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LETTER TO THE EDITOR

REDUCING ECOLOGICAL ASSESSMENT TO REFERENCE BIOTA: IS ICRP CUTTING CORNERS ON ENVIRONMENTAL PROTECTION?

The International Commission on Radiological Protection (ICRP) says one impetus for its 2002 draft environmental recommendations is the trillions of dollars cleanup facing industry and government for old weapons facilities, nuclear plants, and radioactive waste. In August 2002, ICRP--responsible for recommending radiation-pollution protections (which are then translated into national legal standards)--reported its recommendations on its website (www.icrp.org/draft_nonhuman.htm).

Given the report's importance and ICRP's request for comments from the scientific community, conservation biologists need to respond immediately. Despite strengths, (1) the ICRP recommendations take an incomplete approach to ecological assessment. (2) They recommend focusing primarily on modeled radiation doses, not actual empirical measures, and only to a few unspecified organisms. (3) They contradict existing international laws for environmental protection. (4) They defend non-transparent, scientific procedures susceptible to manipulation by vested interests. (5) They reject protection norms for the abiotic environment, e.g., air, water. (6) They ignore preservation and focus only on sustainable development. (7) They make no recommendations regarding keeping radiation doses to the environment ALARA (as low as reasonably achievable), although ALARA is part of current ICRP protections for humans. (8) They make no recommendations for protection of ecosystem structures/functions. Moreover, (9) because nuclear regulators could choose radiologically insensitive species to determine biotic effects, these recommendations could result in great harm to other species, to ecosystems, and to air and water.

Conservation biologists should respond by posting comments, before the end of the year, to this ICRP report (at www.icrp.org/draft_nonhuman.htm) given that (a) it will crucially impact global pollution, (b) ICRP has mandated an unrealistically short time-frame for comments, and (c) the existing report is likely to be approved, even though it was not adopted unanimously by the committee. The source of some problems in the report may be that the main commission of the ICRP includes mainly physicists, not conservation biologists and ecologists.

Kristin Shrader-Frechette

O'Neill Professor

Departments of Philosophy and Biological Sciences

University of Notre Dame

100 Malloy Hall, Notre Dame, IN 46556

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