April 3, 2013
Nancy H. Golden, U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Arlington, VA 22203.
In assessing risk under the ESA, we are often faced with high uncertainty due to gaps in knowledge regarding life history, population dynamics, and stressors. Because of their vulnerability, the consequences of missing effects to endangered species may be great. Thus, in order to meet the statute’s mandate to “insure” that actions do not jeopardize species, we approach risk assessment in a manner that avoids overlooking potential effects. As an example, we examine the role and importance of assessing sublethal effects (those that expand beyond the endpoints of survival, growth, and reproduction), and how we might approach their inclusion in a biological assessment in the face of incomplete information.