 41,709 estimated trips on the river were
affected
