The Stand for Salmon Act is Inappropriate on Many Levels
By Joe Nicolette
My 2 cents. The Stand for Salmon Act is inappropriate on many levels. I was certified as a fisheries scientist by the American Fisheries Society back in 1992 and my graduate degree focused on salmon. One of my primary areas of emphasis is aquatic habitat compensatory restoration offsets/mitigation development and scaling (i.e., how much is enough?). I pioneered habitat equivalency analysis (HEA, a service to service approach) on several oil spill related natural resource damage assessment (NRDA) cases early on in my career before the approach was codified into both OPA and CERCLA, as well as codified in Europe regulations (the Environmental Liabilities Directive). My career has focused on the use of these approaches, including outside NRDA, within a net environmental benefit analysis (NEBA) framework on NEPA permitting related, site remediation, and land development projects.
In looking at the Stand for Salmon Act, it does not appear to allow for mitigation offset approaches, that have been accepted over the past 25+ years by the U.S. Federal Government (and written into law) and now a preferred approach in Europe. This aspect of the Act will singularly prevent any significant development in Alaska.