ABSTRACT
Biocriteria or proxy-based. Biocriteria or other quasi-scientific metrics have several advantages: (1) a coarse technology standard is improved by measures more closely related to the outcomes of interest; (2) an approach to regulatory implementation is provided that is hopefully not as complex or practically overwhelming as more open-ended risk assessment processes; (3) a certain amount of predictability and fairness in implementation is provided; and (4) the rationale for various biocriteria or proxy guidelines might possibly be more easily justified on scientific grounds. Biocriteria and regulatory proxies generally are motivated by the idea that the right criteria can become adequate regulatory tools. Constructed measures are often created on a site-specific basis for many environmental problems, so why not just do that at a general regulatory level? Of course, whether the right outcomes can be captured by the constructed measures is the great challenge. It is also predictable that if more cases and variability (multiple fish species, competing causal factors, water body management approaches, ease of modeling, etc.) needs to be captured, the less likely it is that the criteria will be successful. Given that such criteria are intended to have some kind of scientific base, they are open to criticism for being motivated by expediency rather than explanatory principles. The approach of creating regulatory proxies also has a long history in environmental regulation, and sometimes creates complex policy choices when hard value judgments are replaced by quasi-technical solutions.34
