No. Comment Priority Recommendation Response DEC Remarks 1. Was the risk assessment unbiased and based on good High Response is acceptable.

• Other Authors: The Pennsylvania State University CiteSeerX Archives
• Format: Text
• Language: English
• Subjects: Arctic
• Online Access: http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.369.1323; http://www.dec.state.ak.us/spar/csp/docs/reddog/rafinal/04-usgs_092507.pdf

The risk assessment appears to be based upon valid science and follows best practices for evaluating ecological risk, relying heavily on site-specific and selected published data. This risk assessment is based on specific regulatory guidance that does not necessarily generate information that is of specific significance to the unique ecology of the CAKR. For example, extrapolation from benchmark data from unrelated species to organisms unique to this arctic habitat may introduce inaccuracies not fully anticipated by regulatory guidance. In addition, regulatory guidance can lead to a narrowly focused assessment that may include data gaps and introduce uncertainty and bias to resource management plans developed for Park Service lands. For example, the most sensitive receptors may not be the charismatic higherorder receptors that normally receive regulatory attention.