Applied Ecosystem Services, LLC

How to measure sustainability comes up frequently in conversations among mining professionals. Questions asked include what protocol or algorithm should be used, and what measures should to be included. A lot of serious thought has been given this subject by experienced and insightful environmental managers. Yet there is still discomfort that the lists of measures or the procedure to be used may not be “correct.” Sport analogies may help you understand a solution process in which you can have full confidence.

Regulators require collection and submission of baseline data prior to permit issuance (e.g., NEPA documents or other operating permits), and continuing data to evaluate compliance with permit conditions. The reason is the need to determine whether the proposed project might have unacceptable environmental impacts, and whether operations have such impacts. It is common for analyses accompanying reported data to be inappropriate or superficial and not answer two critical questions. Why do observations and measurements have the values they do?

It is common to read statements like this: “… EPA found that 20 percent of 331 wells tested had nitrate levels above federal drinking water standards …” Such statements contain no useful information because they lack context. To put this statement in context we need much more information. For example: where are these 20% located in relation to all 331 wells, what time of year were these high nitrate concentrations observed, and how frequently did they occur?

Have you missed a permit compliance monitoring or reporting event and been financially penalized? Has your environmental impact statement approval been delayed by regulators’ paralysis by analysis or by many challenges from project opponents? Has your farm or livestock operation been accused of degrading a nearby water body although you comply with discharge permit monitoring requirements? Have you suffered from the “battle of competing experts” in litigation confusing finders of fact on what your environmental data reveal about the case?

Have you missed a permit compliance monitoring or reporting event and been financially penalized? Has your environmental impact statement approval been delayed by regulators’ paralysis by analysis or by many challenges from project opponents? Has your farm or livestock operation been accused of degrading a nearby water body although you comply with discharge permit monitoring requirements? These situations, and many similar ones, share two underlying issues: lack of effective explanation to decision-makers of ecosystem complexity, and inappropriate models used to analyze environmental data.