NEBA lets you put a price on habitat

By GORDON ROBILLIARD and GREG REUB
Entrix Inc.

Imagine a habitat restoration solution to an environmental contamination problem that: costs less, can be implemented quickly, reduces consultants' and lawyers' costs, makes all the stakeholders happy and, most important, actually provides a net environmental benefit, especially for the threatened and endangered salmon of Washington.

Net Environmental Benefits Analysis (NEBA) is a practice area developed by Entrix, Inc. over the past several years and built on experience resolving natural resource damage issues resulting from oil or chemical spills. Entrix is now using NEBA as one of several tools to resolve environmental issues from an array of ecological and habitat disturbances, including timber harvest, agricultural water intake and discharges, solid waste disposal, dredging or filling habitat, mining, wastewater discharges and hydroelectric projects in addition to the more typical contaminated site issues.

NEBA provides the strategy and tactics for evaluating potential environmental solutions, based on the "net environmental benefits" that each solution could provide compared to the monetary costs of the solution.

The essence of NEBA is simple: "The environmental benefits of a mitigation, restoration or enhancement project that affects the natural resources (habitats, fish and wildlife, plants) and peoples' uses of the natural resources should be greater than the environmental costs of project implementation; i.e., there should be a net environmental benefit to the project."

Four additional criteria are important:

• First, the environmental benefits and costs should be measurable.

• Second, the restoration and enhancement activities and projects should be economically feasible.

• Third, the activities and projects should be practical from a construction and implementation perspective.

• Fourth, and often very important, the proposed option must be acceptable to the numerous stakeholders including the government agencies and trustees, NGOs, public in general and the party paying the bills.

NEBA is applicable on a landscape scale ranging from small sites to whole watersheds and can be applied to any project that affects the natural environment.

NEBA uses a number of tools or methods developed by economists, engineers and scientists. Habitat Equivalency Analysis can be used to compare the ecological and natural resource value of habitat losses (e.g. degradation of salmon spawning habitat) related to development activities with habitat gains related to habitat enhancement and restoration activities. This is a great tool for scaling and documenting mitigation options that compensate for potential impacts from a development or past degradation.

Another tool is Restoration Options Analysis (ROA) used to estimate and compare the ecological values different enhancements and restoration options provide over time. These and other NEBA tools can be used to identify the natural resource enhancement or restoration option that provides the greatest net environmental benefit over the long run. Once the ecological or other natural resource benefits are estimated for each option, the monetary costs of implementation can be estimated and compared to examine which option gives the citizens of Washington the most environmental bang for the buck.

Using NEBA to evaluate habitat

For example, the upcoming NMFS regulations [4(d) rules] for threatened species or the corresponding local and state actions, will likely restrict development or other habitat disturbance activities within a prescribed distance of a stream bank, regardless of the real ecological value of the stream habitat for salmonids, or other aquatic and wildlife resources, or the flows in the stream.

Using NEBA, the landowner (e.g., timber company, mining company, housing developer, farmer, etc.) could define the ecological impacts and loss of natural resource services for salmon in ecological "currency" resulting from development and removal of trees near intermittent streams in the upper part of the watershed. Then, the landowner could identify the equivalent amount of ecological and natural resource services that could be provided to salmon through habitat enhancement or restoration in downstream portion of the watershed.

The strategy is to replace the ecological service losses created by removing trees in areas (e.g., intermittent streams) that provide relatively few ecological services with cost-effective restoration projects in areas that provide a relatively large amount of ecological service benefits (e.g., fish-bearing streams).

A recent Entrix project provides an example of how issues related to a contaminated site can be approached using NEBA. A Midwest landfill was listed on the National Priorities List and had limited offsite groundwater contamination. The potentially responsible party (PRP) owned 260 acres of contiguous buffer lands adjacent to the landfill and a state wildlife management area. The buffer lands were considered "prime" wetland and wildlife habitat. A remedy had been selected to cap the landfill combined with an expensive 30-year groundwater treatment process. The estimated commercial property value of the buffer lands was about $250,000.

Entrix used NEBA and a natural resource valuation of the buffer lands. The recreational and ecological value of the property was over 50 times the estimated fair market value. By placing the 260-acre parcel in a preservation easement and enhancing some wetland areas, the PRP was able to use "restoration-based compensation" to settle present and future natural resource damage claims.

Since the land could not be developed for commercial or residential use, the clean-up standards were relaxed, saving the PRP a significant amount in remediation costs while providing a major net environmental benefit.

Entrix has used NEBA and some of its primary tools at several contaminated sites on estuarine waterways, including three in the Pacific Northwest. At each site, a natural resource damage claim was filed for among other things, loss of wetland habitat and juvenile salmon rearing and feeding habitat.

We demonstrated that by enhancing the wetland and salmon rearing habitat at the site as well as restoring or creating additional similar habitat on land that was "ecologically under-utilized" (and vacant from a commercial standpoint), the PRP would be able to settle the claim to the satisfaction of all parties.

In addition, the proposed restoration projects were shown to generate "excess" ecological credits that could be "banked" and sold to other PRPs in the same situation. The "commercial" value of the land has been or can be increased significantly by using it for salmon habitat enhancement and restoration rather than industrial or commercial development. That is, there is a net environmental benefit at an acceptable economic and societal cost.

The key advantages to a NEBA approach are that it:

Provides a common metric for measuring impacts against enhancements and restoration, and therefore a basis for scaling the restoration appropriately to the impacts.

• Can be site and watershed specific.

• Documents environmental benefits of publicly used resources.

• Is based on replacing or restoring lost ecological services with like services and habitats rather than using dollars.

• Provides excellent public relations opportunities through good environmental stewardship.

• Promotes cooperation and public participation.

Most important, application of NEBA allows all parties to arrive at an environmental solution that restores or enhances the environment, while being economically feasible and socially accepted. NEBA is a tool that leads to win-win-win situations, with our natural environment being one of the ultimate winners.

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