EPA
. SAB-EPEC-92-
    007
         UniUdSutM       Scfeno* Advfeory        EPA-S4B-EPEC-92-007
         Environmental       towd (A-101)         Novtmbw 1991
   &EPA AN SAB REPORT:
         EVALUATION OF
         WETLANDS RESEARCH*
         PROGRAM
         PREPARED BY THE WETLANDS
         RESEARCH SUBCOMMITTEE OF THE
         ECOLOGICAL PROCESSES AND
         EFFECTS COMMITTEE

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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460
                                                                 OFFICE OF
                                                              THE ADMINISTRATOR
 EPA-SAB-EPEC-92-007

 November 12, 1991
 The Honorable William Reffly
 Administrator
'U.S. Environmental Protection Agency
 401 M Street, SW
 Washington, D.C. 20460

       SUBJECT: Science Advisory Board Review of EPA's Wetland Research Program

 Dear Mr. Reilly:

       The Wetlands Research Subcommittee of the Ecological Processes and Effects
 Committee of the SAB has completed its review of the draft report "Wetlands Research:
 An Integrated Risk-Based Research Strategy". The charge to the Subcommittee was to:
 1) evaluate the research priorities in terms of Agency needs, 2) determine whether the
 risk-based framework was suitable for managing ecosystems and wetlands in particular,
 and 3) critique the objectives and conceptual approach of the strategy. The Subcommittee
 met once on July 16-17, 1991 in Corvallis to conduct this review.

       The Subcommittee's overall evaluation of the Wetlands Research Program is very
 positive, because  it is a relevant and innovative effort to meet many of EPA's needs for
 information on wetlands protection,  mitigation, and restoration.  The findings of the
 research  program should also assist EPA program managers in  dealing with  such
 important issues as  wetlands classification for regulatory purposes and use of created
 wetlands to mitigate wetland loss.  As  the research moves forward to document the
 ecological functions  supported by  different wetlands types under varying hydrologic
 regimes, it should ultimately provide a better  scientific basis for  decisions concerning
 wetlands delineation for regulatory purposes. In this regard, we caution that the current
 legislative and Agency debates over wetlands regulation and decisions stemming  from
 those debates should not constrain or detract from the necessity of maintaining a strong
 commitment to scientific research that will have significant long-term benefits towards
 protecting and increasing the nation's wetland resources.

       The Subcommittee noted many strengths in the program, including the efforts to
 develop a risk-based framework, a focus  on landscape, and the proposal to characterize
 populations of wetlands by function. At the same time, however,  we believe that the
 Strategy Document does not clearly explain these strengths, and it should be revised to
 address the concerns that we have identified in our report.  In addition, the research
 strategy document should take special care to distinguish objective information about
                                                                      PriMtd on Rtcycltd Paper

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wetlands functions from the societal values and subjective judgements that are added for
regulatory applications.  We are confident that the Wetlands Research Program can
address these concerns because many of them were addressed hi the oral presentations
made to the Subcommittee at the tune of the review.

      The  Subcommittee concurs with the program's geographic priorities,  and if
additional resources can be found, a project dealing with coastal seagrass should be added
to the program, provided that it would not be funded at the expense of other projects hi
the program.

      Although we expect the Office  of Research and Development will address all of
the recommendations presented in this report, we  are especially interested in your
response to these:

      o the need for a distinction between wetland functions and values;


      o a clarification of the relationship between the Wetlands Research Program
       and the Environmental Monitoring and Assessment Program to assure that the
       indicators for monitoring are compatible with the risk based approach hi each
       program; and

      o the need to refine the  risk-based strategy using consistent terms and
       concrete examples.

      We are very pleased by the efforts of the EPA  staff  to apply the concepts of
reducing risk and landscape  functions to  manage critical  wetland resources.   We
appreciate the opportunity to conduct this scientific review and look forward to receiving
your response.

                                    Sincerely,
Dr. Bfiaymond Loehr.TJEairman             iJrTKenneth Dickson, Chairman
Science Advisory Board                    Ecological Processes and
                                          Effects Committee
                       Dr. Allan Hirsch, Chairman
                       Wetlands Research Subcommittee

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            U.S. ENVIRONMENTAL PROTECTION AGENCY
                                  NOTICE

      This report has been written as a part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and advice to
the Administrator and other officials of the Environmental Protection Agency.   The
Board is structured to provide a balanced expert assessment of scientific matters related
to problems facing the Agency.  This report has not been reviewed for approval by the
Agency; and, hence, the contents of this report does not necessarily represent the views
and policies  of the Environmental Protection Agency or other Agencies  in Federal
Government.  Mention  of trade names or commercial products do not constitute a
recommendation for use.

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                                  ABSTRACT

      This  report  presents  the   conclusions  and recommendations  of  the  U.S.
Environmental Protection Agency's Science Advisory Board following a review of EPA's
Wetlands  Research Program.   The Subcommittee supported the direction and the
priorities of the WRP and recommended that EPA implement the WRP consistent with
the strategy document and oral briefings they reviewed. The Subcommittee recommended
that the strategy document be revised to clarify and concisely define the program and
clarify other issues raised in the review. While the  strategy was confusing and failed to
explain the strengths of the program, the oral briefings provided important details that
illustrate a  risk based  approach  that  is supported by  the  Subcommittee.  Program
strengths included: 1) its emphasis on synthesis and integration of wetlands research for
the regulatory process; 2) the development of a risk-based framework; 3) the focus on a
landscape  scale;  4)  the  characterization of populations of wetlands by function; 5) a
comparison of artificial and natural wetland functions; 6) a technology transfer; and 7)
the emphasis on wetlands types that are in significant danger  of loss. The Subcommittee
further recommended that WRP further examine its coordination role with EMAP for the
development  of indicators.   The  Subcommittee  also recommended that EPA add a
research project dealing with coastal seagrass if additional resources can be found.
     WORDS: Wetlands Ecosystems, Functions, and Values; Landscape; Environmental
Monitoring; Ecological Risk.
                                       11

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                U.S. ENVIRONMENTAL PROTECTION AGENCY
                        SCIENCE ADVISORY BOARD
                  WETLANDS RESEARCH SUBCOMMITTEE
CHAIRMAN

Dr. Allan Hirsch, Director, Washington Office, Midwest Research Institute

VICE-CHAIR

Dr. Betty Haak Olson, Program in Social Ecology, University of California at Irvine

MEMBERS

Dr. Donald F. Boesch, Director, Center for Environmental and
      Estuarine Studies System, University of Maryland System

Dr. George F. Carpenter, Michigan Department of Natural Resources

Dr. C. Herb Ward, Professor and Chairman, Department of Environmental Science and
      Engineering, Rice University

CONSULTANTS

Dr. Barbara Bedford, Cornell University

Dr. James Gosselink, Professor Emeritus, Louisiana State University

Dr. Michael Josselyn, Professor, Romberg Tiburon Center for Environmental Studies, San
      Francisco State University

Dr. Joseph Larson, Environmental Institute, University of Massachusetts

Dr. Curtis Richardson,  Director, Duke University Wetlands Center, School of Forestry
      and Environmental Studies

FEDERAL AGENCY LIAISON

Dr. Anne Bartuska, Forest Service, USDA

Mr. David E. Chalk, USDA Soil Conservation  Service

Dr. Robert Stewart, Director, National Wetlands Research Center,
      U.S. Fish and Wildlife Service

Mr. Russell Theriot, Manager Wetlands Research Program, U.S. Army Corps of
     Engineers

                                      • • •
                                      ui

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SCIENCE ADVISORY BOARD STAFF

Edward S. Bender, Designated Federal Official, U.S. Environmental Protection Agency,
      Science Advisory Board, 401 M Street, S.W.  (A-101F), Washington, D.C. 20460

Mrs. Marcia K. Jolly (Marcy), Staff Secretary, U.S. Environmental Protection Agency,
      Science Advisory Board, 401 M Street, S.W.  (A-101F), Washington, D.C. 20460

Mr. Robert  Flaak, Assistant Staff Director, U.S.  Environmental Protection Agency,
      Science Advisory Board, 401 M Street, S.W.  (A-101F), Washington, D.C. 20460

Dr. Donald G. Barnes, Staff Director, U.S. Environmental Protection Agency, Science
      Advisory Board, 401 M Street, S.W. (A-101F), Washington, D.C. 20460
                                      IV

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                         TABLE OF CONTENTS


1.  EXECUTIVE SUMMARY	   1

2.  INTRODUCTION  	   3
     2.1  Statement of the Charge	   3
     2.2  Subcommittee  Review Procedures	   4

3.  EVALUATION OF THE WETLANDS RESEARCH PROGRAM	   6
     3.1 General Evaluation	   6
     3.2  Adequacy of the Research Strategy Document	   8
     3.3  Goals and Objectives  	   9
     3.4   Geographic Priorities	   9
     3.5  Risk-Based Framework	<.	  11
     3.6  Wetlands Functions	  11
     3.7  Value Judgements	  12
     3.8  Consistent Terminology	  14
     3.9  Coordination	  14

4.  SUMMARY OF RECOMMENDATIONS 	  15

5.  LITERATURE CITED	  16

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                         1.  EXECUTIVE SUMMARY

      The Wetlands  Research Subcommittee of the Ecological Processes and  Effects
Committee of the Science Advisory Board (SAB) reviewed the draft report, "Wetlands
Research: An Integrated Risk-Based Research Strategy" at a meeting hi Corvallis, Oregon
on July 16-17, 1991. The report sets forth a five-year research program, building on the
previous five-year wetlands research effort.

      The Subcommittee's overall evaluation of the  directions the Wetlands Research
Program (WRP) is taking was positive, and we strongly support implementation of the
program.   WRP is a  relevant  and  innovative effort to  support  EPA's  needs for
information on wetlands protection, mitigation, and  restoration.  The  findings should
assist  hi dealing  with such  important issues  as  wetlands delineation,  wetlands
classification for regulatory  purposes, and  use of constructed  wetlands to mitigate
wetlands loss.  Further, the research program should assist EPA through providing a
source of scientific expertise to the regulatory program, and we were pleased to note that
there is a good, supportive relationship from the  Office  of Wetlands, Oceans, and
Watersheds.  We would caution, however, that the demand for  short-term  regulatory
support should not detract from the need to maintain a continuing and longer  term
research effort,  as is proposed hi the Research Strategy,  nor should current policy
decisions on such issues as wetlands delineation and classification constrain the research
program in its efforts to provide a better scientific basis for such decisions in the future.
The Subcommittee recommends that the WRP and Wetlands Program Office develop a
supportive and cooperative type of agreement that explains how resources can be focused
on long-term research and how priorities  will be developed to accommodate short-term
needs.

      The Subcommittee felt that the  strengths of the program included:

      (1)   its emphasis on synthesis and integration of wetlands research to provide
            information useful in the  regulatory process;

      (2)   its efforts to develop a risk-based framework;

      (3)   the focus on the landscape scale;

      (4)   the proposal to characterize populations of wetlands of similar type  by
            function;

      (5)   comparison of restored, constructed, and natural wetlands functions;

      (6)   provisions for active information transfer to maintain an effective interface
            between research and regulation;

      (7)   selection of wetlands types that are in significant danger of degradation and
           loss (bottomland hardwood, prairie potholes, western riparian habitats) as the

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           focus for proposed studies.

      At the  same time, however, we believe the Strategy Document itself requires
substantial improvement  and refinement; we felt that  the oral presentations at the
Review provided far greater clarity and justification for the research approach than did
the Strategy document. We recommend, therefore, that the document be revised to:

      (1)    clarify WRP's goals and objectives;

      (2)    ensure  that  key terms,  such  as  risk  assessment,  stress,  stressors,
            dysfunctional, and others are used consistently;

      (3)    provide concrete examples to make the strategy less abstract and difficult
            to follow;

      (4)    clarify the relationship between wetlands functions and wetlands values;

      (5)    more sharply define the risk-based approach; and

      (6)    better define the relationship between WRP and EMAP.

      We concur  with the program's geographic priorities,  and recommend that,  if
additional resources can be found, the project dealing with coastal seagrass should be
expanded to a landscape scale.  However, we do not recommend substituting work on this
topic for the other areas already selected  to receive priority.

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                             2.  INTRODUCTION

      The  Wetlands Research Subcommittee of the Ecological Processes and Effects
Committee of the Science Advisory Board (SAB) met on July 16-17, 1991, to review the
draft FY 1992-1996 Research  Plan entitled "Wetlands Research:  An Integrated Risk-
Based Research Strategy" and to receive a briefing on ORD's Research Plan and the
needs of the wetlands protection program of the Office of Water.  This review was
conducted in tandem with another review of research on Constructed Wetlands for
Wastewater Treatment by a Subcommittee of the Environmental Engineering Committee
of SAB.  Both reviews  were conducted at the request of the Office of Research and
Development (ORD).

2.1 Statement of the Charge

      The charge for the review of the Wetlands Research Program was provided to the
SAB by Dr. Courtney Riordan, Director, Office of Environmental Processes and Effects
Research within  ORD.  In his charge, he noted that the primary goal of this review is
to critique EPA's wetlands research strategy.  It is particularly important that the panel
address the following general questions:

      1.    Are the Agency's  highest research priorities addressed?
            Will the information generated support the Agency's needs in development
            of sound wetlands protection policy?
            Is the proposed research responsive to the regulatory needs of  the Office
            of Water?  What alternatives would you suggest?

      2.    Is the  proposed risk-based  framework suitable  for assessment and
            management  of risks to ecosystems in general and wetland systems in
            particular?
            Does the proposed  combination  of studies best meet program  objectives
            within resource constraints or should alternatives be considered?

      In addition, he asked that the  Subcommittee also consider the following set of
secondary questions:

      1.    Does the research plan have a clear and explicit statement  of objectives?

            a)    How can the scientific objectives be more focused  or  improved?

            b)    Is there a specific research strategy for each objective? Is the overall
                  conceptual  approach clearly defined?  Is it scientifically sound? Are
                  there better approaches? Is the strategy realistically achievable?

            c)    Will  the specific research tasks, when completed, fulfill the research
                  strategy? What are the weak links?  Are there missing tasks?

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            d)    Are the contributions of each research task important to achieving
                  program objectives?
                  Are there nonessential tasks in a project? Are there essential project
                  components that are missing?
                  Are there fall-back options in case a task is not accomplished?

            e)    Are the major deliverables defined hi terms of content and delivery
                  date?  Is the responsibility for producing each  major deliverable
                  clearly identified?
                  Do the outputs clearly lead to meeting the overall project objectives.
                  Can the deliverable be completed hi the allotted tune and within the
                  proposed budget?

      2.     Are each of the  tasks focused  in  the  most efficient way to  answer the
            scientific questions?

            a)    Has the highest priority been given to addressing the most critical
                  research components and tasks?

            b)    For each critical task, is the proposed approach to completing the
                  task the most efficient and scientifically defensible within the budget
                  and timeframe?
                  Are there alternative approaches that should be considered?

      3.     Is each project linked  to other projects to the extent required or desired?
            Are there linkages that should be developed?

      4.     What is the likelihood of success of each proposed research project? Which
            ones are least likely to reach then* objectives?

      5.     Does  the Wetlands  Research  Program build appropriately on  research
            programs in other agencies? Are there  opportunities for collaboration that
            have not been explored?

      6.     What other  changes would you suggest to improve the Wetlands Research
            Program and its component projects to address the stated objectives?

SL2 Subcommittee Review Procedures

      Following the request for the SAB review of the Wetlands Research Program, the
Executive Committee  assigned the review  to  the Ecological  Processes and Effects
Committee (EPEC). A Subcommittee  was formed  to conduct the  review consisting of
members and consultants to  EPEC and liaisons from the federal agencies  that had
significant research interests in wetlands.  The Subcommittee received a  copy  of the
charge, the draft research plan, and administrative instructions prior to the review. The
Subcommittee met  once  on July 16-17, 1991  at the Corvallis Environmental Research
Laboratory.  They received briefings on the first day of the review and discussed their

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concerns and recommendations and drafted preliminary statements on the second day of
the review.  At the conclusion of the review, the chairman presented a summary of the
preliminary findings of the  Subcommittee  to  the  matrix manager of the Wetlands
Research Program.  Following the meeting, a draft report was prepared by the chairman
and reviewed by the Subcommittee via the mail.

      The Subcommittee addressed the primary questions in the charge directly, however,
there was insufficient information provided to respond to all of the secondary questions.
The Federal Agency Liaisons on the Subcommittee provided information on how WRP
=was coordinated and linked with wetlands research in other agencies.  Information on
budgets and delivery schedules was considered to be tentative, so the Subcommittee did
not attempt to evaluate their adequacy or feasibility.

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    3.  EVALUATION OF THE WETLANDS RESEARCH PROGRAM

3.1 General Evaluation

      Our overall evaluation of the directions the Wetlands Research Program (WRP) is
taking is positive, and we wish to express our strong support for implementation of the
program.   WRP  is  a relevant  and  innovative effort  to support  EPA's needs  for
information on wetlands protection, mitigation and restoration.

      The program is undergoing a logical transition from its original focus on water
quality,  cumulative impacts, and mitigation to a broader conceptual scope incorporating
a landscape perspective and modeling effort derived  from previous  work.  There is
evidence that the results of the original projects will be  applied to the new directions.
The needs of the  Office of Water and the EPA Regions have played an important role
in shaping the direction of the proposed research.  The findings of the research should
assist in dealing with such important issues as delineation of boundaries,  categorization
or classification of wetland types, and use of constructed wetlands to mitigate wetlands
loss.  The program provides for investment in an  active  technical information transfer
activity  which should continue to maintain an effective interface between research and
the regulatory role.

      We are aware that the Agency faces urgent political needs to address these issues
now, and that some important decisions will have to be based on  existing information.
We would stress,  however, the importance of allowing  this core research program tune
to pursue  longer term  objectives which can provide  information  of fundamental
importance to wetlands protection in the long run. The  demand for short-term responses
to problems hi the regulatory arena, while very real and pressing, should not detract
from  the need for a continuing and longer term research effort, as outlined in the
Research Strategy document. The research strategy is a very ambitious one in relation
to the overall level of funding allocated to WRP.  This emphasizes the need for highly
focused  effort if the objectives are to be accomplished.  With some exceptions which we
will note, the program generally has done a good job in this regard. At the same tune,
however, this  leaves little flexibility  for  undertaking short-term responses to address
immediate  needs  such as those posed by the  wetlands delineation manual and the
proposals for classifying wetland habitats, or others which may arise in the future.

      We have no specific recommendations concerning solutions to this dilemma, but we
urge the Office of Research and Development to  address it and  to take care that  an
appropriate balance be maintained.  One possible approach would be to consider providing
and sequestering additional  resources specifically  for support of short-term responses.
In any case, while the program must  continue to be responsive, this should not be done
in a way that jeopardizes achievement of its fundamental, longer term goals.

      EPA is the only federal agency with the responsibility to manage all environmental
media and the landscape function approach provides a mechanism  to place  wetland
condition in a broader environmental context - both the influence of other environments

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(the landscape) on wetlands and the influence of wetlands on other environments (for
example, water quality). But it is unrealistic to assume that the EPA Wetlands Research
Program, especially with the present and foreseeable resource limitations, could effectively
address all Agency information needs related to wetlands.  Rather, the WRP should
strategically focus on  those needs which are  particularly appropriate  to  the EPA's
regulatory responsibilities,  which  fill critical needs not well addressed by the research
programs of other agencies, and which build on EPA technical strengths.  In this context,
the focus of the program on landscape function and on risk reduction  is particularly
appropriate and is encouraged. In addition, the research programs of other agencies are
not  effectively addressing  landscape  function  and the EPA program appears to be
applying cutting-edge scientific advances in landscape ecology in the WRP. Furthermore
the  landscape approach builds on work previously carried out by  this program on
cumulative impacts.

      The proposal  to characterize  populations of  wetlands by functions is also an
innovative and potentially very important approach to developing performance standards
and design criteria for restoration and creation of wetlands and, indeed for the entire
approach to wetlands regulation and protection.  However, there are several problems
which could occur complicate such an effort and need to be considered in the strategy
document (see discussion in section 3.7).

      The  Subcommittee  commends the  WRP for its  emphasis  on  synthesis and
integration  of information relevant to  wetland regulation and management.   This
emphasis is  appropriate for EPA's research program because it meets a critical need to
base regulation on sound  science that is not  typically met through university basic
research programs.  While basic research is essential in providing the fundamental
understanding that permits prediction and extrapolation of results  from one system to
the next, a pressing need exists to bring together the results and implications of such
basic research and translate them into terms and  guidelines that are useful in the
regulatory arena.   The Subcommittee does encourage the WRP to employ the talents of
leading wetland scientists from the academic community and elsewhere through research
grants and cooperative agreements to provide additional expertise and vitality.

      The emphasis of the WRP on synthesis and integration is evident in the state-of-
the-science reviews proposed within each sub-program, in  the attempt to scale analysis
up  to the level of landscapes and regions, and  in the use of a modeling framework to
integrate and  plan research. In most cases, the proposed reviews are timely from the
perspective of the status of the science and regulatory needs. The selected areas reflect
emerging areas of basic research where sufficient information exists on which to base a
synthesis. Syntheses at this time should be instrumental in bringing current research
results to regulators and in identifying key gaps in information pertinent to regulation.
The Subcommittee recommends  caution, however,  that  the demand for short-term
regulatory research should not detract from the  long-term need to maintain a continuing
research effort, as is proposed in  the research strategy.

      While the Subcommittee's overall view, therefore, is a favorable one, we do have
a number of concerns and  comments about needs for clarification or refinement of the

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Research Strategy document which are set forth below.

3.2 Adequacy of the Research Strategy Document

      The Subcommittee felt that the  oral  presentations at the review provided far
greater clarity and justification  for  the research  approach  than did the  document,
"Wetlands Research: An Integrated Risk-Based Research Strategy." The draft document
is very abstract, redundant, and difficult to follow.  In fact, the document, as presently
constructed, leaves the impression that the research is too broad  and unfocused.

      The Subcommittee recommends that the Research Strategy document be drastically
reduced in length to eliminate repetition and to provide an incisive report that more
clearly and concisely defines the research program. Specific case examples (e.g., Big Bear)
or empirical data should be included  to explain and justify .better the  conceptual
framework of the document, thereby making it less abstract and  difficult to follow.  In
recommending that the document be rewritten, we would emphasize two points:

      1. From an editorial standpoint,  the document  needs to be shorter, clearer, and
more concise if it is to explain the program to such audiences as Agency decision makers
and program staff.

      2.   The  revision  must address  the issues outlined below.   Otherwise the
streamlined document will not be useful in guiding the program. Again, based on the
oral presentations we received, we think that WRP staff are in a  position to readily
clarify the following issues.  The  rewritten strategy should:

      a.    More clearly define the research goals and objectives.


      b.    Clarify the rationale for selection of priority wetlands types and geographic
            locations.

      c.    Assure  that  component projects  actually contribute  to  a  risk-based
            framework.

      d.    Clarify how the functions of wetland populations  (wetlands of similar type)
            will be determined; and assure that it reflects current scientific knowledge
            on wetlands processes.

      e.    Clarify concepts and language that blur the distinction between wetlands
            functions and value judgements, and assure that  the research is conducted
            in  a  way  that maintains  the  distinction  between scientific  and policy
            judgments.

      f.     Provide for precise  and consistent use of  key terminology, such as risk
            assessment, management, and reduction; effects and impacts; and stress,
            stressor, and response.

                                         8

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       g.     Clarify the relationship between WRP and EMAP.

 Each of these points is discussed briefly below.

5 3.3 Goals and Objectives

       WRP's goals and objectives are not clearly stated in the Strategy document.  For
 example, page 1 of the document describes what the research will accomplish.  Page 11
 sets forth the research objectives in somewhat different, more abstract terms.  Page 16
 outlines key deliverables in still another way.  While all these statements are related,
 they are not entirely consistent and we are concerned that they may be too diffuse.

       The Research Strategy is very ambitious in relation  to the  level of resources
 budgeted for the WRP. Unless the overall budget level can be increased, WRP will have
 to sharpen its agenda and avoid issues that are secondary or tangential to the primary
 objectives.

       We recommend a more consistent statement of WRP goals and concrete objectives
 that clearly states what the WRP  is going to set out to do in the next five years. This
 should assist in maintaining the program's focus and  avoiding pursuit  of too many
 directions.

 3.4    Geographic Priorities

       We agree  with the general wetland types  selected for the research program.
 Prairie pothole wetlands, bottomland hardwood forested wetlands and western riparian
 areas are all experiencing very serious losses, and are appropriate research topics for
WRP.  We do have several caveats, however:

       1.    The Strategy  document does not provide  clear justification for selection of
            wetland types.  This  relates to the lack of linkage between the risk-based
            strategy and the priority setting process, as discussed in Section 3.5 of our
            comments, below.  There is insufficient description of the  rationale for
            selection of these three  types, from among the numerous critical wetland
            habitats. If, for example, the selection was based on such issues as level of
            information available, budgetary considerations, logistics and relationships
            with cooperating parties, as well as on  broader based considerations of
            relative  risk reduction, the document should clearly say so.  Our concerns
            could best be  answered by addressing the issues of how the study locations
            were chosen and their relationship to the risk based strategy.

      2.    We are concerned that WRP is only studying wetland systems dominated by
            permanent surface water and/or high groundwater and by obligate wetland
            plants.  This certainly  appears  to be true for  the  characterization  and
            restoration program.  However, "drier" wetland types, for example, systems
            with near-surface saturation of 14-30 days, are among the most difficult to
            characterize and restore.

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      Scientific literature is extremely limited on ecology and restoration of these
      drier wetland types. For example, there is no discussion of these wetlands
      in EPA's  "Wetlands  Restoration and Creation" handbook. Yet,  EPA has
      frequently required extensive mitigation for seasonal emergent and forested
      wetlands.  We recommend that WRP consider broadening its perspectives
      and approaches to monitoring wetland sites to include systems that  have
      shorter  hydro-periods  and greater dominance of facultative vegetation.
      Given the current political controversy over defining jurisdictional wetlands,
      and the fact that wetlands delineation requires drawing a line across a
      continuum from wet to dry environments, scientific information that can
      enable us to understand ecological processes and interactions  along this
      gradient  could assist in clarifying policy judgments over the  long run
      concerning which areas should be included within "jurisdictional" definitions.

3.     The document is unclear as to whether coastal wetlands are in the program
      or not. On page 11, coastal wetlands are listed as a priority.  However, the
      text of the document  and oral briefings indicate they are not included.  This
      point should be clarified and justified.

      With respect to  the  presentation  made to the Subcommittee on the
      importance of coastal wetlands, we believe that an ongoing research program
      directed towards seagrass systems  should be expanded to the landscape
      level.  This would fill an  important niche not now well addressed in other
      wetlands research programs. If additional resources can be found, we would
      recommend  expanding such work within the WRP.  However,  we do not
      recommend substituting work on this topic for the other three areas already
      selected to receive priority.

4.     There is inconsistent and fragmentary discussion of the inclusion of urban
      wetlands within the WRP.  They are not  included within the discussion of
      Priority Wetland types on pages 9-10, but  an urban wetlands  project is
      included in  the text.  As we understand  it,  a limited amount of work on
      urban  wetlands has been included to address certain specific regional
      priorities.  Urban wetlands have  suffered extensive losses in many  areas
      such as San Francisco Bay, New York, and Los Angeles areas, and these are
      areas  the public wants to save  and restore.  A case can be  made for
      including  a stronger emphasis in WRP on how wetlands can be maintained
      and restored  in developed areas,  in conjunction  with the  constructed
      wetlands and water quality projects.

            We recognize that this would be at a cost to the priorities that WRP
      has identified, and the Subcommittee is not recommending that resources
      be diverted  from those efforts. We would recommend, however, that the
      rationale for including limited  work on urban wetlands be clarified, as well
      as the rationale for not making a more significant effort  there.   This
      recommendation is also related to the  following comments concerning the

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            need  to describe the relationship between the  program  priorities and
            comparative risk.

3.5  Risk-Based Framework

     The concept of developing and  applying a risk-based  strategy is a  good one.
Although the  approach may not be related to "risk" in a strict sense, i.e., involving
chance, probability, or uncertainty, the approach articulated is consistent with the SAB
"Reducing Risk" report and the Agency-wide direction articulated by Administrator Reilly.
However, it is not clear at all that a risk-based approach was rigorously applied in the
development of the WRP, either in the selection of wetland types or in the identification
of wetland functions on which research will be focused.  A manifestation of the problem
of having the risk-based framework drive the research rather than the existing research
efforts, regional concerns, or  individual scientific interests  is found in the conceptual
diagram of the risk-based strategy itself (Figure 1.1).  The flows are unidirectional from
the three component projects to the risk reduction  project.  However, as was stated in
the oral presentation on risk reduction, risk assessment should guide as well as integrate
research. Although the understanding of this need was clearer in the presentations than
in the Research Strategy, the Subcommittee recommends that there be a strong and
concerted effort to assure  that revisit and redesign  component
projects  actually  better  fit  into  the risk-based  framework  and  demonstrate  its
applicability.

      The formal development of a risk-based framework under the WRP also should be
related to and  integrated  with the ongoing  efforts within the Agency to  develop
environmental risk assessment methods (ecorisk guideline development).

3.6  Wetlands Functions

      As previously stated, we commend the program's emphasis on  synthesis and
integration.  It is important,  however, that this work be based on sound scientific
research on wetlands processes. We are concerned that the various hypothetical curves
for stress/response and time/response may be over-generalized and may prove misleading
in terms of actual or empirical experience.  It is important to recognize that  specific
wetlands functions will generate different response curves under different environmental
situations, and that aggregation may yield misleading results.

      The Subcommittee  felt that many  of the "wetland functions" were not clearly
described so as to be able to determine which processes were  going to be selected and,
more importantly, how they are going to be measured.  The concept of function versus
process (rates) needs to be cleared up also.  The importance of hydrology, geology, and
soil science does not appear to be adequately reflected in  the discussion of wetlands
functions; hydrology is the dominant and controlling factor for wetlands and the local
geology is a key factor determining hydrologic regimes and features such as  perched
water tables which can be mapped and predicted. In addition, the WRP does not appear
to include sufficient expertise in these  disciplines among its staff.
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      The presentations helped greatly in answering some of these questions, but the
document itself requires clarification.

3.7  Value Judgements

      The Subcommittee is concerned with the use of language in the document hi ways
that confuse science and value judgments. While it is the role of research to address
topics that  have been identified as being of public  concern, the ways in which the
research is conceived and potential results should be phrased hi scientific language, not
hi terms of normative judgments.  Doing so gives the false  impression of lending the
"objectivity" of science to what should be political/social decisions.  It also runs the risk
of misinterpretation by decision-makers anxious for simple answers to what are complex
issues.  Scientists should utilize terms  that are precise and amenable to evaluation
against data that could be collected by others and interpreted against scientific standards
of evidence.

      For example, the Subcommittee is uncomfortable with the use of terms such as
"high value" and "low value" wetlands, "promoters" and "demoters".  Rather,  scientists
should aim to provide  information in terms of measurable characteristics,  which then
can be  used by decision-makers  to  form value judgments.   In  order to allow this
translation to take place, it may  be  useful to think in  terms of characterizing those
wetlands functions that are "valued ecosystem components" (from Beanlands and Duinker,
1983) to which societal values can be assigned as a separate step.  Clarification of the
relationship between function  and value is essential to the success of the  Research
Strategy.

      The present discussion of "wetland function" versus "wetland value" (pp. 23-24) is
confused. For example, the document includes fish  and wildlife as  "users" who derive
value from wetlands functions.  This confuses ecological functions and societal values.
A more appropriate distinction would be to indicate  that provision of fish and wetland
habitat  is a "function", whereas recreational fishing and hunting uses reflect societal
'Values".

      To elaborate on  this point, we offer the following examples:

      1. Wetland delineation requires drawing a line across a continuum from wet to
dry environments.   Good technical information is necessary to understand  ecological
processes and interactions across the gradient, but the location of the line is, in the final
analysis, a judgment call based in part on non-technical considerations.

      2.   Administrator  Reilly  has  asked for  studies  "to identify  and develop
environmentally sound ways to classify  wetlands according to then* values and to  set
priorities for wetlands protection". This statement shows clearly both the need for good
technical  information  about 'Valued ecosystem  components"  and the  use of  this
information to assign "values" to different wetlands based on percei ed utility to society.

      3.  Landscape level analysis and management requires  (a) characterization or

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assessment  of the landscape of interest  (technical), (b) goal setting and  planning
(judgmental, with technical advice), and (c) plan implementation (engineering/technical,
with economic/social/political input).

      Scientists can  make  statements about  structure,  process, pattern etc.  in the
environment,  with emphasis on controlling processes and  functions, magnitudes of
processes, interactions of structure with function and with  controlling factors.  This
information provides the scientific basis for judgmental decisions. In contrast, judgmental
decisions are the purview of policy makers, regulators and a broad segment of the public,
who must consider other issues in addition to technical ones.

      The EPA Wetlands Research document must carefully and  explicitly separate
technical from non-technical steps in developing an approach to environmental risk
reduction.  For example, the designation of high, medium, and low classes of functions
hi the Synoptic approach described in Chapter 5, blurs the distinction between objectively
determined  functions and value" judgments about the magnitudes of these functions.
Great care  must be  taken to distinguish evaluation of the magnitude of ecological
processes  or  functions from subjective "valuation."   (Graphics shown  in  the oral
presentation were  much clearer in separating objective from judgmental steps than the
written  document).

      We stress the importance of assuring that the WRP characterize the magnitude of
functions of wetlands populations as distinct from their values to  society.  The current
plan fails to maintain this  distinction, which  could result in misuse of the findings.
There is an implied, if not explicit relationship between function and societal value.  In
most instances, the greater the magnitude of the function, the more valuable the wetland
is assumed to  be.  However, any wetland has a number of functions,  each of which may
have a different magnitude at a specific site.  To link overall value to function, therefore,
implies  a weighing of different functions, or in other words, a non-technical evaluation
of the worth of different functions in a particular setting.  We are immediately outside
the arena of science into policy, politics, and social choice.  Second, even if a wetland has
overall functions that are minimal, this does not necessarily translate into low value.  If,
for example, this is the last remnant of a particular kind of wetland in an area, or is the
only kind of wetland that can exist in the local environment, it may  have societal value
far beyond the magnitude of its ecological functions. Again, the decision to classify the
wetland as high or low value is a social choice, not objective science.

      We see no way around this kind of dilemma except the development of good
mechanisms for making social choices.  Decision steps are indispensable in wetlands
management,  but  are, in general, poorly handled.  As far as we are aware, no good
process  has been developed to allow decisions about wetlands management to be made
in a rational manner, using  the best scientific information available, and representing
fairly the societal values involved.

      The Subcommittee recommends that ORD's research address such  process because
advances there could make a significant contribution to  wetland management, and is
particularly relevant considering the emphasis given in the ORD document to landscape-

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level analysis.

      The Risk Reduction Project does involve making value judgments and setting goals.
We support this initiative, but only if the process and criteria through which values are
assigned to objectively determined wetlands function are made very explicit.  Further,
WRP should take steps to assure that individuals with background in such disciplines as
economics,  group dynamics, and conflict resolution participate in design of this work.

3.8  Consistent Terminology

      The  committee is also concerned that the WRP define its terms and use them in
precise and consistent ways.  Examples include terms such as "stress", "stressor" , and
"fringe" wetland.  Failure to define "stress", "stressor", and "dysfunctional" and to use the
terms unambiguously is not unique to this document but is common in the literature.
References made to "risk assessment," "risk, management" and "risk reduction"  do not
uniformly follow terminology used in the  Agency and create  some confusion.  For this
reason, it is imperative that the document be clear on its use of these terms.

      In the  case  of "fringe"  wetland, the WRP staff should  note that its  use is
inconsistent with an established use in the  literature.  The WRP uses "fringe" in referring
to "riverine" wetlands.  Brinson (1990) distinguishes "fringe" from  "riverine",  and uses
"fringe" to refer to lake  shore and tidal wetlands  where the  flow of water is two-
directional.

3.9 Coordination

      We believe that the WRP has made very good efforts  to coordinate its research
activities with those of the Fish and Wildlife Service, the Corps of Engineers, and the
Forest Service. Any important wetlands studies in NOAA should be considered as well,
if this has  not yet been done.

      With respect to internal ORD coordination, we were concerned whether there was
adequate coordination between WRP and the EMAP wetlands component, particularly on
the topic of indicator development. The rationale for somewhat different approaches to
wetlands indicators in the two programs was presented to us, but we were not entirely
persuaded that the need for parallel approaches had been carefully examined or justified.
In view of the relatively limited resources for the WRP, we recommend that, if this has
not yet been accomplished, an in-depth review of relationships between the  two programs
be done with the objective of maximizing coordination.  The relationships between the
two programs and the information that each program will provide to the other should
be more clearly reflected in the final Wetlands Research Strategy.
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