EVALUATION OF THE NO ACTION. NATURAL RECOVERY ALTERNATIVE The NEPA requires the Trustees to consider a “no action” alternative, and the OPA and OSPRA regulations require consideration of the natural recovery option. These options are equivalent. Under this alternative, the Trustees would take no direct action to restore injured natural resources. Instead, the Trustees would rely on natural processes for recovery of the injured natural resources. The principal advantages of this approach are the ease of implementation and cost-effectiveness. This approach relies on the capacity of ecosystems to “self-heal” and, in this case, is selected as the primary restoration alternative. While natural recovery of the injured natural resources would occur over time, compensation for interim losses would not be provided under the no action/natural recovery alternative. The OPA and OSPRA regulations, however, clearly establish Trustee responsibility to seek compensation for interim losses pending recovery of the natural resources; therefore, because losses were suffered during the period of recovery from this incident and technically feasible, cost-effective alternatives exist to compensate for these losses, the no action/natural recovery option is not selected as a compensatory restoration alternative.
